To me certification in TCPA class actions comes down to one issue– did the numbers all come from a single identical source, or multiple sources. The reason–as explained best by the Fifth Circuit Court of Appeals in Gene & Gene v. Bippay— is that consent is generally the central issue in a TCPA case. Still courts struggle with this concept, and you occasionally see #biglaw screw up with a resulting certification of a multi-source TCPA class action. Well things went the right way in Lyngaas v. Solstice, 2025 WL 2689015 (E.D. There are a myriad of ways for Solstice to evidence contact, aside from those included in Plaintiff’s initial and current definitions, as Solstice has shown through concrete evidence.