The Heartland Dental AI call-recording lawsuit is a proposed federal class action filed in July 2025 by a dental patient, Megan Lisota, who alleged that Heartland Dental and its phone-service vendor RingCentral used artificial intelligence to secretly record, transcribe, and analyze patient calls in violation of the federal Wiretap Act. A federal judge dismissed the original complaint in January 2026 under the statute’s “ordinary course of business” exception, and an amended complaint is now pending before the same court.
Who Sued and What They Alleged
Lisota filed her complaint on July 3, 2025, in the U.S. District Court for the Northern District of Illinois, Case No. 1:25-cv-07518. She named Heartland Dental, LLC and RingCentral, Inc. as defendants.1Bloomberg Law. Heartland Dental, RingCentral Beat AI Call Transcription Suit She had been a patient at a former Tru Family Dental office, one of 23 practices Heartland acquired in a late-2020 deal.2PR Newswire. Heartland Dental Grows National Network of Supported Offices With Acquisition of Tru Family Dental
The complaint focused on what RingCentral’s software allegedly did during ordinary calls to the dental office. Beyond connecting the call, the platform performed real-time voice transcription, generated automated call summaries, and ran sentiment analysis that labeled the emotional tone of conversations as positive, negative, or neutral.3Oral Health Group. The Consent Gap: What the Heartland Lawsuit Teaches Us About AI in Dentistry
Lisota alleged she shared personally identifiable information and protected health information during those calls, that no one told her the conversations were being captured and analyzed by AI, and that she never consented. She characterized the practice as eavesdropping in violation of Title I of the Electronic Communications Privacy Act, better known as the Federal Wiretap Act. She also alleged Heartland Dental was separately liable for procuring RingCentral’s services.3Oral Health Group. The Consent Gap: What the Heartland Lawsuit Teaches Us About AI in Dentistry
Why the Judge Dismissed the Case
On January 13, 2026, Judge Lindsay C. Jenkins granted both defendants’ motions to dismiss. The ruling turned on one provision of the Wiretap Act. Under 18 U.S.C. § 2510(5)(a), a device used by a communication service provider in the ordinary course of its business is exempt from the statute’s interception rules.1Bloomberg Law. Heartland Dental, RingCentral Beat AI Call Transcription Suit
Judge Jenkins found that RingCentral markets itself as an “AI-powered business communications platform” and that transcription, summarization, and sentiment analysis are central to what the company sells rather than a side project unrelated to its core service. Because those AI tools were essential to RingCentral’s business, they fell within the exception.4CourtListener. Lisota v. Heartland Dental, LLC The court also rejected Lisota’s argument that using call data to train AI models, or to help Heartland book more appointments, were separate business purposes outside the exception. Improving AI models, the court reasoned, is incidental to providing AI transcription in the first place.5Holland & Knight. Recent GenAI Class Actions Build on Early Successes
Once the exception protected RingCentral, the claim against Heartland Dental collapsed with it. If RingCentral did not violate the statute, Heartland could not be liable for paying for services that were lawful. Judge Jenkins called the exception ruling dispositive and declined to reach other defense arguments, including whether Heartland was itself a party to the communications and whether the calls were truly intercepted while “in transit.”4CourtListener. Lisota v. Heartland Dental, LLC
Lisota did win one point. Both defendants had argued she failed to allege a concrete injury, but the court found she had Article III standing to sue. The alleged eavesdropping, Judge Jenkins ruled, closely resembled the common-law tort of intrusion upon seclusion, and that was enough to satisfy constitutional standing requirements.4CourtListener. Lisota v. Heartland Dental, LLC
The Amended Complaint and Current Status
The dismissal was without prejudice, so Lisota was free to refile. On February 3, 2026, she did. The amended complaint takes a different angle, arguing that RingCentral’s AI tools are a separate, optional product rather than a core part of its phone service. That framing is designed to knock out the ordinary course of business defense that ended the first round. The amended pleading also adds a new claim for intrusion upon seclusion, alleging that RingCentral uses patient call data to train its own AI models.4CourtListener. Lisota v. Heartland Dental, LLC
Both defendants moved to dismiss again on March 6, 2026. Heartland Dental’s motion challenged both jurisdiction and the legal sufficiency of the claims. RingCentral filed a separate motion arguing the amended complaint still fails to state a valid claim. Under the court’s schedule, the plaintiff’s responses were due April 3, 2026, and the defendants’ replies were due April 24, 2026. As of mid-2026, those motions remain pending.4CourtListener. Lisota v. Heartland Dental, LLC
What the Ruling Means for AI on Customer Calls
The January 2026 decision is one of the first federal rulings to apply the Wiretap Act’s ordinary course of business exception to AI-driven communication tools. Legal commentators have called it a significant win for technology providers, on the reasoning that when a company’s core product is an AI-powered platform, using AI to process calls is not an unlawful interception under the federal statute.5Holland & Knight. Recent GenAI Class Actions Build on Early Successes
The court did draw a line. Judge Jenkins distinguished this case from situations involving “targeted advertising informed by intercepted content,” where the interception would serve objectives separate from the communication service itself. That leaves room for future plaintiffs who can show the AI analysis went beyond what was necessary to deliver the service being sold.5Holland & Knight. Recent GenAI Class Actions Build on Early Successes
Some analysts expect the federal exception to push future wiretap challenges into state courts, particularly in California, where the California Invasion of Privacy Act may impose different liability standards that are harder for AI platform providers to overcome.5Holland & Knight. Recent GenAI Class Actions Build on Early Successes
The HIPAA Angle
The Lisota case is a Wiretap Act case, not a HIPAA case, and it is worth being clear about that boundary before assuming otherwise. The facts underneath it do raise separate questions about how dental practices handle protected health information when using AI. Patients calling a dental office routinely share names, insurance details, and information about medical conditions, and if those calls are transcribed and analyzed by AI, the data handling falls within HIPAA’s framework.
Under HIPAA, any AI vendor that stores, processes, or analyzes protected health information is considered a “business associate” and must sign a Business Associate Agreement with the practice. Those agreements are required to spell out data use limitations, security standards, and breach notification procedures. BAAs should prohibit the use of patient data for AI model training unless the practice specifically authorizes it, which is the exact issue at the center of Lisota’s amended complaint.6California Dental Association. AI in Dentistry: What Are the HIPAA Violation Risks
As of mid-2026, no HIPAA enforcement action has been reported against Heartland Dental or RingCentral in connection with the call analytics at issue in this litigation.