Highlights From FCC's Reassigned Number Database Order

By Michael McTigue, Meredith Slawe and Michael Stortz (January 9, 2019, 3:56 PM EST) -- On Dec. 13, 2018, the Federal Communications Commission unanimously approved the establishment of a comprehensive database of mobile numbers that would allow callers to ascertain whether a number was subject to reassignment to another user before calling that number.[1] In a notable and late-breaking development, the commission's final order included a limited safe harbor from liability under the Telephone Consumer Protection Act for callers who rely on the database to determine that a number was not subject to reassignment.[2] Although much remains to be done, and the parameters of the new database and safe harbor remain to be determined, the FCC's order represents an important first step towards reasonable TCPA rules that protect consumers while allowing compliance-minded companies to use modern technology to communicate with their customers, without persistent fear of abusive and costly litigation and uncertain potential liability....

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