In Hurrle v. Real Time Resolutions, LLC, 2014 WL 670639, (U.S.D.C. W.D. Wash. CASE NO. C13-5765 BHS 2014), Judge Settle granted a stay of a TCPA case based on the Primary Jurisdiction doctrine, and the Communications Innovators Petition pending before the FCC. A copy of the Order can be found here.