The American Collections Association, along with 7 other companies and trade associations, all filed suit against the FCC in 2015 following the FCC's July 2015 Order "clarifying" the definition of an autodialer, who the "called party" is, and how to revoke consent. 

All 7 suits were consolidated in the D.C. Federal Circuit Court of Appeals.  The arguments were fully briefed in writing earlier this year and the panel of federal judges held an oral argument (hearing) on October 19, 2016.  During the hearing, which lasted several hours, the FCC asked tough questions of both sides, but especially seemed to grill the FCC about the problematic way in which they had interpreted the TCPA.  For example, the judges pressed the FCC's attorney about how companies could fully comply with the reassigned number rule when there still existed no comprehensive list of such numbers. 

The FCC admitted they were aware of no perfect solution, but they believed the industry would be forced to come up with one, like it did for ported wireless numbers.  The FCC stated they were aware of at least 5 companies who offered reassigned number scrubbing, some of whom claimed to be 95-99% accurate.  The contact center industry anxiously awaits the Court's ruling on these important issues.