In Saunders v. Dyck O’Neal, Inc., No. 1:17-CV-335, 2018 WL 3453967 (W.D. Mich. July 16, 2018), defendant argued that its “direct drop” voicemails are not covered by the Telephone Consumer Protection Act (“TCPA”). The court disagreed and denied Dyck O’Neal’s motion for summary judgment. Id. at *1.

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