The following excerpt is from Gutierrez v. Barclaycard, CASE NO. 10cv1012 DMS (BGS) (S.D. Cal. 2011):
However, at least one other court has taken a different approach from Leyse. See Dawson v. Am. Dream Home Loans, No 06CV000513, 2006 WL 2987104 (Ohio Com. Pl. Oct. 4, 2006). In Dawson, the court found the TCPA "provides for a cause of action for any person who receives an unsolicited fax and does not limit the cause of action to the intended recipient of an unsolicited fax." Id. at *4.
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