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A federal judge in the Northern District of Ohio recently held that text messages are not subject to the TCPA’s Do-Not-Call provision because they are not “calls” within the meaning of the statute. Stockdale v. Skymount Prop. Grp., LLC, et al., 2026 WL 591842 (N.D. Ohio Mar. 3, 2026). In Stockdale, Plaintiff alleged that she