Given the TCPA's lack of an express limitations period and the inherent uncertainty in selecting an analogous state statute of limitations, 28 USC § 1658's four-year statute of limitations is appropriate for TCPA actions.
Stern v. Bluestone 47 A.D.3d 576, 850 N.Y.S.2d 90, 2008 N.Y. Slip Op. 00611
Worsham v. Fairfield Resorts, Inc., No. 1058 (Md. Ct. Spec. App. – September 2009)