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Text Messages Facebook Inc v Duguid ATDS

McDermott Will & Emery

2024 Updates to State Mini-TCPA Laws

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Since the Supreme Court of the United States issued its ruling in Facebook v. Duguid, which narrowly interpreted the dialing technologies that are considered an automated telephone dialing system (ATDS) regulated by the...more

Klein Moynihan Turco LLP

Are Law Firms Susceptible to TCPA ATDS Claims?

On September 25, 2024, 1-800-LAW-FIRM, PLLC (“Defendant”) was sued in the United States District Court for the Eastern District of Michigan for allegedly violating the automatic telephone dialing system (“ATDS”) and National...more

Womble Bond Dickinson

Second Circuit Finds Text Messages Selected and Sent From a List Using Alleged “SMS Blaster” Not Subject to TCPA Autodialer...

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Aligning itself with three other federal appellate courts, the Second Circuit recently made clear in Soliman v. Subway Franchisee Adver. Fund Trust, Ltd., No. 22-1726-cv, 2024 U.S. App. LEXIS 11417 (2d Cir. May 10, 2024),...more

Carlton Fields

11th Circuit: Another GoDaddy TCPA Class Settlement Is a No-Go

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In the latest decision in a long-running saga in Drazen v. Pinto, the Eleventh Circuit Court of Appeals tackled several issues regarding a proposed class settlement agreement....more

Troutman Pepper Locke

Pa. Autodialer Decision Has Turned TCPA Tides in 3rd Circ.

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The U.S. Supreme Court's 2021 decision in Facebook Inc. v. Duguid resolved a long-standing circuit split over the definition of an automatic telephone dialing system, or ATDS, under the Telephone Consumer Protection Act. ...more

McDermott Will & Emery

Special Report - State Mini-TCPA Laws Create Patchwork Quilt of Regulations for Automated Calls and Texts - July 2023

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Since the Supreme Court of the United States issued its 2021 ruling in Facebook v. Duguid, which narrowly interpreted the dialing technologies that are considered an automated telephone dialing system (ATDS) regulated by the...more

McDermott Will & Emery

Multiple Layers of TCPA Defense Remain Important after Duguid

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The Supreme Court’s 2021 decision in Facebook v. Duguid changed the landscape of Telephone Consumer Protection Act (TCPA) litigation. For years prior, aggressive plaintiffs had stretched the TCPA’s antiquated language...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

Proposed Federal TCPA Legislation Offers a New and Narrow ATDS Definition

On July 12, 2022, Representatives Raja Krishnamoorthi, D-Ill., and Katie Porter, D-Calif. introduced H.R. 8334 in the U.S. House of Representatives, which was referred to the Committee on Energy and Commerce. The bill would...more

Fox Rothschild LLP

New House Bill Threatens to Expand the TCPA to Regulate Text Messages

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Last week, six House Democrats introduced H.R. 8334, the Robotext Scam Prevention Act, which seeks to expand federal telemarketing laws to, among other things, expressly cover text messaging. ...more

Goodwin

Third Circuit Rules that Caller Must Use An “Automatic Telephone Dialing System’s” Ability to Produce or Store Telephone Numbers...

Goodwin on

On June 14, 2022, the Third Circuit Court of Appeals (Third Circuit) issued a significant decision regarding the TCPA’s restrictions in Section 227(b)(1)(A)(iii) on using an automatic telephone dialing system (ATDS)...more

Troutman Pepper Locke

Recent Trends in TCPA Litigation - The Consumer Finance Podcast

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Please join Troutman Pepper Partner Chris Willis and his guest and fellow Partner Stefanie Jackman as they discuss recent trends in Telephone Consumer Protection Act (TCPA) litigation, including how the landscape has changed...more

Goodwin

Florida’s Telephone Solicitation Act Survives First Constitutional Challenge

Goodwin on

Since becoming law in July 2021, Florida’s Telephone Solicitation Act (FTSA), Fla. Stat. § 501.059(8)(a), has been a favorite of plaintiffs’ lawyers seeking to take advantage of its ambiguous restrictions on certain sales...more

Faegre Drinker Biddle & Reath LLP

Eighth Circuit Finds That System That Sends Texts to Stored Numbers is Not an ATDS, Rejects Plaintiffs’ Interpretation of Footnote...

Last week, the Eighth Circuit affirmed a finding that a dialing system does not qualify as an ATDS if it randomly selects numbers from a stored list. See Beal v. Truman Road Dev. (8th Cir. Mar. 24, 2022)...more

Faegre Drinker Biddle & Reath LLP

Personal Cell Phones May Qualify as “Residential Telephones” Subject to DNC Rules, but Calls Made to a Pre-produced List Are Not...

Last week, the U.S. District Court for the Northern District of Texas held that mobile phones may qualify as “residential telephones” when used (as the Complaint alleged) primarily for “personal, family, and household use,”...more

Moore & Van Allen PLLC

“Simply Beyond the Bounds of Common Sense”

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California federal court rejects plaintiff’s attempt to circumvent Facebook In April 2021, the Supreme Court dealt a massive blow to Telephone Consumer Protection Act claims based on automatic telephone dialing systems...more

Wyrick Robbins Yates & Ponton LLP

The Aftermath of Facebook v. Duguid: Trends and Practical Tips

As we discussed in a post last year the Supreme Court issued a landmark decision in the Spring of 2021, on the TCPA’s definition of an “automatic telephone dialing system.” In that decision, called Facebook v. Duguid, the...more

ArentFox Schiff

Unanimous Supreme Court Decision Narrows the Scope of the TCPA

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An April Supreme Court ruling significantly reduced the scope of communications platforms that could be considered autodialers subject to the Telephone Consumer Protection Act (TCPA). The decision in Facebook, Inc. v....more

Womble Bond Dickinson

Company Using Predictive Dialer Prevails in Post-Facebook Decision

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A federal court out of Nebraska recently issued a decision providing a decisive post-Facebook v. Duguid victory for a company using a predictive dialer. In Grome v. USAA Savings Bank, No. 4:19-CV-3080, 2021 WL 3883713 (D....more

Goodwin

Florida Tightens Telemarketing Restrictions In Wake of Duguid Ruling

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Restrictions on telemarketing to Florida residents are about to get tighter. Just a few months ago, in Facebook, Inc. v. Duguid, 592 U.S. ___ (2021), the U.S. Supreme Court ruled that for the purposes of the Telephone...more

Carlton Fields

CF on Cyber: An Update on the Changes to the Florida Telemarketing Act

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On June 29, Gov. Ron DeSantis signed into law a bill enacting substantial changes to the Florida Telemarketing Act, which are effective July 1, 2021. In this podcast, Carlton Fields shareholders Aaron Weiss and Charles...more

Sunstein LLP

Privacy in the Cellphone Era: The Supreme Court Opens the Door to Automated Text Messages

Sunstein LLP on

In 1890, Louis Brandeis wrote a seminal law review article on privacy, defining it as “the right to be left alone.” In 1991, Congress enacted the Telephone Consumer Protection Act (TCPA) to reinforce that right. This month,...more

Sheppard Mullin Richter & Hampton LLP

Texting Post-Duguid: Can Consent Practices Change?

Providing business teams with advice for sending text messages can be nothing short of frustrating. For businesses used to sending email marketing, the laws for texting are unexpected. Unlike the CAN-SPAM Act, TCPA requires...more

King & Spalding

Supreme Court Limits the Reach of the TCPA by Narrowing the Definition of “Autodialer”

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On April 1, 2021, in Facebook, Inc. v. Duguid, the Supreme Court clarified what constitutes an “automatic telephone dialing system”—commonly referred to as an “autodialer”—under the Telephone Consumer Protection Act (“TCPA”)....more

Hudson Cook, LLP

[Webinar] Compliance Coffee Break: The Facebook, Inc. v. Duguid Supreme Court decision - What it means for TCPA private actions...

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On April 1, 2021, the U.S. Supreme Court announced its decision in Facebook, Inc. v. Duguid, adopting a narrow "autodialer" standard under the Telephone Consumer Protection Act (TCPA). In siding with Facebook, the Supreme...more

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