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FCC “One-to-One Rule” Case: States File Amicus Brief in Support of Rehearing

Last month, we discussed the motion filed by the National Consumers League and four small business owners to intervene in the case of Insurance Marketing Coalition Limited. v. FCC. This motion aimed to challenge the Eleventh...more

2024 Consumer Financial Services 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

Eleventh Circuit Re-Opens TCPA “Lead Generator Loophole” and Signals Further Erosion of Judicial Deference to Administrative Rules

In Insurance Marketing Coalition Ltd. v. FCC, ‎— F.4th —-, 2025 WL 289152 (11th Cir. Jan. 24, 2025)‎, the U.S. Court of Appeals for the Eleventh Circuit came to the rescue of the lead generation industry, striking down new...more

Eleventh Circuit Vacates FCC’s One-to-One Consent Rule; FCC Issues Stay

In a previous post, we discussed the oral arguments held on December 18, 2024, by the U.S. Court of Appeals for the Eleventh Circuit in the case of Insurance Marketing Coalition Limited (IMC) v. Federal Communications...more

TCPA Trends: 2024 Year-in-Review and 2025 Predictions — The Consumer Finance Podcast [Audio]

In this episode of The Consumer Finance Podcast, host Chris Willis is joined by Partners Virginia Flynn and Chad Fuller for the first edition of a special year-in-review series. Together, they provide a comprehensive analysis...more

Eleventh Circuit Judges Question FCC’s One-to-One Consent Rule

On December 18, the U.S. Court of Appeals for the Eleventh Circuit held oral arguments in Insurance Marketing Coalition Limited (IMC) v. Federal Communication Commission (FCC), which challenges the FCC’s December 2023 order...more

California Governor Signs Legislation Impacting Health Care Claim Reimbursement and DMHC Requests for Records

On September 27, California Governor Gavin Newsom signed into law two bills that will impact health care service plans and insurers in the state....more

9th Circ. Clarifies ERISA Preemption for Healthcare Industry

On May 31, the U.S. Court of Appeals for the Ninth Circuit published an opinion in Bristol SL Holdings Inc. v. Cigna Health and Life Insurance Co., which has significant implications for the healthcare industry. Originally...more

White House Finalizes New Mental Health Parity Rule

The White House has finalized the new Mental Health Parity rule, which focuses on increasing access to mental health/substance use disorder treatment through nonquantitative treatment limitations (NQTL) data and reporting,...more

Fifth Circuit Affirms Vacatur of Insurer-Friendly "No Surprises Act" Regulations

In a win for health care providers, on August 2, the Fifth Circuit Court of Appeals affirmed a Texas federal judge’s grant of summary judgment in favor of the Texas Medical Association and LifeNet, an air ambulance company,...more

Ninth Circuit Court of Appeals Restricts Out-of-Network Providers’ Ability to Avoid ERISA Preemption of State Law Claims

On May 31, the Ninth Circuit Court of Appeals published an opinion in Bristol SL Holdings, Inc. v. Cigna Health and Life Insurance Company, which has significant implications for the healthcare industry, most notably by...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

July 2023 Class Action Blog Summary

What are the most significant judicial decisions affecting class action litigation, and how might they impact your business?...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

The Ninth Circuit Reinforces Narrow Interpretation of ATDS under Borden Holding System Must Generate Random or Sequential...

On April 13, the Ninth Circuit issued an opinion affirming a district court’s summary judgment order on the grounds that under Borden v. eFinancial, LLC, discussed here, to qualify as an automatic telephone dialing system...more

Take Two: En Banc Eleventh Circuit to Address Whether a Single Text Message Can Confer Standing Under TCPA

As discussed here, on July 27, 2022, the Eleventh Circuit Court of Appeals sua sponte vacated the district court’s approval of a $35 million class-action settlement in Drazen and Godaddy.com, LLC (Godaddy) v. Pinto. Although...more

Ninth Circuit Reaffirms Borden Interpretation of ATDS

Do the text messages that Facebook sends to your phone with birthday reminders violate the Telephone Consumer Protection Act (TCPA)? According to the Ninth Circuit in a recent decision, the answer is no because users provided...more

Federal Court Finds Text Messages From a Chatbot Do Not Constitute a Prerecorded or Artificial Voice Under the TCPA

Do text messages sent by a chatbot fall within the provisions of the Telephone Consumer Protection Act (TCPA) prohibiting unsolicited calls made using an “artificial or prerecorded voice?” According to the United States...more

Ninth Circuit Reverses Dismissal of Lawsuit Challenging Unwanted Business Texts Holding TCPA Protection Extends to Business...

On October 12, the Ninth Circuit issued a decision, reversing the dismissal of a lawsuit on the grounds that the Telephone Consumer Protection Act (TCPA) does not extend to unwanted business texts. In Chennette v. Porch.com,...more

AAA Issues Amended Commercial Arbitration Rules

Effective September 1, the American Arbitration Association (AAA) has finally updated its Commercial Rules and Mediation Procedures, concluding a two-year internal review. The amendments provide greater procedural discretion...more

Anti-Robocall Litigation Task Force Targets Facilitators of Foreign Illegal Robocalls

Escalating efforts to crack down on illegal robocalls, state attorneys general announced on August 2 that they have established a nationwide Anti-Robocall Litigation Task Force. The task force comprises attorneys general from...more

Eleventh Circuit Requires Standing for All Class-Action Members, Decertifying TCPA Class Settlement

Class-action plaintiffs do not get a free pass on constitutional standing requirements, as the Eleventh Circuit Court of Appeals reminded litigants sua sponte in Drazen and Godaddy.com, LLC v. Pinto last week when it vacated...more

TCPA: Text Messages Still Hot-Button Issue After Furniture Companies Resolve Class for Millions

On July 6, the U.S. District Court for the Middle District of Florida granted final approval of a multimillion-dollar, class-action settlement in Parker v. Stoneledge Furniture, LLC, et al., No. 21-740 (M.D. Fla.) to resolve...more

California Dealership Resolves Telemarketing Prerecorded Message TCPA Class for $2.5M

In late June 2022, the U.S. District Court for the Central District of California gave final approval for a $2.5 million class-action settlement in Johnson v. Moss Brothers Auto Group to resolve claims brought against a motor...more

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