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.

A click-to-dial system is a less automated version of a predictive dialer system. Like a predictive dialer, it operates from a list of phone numbers. However, rather than automatically placing the calls and directing them to agents like in a predictive dialer system, it sends the phone numbers to a live agent, who clicks something to initiate each individual call.