Urgent Update: Soundboard Technology, Determining it is Robocall

14th November 2016

Friends and clients, just hours ago the FTC published its finalized new staff opinion letter regarding avatar or "soundboard" technology. The letter is signed by the FTC's Lois Greisman, Associate Director, Division of Marketing Practices. The letter can be found here and should be immediately reviewed by any company who uses or offers avatar ...

Don't mess up your web consent forms!

7th November 2016

On November 1, 2016, the FTC announced a new settlement with a group of companies known by the brand, "Consumer Education Group" operating primarily from Colorado and California. Most of the 2.34 million dollar fine was suspended due to the defendants' inability to pay, although they were required to come up with $100,000 as a civil penalty. ...

Last Week's Call Recording Settlement is a Stern Reminder

1st November 2016

A number of our clients have recently asked us about state call recording laws and best practices. Just last week, Wyndham Hotels and Resorts agreed to pay $7.3 million to settle a California call recording class action filed by plaintiff Joyce Roberts. The lawsuit alleges that in 2012, Wyndham routed certain reservations calls to an outside ...

FTC hikes fines, FCC hikes fees

8th September 2016

Effective August 1, 2016, the FTC raised its civil penalty from $16,000 to a staggering $40,000. This is a per violation penalty, and adds up quickly. Among other violations, the new fine applies to any violation of its Telemarketing Sales Rule, or any other act which it defines as an "unfair or deceptive act or practice." Therefore, the ...

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Last Week's Call Recording Settlement is a Stern Reminder

FTC hikes fines, FCC hikes fees

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