AGV Sports Group, Inc. v. Protus IP Solutions, Inc., 10 A.3d 745

Seven plaintiffs allege MTCPA and TCPA violations due to hundreds of unsolicited faxes by Protus IP Solutions.
Mass of faxes occurred over three years before suit filed on December 17, 2008.
Maryland default three-year limitations unless a specialty statute applies under CJP § 5-102(a)(6).
District Court certified whether MTCPA is an 'other specialty' under § 5-102(a)(6).
MTCPA creates remedies including attorney’s fees and either $500 per violation or actual damages.
Court holds MTCPA is not a statutory specialty; damages can be unliquidated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is MTCPA an 'other specialty' under CJP § 5-102(a)(6)?	AGV: MTCPA satisfies Crowder criteria for a specialty.	Protus: MTCPA lacks the narrow specialty features; damages are unliquidated.	No; MTCPA not an 'other specialty'.

Greene Tree Home Owners Ass'n v. Greene Tree Assocs., 358 Md. 453 (2000) (held CPA not an 'any other specialty' due to unliquidated damages)
Master Fin., Inc. v. Crowder, 409 Md. 51 (2009) (provided three-part framework for 'any other specialty')