Last week, the Western District of Washington granted in part and denied in part a motion to dismiss a TCPA putative class action lawsuit against Assurance IQ and Boomsourcing after finding that plaintiffs failed to allege facts to support the elements of a TCPA claim.  See Order Granting in Part and Denying in Part Motions to Dismiss, Rogers v. Assurance IQ, LLC, No. 2:21-cv-00823-TL (W.D. Wash. March 27, 2023).

Plaintiffs’ alleged they received pre-recorded marketing calls to their home landlines or cellphones from Assurance IQ, an insurance company, without consent.  Two of the plaintiffs also alleged that they received these calls despite having their numbers registered on the Do Not Call registry.  The complaint also sought to hold Boomsourcing liable for TCPA violations, alleging that Boomsourcing was Assurance IQ’s vendor that physically dialed the calls.

The court held that plaintiffs failed to allege a pre-recorded voice call claim because plaintiffs’ allegations simply stated that the calls were pre-recorded without offering any facts explaining how plaintiffs reached that conclusion.  The court explained that, even before discovery, plaintiffs should be able to allege facts that support the inference that the call was pre-recorded, such as the nature or circumstances of the call, rather than merely stating the legal conclusion.

Similarly, the court held that plaintiffs failed to allege facts to support a claim that Assurance IQ called their residential phone numbers after plaintiffs had registered their numbers on the Do Not Call registry.  Again, the court noted that these facts should be simple for plaintiffs to allege without discovery.  Instead, the complaint alleged that plaintiffs’ telephone numbers were for “personal use” rather than residential lines.  The complaint also used the passive voice to state the phone numbers “were registered” on the Do Not Call registry instead of alleging that plaintiffs themselves registered their numbers.  The court therefore found the allegations to be conclusory and insufficient to sustain the TCPA claim.

Finally, defendant Boomsourcing moved to dismiss on the theory that plaintiffs failed to allege it was directly liable for a TCPA violation, while defendant Assurance IQ argued that plaintiffs failed to allege it was vicariously liable.  The court agreed with Boomsourcing, noting that the allegation that Boomsourcing “physically dialed” the calls did not show that Boomsourcing knew Assurance IQ was placing the calls in violation of the TCPA.  Furthermore, plaintiffs failed to allege any facts that Boomsourcing physically dialed the specific calls made to plaintiffs.  As to Assurance IQ, the court held that plaintiffs failed to allege any facts establishing an agency relationship between Assurance IQ and the service providers that placed the calls. While the complaint mentioned a contract between Assurance IQ and Boomsourcing, it failed to include any specifics demonstrating the contract required Boomsourcing to place pre-recorded calls on Assurance IQ’s behalf.

Despite these significant deficiencies in the amended complaint, the court granted plaintiffs leave to amend their complaint one final time, noting that the previous amendments were not in response to a motion to dismiss.

    Photo of Jenna Zhang Jenna Zhang

    Jenna Zhang advises clients across industries on data privacy, cybersecurity, and emerging technologies. 

    Jenna partners with clients to ensure their compliance with the rapidly evolving federal and state privacy and cybersecurity laws. She supports clients in designing new products and services, drafting privacy…

    Jenna Zhang advises clients across industries on data privacy, cybersecurity, and emerging technologies. 

    Jenna partners with clients to ensure their compliance with the rapidly evolving federal and state privacy and cybersecurity laws. She supports clients in designing new products and services, drafting privacy notices and terms of use, responding to cyber and data security incidents, and evaluating privacy and cybersecurity risks in corporate transactions. In particular, she advises clients on substantive requirements relating to children’s and student privacy, including COPPA, FERPA, age-appropriate design code laws, and social media laws.

    As part of her practice, Jenna regularly represents clients in data privacy investigations and enforcement actions brought by the Federal Trade Commission and state attorneys general. She also supports clients in proactive engagement with regulators and policymakers to ensure their perspectives are heard.

    Jenna also maintains an active pro bono practice with a focus on supporting families in adoptions, guardianships, and immigration matters.