A retail company wants to launch an SMS campaign in the United States to promote a flash sale. They have a list of customer phone numbers collected during online checkout. What is the most critical first step they must take to comply with the Telephone Consumer Protection Act (TCPA)?
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A
Scrub the list against the National Do Not Call Registry.
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B
Ensure they have obtained prior express written consent from each customer to receive marketing text messages.
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C
Send an initial message asking customers to reply 'YES' to confirm their subscription.
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D
Include an 'unsubscribe' link in the first message.