Brent v. My Goals Solutions Inc.
- James Oetken
- 1:25-cv-03584
- U.S. District Court · Southern District of New York
- 2
In Brent v. My Goals Solutions, Judge Oetken denied dismissal, holding unwanted solicitations can establish Telephone Consumer Protection Act standing.
Raikka Brent and My Goals Solutions, Inc.; the ruling allows Brent’s TCPA action to proceed past the motion-to-dismiss stage.
What happened
In Brent v. My Goals Solutions, Raikka Brent alleged that she asked My Goals Solutions, Inc. to stop sending her messages, but continued receiving solicitation texts and calls.
The company argued that Brent had alleged only a technical violation and had not shown a concrete harm needed to bring the case in federal court. The court disagreed, explaining that unwanted messages can cause the nuisance and privacy harms protected by the Telephone Consumer Protection Act.
Judge J. Paul Oetken denied the motion to dismiss. The company must answer the amended complaint within 14 days, and the clerk was directed to close the motion.
The detailed version
- Brent v. My Goals Solutions Inc. · No. 1:25-cv-03584
- James Oetken
- Aug. 11, 2025
Background
Raikka Brent brought the action under the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, and a related Federal Communications Commission regulation, 47 C.F.R. § 64.1200(d). Her amended complaint alleges that she verbally asked My Goals Solutions, Inc. to stop sending her text messages on or about March 18, 2025. She alleges that the company nevertheless continued sending solicitation text messages and making solicitation calls through June 13, 2025.
Motion to Dismiss
My Goals Solutions moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal for failure to state a legally sufficient claim. The company argued that Brent had pleaded only a bare TCPA violation and had not alleged a concrete harm sufficient to establish standing, meaning the injury required to bring a claim in federal court.
Court’s Analysis
The court rejected that argument. It explained that the TCPA protects against nuisance and privacy harms caused by unsolicited text messages. Those harms have a close relationship to harms traditionally recognized as supporting a lawsuit, so Brent did not need to allege an additional injury beyond the unwanted solicitations identified in the complaint. The court also stated that the Supreme Court’s decision in TransUnion LLC v. Ramirez did not concern the TCPA and did not change the Second Circuit’s ruling in Melito v. Experian Marketing Solutions, Inc.
Disposition
The court denied Defendant’s motion to dismiss. It ordered Defendant to file an answer to the amended complaint within 14 days and directed the clerk to close the motion at Docket Number 11.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.