ZocDoc Inc. failed a second time to convince the Second Circuit that its offer to settle with the named plaintiff in a junk fax class action should moot the whole case.

The ruling cuts off yet another defense attempt to exploit perceived loopholes in the U.S. Supreme Court’s Campbell-Ewald Co. v. Gomez ruling. There the court held that rejecting a defendant’s offer of full relief doesn’t moot a plaintiff’s individual or class claims.

Radha Geismann M.D. P.C. sued ZocDoc for...