In 1991, the U.S. Congress, in response to concerns and complaints about the increasing number of unsolicited telemarketing calls to consumers, passed the Telephone Consumer Protection Act (TCPA). The TCPA (Public Law 102-243) updated the Communications Act of 1934 and is the primary law governing telemarketing. The TCPA mandated that the Federal Communications Commission (FCC) amend its rules and regulations to implement methods for protecting the privacy rights of citizens by restricting the use of the telephone network for unsolicited advertising as stated in the TCPA. Although the TCPA was specifically directed at telemarketing activities and abuses, some of its prohibitions and some of the subsequent FCC "Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991" are not specifie to telemarketing. Rather they ...