United States District Court for the Northern District of Illinois alleging that the companies used an automated dialer to call customers' cellphones without consent. This is the largest proposed cash settlement under the TCPA to date. It is notable that this legal action involved informational telephone calls, which are not subject to the "prior express written consent" requirements which have been in place for telemarketing calls since October 2013. The United States Supreme Court resolved a significant circuit split to decide that federal courts have federal question subject matter jurisdiction in Mims v. Arrow Financial Services, LLC, 565 US 368, 132 S. Ct. 740, 181 L. Ed. 2d 881 (2012). In 2015, Congress added an exemption to § 227(b)(1)(A)(iii) to allow for robocalls related to federally-owed debt collection. This resulted in the Supreme Court case Barr v. American Assn. of Political Consultants, Inc., 591 U.S. ___ (2020), which ruled this created a content-based restriction on free speech that failed strict scrutiny, and invalidated the exemption but leaving the rest of the statue in place due to severability. In January 2017, the Ninth Circuit Court of Appeals found two text messages were enough to obtain Article III standing. In August 2019, the 11th Circuit Court of Appeals found a single text message was not enough to obtain Article III standing under TCPA. In July 2020, the US Supreme Court found the "government-debt" exception to the TCPA was unconstitutional. The "government-debt" exception was added as an amendment to the TCPA in 2015. The case, Barr v. American Assn. of Political Consultants, Inc., was brought by political groups that desired to use robocalls for political ads. The court found the TCPA did unconstitutionally favor debt collection speech over political speech and violated the First Amendment. In July 2020, the Southern District of Texas found a single text message was enough to obtain Article III standing. In September 2020, the Eastern District of Texas found a single missed call using a localized number was enough trigger Article III standing under TCPA. The court reasoned, "At issue in this case is a missed call, not a single, unsolicited text message. It only takes one glance at a text message to recognize it is for an extended warranty for a car you have never owned or a cruise you have won from a raffle you never entered. A missed call with a familiar area code, on