“The chirp, buzz, or blink of a cell phone receiving a single text message is more akin to walking down a busy sidewalk and having a flyer briefly waved in one’s face. Annoying, perhaps, but not a basis for invoking the jurisdiction of the federal courts.” Salcedo v. Hanna, No. 17-14077, 2019 WL 4050424, at *7 (11th Cir. 2019). In a recent ruling, the Eleventh Circuit held that plaintiff John Salcedo’s receipt of a single… Continue Reading