YOU’RE WELCOME!: R.E.A.C.H. Brokered Ten-Business Day Revocation Rule Saves Hilton in TCPA Class Action

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Law Conference of Champions V ticket prices as I type: $589.00 (and rising.)

When a business is asked to stop calling or texting it must do so in order to comply with the TCPA. Like so much else under the statute, however, the rules related to revocation of consent are constantly shifting.

At one point not long ago the FCC had proposed limiting revocation timing to just 24 hours– meaning a business would have to honor revocation requests nearly immediately– a difficult task for major enterprises using multiple contact channels and platforms.

Most business interests countered that the rule should be 30 days– a much-to-long period the then-Democratic-leaning Commission was never going to grant.

Responsible Enterprises Against Consumer Harassment (R.E.A.C.H.) came in and propose a compromise position– 10 business days. Recognizing the reasonableness of the proposal the FCC eventually adopted R.E.A.C.H.’s proposed timeframe and updated the CFR provisions in accord.

Flash forward to Tuesday of this week.

Hilton Resorts is facing a major TCPA class action over allegations it failed to honor opt out requests.

A consumer had apparently received over a dozen unwanted marketing messages after requesting that they stop.

However, Hilton had complied with the 10 business day rule R.E.A.C.H. had brokered for the industry– and the result was fantastic.

In Plenty v. Hilton, 2026 WL 3411213 (E.D. Wash. Nov. 10, 2026) the court dismissed Plaintiff’s claims against Hilton concluding that because Hilton had stopped messaging within the ten business day requirement of the regulations it could not be held liable.

So… case dismissed. Thanks directly to the hard work of R.E.A.C.H.

You’re welcome Hilton.

I will say the 10-business day rule is under attack currently– a new FCC proposal might limit the rule to 7 days (or even less.)

Please join R.E.A.C.H. today and help us to push back on this rule change– and many others that may make it more difficult for consumers to receive the contact they desire.

Speaking of difficult– have you seen repeat TCPA litigator Nathen Barton on Deserve to Win Ep. 57? This guy has brought over 50 TCPA suits–without a lawyer!– and even won a jury trial. He talks to us for nearly an hour about his experiences and you will DEFINITELY want to tune in and see what makes this guy tick.

Chat soon.

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Published by Eric "Czar" Troutman

The Czar of TCPAWorld Eric Troutman is one of the country’s prominent class action defense lawyers and is nationally recognized in Telephone Consumer Protection Act (TCPA) litigation and compliance. He has served as lead defense counsel in more than 70 national TCPA class actions and has litigated nearly a thousand individual TCPA cases in his role as national strategic litigation counsel for major banks and finance companies. He also helps industry participants build TCPA-compliant processes, policies, and systems. Eric has built a national litigation practice based upon deep experience, rigorous analysis and extraordinary responsiveness. Eric and his team feel equally at home litigating multibillion dollar telecommunications class actions in federal court as they do developing and executing national litigation strategies for institutions facing an onslaught of individual TCPA matters. They thrive in each of these roles – delivering consistently excellent results – while never losing sight of the client experience. While many firms now tout TCPA expertise, Eric has been there from the beginning. He built one of the country’s first TCPA-only defense teams and began serving as national TCPA counsel for his clients nearly a decade ago. This perspective allows him to swiftly develop the right litigation strategies for dealing with recurring problems, without wasting time on tactics that are bound to fail. Eric’s rich historical perspective and encyclopedic knowledge of the TCPA landscape also make him an invaluable resource to institutional compliance teams struggling to comply with the shifting regulatory landscape. No task is too small – or too big. Indeed, Eric and his team have helped build TCPA-compliant systems and processes for some of the largest and most complex corporate entities in the country. He commonly works with in-house compliance counsel to build and implement enterprise and business-line specific TCPA solutions, performs TCPA audits and drafts and reviews proposed TCPA policies and procedures. He and his team also have the technical expertise necessary to assist call centers seeking to develop TCPA-resistant call path architecture or to modify existing telephony and software integration to better insulate from potential TCPA exposure. Eric has built a reputation for thought leadership. An avid blogger and speaker, he has been at the forefront of the industry’s effort to push for clarity and a return to sanity for the TCPA for years. He was selected to advocate for the financial services industry on important TCPA issues before the Federal Communications Commission and co-authored the nation’s only comprehensive practice guide on TCPA defense. In his spare time, Eric leads defense teams representing banks and other financial services companies in consumer finance litigation matters. He has experience representing clients in UCC, TILA, RESPA FCRA, CCRA, CLRA, FDCPA, RFDCPA and FCCPA claims, as well as in fraud and bank operations issues.

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