In Reyes v. Lincoln Automotive Financial Services, the Second Circuit was asked to address whether the Telephone Consumer Protection Act (“TCPA”) “permits a consumer to unilaterally revoke his or her consent to be contacted by telephone when that consent is given, not gratuitously, but as bargained-for consideration in a bilateral contract.” 861 F.3d 51 (2d Cir. 2017). The court held the TCPA does not allow revocation of consent in these narrow circumstances.