Whether the definition of an 'automatic telephone dialing system' (ATDS) in the Telephone Consumer Protection Act of 1991 (TCPA) encompasses any device that can 'store' and 'automatically dial' telephone numbers, even if the device does not 'us[e] a random or sequential number generator'

QUESTION PRESENTED In Facebook, Inc. v. Duguid, No. 19-511 (U.S. granted July 9, 2020), this Court granted certiorari to determine whether the definition of an “automatic telephone dialing system” (““ATDS”) in the Telephone Consumer Protection Act of 1991 (“TCPA”) encompasses any device that can “store” and “automatically dial” telephone numbers, even if the device does not “us[e] a random or sequential number generator.” 47 U.S.C. §227(a). This case presents the same question. The question presented is: Whether the definition of ATDS in the TCPA encompasses any device that can “store” and “automatically dial” telephone numbers, even if the device does not “us[e] a random or sequential number generator.” ii STATEMENT OF