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California Attorney General Sponsors Bill Banning Credit Reporting of Medical Debt

On April 2, the California Senate Judicial Committee passed Senate Bill 1061. The bill seeks to prevent health care providers and contracted collection agencies from providing information about patients’ medical debt to...more

New York Federal District Court Holds the Reasonableness of Investigation Into Alleged Identity Theft is a Factual Question under...

A U.S. district court in the Eastern District of New York recently denied a motion for summary judgment filed by a credit card issuer because the plaintiff alleged identity theft and a reasonable factfinder could determine...more

New TCPA Rules: Revoking Consent to Robocalls and Robotexts

On February 15, the Federal Communications Commission (FCC) approved amendments to the rules and regulations implementing the Telephone Consumer Protection Act (TCPA). The adopted Report and Order and Further Notice of...more

CFPB Reports on Student Borrowers’ Experiences During Return to Loan Repayment

As federal student loan repayments resume after a three-year pause due to the COVID-19 pandemic, the Consumer Financial Protection Bureau (CFPB) published an Issue Spotlight on student borrowers’ experiences, using consumer...more

Pennsylvania District Court Finds No Personal Liability Under the TCPA

In Perrong v. Chase Data Corp., et al., a court in the Eastern District of Pennsylvania recently ruled that no personal liability attaches to the owner of a company for Telephone Consumer Protection Act (TCPA) violations....more

FCC Rules AI-Generated Voices Fall Under TCPA Restrictions

Yesterday, the Federal Communications Commission (FCC) issued a unanimous ruling that the Telephone Consumer Protection Act’s (TCPA) restrictions on the use of “artificial or prerecorded voices” apply to AI technology that...more

Consumer Financial Services 2023 Year in Review and A Look Ahead

We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more

Pa. Autodialer Decision Has Turned TCPA Tides in 3rd Circ.

The U.S. Supreme Court's 2021 decision in Facebook Inc. v. Duguid resolved a long-standing circuit split over the definition of an automatic telephone dialing system, or ATDS, under the Telephone Consumer Protection...more

Magistrate Judge Recommends No FCRA Liability for Accurately Reporting a Publicly Available Conviction that was Expunged

A magistrate judge in the Northern District of Georgia recently recommended granting summary judgment in a Fair Credit Reporting Act (FCRA) case in favor of a background reporting company on the grounds that a report given...more

In the Ninth Circuit Precision is Required in an Offer of Judgment

A U.S. District Court in the Southern District of California recently held that a Federal Rule of Civil Procedure 68 offer of judgment must clearly state that attorneys’ fees and costs are limited or waived, as Arvest Central...more

Arizona Federal District Court Holds MMS’s Are Not Prerecorded Messages Under the TCPA Unless They Play Automatically

A district court in the District of Arizona granted a motion to dismiss in a Telephone Consumer Protection Act (TCPA) case on the basis that multimedia messaging service (MMS) texts do not constitute prerecorded messages...more

Undated Model Debt Violation Notice Does Not Violate the FDCPA

Last week, a district court in Nevada held that an undated, model form debt validation notice does not violate the Fair Debt Collection Practices Act (FDCPA). In Bergida v. PlusFour, Inc., the defendant sent a debt validation...more

Letter Vendor Claim Remanded to State Court for Lack of Standing

In Moore v. Merchants & Medical Credit Corp., Inc., the plaintiff initiated litigation in state court alleging a violation of the Fair Debt Collection Practices Act (FDCPA) based on the defendant’s use of a letter vendor to...more

Pennsylvania Federal Court Declines to Dismiss Case Involving Political Message Allowing TCPA Claim Based on Prerecorded Message...

In Perrong v. Bradford et al, the plaintiff alleged that the defendant, an elected official, violated the Telephone Consumer Protection Act (TCPA) by calling his residential phone using a prerecorded message and an automatic...more

Parking Company Ordered to Pay $106,000 in Fines for Alleged Violations of the Colorado Fair Debt Collection Practices Act

Parking Revenue Recovery Services, Inc. (PRRS), a collection company, was accused of violating the Colorado Fair Debt Collection Practices Act (CFDCPA) by allegedly illegally collecting or attempting to collect on parking...more

Ninth Circuit Affirms Dismissal of TCPA Case Involving Text Messages Holding “Prerecorded Voice Messages” Require Audible...

On August 8, a unanimous panel of the Ninth Circuit issued a decision affirming a district court’s partial dismissal judgment entered in Trim v. Reward Zone USA LLC, holding that text messages did not use prerecorded voices...more

California Federal Court Denied Class Certification in TCPA Case Where Plaintiff Arguably Requested Calls

In Wiley v. American Financial Network, Inc., a district court judge in the Central District of California denied a motion for class certification in a Telephone Consumer Protection Act (TCPA) case, finding the defendant...more

California Court of Appeal Affirms Grant of Summary Judgment Against Health Care Provider in Win for Managed Care Payors and...

The California Court of Appeal, in a major win for managed care payors and claims administrators, affirmed a lower court decision granting summary judgment in favor of United Healthcare (United), finding that United did not...more

Case Update: Tenth Circuit Denies Petitions for Rehearing in Decision Requiring Substantial Changes to Health Plan Denial Letters

As discussed here, D.K. et al. v. United Behavioral Health et al. is a case that has been carefully watched in the health benefits space for its impact on what health plan administrators must include in adverse benefit...more

Eleventh Circuit Reverses Course and Holds a Single Text Message Constitutes TCPA Standing

The Eleventh Circuit has now joined seven other circuits in holding that receipt of unwanted text messages constitutes concrete injury for standing. On July 24, the Eleventh Circuit issued an en banc decision in Drazen v....more

First Post-Facebook Appeal Makes Its Way to Supreme Court

More than two years after the Supreme Court released its ruling in Facebook v. Duguid, confirming the meaning of automatic telephone dialing systems (ATDS) under the Telephone Consumer Protection Act (TCPA), a plaintiff has...more

FCC Proposes New Rules for Revocation under the TCPA

On June 29, 2023, the Federal Communications Commission (FCC or Commission) issued a notice of proposed rulemaking clarifying how consumers may revoke consent to receive calls or texts under the Telephone Consumer Protection...more

Ohio Federal Court Finds Plaintiff Has Standing in TCPA Case Over Messages Left With Wrong Recipient

On June 28, a magistrate judge in the U.S. District Court for the Southern District of Ohio issued a report recommending that the defendant’s motion to dismiss be denied because the plaintiff had standing under the Telephone...more

Ninth Circuit Holds Phone Owner Suffers Concrete Injury From Unsolicited Telemarketing Texts Even if Not “Actual User” of the...

On June 30, the Ninth Circuit Court of Appeals held that the plaintiff’s claims that she received five text messages to a cell number that she had placed on the National Do-Not-Call Registry satisfied the demands of Article...more

FTC Seeks Public Input on Joint Consumer Protection Efforts with State Attorneys General

On June 12, the Federal Trade Commission (FTC or Commission) published a request for public comment seeking comments and suggestions on effective coordination efforts with state attorneys general nationwide to help educate...more

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