On May 26, 2021, we posted a blog concerning a Third Circuit Court of Appeals decision in Leyse v. Bank of America. Mr. Leyse understood the blog as indicating that the court found that Mr. Leyse had engaged in what the blog called “TCPA call baiting” (the TCPA is the Telephone Consumer Protection Act). We removed the blog and retract any and all portions of it that might have been understood as indicating that the court found that Mr. Leyse had sought, as the blog’s definition of “TCPA call baiting” stated, “to generate calls [or] text messages, done to try to entrap telemarketers into violating the TCPA.”

Lead Generator Found Liable for Major TSR Violations
On September 1, 2023, Judge Lindsay C. Jenkins of the Northern District of Illinois entered an order granting the Federal Trade Commission (“FTC’) partial summary