RILA Reply Comments Rules and Regulations

The Retail Industry Leaders Association (“RILA”) submits these reply comments to advocate for reasonable and administrable rules interpreting the “automatic telephone dialing system” (“ATDS”) provisions of the Telephone Consumer Protection Act (“TCPA”). This issue is of critical importance to RILA’s members. The lack of consistent, clear, and workable regulatory guidance interpreting ATDS restrictions continues to have significant consequences for the retail industry. Not only are compliance-oriented retailers left to grapple with contradictory judicial rulings, they are increasingly faced with rampant, abusive litigation under the TCPA because of the lack of commonsense rules.