The Courts have been pretty consistent that a pure offer to buy a property is not a solicitation, but a an offer to buy tied to a hidden service for which the consumer is charged is a solcitation.

This matters because folks really like to cold call property owners in an effort to buy their properties. But folks also really like to cold call FSPOs and expired listings in an effort to list their properties– which is very different.

Well in Cofey v. Fast Easy Offer, 2025 WL 1591302 (D. Az. June 5, 2025) the Court held calls asking “Have you given up on selling your…property?” were not telephone solicitations because they did not offer to sell or rent anything to the call recipient.

The court thoroughly analyzed the facts and law and determined the calls only related to future selling activ

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