Consumers do not like automated cold calls, so many jurisdictions have made marketing voice broadcasts illegal unless the recipient has previously consented to such calls. The U.S. Congress passed the Telephone Consumer Protection Act (TCPA) in 1991. Recipients of illegal voice broadcast calls under the TCPA may sue the caller for statutory damages of $500 to $1500 per violation. TCPA class actions have been settled for millions of dollars. Even before the TCPA was enacted, state laws prohibited voice broadcast solicitations. California's Consumers Legal Remedies Act prohibited many such calls and allows plaintiffs to recover attorneys' fees.