Court Dismisses Lawsuit Against Dental Service Organization (DSO) Involving AI Calls, Citing Normal Business Exception

# DentalGoodNews｜On January 13, 2026, the United States District Court for the Northern District of Illinois dismissed the plaintiff's claim brought under the federal Wiretap Act in the case of Lisota v. Heartland Dental and RingCentral, citing the "ordinary course of business" exception under the Electronic Communications Privacy Act (ECPA). The court ruled that the AI-powered call transcription and analysis service provided by RingCentral to the Dental Service Organization (DSO) does not constitute unlawful interception.

The lawsuit was filed on July 3, 2025, naming Heartland Dental and cloud communications service provider RingCentral as defendants. Plaintiff Megan Lisota alleged that her dental practice contracted Heartland Dental to handle incoming call administrative tasks, which in turn subcontracted RingCentral to provide cloud-based phone services. This service integrated AI-powered real-time speech transcription, automatic call summarization, and sentiment analysis features. The plaintiff claimed that her call content was processed without explicit notification or consent, violating the ECPA's prohibition against intercepting electronic communications.

The court, relying on Section 2510(5)(a) of the ECPA, determined that the statutory definition of "intercept" does not include equipment used by an electronic communication service provider in the "ordinary course of business." The court confirmed that RingCentral is an electronic communication service provider, a point not disputed by the parties. The contested issue was whether its AI recording and analysis activities fell within the "ordinary course of business." The court found that RingCentral explicitly positions its product as an "AI-powered business communications platform," and the aforementioned AI features are integral components of its core service, thus qualifying for the exemption.

The court also rejected the plaintiff's argument that RingCentral had two separate business purposes: first, improving dental appointment conversion rates; and second, using call data to optimize its AI models. The court held that improving appointment conversion is a manifestation of integrating AI capabilities into the phone service, and using call data to refine algorithms is an "incidental activity" to providing the AI transcription service. Neither action removes the AI functionality from the scope of the "ordinary course of business." Heartland Dental, having merely commissioned and procured the service, was also held not liable under the ECPA.

Heartland Dental's official website indicates that the company was founded in 1995 and is one of the largest Dental Service Organizations (DSOs) in the United States, supporting over 1,900 affiliated practices and more than 3,100 affiliated doctors across 39 states and the District of Columbia. According to previous reports by DGN, this case represents one of the early federal-level rulings found to date concerning litigation arising from DSOs' use of AI-powered call analysis tools.

This ruling did not adjudicate the "party to the call" exception. Heartland Dental also invoked this exception in its defense—under the ECPA, a party to a communication is permitted to record it. The court deemed the "ordinary course of business" exception sufficient to resolve the case but noted that in multi-level call routing scenarios, determining who qualifies as a "party to the call" could present complex legal questions.

As of publication, the plaintiff has not publicly indicated the next steps in the litigation. The case was presided over by Judge Lindsay C. Jenkins of the United States District Court for the Northern District of Illinois.