This week an Illinois court found that Economic Strategy Group (ESG) violated the Telephone Consumer Protection Act (TCPA) by making robocalls to almost 1 million individuals purporting to be conducting a political survey but also offering a “free cruise” for taking part in the survey. U.S. District Judge Matthew F. Kennelly said in his lengthy order, “The evidence is uncontroverted that a prerecorded message was played on each call”; “this is a violation of the TCPA, irrespective of whether the calls were made by or on behalf of a tax-exempt non-profit, were made for a political or non-commercial purpose, or did not make reference to or play long enough to mention defendants’’ vacation products.” However, the court did not determine whether the robocalls were made on ESG’s own behalf or on behalf of Caribbean Cruise Line, Inc., Vacation Ownership Marketing Tours Inc., and the Berkley Group Inc. The judge said he will leave it up to a jury to decide the direct or indirect liability of each defendant in this case.