The Northern District of Illinois recently validated a company’s narrow interpretation for the scope of communications a party opts out of when it revokes consent under 47 C.F.R. § 64.1200(d). In Stamper v. Manus-Northwestern Oral Health Center, Ltd., the court granted a defendant’s motion to dismiss confirming that the plaintiff did not adequately revoke consent to receive all marketing communications from the defendant after replying “stop” to one message instead of “STOPALL” as instructed to cease all communications. 2025 WL 2044093 (N.D. Ill. July 17, 2025). For companies with multipronged or multichannel communication streams, this decision provides validation that an opt-out from one category of message or specific campaign need not be read as a bar to all messages.

In Stamper, the plaintiff alleged they had “received texts advertising [defendant]’s services on at least a monthly basis from September 2022 to January 2023, despite repeatedly responding “stop” in an attempt to unsubscribe in the manner the messages instructed.” Id. at 1. The texts included notifications of open appointments, recall messages and reminders that a person was due for an appointment. Some of the texts were addressed to different individuals for whom the plaintiff had provided their number as the point of contact.

Continue reading “District Court Limits the Impact of a “Stop” Text”