This just in.

https://scholar.google.com/scholar_c...=1&oi=scholarr

Summary:

Telephone Dialing System Found Not to be an ATDS

In Ferrer v. Bayview Loan Servicing, LLC, plaintiff Maria Ferrer alleged, among other things, that Bayview used an ATDS to call her cell phone 44 times. The Southern District of Florida has found that the system used by Bayview to make the calls to the plaintiff was not an Automatic Telephone Dialing System (ATDS) because it requires call-by-call human intervention. The system used by the defendants was the Avaya X1 platform. Read the court's order granting summary judgment in favor of the defendants here.