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 In August, the Ninth Circuit determined that when following the purpose of the TCPA there could be no coverage when a policy, in this case a directors and officers liability (D&O) policy, included exclusionary language for invasion of privacy claims. The case is L.A. Lakers, Inc. v. Fed. Ins. Co., 2017 U.S. App. LEXIS 16109.

In 2012 during a Los Angeles Lakers game at the Staples Center, a Lakers fan saw a message on the scoreboard asking attendees to send a text message to a certain number in order to have his message appear on the scoreboard screen. In response to his message, the fan received this text message:

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