Describes motivation process for creativity with emphasis on intrinsic motivation by Corey K Katir

By Ronald G. London

Be sure to spend some time with our new advisory in which we expand on our previous entry outlining the basics of the revised FCC automated/prerecorded telemarketing rules.  The advisory explains how, even though the FCC’s primary purpose was to mirror FTC prerecorded telemarketing rules adopted several years back (which were the subject of our advisory issued at that time, here), some additional new requirements resulted from the FCC’s update of its rules.

These include raising the bar for the type of consent needed for auto-dialed live-agent telemarketing to cell phones as part of the new prior, written signed consent requirement for prerecorded telemarketing generally, and extending the automated opt-out mechanism required for prerecorded telemarketing to “abandoned” live-agent telemarketing calls.  While the FCC mostly tracked existing FTC regulations, these additional requirements are new and may require operational changes for a variety of companies. 

In addition, to the extent the FTC’s jurisdiction does not cover certain business sectors, such as common carriers, banks and other financial institutions, and the business of insurance, to the extent participants in those industries had not started adhering to the FTC prerecorded telemarketing rules, adoption of similar rules by the FCC will mean a variety of new compliance burdens for those companies.  Access the advisory here.

FCC Also Remedies Confusion in Its Rulemaking Proposal by Ensuring New Rules Do Not Affect Non-Telemarketing Prerecorded Calls and Text Messages, Such as for Debt Collection, Airline and School Notifications, Fraud Alerts, Surveys Calls, and Wireless Usage Data

By Ronald G. London

The Federal Communications Commission released a Report and Order that revises its rules governing automated/prerecorded telemarketing to modify the consent and opt-out requirements for such calls.    The rule change eliminates the “established business relationship” exception that previously allowed autodialed/prerecorded telemarketing to residential lines.  Meanwhile, the FCC was careful to ensure the new rules cover only automated/prerecorded “telemarketing” calls and text messages, i.e., those that seek to sell or advertise goods or services, while leaving intact preexisting regulations for non-sales prerecorded calls, such as customer-care, surveys, calls by or on behalf of tax-exempt, non-profit entities, etc.
 

In short, the FCC’s R&O operates to:

• Revise its rules to require prior express written, signed consent for all autodialed/prerecorded telemarketing calls to wireless numbers and residential lines.  The consent must specify the phone number to which it applies, be signed (though anything satisfying the E-SIGN Act qualifies), and reflect willingness to receive prerecorded calls in a clear and conspicuous way.  The FCC also specified that the consent cannot be required, directly or indirectly, as a condition for purchasing any good/service.

• Adopt rules applicable to all automated/prerecorded telemarketing calls that allow consumers to opt out of future automated/prerecorded calls during the call.  This requires “promptly” offering an automated interactive keypress or voice-activated opt-out mechanism that permits the called party to make a company-specific do-not-call request.

• Revise the rules to limit permissible abandoned calls – i.e., live-agent auto- or predictive-dialed telemarketing calls that when answered by the consumer do not connect to a live agent within 2 seconds – by requiring calculating the 3% of such calls that are permissible on a per-campaign basis (rather than across all a telemarketer’s campaign, as previously). 

The new regulations mean the FCC prerecorded telemarketing call rules essentially mirror those the  FTC adopted in 2008, which we described in detail here, and have been in effect going on several years now. 

That said, some entities/industries fall outside the FTC’s jurisdiction (i.e., common carriers, banks/credit unions/S&Ls, the business of insurance), and to the extent they have telemarketed without using third-party call centers may not have been complying with the FTC prerecorded telemarketing rules – now, they must commence doing so under the FCC rules.  The FCC’s R&O also confirms that telemarketing text-messages fall within and must comply with the written, signed consent regime.

For any entity or conduct newly covered by the FCC rules, and to the extent they differ at all from the FTC version, the FCC adopted a phase-in, so compliance with the FCC prior written, signed consent obligation is required 12 months after OMB approval of the new rules appears in the Federal Register, compliance with the FCC automated opt-out rule must occur by 90 days after publication of OMB approval, and compliance with the FCC’s revised abandoned call calculation rule is required 30 days after Federal Register publication.

By Ronald G. London

The U.S. Supreme Court has issued a decision in Mims v. Arrow Financial Services, LLC, resolving a split among federal appeals courts, by holding that claims under the Telephone Protection Act (TCPA), which provides consumers private rights of action for telemarketing violations, can be brought under “federal question” jurisdiction in federal courts rather than only in state courts.

The TCPA is the statute administered by the Federal Communications Commission (FCC) that regulates telemarketing and other commercial calling practices. It prohibits automated and/or prerecorded calls to cell phones in the absence of prior express consent by the called party, and significantly restricts such calls to residential lines. It is also a basis for various do-not-call rules, including the administration of and requirement to honor National Do Not Call Registry listings, as well as the obligation for companies that telemarket to maintain an internal do-not-call list. (The TCPA also regulates “junk fax” advertisements.)

The TCPA gives the FCC rulemaking authority to regulate in these areas, as well as the ability to impose fines for violations. At the same time, it provides a private right of action for violations of its do-not-call provisions, autodialed/prerecorded-call restrictions, and/or of other technical prohibitions and obligations.  The statue provides that such claims may be brought in the courts of the various states and the complainant can seek actual damages or $500 in statutory damages, which may be trebled for any willful violation(s).

But courts have split on whether such claims may be brought in the federal courts.  Generally speaking, the courts have agreed that TCPA claims may proceed in federal court under their “diversity” jurisdiction, i.e., the parties are from different states and the complaint seeks $75,000 or more in damages, as well as, after its adoption, under the federal Class Action Fairness Act where plaintiffs seek to proceed as a class (and certain other procedural requirements are met). However, if neither of these apply, the only other basis for federal court jurisdiction relevant to the TCPA would be “federal question” jurisdiction where at least one of the issues to be litigated involves rights, obligations or restrictions arising under federal law.

Initially, though there was some divergence very early on, most federal courts came to agree that the TCPA’s express provision for claims in state court precluded federal question jurisdiction. This became the rule in the federal courts in the Second, Third, Fourth, Fifth, Ninth, and Eleventh Circuits. More recently, however, the U.S. Court of Appeals for the Seventh Circuit held that the TCPA does provide federal question jurisdiction. And, the Sixth Circuit had joined the Seventh Circuit in also holding federal question jurisdiction exists. 

The Arrow Financial case before the Supreme Court came through the Eleventh Circuit, where both that Circuit Court and the district court below it held that Mimms could not proceed under federal question jurisdiction in the federal courts.  In reversing the Eleventh Circuit, the Supreme Court held that Congress’ specification in the TCPA that private parties may seek redress for violations of the Act (or FCC rules thereunder) “in an appropriate court of [a] State,” “if [such an action is] otherwise permitted by the laws or rules of court of [that] State,” is a “permissive grant of jurisdiction to state courts” that does not erect “any barrier to the U.S. district courts’ exercise of the general federal-question jurisdiction they have possessed since 1875.” 

Construing the general federal law that creates federal-question jurisdiction, which states that “district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States,” the Court held that insofar the TCPA creates the right of action and provides the rules of decision, Mimms’ claim plainly “aris[es] under” the “laws … of the United States.”  It also observed that there is a “deeply rooted presumption” in favor of concurrent federal and state court jurisdiction.  That presumption is rebuttable only if “Congress affirmatively ousts the state courts of jurisdiction over a particular federal claim,” which occurs only under an explicit statutory directive, an unmistakable implication from legislative history, or by a clear incompatibility between state-court jurisdiction and federal interests, none of which are present with respect to the TCPA, the Court held.

The case is important as it opens the doors of the federal courts for federal-question TCPA claims in the six Circuits where they previously were barred.  Now, even if the parties do not come from different states and have at least $75,000 at issue (the basis for diversity jurisdiction) or did not seek to proceed as a class, litigants may proceed in federal court. 
 

Also Reinforces That Telemarketing Sales Rule’s Caller ID Flexibility Only Goes So Far

The Federal Trade Commission (FTC) has announced a $500,000 settlement of a telemarketing enforcement action that it brought based on allegations that the telemarketer interfered with the right of consumers to be placed on companies’ internal do-not-call lists, and that it altered outgoing caller ID to inaccurately display the identity of the calling party. The enforcement action is a reminder that telemarketing customer service reps must be trained to be particularly sensitive to understanding – and effectuating – consumer requests to be added to a company’s do-not-call list, even they don’t request it in such specific terms.

The settlement resolves a complaint the FTC filed in the federal court for the Northern District of Illinois alleging that Americall, a telemarketer specializing in calls on behalf of banks, credit card issuers, insurance companies, and other financial institutions, violated the FTC’s Telemarketing Sales Rule (TSR).  The FTC alleged Americall “trains [its] representatives to interfere with entity-specific do-not-call requests” by instructing in training manuals that, absent other, more specific requests, consumer statements like “Don’t call me again,” “Don’t call me back,” or “I do not accept solicitation calls,” should not result in a consumer’s placement on the internal do-not-call list of the entity on whose behalf the agent has called.

In the FTC’s view, apparently, these and “similar statements”  are sufficient to require that the consumer’s phone number be logged on the company’s internal do-not-call list.  In other words, a consumer need not speak the magic words “put me on your do-not-call list,” or any similar invocation, but rather need only assert some general sentiment that the calling party not call again. 
But while one could certainly see a statement like “do not call me again” being treated as the equivalent of “put me on your do-not-call list,” is it really fair to say that “don’t call me back,” or the even less specific “I do not accept solicitation calls” all mean “put me on the list” as well?  “Don’t call me back,” for example, is rather non-specific – does it mean don’t call again ever, don’t call again with regard to your current campaign or offer, or even simply don’t call me again anytime soon?

“I do not accept solicitation calls” is an even more generic statement, particularly viewed in the context of whether a consumer is invoking his or her entity-specific do-not-call rights, as it does not even refer to the specific company calling.  Treating such non-company-specific language as a do-not-call request is even more curious given that any consumer who “does not accept solicitation calls” can effectuate that desire by being placed on the national (or a state) do-not-call registry.

Such musings, however, may well be irrelevant,  insofar as the FTC – the agency charged with enforcing its entity-specific do-not-all rules – appears to consider all the above sentiments sufficient to constitute a do-not-call request.  The bottom line, it seems, is that anytime a consumer expresses that s/he does want further calls, that statement  must be treated as a do-not-call request.  Accordingly, telemarketing agents should be trained to err more on the sides of caution and over-inclusiveness in what is treated as a do-not-call request.

The FTC’s complaint also charged that the telemarketer, armed with knowledge of the names of the companies on whose behalf it placed calls, and thus the ability to properly identify them in outgoing caller ID, altered the calling party name to disguise the identity of Americall and/or its client(s).  The complaint gave the example that, in some instances, when calling on behalf of a fire insurance company, the caller ID displayed the promotional phrase “Gas Rebate Center” to entice consumers to answer the phone.   While the TSR allows for the identity of either the telemarketer or the company on whose behalf the call is made, the name must fairly identify the caller – before the consumer picks up the phone.

The Americall settlement is a half-million-dollar reminder of the need to properly honor entity-specific do-not-call requests, as well as the need for accurate call ID.  The settlement also imposes five years’ worth of record-keeping obligations.  In its press release announcing the settlement, the Director of the FTC’s Bureau of Consumer Protection, David Vladeck, expressed that “When it comes to the Do Not Call provisions, compliance is not rocket science.”  Nonetheless this case reinforces the need to for companies to stay ever vigilant regarding their telemarketing practices.

By Ronald G. London

Be sure to spend some time with our new advisory in which we expand on our previous entry outlining the basics of the revised FCC automated/prerecorded telemarketing rules.  The advisory explains how, even though the FCC’s primary purpose was to mirror FTC prerecorded telemarketing rules adopted several years back (which were the subject of our advisory issued at that time, here), some additional new requirements resulted from the FCC’s update of its rules.

These include raising the bar for the type of consent needed for auto-dialed live-agent telemarketing to cell phones as part of the new prior, written signed consent requirement for prerecorded telemarketing generally, and extending the automated opt-out mechanism required for prerecorded telemarketing to “abandoned” live-agent telemarketing calls.  While the FCC mostly tracked existing FTC regulations, these additional requirements are new and may require operational changes for a variety of companies. 

In addition, to the extent the FTC’s jurisdiction does not cover certain business sectors, such as common carriers, banks and other financial institutions, and the business of insurance, to the extent participants in those industries had not started adhering to the FTC prerecorded telemarketing rules, adoption of similar rules by the FCC will mean a variety of new compliance burdens for those companies.  Access the advisory here.

FCC Also Remedies Confusion in Its Rulemaking Proposal by Ensuring New Rules Do Not Affect Non-Telemarketing Prerecorded Calls and Text Messages, Such as for Debt Collection, Airline and School Notifications, Fraud Alerts, Surveys Calls, and Wireless Usage Data

By Ronald G. London

The Federal Communications Commission released a Report and Order that revises its rules governing automated/prerecorded telemarketing to modify the consent and opt-out requirements for such calls.    The rule change eliminates the “established business relationship” exception that previously allowed autodialed/prerecorded telemarketing to residential lines.  Meanwhile, the FCC was careful to ensure the new rules cover only automated/prerecorded “telemarketing” calls and text messages, i.e., those that seek to sell or advertise goods or services, while leaving intact preexisting regulations for non-sales prerecorded calls, such as customer-care, surveys, calls by or on behalf of tax-exempt, non-profit entities, etc.
 

In short, the FCC’s R&O operates to:

• Revise its rules to require prior express written, signed consent for all autodialed/prerecorded telemarketing calls to wireless numbers and residential lines.  The consent must specify the phone number to which it applies, be signed (though anything satisfying the E-SIGN Act qualifies), and reflect willingness to receive prerecorded calls in a clear and conspicuous way.  The FCC also specified that the consent cannot be required, directly or indirectly, as a condition for purchasing any good/service.

• Adopt rules applicable to all automated/prerecorded telemarketing calls that allow consumers to opt out of future automated/prerecorded calls during the call.  This requires “promptly” offering an automated interactive keypress or voice-activated opt-out mechanism that permits the called party to make a company-specific do-not-call request.

• Revise the rules to limit permissible abandoned calls – i.e., live-agent auto- or predictive-dialed telemarketing calls that when answered by the consumer do not connect to a live agent within 2 seconds – by requiring calculating the 3% of such calls that are permissible on a per-campaign basis (rather than across all a telemarketer’s campaign, as previously). 

The new regulations mean the FCC prerecorded telemarketing call rules essentially mirror those the  FTC adopted in 2008, which we described in detail here, and have been in effect going on several years now. 

That said, some entities/industries fall outside the FTC’s jurisdiction (i.e., common carriers, banks/credit unions/S&Ls, the business of insurance), and to the extent they have telemarketed without using third-party call centers may not have been complying with the FTC prerecorded telemarketing rules – now, they must commence doing so under the FCC rules.  The FCC’s R&O also confirms that telemarketing text-messages fall within and must comply with the written, signed consent regime.

For any entity or conduct newly covered by the FCC rules, and to the extent they differ at all from the FTC version, the FCC adopted a phase-in, so compliance with the FCC prior written, signed consent obligation is required 12 months after OMB approval of the new rules appears in the Federal Register, compliance with the FCC automated opt-out rule must occur by 90 days after publication of OMB approval, and compliance with the FCC’s revised abandoned call calculation rule is required 30 days after Federal Register publication.

By Ronald G. London

The U.S. Supreme Court has issued a decision in Mims v. Arrow Financial Services, LLC, resolving a split among federal appeals courts, by holding that claims under the Telephone Protection Act (TCPA), which provides consumers private rights of action for telemarketing violations, can be brought under “federal question” jurisdiction in federal courts rather than only in state courts.

The TCPA is the statute administered by the Federal Communications Commission (FCC) that regulates telemarketing and other commercial calling practices. It prohibits automated and/or prerecorded calls to cell phones in the absence of prior express consent by the called party, and significantly restricts such calls to residential lines. It is also a basis for various do-not-call rules, including the administration of and requirement to honor National Do Not Call Registry listings, as well as the obligation for companies that telemarket to maintain an internal do-not-call list. (The TCPA also regulates “junk fax” advertisements.)

The TCPA gives the FCC rulemaking authority to regulate in these areas, as well as the ability to impose fines for violations. At the same time, it provides a private right of action for violations of its do-not-call provisions, autodialed/prerecorded-call restrictions, and/or of other technical prohibitions and obligations.  The statue provides that such claims may be brought in the courts of the various states and the complainant can seek actual damages or $500 in statutory damages, which may be trebled for any willful violation(s).

But courts have split on whether such claims may be brought in the federal courts.  Generally speaking, the courts have agreed that TCPA claims may proceed in federal court under their “diversity” jurisdiction, i.e., the parties are from different states and the complaint seeks $75,000 or more in damages, as well as, after its adoption, under the federal Class Action Fairness Act where plaintiffs seek to proceed as a class (and certain other procedural requirements are met). However, if neither of these apply, the only other basis for federal court jurisdiction relevant to the TCPA would be “federal question” jurisdiction where at least one of the issues to be litigated involves rights, obligations or restrictions arising under federal law.

Initially, though there was some divergence very early on, most federal courts came to agree that the TCPA’s express provision for claims in state court precluded federal question jurisdiction. This became the rule in the federal courts in the Second, Third, Fourth, Fifth, Ninth, and Eleventh Circuits. More recently, however, the U.S. Court of Appeals for the Seventh Circuit held that the TCPA does provide federal question jurisdiction. And, the Sixth Circuit had joined the Seventh Circuit in also holding federal question jurisdiction exists. 

The Arrow Financial case before the Supreme Court came through the Eleventh Circuit, where both that Circuit Court and the district court below it held that Mimms could not proceed under federal question jurisdiction in the federal courts.  In reversing the Eleventh Circuit, the Supreme Court held that Congress’ specification in the TCPA that private parties may seek redress for violations of the Act (or FCC rules thereunder) “in an appropriate court of [a] State,” “if [such an action is] otherwise permitted by the laws or rules of court of [that] State,” is a “permissive grant of jurisdiction to state courts” that does not erect “any barrier to the U.S. district courts’ exercise of the general federal-question jurisdiction they have possessed since 1875.” 

Construing the general federal law that creates federal-question jurisdiction, which states that “district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States,” the Court held that insofar the TCPA creates the right of action and provides the rules of decision, Mimms’ claim plainly “aris[es] under” the “laws … of the United States.”  It also observed that there is a “deeply rooted presumption” in favor of concurrent federal and state court jurisdiction.  That presumption is rebuttable only if “Congress affirmatively ousts the state courts of jurisdiction over a particular federal claim,” which occurs only under an explicit statutory directive, an unmistakable implication from legislative history, or by a clear incompatibility between state-court jurisdiction and federal interests, none of which are present with respect to the TCPA, the Court held.

The case is important as it opens the doors of the federal courts for federal-question TCPA claims in the six Circuits where they previously were barred.  Now, even if the parties do not come from different states and have at least $75,000 at issue (the basis for diversity jurisdiction) or did not seek to proceed as a class, litigants may proceed in federal court. 
 

Also Reinforces That Telemarketing Sales Rule’s Caller ID Flexibility Only Goes So Far

The Federal Trade Commission (FTC) has announced a $500,000 settlement of a telemarketing enforcement action that it brought based on allegations that the telemarketer interfered with the right of consumers to be placed on companies’ internal do-not-call lists, and that it altered outgoing caller ID to inaccurately display the identity of the calling party. The enforcement action is a reminder that telemarketing customer service reps must be trained to be particularly sensitive to understanding – and effectuating – consumer requests to be added to a company’s do-not-call list, even they don’t request it in such specific terms.

The settlement resolves a complaint the FTC filed in the federal court for the Northern District of Illinois alleging that Americall, a telemarketer specializing in calls on behalf of banks, credit card issuers, insurance companies, and other financial institutions, violated the FTC’s Telemarketing Sales Rule (TSR).  The FTC alleged Americall “trains [its] representatives to interfere with entity-specific do-not-call requests” by instructing in training manuals that, absent other, more specific requests, consumer statements like “Don’t call me again,” “Don’t call me back,” or “I do not accept solicitation calls,” should not result in a consumer’s placement on the internal do-not-call list of the entity on whose behalf the agent has called.

In the FTC’s view, apparently, these and “similar statements”  are sufficient to require that the consumer’s phone number be logged on the company’s internal do-not-call list.  In other words, a consumer need not speak the magic words “put me on your do-not-call list,” or any similar invocation, but rather need only assert some general sentiment that the calling party not call again. 
But while one could certainly see a statement like “do not call me again” being treated as the equivalent of “put me on your do-not-call list,” is it really fair to say that “don’t call me back,” or the even less specific “I do not accept solicitation calls” all mean “put me on the list” as well?  “Don’t call me back,” for example, is rather non-specific – does it mean don’t call again ever, don’t call again with regard to your current campaign or offer, or even simply don’t call me again anytime soon?

“I do not accept solicitation calls” is an even more generic statement, particularly viewed in the context of whether a consumer is invoking his or her entity-specific do-not-call rights, as it does not even refer to the specific company calling.  Treating such non-company-specific language as a do-not-call request is even more curious given that any consumer who “does not accept solicitation calls” can effectuate that desire by being placed on the national (or a state) do-not-call registry.

Such musings, however, may well be irrelevant,  insofar as the FTC – the agency charged with enforcing its entity-specific do-not-all rules – appears to consider all the above sentiments sufficient to constitute a do-not-call request.  The bottom line, it seems, is that anytime a consumer expresses that s/he does want further calls, that statement  must be treated as a do-not-call request.  Accordingly, telemarketing agents should be trained to err more on the sides of caution and over-inclusiveness in what is treated as a do-not-call request.

The FTC’s complaint also charged that the telemarketer, armed with knowledge of the names of the companies on whose behalf it placed calls, and thus the ability to properly identify them in outgoing caller ID, altered the calling party name to disguise the identity of Americall and/or its client(s).  The complaint gave the example that, in some instances, when calling on behalf of a fire insurance company, the caller ID displayed the promotional phrase “Gas Rebate Center” to entice consumers to answer the phone.   While the TSR allows for the identity of either the telemarketer or the company on whose behalf the call is made, the name must fairly identify the caller – before the consumer picks up the phone.

The Americall settlement is a half-million-dollar reminder of the need to properly honor entity-specific do-not-call requests, as well as the need for accurate call ID.  The settlement also imposes five years’ worth of record-keeping obligations.  In its press release announcing the settlement, the Director of the FTC’s Bureau of Consumer Protection, David Vladeck, expressed that “When it comes to the Do Not Call provisions, compliance is not rocket science.”  Nonetheless this case reinforces the need to for companies to stay ever vigilant regarding their telemarketing practices.

First Orion developed PrivacyStar™, a relatively new and increasingly popular smartphone app for the Android and Blackberry. The app’s main purpose is to block unwanted calls and text messages, and to provide Caller ID for unknown callers so subscribers may take appropriate action by adding the numbers to their Privacy List. The app also provides a SmartBlock capability, which employs the data gathered from PrivacyStar™ usage to automatically block most blocked numbers; Do Not Disturb, which forwards all non-blocked incoming calls to voicemail; and more recently, SMS ID and Voice-Activated Directory Assistance functionality (in the Android smartphone).
 

After garnering much interest from the FTC, the PrivacyStar™ app now also provides an interesting feature that enables subscribers to immediately file a federal complaint against the incoming number. According to First Orion, an estimated 150 million telemarketing calls are being made daily in the United States and of those, as many as 20% may be Do Not Call violations. Consumers are able to directly report potential Do Not Call Registry and Fair Debt Collection Practices Act violations to the FTC straight from their smartphone. Moreover, PrivacyStar™ complaint data generated by subscribers is automatically fed directly into Consumer Sentinel, the secure government database containing information about complaints filed with the FTC, that is available to more than 1,800 law enforcement agencies in the U.S. and abroad for consumer protection purposes. In essence, the PrivacyStar™ app now makes it easier for phone users to file federal complaints. Though the complaint data filed with the FTC does not distinguish between complaints and inquiries, the app assists the FTC to gather complaint data. The FTC or the relevant law enforcement agency will then decide whether to open an investigation.

The introduction of the PrivacyStar™ app has made the filing of federal complaints about unsolicited telephone calls much easier and convenient for phone users. The relative ease and convenience of filing federal complaints has already significantly helped the FTC to gather complaint data that may result in federal investigations. In light of the PrivacyStar™ app’s growing popularity, it is necessary for companies that engage in this form of direct marketing to be aware that this technology is out there and that enforcement agencies are watching.

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