TCPA Plaintiff Richard Zelma Ordered to Explain Quotes Which Don’t Exist

In a July 14th decision, a federal judge in New Jersey ordered pro se litigant Richard Zelma to explain why his brief in a TCPA case contained numerous quotes that did not exist in the actual court decisions he cited. Zelma v. Wonder Group, Inc, No. 25cv3232, Lexis 135885, (U.S. Dist. N.J July 14, 2025). […]

What the FTC thinks “clear and conspicuous” means for TSR enforcement

The Telemarketing Sales Rule (“TSR”) and Telephone Consumer Protection Act (“TCPA”) both require various disclosures to consumers, either during calls or texts, like the price of goods purchased, or before, e.g. that the consumer is consenting to be contacted by a business. These disclosures are required to be “clear and conspicuous”, but that standard is […]

Court Rules Serial Plaintiff Cannot Act Both As Plaintiff and Class Counsel

In Todd C. Bank v. Dimension Service Corporation, the judge considered Plaintiff Todd C. Bank’s motion to dismiss several affirmative defenses brought by the Defendant in response to Bank’s TCPA class action. Bank v. Dimension Serve. Corp., No. 1:23-cv-2467, 2023 U.S. Dist. LEXIS 230814 (E.D.N.Y. Dec. 29, 2023). Defendant argued that “the putative class should […]

Which Law Applies when an Area Code Does Not Match the Call Recipient’s Location?

For many years, we have advised our clients to comply with the most restrictive call monitoring disclosure laws (all-party consent) because area code does not determine location in the era widespread mobile phone use. Thus, even if a telephone number has a Missouri area code (which is a one-party consent state), a plaintiff could, and […]

Federal Trade Commission 2023 Fiscal Year “Do-not-call” Registry Data

The Federal Trade Commission has released its 2023 fiscal year “do-not-call” registry data. See https://www.ftc.gov/news-events/news/press-releases/2023/11/ftc-releases-annual-do-not-call-registry-data-book-showing-consumer-complaints-continued-decrease. It notes consumer “do-not-call” and robocall complaints have decreased to a five-year low. The list now contains 249 million phone numbers, up from 246.8 million last year. Almost 2,000 organizations pay for full access to the list, while almost 8,000 […]

Plaintiffs at it Again with Silly Opt-Out Language

A court has ordered arbitration in a case brought by a plaintiff who replied “S T O P” with spaces between each letter instead of “STOP” with no spaces, purportedly to opt out of text messages from the defendant. Johnson v. Whaleco, Inc., No. 5:23-cv-00403 (M.D. Fla. Sept. 27, 2023). The court ordered arbitration because […]