Eva A. Cann, left, and Jonathan E. Green, right, shareholders with Baker Donelson. Courtesy photos Eve A. Cann, left, and Jonathan E. Green, right, shareholders with Baker Donelson. Courtesy photos

In its newly released decision in Facebook v. Duguid, the U.S. Supreme Court (SCOTUS), in an opinion authored by Justice Sonia Sotomayor, issued a long-awaited ruling resolving a circuit split on the definition of an autodialer under the Telephone Consumer Protection Act (TCPA). In doing so, the court takes us on a lengthy grammar lesson on statutory construction, before ultimately ruling in favor of Facebook and holding that a necessary feature of an autodialer under the TCPA is the capacity to use a random or sequential number generator to either store or produce phone numbers to be called.