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Vicarious Liability Telemarketing

Klein Moynihan Turco LLP

TCPA Vicarious Liability - June 6, 2025

Our readers are well aware of the fact that companies can be held vicariously liable for Telephone Consumer Protection Act (“TCPA”) violations. However, a recent decision from an Illinois federal court highlights the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

The Telephone Consumer Protection Act and Sales Agents: The Dangers of the ‘Canary Trap’

The Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, was enacted in 1991 “to protect the privacy interests of residential telephone subscribers,” according to the act’s legislative history. The TCPA provides for a...more

Klein Moynihan Turco LLP

TCPA Vicarious Liability

An Illinois federal district court judge recently held that State Farm Mutual Automobile Insurance Company (“State Farm”) may be vicariously liable for alleged Telephone Consumer Protection Act (“TCPA”) violations. In Nater...more

Faegre Drinker Biddle & Reath LLP

Texas District Court Joins the Third, Sixth, and Eleventh Circuit Courts of Appeal, Permitting a Private Right of Action for...

The Northern District of Texas, in Powers v. One Technologies, LLC, joined its sister courts and the Third, Sixth, and Eleventh Circuit Courts of Appeal to hold that 47 C.F.R. § 64.1200(d), which prohibits certain...more

Benesch

Direct Energy Defeats TCPA Claim: No Liability for Unknown Telemarketer’s Calls

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With all the talk of the Supreme Court’s decision in AAPC, it’s upcoming decision in Facebook, and all the other currently hot items-of-the-year in TCPA litigation (Creasy, etc.), it can be easy to skip past decisions that...more

Womble Bond Dickinson

A Pair of Federal Courts Find No Vicarious Liability Under the TCPA

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Companies that rely on third parties to market products could face legal exposure under the Telephone Consumer Protection Act (TCPA) when those third-party agents call, text or fax consumers without the requisite consent....more

Faegre Drinker Biddle & Reath LLP

District of Nevada Applies Agency Principles to TCPA Suit Against Messaging Platform and Consumer-Info Company, Dismisses Claims

Last week, the District of Nevada contributed to a growing consensus among Ninth Circuit district courts that TCPA liability generally does not extend to companies that produce equipment used to place unlawful calls—such as...more

Faegre Drinker Biddle & Reath LLP

Seventh Circuit Remands $280 Million TCPA Penalty Against DISH Network, LLC

The Seventh Circuit recently issued an opinion with significant implications for defendants evaluating the prospects for due process challenges to awards of statutory damages under the TCPA, as well as defendants facing...more

BCLP

Lead Generation and the TCPA: How to Protect Your Company from Downstream Bad Actors

BCLP on

Many businesses, including retailers, rely on inbound lead generators to identify prospective customers for telephone or text-based direct marketing campaigns. Sourcing inbound leads from a variety of providers allows firms...more

Foley & Lardner LLP

Seventh Circuit Weighs in on Vicarious Liability Under TCPA

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Last month, the United States Court of Appeals for the Seventh Circuit clarified the application of common-law vicarious liability principles to TCPA class actions in Warciak v. Subway Restaurants, Inc., 2020 WL 559105 (7th...more

Womble Bond Dickinson

Cruise Line Sails into Sea of TCPA Liability from Vendor’s Use of Soundboard Tech

Womble Bond Dickinson on

New communications technologies are being adopted at a rapid pace by industry.  This has led to the emergence of legal questions over whether this new technology is regulated by the TCPA.  One such question, which has seen...more

Womble Bond Dickinson

Security Company Found Vicariously Liable for TCPA Violations Committed by Lead Seller

Womble Bond Dickinson on

The realm of lead generation can present a minefield of TCPA risks. The recent order granting summary judgment in Braver v. NorthStar Alarm Systems, LLC, No. CIV-17-0383, 2019 WL 3208651 (W.D. Ok. Jul. 15, 2019) illustrates...more

Faegre Drinker Biddle & Reath LLP

Court Grants Plaintiff’s Motion for Summary Judgment on Vicarious Liability Issues

The Western District of Oklahoma recently granted a plaintiff’s motion for summary judgment against NorthStar Alarm Services, LLC (“NorthStar”) in a certified class action. The court held, in part, that NorthStar was...more

Eversheds Sutherland (US) LLP

Who’s calling? Standards for third-party liability under the TCPA

Companies that market products through third-party agents or distributors face a particular risk under the Telephone Consumer Protection Act (TCPA) when their agents call, text or fax consumers without obtaining the necessary...more

Kilpatrick

Fourth Circuit finds manufacturers not vicariously liable for retailers’ TCPA violations

Kilpatrick on

Takeaway: A recent Fourth Circuit decision finding that UTC and Honeywell, manufacturers of home-security systems, could not be held vicariously liable for calls by downstream retailers in violation of the Telephone Consumer...more

Troutman Pepper Locke

Fourth Circuit Rejects Vicarious Liability Theory Under the TCPA

Troutman Pepper Locke on

The Fourth Circuit dealt another blow to plaintiffs trying to drum up vicarious liability under the Telephone Consumer Protection Act (“TCPA”). See Hogdin v. UTC Fire & Sec. Americas Corp. Inc., 2018 WL 1308605 (4th Cir. Mar....more

Proskauer - California Employment Law

California Employment Law Notes - September 2017

Jobseeker Website May Be Compelled To Disclose Identity Of Anonymous Posters Who Criticized Employer - ZL Technologies, Inc. v. Does 1-7, 13 Cal. App. 5th 603 (2017) - ZL Technologies brought suit, alleging libel per se and...more

Kilpatrick

Ninth Circuit Declines to Hold Seller Vicariously Liable for Third-Party Telemarketer’s TCPA Violations

Kilpatrick on

Takeaway: Decisions addressing a seller’s exposure to vicarious liability for calls placed by a third-party telemarketer in violation of the Telephone Consumer Protection Act (“TCPA”) offer little predictability or guidance....more

Smith Debnam Narron Drake Saintsing & Myers,...

Guest Post: District Court Rejects Vicarious Liability Claims under the TCPA

A Michigan district court recently weighed in on the availability of vicarious liability for violations of the Telephone Consumer Protection Act (the “TCPA”). In Kern v. VIP Travel Servs., the plaintiffs received several...more

Ballard Spahr LLP

Dish Network Liable for $61 Million in Treble Damages for Service Provider's TCPA Violations

Ballard Spahr LLP on

A recent federal court ruling provides a potent reminder that companies can be held liable for consumer protection law violations committed by third-party vendors—and underscores the importance of maintaining strong vendor...more

Kelley Drye & Warren LLP

Indiana Amends Telemarketing Law, Bringing New Disclosure Requirements and DNC Vicarious Liability

Last month, the Indiana Governor signed into law House Bill No. 1444, which amends Indiana’s “do not call” statute and extends liability beyond the telephone solicitor, to individuals or entities that “directly or indirectly...more

K&L Gates LLP

Court Rejects TCPA Claims Based on Theory of Third-Party Liability

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The U.S. District Court for the Northern District of West Virginia recently granted summary judgment for the defendant alarm manufacturers in In re Monitronics International, Inc. Telephone Consumer Protection Act Litigation...more

Morrison & Foerster LLP - Class Dismissed

No Capacity and No Liability: Court Rules Dialing System Is Not Subject to TCPA and Verizon Is Not Vicariously Liable

In its July 2015 declaratory ruling, the FCC significantly broadened the TCPA’s definition of an automatic telephone dialing system (ATDS) to encompass not only equipment with the “present ability to dial randomly or...more

Benesch

UTC Fire & Security Obtains Summary Judgment In Putative TCPA Class Action

Benesch on

The Telephone Consumer Protection Act, 47 U.S.C. § 227 (“TCPA”), prohibits initiating a telephone call using a prerecorded voice to wireless or residential telephone numbers unless the called party consents to receiving the...more

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