News & Analysis as of

Facebook Inc v Duguid Random or Sequential Number Generator

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

Klein Moynihan Turco LLP

Third Circuit Clarifies TCPA ATDS Liability

On April 8, 2024, the Third Circuit Court of Appeals issued an opinion clarifying Telephone Consumer Protection Act (“TCPA”) Automatic Telephone Dialing System (“ATDS”) liability in the wake of the United States Supreme...more

Womble Bond Dickinson

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

Womble Bond Dickinson on

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

Troutman Pepper

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

Troutman Pepper on

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

Troutman Pepper

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

Troutman Pepper on

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

First Post-Facebook Appeal Makes Its Way to Supreme Court

Troutman Pepper on

More than two years after the Supreme Court released its ruling in Facebook v. Duguid, confirming the meaning of automatic telephone dialing systems (ATDS) under the Telephone Consumer Protection Act (TCPA), a plaintiff has...more

Troutman Pepper

The Ninth Circuit Reinforces Narrow Interpretation of ATDS under Borden Holding System Must Generate Random or Sequential...

Troutman Pepper on

On April 13, the Ninth Circuit issued an opinion affirming a district court’s summary judgment order on the grounds that under Borden v. eFinancial, LLC, discussed here, to qualify as an automatic telephone dialing system...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

Recent Trends in TCPA Litigation - The Consumer Finance Podcast

Troutman Pepper on

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

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

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

Troutman Pepper

Post-Facebook v. Duguid: Lower Courts Speak (UPDATED)

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The U.S. Supreme Court’s long-awaited decision in Facebook v. Duguid, 141 S. Ct. 1163 (2021), answered in the affirmative a question that had divided courts for years: Did the Telephone Consumer Protection Act’s (TCPA)...more

Troutman Pepper

4 Ways Courts Are Approaching High Court’s TCPA Ruling

Troutman Pepper on

The U.S. Supreme Court’s long-awaited decision in Facebook v. Duguid answered in the affirmative a question that had divided courts for years: Did the Telephone Consumer Protection Act’s definition of automatic telephone...more

ArentFox Schiff

Unanimous Supreme Court Decision Narrows the Scope of the TCPA

ArentFox Schiff on

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

ArentFox Schiff

Class Actions Quarterly Update: Supreme Court - September 2021

ArentFox Schiff on

The latest trends and developments in the class action world. Since our last update was published, the United States Supreme Court has addressed a number of appeals involving class actions. Requirement of Concrete...more

Womble Bond Dickinson

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

Womble Bond Dickinson on

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

Womble Bond Dickinson

Company Using Predictive Dialer Prevails in Post-Facebook Decision

Womble Bond Dickinson on

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

Faegre Drinker Biddle & Reath LLP

Does Unused “Capacity” Make a Dialer an ATDS? District Court Says “No” in Ruling on Pleading Requirements After Facebook

Three months after the Supreme Court’s landmark Facebook ruling, a growing number of trial courts have grappled with interpreting and applying the High Court’s directive. One of the more interesting decisions came out of the...more

Goodwin

Florida Tightens Telemarketing Restrictions In Wake of Duguid Ruling

Goodwin on

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

Hudson Cook, LLP

Facebook Decision Upends TCPA Litigation Landscape

Hudson Cook, LLP on

[co-author: Michael Daly] The Supreme Court’s decision was a victory for Facebook and any other business that routinely attempts to communicate with its consumers using stored lists of consumer numbers. The Supreme...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

Foley & Lardner LLP

Florida Telemarketing Alert: Florida Likely Has Adopted Strict Rules on Marketing Phone Calls, Text Messages, and Voicemails

Foley & Lardner LLP on

On April 28, 2021, both houses of the Florida legislature unanimously voted to amend Florida’s Telemarketing Act with CS/SB 1120 (the “Act”). The Act was presented to Florida Governor Ron Desantis on June 28, and approved by...more

Troutman Pepper

Court Finds Calls Triggered by Alarm System Do Not Violate the TCPA

Troutman Pepper on

In Watts v. Emergency Twenty Four, Inc. (No. 20-cv-1820 (N.D. Ill. June 21, 2021), the Northern District of Illinois granted a motion to dismiss claims asserted against a security company under the Telephone Consumer...more

Carlton Fields

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

Carlton Fields on

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

Smith Debnam Narron Drake Saintsing & Myers,...

The Supreme Court Weighs in on the Telephone Consumer Protection Act

On April 1, 2021, the United States Supreme Court unanimously held that in order to qualify as an automated telephone dialing system under the Telephone Consumer Protection Act (the “TCPA”), a device must have the capacity...more

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