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Paul Besozzi

I have practiced in the telecommunications regulatory field, including before the FCC and state regulatory agencies, for some 35 years. This has included advising clients on all manner of compliance, rulemaking, enforcement and legislative issues relating to the Telephone Consumer Protection Act and Junk Fax Act, particularly before the FCC which develops the regulations implementing those statutes. My efforts include reviewing clients' technology and TCPA compliance plans to determine whether they meet FCC requirements and advising on strategies for raising issues with the FCC.

Section 13(d)(1) of the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (TRACED Act) directed the the Federal Communications Commission’s (FCC) to establish a process for registering a “single consortium that conducts private-led efforts to trace back the origin of suspected unlawful robocalls.” The FCC is required to consider new interested consortia on an

Federal Communications Commission (“FCC”) Chairwoman Jessica Rosenworcel announced on April 7, 2022, that “five more state Attorneys General are partnering with the FCC in robocall investigations.” As a result, a majority of states (some 27 plus the District of Columbia) have now signed Memoranda of Understanding (“MOU”) with the FCC’s Enforcement Bureau.

The most recent

Fingerprint Scanning on Blue TechnologyThe Illinois Supreme Court’s recent broad interpretation of the pioneering Illinois Biometric Identity Protection Act justifies close attention to legislative and regulatory developments regarding collection and protection of biometric identifier data.  Our previous report of this decision may be found here.  Two other states, Texas and Washington, already have biometric identifier privacy laws in place, although not with the breadth of the Illinois statute. For example, neither of those statutes provides for a private right of action that is afforded under the Illinois law. In each case, enforcement of provisions is left to the state Attorney General. 
Continue Reading States’ Focus on Biometric Privacy Developments Warrants Close Attention

Noting that some 35 million telephone numbers are disconnected and made available for reassignment to consumers annually, the Federal Communications Commission (“FCC”) took a further step last Thursday to address the “problem of unwanted calls to reassigned numbers.”  The problem with these calls already is well known to businesses that rely on phone calls or text messages to communicate with their customers: a caller places a call or sends a text  to a number for which it has previously obtained the necessary consent, only to find out later that the number has since been reassigned to someone else (who has not provided consent).  The FCC declared in the Declaratory Ruling and Order of July 2015 (“2015 Declaratory Ruling”) that these calls may violate the TCPA, although it also created a limited safe harbor for a single call or message made post-reassignment
Continue Reading Reassigned Numbers: Sailing Towards A New TCPA “Safe Harbor?”