The federal Wiretap Act provides a civil cause of action to any person whose wire, oral, or electronic communication is intercepted, disclosed, or intentionally used in violation of 18 U.S.C. §§ 2510–2523. (18 U.S.C. § 2520(a).)  Under § 2520(e), the action must be brought no later than two years after the date upon which the claimant first has a reasonable opportunity to discover the violation.  This decision holds that “the violation” refers individually to each instance in which the defendant intercepted a phone call, not to the defendant’s general practice that results in those individual violations.  Thus, in this case, a defense attorney who received discovery including transcripts of her telephone calls with inmates at the defendant’s private jail, had a reasonable opportunity to discover at that time all the violations the defendant had committed by recording phone calls before that date–and since she sued more than two years later, her claims based on those violations were time-barred.  However, claims based phone calls that were recorded afterwards discovery of the defendant’s earlier recording practice did not trigger the statute of limitations.  Instead, defendant would have to show when plaintiff had a reasonable opportunity to discover the later recorrdings.