News & Analysis as of

ATDS Text Messages Statutory Interpretation

Troutman Amin LLP

CURIOUS: Second Circuit Issues Oddly-Worded Remand In LaBoom Disco ATDS Ruling Following Facebook– Does It Mean Anything?

Troutman Amin LLP on

Real quick one for the TCPA super nerds. You’ll recall way back in April 2020 the world was melting down. No, I’m not talking about COVID. I am talking about ATDS cases. Perhaps the high-water mark of TCPAWorld ATDS chaos...more

Troutman Pepper Locke

California Federal Court Dismisses TCPA Complaint Finding Recruitment Messages Are Not Solicitations

Troutman Pepper Locke on

In a recent ruling, a U.S. District Court for the Central District of California granted a defendant’s motion to dismiss a complaint brought under the Telephone Consumer Protection Act (TCPA). The complaint alleged that the...more

Troutman Pepper Locke

Second Circuit Upholds TCPA Case Dismissal: ATDS Must Generate Phone Numbers, Text Messages Don’t Qualify as Artificial Voices

Troutman Pepper Locke on

In Soliman v. Subway Franchisee Advertising Fund Trust, Ltd, the plaintiff alleged that the defendant violated the Telephone Consumer Protection Act (TCPA) by sending a text message to her cell phone using an automatic...more

Burr & Forman

Ninth Circuit Holds Text Messages Are Not Prerecorded Calls

Burr & Forman on

Trim v Reward Zone USA LLC, No. 22-55517, 2023 WL 5025264 (9th Cir. August 8, 2023) - Plaintiff filed a putative class action, contending, in part, that three marketing text messages she received utilized prerecorded voices,...more

Womble Bond Dickinson

FCC Addresses TCPA ATDS Definition in Win for P2P Texting Platforms

Womble Bond Dickinson on

The FCC’s proceedings regarding the definition of the term “automatic telephone dialing system” have been pending since May of 2018 when, shortly after the D.C. Circuit’s opinion in ACA International v. FCC, the Commission...more

Womble Bond Dickinson

TCPA Developments on Definition of ATDS Continue Full Steam in Midst of Global Pandemic

Womble Bond Dickinson on

COVID-19 has closed courts and delayed hearings and trials across the country, but developments concerning the definition of an automatic telephone dialing system have continued unabated. Over the past few months, courts have...more

Akin Gump Strauss Hauer & Feld LLP

Second Circuit Decision Widens Circuit Split in TCPA Landscape

- In a departure from the majority view, the 2nd Circuit has held that a texting platform need not have the capacity for random or sequential number generation in order to constitute an an automatic telephone dialing system...more

Ballard Spahr LLP

Second Circuit adopts broad TCPA autodialer definition

Ballard Spahr LLP on

A unanimous three-judge panel of the U.S. Court of Appeals for the Second Circuit, in Duran v. La Boom Disco, Inc., handed a win to the plaintiffs’ bar by holding that the Telephone Consumer Protection Act’s (TCPA) statutory...more

Hinshaw & Culbertson LLP

Circuit Split Created as Eleventh and Seventh Circuits Narrowly Interpret Definition of Auto-Dialer Under the TCPA

We now have a split among federal circuits regarding the definition of an automatic telephone dialing system (ATDS), under the Telephone Consumer Protection Act (TCPA), which limits automated calls and text messages. What...more

Womble Bond Dickinson

First Lower Court in Eleventh Circuit Follows Glasser in Granting Summary Judgment in TCPA Case

Womble Bond Dickinson on

The Eleventh Circuit in Glasser v. Hilton Grand Vacations Co., LLC recently confirmed that the definition of Automatic Telephone Dialing System (ATDS) is narrow, holding that to qualify a dialer must both have the capacity to...more

Faegre Drinker Biddle & Reath LLP

Seventh Circuit Disagrees with Ninth Circuit and Joins the Third and Eleventh Circuit in Adopting a Narrow Interpretation of ATDS

In a decision released on February 19 that relied principally on rules of grammar, the Seventh Circuit held that to be an ATDS under the TCPA, a device must be capable of storing or producing telephone numbers using a random...more

Burr & Forman

Gadelhak v. AT&T: The Seventh Circuit Joins the Eleventh Circuit in Taking a Big Bite Out of the TCPA

Burr & Forman on

My last blog post provided a background of the evolving definition of “automated telephone dialing system” (ATDS) under the Telephone Consumer Protection Act (TCPA) and described the FCC’s long-running effort to expand the...more

Womble Bond Dickinson

Court in W.D. Missouri Holds an ATDS Must Have Capacity to Randomly or Sequentially Generate Numbers

Womble Bond Dickinson on

The new decade has brought us a series of new decisions regarding one of our favorite issues under the TCPA – the definition of an automatic telephone dialing system (“ATDS”). This week, a District Court in the Western...more

Jones Day

Eleventh Circuit Reins in TCPA Liability

Jones Day on

The Situation: The Telephone Consumer Protection Act ("TCPA") prohibits unconsented calls or texts made "using an automatic telephone dialing system" ("ATDS"), defined as "equipment which has the capacity—(1) to store or...more

Faegre Drinker Biddle & Reath LLP

Court Holds That Text-Messaging System Must Be Able to Randomly or Sequentially Generate Numbers to Qualify as an ATDS

The Northern District of Illinois recently entered summary judgment against a group of plaintiffs because it found the system at issue was not an ATDS. In Smith v. Premier Dermatology, No. 17-3712, 2019 WL 4261245 (N.D....more

Womble Bond Dickinson

Sixth Circuit Affirms TCPA Summary Judgment Based on Lack of Random or Sequential Number Generation

Womble Bond Dickinson on

In Gary v. Trueblue, Inc., 346 F.Supp.3d 1040 (E.D. Mich. Oct. 11, 2018), the court granted the Defendant’s motion for summary judgment on the basis that Plaintiff failed to establish the Defendant’s dialing system had the...more

Womble Bond Dickinson

Court Finds Texting Platform Not ATDS Under “Plain Meaning” of TCPA Statute

Womble Bond Dickinson on

It has almost been a year since the U.S. Court of Appeals for the District of Columbia Circuit released its decision in ACA International v. FCC, and since that time we have highlighted numerous cases in which a court’s...more

Womble Bond Dickinson

Using Prior FCC Rulings and Focusing on Human Intervention, Court Finds Texting Platform Is Not An ATDS

Womble Bond Dickinson on

In today’s world of ever-conflicting TCPA rulings, it is important to remember that, where courts are asked to determine the TCPA’s ATDS definition, their inquiry will revolve around the question of whether that definition...more

Fenwick & West LLP

Ninth Circuit Adopts Expansive Definition of Auto-Dialer in TCPA Case

Fenwick & West LLP on

In a ruling that increases liability for companies that use text messaging for marketing or communicating with customers, the U.S. Court of Appeals for the Ninth Circuit adopted an expansive definition of what constitutes an...more

Ballard Spahr LLP

Ninth Circuit Accepts Broad Definition of ATDS

Ballard Spahr LLP on

A unanimous three-judge panel of the U.S. Court of Appeals for the Ninth Circuit on Thursday handed the plaintiffs’ bar a resounding win. ...more

Womble Bond Dickinson

It Will All Come Out in the “Wash”: Did a Southern California District Court Just Solve the TCPA’s ACA Int’l/ATDS Conundrum Once...

Womble Bond Dickinson on

Sometimes the most obvious answer is the hardest one to see. For weeks now the courts have been debating whether the 2003 and 2008 Predictive Dialer Rulings were set aside by ACA Int’l or just the 2015 TCPA Omnibus ruling....more

21 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide