FCC Seeks Comment On New Autodialer Definition

In March 2018, the United States Court of Appeals for the D.C. Circuit issued a decision vacating portions of the Federal Communications Commission's ("FCC") 2015 Order. This decision will have a profound impact on how the Telephone Consumer Protect Act ("TCPA") and its implementing regulations will be both interpreted and revisited in the months to come. In the aftermath of the decision, the FCC has gone back to the drawing board to, among other things, address the definition of autodialer or automatic telephone dialing system ("ATDS") within the meaning of the statute. On May 14, 2018, the FCC issued a public notice seeking comment on the autodialer definition and several other TCPA-related issues.