CALABRESI, Circuit Judge:
Background
This case centers on the intersection of four laws: (a) the federal Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, which provides a statutory penalty of $500 for each instance of unsolicited, commercial fax transmission and a federal cause of action "if otherwise permitted by the laws or rules of court of a State." Id. § 227(b)(3) (emphasis added); (b) New York C.P.L.R. 901(b), which prohibits...
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