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7 Riskiest Dialing Methods Under the TCPA - Autodialer (Avatar)

7 Riskiest Dialing Methods Under the TCPA - Autodialer (Avatar)
7 Riskiest Dialing Methods Under the TCPA
Autodialer (Avatar)
Risk Score


Also known as “Soundboard Technology,” Avatar technology was described by the D.C. District Court of Appeals as a technology that “enables telemarketing agents to communicate with consumers over the phone by playing prerecorded audio clips instead of using the agent’s live voice. The agent can choose a prerecorded clip to ask questions of or respond to a consumer while retaining the ability to break into the call and speak to the consumer directly. Soundboard also enables agents to make and participate in multiple calls simultaneously.”

What are the risks?

Some courts may consider Avatar technology to be the same as a robocall or prerecorded voice, despite a live agent operating the technology.

How is Avatar different than Live Agent?

An avatar autodialer is different from a live agent autodialer in that the agent communicates with the consumer via the playing of multiple recorded audio snippets, rather than the agent’s own voice.

Case Study

Soundboard Ass’n v. FTC

In this case, the D.C. District Court of Appeals upheld an FTC opinion letter from November 2016 that extended robocalling restrictions to avatar soundboard technology. Companies that use this technology will be required to have prior written consent and comply with the prerecorded message requirements under the Telemarketing Sales Rule (TSR).

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