by Sheila Raftery Wiggins
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A California federal court ruled that a text asking a patient to rate the doctor - sent minutes after the examination by a company that contracts with the health care provider to send Patient Satisfaction Surveys - does not alone satisfy an inference that the text was sent by an Automatic Telephone Dialing System ("ATDS") within the definition of the Telephone Consumer Protection Act, 47 U.S.C. § 227 ("TCPA").
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