Other courts in this District have made rulings on treble damages on which this Court can draw. Courts in this District have ruled that a willful or knowing TCPA violation does not require that the defendant had actual knowledge that an action violated the TCPA, but only that the action itself was intentional. See Newbold v. State Farm Mutual Automobile Insurance Co., 2015 WL 1368554, at *5 (N.D. Ill. Jan. 23, 2015) ("Courts generally have interpreted [willful or knowing] to mean voluntary, intentional, actions, and not to require specific knowledge that the action constitutes a violation of the TCPA."); Bridgeview Health Care Center Ltd. v. Clark, 2013 WL 1154206, at *7 (N.D. Ill. March 19, 2013) ("The Court adopts the more common interpretation that 'willfully' or 'knowingly' simply requires that the act be intentional or volitional, as opposed to inadvertent, and not that defendant must have known that the conduct would violate the statute."); Sengenberger v. Credit Control Services, Inc., 2010 WL 1791270, at *6 (N.D. Ill. May 5, 2010) (no requirement of knowledge that an act violated the TCPA for treble damages); Charvat v. Allstate Corporation, 29 F.Supp.3d 1147, 1151 (N.D. Ill. March 5, 2014) (willful or knowing TCPA violation only requires defendant knew of facts constituting the offense). This Court agrees with other courts in this District: for Defendant to be liable for treble damages in this case, Plaintiffs must demonstrate that Defendant knew that VVT was making its calls intentionally, rather than inadvertently.

Because the award in excess of $8.1 billion violates due process, the Court will not exercise its discretionary authority to increase the award. The Court, therefore, will not address the split of authority on the requirements to prove knowing violations (see e.g., Lary v. Trinity Physician Financial & Insurance Services, 780 F.3d 1101, 1106–07 (11th Cir. 2015) (must prove actual knowledge that the act violated the TCPA); contra e.g., Sengenberger v. Credit Control Services, Inc., 2010 WL 1791270, at *6 (N.D. Ill. May 5, 2010) (must only prove the act was intentional, not accidental)) or whether the enhanced award would constitute punitive damages see Alea London Ltd. v. American Home Services, Inc., 638 F.3d 768, 778 (11th Cir. 2011) (enhanced awards up to $1,500 under the TCPA were more compensatory than punitive). G. Counts VII and VII California Claims

See In re Monitronics Intern., Inc., 2014 WL 316476, at *5 (N.D.W.V. Jan. 28, 2014) (collecting cases). Sengenberger v. Credit Control Servs., Inc., 2010 WL 1791270, at *6 (N.D.Ill. May 5, 2010). Id. (citing 47 U.S.C. § 312(f)).

While neither the TCPA nor FCC regulations provide a definition for willful and knowing, most courts have interpreted the willful or knowing standard to require only that a party's actions were intentional, not that it was aware that it was violating the statute. See, e.g., Alea London Ltd., 638 F.3d at 776 (holding that the TCPA requires mere “knowing” conduct); Harris v. World Fin. Network Nat. Bank, 867 F.Supp.2d 888, 896–97 (E.D.Mich.2012); Sengenberger v. Credit Control Servs., Inc., 2010 WL 1791270 (N.D.Ill. May 5, 2010); Bridgeview Health Care Ctr. Ltd. v. Clark, 2013 WL 1154206 (N.D.Ill. Mar. 19, 2013).

s consent. Instead, we view the silence in the statute as evidence that the right to revoke exists"); Legg v. Voice Media Grp., Inc., 13-62044-CIV, 2014 WL 29594, *3 (S.D. Fla. Jan. 3, 2014) (denying motion to dismiss because Plaintiff sufficiently pled that he revoked his consent to receive text messages from Defendant); Beal v. Wyndham Vacation Resorts, Inc., 956 F. Supp. 2d 962, 977 (W.D. Wis. 2013) ("consumers can revoke their consent to receive autodialer calls under the Telephone Consumer Protection Act and may do so orally"); Adamcik v. Credit Control Servs., Inc., 832 F. Supp. 2d 744, 749 (W.D. Tex. 2011) (relying on common law principles to conclude that consumers may revoke consent to receive autodialer calls under the TCPA and that they may do so orally or in writing); Moore v. Firstsource Advantage, LLC, No. 07-CV-770, 2011 WL 4345703, at *11-12 (W.D.N.Y. Sept.15, 2011) (oral request to cease making autodialer calls ineffective, written revocation required under the TCPA); Sengenberger v. Credit Control Servs., Inc., No. 09 C 2796, 2010 WL 1791270, at *4 (N.D. Ill. May 5, 2010) (because consent revoked in writing, all calls made after that were violative of the TCPA); Munro v. King Broad.Co., C13-1308JLR, 2013 WL 6185233, *3 (W.D. Wash. Nov. 26, 2013);Gutierrez v. Barclays Group, 2011 WL 579238 (S.D. Cal. 2011) (a consumer can revoke consent given under the TCPA orally or in writing because the statute does not require revocation to be in writing). "The courts that have reached this conclusion have done so for several key reasons.

Other courts have concluded that consent can be revoked, but only through writing. E.g., Starkey v. Firstsource Advantage, LLC, 2010 WL 2541756, *5–6 (W.D.N.Y. Mar. 11, 2010); Cunningham v. Credit Management, L.P., 2010 WL 3791104, *5 (N.D.Tex. Aug. 30, 2010); Moore v. Firstsource Advantage, LLC, 2011 WL 4345703, *11 (W.D.N.Y. Sept. 15, 2011); Moltz v. Firstsource Advantage, LLC, 2011 WL 3360010, *6 (W.D.N.Y. Aug. 3, 2011); Sengenberger v. Credit Control Services, Inc., 2010 WL 1791270, *4 (N.D.Ill. May 5, 2010). In those cases, the courts relied on the fact that the cases involved debt collection calls and that the Fair Debt Collection Practices Act generally applies to debt collection.

See In re: Rules and Regulations Implementing the Tel. Consumer Prot. Act of 1991, 23 F.C.C.R. at ¶ 9 (F.C.C. 2007). As to Plaintiff's argument that he revoked his consent, he cites my ruling in Sengenberger v. Credit Control Servs., Inc., 2010 WL 1791270, *4 (N.D. Ill. May 5, 2010). In that case, plaintiff debtor sued a collection agency for its use of auto-dialed, pre-recorded calls.