Rabbitt v. Rohrman - Is a Text Message a Call for TCPA and Do Not Call (DNC)

When Is a Text a “Call”? Courts Remain Split and Ecommerce Businesses Are Caught in the Middle

Ecommerce Innovation Alliance

April 10, 2026

The legal landscape around SMS marketing is becoming more complex and more consequential for ecommerce businesses. A recent Illinois federal court decision in Rabbitt v. Rohrman Midwest Motors adds new momentum to a growing divide among courts: whether a text message qualifies as a “call” under the Telephone Consumer Protection Act (TCPA). In Rabbitt v. Rohrman, the court concluded that it can. This brings SMS messages within the scope of the TCPA’s Do Not Call (DNC) rules.…

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