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Pleadings and Discovery

This brief addresses the applicability of section 227(c)(5) to text messages. 

The Telephone Consumer Protection Act prohibits sending text messages to phone numbers on the national Do Not Call List, just as it prohibits traditional voice calls. As both the FCC and courts have long recognized, the plain meaning of the word “call” in the TCPA
encompasses any attempt to communicate by phone, “regardless of whether that call is communicated by voice or text.”

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This brief addresses the applicability of section 227(c)(5) to text messages. 

The Telephone Consumer Protection Act prohibits sending text messages to phone numbers on the national Do Not Call List, just as it prohibits traditional voice calls. As both the FCC and courts have long recognized, the plain meaning of the word “call” in the TCPA
encompasses any attempt to communicate by phone, “regardless of whether that call is communicated by voice or text.”

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DentalPlans made many thousands of telemarketing robocalls to the cell phones of Plaintiff and tens of thousands of other similarly situated Americans. On June 6, 2024, this Court denied defendant DentalPlans’ summary judgment motion on the issue of whether it had consent to make the calls, and granted Plaintiff’s motion for class certification.

The summary judgment ruling was based upon the Court’s finding that DentalPlans was required to have obtained “prior express written consent” for its robocalls, because that is the standard the FCC set for telemarketing robocalls.

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This June 16, 2025 memorandum of law opposing a motion to compel arbitration was filed in a federal court case in the District of New Jersey.  The case involves a home equity investment (HEI) mortgage, in which homeowners receive a lump sum in exchange for a share of their home's future value, typically upon sale or refinance. Unlike traditional loans, HEIs do not involve monthly payments or interest charges. The investor's return is tied to the appreciation of the home's value.

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