The latest episode of Full Spectrum’s Inside the TCPA series takes a closer look at shifting strategies to provide effective enforcement of TCPA violations. Unlike TCPA actions of the past, which focused primarily on the entity that is placing the call, these new TCPA actions rely upon new approaches to enforcement, involving both new targets and new enforcers. We discuss how the government (importantly, not just the FCC) is looking “up the chain” in enforcement matters to target service providers who allegedly assist unlawful robocalling and spoofing practices. The theories used are different and involve varying degrees of allegedly culpable conduct, but the significance is in WHO the government is targeting, and HOW the government is seeking to modify behavior. If this approach continues, service providers may face new risks and may need new compliance strategies.
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