b'Looking Ahead to 2021 What to WatchThe Supreme Court heard oral argument in Facebook,Supreme Courts decision clarifying definition ofInc. v. Duguid, No. 19-0511, in December 2020.anATDS.Accordingly, in early 2021 we can expect to hear theSupreme Courts decision, which will resolve thePotential decisions from other circuit courts on growing circuit split and uncertainty among federalissue of whether the TCPA allows for unilateral district courts surrounding one of the most confusingrevocation of consent for automated calls provided aspects affecting TCPA liabilitywhat equipment isin a bargained-for exchange.an ATDS. If the Supreme Court reverses the holding inGrowth in the circuit split regarding the number of Duguid, we could see the Democrats wield their control of Congress and amend the TCPA consistent with thetext messages or calls that suffice to confer Article Ninth Circuits expansive protections for call recipients.III standing in TCPA cases.We also expect to see the trend of increasing TCPAIncreased TCPA litigation flowing from FCCs Orderlitigation continue, especially following the FCCsamending Section 1.80 of its TCPA rules.Order amending Section 1.80 of its TCPA rules, which extended the applicable statute of limitations period. It is also possible that in the coming year additional circuit courts will join the Eleventh and Second Circuits in ruling on whether the TCPA allows for unilateral revocation of consent for automated calls provided in a bargained-for exchange. Further, the Supreme Court is poised to decide in TransUnion LLC v. Ramirez, No. 20-0297, whether Article III of the U.S. Constitution authorizes damages in a class action where the majority of the class was not actually injuredsuch as could be the case in TCPA cases. Article III standing under the TCPA may be further affected in the coming year given the growing circuit split regarding the number of text messages or calls that suffice to confer standing.27'