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What is click-to-dial?
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.
What are the risks?
If a predictive dialer system is unlikely to be considered an ATDS post-Facebook, a click-to-dial system is even less likely to be subject to ATDS restrictions.
Case Study
A magistrate judge for the U.S. District Court for the Eastern District of Michigan determined that a click-to-dial system is not an autodialer because it does not dial phone numbers without human intervention. Because of the inclusion of the “clicker agent,” each individual phone call must be initiated by a human.