Facebook, Inc. v. Duguid
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A short, plain-English overview of Facebook, Inc. v. Duguid.
The Supreme Court addressed whether Facebook's login notification system violated the Telephone Consumer Protection Act (TCPA) by using an autodialer. The Court determined that to qualify as an autodialer, a device must use a random or sequential number generator to store or produce telephone numbers. The Ninth Circuit's decision was reversed, as Facebook's system did not meet this definition.
Holding
The single most important “bottom line” of what the Court decided in Facebook, Inc. v. Duguid.
The Court held that a device must use a random or sequential number generator to qualify as an autodialer under the TCPA.
Key Quotes
Short excerpts from the syllabus in Facebook, Inc. v. Duguid that support the summary and concepts above.
To qualify as an “automatic telephone dialing system” under the 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.
Congress ultimately chose a precise autodialer definition.
This Court cannot rewrite the TCPA to update it for modern technology.
