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Are cell phones considered click-to-dial?

Cell phones are generally thought to be manual calling devices, like many click-to-dial systems. However, there has been no clear or consistent guidance from the Federal Communications Commission (FCC) or the courts as to whether or not a cell phone is considered a click-to-dial device. Telephone Consumer Protection Act (TCPA) compliance on this issue depends entirely on specific district court rulings for specific jurisdictions.