Real Property Update
No cases of interest to report.
Financial Services Update
- TCPA / ATDS: To qualify as an ATDS, a device must have the capacity to store a telephone number using a random or sequential number generator, or to produce a telephone number using a random or sequential number generator – Facebook, Inc. v. Duguid, No. 19-511 (U.S. Apr. 1, 2021)
- FCRA / Description of Judgment: Credit reporting agency’s description of default judgment, which had been entered against a consumer as “satisfied,” was accurate – Shimon v. Equifax Info. Servs. LLC, No. 20-689 (2d Cir. Apr. 9, 2021)
Title Insurance Update
No cases of interest to report.