⚠ Penalty Exposure — Illinois
Per Violation
$50,000
Willful
$50,000
AG Max/Violation
$50,000
10,000 Calls
$500,000,000
= exposure
Overview
Illinois is one of the highest-risk states for outbound callers. The Restricted Call Registry Act (815 ILCS 413) maintains a state DNC list and imposes up to $50,000 per violation. Add BIPA (Biometric Information Privacy Act, 740 ILCS 14) — which creates massive class action exposure if you use voice biometrics or AI voice without consent — and Illinois becomes a litigation magnet. The AG runs aggressive telemarketing enforcement and class actions are common.
Consent Requirements by Channel
| Channel | Consent Required | One-to-One |
|---|---|---|
| Voice Call | Prior Express | — |
| SMS | Written Consent Required | Required |
| MMS | Written Consent Required | Required |
| AI Voice | Written Consent Required | Required |
| Prerecorded | Written Consent Required | Required |
| Ringless VM | Written Consent Required | Required |
| Fax | Written Consent Required | — |
Key Court Decisions
Blow v. Bijora, Inc.
6/10Northern District of Illinois · Apr 2023
BIPA and TCPA claims can proceed in parallel where telemarketing calls involve voice biometric data collection.
Recent Enforcement Actions
Sumco Panama / Roy Cox Jr. / Michael Aaron Jones
$299,997,000Aug 2023 · automotive
Largest fine in FCC history. International auto warranty scam placed 5.19 billion calls to 550 million phones in just 3 months (Jan-Mar 2021), using 1.05 million spoofed caller IDs. Illinois was among the hardest-hit states. After FCC ordered carriers to stop carrying this traffic, illegal auto warranty calls dropped 99%. Demonstrates that carrier-level enforcement (blocking at the network) is the most effective tool against massive robocall operations.
Yodel Technologies LLC
$400,000Jul 2023 · telecommunications
Part of FTC Operation Stop Scam Calls — largest crackdown on illegal telemarketing in FTC history (180+ actions). Yodel initiated 1.4 billion calls using leads from consent farms, with 500+ million to DNC numbers. $1M penalty (suspended to $400K after partial payment). Banned from telemarketing permanently. Key lesson: buying leads from "consent farm" websites does NOT constitute valid prior express written consent under the TSR.
Michael D. Lansky LLC d/b/a Avid Telecom
May 2023 · telecommunications
First legal action of the Anti-Robocall Multistate Litigation Task Force. Avid Telecom transmitted 24.5 billion calls (90%+ lasted under 15 seconds = robocalls), including 290 million to Illinois numbers and 7.5 billion to DNC-registered numbers. Used spoofed/invalid caller IDs including 8.4 million calls appearing to come from government agencies. VoIP providers that knowingly facilitate illegal traffic are now primary enforcement targets — not just the telemarketers themselves.
Key Rules
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This is a compliance reference tool, not legal advice. Data compiled from public statutes, LegiScan, CourtListener, state AG offices, and AI-assisted analysis. Verify all information with qualified counsel before relying on it. Full terms & data sources →