In Gager v. Dell Financial Services, LLC, Case No: 12-2823 (U.S. Court of Appeals, Third Circuit, order entered August 22, 2013), the U.S. Court of Appeals for the Third Circuit held that the Telephone Consumer Protection Act (“TCPA”) allows consumers to revoke “prior express consent” to receive automated calls on their cell phones at any time.  The court rejected defendant’s argument there was no right to revoke consent since the law was silent on revocation. This is the first decision on these issues by any federal or state appeals court.