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A few weeks back I told you a new wave of TCPA class actions was coming involving litigators who opt out of SMS messages without using keywords such as STOP or QUIT:
ITS HERE: The First of a Wave of New “Keyword Avoider” SMS Opt Out TCPA Class Actions Has Been Filed and TCPAWorld Will Never Be the Same
Well that wave is already crashing with at least half a dozen new suits contending some very curious “opt outs” qualify as TCPA revocations.
Check these new class actions out:
Rose v. 307 SW 2nd St
S.D. FL; 0:25-cv-61339
texts after “I do not wish to be contacted”
Dudek v. Surf Clean Energy
E.D. NY; 2:25-cv-03621
texts after “S” (responded solely with uppercase letter “S”)
Gomez v. Gage Bowl
C.D. CA; 2:25-cv-05257
texts after “exit”
Torre v. American First Finance
E.D. CA; 2:25-cv-01447
texts after ‘cease and desist’
Gabai v. Tabs Labs
C.D. CA; 2:25-cv-04630
texts after ‘remove’ and ‘no’
Mokled v. Hanna Cars
S.D. FL; 0:25-cv-60899
texts after ‘no’
And notice this is definitely being done on purpose. Check out the Gomez evader at work:

He said “Exit” three different times. No effort to switch to “stop” or “unsubscribe.”
Or how about Miss. “I do not wish to be contacted”:

You can’t tell me that’s not a set up.
In one suit a guy just texted “S” and claimed it was a valid opt out. Then again the stop notifier seems to have invited that:

Weird right?
Bottom line– the keyword avoider opt out TCPA litigation wave is real and upon us. Again, after the FCC’s revocation rule in April went into effect these lawsuits are very much an issue because a consumer can revoke via any reasonable means and are not limited to any specific keyword in an SMS revocation effort.
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Under certain state laws, the following statements may be required on this website and we have included them in order to be in full compliance with these rules. The choice of a lawyer or other professional is an important decision and should not be based solely upon advertisements. Attorney Advertising Notice: Prior results do not guarantee a similar outcome. Statement in compliance with Texas Rules of Professional Conduct. Unless otherwise noted, attorneys are not certified by the Texas Board of Legal Specialization, nor can NLR attest to the accuracy of any notation of Legal Specialization or other Professional Credentials.
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Find Your Next Job !
A few weeks back I told you a new wave of TCPA class actions was coming involving litigators who opt out of SMS messages without using keywords such as STOP or QUIT:
ITS HERE: The First of a Wave of New “Keyword Avoider” SMS Opt Out TCPA Class Actions Has Been Filed and TCPAWorld Will Never Be the Same
Well that wave is already crashing with at least half a dozen new suits contending some very curious “opt outs” qualify as TCPA revocations.
Check these new class actions out:
Rose v. 307 SW 2nd St
S.D. FL; 0:25-cv-61339
texts after “I do not wish to be contacted”
Dudek v. Surf Clean Energy
E.D. NY; 2:25-cv-03621
texts after “S” (responded solely with uppercase letter “S”)
Gomez v. Gage Bowl
C.D. CA; 2:25-cv-05257
texts after “exit”
Torre v. American First Finance
E.D. CA; 2:25-cv-01447
texts after ‘cease and desist’
Gabai v. Tabs Labs
C.D. CA; 2:25-cv-04630
texts after ‘remove’ and ‘no’
Mokled v. Hanna Cars
S.D. FL; 0:25-cv-60899
texts after ‘no’
And notice this is definitely being done on purpose. Check out the Gomez evader at work:

He said “Exit” three different times. No effort to switch to “stop” or “unsubscribe.”
Or how about Miss. “I do not wish to be contacted”:

You can’t tell me that’s not a set up.
In one suit a guy just texted “S” and claimed it was a valid opt out. Then again the stop notifier seems to have invited that:

Weird right?
Bottom line– the keyword avoider opt out TCPA litigation wave is real and upon us. Again, after the FCC’s revocation rule in April went into effect these lawsuits are very much an issue because a consumer can revoke via any reasonable means and are not limited to any specific keyword in an SMS revocation effort.
More Upcoming Events
Sign Up for any (or all) of our 25+ Newsletters
You are responsible for reading, understanding, and agreeing to the National Law Review’s (NLR’s) and the National Law Forum LLC’s Terms of Use and Privacy Policy before using the National Law Review website. The National Law Review is a free-to-use, no-log-in database of legal and business articles. The content and links on www.NatLawReview.com are intended for general information purposes only. Any legal analysis, legislative updates, or other content and links should not be construed as legal or professional advice or a substitute for such advice. No attorney-client or confidential relationship is formed by the transmission of information between you and the National Law Review website or any of the law firms, attorneys, or other professionals or organizations who include content on the National Law Review website. If you require legal or professional advice, kindly contact an attorney or other suitable professional advisor.
Some states have laws and ethical rules regarding solicitation and advertisement practices by attorneys and/or other professionals. The National Law Review is not a law firm nor is www.NatLawReview.com intended to be a referral service for attorneys and/or other professionals. The NLR does not wish, nor does it intend, to solicit the business of anyone or to refer anyone to an attorney or other professional. NLR does not answer legal questions nor will we refer you to an attorney or other professional if you request such information from us.
Under certain state laws, the following statements may be required on this website and we have included them in order to be in full compliance with these rules. The choice of a lawyer or other professional is an important decision and should not be based solely upon advertisements. Attorney Advertising Notice: Prior results do not guarantee a similar outcome. Statement in compliance with Texas Rules of Professional Conduct. Unless otherwise noted, attorneys are not certified by the Texas Board of Legal Specialization, nor can NLR attest to the accuracy of any notation of Legal Specialization or other Professional Credentials.
The National Law Review – National Law Forum LLC 2070 Green Bay Rd., Suite 178, Highland Park, IL 60035 Telephone (708) 357-3317 or toll-free (877) 357-3317. If you would like to contact us via email please click here.
Copyright ©2025 National Law Forum, LLC
