In Romero v. Department Stores National Bank, 199 F.Supp.3d 1256, 1265 (S.D. Cal. 2016), the California District Court held that a TCPA plaintiff must show that their injury from autodialed calls was substantively different than had the calls been manually dialed; “Moreover, the specific facts of this case reveal that any harm suffered by Plaintiff is unconnected to the alleged TCPA violations. Defendants here were creditors of Plaintiff and were attempting to collect a debt. They were calling Plaintiff’s cell phone because that was the only telephone number she provided them. Although these calls seeking to collect debts may have been stressful, aggravating, and occupied Plaintiff’s time, that injury is completely unrelated to Defendants’ use of an ATDS to dial her number. Plaintiff would have been no better off had Defendants dialed her telephone number manually”. Two cases recently disagreed with that decision. See Mohamed v. Off Lease Only, Inc., 15-23352-Civ, 2017 WL 1080342 *2 (S.D. Fla. 03/22/2017) (“I respectfully disagree with the Romero and Ewing decisions”); Hamza v. Dunhams Athleisure Corp., Case No. 16-11641, 2017 WL 1077895 * 4 (E.D. Mich. 03/22/2017) (“The standard proposed by Defendant, as set forth in Romero, is not reasonable and should not be adopted”).