Comments Filed in Reassigned Numbers and Post-ACA International Proceedings

Two important TCPA proceedings are underway at the FCC. The first proceeding addresses the potential creation of a reassigned number database and the second proceeding involves a host of key issues in the wake of the D.C. Circuit ruling in ACA International v. Federal Communications Commission, No. 15-1211 (D.C. Cir. March. 16, 2018), including reassigned number liability, revocation of consent and the definition of an “automatic telephone dialing system.” Cf. 47 U.S. Code § 227(a)(1).

Drinker Biddle filed comments on behalf of the Retail Industry Leaders Association (“RILA”), a leading trade association for the retail industry, addressing a potential reassigned number database with an accompanying safe harbor for liability, which were covered by Law360 here. RILA’s comments urged the FCC to establish a comprehensive database of reassigned numbers along with a safe harbor for companies that make use of the registry. More than forty comments were filed to the docket by industry participants, compliance vendors, advocacy groups, and carriers. Several other “express comments” were filed by members of the public. Reply comments are due on July 9th.

Given its significance, the second proceeding drew comments from more than sixty interested parties. Drinker Biddle filed comments on behalf of RILA, National Opinion Research Center (NORC) at the University of Chicago, and International Pharmaceutical & Medical Device Privacy Consortium. Reply comments are due on June 28th.

Drinker Biddle’s TCPA team will continue to closely monitor these important proceedings as they move forward.

Michael P. Daly

About the Author: Michael P. Daly

Mike Daly has spent two decades defending, counseling and championing clients that interact with consumers. His practice focuses on defending class actions, handling critical motions and appeals, and maximizing the defensibility of marketing and enforceability of contracts. Clients large and small have trusted him to protect their businesses, budgets and brands in complex cases across the country.

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