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June 18, 2015

By: Julia B. Strickland, Stephen J. Newman, Brian C. Frontino

On June 18, 2015, the Federal Communications Commission (“FCC”) voted on 21 petitions relating to the Telephone Consumer Protection Act, 47 U.S.C. § 227, et seq. (“TCPA”).  Of note, the petitions sought comment and clarification on three issues:  (1) the definition of an automatic telephone dialing system (“ATDS”); (2) the applicability of the TCPA to calls made to recycled cellular telephone numbers, commonly referred to as “wrong party calls;” and (3) whether and in what manner consent may be revoked.  While the FCC also provided an exemption for certain calls, such as fraud alerts, unfortunately, based on the FCC’s statements from the June 18th open meeting, the FCC’s ruling will make it even more difficult for businesses to comply with the TCPA.  The content of this Stroock Special Bulletin is based upon the FCC’s oral recitation of its ruling at the June 18th open meeting; we are awaiting the written ruling.

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