The Telephone Consumer Protection Act (“TCPA”) prohibits sending faxes without consent. It also applies to certain automated telephone calls made without prior consent. The TCPA is frequently the subject of class action litigation, as the liquidated damages permitted under the TCPA can be large. Capital One and other collection agencies have announced that they have agreed to settle claims brought under the TCPA, in which it was alleged that defendants had called individuals on their mobile phones without consent. Decl. of Jonathan D. Selbin, In re Capital One Tel. Consumer Prot. Act Litig., No. 12-CV-10064 (N.D. Ill. July 14, 2014) (ECF No. 131-1). The settlement is noteworthy for its amount: the total cash payments under the settlement exceed $75 million, the bulk of which is to be paid by Capital One. The settlement is awaiting preliminary approval.