Court Vacated $122,500 Judgment in Ohio TCPA Case

An Ohio federal court ruled in favor of a debt collector following a shift in the legal definition of autodialers.

Updated on Oct. 1, 2026 in Debt Relief

Court Vacated $122,500 Judgment in Ohio TCPA Case

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An Ohio District Court granted summary judgment to Receivables Performance Management, LLC, vacating a prior $122,500 judgment against the company. The ruling follows the Supreme Court's 2021 decision in Facebook, Inc. v. Duguid, which redefined what constitutes an automatic telephone dialing system.

Why it matters

The decision clarifies the legal status of predictive dialing technology used by debt collectors. By aligning with the Supreme Court precedent, the court established that systems which do not store or produce random phone numbers fall outside the scope of certain telecommunications act penalties.

The defendant allegedly contacted the plaintiff's cellphone 245 times using a Noble Predictive Dialer. This system, which operates from pre-existing lists, was determined not to be an automatic telephone dialing system under current federal standards.

The players

Receivables Performance Management, LLC

This organization operates as a debt collection agency that utilizes predictive dialing systems to manage communication with debtors.

Phillip Ramsey

He is the plaintiff who initiated the legal action in 2016 regarding repeated calls to his cellphone.

Facebook, Inc.

This major technology company was the petitioner in a landmark 2021 Supreme Court case that redefined federal autodialer regulations.

The details

The court found that the Noble Predictive Dialer used by the defendant functioned by selecting accounts from a database rather than generating random numbers. Consequently, the judge concluded that the dialing system did not meet the legal threshold for an automatic telephone dialing system as established by the Supreme Court.

Phillip Ramsey filed the initial lawsuit against the company in 2016.
A judge initially denied summary judgment to the defendants in 2019.
The court previously granted partial summary judgment to the plaintiff in 2020.
The Supreme Court issued the Facebook, Inc. v. Duguid ruling in 2021.
The District Court granted the motion for reconsideration on September 29, 2026.

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Market Dynamics

The ruling aligns with the standard set by the Facebook, Inc. v. Duguid decision regarding the regulation of automated communications. This outcome narrows the liability landscape for collection agencies relying on predictive dialing software to manage account outreach.

The ruling limits the potential litigation risks for financial entities utilizing predictive dialers for collection efforts. Retail investors in companies leveraging similar call center technologies may see reduced exposure to TCPA-related legal settlements.

The takeaway

This decision reinforces the importance of tracking Supreme Court precedents in consumer protection law. Companies and individuals should note that technical definitions of equipment often determine the validity of claims in telecommunications litigation.