At least one district court of the First Circuit has followed the majority approach of the Second, Seventh, Ninth, and Tenth Circuits, see Kalika, LLC v. Bos. & Maine Corp., Case No. CV 15-14043-GAO, 2019 WL 1276099, at *1, 7 (D. Mass. Mar. 20, 2019), and at least one has followed the minority approach of the Fourth and Eleventh Circuits, see Bridge v. Invest Am., Inc., 748 F. Supp. 948, 952 (D.R.I. 1990). The First Circuit has not yet weighed in on the question.