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1. Laci Satterfield received an unsolicited text message from book publisher Simon & Schuster, advertising a new Stephen King novel. Satterfield sued Simon & Schuster

1. Laci Satterfield received an unsolicited text message from book publisher Simon & Schuster, advertising a new Stephen King novel. Satterfield sued Simon & Schuster for violation of the Telephone Consumer Protection Act (TCPA). Simon & Schuster defended, arguing that a text message was not a "telephone call" under the TCPA. HOW SHOULD THE COURT RULE ON THIS ISSUE AND WHY?

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