diff --git a/docs/CELLPHONE_USA_TCPA_FCC_COMPLIANCE.txt b/docs/CELLPHONE_USA_TCPA_FCC_COMPLIANCE.txt
index f8115b7b..fad03260 100644
--- a/docs/CELLPHONE_USA_TCPA_FCC_COMPLIANCE.txt
+++ b/docs/CELLPHONE_USA_TCPA_FCC_COMPLIANCE.txt
@@ -1,8 +1,8 @@
-CELLPHONE FILTERING DOC	  Started: 2013-09-20	Updated: 2014-07-03
+CELLPHONE FILTERING DOC	  Started: 2013-09-20	Updated: 2015-06-26
 
 On October 16th, 2013 the FCC issued a rule change to not allow auto-dialing cellphones in the USA unless you have "express consent" from the person you are calling. This document is a summary of what this rule change means to businesses and organizations, and goes over how they can make sure they are in compliance with the TCPA(Telephone Consumer Protection Act of 1991) depending on their interpretation of the regulatory language. 
 
-First, here is a good summary of what the changes are, and what the definition of terms are:
+First, here is a good summary of what the 2013 changes are, and what the definition of terms are(the June 2015 changes are detailed further down):
 http://www.copilevitz-canter.com/resources/articles/upcoming-fcc-rule-changes-regarding-express-consent-to-call-cell-phones
 
 Now time for a disclaimer. I am not a lawyer, and this document was not written by a lawyer. If you want legal advice on this topic, I strongly suggest discussing it with a lawyer who specializes in telecommunications law.
@@ -13,7 +13,16 @@ In summary, the new regulations ban any calls to cellphones in the USA by "autom
 	  and 
 	(B) to dial such numbers". 
 
-This is such a broad definition that even a modern smartphone fits it's definition. But, the FCC also has said more recently that the basic function of an ATDS is “the capacity to dial numbers without human intervention”, which should pretty much exclude smartphones, as well as dialing systems where human intervention would be necessary for any calls to be placed, such as auto-dialers. Unfortunately, some recent court rulings have ignored the "human intervention" exclusion, and ruled against companies that were purely click-to-dial calling people because their phone systems had "the capacity to store and dial phone numbers". Under this very strict interpretation of the law, there is virtually no way to call anyone on a cellphone unless you use only a basic analog wired phone.
+This is such a broad definition that even a modern smartphone fits it's definition. But, the FCC also has said in 2013 that the basic function of an ATDS is “the capacity to dial numbers without human intervention”, which should pretty much exclude smartphones, as well as dialing systems where human intervention would be necessary for any calls to be placed, such as auto-dialers. Unfortunately, some recent court rulings have ignored the "human intervention" exclusion, and ruled against companies that were purely click-to-dial calling people because their phone systems had "the capacity to store and dial phone numbers". Under this very strict interpretation of the law, there is virtually no way to call anyone on a cellphone unless you use only a basic analog wired phone.
+
+Unfortunately in June of 2015, the FCC ruled that they will use the strict interpretation of an auto-dialer:
+
+"Kristi Lemoine of the FCC’s Consumer and Governmental Affairs Bureau, affirms that if equipment has the capacity to dial random or sequential  numbers, “even with some modification,” it qualifies as an autodialer."
+http://www.natlawreview.com/article/fcc-ruling-tightens-tcpa-restrictions-dissenters-warn-increased-class-action-abuse
+
+"Human intervention — like touch screen dialing button — is not sufficient to overcome ATDS status"
+http://www.natlawreview.com/article/fcc-approves-new-tcpa-rules-telephone-consumer-protection-act
+
 
 It is important to mention that this regulatory change has no effect on automated calls to land line phones, except that it does disallow all pre-recorded robo-calls for marketing purposes unless you have express consent.