Dialer compliance news: what changed and what it means for your team

Last updated 2026-07-09

What is dialer compliance and why is it in the news right now?

Dialer compliance is the practice of making sure your outbound call and text technology, your contact lists, and your consent records all satisfy federal and state law before a single number is dialed. The law that governs most of this is the Telephone Consumer Protection Act, 47 U.S.C. § 227, passed in 1991 and expanded through FCC rulemaking ever since. ^[1]

The reason it stays in the news is money. One unsolicited autodialed call can cost you $500 in statutory damages. If a court finds willfulness, that number triples to $1,500 per call or text, and class actions stack thousands of individual violations into eight-figure settlements. ^[1]

The last 18 months have been unusually busy. The FCC passed a sweeping one-to-one consent rule in December 2023, set to take effect January 27, 2025. Lead generators, insurance marketers, and mortgage shops spent most of 2024 scrambling to comply. Then, in January 2025, the 11th Circuit Court of Appeals vacated that specific FCC order before it took effect, sending everyone back to square one. ^[2] That whipsaw created real confusion. A lot of teams are still not sure where they stand.

Here's the short answer. The base statute never went away. The FCC order was a regulatory addition on top of 47 U.S.C. § 227. Vacating the order means the FCC's new one-to-one language is gone, but the existing requirement for prior express written consent to autodialed marketing calls and texts to cell phones is still fully in force. ^[1]

What did the FCC's one-to-one consent rule actually say?

The FCC adopted the one-to-one consent rule in a December 2023 Report and Order. The core requirement was that consent for autodialed or prerecorded telemarketing calls or texts had to be obtained separately for each seller. A consumer checking a box on a lead-gen form that said something like "I consent to be contacted by our partners" would no longer cover an unlimited list of buyers. Each company wanting to reach that consumer would need its own express written consent. ^[2]

The rule also included a "logically and topically related" requirement: consent could only cover calls and texts about the same general subject matter the consumer was engaging with when they gave consent. A mortgage inquiry form could not generate valid consent for a home warranty company calling about something unrelated. ^[2]

This was a direct hit at the shared-lead model used by insurance aggregators, solar lead generators, and financial services comparison sites. The FCC's stated goal was to close what it called the "lead generator loophole" that let a single consent click reach dozens of marketers. ^[2]

The 11th Circuit's January 2025 vacatur came in Insurance Marketing Coalition Ltd. v. FCC. The court found the FCC exceeded its authority under the TCPA in that specific rulemaking. ^[3] The FCC has not yet said whether it will appeal or pursue a revised rule. That legal uncertainty is one of the biggest open questions in dialer compliance right now.

For a broader look at how the TCPA applies to text messaging specifically, see our tcpa sms compliance guide.

Does the 11th Circuit ruling mean outbound teams can go back to bulk-consent lead lists?

No. And this is the misread that worries me most about how teams are reacting to the 2025 news cycle.

The vacatur removed the FCC's new one-to-one consent regulation. It did not remove the TCPA's existing consent requirement. Under the pre-2025 status quo, you still need "prior express written consent" (PEWC) to make autodialed or prerecorded marketing calls or texts to cell phones. ^[1] The FCC's existing 2012 rules defining PEWC are still in effect. Those rules require that the consent be in writing, that it clearly authorize the specific seller, and that it disclose the use of an autodialer or artificial voice. ^[4]

Broad blanket consent language from a third-party lead gen form has always been legally questionable, long before the 2025 rule. Courts have been skeptical of it for years. The 11th Circuit ruling removed one layer of new restriction. It did not bless the old practices.

One more thing worth knowing. Several states have passed their own one-to-one or near-one-to-one consent laws that the federal ruling does not touch. Florida's Mini-TCPA (SB 1120), effective July 1, 2021, is one of the most aggressive. ^[5] Oklahoma passed similar legislation. State laws can be stricter than federal law, and they often are.

What are the current TCPA rules for autodialers and prerecorded calls?

The TCPA prohibits using an automatic telephone dialing system (ATDS) or an artificial or prerecorded voice to call or text a cell phone number without prior express consent. For marketing calls, that consent must be written (PEWC). For purely informational calls, prior express consent (which can be oral) is enough. ^[1]

What counts as an ATDS was the subject of massive litigation after the Supreme Court's 2021 Facebook v. Duguid decision, which narrowed the definition to systems that use a random or sequential number generator to store or produce numbers. ^[6] Systems that simply dial from a stored list without random generation arguably fall outside that definition under Duguid. But courts have not uniformly agreed on how to apply Duguid, and several state laws use a broader definition that does not depend on the random-number-generator question. ^[5]

Prerecorded voice calls have a separate, cleaner prohibition. Even if your dialer is not an ATDS under the post-Duguid definition, delivering a prerecorded or artificial voice message to a cell phone for marketing purposes still requires PEWC. This catches a lot of teams who switched from predictive dialers to soundboard or drop-voicemail technology thinking they had escaped the ATDS rules.

For live-agent calls (no autodialer, no prerecorded message), the main obligations are the National Do Not Call Registry, calling window restrictions (8 a.m. to 9 p.m. local time at the called party's location), and company-specific DNC list maintenance. ^[7]

Call type	Technology trigger	Consent required (marketing)	Key statute/rule
Autodialed to cell	ATDS under Duguid	Prior express written consent	47 U.S.C. § 227(b)(1)(A)
Prerecorded/artificial voice to cell	Any dialer	Prior express written consent	47 U.S.C. § 227(b)(1)(A)
Live agent to cell	No ATDS, no recording	Prior express consent (oral OK for info calls)	47 U.S.C. § 227
Any call to residential landline	Prerecorded voice	Prior express written consent (marketing)	47 C.F.R. § 64.1200
Any outbound marketing call	Any	Must honor DNC, 8am-9pm window	47 U.S.C. § 227(c)

What do the new FCC rules say about call authentication and STIR/SHAKEN?

STIR/SHAKEN is a call-authentication framework the FCC mandated under the TRACED Act of 2019. Large carriers had to implement it by June 2021. Smaller carriers got extensions, but the FCC has pushed hard on full implementation and now requires robocall mitigation database registration for any voice service provider. ^[8]

For outbound sales teams, STIR/SHAKEN matters because it affects whether your calls show up as "Likely Spam" on the recipient's phone. If your carrier cannot authenticate your calls with a full "A" attestation (meaning the carrier vouches that you are the legitimate account holder for that number), your calls may get flagged or blocked before they ring. ^[8]

The FCC's Robocall Mitigation Database requires all voice service providers to file a robocall mitigation program. If you are buying outbound calling as a service, your provider needs to be registered. The database is searchable through the FCC's site. ^[8]

Here's the practical takeaway. Outbound teams need providers with clean STIR/SHAKEN attestation records who can explain how your campaigns get labeled. Cheap offshore dialer services that can't get A-level attestation will hurt your answer rates no matter how perfect your consent is.

What recent TCPA lawsuits and settlements should dialer teams know about?

A few real cases set the current risk floor.

In Krakauer v. Dish Network (4th Cir. 2018), the court upheld a $61 million judgment covering roughly 51,000 calls to DNC-registered numbers. That works out to about $1,200 per call. ^[9] The case still shows up in class action complaints and stands for the point that vicarious liability applies: companies can be held responsible for their vendors' and third-party callers' violations.

In Van Patten v. Vertical Fitness Group (9th Cir. 2017), the court examined a gym that texted a former member without adequate consent. The takeaway was that consent obtained for one purpose (joining a gym) does not automatically extend to marketing messages after a relationship ends.

The Facebook v. Duguid ruling in 2021 (mentioned above) was technically a win for defendants because it narrowed the ATDS definition. It did not end TCPA litigation. Plaintiffs pivoted quickly to prerecorded-voice claims and to state law claims that don't depend on the ATDS definition. ^[6]

More recently, settlements in the $10 million to $30 million range have been reported in insurance and real estate verticals, usually involving purchased lead lists or shared-consent models. These don't always produce published opinions, so exact figures are harder to nail down. Plaintiff law firms that specialize in TCPA class actions have built this into a highly developed practice area.

For the latest developments, our tcpa news today feed tracks new FCC orders, significant court decisions, and state law changes as they happen.

How do state laws add to federal dialer compliance requirements?

Federal law sets a floor. States can go higher, and many have.

Florida's SB 1120 (effective July 1, 2021) amended the Florida Telephone Solicitation Act to require written consent before making any autodialed sales call or text to a Florida resident. Here's the part that trips people up: it does not require the technology to meet the federal ATDS definition. Any system that dials numbers automatically from a list requires consent under Florida law. The private right of action allows $500 per call, with a treble-damages option. ^[5]

Texas Business & Commerce Code Chapter 305 restricts automated calls and texts and gives the state attorney general enforcement authority, plus a private right of action. Oklahoma, Washington, and Maryland have passed similar updates.

California's CCPA/CPRA does not regulate call technology the way the TCPA does, but it imposes data rights that affect how you store and use contact information, which intersects with consent recordkeeping for dialer programs.

This is why the 11th Circuit ruling on the FCC's one-to-one consent rule did not give outbound teams a clean pass. Even if you are technically clear under the current federal standard, a Florida consumer on your list can still bring a state-law claim. ^[5]

A useful habit: before launching any campaign, map your list against state distribution. If 15% of your numbers are Florida area codes, your Florida exposure is real and worth thinking about separately from your federal exposure.

If your team does any text-based outreach, the sms opt in process needs to reflect both federal PEWC requirements and state-specific written-consent rules.

What does 'prior express written consent' actually require for dialers?

The FCC's 2012 rules define prior express written consent as an agreement that: (1) is signed by the called party (electronic signature counts); (2) clearly authorizes the specific seller to use an autodialer or prerecorded voice to deliver telemarketing messages; (3) provides a phone number at which the called party agrees to receive such calls; and (4) is not a condition of purchasing goods or services. ^[4]

That four-part test catches a lot of web forms that compliance teams think are adequate but aren't. The most common failures:

First, the form doesn't name the seller. "We and our partners" or "up to five companies" does not clearly authorize a specific company. Post-vacatur, this is still a problem because the 2012 rules never allowed truly anonymous blanket consent.

Second, the form doesn't disclose autodialed or prerecorded technology. You have to say, in substance, that you'll use automated technology. "We may contact you" without specifying the method is not enough.

Third, the consent is buried. Courts have looked at whether the consumer could realistically have understood what they were agreeing to. A footnote in gray text on a signup page is legally weaker than a standalone checkbox with plain-language disclosure.

Fourth, there's no record. You can have the world's best consent form and lose a TCPA case if you can't prove a specific person, on a specific date, using a specific phone number, agreed to your terms. Consent recordkeeping is the part most small teams skip, and it's the part that decides whether you win or lose in litigation. ^[4]

For teams building or auditing their web intake, our sms opt in form templates include the disclosure language and checkbox placement that matches current FCC guidance.

What should outbound teams do right now to stay compliant?

Given where things stand (post-vacatur federal uncertainty, aggressive state laws, an active plaintiffs bar), here is what I'd actually do if I ran compliance for a 20-person outbound sales team.

First, audit your consent chain for every list you're dialing. more than your process. The actual consent records for the actual numbers. If you can't produce a timestamp, IP address, and the exact form language for a given contact, treat that number as unconsented for ATDS and prerecorded purposes.

Second, scrub against the National Do Not Call Registry and your internal DNC list before every campaign. The FTC safe harbor requires scrubs every 31 days at minimum. ^[7] Scrubbing quarterly is not enough, and the rule is unambiguous about that.

Third, know your technology. If you use a predictive dialer, a power dialer, or any system that places calls before an agent answers, confirm with your vendor whether it meets the post-Duguid ATDS definition and how your carrier handles STIR/SHAKEN attestation.

Fourth, flag Florida, Oklahoma, and Washington numbers for extra scrutiny. These states have stricter state-level rules that don't depend on the federal ATDS definition.

Fifth, document everything. Consent records, DNC scrub dates, campaign settings, and agent training logs. In a TCPA class action, the ability to produce clean documentation is often the difference between a quick dismissal and a seven-figure settlement.

LeadCompliant's free TCPA compliance kit includes a consent-form template, DNC scrub checklist, and a calling-window calculator for all 50 states. It's free because we'd rather teams use good tools than get sued.

For an end-to-end look at compliant text outreach specifically, the tcpa fundamentals guide covers consent, opt-out, and message content in one place.

How does the National Do Not Call Registry work for dialers?

The National DNC Registry is maintained by the FTC under 16 C.F.R. Part 310 (the Telemarketing Sales Rule) and the FCC under 47 C.F.R. § 64.1200. ^[7] Any seller or telemarketer making outbound marketing calls to residential phone numbers must scrub their lists against the Registry before calling. A number registered on the DNC list cannot be called for marketing purposes unless the caller has an established business relationship (EBR) with the consumer, or the consumer has given written permission.

The EBR exemption is narrower than most teams think. Under the FTC's rule, an EBR from a purchase lasts 18 months from the date of the last transaction. An EBR from an inquiry or application lasts 3 months. ^[7] After that window, the number is protected even if it's still in your CRM.

Access to the Registry costs money. The FTC charges by area code, currently $72 per area code per year (as of 2024) with a cap at $18,044 for access to the full national list. ^[7] Small teams calling in a few states can save money by buying only the area codes they work. There is a free option for organizations making 5 or fewer area code subscriptions, but commercial outbound teams almost always blow past that threshold.

Scrubbing frequency matters. You must scrub within 31 days before any call. If your scrub date was 45 days ago, you're outside the safe harbor window. ^[7]

The DNC rules apply to calls to mobile numbers too. A cell number on the DNC registry gets the same protection as a residential landline for purposes of outbound marketing calls.

What are the penalties for TCPA and DNC violations in 2025?

The TCPA sets statutory damages at $500 per violation. Courts can treble that to $1,500 per violation for willful or knowing violations. ^[1] There is no damages cap in the TCPA, which is exactly why class actions are so lucrative for plaintiffs. A single campaign sending 100,000 texts to unconsented numbers creates potential exposure of $50 million at $500 per text, or $150 million if a court finds willfulness.

The FCC and FTC can also impose civil forfeiture penalties under their own authority. The FCC's maximum per-violation fine for robocall violations under the TRACED Act is $10,000 per call, up to $10 million per campaign, separate from private TCPA litigation. ^[8]

Florida's state TCPA analog allows $500 per violation with treble damages for willfulness, essentially mirroring the federal structure but applying to a broader set of technology. ^[5]

In practice, most TCPA risk for small and mid-size outbound teams comes from class action plaintiffs, not regulator enforcement. The FCC and FTC tend to focus their enforcement on high-volume robocallers and scams. Private class action attorneys focus wherever the damages math is biggest. Lead-gen dependent businesses, insurance agencies, real estate brokerages, and mortgage shops sit high on the plaintiff bar's radar.

The $61 million Krakauer v. Dish Network judgment is the best single data point for what happens when a large enterprise ignores DNC requirements at scale. ^[9] For smaller teams, even a single-plaintiff suit demanding a nuisance-value settlement of $5,000 to $10,000 per complaint is a real cost. Plaintiff attorneys often file individually rather than as a class when targeting small businesses, because small businesses are more likely to settle quickly.

The chart below shows the TCPA penalty structure across violation types.

What dialer compliance issues should text-first teams watch?

Text messaging carries the same TCPA exposure as voice calls, and in some ways more, because texts are easy to document and easy to screenshot. A consumer who receives 50 unwanted texts has 50 provable violations sitting on their phone.

The consent requirements for marketing texts are identical to marketing calls: prior express written consent, with the name of the texting company, disclosure of automated technology, and a phone number provided by the consumer. ^[4]

Opt-out handling is a specific compliance point for SMS. Under FCC guidance and carrier rules, you must honor STOP and similar opt-out keywords immediately and must not send any further marketing messages after receiving a valid opt-out. ^[4] Sending even one follow-up message after an opt-out is a clean TCPA violation.

Carrier filtering has become a major operational issue separate from legal compliance. The major carriers (AT&T, Verizon, T-Mobile) run their own spam-filtering systems. High-volume texts from short codes or 10DLC numbers that lack proper campaign registration get filtered or blocked. The Campaign Registry (TCR) requires businesses to register their brand and specific messaging use cases before texting at scale. This is not a legal requirement under the TCPA itself, but violating carrier rules will get your messages blocked and can get your numbers deactivated. ^[10]

For teams thinking about building an SMS program from scratch, the sms double opt in process adds a second confirmation step that both strengthens your consent records and helps identify invalid numbers before you build list size.

The intersection of lead generation and SMS compliance gets complicated fast, especially for industries like real estate and insurance where leads are often purchased. Our lead generation compliance news coverage tracks how courts and the FCC treat purchased-list texting in real time.

How often do the rules change and how do I stay current?

The honest answer: often enough that a compliance program you set up 18 months ago may have real gaps today.

The FCC issues Declaratory Rulings, Reports and Orders, and enforcement actions on an ongoing basis. The TCPA has been litigated in every federal circuit, and circuit splits create different rules depending on where your called parties live. Congress occasionally amends the statute. State legislatures have been actively passing new telemarketing laws since 2021. And the FTC updates its Telemarketing Sales Rule separately from FCC activity.

My actual recommendation for a small team: designate someone to read one compliance-focused newsletter per week. The FCC's public notices are free and searchable on its site. ^[8] For curated summaries without reading government filings, several law firm blogs track TCPA developments; the LeadCompliant tcpa news today section aggregates significant changes as they happen.

A calendar reminder to re-scrub your DNC list every 31 days and to review your consent forms every 6 months costs almost nothing. Against the alternative, it's the obvious trade.

Nobody has good data on how many small-team violations go unreported versus resolved quietly, but the plaintiff-attorney infrastructure around TCPA has grown a lot since 2015, and serial plaintiffs actively sign up for marketing lists to generate cases. That dynamic is not going away.

This article is educational and is not legal advice. If you have specific exposure questions, talk to a telemarketing law attorney.

Frequently asked questions

Is the FCC's one-to-one consent rule still in effect after the 11th Circuit ruling?

No. The 11th Circuit vacated the FCC's December 2023 one-to-one consent order in January 2025 before it took effect, in Insurance Marketing Coalition Ltd. v. FCC. The pre-existing TCPA consent requirements, including the 2012 prior express written consent rules for autodialed marketing calls, remain fully in force. The vacatur removed the new layer; it did not eliminate existing federal consent obligations.

What is the fine for a single TCPA violation?

The TCPA sets statutory damages at $500 per call or text. Courts can increase that to $1,500 per violation for willful or knowing violations under 47 U.S.C. § 227(b)(3). There is no statutory cap. Class actions can aggregate thousands of individual violations, which is why multi-million-dollar settlements are common even in cases involving relatively short campaigns.

Do TCPA rules apply to B2B calls and texts?

Partially. The TCPA's autodialer and prerecorded-voice restrictions apply to calls to cell phones regardless of whether the recipient is a business contact or consumer. If you are calling a businessperson on their personal cell, TCPA applies. Calls to business landlines have somewhat different treatment under the statute, but DNC obligations and state law requirements may still apply. B2B teams are not fully exempt.

How long does an established business relationship (EBR) last for DNC purposes?

Under FTC rules, an EBR from a purchase, rental, or financial transaction lasts 18 months from the last transaction date. An EBR from an inquiry or application lasts 3 months from the date of the inquiry. After those windows, the consumer's DNC registration is fully protected again, and you need fresh written permission to call for marketing purposes.

What is STIR/SHAKEN and does it affect my dialer?

STIR/SHAKEN is an FCC-mandated call-authentication framework that lets carriers verify whether the calling number is legitimate. Your outbound calls receive an attestation level (A, B, or C). Calls without A-level attestation risk being labeled Likely Spam on the recipient's phone before it rings. If your carrier or dialer provider can't get A-level attestation, your answer rates suffer independently of whether your consent records are clean.

Can I text people who filled out a form on a partner's website?

Only if the consent form on that partner's site specifically named your company, disclosed automated texting, and collected the consumer's phone number for that purpose. Generic partner-network consent language, like 'we and our partners may contact you,' has never satisfied the FCC's prior express written consent standard. The 2025 vacatur of the one-to-one rule did not make blanket consent language valid; courts were skeptical of it before the 2023 rule existed.

How often do I need to scrub my calling list against the DNC Registry?

At minimum every 31 days before any marketing call. The FTC's safe harbor requires that your scrub occurred within 31 days of the call date. Scrubbing monthly and then calling for 60 days without a new scrub puts the later calls outside the safe harbor. Most compliant teams build a standing monthly scrub into their campaign workflow as a non-negotiable step.

Does Florida's Mini-TCPA apply to out-of-state callers?

Yes. Florida's SB 1120 applies based on where the called party receives the call, not where the caller is located. If you are calling a Florida phone number from a call center in Texas or Ohio, Florida law applies. Florida's version does not require the technology to meet the federal ATDS definition, so it catches more dialer types than the current post-Duguid federal standard.

What records do I need to keep to defend a TCPA lawsuit?

For each contacted number you need: the consent record (timestamp, IP address, exact form language shown to the consumer, the phone number entered), the date of the DNC scrub before the contact, which campaign settings were active (dialer type, prerecorded content if any), and any opt-out requests received and honored. Courts have found against defendants not because consent didn't exist, but because they couldn't prove it for specific numbers.

Does the 10DLC registration requirement relate to TCPA compliance?

Indirectly. 10DLC (10-digit long code) registration with The Campaign Registry is a carrier requirement, not a federal law requirement. But it affects whether your texts reach recipients. Unregistered campaigns get filtered or blocked by AT&T, Verizon, and T-Mobile. Running compliant consent practices while sending from unregistered numbers means your messages may not arrive, and your recipients may still complain about attempted contacts.

What happened in Krakauer v. Dish Network?

The 4th Circuit upheld a $61 million judgment in 2018 against Dish Network for roughly 51,000 calls made to National Do Not Call Registry numbers by a third-party vendor. The court found Dish vicariously liable for its vendor's violations. The case remains one of the most cited TCPA outcomes and established clearly that companies are responsible for their vendors' compliance failures, not only their own direct calling activity.

Are ringless voicemail drops covered by the TCPA?

Almost certainly yes, though not every court has ruled on the exact technology. Ringless voicemails deliver a prerecorded message to a voicemail inbox without ringing the phone. The FCC has indicated these are covered by the TCPA's prerecorded-voice prohibition. Several district courts have agreed. Treating ringless voicemail as TCPA-exempt is a legally risky position given current agency guidance and case law trends.

What is the calling window rule under the TCPA?

Under 47 C.F.R. § 64.1200, outbound telemarketing calls may only be placed between 8 a.m. and 9 p.m. local time at the called party's location. That means local time at the recipient's end, not the caller's. A team in California calling East Coast numbers at 6 a.m. Pacific time is calling those recipients at 9 a.m. Eastern, which is fine. But calling West Coast numbers at 8 p.m. Pacific while sitting in New York violates the rule.

How does the Supreme Court's Facebook v. Duguid ruling affect my predictive dialer?

The 2021 Duguid ruling held that an ATDS under the TCPA must use a random or sequential number generator to store or produce numbers to be dialed. Systems that dial from a pre-set stored list without random generation may not qualify as an ATDS under this definition. However, if your dialer uses any prerecorded messages, the prerecorded-voice prohibition applies regardless of ATDS status. And several state laws use broader ATDS definitions unaffected by Duguid.

Sources

1. Cornell Law School Legal Information Institute, 47 U.S.C. § 227 (TCPA statute text): TCPA prohibits autodialed or prerecorded calls to cell phones without prior express consent; statutory damages $500 per violation, up to $1,500 for willful violations
2. U.S. Court of Appeals, 11th Circuit, Insurance Marketing Coalition Ltd. v. FCC (2025): 11th Circuit vacated the FCC's December 2023 one-to-one consent rule in January 2025, finding the FCC exceeded its statutory authority under the TCPA
3. FCC, 47 C.F.R. § 64.1200 (FCC implementing regulations for TCPA): FCC 2012 rules define prior express written consent: signed agreement, names the seller, discloses autodialer use, provides phone number, not conditioned on purchase
4. Florida Legislature, SB 1120 (2021), Florida Telephone Solicitation Act amendments: Florida SB 1120 effective July 1, 2021 requires written consent for autodialed sales calls or texts to Florida residents; does not require federal ATDS definition; $500 per violation with treble damages option
5. U.S. Supreme Court, Facebook Inc. v. Duguid, 592 U.S. 395 (2021): Supreme Court held that an ATDS under the TCPA must use a random or sequential number generator; systems dialing from stored lists without random generation may not qualify as ATDS
6. FTC, National Do Not Call Registry, 16 C.F.R. Part 310 (Telemarketing Sales Rule): DNC scrub required within 31 days before any call; EBR exemption lasts 18 months from last purchase or 3 months from inquiry; area code access currently $72/year per area code
7. U.S. Court of Appeals, 4th Circuit, Krakauer v. Dish Network (2018): $61 million judgment upheld for approximately 51,000 calls to DNC-registered numbers; court found Dish vicariously liable for third-party vendor violations
8. The Campaign Registry (TCR), 10DLC brand and campaign registration: Major carriers require 10DLC brand and campaign registration before high-volume business texting; unregistered campaigns face filtering and blocking by AT&T, Verizon, T-Mobile