Is a text message a "call" under the Telecommunications Act?

messages. The TCPA makes it unlawful "to make any call (other than a call ... made with the prior express consent of the called party) using any automatic telephone dialing system ... to any telephone number assigned to a ... cellular telephone service[.]" 47 U.S.C. 227(b)(1)(A)(iii). A text message is a "call" within the meaning of the TCPA. Satterfield v. Simon & Schuster, Inc., 569 F.3d 946, 952 (9th Cir. 2009). The TCPA, however, does not define the term "to make any call[.]"