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ARTICLE · 23 FEBRUARY 2024

FCC: AI-Generated Robocalls Illegal Under The TCPA

Cooley LLP
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In a unanimous, bipartisan decision, the Federal Communications Commission (FCC) has issued a declaratory ruling to confirm that artificial intelligence-generated voices...

United StatesMedia, Telecoms, IT, Entertainment
Robert McDowell
Robert McDowell
Scott Dailard
Scott Dailard
Christy Burrow
Christy Burrow
Henry Wendel
Henry Wendel
J.G. Harrington
J.G. Harrington
Author LinkedIn connections

In a unanimous, bipartisan decision, the Federal Communications Commission (FCC) has issued a declaratory ruling to confirm that artificial intelligence-generated voices are "artificial" under the Telephone Consumer Protection Act (TCPA). The FCC's decision comes on the heels of an FCC cease-and-desist letter issued to a company that originated robocalls to New Hampshire presidential primary voters using an AI-generated voice that sounded like President Joe Biden, and just a week after FCC Chairwoman Jessica Rosenworcel issued a press release saying she had proposed to "make AI voice-generated robocalls illegal."

FCC's AI inquiry

The TCPA protects consumers from unwanted calls made "using an artificial or prerecorded voice to deliver a message without the prior express consent of the called party" unless an exemption applies. Recognizing that AI could be used to protect against or make illegal calls, the FCC opened an inquiry in November 2023 on how AI

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