As we have previously discussed, two recent decisions narrowly interpreted the term automatic telephone dialing system (“ATDS”), the definition of which will determine the fate of many TCPA claims. See Hunt v. 21st Mortgage Corp., 2013 WL 5230061 (N.D. Ala. Sept. 17, 2013) and Stockwell v. Credit Management, L.P., No. 30-2012-00596110-CU-NP-CXC (Cal. Super. Ct. Oct. 3, 2013). (Our prior posts on those cases are available here and here). A district court in Washington recently followed this trend.