Autodialer: US Court of Appeals Deepens Split in TCPA Confusion

The Second Circuit in Duran v La Boom Disco Inc., held that systems that can call numbers from a list or database uploaded by humans constitutes an ATDS, and clicking “send” or a similar button does not require enough human intervention to turn an autodialer into a non-automatic one; a smartphone is not an ATDS, as clicking on a name in a digital phonebook is a form of speed-dialing or constructive dialing that is not the functional equivalent of dialing by inputting numbers.

https://www.troutman.com/images/content/2/2/v2/225037/Duran-v.-La-Boom-Disco-Inc.-2d-Cir..pdf