In Charvat v. NMP, the Sixth Circuit split the baby. Noting the differing language in the TCPA’s provision providing for private causes of action for automated/prerecorded-call and other technical violations, as compared to that providing the private cause of action for do-not-call violations, it held that statutory damages for do-not-call violations are limited to $500 per call ($1500 where willful), but for other types of violations, each separate failure to comply – even if on the same call – are separately compensable. As quickly as statutory TCPA damages can add up, especially where companies may place multiple calls to a given number, this ruling makes them add up that much faster if the calls involve violations of anything other than the do-not-call restrictions.