TCPA / CIPA Violation Demand Letter - California

TELEPHONE CONSUMER PROTECTION ACT AND

CALIFORNIA INVASION OF PRIVACY ACT

VIOLATION DEMAND LETTER

SENT VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED
AND FIRST-CLASS MAIL

[__/__/____]

[DEFENDANT COMPANY LEGAL NAME]
ATTN: Legal Department / Compliance Officer / Registered Agent
[DEFENDANT PRINCIPAL ADDRESS]
[CITY, STATE ZIP]

[DEFENDANT CALIFORNIA REGISTERED AGENT (IF DIFFERENT)]
[REGISTERED AGENT ADDRESS]
[CITY, CALIFORNIA ZIP]

Re: DEMAND — TCPA, CIPA, CLRA AND UCL VIOLATIONS — UNAUTHORIZED TELEPHONE COMMUNICATIONS
Consumer: [CONSUMER FULL NAME]
Telephone Number(s) Affected: [________________________________]
Type of Number: ☐ Cellular ☐ Residential Landline ☐ VoIP
Approximate Number of Violations: [________________________________]
Date Range of Violations: [__/__/____] to [__/__/____]
CLRA 30-Day Notice Date: [__/__/____]

Dear Sir or Madam:

This law firm represents [CONSUMER FULL NAME] ("Consumer" or "Client") in connection with your company's systematic violations of the Telephone Consumer Protection Act ("TCPA"), 47 U.S.C. § 227; the California Invasion of Privacy Act ("CIPA"), Cal. Penal Code § 630 et seq.; the California Consumer Legal Remedies Act ("CLRA"), Cal. Civ. Code § 1750 et seq.; and the California Unfair Competition Law ("UCL"), Cal. Bus. & Prof. Code § 17200 et seq.

Please direct all further communications regarding this matter exclusively to our office. Immediately and permanently cease all telephone calls, text messages, and automated communications to our Client.

CLRA NOTICE: Pursuant to California Civil Code Section 1782(a), this letter constitutes formal 30-day written notice of violations of the Consumer Legal Remedies Act. If your company does not provide appropriate remedies within 30 days of this letter, our Client will file suit seeking actual damages, punitive damages, injunctive relief, and mandatory attorney's fees under the CLRA.

I. CALIFORNIA LEGAL FRAMEWORK

California provides layered consumer protections against unauthorized telephone communications that significantly exceed federal TCPA remedies. A California plaintiff may simultaneously assert federal TCPA claims ($500-$1,500 per violation) and California CIPA claims ($5,000 per violation), as well as CLRA and UCL claims for additional relief. The combined exposure in California often dwarfs exposure in other states.

A. Federal TCPA — 47 U.S.C. § 227

The Telephone Consumer Protection Act prohibits:

1. Automated Calls/Texts to Cell Phones (§ 227(b)(1)(A)(iii)): Making any call using an automatic telephone dialing system (ATDS) or an artificial or prerecorded voice to any telephone number assigned to a cellular telephone service, without the prior express consent of the called party.

2. Calls to Residential Numbers Using Prerecorded Messages (§ 227(b)(1)(B)): Initiating any telephone call to a residential telephone line using an artificial or prerecorded voice message without prior express consent.

3. Telemarketing to Numbers on Do-Not-Call Registry (§ 227(c)): Making telemarketing calls to telephone numbers registered with the National Do-Not-Call (DNC) Registry or on the company's internal DNC list.

TCPA Statutory Damages:

• $500 per violation for each unauthorized call or text
• $1,500 per violation for each willful or knowing violation — 47 U.S.C. § 227(b)(3)(C)

ATDS Definition Post-Facebook, Inc. v. Duguid (2021): Following the Supreme Court's decision in Facebook, Inc. v. Duguid, 141 S.Ct. 1163 (2021), an ATDS is equipment that uses a random or sequential number generator either to store or produce telephone numbers to be called. The Ninth Circuit has applied this definition in cases involving California-resident plaintiffs. See Borden v. eFinancial, LLC, 53 F.4th 1230 (9th Cir. 2022).

Note: Prerecorded/artificial voice messages sent to cellular phones remain independently actionable under § 227(b)(1)(A) regardless of whether the equipment qualifies as an ATDS under Duguid. Evidence of prerecorded delivery is sufficient.

TCPA Statute of Limitations: 4 years from the date of violation — 28 U.S.C. § 1658(a).

B. California Invasion of Privacy Act (CIPA) — Cal. Penal Code §§ 630-638.55

The California Invasion of Privacy Act provides some of the strongest telephone privacy protections in the United States. Its stated purpose is to "protect the right of privacy of the people of this state." Cal. Penal Code § 630.

1. Cal. Penal Code § 632 — All-Party Consent to Recording

California is an all-party (two-party) consent state for recording of confidential communications. Section 632 prohibits the intentional recording of a confidential communication without the consent of all parties. "Confidential communication" means any communication made under circumstances reasonably indicating that any party desires it to be confined to the parties present.

Application: Recordings of consumer telephone calls by your company — including quality-assurance recordings — without disclosure and consent of the consumer violate § 632. Each recorded call is an independent violation.

2. Cal. Penal Code § 632.7 — Recording Cellular and Cordless Communications

Section 632.7 independently prohibits the intentional recording of any communication transmitted between a cellular telephone and any other device, without the consent of all parties. Unlike § 632, there is no "confidential communication" requirement — any cellular call recording without all-party consent violates § 632.7.

Application: Prerecorded messages delivered to cellular phones, automated voicemails, and recorded customer service calls to cellular numbers are independently actionable under § 632.7, even if the consumer is not personally on the line when the recording is made.

3. Cal. Penal Code § 637.2 — Private Right of Action and $5,000 Per Violation

Section 637.2 provides an explicit private right of action for any person injured by a violation of CIPA:

• $5,000 per violation, OR
• Three (3) times actual damages, whichever is greater
• Injunctive relief to prevent further violations
• Attorney's fees and costs

Key Distinction from Federal TCPA: CIPA's $5,000-per-violation statutory remedy is 10x the TCPA's $500 standard remedy. Where TCPA and CIPA violations overlap (e.g., prerecorded message to a cellular phone), California plaintiffs may assert both claims for the same call, subject to offset for double recovery. California courts have permitted stacking of TCPA and CIPA claims. See Jance v. Homerun Offer LLC, 2021 WL 3270154.

CIPA Statute of Limitations: 3 years — Cal. Code Civ. Proc. § 338(a).

C. California Automatic Dialing-Announcing Device Law — Cal. Pub. Util. Code §§ 2871-2883

California separately regulates Automatic Dialing-Announcing Devices (ADADs) through the California Public Utilities Commission (CPUC). An ADAD is any device or system that automatically dials telephone numbers and plays a recorded message.

Key CPUC ADAD Requirements:

Violations of the CPUC ADAD rules are subject to PUC-imposed fines and may support UCL "unlawful" business practices claims. Unregistered ADADs subject operators to civil penalties per § 2883.

D. California Consumer Legal Remedies Act (CLRA) — Cal. Civ. Code § 1750 et seq.

The CLRA prohibits unfair and deceptive practices in connection with the sale or lease of goods or services to consumers. Where your company's telephone contacts were made to market goods or services, the CLRA provides additional remedies:

Relevant CLRA Prohibitions (Cal. Civ. Code § 1770):

☐ § 1770(a)(3) — Misrepresenting the source, sponsorship, approval, or certification of goods or services
☐ § 1770(a)(5) — Representing that goods/services have sponsorship, approval, or characteristics they do not have
☐ § 1770(a)(9) — Advertising goods/services with intent not to sell them as advertised
☐ § 1770(a)(14) — Representing a transaction confers rights that it does not

CLRA Remedies — Cal. Civ. Code § 1780:

• Actual damages
• Punitive damages (where malice, oppression, or fraud is shown)
• Injunctive and declaratory relief
• Restitution of property
• Mandatory attorney's fees to prevailing plaintiff — Cal. Civ. Code § 1780(e)

30-Day Pre-Suit Notice Requirement: Before filing a CLRA damages action, the consumer must provide 30 days' written notice. This letter constitutes that notice. Cal. Civ. Code § 1782(a). CLRA injunctive relief claims may be filed immediately without notice.

E. California Unfair Competition Law (UCL) — Cal. Bus. & Prof. Code § 17200 et seq.

The UCL prohibits any unlawful, unfair, or fraudulent business act or practice.

Three Prongs of UCL Liability:

1. Unlawful — Any violation of another law (TCPA, CIPA, CLRA, ADAD) constitutes an "unlawful" business practice under the UCL
2. Unfair — Practices that offend public policy or cause harm to consumers disproportionate to any benefit
3. Fraudulent — Practices likely to deceive members of the public

UCL Remedies:

• Restitution — Return of money acquired through unfair/unlawful practice — Cal. Bus. & Prof. Code § 17203
• Disgorgement — Of profits obtained through unlawful conduct
• Injunctive relief — Including public injunctive relief, which may not be compelled to arbitration — McGill v. Citibank, N.A. (2017) 2 Cal.5th 945

UCL Statute of Limitations: 4 years — Cal. Bus. & Prof. Code § 17208.

F. Rosenthal Fair Debt Collection Practices Act — Cal. Civ. Code § 1788 et seq. (If Applicable)

☐ [Check if applicable] If your company's calls were made in connection with the collection of a consumer debt, the Rosenthal Fair Debt Collection Practices Act ("Rosenthal Act"), Cal. Civ. Code § 1788 et seq., applies. The Rosenthal Act extends federal FDCPA protections to ALL debt collectors in California (not just third-party collectors as under federal law) and provides:

• Statutory damages of $100-$1,000 per action — Cal. Civ. Code § 1788.30(b)
• Actual damages for emotional distress — Cal. Civ. Code § 1788.30(a)
• Attorney's fees to prevailing plaintiff — Cal. Civ. Code § 1788.30(c)
• Statute of limitations: 1 year from last violation — Cal. Civ. Code § 1788.30(f)

G. California Attorney General Enforcement Authority

The California Attorney General may bring enforcement actions under:

• Cal. Penal Code § 637.2 (CIPA) — AG may seek injunctive relief and civil penalties
• Cal. Bus. & Prof. Code § 17200 et seq. (UCL) — AG may seek restitution, injunctive relief, and penalties up to $2,500 per violation — Cal. Bus. & Prof. Code § 17206
• Prior AG enforcement actions against your company: [________________________________] (if known)

II. STATEMENT OF FACTS

A. Consumer and Account Information

B. Consent Status

Our Client:

☐ Never provided any form of consent to receive calls, texts, or prerecorded messages from your company

☐ Never provided prior express written consent for telemarketing communications as required by 47 C.F.R. § 64.1200(a)(2) for autodialed or prerecorded telemarketing calls/texts

☐ Provided limited consent for one purpose (specifically: [________________________________]) that did not extend to the communications received

☐ Revoked all prior consent on [__/__/____] by [________________________________] (verbal request / written request / text-message opt-out reply / email)

☐ Acquired this telephone number after any consent was given. The number was assigned to our Client on approximately [__/__/____]. Our Client never consented to calls from your company.

☐ The purported consent was obtained through deceptive practices — specifically: [________________________________]

C. Detailed Call and Text Log

[Continue or attach separate log as Exhibit A]

Total Documented Violations: [________________________________]
Estimated Additional Violations (not yet documented): [________________________________]

D. Evidence of Automated Dialing Equipment

The following characteristics indicate use of an ATDS, ADAD, or prerecorded/artificial voice:

☐ Clearly prerecorded or synthetic voice message — no live human response when consumer answered
☐ Characteristic "dead air" or pause before a live agent connected (click-delay indicating predictive dialer)
☐ Identical or nearly identical message content across multiple separate calls
☐ Generic script with no individualized reference to our Client's account
☐ Calls received at regular automated intervals (e.g., same time each day, every 48 hours)
☐ Calls/texts originating from rotating caller ID numbers (spoofed or rotated)
☐ Company website or marketing materials reference "automated outreach," "dialer technology," or similar
☐ SEC filings or press releases reference automated calling platform
☐ Third-party platform (e.g., [________________________________]) used for campaigns
☐ Simultaneous calls to multiple family members using same household data
☐ Other: [________________________________]

III. LEGAL ANALYSIS

A. TCPA — Autodialed and Prerecorded Calls (47 U.S.C. § 227(b)(1))

Your company made [________________________________] calls and/or sent [________________________________] text messages to our Client's cellular telephone number using an automatic telephone dialing system and/or an artificial or prerecorded voice, without our Client's prior express consent. Each such communication is an independent violation of 47 U.S.C. § 227(b)(1)(A)(iii), subject to $500 in statutory damages, increased to $1,500 for willful or knowing violations.

B. TCPA — Do-Not-Call Violations (47 U.S.C. § 227(c))

☐ Our Client's telephone number was registered on the National Do-Not-Call Registry on [__/__/____]. Your company made [________________________________] telemarketing calls after that date, each constituting an independent violation of 47 U.S.C. § 227(c)(5), subject to $500/$1,500 statutory damages.

☐ Our Client submitted a company-specific do-not-call request on [__/__/____]. Your company continued calling after that date in violation of 47 C.F.R. § 64.1200(d)(3).

C. California Invasion of Privacy Act — CIPA Analysis

§ 632 All-Party Consent Violations:

☐ Your company recorded telephone calls with our Client without disclosing the recording or obtaining our Client's consent. California requires the consent of all parties to record any confidential communication. Each recorded call constitutes a separate CIPA violation subject to $5,000 in statutory damages under Cal. Penal Code § 637.2(a).

§ 632.7 Cellular Communication Recording Violations:

☐ Your company recorded, monitored, or caused the delivery of prerecorded messages to our Client's cellular telephone without our Client's consent. Section 632.7 requires all-party consent for cellular communication recordings regardless of whether the communication is "confidential." Each such communication is an independent violation subject to $5,000 in statutory damages.

CIPA Does Not Require Confidentiality for § 632.7: Unlike § 632, which applies to "confidential communications," § 632.7 applies to all cellular communications recorded without consent. This distinction makes § 632.7 broader and easier to establish than a § 632 claim.

California Courts and the § 632.7 Prerecorded Voicemail Issue:

Courts applying California law have held that prerecorded voicemail messages delivered to cellular phones — where the message is recorded before delivery and the consumer does not consent — constitute recordable communications under § 632.7. See Coles v. U.S. Life Ins. Co., No. 2:17-cv-07467 (C.D. Cal.). Each prerecorded voicemail left on our Client's cellular phone is thus independently actionable under CIPA.

D. CPUC Automatic Dialing-Announcing Device Violations

☐ Your company used an ADAD to contact our Client without registering with the California Public Utilities Commission as required by Cal. Pub. Util. Code § 2872.
☐ Your company used an ADAD to call our Client outside the permitted hours of 9:00 a.m. to 9:00 p.m. local time — § 2874.
☐ Your company failed to provide required caller identification — § 2876.
☐ Your company's ADAD messages did not include a required opt-out mechanism — § 2877.

Violations of the CPUC ADAD statute constitute "unlawful" business practices under the UCL, Cal. Bus. & Prof. Code § 17200.

E. Willful and Knowing Violations — Enhanced Damages

TCPA violations are "willful or knowing" — triggering $1,500 per violation — where the defendant continued calling after being placed on notice. CIPA does not require willfulness for the $5,000 per violation remedy.

Your violations were willful because:

☐ You continued calling our Client after our Client explicitly revoked consent on [__/__/____] by [________________________________]
☐ You continued calling after our Client requested placement on your do-not-call list on [__/__/____]
☐ You continued calling a number registered on the National DNC Registry
☐ Your company has been the subject of prior TCPA complaints filed with the FCC (FCC Complaint No. [________________________________])
☐ Your company has been named in prior TCPA/CIPA litigation: [________________________________]
☐ Your company was subject to FTC or state AG enforcement: [________________________________]
☐ Other evidence of willfulness: [________________________________]

IV. DAMAGES CALCULATION

A. Federal TCPA Statutory Damages — 47 U.S.C. § 227(b)(3)

B. California Invasion of Privacy Act Damages — Cal. Penal Code § 637.2

Note on Stacking: California plaintiffs may assert both TCPA and CIPA claims for the same call. Courts have generally permitted this, subject to equitable offsets against double recovery of actual damages. Because CIPA statutory damages ($5,000) far exceed TCPA statutory damages ($500-$1,500), the CIPA exposure dominates the analysis.

C. CLRA Damages — Cal. Civ. Code § 1780

D. Rosenthal Act Damages (If Debt Collection) — Cal. Civ. Code § 1788.30

E. Total Damages Summary

V. PRESERVATION OF EVIDENCE

You are hereby directed to immediately preserve all documents and electronically stored information related to our Client and your company's calling practices, including:

• All call records (outbound and inbound), dialer logs, and CDRs related to our Client's telephone number(s)
• All text message records, campaign data, and delivery receipts
• All consent records — including any lead generation forms, website click-through records, or affiliate-sourced consent documentation
• Your company's internal and external Do-Not-Call lists and opt-out processing records
• Your company's California CPUC ADAD registration documentation
• All calling platform data, including dialer software configuration files, campaign settings, and vendor agreements
• All TCPA and CIPA compliance policies, training materials, and compliance reports
• All prior consumer complaints (written, phone, email, social media) related to unauthorized calls
• All FCC, FTC, CPUC, or California AG inquiries, investigations, and enforcement correspondence
• All vendor agreements with lead generators, list brokers, and third-party dialing services
• Records of any prior TCPA, CIPA, or Rosenthal Act litigation involving your company

California recognizes independent tort claims for intentional spoliation of evidence. Cedars-Sinai Med. Ctr. v. Superior Court (1998) 18 Cal.4th 1. Intentional destruction, alteration, or concealment of evidence may result in adverse jury instructions, evidentiary sanctions, and independent damages claims.

VI. DEMAND FOR SETTLEMENT

To resolve this matter without litigation, we demand the following within thirty (30) days:

A. Monetary Compensation

Payment of $[________________________________] as full settlement of our Client's claims, representing:

B. Injunctive Relief (Non-Monetary Demands)

1. Permanent, unconditional removal of our Client's telephone number(s) from all calling lists, text message campaigns, and marketing databases
2. Placement of our Client's number(s) on your company's internal Do-Not-Call list
3. Written confirmation (signed by a compliance officer) within 5 business days confirming: (a) removal from all calling databases, (b) placement on internal DNC list, and (c) notation in our Client's account record
4. Confirmation that no third-party vendors or lead generators with whom you share data will contact our Client

VII. RESPONSE REQUIRED

Please respond to this demand in writing within thirty (30) days of the date of this letter. Your written response must include:

1. The identity of your calling platform, software vendor, and/or third-party dialing service
2. The source from which your company obtained our Client's telephone number
3. All consent records your company claims to possess relating to our Client
4. Your company's California CPUC ADAD registration number (if applicable)
5. A written settlement offer
6. Written confirmation of immediate cessation of all communications to our Client

If no satisfactory response is received within 30 days, our Client is authorized to file suit in:

• California Superior Court, County of [________________________________], or
• United States District Court for the [Northern / Central / Southern / Eastern] District of California

without further notice.

VIII. CLASS ACTION INVESTIGATION

We are presently investigating whether your company's calling practices have affected other California consumers in a manner substantially similar to our Client's experience. California has among the most plaintiff-favorable class action rules in the United States, and TCPA/CIPA class actions have been certified and resolved for substantial aggregate recoveries in California federal and state courts. If the evidence warrants, our Client may pursue a class action in addition to, or instead of, an individual claim.

We also reserve the right to seek public injunctive relief under the UCL on behalf of the general public. Such claims are non-arbitrable under McGill v. Citibank, N.A. (2017) 2 Cal.5th 945 and cannot be stripped by any arbitration clause in your terms of service.

IX. CONCLUSION

California provides some of the most substantial remedies for telephone privacy violations in the nation. The California Invasion of Privacy Act's $5,000 per violation statutory damages, combined with federal TCPA damages, attorney's fees under the CLRA, and UCL restitution, creates substantial exposure for companies that engage in systematic unauthorized calling.

We strongly encourage your company to resolve this matter promptly. The cost of settlement is a fraction of the cost of California litigation.

This letter is written without prejudice to any and all rights and remedies of our Client, all of which are expressly reserved.

Respectfully submitted,

[LAW FIRM NAME]

By: [________________________________]
[ATTORNEY NAME]
State Bar of California No. [________________________________]
[STREET ADDRESS]
[CITY, CALIFORNIA ZIP]
Telephone: [________________________________]
Email: [________________________________]

Attorneys for [CONSUMER FULL NAME]

ENCLOSURES:

☐ Call/text log with dates, times, and descriptions (Exhibit A)
☐ Telephone billing records / carrier records
☐ Screenshots of text messages
☐ Voicemail recordings (digital file or USB drive)
☐ National DNC Registry confirmation printout
☐ Written revocation of consent (if applicable)
☐ Screenshots of website / lead form (if applicable)
☐ Authorization to represent client

cc: [CONSUMER FULL NAME], c/o [ADDRESS]
California Attorney General — Consumer Protection Section (oag.ca.gov)
Federal Trade Commission (donotcall.gov)
FCC Consumer Complaints (consumercomplaints.fcc.gov)
[CLIENT FILE]

CALIFORNIA-SPECIFIC PRACTICE NOTES

☐ CIPA § 637.2 Is the Dominant California Remedy: At $5,000 per violation, CIPA statutory damages dwarf federal TCPA damages. Always plead CIPA § 632.7 alongside TCPA § 227(b) for prerecorded cellular calls. For 20 such calls, exposure is $100,000 under CIPA versus $10,000-$30,000 under TCPA alone.

☐ Two-Party Consent (All-Party in California): California requires consent of ALL parties to record a telephone call. This is broader than federal law. Any quality-assurance recording without disclosure is an independent CIPA violation.

☐ CLRA 30-Day Notice Is Mandatory for Damages: Do not skip the 30-day notice if filing CLRA damages claims. Injunctive relief under the CLRA can be filed immediately. See Cal. Civ. Code § 1782(c).

☐ UCL Public Injunctive Relief Cannot Be Arbitrated: Under McGill v. Citibank, any UCL claim for public injunctive relief is non-arbitrable. This prevents defendants from forcing all claims into individual arbitration.

☐ Class Actions Are Efficient in California: California superior courts and the Northern and Central Districts of California have extensive experience certifying TCPA/CIPA class actions. Individual and class claims are often pursued together.

☐ California AG Has CIPA Enforcement Authority: Prior AG actions against the same defendant are admissible as willfulness evidence. Check AG press releases and the CalAG enforcement database.

☐ Rosenthal Act Covers All California Debt Collectors: Unlike federal FDCPA (which covers only third-party debt collectors), the Rosenthal Act extends to original creditors collecting their own debts. Always assess Rosenthal Act applicability in debt-related calling cases.

☐ Prejudgment Interest Under Cal. Civ. Code § 3291: Available in personal injury (emotional distress) CIPA claims from the date the complaint is filed. Consider pleading emotional distress damages.

☐ Small Claims Option: California Small Claims Court limit is $12,500 (individuals). For fewer violations where damages are under $12,500, Small Claims is fast and efficient. However, CLRA and UCL attorney's fees are not available in Small Claims.

☐ Evidence Preservation: Request call records from the consumer's carrier (Verizon, AT&T, T-Mobile) via subpoena or informal request. Phone billing records often identify calls by date, time, and number better than self-reported logs.

SOURCES AND REFERENCES

• TCPA, 47 U.S.C. § 227: https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title47-section227
• FCC TCPA Rules, 47 C.F.R. § 64.1200: https://www.ecfr.gov/current/title-47/chapter-I/subchapter-B/part-64/subpart-L
• California Invasion of Privacy Act, Cal. Penal Code §§ 630-638.55: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=632.7.&lawCode=PEN
• Cal. Penal Code § 637.2 (private right of action): https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=637.2.&lawCode=PEN
• CPUC ADAD Rules, Cal. Pub. Util. Code §§ 2871-2883: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=2871.&lawCode=PUC
• CLRA, Cal. Civ. Code § 1750: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1750.&lawCode=CIV
• UCL, Cal. Bus. & Prof. Code § 17200: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=17200.&lawCode=BPC
• Rosenthal FDCPA, Cal. Civ. Code § 1788: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1788.&lawCode=CIV
• Facebook, Inc. v. Duguid, 141 S.Ct. 1163 (2021): https://www.supremecourt.gov/opinions/20pdf/19-511_p86b.pdf
• McGill v. Citibank, N.A. (2017) 2 Cal.5th 945: https://law.justia.com/cases/california/supreme-court/2017/s224699.html
• California AG — Consumer Protection: https://oag.ca.gov/consumers/complaints
• FCC Consumer Complaints (TCPA): https://consumercomplaints.fcc.gov
• National Do-Not-Call Registry: https://www.donotcall.gov
• CPUC Consumer Information: https://www.cpuc.ca.gov/consumer/complaints/

This template is for informational purposes only and does not constitute legal advice. California telephone privacy law is highly technical. This letter also serves as CLRA 30-day pre-suit notice. Consult a licensed California attorney before use.