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Texas Telemarketing (SB 140) – Update The Ruling, the Confusion And Now the First Litigation Claim
A new lawsuit was recently filed that brings fresh attention to Texas’s expanded telemarketing law. On December 2, 2025, a known plaintiff filed a claim in the U.S. District Court for the Western District of Texas, Callier v Holistic Choice Labs LLC. This claim is being closely watched across industries that rely on outbound calls or text messages. This signals a shift from regulatory interpretation on the registration requirements to active litigation tied to Texas’s “Mini-TCPA,” effective September 1, 2025.
While the Texas Attorney General has attempted to clarify aspects of the telemarketer registration requirements around consent-based outreach. This filing is a warning shot over the bow and an early reminder that uncertainty around consent, registration and documentation can quickly translate into litigation risk.
