The Eleventh Circuit recently held that a plaintiff does not suffer concrete injury through receipt of a single ringless voice mail message. Grigorian v. FCA US LLC, No. 19-15026, 2020 WL 7238392 (11th Cir. Dec. 9, 2020). The Eleventh Circuit previously ruled that receipt of a single, unsolicited text message does not constitute the harm necessary to achieve Article III … [Read more...]