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TCPA exposure is not evenly distributed across a list. A small number of people file repeatedly, often with the same handful of firms, and they are in commercial databases precisely because they keep appearing in filings. Screening against those databases is the cheapest risk reduction available to a calling operation.
The unit is the call, not the lawsuit. A single record dialled repeatedly across a follow-up cadence becomes a large number quickly, which is why suppression has to happen before the dialler rather than after a complaint.
Statutory damages under 47 U.S.C. § 227.
What a scrub actually catches
- Known serial plaintiffs, by phone number, across multiple filings.
- Numbers associated with plaintiff-side TCPA firms.
- Numbers appearing on published complaint dockets.
- In better products, numbers showing the behavioural pattern of a filer before they have filed.
What it does not catch
A scrub is a filter on known bad outcomes, not a licence. It says nothing about whether your consent is valid, whether you honoured a revocation, whether you called inside permitted hours, or whether the number was reassigned to somebody who never consented to anything. A clean scrub on a record with no defensible consent behind it is a clean scrub on an indefensible call.
Who should be running it
| Step | Vendor | You |
|---|---|---|
| Scrub at generation | Yes — before the lead is sold | — |
| Scrub before dialling | — | Yes, on your own list |
| Re-scrub aged records | — | Yes, before any re-engagement |
| Maintain internal suppression | — | Yes, permanently |
Both sides should be doing it, and the answer "our vendor handles it" is not a position you can defend if you are the one who placed the call. The scrub costs cents; a single willful claim does not.
Questions brokers ask
What is a TCPA litigator scrub?
A check of phone numbers against commercial databases of known serial TCPA plaintiffs and plaintiff-side firms, run before the numbers reach a dialler so that matches are suppressed rather than called. It costs cents per record and removes the concentrated part of the risk.
Does a litigator scrub make calling compliant?
No. It filters out the people most likely to sue you; it says nothing about whether your consent is valid, whether you honoured a revocation, or whether you called inside permitted hours. Treating the scrub as the compliance programme is the common and expensive mistake.
Should the lead vendor scrub, or should I?
Both. The vendor should scrub at generation so a known filer never becomes a lead. You should scrub your own dialling list, because you are the one placing the call and "our vendor handles it" is not a defence that survives contact with a complaint.
How much does litigator scrubbing cost?
Low single-digit cents per record from the established providers, with volume pricing below that. Against statutory damages of $500 to $1,500 per call it is the cheapest line item in a calling operation.
Do aged leads need re-scrubbing?
Yes, and more than fresh ones. Numbers get reassigned, people become plaintiffs, and consent gets revoked in the months between generation and re-engagement. A scrub from six months ago is evidence about a list that no longer exists.
Alex Makowski
Founder, Infinite Bookings
Runs the lead generation operation behind Infinite Bookings — paid traffic, the funding application, and the delivery pipeline that puts records into brokers’ CRMs.
Reachable directly at alex@infinitebookings.com or 732-609-7182.