A litigator scrub checks numbers against databases of known serial TCPA plaintiffs and the attorneys who file for them, and suppresses matches before they reach a dialler. It matters because TCPA claims are concentrated: a small population of repeat filers accounts for a large share of suits, so removing them removes most of the realistic exposure from a list at a cost of cents per record.
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.
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.
| 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.
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.
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.
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.
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.
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.
We will tell you straight up if we cannot help you. No commission deals, no free trials, no chasing you for three weeks.