By Eric Berman (April 3, 2018, 11:45 AM EDT) -- In Reese v. Anthem Inc.,[1] the U.S. District Court for the Eastern District of Louisiana dismissed a putative class action lawsuit alleging violations of the Telephone Consumer Protection Act.[2] Even for telemarketers and TCPA practitioners, Reese may be easy to overlook. The decision — barely 10 pages long — was issued by a court that is hardly considered a TCPA litigation hotbed (unlike, for example, federal courts in California, Illinois and Florida). Two of the three defendants were 501(c)(3) charities, rare targets of TCPA litigation indeed. And, shortly after Reese was decided, the D.C. Circuit handed down its long-awaited decision partially rejecting the Federal Communications Commission's July 2015 rulemaking — a development that has since monopolized the TCPA bar's attention.[3]...