On March 16, 2018, the U.S. Court of Appeals for the D.C. Circuit released its hotly anticipated decision in ACA Int’l v. FCC. The decision—impacting a wide range of industries (including financial services, retail and healthcare)—limited the FCC’s overly expansive definition of “automatic telephone dialing system” (ATDS) and vacated its ruling on reassigned telephone numbers, but declined to set aside other rulings governing calls and texts to consumers.
In the aftermath of this decision and immediately following the FCC’s Open Commission meeting, Manatt hosted a webinar dissecting the ruling and the most crucial takeaways. Topics covered included:
- Key aspects of the ruling, including those related to the definition of an ATDS; reassigned telephone numbers; revocation of consent; and the exigent healthcare exemption
- Practical guidance to companies about compliance in the wake of the D.C. Circuit’s decision, such as possible changes to consumer agreements
- General litigation strategies for companies involved in Telephone Consumer Protection Act (TCPA) litigation
- What’s next in the ever-changing TCPA space, including key insights from the FCC’s Open Commission meeting on March 22
Christine M. Reilly
Diana L. Eisner
Kristin E. Haule
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