by David O. Klein
Courts across the country continue to adapt in the wake of the U.S. Supreme Court's decision in Facebook, Inc. v. Duguid. A little over a year ago, this landmark case settled a circuit split about what features dialing equipment must have to qualify as an autodialer under the Telephone Consumer Protection Act ("TCPA"). Despite the decision's ramifications, most interpreting courts declined to step away from Facebook's analysis. However, this may have changed in a case titled Panzarella v. Navient Solutions, Inc. In this recent decision, the Third Circuit seems to have broadened the TCPA autodialer definition to a startling degree.
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