Here is the FCC’s ruling regarding agency liability under the TCPA. The FCC declared that sellers “may be held vicariously liable under federal common law principles of agency including not only formal agency, but also principles of apparent authority and ratification” – opining that vicarious liability would incentivize companies to police TCPA compliance by third party vendors and telemarketers. The FCC declined to extend vicarious liability to calls made merely “to aid or benefit the seller,” if an agency relationship does not exist between the seller and the third-party.