The Southern District of Florida recently ruled that ringless voicemails (RVM) are “calls” under the Telephone Consumer Protection Act (TCPA). In Schaevitz v. Braman Hyundai, No. 1:17-cv-23890 (S.D. Fla. Mar. 25, 2019) the defendant sent a pre-recorded RVM to the plaintiff soliciting a return call regarding trading in the plaintiff’s car for a newer