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ARTICLE · 28 JULY 2025

Caller ID And Text Messages

Klein Moynihan Turco LLP
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In Newell v. JR Capital, LLC, a Pennsylvania federal court recently considered, among other things, whether the Telephone Consumer Protection Act's ("TCPA") caller identification ("Caller ID") requirements...

United StatesMedia, Telecoms, IT, Entertainment
David O. Klein
David O. Klein
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In Newell v. JR Capital, LLC, a Pennsylvania federal court recently considered, among other things, whether the Telephone Consumer Protection Act's ("TCPA") caller identification ("Caller ID") requirements apply to text messages. Below, we discuss the decision in detail and its implications for telemarketers.

Private Right of Action for Failing to Comply With Caller ID Requirements

Newell alleged that he received five unsolicited text messages from JR Capital advertising its products. Every text message contained a link to the JR Capital website, and four of the messages included a contact phone number. In the Complaint, Newell alleged, among other things, that JR Capital's text messages violated the TCPA regulations establishing Caller ID requirements ("Caller ID Regulations"). JR Capital moved to dismiss the Caller ID Regulations claim arguing that: (1) no private right of action exists under the Caller ID Regulations; (2) the Caller ID Regulations do not apply

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