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Thursday, October 22, 2026

E.D. Cal Judge Rules SMS Are Calls Under TCPA as Coast Dental Settlement Hits $3.84M

A federal magistrate judge in E.D. Cal ruled that text messages count as calls under the TCPA, adding another data point to a running legal debate. Separately, the Coast Dental TCPA settlement was confirmed at $3.84 million and a Middle District of Alabama court certified a class settlement with per-member awards of $500 to $1,000.

1Lookup Signal Report

2.9% of 3,628 phone checks on 1Lookup came back VOIP today

Across 3,628 checks run on the 1Lookup platform on 2026-10-22, 2.9% came back VOIP. Mobile numbers ran at 70.4% of checks, up 6.6 points from the trailing seven-day average of 63.8%, while landline ran at 14.0%, down 8.8 points from the trailing seven-day average of 22.8%. Phone number status checks showed 84.6% active across 3,068 of 3,628 numbers, and email deliverability checks found 89.6% deliverable with 4.1% undeliverable across 2,413 checks.

Phone line types

3,628 checks

  • mobile70.4%
  • landline14%
  • VOIP2.9%
  • other line types12.7%

Phone number status

3,628 checks

  • active84.6%
  • inactive2.3%
  • other line types13.1%

Email deliverability

2,413 checks

  • deliverable89.6%
  • risky4.6%
  • undeliverable4.1%
  • other line types1.7%

Every completed lookup on 1Lookup this UTC day.

  1. 01

    E.D. Cal magistrate judge rules SMS messages are calls under the TCPA

    In Lewis v. Tenth Hall, 2026 WL 3152283 (E.D. Cal. Oct. 21, 2026), the court held that SMS messages are calls under the TCPA, following established authority on the question. The ruling adds another data point to the ongoing debate over whether text messages qualify as calls for TCPA purposes.

    Why it matters: If your business sends marketing or informational texts, this ruling confirms that courts in this district treat those texts the same as phone calls for TCPA liability purposes, meaning consent and do-not-call rules that apply to calls apply to your texts too.

  2. 02

    Coast Dental's TCPA text message settlement set at $3.84 million

    Coast Dental will pay up to $3.84 million to resolve a TCPA class action over text messaging do-not-call violations, confirming the figure reported earlier this week. The settlement is one more in a series of multi-million-dollar TCPA SMS do-not-call class action resolutions.

    Why it matters: This settlement shows text message do-not-call violations continue to draw seven-figure payouts. If your outbound program includes SMS, scrubbing against do-not-call lists before texting is as important as it is for calls.

  3. 03

    Alabama court certifies TCPA class settlement with $500 to $1,000 per member

    In Jenae Knox v. Maximus Educ., LLC, dba Aidvantage, the Middle District of Alabama certified a TCPA class settlement awarding each participating class member between $500 and $1,000 in damages, described as an extremely favorable award despite defense counsel's extensive TCPA experience.

    Why it matters: This settlement size shows individual TCPA violations can carry real per-person cost. If your calling or texting program has gaps in consent tracking, exposure scales with every contact in the class.

  4. 04

    Report finds fewer than half of phone companies fully verify caller ID

    AccountsRecovery.net's October 22 Daily Digest included a report stating fewer than half of phone companies fully verify caller ID. The digest also covered a $662 million Snap Finance lease forgiveness settlement across 17 states and other collections industry litigation items.

    Why it matters: If fewer than half of phone companies fully verify caller ID, businesses that rely on accurate caller ID display for outbound calls face a real risk their numbers get flagged or spoofed without full carrier-side verification backing them up.

  5. 05

    TCPA defense lawyer sanctioned for using GenAI tools in court filings

    A TCPA defense lawyer was sanctioned for using generative AI tools in legal work. TCPAWorld's commentary argued that GenAI legal tech tools do not work reliably and are unlikely to work in the foreseeable future for this kind of legal work.

    Why it matters: If your business uses outside counsel or compliance vendors leaning on GenAI tools to draft TCPA filings or compliance guidance, this sanction is a reminder that unchecked AI output can create real legal risk rather than reduce it.

Questions people asked today

Does a new ruling say text messages count as calls under the TCPA?
Yes. In Lewis v. Tenth Hall, an E.D. Cal magistrate judge held that SMS messages are calls under the TCPA, following existing authority on the question, as of October 21, 2026.
How much is the Coast Dental TCPA settlement worth?
Coast Dental agreed to pay up to $3.84 million to resolve a TCPA class action over text messaging do-not-call violations.
What did the Alabama TCPA class settlement award?
The Middle District of Alabama certified a settlement in Jenae Knox v. Maximus Educ., LLC, dba Aidvantage, awarding each participating class member $500 to $1,000 in damages.
What share of phone checks on 1Lookup came back VOIP today?
Across 3,628 checks run on the 1Lookup platform on October 22, 2026, 2.9% came back VOIP, while mobile numbers ran at 70.4% of checks, up 6.6 points from the trailing seven-day average of 63.8%.

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