The FCC holds squarely:
if a texting platform actually “requires a person to actively and affirmatively manually dial each recipient’s number and transmit each message one at a time” and lacks the capacity to transmit more than one message without a human manually dialing each recipient’s number, as suggested in the P2P Alliance Petition, then such platform would not be an “autodialer” that is subject to the TCPA.
This is big news for folks using text platforms that allow template-based, fast-paced texting, on a one-to-one (i.e. click-to-text) basis so long as the phone number is entered each time.
Notably the FCC specifically rejected the NCLC’s position that such platforms would enable marketers to spam people’s phones:
The TCPA does not and was not intended to stop every type of call.
To read more, click here.