Florida Prosthodontics, P.A. v. Dentsply Sirona, Inc. - 6 ...

Case 6:17-cv-00899-RBD-GJK Document 1 Filed 05/18/17 of 11 PagelD 1

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UNITED STATES DISTRICT COURT 2011111AFOR THE MIDDLE DISTRICT OF FLORIDA I 18 pM 9.

ORLANDO DIVISION r-• 03

FLORIDA PROSTHODONTICS, P.A., a Florida Case No 74CAT,P, pi ru1"",K0411-C1- 37

corporation, individually and on behalfofall others

similarly situated, PLAINTIFF'S CLASS A1CTIONCOMPLAINT AND DEMAND FOR

Plaintiff, JURY TRIAL

V.

DENTSPLY SIRONA, INC., a Delaware

corporation,Defendant.

Plaintiff Florida Prosthodontics, P.A., by and through its undersigned counsel,

brings this Class Action Complaint and Demand for Jury Trial against Defendant

Dentsply Sirona Inc. ("Defendant" or "Dentsply"), on behalf of itself and all others

similarly situated, for violations of the Telephone Consumer Protection Act of 1991, as

amended by the Junk Fax Prevention Act of 2005, 47 U.S.C. 227 ("the Act"), and its

accompanying regulations. The following allegations are based upon Plaintiff's personal

knowledge as to itself, and as to all other matters upon information and belief, including

investigation conducted by its attorneys.

NATURE OF THE ACTION

1. In 1991, Congess passed the Telephone Consumer Protection Act, 47

U.S.C. 227 ("TCPA"), which, among other things, prohibited any person or entity from

sending fax advertisements without the recipient's prior express consent. That law was

passed in response to widespread complaints from consumers and business about the

annoyance, cost, and intrusion caused by unsolicited fax advertisements.


2. In passing the TCPA, Congress found that in addition to invading

recipients' privacy, unsolicited faxes harm their recipients, costing loss of paper and ink

toner, excess wear and tear on the receiving fax machine, temporary loss of usage of the

fax machine, and loss of time, as the recipient and/or its employees must attempt to

discern the source and purpose of the unsolicited message.

3. Fourteen years later, with consumers and business still besieged by

unsolicited fax advertisements, Congress amended the TCPA by passing the Junk Fax

Prevention Act of 2005, which required senders of fax advertisements to include on the

first page a clear and conspicuous notice to recipients of their right to stop future

advertisements, as well as instructions for exercising that right.

4. Even though it has been illegal for over a quarter-century to send

unsolicited fax advertisements, Dentsply—one of the country's largest producers of

dental equipment and consumables— continues to send them to prospective customers,

which include dentist and orthodontist offices throughout the country. Worse still,

Dentsply does so without the recipients' consent, and without including the opt-out

language required by the Junk Fax Prevention Act of 2005.

5. One such recipient was Plaintiff Florida Prosthodontics, P.A., a father-

and-son-owned dental practice in Florida that received the fax advertisement attached as

Exhibit 1 on April 28, 2017 (hereinafter "the Fax"). Because Plaintiff did not consent to

receive fax advertisements from Dentsply, it brings suit on behalf of itself and all others

similarly situated, seeking redress for Dentsply's unlawful conduct.

2


PARTIES

6. Plaintiff Florida Prosthodontics, P.A. is a corporation organized and

existing under the laws of the State of Florida, with its headquarters and principal place

of business located at 2180 North Courtenay Parkway, Merritt Island, Florida 32953.

7. Defendant Dentsply Sirona Inc. is a corporation organized and existing

under the laws of the State of Delaware, with its headquarters and principal place of

business located at 221 W. Philadelphia Street, Suite 60W, York, Pennsylvania 17401.

JURISDICTION AND VENUE

8. This Court has subject-matter jurisdiction over this action under 28 U.S.C.

1331 because Plaintiff's claims arise under a federal statute.

9. This Court has personal jurisdiction over Defendant because it routinely

transacts business in Brevard County and throughout the State ofFlorida, and because the

conduct giving rise to this action was directed at 13revard County.

10. Venue is proper in this Court under 28 U.S.C. 1391 because Defendant

routinely transacts business in Brevard County and throughout the State of Florida,

because the conduct giving rise to this action was directed at Brevard County, and

because the injuries alleged in this Complaint took place in Brevard County.

COMMON FACTUAL ALLEGATIONS

11. Dentsply is one of the world's largest producers of dental equipment and

consumables such as anesthetics, dental implants, teeth cleaning supplies, orthodontics

equipment, and imaging equipment. Publicly traded on the NASDAQ since 1993,

Dentsply had sales of roughly $3.7 billion in 2016.

3


12. Unlike its counterparts in the medical device and consumables fields,

which can generate substantial revenue through sales to institutional clients like hospitals

and health care networks, Dentsply is dependent on small and independent dental offices

for much of its revenue in the United States.

13. To that end, Dentsply must engage in substantial marketing efforts to

reach its potential client base. Historically, this is by working with a number of

distributors, who then develop relationships with and market to individual dental offices.

14. In addition to relying on its distributors, however, Dentsply has also

chosen to market directly to dental offices themselves by faxing advertisements for its

products. Unfortunately, rather than limiting the messages to offices that have requested

information from Dentsply or otherwise agreed to accept them, Dentsply has chosen to

send unsolicited fax advertisements to dental offices throughout the country, hoping to

generate new sources of business.

15. On information and belief, Dentsply has sent fax advertisements similar to

that attached as Exhibit 1 to thousands of dental offices throughout the country.

FACTS SPECIFIC TO THE PLAINTIFF

16. Plaintiff Florida Prosthodontics, P.A. is a father-and-son owned dental

office with locations in Merritt Island, Rockledge, and Winter Park, Florida.

17. On April 28, 2017, Plaintiff received the Fax, attached as Exhibit 1. The

cover sheet for the Fax indicated that it was sent by Philip Swarm, a Dentsply employee.

4


18. Although the cover page and header of the Fax indicated that the

transmission included three pages, only two pages (the cover page and another, labeled as

pages one and three, respectively) were received by Plaintiff.

19. The body of the Fax included images and descriptions ofvarious Dentsply

products, along with a list of "May & June 2017 Midwest Deals, including discounts,

"buy one get one" offers and more.

20. The Fax instructed recipients to contact Dana Larkin, a "LOCAL

EXECUTIVE MIDWEST SPECIALIST" with Dentsply.

21. Nowhere in the Fax did Dentsply provide notice to Plaintiff of its ability to

opt out of receiving further fax advertisements, nor did it provide instructions for doing

SO.

22. As a result of Dentsply's Fax, Plaintiff lost money or property in the form

of the ink and paper used in printing the Fax, the additional wear and tear caused to

Plaintiff's fax machine in receiving and printing the Fax, and the lost time and

productivity of its employees in reviewing the Fax.

CLASS ALLEGATIONS

23. Plaintiff brings this class action on behalf of itself and a Class of similarly

situated individuals, defined as follows:

All persons in the United States who subscribed to a telephonenumber that received a facsimile message from Defendant

advertising Defendant's products or services within four years of

the filing of this Complaint.

The following people are excluded from the Class: (1) any Judge or magistrate presiding

over this action and any members of their families; (2) Defendant and its subsidiaries,

5


parents, successors, predecessors, and any entity in which Defendant or its related entities

have a controlling interest, as well as their current and former employees, officers, and

directors; (3) persons who properly execute and file a timely request for exclusion from

the Class; (4) persons whose claims arising out of substantially the same conduct by

Defendant have been fmally adjudicated on the merits or otherwise released; (5)

Plaintiffs counsel and Defendant's counsel; and (6) the legal representatives, successors,

and assigns of any such excluded persons.

24. Numerosity: The exact size of the Class is unknown to Plaintiff at this

time, but it is clear that individual joinder would be impracticable. On information and

belief, the Class includes thousands of members. Ultimately those members will be

identified through Defendant's facsimile transmission logs.

25. Commonality and Predominance: Common questions of law and fact

exist as to all Class members' claims, and predominate over any questions affecting Class

members. With respect to the Class, those questions include:

a. Whether Defendant's unsolicited fax messages were

"advertisements" within the TCPA's meaning;

b. Whether Defendant obtained the Class members' prior expressconsent to send the fax advertisements;

c. Whether Defendant's faxes included the notice and opt-outinstructions required by the TCPA and its implementingregulations; and

d. Whether Defendant's conduct was knowing and willful.

6


26. Typicality: Plaintiff s claims are typical of the other Class members

because it, like the rest of the class, from Defendant within the last four years and

suffered similar injuries.

27. Adequacy: Plaintiff will fairly and adequately represent and protect the

Class's interests, and has retained counsel competent and experienced in similar actions.

Plaintiff has no interests antagonistic to the Class, and Defendant has no defenses unique

to Plaintiff.

28. Superiority: Class proceedings are a superior method of resolving this

dispute because individual joinder of all Class members is impracticable, and the

damages suffered by individual Class members will be small relative to the burden and

expense ofpursuing their claims individually. Accordingly, Class members would not be

able to obtain effective relief from Defendant individually. Even if Class members could

sustain individual litigation, however, it would still be inferior to a class action because

individual litigation would increase the delay and expense to all parties and to the judicial

system. By contrast, class proceedings would be more manageable and would provide

economies of scale and uniform resolution of all claims asserted.

FIRST CAUSE OF ACTIONViolation of 47 U.S.C. 227

(On Behalf of Plaintiff and the Class)

29. Plaintiff incorporates the foregoing allegations as if fully set forth herein.

30. The Act and its implementing regulations prohibit any person or entity

from using "any telephone facsimile machine, computer, or other device to send, to a

telephone facsimile machine, an unsolicited advertisement, unless" (i) the sender has an

7


established business relationship with the recipient; and (ii) the sender obtained the

recipient's fax number voluntarily within the scope of the business relationship or

through the recipient's voluntary public dissemination of the number; and (iii) the

advertisement includes, on its first page, a clear and conspicuous notice informing the

recipient of its right to and the process for opting out of receipt of further unsolicited

advertisements from the sender. See 47 U.S.C. 227(b)(1)(C), (b)(2)(D); See 47 C.F.R.

64.1200(a)(4)(iii).

31. The Act and its implementing regulations impose further requirements on

the opt-out notice that must accompany an unsolicited fax, including that the notice

identifies what must be included in the opt-out request, and that the notice identify a toll-

free telephone number or separate cost-free contact form, available 24 hours a day, 7 days

a week for submission of the opt-out request. See 47 U.S.C. 227(b)(1)(C), (b)(2)(D);

See 47 C.F.R. 64.1200(a)(4)(iii).

32. On April 28, 2017, Defendant transmitted the Fax attached as Exhibit 1 to

Plaintiff's fax machine. The Fax advertised Defendant's products for sale.

33. Plaintiff did not request that Defendant send advertisements to its fax

machine, nor did it otherwise consent to receive the Fax attached as Exhibit 1.

34. Plaintiff did not provide its fax number to Defendant for the purpose of

receiving fax advertisements nor did it publish the number publicly for the purpose of

receiving fax advertisements.

35. In violation of 47 U.S.C. 227(b)(1)(C) and 47 C.F.R.

64.1200(a)(4)(iii), Defendant's Fax to Plaintiff did not include a clear and conspicuous

8


notice on its first page stating that Plaintiff could request that Defendant not send any

future unsolicited advertisements to Plaintiff's fax machine, identifying the requirements

for such a request, and informing Plaintiff that failure to respond within 30 days was

unlawful.

36. Further in violation of 47 U.S.C. 227(b)(1)(C) and 47 C.F.R.

64.1200(a)(4)(iii), Defendant's Fax to Plaintiff did not include a clear and conspicuous

notice on its first page identifying a cost-free method or mechanism for submitting an

opt-out request. See 47 U.S.C. 227(b)(1)(C), (b)(2)(D); See 47 C.F.R.

64.1200(a)(4)(iii).

37. Thus, in violation of the Act and its implementing regulations, Defendant

transmitted the Fax to Plaintiffwithout its prior consent or the required opt-out language.

38. As a sophisticated business and as the entity responsible for creating and

disseminating the fax advertisements at issue in this case, Defendant knew that its fax

advertisements lacked the opt-out language required by the Act and its implementing

regulations. Moreover, Defendant knew or should have known that it lacked prior express

consent from Plaintiff and the Class to send the fax advertisements at issue.

39. As a result of Defendant's transmission of the Fax and other fax

advertisements like it, Plaintiff and the Class lost money or property in the form of the

ink and paper used in printing the unsolicited fax advertisements, the additional wear and

tear caused to their fax machines in receiving and printing the unsolicited fax

advertisements, and the lost time and productivity of their employees in reviewing the

unsolicited fax advertisements.

9


40. Accordingly, Plaintiff seeks an Order: (i) permanently enjoining

Defendant from sending the unlawful fax advertisements described above; (ii) awarding

Damages to Plaintiff and the Class in an amount of $1,500 for each unlawful fax

advertisement received; and (iii) requiring Defendant to pay Plaintiff's and the Class's

attorneys' fees and costs.

PRAYER FOR RELIEF

WIIEREFORE, Plaintiff Florida Prosthodontics, P.A, individually and on behalf

of the Class defined above, respectfully requests that the Court grant the following relief:

A. Certify this case as a class action on behalf of the Class defined above,

appoint Plaintiff Florida Prosthodontics, P.A. as Class representative, and appoint Daniel

Dill of the Dill Law Group PA as class counsel;

B. Declare that, as described herein, Defendant knowingly and/or willfully 47

U.S.C. 227 and its implementing regulations;

C. Award injunctive and other equitable relief as necessary to protect the

interests of Plaintiff and the Class, including an order prohibiting Defendant from

sending further unlawful fax advertisements like those described above;

D. Award Plaintiff and the Class damages of $1,500 per unlawful fax

received, pursuant to 47 U.S.C. 227(b)(3);

E. Award Plaintiff and the Class their reasonable litigation expenses and

attorneys' fees;

F. Award Plaintiff and the Class pre- and post-judgment interest, to the

extent allowable; and

10


G. Award such other and further relief as equity and justice may require.

JURY DEMAND

Plaintiff demands a trial by jury for all issues so triable.

Respectfully submitted,Dated: May 9, 2017

FLORIDA PROSTHODONTICS, PA,individually and on behalf of all otherssimilarly situated,

By:Daniel F. DillFlorida Bar Identification No. 056405The Dill Law Group PA350 E. Pine StreetOrlando, FL 32801Telephone: 407.367.0278Facsimile: [email protected]

11

Case 6:17-cv-00899-RBD-GJK Document 1-1 Filed 05/18/17 Page 1 of 3 PagelD 12

EXHIBIT 1

FROFV1 TO

"i'r-1;ase 6:17-cv-00899-RBD-GJK Dournent 1-1 Filed 05/18/17 Page 2 of 3 PagelD 13

201 7/04/2i3 1 7:1 9:36 1 /3

DNA

USA Home Office

USA Home Office

NA

Name: Philip Swann [email protected]

Phone: 443-388-6207 Fax: 43232 913214538979

E-mail [email protected]

Sent: 4/28117 at: 4:09:42 PM 3 page(s) (inducing cover)

Subject: State of FL, Local Dentsply1Sirona Midwest Handpiece & Bur Deals!, Dana Larkin

Comments:

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Mav St June 2017 Local Midwest Deals!

2017/04/28117:19:36 3 /3

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CONTACT LOCAL EXECUTIVE MIDWEST SPECIALIST

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Cell:(813) 230-11104

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Case 6:17-cv-00899-RBD-GJK Document 1-2 Filed 05/18/17 Page 1 of 2 PagelD 15518/2017 Florida Middle Civil Cover Sheet

JS 44 (Rev 09/10)

UNITED STATES DISTRICT COURTMIDDLE DISTRICT OF FLORIDA

CIVIL COVER SHEET

This automated JS-44 conforms generally to the manual JS-44 approved by the Judicial Conference ofthe United States in September1974. The data is required for the use ofthe Clerk ofCourt for the purpose ofinitiating the civil docket sheet. The information

contained herein neither replaces nor supplements the filing and service ofpleadings or other papers as required by law.

Plaintiff(s): Defendant(s):First Listed Plaintiff: First Listed Defendant:

Florida Prosthodontics, PA; Dentsply Sirona, Inc.;County ofResidence: Brevard County County ofResidence: Outside This District

County Where Claim For Relief Arose: Brevard County

Plaintiff s Attorney(s): Defendant's Attorney(s):Daniel F. Dill (Florida Prosthodontics, PA)The Dill Law Group PC350 E. Pine StreetOrlando, Florida 32801Phone: 407.367.0278Fax: 407.206.3297Email: [email protected]

Basis of Jurisdiction: 3. Federal Question (U.S. not a party)

Citizenship of Principal Parties (Diversity Cases Only)Plaintiff: N/A

Defendant: N/A

Origin: I. Original Proceeding

Nature of Suit: 890 Other Statutory Actions

Cause of Action: Violation of Telephone Consumer Protection Act, 47 U.S.C. 227

Requested in ComplaintClass Action: Class Action Under FRCP23

Monetary Demand (in Thousands): 5000

Jury Demand: Yes

Related Cases: Is NOT a refiling ofa previously dismissed action

Signature: Daniel T. Dill

Date: May 9, 2017

1/2

Case 6:17-cv-00899-RBD-GJK Document 1-2 Filed 05/18/17 Page 2 of 2 PagelD 1651812017 Florida Middle Civil Cover Sheet

Ifany of this information is incorrect, please dose this window and go back to the Civil Cover Sheet Input form to make the conection and generate the

updated JS44. Once corrected, print this form, sign and date it, and submit it with your ncW civil action.

2/2

ClassAction.orgThis complaint is part of ClassAction.org's searchable class action lawsuit database and can be found in this post: Dentsply Hit with TCPA Lawsuit over 'Junk' Faxes

https://www.classaction.org/news/dentsply-hit-with-tcpa-lawsuit-over-junk-faxes

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