the other hand, is more difficult to immediately dismiss as an automated message." In October 2020, the Northern District of Ohio found the TCPA was unconstitutional from 2015 through 2020 due to the "government-debt" exception, which exempted calls made to collect a debt owed or guaranteed by the United States. The defective provision was severed from the TCPA in 2020. The Ohio court reasoned the severance did not apply retroactively, so the court lacked jurisdiction over all claims from 2015 through 2020. In December 2020, the District Court for the Southern District of Ohio found that a consumer can revoke consent to be contacted by the holder of a debt, and a third party debt collector calling on behalf of the holder can be held liable for TCPA violations even if the revoked consent was not communicated to the third party debt collector. Specifically the court found "[a] third party debt collection agency is liable for autodialed calls under the TCPA when the consumer has revoked his prior express consent to be called, even when that revocation has not been communicated to the debt collector or the debt collector otherwise fails to confirm the consumer has consented to calls." Andrew Perrong has filed at least 45 TCPA lawsuits against a wide variety of businesses, ranging from chimney sweeps and collection agencies to large businesses like Verizon and Citibank. Perrong has demanded tens of thousands of dollars in some cases, and most of his suits are settled quickly. It is unknown how much money Perrong has made from his settlements. His first settlement occurred in 2015 while a senior at La Salle College High School. In the Supreme Court decision Facebook v. Duguid (2021), the Court established that for a device to qualify as an "automatic telephone dialing system", it must be based on the capacity to store or produce numbers from a random or sequential generator. The case ruled that an automatic system that may phone a user from a stored number but otherwise not generated in a random or sequential way (such as for two-factor authentication) does not meet this definition under the TCPA. FCC Actions Since 2015, the Federal Communications Commission has ordered violators of the TCPA to pay $208.4 million. The sum includes forfeiture orders in cases involving robocalling, Do Not Call Registry and telephone solicitation violations. According to records obtained by The Wall Street Journal, the