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In Pinn v. Consumer Credit Counseling Foundation, a company that made calls on behalf of a non profit can be liable for violating the DNC rules though the CFR appears to say otherwise. The court found the calls were made to sell for profit services so the caller could be liable.
In Family Health Physical Medicine v. Pulse8 the fourth district court concluded that a Fax itself must relate to or involve the buying and selling of property, goods, or services to defer to a 2006 order from the Federal Communications Commission FCC on Faxes