Well, they didn’t actually use the word “devastation”. In Susinno v. Work out World, Inc., 2017 WL 2925432, at *4 (C.A.3 (N.J.), 2017), the Court of Appeals for the Third Circuit held that:
Traditionally, a plaintiff’s “privacy is invaded” for the purpose of an intrusion upon seclusion claim by telephone calls “only when [such] calls are repeated with such persistence and frequency as to amount to … hounding.” Intrusion upon Seclusion, Restatement (Second) of Torts § 652B, cmt d (1977). The Second Restatement suggests that because “two or three” calls would not be “highly offensive to the ordinary reasonable [person],” they traditionally would provide no cause of action. Id. Yet when Congress found that “[u]nsolicited telemarketing phone calls or text messages, by their nature, invade the privacy and disturb the solitude of their recipients,” Van Patten, 847 F.3d at 1043, it sought to protect the same interests implicated in the traditional common law cause of action.3 Put differently, Congress was not inventing a new theory of injury when it enacted the TCPA. Rather, it elevated a harm that, while “previously inadequate in law,” was of the same character of previously existing “legally cognizable injuries.” Spokeo, 136 S. Ct. at 1549. Spokeo addressed, and approved, such a choice by Congress.