by David O. Klein
Courts across the country continue to adapt in the wake of the
U.S. Supreme Court's decision in Facebook, Inc. v. Duguid. A little
over a year ago, this landmark case settled a circuit split about what
features dialing equipment must have to qualify as an autodialer under
the Telephone Consumer Protection Act ("TCPA"). Despite the decision's ramifications, most interpreting courts declined to step away from
Facebook's analysis. However, this may have changed in a case titled
Panzarella v. Navient Solutions, Inc. In this recent decision, the
Third Circuit seems to have broadened the TCPA autodialer definition
to a startling degree.
https://tinyurl.com/5jaxbc76
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