1. Does the statutory definition of ATDS encompass any device that can "store" telephone numbers, even if the device does not "us[e] a random or sequential number generator"?

2. Does a device that requires significant human intervention to initiate telephone calls and/or send text messages qualify as "automatic" under the TCPA?

3. Is the Hobbs Act violated when a circuit court of appeals relies upon orders by the Federal Communications Commission that were previously invalidated by another circuit court of appeals presiding over an appeal of an Federal Communications Commission ruling under the Hobbs Act?

Does the statutory definition of ATDS encompass any device that can 'store' telephone numbers, even if the device does not 'us[e] a random or sequential number generator?