original before “transaction.” It instead says that the debtor has given his consent when he gives his number “during the transaction” that involves the debt (ie., “regarding the debt”). 23 F.C.C. Red. at 564-65, 567 (emphasis added). This language does not change the general definition of express consent; it instead “emphasize[s]” that creditors can call debtors only “to recover payment for obligations owed,” not on any topic whatsoever. See id. at 564, 565 n. 36. So it ensures that a debtor who gives his number outside the context of the debt has not given his consent to be called regarding the debt. FCC’s Letter Brief, Re: Nigro v. Mercantile Adjustment Bureau, LLC, 2014 WL 3612689, at *8-*9 (C.A.2); see Nigro v. Mercantile Adjustment Bureau, LLC, 769 F.3d 804, 806-07 (2d Cir.2014) (<HOLDING>). Contra Reply Br. 9-11. Still, then, any
holding that defendant was not resident of his mothers household even though his drivers license listed his mothers address and he received mail there because he expressed a belief that his residence was in a different location than his mothers home he rented and occupied his own residence and he testified that he was only living with his mother after expiration of his lease until he could find another place to live holding defendant gave a valid and knowing consent to a search of his dwelling and automobile when he agreed to the terms of probation holding that defendants failure to withdraw consent to search for criminal activity in his home included the top floor because he did not withdraw his consent to search when he observed the officer go upstairs holding that a third party did not give his prior express consent to be called about a debt when he gave his number outside of the context of the debt holding that the debtor gave his prior express consent even though he didnt give his number until one year after debt was incurred