With the aggressive pace of technological change and the seeming onslaught of news regarding data breaches, cyberattacks, and technological threats to privacy and security, it is easy to mistakenly assume these are fundamentally new threats. In fact, the pace of technological change is perhaps slower than it feels, and many of these seemingly new categories of threats have been with us longer than we remember. “Nervous System” is a bimonthly blog that approaches issues of data privacy and cybersecurity from the context of history—to look to the past for clues about how to interpret the present and prepare for the future.

Within hours after the FCC issued the 2015 TCPA Omnibus Declaratory Ruling and Order, lawyers for the Association of Credit and Collection Professionals (ACA) International filed a petition for review seeking clarity on several crucial issues. Years later, the world of TCPA litigators is still collectively holding its breath, awaiting a ruling to answer an age-old question: Just what is an autodialer?

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