Happy Halloween TCPA-landers!

I’ve dug into some of the data available from the good folks at Web Recon and what I’ve found is down right *scary*. All tricks, no treats to be found, here unfortunately.

First, TCPA filings are up over 40% year to date. Indeed, the TCPA is now officially obeying Moore’s Law and doubling every two years. This year we’re on track to scrape 5,000 filings. If the trend continues we’ll be at 7,400 filings next year and flirting with 10k by the end of 2018.

Notably, we’ve already seen as many TCPA filings through the end of September (3,712) as all of last year. Exciting.  And there were 449 TCPA suits filed in September, 2016 alone. Yikes!

But the truly *terrifying* part is the pace of TCPA class action filings. They’re exploding—up 80% YTD! There have already been 767 class action filings this year compared with 585 for all of last year.

The FCC is obviously to blame here. Prior to the Omnibus ruling in 2015 TCPA class actions were filed at an average of about 20.6 per month. Since the Omnibus they’ve more than doubled to 73.4 per month. Take a look:

Indeed, there were as many class action suits filed July-Sept., 2016 as there were the entire year preceding the Omnibus. And there were 119 TCPA class action suits filed in September, 2016 alone. *Insert ear-splitting scream here.*