In Grant v. Regal Auto. Grp., No. 8:19-cv-363-T-23JSS, 2020 U.S. Dist. LEXIS 91897, at *7 (M.D. Fla. May 27, 2020) , the District Court certified a ‘ringless voicemail’ TCPA class.

The plaintiff proposes administratively feasible methods for ascertaining class members. First, the plaintiff aims to use third-party records, which should determine the scope of the potential class with precision. Although the defendant notes that only six thousand of the fourteen thousand ringless voicemails were dispatched successfully, the defendant provides [*8]  neither reasonable argumentation nor probative evidence suggesting that the remaining six thousand telephone numbers identified in the campaign records portray incorrect information (for example, an incorrectly dialed telephone number or an erroneously designated name or address).  Of course, the defendant bears no burden to disprove the entire claim to defeat class certification. Valley Drug Co. v. Geneva Pharm., Inc., 350 F.3d 1181 (11th Cir. 2003). But the defendant must challenge the plaintiff’s methods with more than conjecture about the inaccuracy of the plaintiff’s records. (Doc. 16 at 13-14) Also, according to the defendant, the plaintiff “claims this Court can rely solely  on unreliable records to identify class members.” But the plaintiff claims nothing of the sort.5Instead, the plaintiff states that the records, reliably procured and amply describing the identity of the class members, are sufficient to identify the class. These records are useful for identification and, if nothing else, the records provide an advanced and workable “starting point” from which to identify a class. Reyes, 2018 WL at *13. If need exists for additional verification, the plaintiff posits that she can ascertain class members by employing two other methods – “reverse-appending” and subpoena – each of which carries precedential approval. See, e.g., Keim v. ADFMidAtlantic, LLC, 328 F.R.D. 668, 677-79 (S.D. Fla. 2018) (approving, over the defendants’ objections, the plaintiff’s proposal to subpoena service carriers and employ “reverse lookups” to ascertain subscriber information, and compiling precedent that adopts these methods); Booth v. Appstack, Inc., 2015 WL 1466247, at *4 (W.D. Wash. 2015) (“Defendants’ reliance on these limitations [of the call records] is misplaced because Plaintiffs intend to rely on additional records, such as telephone carrier records and reverse-lookup directories, to identify class members and establish elements of the claims.”). The plaintiff cites extensive legal authority for the methods the plaintiff proposes. See, e.g., (Doc. 52 at 14-16) By contrast, the defendant advances scant authority – likely because only scant authority exists – suggesting that the plaintiff’s proposed methods for ascertaining class members prove unreliable or subjective. . . .The defendant attempts to undermine the authoritative force of the plaintiff’s cited precedent for the “reverse-append” method by noting that the precedent “involved uncontested settlement classes and [is] therefore, of no relevance.” Not only is the defendant’s assertion demonstrably inaccurate, but also the defendant fails to explain why this is a distinction that results in a difference. That is, despite a defendant’s opposition to class certification, the ability to objectively ascertain class members remains a steadfast requirement for class certification. Further contesting the “reverse-append” method, the defendant asserts the novelty and unreliability of the method, and the defendant argues that the plaintiff fails to specify how the method would operate. But the plaintiff describes the “reverse-append” method and cites to a case that suitably explains the method (Doc. 52 at 15, n. 4), and the plaintiff cites extensive authority in which the “reverse-append” method receives approval. (Doc. 52 at 16) The method is anything but novel and, in this instance, the method appears reliable.  Finally, the defendant appeals twice to “common sense” to oppose class certification. However, common sense – alongside a host of precedent  commends the propriety of class certification if the plaintiff possesses detailed records from which to ascertain class members, as well as two approved methods for verifying the class members. The plaintiff’s proposed method contains three feasible steps for reasonably identifying the members of the class, and the defendant’s objections fail.