PrIvSecBlog.com
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Privacy and Security Law Blog : Davis Wright Tremaine LLP : Seattle, Los Angeles, Washington D.C., New York, San Francisco, Shanghai, Portland, and Anchorage Law Firm
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Excerpted from the website:
- Earlier this week, the Federal Communications Commission issued a Forfeiture Order that, in fining Dynasty Mortgage, L.L.C., $748,000 for violations of the National Do-Not-Call Registry (NDNCR), instantly became one of the more notable decision in the FCC’s relatively limited body of telemarketing enforcement case law. The decision’s importance lies primarily in the fact that it is one of the few times the FCC pursued an alleged violator all the way through the four phases of pursuing complaints against it (i.e., citation, letter of inquiry investigation, notice of apparent liability for post-citation violations and, finally, forfeiture order), and consequently issued legal findings and factual conclusions that offer insight on how the do-not-call rules are intended to operate in real-world practice. This is significant, because many of the FCC’s rules (and the parallel rules of the FTC) are in the form of generalized prohibitions and obligations that state what telemarketers are supposed to do, but not how to go about doing so.
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