All Articles


August 2003

Tightening “de Mayo”: The FTC Revises an Important Informal Staff Opinion Letter

The revised “de Mayo letter” provides more detailed guidance as to when a debt is considered to be in “default”, and potentially subject to the FDCPA, and when a collection agency employee can be considered to be a “de facto” employee of the creditor client, and therefore potentially exempt from the FDCPA.

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March 2003

Madigan v. Telemarketing Associates, Inc

by Errol Copilevitz

It was held that consistent with the Court’s precedent and the First Amendment, states may maintain fraud actions when fundraisers make false or misleading representations designed to deceive donors about how their donations will be used.

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April 2002

Court Rules on the Constitutionality of the Telephone Consumer Protection Act

by William Raney

Holding that a provision of the TCPA regarding unsolicited fax advertisements was unconstitutional, a federal judge in Missouri effectively held, by extension, that the standards applied to other laws affecting telemarketing must be constitutional.

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February 2002

Changing the Terms of Debate on the Revisions to the Telemarketing Sales Rule

by William Raney

Regarding the FTC’s proposals to amend the Telemarketing Sales Rule as it relates to the use of predictive dialers, the alleged nuisance should be balanced against the benefits of predictive dialing to come to a reasonable interpretation.

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December 2001

Nonprofit Files Constitutional Challenge to Indiana Do-Not-Call List

by William Raney

An Indiana firefighters’ nonprofit challenges the constitutionality of the Do-Not-Call list, which applies to the phone number (not the resident attached to the phone number) without regard to the resident’s history with the nonprofit and variously to some telemarketing calls while exempting others.

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October 2001

State Regulation of Predictive Dialers

by William Raney

Predictive dialers have helped the industry make more calls using fewer telemarketers.However until this year, the use of predictive dialers was largely unregulated by state or federal law.

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August 2001

“Nexus” and State Taxation of Telemarketing

by William Raney

A state can tax a sale if it has sufficient “nexus” with that state. If the telemarketing firm - or its clients -  has a physical presence in the state, sales and/or use tax may need to be collected depending on the particular campaign in question.

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June 2001

Louisiana Adopts Onerous Do-Not-Call List Law

by William Raney

May 24, 2001, the governor of Louisiana signed a law creating a state do-not-call list requiring all purchasers of the list to post a $20,000 bond to be applied to penalties for future violations.

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February 2001

Appellate Court Hears Oral Argument on Immediate Disconnect Statute

by William Raney

This firm argued to challenge the immediate disconnect law in Arkansas. The law, unusually, applies to charitable solicitations by telephone, rather than solely to telemarketing by commercial entities, putting an unfair and undefined burden on a telemarketer to determine what constitutes cause for disconnect.

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February 2001

New Legislation Clarifies Uncertain Areas of Telemarketing Law

by William Raney

Two cases in which state legislatures can get things right and pass legislation that clarifies a murky area of the law, or that attempts to unify treatment of an aspect of the business which was previously treated inconsistently.

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