On March 16, 2018, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) issued its anticipated decision, ACA Int’l v. Fed. Communications Comm’n, 885 F.3d 687 (D.C. Cir. 2018), that, among other rulings, set aside the Federal Communications Commission’s (FCC) 2015 Order. The FCC’s 2015 Order attempted to clarify what constitutes an “automatic telephone dialing system (ATDS)” under the Telephone Consumer Protection Act (TCPA), 47 U.S.C.A. § 227. The TCPA prohibits the use of an ATDS to make a call to a cell phone number without prior express consent. Id. § 227(b)(1)(A (iii). An ATDS is defined as equipment that has the capacity to “(A) to store or produce telephone numbers to be called, using a random or sequential number generator; and (B) to dial such numbers.” 47 U.S.C.A. § 227(a)(1).