This article regarding a recent Third Circuit ruling allowing a woman to bring a suit under the Telephone Consumer Protection Act over a single pre-recorded message left on her voicemail shows that defendants cannot count on the U.S. Supreme Court’s pivotal Spokeo decision to end consumer protection class actions. Jeffrey J. Greenbaum, Chair of the Firm’s Class Action Practice Group, commented: “Here, the woman certainly didn’t seem to have any real injury; she didn’t take the call…The court seems to be taking a minimalist view of the type of injury necessary to invoke federal jurisdiction…The opinion has the potential to open the floodgates to a cottage industry of plaintiffs’ class action TCPA lawyers.”
