Another day, another massive TCPA settlement. Although this one is actually a CEMA settlement– Washington’s MASSIVELY IMPORTANT mini-TCPA.

Block, Inc. just agreed to pay up to $12.5MM to settle CEMA claims up in Washington state.

The settlement arises from claims related to Block’s CashApp “refer a friend” program.

The program offered a bounty to users of the app if they referred a friend– i.e. get $5.00 when you refer a friend. Stuff like that.

One little problem– while this might fly under restrictive TCPA rules, the Washington CEMA applies to companies that “assist” in transmission of illegal messages.

As a result of CEMA’s broader requirements, companies operating refer-a-friend style SMS programs need to be very cautious in Washington state.

Of course Block hired #biglaw who took hundreds of thousands of dollars (or more) off of Block and then guided it into a massive settlement.

Just unreal how many times we have seen this movie before. Same thing over and over. #Biglaw comes into a case. Screws it up. Settle for huge dollars.

Hire #biglaw. Expect a #bigloss (and an even bigger settlement.)

Anyhoo, this settlement covers 1,975,187 unique phone numbers with Washington area codes that Block users sent messages to (yikes)

The attorneys for the class will seek about $3.1MM in fees. After administration and other costs there should be over $8MM sitting out there for the class.

That’s a lot of dough. And none of it will go back to Block– this is sunk money folks.

Will keep an eye on the claims rate here.