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Auto-Dialed Calls ATDS Summary Judgment

Troutman Pepper Locke

New Mexico Federal Court Denies Summary Judgment on Majority of Claims Brought Under the TCPA Over Telemarketing Calls

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Recently, a U.S. District Court in the District of New Mexico denied a defendant’s motion for summary judgment on Telephone Consumer Protection Act (TCPA) claims for telemarketing calls, finding genuine questions of fact...more

Faegre Drinker Biddle & Reath LLP

ATDS Status Turns on Capability of Dialing Equipment, Not Actual Use, Third Circuit Holds—But Liability Turns on Actual Use, Not...

Last week, the U.S. Court of Appeals for the Third Circuit concluded that the TCPA’s definition of “automatic telephone dialing system” (or “ATDS”) includes all dialing equipment with the present ability to generate random or...more

Orrick, Herrington & Sutcliffe LLP

South Carolina District Court Grants Summary Judgment for TCPA Defendant after Supreme Court’s Duguid Decision

A South Carolina federal district court recently granted summary judgment for a TCPA defendant in one of the first major lower court decisions following the Supreme Court's opinion in Facebook v. Duguid, which clarified (and...more

Holland & Knight LLP

District Court's Decision in TCPA Case Follows Supreme Court's Duguid Opinion

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The U.S. District Court for the District of South Carolina, in the matter of Margueritte Timms v. USAA Federal Savings Bank, 2021 WL 2354931 on June 9, 2021, granted defendant USAA Federal Savings Bank's (USAA) Motion for...more

Faegre Drinker Biddle & Reath LLP

Seventh Circuit Reaffirms Gadelhak, Rejects Challenge to Narrow ATDS Definition

The Seventh Circuit last week affirmed its holding in Gadelhak v. AT&T Services, Inc., 950 F.3d 458 (7th Cir. 2020) that, to qualify as an “automatic telephone dialing system” (ATDS) under the TCPA, a device or calling system...more

Troutman Pepper Locke

Summary Judgment & Shifting the Burden of Proof: Court Grants Summary Judgment for Plaintiff and Denies Summary Judgment for...

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In Russell v. Law, Judge Van Bokkelen, of the United States District Court for the Northern District of Indiana, granted summary judgment, in part, to Russell Friend (“Plaintiff”)– alleging Taylor Law, PLLC (“Defendant”)...more

Proskauer - Minding Your Business

Sixth Circuit Tips the Scale in Split Over What Constitutes an Autodialer Under the TCPA

The Sixth Circuit has joined the Second and Ninth Circuits in their broad interpretation of the Telephone Consumer Protection Act’s (TCPA) autodialer provision. In doing so, it has tipped the scale in a circuit split that is...more

McGlinchey Stafford

Florida Real Property & Business Litigation Report, Volume 13, Issue 28

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Barr v. American Association of Political Consultants, Inc., Case No. 19–631 (2020). The federal government cannot exempt itself from the anti-robocall provisions of the Telephone Consumer Protection Act of 1991, 47 U. S. C....more

Faegre Drinker Biddle & Reath LLP

Court Applies the Seventh Circuit’s Gadelhak Decision and Grants Summary Judgment Against Certified Class

The Southern District of Indiana recently entered summary judgment against a certified class of TCPA plaintiffs because it concluded that defendants’ SoundBite platform did not qualify as an ATDS under the standard the...more

Faegre Drinker Biddle & Reath LLP

Court Enters Summary Judgment Against Plaintiff, Finds No Triable Issues Regarding Revocation of Consent

The Eastern District of California recently entered summary judgment against a plaintiff because it found that the plaintiff failed to revoke his consent to receive auto-dialed calls on his cell phone. Wright v. USAA Savings...more

King & Spalding

Circuit Split Emerges on TCPA Definition of “Auto-dialer”

King & Spalding on

On January 27, 2020, the Eleventh Circuit affirmed the Middle District of Florida’s order granting summary judgment in favor of defendant Hilton Grand Vacations Company, LLC (“Hilton”), and reversed the Northern District of...more

Womble Bond Dickinson

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

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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

Benesch

Federal Missouri Court Continues To Rein In Expansive TCPA Interpretation

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The Telephone Consumer Protection Act case law interpreting the definition of an “automatic telephone dialing system” (“ATDS”) is changing under plaintiffs’ feet and coalescing against the definition set forth in Marks v....more

Womble Bond Dickinson

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

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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

Faegre Drinker Biddle & Reath LLP

Central District of California Grants Motion for Summary Judgment After Finding That Plaintiff Failed to Revoke Prior Express...

The Central District of California recently granted summary judgment to the defendant on a TCPA claim in Mendoza v. Allied Interstate LLC, SACV 17-885 JVS (KESx), 2019 WL 5616961 (C.D. Cal. Oct. 22, 2019), finding that the...more

Faegre Drinker Biddle & Reath LLP

Court Finds Plaintiff’s ATDS Evidence Insufficient and Grants Summary Judgment for Defendant

The Southern District of Florida recently granted a defendant’s motion for summary judgment on certain aspects of a plaintiff’s TCPA claim because plaintiff could not establish that defendant used an ATDS to call her cell...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

Sheppard Mullin Richter & Hampton LLP

The Sixth Circuit Limits the Meaning of ATDS Under the TCPA

Recently, the Sixth Circuit in Gary v. Trueblue, Inc., No. 18-2281, 2019 U.S. App. LEXIS 26959 (6th Cir. Sep. 5, 2019), weighed in on the meaning of Automatic Telephone Dialing System (“ATDS”) under the Telephone Consumer...more

Faegre Drinker Biddle & Reath LLP

Florida U.S. District Court Grants Victory for Defendant, Finds its Dialing Equipment Is Not an ATDS

In many TCPA cases, the sufficiency of a plaintiff’s allegations, particularly those concerning the defendant’s alleged use of an automatic telephone dialing system (“ATDS”), are tested at the pleadings stage through a motion...more

Womble Bond Dickinson

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

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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

First Court Within Ninth Circuit Declines to Follow Reyes and Finds that Consent Can Be Revoked Under the TCPA

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As all of us TCPA enthusiasts know, a cornerstone issue in many TCPA cases is whether plaintiff has provided consent to be contacted and whether that consent can be revoked. According to the Second Circuit’s decision in Reyes...more

Womble Bond Dickinson

Navient Wins Summary Judgment: Court Confirms Calls to Collect Government-Backed Debt Exempt From TCPA

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In a recently published decision, a federal court granted student loan processor Navient’s motion for summary judgment, concluding that a statutory exception that makes calls solely to collect a debt owed to or guaranteed by...more

Mintz

TCPA Class Action Update – December 2018

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Spotlight on Consent: Individualized Questions of Consent Preclude Class Certification - Despite the overwhelming focus this year on the issue of what constitutes an automatic telephone dialing system, defendants should...more

Goodwin

District of Minnesota Rejects Marks, Grants Defendant Summary Judgment in TCPA Case

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On November 13, 2018, the District of Minnesota rejected the Ninth Circuit’s expansive interpretation of the Telephone Consumer Protection Act’s (TCPA’s) automatic telephone dialing system (ATDS) provision in Marks v. Crunch...more

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