D.C. Circuit Dooms “Idiosyncratic” or “Imaginative” TCPA Revocation Efforts While Blessing Contractual Revocation Provisions in Upholding FCC’s Revocation Approach
Nearly a year-and-a-half after oral argument on the ACA International v. FCC petition for review of the Federal Communications Commission’s 2015 Omnibus Order, the D.C. Circuit Court of Appeals issued its long-anticipated opinion last Friday, March 16th, in a 51-page decision authored by Judge Srinivasan. This article focuses on the D.C. Circuit’s handling of the issue of revocation of consent and its further implications for contracting parties addressing the same.