Many welcomed the U.S. Supreme Court's 2021 Duguid decision because it appeared to call a halt to at least some of the abuses of the Telephone Consumer Protection Act, 47 U.S.C. Section 227. See Facebook v. Duguid, 141 S. Ct. 1163. In Duguid, the court held that Facebook was not liable because the equipment it used to send the text messages at issue did not qualify as an "automatic telephone dialing system," or ATDS, under the TCPA.