On April 1, 2021, the U.S. Supreme Court decided Facebook, Inc. v. Duguid, holding that to qualify as an “automatic telephone dialing system” (commonly referred to as an “autodialier”) under Section 227(a)(1)(A) of the Telephone Consumer Protection Act (TCPA), “a device must have the capacity either to store a telephone number using a random or sequential number generator, or to produce a telephone number using a random or sequential number generator.” Facebook, Inc.
