Mealey's (January 6, 2023, 7:18 AM EST) -- SAN FRANCISCO — Relying on the recent ruling in Borden v. eFinancial LLC, a divided Ninth Circuit U.S. Court of Appeals panel upheld a trial court’s determination that automated birthday notification texts to a Facebook user did not violate the Telephone Consumer Protection Act (TCPA) because Meta Platforms Inc., Facebook’s owner, did not use an “automated telephone dialing system” (autodialer) as defined by the statute....