In January of this year, NorthStar Alarm Services, LLC filed a petition with the FCC asking the agency to rule that soundboard technology, also known as avatar, does not fall under the definition of a prerecorded message under the TCPA. Soundboard technology functions by allowing a live caller to converse with a call recipient by using prerecorded voice snippets to carry on the conversation. Specifically, NorthStar asked the FCC to rule that: "1) The use of soundboard technology does not constitute the use of an artificial or prerecorded voice that delivers a message under the TCPA; or, in the alternative, 2) The use of soundboard technology on a one-to-one basis, whereby the soundboard agent conducts only one call with one individual at a single time, does not constitute the use of an artificial or prerecorded voice that delivers a message under the TCPA."

Early last week, the FCC sent out a request for comments on this petition. Comments are due on March 15th, and reply comments are due on March 29th. Read the FCC's full request for comments here. Commenting instructions are included in the request.