By Matthew Rosenkoff ( July 3, 2017, 10:22 AM EDT) -- Recently, the U.S. Court of Appeals for the Second Circuit held that the Telephone Consumer Protection Act "does not permit a consumer to revoke its consent to be called when the consent forms part of a bargained-for exchange." See Reyes v. Lincoln Automotive Financial Services, No. 16-2104-cv, 2017 U.S. App. LEXIS 11057 (2d Cir. June 22, 2017). This decision comes almost two years after the Federal Communications Commission issued its omnibus order which applied a common-sense approach to revocation and clarified that consumers may revoke consent through any reasonable means. See In the Matter of Rules & Regulations Implementing the Telephone Consumer Protection Act of 1991, 30 F.C.C. Rcd. 7961, 7993-94 (2015) (hereinafter "2015 FCC ruling"). Naturally, one might read Reyes to provide justification for ignoring revocation requests in certain circumstances. However, the practical applicability of Reyes may, in fact, be minor because it is unclear whether it will have broader application and, even if it does, other statutory violations still lurk....