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TCPA - Ninth Circuit Affirms Decertification of “Junk Fax” Class

Takeaway: In True Health Chiropractic, Inc. v. McKesson Corp., No. 22-15710, 2023 WL 7015279, at *1 (9th Cir. Oct. 25, 2023), the Ninth Circuit affirmed the district court’s decertification of a “junk fax” class, finding that...more

TCPA: Reversing panel decision, full Eleventh Circuit finds single text message sufficient to establish TCPA standing

Takeaway: In Drazen v. Pinto, 74 F.4th 1336 (11th Cir. 2023) (en banc), the Eleventh Circuit held a single “unwanted, illegal” text message sufficient to establish concrete injury for standing purposes. This holding...more

TCPA Class Actions – Ninth Circuit Finds Businesses Have TCPA Standing

Takeaway: In Chennette v. Porch.com, Inc., -- F.4th ----, No. 20-35962, 2022 WL 6884084 (9th Cir. Oct. 12, 2022), the Ninth Circuit expanded the scope of standing under the Telephone Consumer Protection Act (“TCPA”), finding...more

TCPA – Sixth Circuit affirms enforceability of TCPA from 2015 to 2020

Takeaway: In Lindenbaum v. Realgy, LLC, --- F.4th ----, 20-4252, 2021 WL 4097320 (6th Cir. Sept. 9, 2021), the Sixth Circuit rejected the defendant’s argument that the Telephone Consumer Protection Act (“TCPA”) had been...more

TCPA Class Actions – District Court Declares TCPA Robocalling Restriction Unconstitutional From 2015 to 2020

Takeaway: Most commentators (including this one) interpreted the U.S. Supreme Court’s fractured plurality opinion in Barr v. Am. Ass’n of Political Consultants, Inc, 140 S. Ct. 2335, 2343 (2020) (“AAPC”), as invalidating the...more

TCPA Class Actions - Supreme Court Severs Government Debt Collection Exception

Takeaway: In Barr v. American Association of Political Consultants, Inc, No. 19-631, 2020 WL 3633780 (U.S. July 6, 2020), the Supreme Court invalidated the exception for calls made for the purpose of collecting government...more

TCPA Class Actions - Eleventh Circuit Narrows Scope of TCPA, Splitting with Ninth Circuit

Takeaway: The recent explosion in telemarketing calls has been driven by telephone equipment that allows companies to automatically dial a stored list of potential customers. In Glasser v. Hilton Grand Vacations Co., LLC,...more

Eleventh Circuit reinvigorates Spokeo in single text message TCPA case

Takeaway: Despite the relatively minor nuisance of receiving an unsolicited advertisement, TCPA defendants have had little success challenging TCPA claims on Spokeo (standing) grounds. In Salcedo v. Hanna, --- F.3d ---, No....more

TCPA: district court strikes class allegations due to individualized issues of consent and revocation

Takeaway: More class actions are filed under the Telephone Consumer Protection Act (TCPA) than any other statute, and TCPA claims often present common issues capable of class certification. But courts will not certify a...more

Ninth Circuit dismisses TCPA claim, finds recipient’s insurance enrollment form constituted “prior express consent”

Takeaway: A recent Ninth Circuit decision find holding that the plaintiff had provided “prior express consent” to receive calls from a third-party telephone consultant shows that the scope of “prior express consent” is based...more

Fourth Circuit finds manufacturers not vicariously liable for retailers’ TCPA violations

Takeaway: A recent Fourth Circuit decision finding that UTC and Honeywell, manufacturers of home-security systems, could not be held vicariously liable for calls by downstream retailers in violation of the Telephone Consumer...more

Consent Issues Preclude Certification of TCPA Class Action

Takeaway: A March 2017 D.C. Circuit decision excluding solicited faxes from the scope of the TCPA may spell trouble for class action plaintiffs. The Northern District of Illinois recently ruled that, at least where there is...more

Ninth Circuit Declines to Hold Seller Vicariously Liable for Third-Party Telemarketer’s TCPA Violations

Takeaway: Decisions addressing a seller’s exposure to vicarious liability for calls placed by a third-party telemarketer in violation of the Telephone Consumer Protection Act (“TCPA”) offer little predictability or guidance....more

Spokeo and the TCPA: Mere Receipt of Fax with Non-Compliant Opt-Out Notice is Not “Concrete Injury”

In ARcare v. Qiagen N. Am. Holdings, Inc., No. CV 16-7638 PA (ASX), 2017 WL 449173, at *1 (C.D. Cal. Jan. 19, 2017), the district court granted the defendant’s motion to dismiss a TCPA class action, finding that the simple...more

The TCPA and Risk of “Sabotage Liability”

Takeaway: The Telephone Consumer Protection Act (“TCPA”) broadly defines the “sender” of a facsimile advertisement to include any entity “whose goods or services are advertised.” On its face, this language creates risk of...more

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