The Second Department determined the content of text messages was admissible (i.e., authenticated) because the messages “made no sense” unless sent by the defendant:
…[T]he text messages from the defendant to the complainant were properly admitted into evidence. Since the content of the text messages “made no sense unless [they were] sent by defendant” …, the text messages themselves were sufficient to authenticate that they were sent by the defendant … . People v Green, 2013 NY slip Op 04623, 2nd Dept, 6-19-13