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Pa. Autodialer Decision Has Turned TCPA Tides in 3rd Circ.

The U.S. Supreme Court's 2021 decision in Facebook Inc. v. Duguid resolved a long-standing circuit split over the definition of an automatic telephone dialing system, or ATDS, under the Telephone Consumer Protection...more

Arizona Federal District Court Holds MMS’s Are Not Prerecorded Messages Under the TCPA Unless They Play Automatically

A district court in the District of Arizona granted a motion to dismiss in a Telephone Consumer Protection Act (TCPA) case on the basis that multimedia messaging service (MMS) texts do not constitute prerecorded messages...more

Pennsylvania Federal Court Declines to Dismiss Case Involving Political Message Allowing TCPA Claim Based on Prerecorded Message...

In Perrong v. Bradford et al, the plaintiff alleged that the defendant, an elected official, violated the Telephone Consumer Protection Act (TCPA) by calling his residential phone using a prerecorded message and an automatic...more

Ninth Circuit Affirms Dismissal of TCPA Case Involving Text Messages Holding “Prerecorded Voice Messages” Require Audible...

On August 8, a unanimous panel of the Ninth Circuit issued a decision affirming a district court’s partial dismissal judgment entered in Trim v. Reward Zone USA LLC, holding that text messages did not use prerecorded voices...more

California Federal Court Denied Class Certification in TCPA Case Where Plaintiff Arguably Requested Calls

In Wiley v. American Financial Network, Inc., a district court judge in the Central District of California denied a motion for class certification in a Telephone Consumer Protection Act (TCPA) case, finding the defendant...more

Eleventh Circuit Reverses Course and Holds a Single Text Message Constitutes TCPA Standing

The Eleventh Circuit has now joined seven other circuits in holding that receipt of unwanted text messages constitutes concrete injury for standing. On July 24, the Eleventh Circuit issued an en banc decision in Drazen v....more

First Post-Facebook Appeal Makes Its Way to Supreme Court

More than two years after the Supreme Court released its ruling in Facebook v. Duguid, confirming the meaning of automatic telephone dialing systems (ATDS) under the Telephone Consumer Protection Act (TCPA), a plaintiff has...more

FCC Proposes New Rules for Revocation under the TCPA

On June 29, 2023, the Federal Communications Commission (FCC or Commission) issued a notice of proposed rulemaking clarifying how consumers may revoke consent to receive calls or texts under the Telephone Consumer Protection...more

Ohio Federal Court Finds Plaintiff Has Standing in TCPA Case Over Messages Left With Wrong Recipient

On June 28, a magistrate judge in the U.S. District Court for the Southern District of Ohio issued a report recommending that the defendant’s motion to dismiss be denied because the plaintiff had standing under the Telephone...more

Sixth Circuit Holds Receipt of One Ringless Voicemail Causes Article III Harm Under the TCPA

On June 1, the Sixth Circuit Court of Appeals issued a ruling in Dickson v. Direct Energy, LP, holding that the plaintiff’s claims that he received a single ringless voicemail (RVM) for commercial purposes satisfy the demands...more

Florida State Court Holds Mere Statutory Violation Not Enough to Confer Standing Under TCPA

On May 10, Florida’s Third District Court of Appeal issued an opinion in Pet Supermarket, Inc. v. Eldridge, holding that the plaintiff and putative class representative lacked standing to pursue his class action lawsuit under...more

The Ninth Circuit Reinforces Narrow Interpretation of ATDS under Borden Holding System Must Generate Random or Sequential...

On April 13, the Ninth Circuit issued an opinion affirming a district court’s summary judgment order on the grounds that under Borden v. eFinancial, LLC, discussed here, to qualify as an automatic telephone dialing system...more

Treble Trouble in Paradise: Court Refuses to Treble Jury’s $8,500 TCPA Award to Plaintiff

On April 4, the U.S. District Court for the Northern District of Texas declined to increase or treble the plaintiff’s $8,500 jury trial damages awarded under the Telephone Consumer Protection Act (TCPA) after failing to find...more

New York Federal Court Partially Denies MSJ in TCPA Case Finding Possession of Cell Number Does Not Prove Consent

A federal district court in the Western District of New York recently denied in part a motion for summary judgment in a case alleging violations of the Telephone Consumer Protection Act (TCPA) based on collection calls and...more

Pennsylvania Federal Court Certifies TCPA Class Finding Common Question in Determining Existing Business Relationship

In a class action lawsuit against Pisa Group, Inc. for alleged violations of the Telephone Consumer Protection Act (TCPA), the plaintiff moved to certify a class of all persons in the United States who received more than one...more

Take Two: En Banc Eleventh Circuit to Address Whether a Single Text Message Can Confer Standing Under TCPA

As discussed here, on July 27, 2022, the Eleventh Circuit Court of Appeals sua sponte vacated the district court’s approval of a $35 million class-action settlement in Drazen and Godaddy.com, LLC (Godaddy) v. Pinto. Although...more

Consumer Advocates Respond to DentalPlans’s FCC Petition Regarding Membership Renewal Calls

As the Federal Communications Commission (FCC) considers whether DentalPlans.com’s (DentalPlans) plan renewal calls constitute telemarketing under the Telephone Consumer Protection Act (TCPA), multiple interested parties,...more

Amended TCPA Exemptions Rule Published

As previously reported here, the Federal Communications Commission (FCC) issued a proposed rule specifying that to be exempt from the Telephone Consumer Protection Act’s (TCPA) consent requirements callers would be limited to...more

2/3/2023  /  FCC , Robocalling , TCPA , Telecommunications

FCC Issues Mixed-Bag Amended TCPA Exemptions Order

As previously reported here, the Federal Communications Commission (FCC) issued a proposed rule in December 2020 that would place new call-frequency limitations and opt-out requirements on certain prerecorded...more

Second Circuit Dismisses TCPA Case for Failure to Plead Use of an ATDS

On January 9, the district court for the Eastern District of New York dismissed a pro se plaintiff’s TCPA lawsuit for failure to properly allege that the defendants used an automatic telephone dialing system (ATDS) when...more

Ninth Circuit Remand of $925M TCPA Class Award Offers Possible Ceiling on Damages

Allowable statutory damages under the Telephone Consumer Protection Act (TCPA) have a floor of $500 and, generally speaking, determining total damages is a simple math calculation. In the class action scenario, however, this...more

Dental Plan Provider Petitions FCC for Clarification Regarding Renewal Calls

On January 3, DentalPlans.com (DentalPlans) filed a petition with the Federal Communications Commission (FCC) seeking a declaratory ruling that: (1) renewal notifications do not constitute telemarketing or advertising under...more

Ninth Circuit Reaffirms Borden Interpretation of ATDS

Do the text messages that Facebook sends to your phone with birthday reminders violate the Telephone Consumer Protection Act (TCPA)? According to the Ninth Circuit in a recent decision, the answer is no because users provided...more

Finally, The Ninth Circuit Endorses Narrower Definition of Automatic Telephone Dialing System Under the TCPA

On November 16, the Ninth Circuit issued a decision affirming the dismissal of a lawsuit on the grounds that to qualify as an automatic telephone dialing system (ATDS) under the Telephone Consumer Protection Act (TCPA) the...more

FCC Rules Ringless Voicemails Require Consent

On November 21, the Federal Communications Commission (FCC) issued a Declaratory Ruling and Order finding that companies must obtain consent before sending a “ringless voicemail” to a consumer’s phone because it constitutes a...more

11/23/2022  /  ATDS , FCC , Robocalling , TCPA , Telecommunications , Voicemail
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