Lisota v. Heartland Dental, LLC et al

Published by Crandall Consulting · Informational litigation intelligence · Last substantive update: August 23, 2026

Docket / citation: 1:25-cv-07518 · Filed: 2026-01-13

Summary

The Northern District of Illinois held on January 13, 2026 that the plaintiff had standing via an analogy to intrusion upon seclusion but that her Federal Wiretap Act claim failed because the ordinary-course-of-business exception applied to the electronic communications provider. The court granted defendants' motions to dismiss the complaint without prejudice and declined to resolve the party-to-the-communication/agency question.

Litigation Status

Status, direction, and weight describe how tracked public sources characterize this matter as of our last review — they are informational classifications, not legal assessments.

Procedural Posture

Plaintiff filed a putative class action alleging violations of the Federal Wiretap Act. Defendants moved to dismiss; the court considered standing and statutory exceptions and granted dismissal for failure to state a claim without prejudice.

Reported Holding

The district court found the plaintiff had Article III standing by analogy to the common-law tort of intrusion upon seclusion, but concluded the Federal Wiretap Act claim failed because the statutory "ordinary course of business" exception applied to RingCentral as a provider of electronic communication services. The court granted defendants' motions to dismiss for failure to state a claim and dismissed the complaint without prejudice (Mem. Op. & Order, Jan. 13, 2026).

What the Court Decided

The court granted defendants' motions to dismiss (Rule 12(b)(6)) and held that the ordinary-course-of-business exception to the Wiretap Act applied to RingCentral's interception/analysis of calls, so the complaint did not state a claim. The dismissal was without prejudice.

What the Court Did Not Decide

The court declined to resolve whether defendants could be treated as a "party to the communication" for purposes of the party exception (i.e., questions of agency/authority and whether a technology provider is a party to the communication) and declined to endorse either approach on that split issue.

Significance

Generally viewed as defense-favorable. Characterizations of significance describe how the matter has generally been discussed in tracked public sources; individual holdings are often narrow, procedural, or fact-specific, and this page does not state or imply broader holdings than the sources support.

What This Page Does and Does Not Say

This page reports what our tracked public sources say about this matter — including, where identified, the procedural posture (for example, a ruling on a motion to dismiss is not a final merits decision). It does not report legal conclusions beyond those sources, does not predict outcomes, and does not constitute legal advice.

Technologies at Issue

• AI-supported telephone service
• call transcription
• speech recognition
• language learning models

Third parties named or identified in tracked sources: RingCentral, Inc., Heartland Dental, LLC.

Statutes Invoked

• Federal Wiretap Act (18 U.S.C. § 2510 et seq.; including references to § 2510(5)(a)(ii) and § 2511(2)(d)) — one-party consent · private right of action

Claims Asserted

Claims identified in tracked public sources; pleadings may include additional or amended claims.

• Federal Wiretap Act (18 U.S.C. § 2510 et seq.) claim
• Privacy-related allegations (analogy to intrusion upon seclusion for standing)

What This Matter May Mean for Website Operators

Federal Wiretap Act (ECPA Title I) is a one-party consent statute with a private right of action. Consent standard and private enforceability are the structural features that most shape where website tracking claims are filed and how they are valued.

The reported outcome direction at the pleading stage reflects how tracked sources characterize the ruling; such rulings are often narrow, posture-specific, and fact-bound rather than broad statements of law.

Detection of a similar technology on a website is an informational risk indicator, not a legal conclusion, and nothing in this section is legal advice.

Related Intelligence

Sources

• Lisota v. Heartland Dental, LLC et al, 1:2025cv07518 - Document 38 (N.D. Ill. 2026) — Justia · Tier A (Primary authority) · 2026-01-13

About This Page

Publisher: Inspection-Ready Institute, Inc. (DBA Crandall Consulting), an independent website compliance and risk consultancy. We are not a law firm and nothing on this page is legal advice.

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