Two courts. One message. Post-McLaughlin, some judges are making it clear: text messages are not “telephone calls” under the TCPA. In Davis v. CVS Pharmacy, Inc., No. 4:24-cv-477-AW-MAF, 2025 U.S. Dist. LEXIS 167366 (N.D. Fla. Aug. 26, 2025), the plaintiff claimed CVS Pharmacy sent him two unsolicited texts while his number was on the National Do Not Call Registry. But he didn’t allege a single call.