TCPA Quick Hitter: Another Court Holds Threadbare Allegation of Prerecorded Voice Usage Insufficient to State a Claim
Monday, November 21, 2022
7th Circuit Van Elzen v. Advisors 2022 TCPA Case

So real quick folks, I see a trend here.

In the old days–last year–a plaintiff could state a claim under the TCPA merely by alleging a prerecorded voice was used to contact him/her. No muss, no fuss.

Lately, however, courts have been requiring more.

Van Elzen v. Advisors, 2022 WL 16961131 (E.D. Wisc. Nov. 16, 2022) is of the same ilk. It holds that the mere allegation of prerecorded call usage is simply insufficient. Something more needs to be alleged. (And the fact that others received the same call is insufficient.)

That’s it. Something to be thankful for.

Big Thanksgiving blog up later today. We have so much to be thankful for.

Also for those looking to bid for advertising in the annual review the deadline is this Wednesday at noon pacific! Don’t miss it.


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