Business or Residential Number? Eastern District of Pennsylvania Adopts Ninth Circuit’s Test and Grants Summary Judgment for Defendant

The US District Court for the Eastern District of Pennsylvania recently granted summary judgment for defendant JR Capital upon finding that the text messages at issue were sent to a business line, not a “residential” phone number. See Newell v. JR Capital, LLC, 2026 WL 2408527 (E.D. Pa. Aug. 17, 2026). While the court did not go so far as deciding, as other courts have done, that cell phones categorically are not “residential,” the opinion still provides a helpful demonstration of how a defendant can establish that a phone number is primarily being used for business purposes.