A California federal court ruled that a text asking a patient to rate
the doctor - sent minutes after the examination by a company that
contracts with the health care provider to send Patient Satisfaction
Surveys - does not alone satisfy an inference that the text was sent by
an Automatic Telephone Dialing System ("ATDS") within the definition of
the Telephone Consumer Protection Act, 47 U.S.C. ยง 227 ("TCPA").