July 24, 2019 — Comments

This is an Application for Review of the Consumer and Governmental Affairs Bureau’s recent ruling on P2P texts, submitted by the National Consumer Law Center on behalf of its low-income clients and Consumer Federation of America, Consumer Action, EPIC, National Association of Consumer Advocates, and Public Knowledge, is filed pursuant to Section 1.115 of the Commission’s rules. The Bureau’s P2P Ruling (“Ruling”) includes interpretations of the Telephone Consumer Protection Act (“TCPA”) and its application to the P2P texting platform that are in conflict with the TCPA itself, established Commission policy, and case precedent. The Ruling implicitly relies on facts regarding the P2P system’s level of automation that are not supported by the record and are contrary to readily available information.