On September 24, 2019, the District of Massachusetts held in Katz v. Liberty Power Corp., LLC that the government debt collection exemption to the Telephone Consumer Protection Act (“TCPA”), 47 U.S.C. §§ 227 et seq., is an unconstitutional violation of the First Amendment. No. 18-cv-10506-ADB, 2019 WL 4645524 (D. Mass. Sept. 24, 2019).