by Daniel S. Blynn

Several years ago, in /Salcedo v. Hanna/, the Eleventh Circuit held
that the receipt of a single allegedly unsolicited, autodialed text
message was not a concrete enough injury-in-fact to establish Article
III standing for a plaintiff under the federal Telephone Consumer
Protection Act (TCPA). We covered that decision here.

Since then, the /Salcedo/ court's reasoning has been applied by
Florida district courts in cases involving five text messages, the
receipt of ringless voicemails, and unanswered prerecorded message
calls.

https://tinyurl.com/bdhns5xj

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