TCPA Tracker: July-August 2025

I. Central District of Illinois Finds Text Messages Are Not Covered Under the TCPA

The United States District Court for the Central District of Illinois granted Defendant Blackstone Medical Services, LLC's motion to dismiss a putative class action complaint, holding text messages are not covered by the Do Not Call provisions of the TCPA.

The complaint alleged that Plaintiffs received repeated marketing text messages despite texting STOP in response. Based on these facts, Plaintiffs filed suit under 47 C.F.R. § 227 et. seq. and 47 C.F.R. §64.1200(c)(2) and (d), as well as the Florida Telephone Solicitation Act ("FTSA"), Fla. Stat. § 501.059(5). With respect to the TCPA causes of action, Defendant moved to dismiss, arguing that phrases like "text message" and "SMS message" were entirely absent from Section 227(c)(5) and its implementing instructions. Thus, by the statute's plain text, Section 227(c) only covers "telephone calls," not text messages. In