Comments due on FCC TCPA request for comment

The Consumer and Governmental Affairs Bureau of the Federal Communications Commission has published [83 FR 26284] a notice requesting comment on issues related to interpretation and implementation of the Telephone Consumer Protection Act (TCPA) following the recent decision of the U.S. Court of Appeals for the District of Columbia in ACA International v. FCC:

• what constitutes an "automatic telephone dialing system";
• how to treat calls to reassigned wireless numbers; and
• how a called party may revoke prior express consent to receive robocalls under the TCPA.

The Commission's prior interpretations on those three issues were voided by the Court. The notice is a summary of the Commission's Public Notice released on May 14, 2018. Comments are due on June 13, and reply comments by June 28, 2018.