Navigating Personal Jurisdiction in TCPA Cases: Insights from Ingram v. Money Map Press

A recent decision issued by the United States District Court for the Northern District of California in Ingram v. Money Map Press, 23-cv-05802-CRB, 2024 U.S. Dist. LEXIS 130905 (N.D. Cal. July 24, 2024) addresses an important personal jurisdiction defense potentially available to defendants facing claims under the Telephone Consumer Protection Act (TCPA) that are filed against them in states outside of their home state of residence. 

Background

In Ingram, the plaintiff, a resident of California, filed a lawsuit in district court in California alleging the defendant sent him 124 unsolicited promotional text messages, despite the fact that his telephone number was allegedly registered on the National Do-Not-Call registry, in violation of the TCPA. The plaintiff sought monetary damages and injunctive relief. The defendant, a Maryland company, moved to dismiss the case for lack of personal jurisdiction, arguing that it did not have sufficient contacts…