How Courts Are Interpreting DC Circ. Autodial Ruling

By Cory Eichhorn and Annelise Del Rivero (May 29, 2018, 1:39 PM EDT) -- On March 16, 2018, the U.S. Court of Appeals for the District of Columbia Circuit rendered a long-awaited opinion in ACA International v. Federal Communications Commission, which addressed various components of the Telephone Consumer Protection Act. The case arose out of ACA International and a number of regulated entities' challenge to a 2015 FCC order that sought, among other things, to clarify certain aspects of the TCPA's prohibition against using automatic dialing systems to make certain phone calls. While the opinion addressed a variety of issues as it related to the 2015 order, this article addresses the practical impact of the D.C. Circuit's ruling as it relates to what automated dialing equipment is subject to the TCPA's restrictions on making calls without consent to do so....

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