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Motion to Dismiss Telephone Consumer Protection Act

Shipkevich PLLC

TCPA Litigation Update: Virginia, Texas, and Nevada Federal Courts Toss TCPA Lawsuits Over Lack of Clear Defendant Ties

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Federal district courts in Virginia, Texas, and Nevada have recently dismissed a series of lawsuits brought under the Telephone Consumer Protection Act (TCPA), finding that plaintiffs failed to show how the defendants were...more

Faegre Drinker Biddle & Reath LLP

Court Dismisses TCPA Case Due to Failure to Plausibly Allege That the Defendant Made the Calls at Issue

A recent decision out of the Eastern District of Virginia, Matthews v. Senior Life Ins. Co., provides a helpful reminder that TCPA complaints do not satisfy Rule 8’s pleading standard if they do not plausibly link the...more

Faegre Drinker Biddle & Reath LLP

Federal Court Dismisses Lawsuit, Finding Alleged Faxes Were Not Sent to a “Telephone Facsimile Machine”

The TCPA generally prohibits the transmission of an “unsolicited advertisement” to a “telephone facsimile machine.” 47 U.S.C. § 227(b)(1)(c). But is an “online fax service” a “telephone facsimile machine”? And can a plaintiff...more

Faegre Drinker Biddle & Reath LLP

Python Bites Back: Counterclaims Based on Alleged Consent Survive Plaintiff’s Motion to Dismiss

TCPA defendants often assert, in either a motion to dismiss or answer (or both), that a plaintiff gave prior express consent to receive the calls or text messages at issue. But it is the exceptional case where a defendant...more

Klein Moynihan Turco LLP

TCPA Lawsuits Should Be Closely Scrutinized

Last month, in Lawson v. Nations Health Grp., Inc. (“Defendant”), a magistrate judge for the United States District Court for the Southern District of Florida issued a useful decision for Telephone Consumer Protection Act...more

Faegre Drinker Biddle & Reath LLP

N.C. Federal Court Casts Doubt on Extraterritorial Reach of State Telemarketing Statute

The Middle District of North Carolina recently denied, in part, a motion seeking dismissal of serial TCPA plaintiff Craig Cunningham’s complaint alleging violations of the TCPA and the North Carolina Telephone Solicitations...more

Kilpatrick

N.C. district court makes clear that cell phone may constitute a residential phone in denying motion to dismiss TCPA class action

Kilpatrick on

A North Carolina federal district court recently denied a motion to dismiss a putative class action alleging violations of the Telephone Consumer Protection Act (“TCPA”) based on the receipt of text message solicitations....more

Pillsbury Winthrop Shaw Pittman LLP

Developments in Association Law 2022 – 2024

The following is a review of notable cases and regulatory developments for nonprofit organizations at the federal and state levels during the last two years....more

Troutman Pepper Locke

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

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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

Klein Moynihan Turco LLP

Carefully Examine Those TCPA Complaints!

Last month, in Woodard v. Health Insurance Alliance (“HIA”), a judge for the United States District Court for the Eastern District of Illinois issued a useful decision for defendants, dismissing Plaintiff’s Telephone Consumer...more

Faegre Drinker Biddle & Reath LLP

Middle District of Florida Analyzes Standing for Professional Plaintiffs

The U.S. District Court for the Middle District of Florida recently denied a defendant’s motion to dismiss on standing grounds even though plaintiff remained on the line to discover the identity of the caller solely for the...more

Mintz - Technology, Communications & Media...

Telephone and Texting Compliance News: Litigation Update — Two Courts Agree With Defendant’s Challenges to Imprecise TCPA Class...

Although most courts will punt on a motion to strike a class definition at the pleading stage, two recent rulings reveal that such motions can succeed. In Sowders v. Scratch Financial, Inc., No. 23-0056, 2023 WL...more

Goodwin

Internet Privacy Litigation Continues to Create Uncertainty for Websites Using Third-Party Technology while Expanding to More...

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The Authors previously published the below client alert on June 8, 2023, analyzing privacy litigation under the California Invasion of Privacy Act (CIPA) and other wiretap statutes in Pennsylvania and Maryland. We provide...more

Troutman Pepper Locke

Colorado Federal Court Declines to Dismiss TCPA Claim: Finds ATDS Plausibly Alleged Based on Reasoning in Facebook’s Footnote 7

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More than two years after the Supreme Court’s opinion in Facebook v. Duguid, courts and litigants continue to wrestle with the statutory definition of “automatic telephone dialing system” (ATDS) under the Telephone Consumer...more

Troutman Pepper Locke

Ohio Federal Court Finds Plaintiff Has Standing in TCPA Case Over Messages Left With Wrong Recipient

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On June 28, a magistrate judge in the U.S. District Court for the Southern District of Ohio issued a report recommending that the defendant’s motion to dismiss be denied because the plaintiff had standing under the Telephone...more

Jackson Walker

Supreme Court of Texas Runs at the Low Hurdle of Prima Facie Evidence in Anti-SLAPP Motion Practice

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Last week, the Supreme Court of Texas addressed the quantum of evidence required for a plaintiff to support a prima facie case and survive a motion to dismiss brought under the Texas Citizens Participation Act, Texas’s...more

Shipkevich PLLC

Judge Calls Out TCPA Frequent Filer: “Far From Plaintiff’s First Rodeo”

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“This is far from Plaintiff Na’eem Betz’s first rodeo. A frequent pro se filer, he brings this TCPA action against Synchrony Bank for allegedly calling him over 80 times using an autodialer and pre-recorded message,” stated...more

Shipkevich PLLC

California’s Northern District Court Holds Text Messages are Not Pre-Recorded or Artificial Voices Under the Federal TCPA

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On November 18, 2022, the United States District Court for the Northern District of California ruled that text messages sent by a “chatbot” do not constitute an artificial or prerecorded voice, per the federal Telephone...more

Faegre Drinker Biddle & Reath LLP

District of Connecticut Rejects ATDS Allegations in Complaint Against Subway

The District of Connecticut recently dismissed a TCPA action against the Subway Franchisee Advertising Fund Trust (“Subway”) because plaintiff failed to allege that Subway used an ATDS to send text messages to her cell...more

Faegre Drinker Biddle & Reath LLP

Southern District of New York Denies Motion to Dismiss Because Plaintiff Sufficiently Alleged That He Was a “Residential...

The TCPA’s Do Not Call (DNC) regulations prohibit telephone solicitations to “residential telephone subscriber[s]” who have “registered [their] telephone number on the national do-not-call registry.” See 47 C.F.R. §...more

Faegre Drinker Biddle & Reath LLP

Court Rejects Healthcare Facility’s Use of Emergency Purpose Exception

The Middle District of Florida recently held that a defendant cannot invoke the “emergency purposes” exception to the TCPA if the defendant continues to send messages after the plaintiff has instructed the defendant to stop. ...more

Faegre Drinker Biddle & Reath LLP

Defendants Suable in State Where Calls Inadvertently Received, If Similar Calls Purposefully Directed at Forum Residents, Tenth...

Last week, the U.S. Court of Appeals for the Tenth Circuit applied the Supreme Court’s recent Ford Motor decision on personal jurisdiction to a Rule 12(b)(2) motion to dismiss a TCPA claim. In Hood v. American Auto Care,...more

Faegre Drinker Biddle & Reath LLP

W.D.N.Y. Court Dismisses Claim, Finding a School District Is Not a “Person” Under the TCPA, Plaintiff Appeals

The Western District of New York in Clark v. Buffalo City School District, Case No. 1:21cv00700, 2021 WL5764703 (W.D.N.Y. Oct. 28, 2021) recently granted a motion to dismiss because the defendant (a school district) was not a...more

Robinson+Cole Data Privacy + Security Insider

Court Denies GrubHub’s Motion to Dismiss in TCPA Class Action

The U.S. District Court for the Northern District of Illinois denied a motion to dismiss a class action for allegations that GrubHub, Inc. violated the Telephone Consumer Protection Act (TCPA). The plaintiff alleged that she...more

Womble Bond Dickinson

Plaintiffs Alleging Use of Predictive Dialer Defeat Motion to Dismiss TCPA Class Action

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A federal district court in Illinois recently denied an insurance provider’s motion to dismiss a TCPA class action complaint, finding that the alleged use of a predictive dialer was sufficient at the pleading stage. In...more

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