The Northern District of Illinois was one of the first courts after ACA International to hold that a telephonic system must have a random or sequential number generator to be an ATDS. The court recently doubled down on that position, holding that “[p]redictive dialers include a wide variety of devices, some of which do not qualify as an ATDS under the TCPA because they lack the capacity to randomly or sequentially generate numbers to dial.” Zeidel v. Nat’l Gas & Elec., LLC, 18-cv-06792, 2019 U.S. Dist. LEXIS 83988 (N.D. Ill. May 17, 2019).
Read the Whole Story »
