National Law Review
7/15/2026

Seventh Circuit Holds Text Messages Are Not 'Telephone Calls' Under TCPA DNC Provisions
Original: TEXTS AREN’T CALLS!: Seventh Circuit Court of Appeals Holds Definitively Text Messages Are Not Telephone Calls for TCPA DNC Purposes– And Now the Whole Nation Will Take Notice
Short summary
The Seventh Circuit held in Stenindingr v. Blackstone Medical Services that text messages are not 'telephone calls' under the TCPA's DNC provisions, barring private lawsuits for unwanted SMS. The court reasoned that 'telephone call' meant voice communication in 1991 when the TCPA was enacted. However, agencies can still enforce against illegal SMS, and automated campaigns under §227(b) remain subject to TCPA requirements.
- •Seventh Circuit: SMS messages are not 'telephone calls' under TCPA DNC rules — no private right of action
- •Agency enforcement under other TCPA provisions remains available for illegal SMS
- •Automated SMS campaigns under §227(b) still subject to TCPA; state laws may still apply
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