The TCPA was passed by the United States Congress in 1991 and signed into law by President George H. W. Bush. The TCPA restricts telephone solicitations and the use of automated telephone machinery for calls to personal home phones. With the creation and use of automated calling machines that could use a prerecorded message to solicit a person to the point of all most harassment. The TCPA was necessary to control these calls, the Telephone Consumer Protection Act was created to limit the use of automatic dialing systems, automated or prerecorded voice messages, SMS text, and fax machines. This act also put some rules into play like setting perimeters of when customers could be called and required solicitors to maintain a “do not call” list of the persons who did not want to be contacted and they had to honor that list for 5 years. This original do not call list were somewhat ineffective due to a consumer having to make a request for each telemarketer. The burden for registering with each telemarketer was lifted by the signing of the