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Telephone and Texting Compliance News — April 2025

We are pleased to present our latest edition of Telephone and Texting Compliance News, providing insights and news related to the Telephone Consumer Protection Act (TCPA). In this month’s Regulatory Update, we cover the FCC’s proposal to close the caller ID authentication gap on non-IP networks. The FCC’s new Notice of Proposed Rulemaking (NPRM) outlines criteria for evaluating whether non-IP authentication standards are “developed,” “reasonably available,” and “effective,” and tentatively identifies two standards that meet these criteria. The FCC proposes ending the implementation extension for providers using non-IP technology, requiring adoption of an approved standard and certification in the Robocall Mitigation Database. A two-year compliance deadline is proposed. Comments are due 30 to 60 days after the Federal Register publication.

In our Litigation Update, we explore two recent TCPA decisions. The Eleventh Circuit denied a motion to intervene in the Insurance Marketing Coalition v. FCC case, finding it untimely under the Rule 15(d) and effectively ending the challenge to the FCC’s one-to-one consent rule. In a separate case, the Tenth Circuit affirmed that robocalls made by the City of Albuquerque during the COVID-19 pandemic qualified for the TCPA’s emergency purposes exception, emphasizing their informational nature and connection to public health efforts.

If you have suggestions for topics you’d like us to feature in this newsletter, or any questions about the content in this issue, please feel free to reach out to an attorney on Mintz’s TCPA and Consumer Calling Practice team.

In This Edition

Regulatory Update

Litigation Update

 

 

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Authors

Russell H. Fox is a wireless communications attorney at Mintz. He guides clients through federal legislative, regulatory, and transactional matters. Russell also participates in FCC proceedings, negotiates spectrum agreements, and represents clients in spectrum auctions.
Jonathan Garvin is an attorney at Mintz who focuses on legal challenges facing companies in the communications and media industries. He advises clients on transactional, regulatory, and compliance issues before the FCC involving wireless, broadband, broadcast, and cable matters.
Joshua Briones

Joshua Briones

Member / Managing Member, Los Angeles Office

Joshua Briones is a commercial litigator who defends consumer class actions for Mintz. He's represented clients in a wide range of industries, including financial services, life sciences, manufacturing, and retail, in cases involving false advertising, unfair trade practices, and other claims.
Esteban Morales is a Mintz litigator who handles class action defense and financial services litigation for companies of all sizes. He defends clients targeted in class action suits, and the results include dismissals at the pleading stage. Esteban practices in Mintz's Sports Law Practice.