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In 2020, in Gadelhak v. AT&T Services, the United States Court of Appeals for the Seventh Circuit upheld the Northern District of Illinois’s ruling that a tool that sends text message surveys to consumers was not an automatic telephone dialing system under the Telephone Consumer Protection Act of 1991. The Seventh Circuit reached this decision by rendering a different interpretation for the statutory definition of an automatic dialer than the district court. Gadelhak widened an already substantial circuit court split regarding what technologies the Act covers. This Comment evaluates the strengths and shortcomings of the Seventh Circuit’s narrow interpretation of the statutory definition of an automatic telephone dialing system. It also discusses the potential impact of the Ninth Circuit’s 2019 case, Facebook, Inc. v. Duguid, which explores the same issue, as the Supreme Court of the United States prepares to decide it.


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7 Sep 2022
484 kB



  • Subject
    • Communications Law

    • Courts

    • Supreme Court of the United States

  • Journal title
    • Boston College Law Review

  • Volume
    • 62

  • Issue
    • 9

  • Pagination
    • E.Supp. II.-62

  • Date submitted

    7 September 2022

  • Additional information
    • Suggested Citation:

      Scott J. Sheltra, Comment, A (Solicited) Call for Clarity: The Definition of Automatic Telephone Dialing System After Gadelhak, 62 B.C. L. REV. E. SUPP. II.-62 (2021),