On March 27, 2014, the FCC granted, in part, a petition for
expedited declaratory ruling filed by the Cargo Airline Association
("CAA"). (The FCC's CAA Order can be found
here.) In its petition, the CAA asked the FCC: (1) to clarify
that package delivery companies can rely upon representations from
senders that the package recipient consents to receiving autodialed
and prerecorded calls to a wireless telephone number for purposes
of notifications regarding shipment of the package; (2) in the
alternative, to declare that package delivery notifications are
exempt from the TCPA's requirement to obtain prior express
consent before making autodialed or prerecorded calls to a wireless
telephone number. In support of its second request, CAA proposed
conditions that it asserted would protect consumer's privacy
interests. While the FCC declined to clarify the consumer consent
requirement in this context, the agency relied on its section
227(b)(2)(C) authority (which allows the
