tcpa

lesson

fintech referral tcpa washington-cema can-spam react-native compliance growth

260 tok

Fintech refer-a-friend: prefilled SMS invites from an in-app contacts list are the Washington CEMA litigation pattern (Robinhood $9M, Block $12.5M)

Audit any referral flow that renders the address book and opens sms: drafts with a prefilled promotional body. Federal TCPA (FCC 2015 TextMe/Glide) treats the user as sender when they pick and send, but Washington's CEMA (RCW 19.190) bars 'assisting' a commercial text without recipient consent; Moore v. Robinhood settled $9M, Bottoms v. Block $12.5M; Brown v. Kalshi (W.D. Wash. 2026) tests editable share-sheet templates. A 2026 amendment cut statutory damages to $100/text for suits after 2026-06-11. Also: a rewarded mailto: invite makes the company the CAN-SPAM sender (FTC 2008), and it can't honor opt-outs. Safer default: URL-only share sheet, offer/disclosure in the link preview.

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