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Court Denies Atypical Plaintiff’s Motion to Certify Unascertainable Fail-Safe Class

The Middle District of Florida has denied a motion for class certification, finding the proposed class definition would have created a fail-safe class, the class members were not ascertainable, and the plaintiff’s claims were...more

Florida Federal Court Rejects ATDS Allegations, Grants Motion to Dismiss

In a text message case, the U.S. District Court for the Southern District of Florida recently granted Atlantic Coast Enterprise, LLC’s (“Ace”) motion to dismiss upon finding that the plaintiff had failed to plausibly allege...more

District Court Denies Class Certification Due to Lack of Ascertainability

Recently, the Middle District of Florida denied a motion for class certification, finding that the plaintiff had not sufficiently shown that the putative classes were ascertainable. Sliwa v. Bright House Networks, LLC &...more

From the Four Corners of the Pleading: Plaintiffs Cannot Rely On Factual Allegations Outside the Pleadings To Defeat a Motion to...

The Northern District of Texas recently dismissed a TCPA claim because “the Complaint nowhere alleges that he was called or texted using an ATDS.” The Court’s opinion emphasized that simply asserting that “the text messages...more

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

Northern District of Illinois Finds Plaintiff Failed to Adequately Allege Use of an ATDS

In a recent Northern District of Illinois case, a plaintiff’s TCPA claim was dismissed after the court found that the complaint did not contain sufficient facts to plausibly allege the defendant had used an ATDS. See Bader v....more

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