Why Repeat TCPA Filers Matter and How Small Call Centers Can Protect Themselves With Pre-Call Screening 

A small share of TCPA plaintiffs accounted for almost half of the cases in one recent litigation analysis.

CompliancePoint found that 21.3% of plaintiffs in its 2024 TCPA dataset filed two or more cases that year. Those repeat filers accounted for 49.2% of the cases.

The finding comes from CompliancePoint’s TCPA Litigation Trends 2025 Year in Review, which defines serial plaintiffs as people who filed two or more TCPA cases during a year.

Small call centers, independent lead generators, and solo insurance agents should be asking one thing before dialing: How much do we actually know about this number?

Pre-call screening cannot tell you whether a call is legal, but it can show DNC status, complaint history, and TCPA litigation indicators before you dial.  

What CompliancePoint Found About Repeat TCPA Filers         

CompliancePoint identified 226 serial plaintiffs in its 2024 TCPA dataset. Under its definition, a serial plaintiff was someone who filed two or more TCPA cases during the year.

Those 226 people represented 21.3% of plaintiffs but accounted for 49.2% of cases.

The important part is the concentration of cases among a relatively small group of plaintiffs.

It does not mean almost half of consumers who receive marketing calls regularly file TCPA lawsuits. It also does not mean repeat filers are doing anything wrong. Consumers can bring TCPA claims when they believe a business violated their rights.

What the data does show is that a smaller group of plaintiffs filed a large share of the TCPA cases in CompliancePoint’s dataset.

If your business makes outbound calls, a TCPA litigation indicator associated with a number is another signal you may want to review before dialing. It should be considered with other factors such as consent, DNC status, opt-outs, reassigned numbers, calling rules, and internal suppression records.

Why Repeat TCPA Filers Matter to Small Call Centers and Lead Generators  

Being a small business does not remove TCPA compliance obligations, but a small call center may have far fewer people managing them.

A five-person call center may not have a compliance employee checking every lead file. An independent insurance agent may receive a spreadsheet of purchased leads and start calling that afternoon.

That leaves less room to fix a questionable lead after calls have already started.  

Small Call Centers  

Small call centers often work with lists supplied by clients, lead vendors, or internal sales teams.

Agents may know very little about where each number came from. A campaign file might contain current leads, older records, purchased data, and numbers collected under different consent terms.

Once that file enters a dialer, a problem can affect many calls quickly.

Checking the list before launch gives the business a chance to identify records that need more review.

Independent Lead Generators  

Lead generators may receive consumer information from landing pages, affiliates, publishers, data vendors, or older databases.

An active phone number does not tell you how the lead was collected.

Businesses still need to know when consent was obtained, what language was shown, which parties were covered, and whether an opt-out has happened since.

Complaint and TCPA litigation indicators can give the lead generator more information before contacting, routing, or selling the lead.  

Solo Insurance Agents  

Independent insurance agents may buy leads from aggregators or work older prospect lists without a dedicated compliance team.

When a complaint arrives, the agent may need to locate the original lead record, consent details, call history, vendor information, and prior opt-out requests.

Checking those signals before dialing can tell an agent which leads need another look.  

A Valid Phone Number Is Not the Same as a Low-Risk Number  

Phone validation answers important operational questions.

Is the number active? Is it a landline, wireless number, or VoIP line? Which carrier serves it? What state and time zone are associated with it?

Those details do not answer every compliance question.

A working phone number could also appear on a Do Not Call registry. It may have prior telemarketing complaint history. It may have been associated with TCPA litigation. It could also belong to someone who already asked your company not to call.

The phone number may even have changed owners since consent was collected.

A valid-number check and a compliance check answer different questions.

Consent, campaign purpose, exemptions, internal opt-outs, state requirements, and the way the call or text is made still matter.

How Pre-Call TCPA Screening Helps Before an Outbound Call  

Small outbound teams do not need to wait for a complaint before reviewing a phone number.

Start with the number itself.

First, confirm that the number is valid and belongs in the campaign. Then check applicable DNC status and compare it with your internal DNC and suppression records.

Next, review available complaint and litigation indicators.

If a number comes back with a complaint or litigation indicator, check the lead more closely before an agent calls. That could mean checking the lead source, consent date, consent language, prior contact history, or campaign eligibility.

The same approach applies to purchased leads.

A vendor saying that leads are compliant should not be the only information you have. Your business should understand how the records were collected and what permission was provided.

Keep records of the checks performed and the information used to make calling decisions.

Check these signals before the campaign starts, not for the first time after a complaint or demand letter arrives.  

How Searchbug Supports Pre-Call TCPA Review 

Searchbug’s Phone Validator and DNC Check can help outbound teams review phone and compliance-related signals before outreach starts.

Two of those signals, TCPA Litigator and DNC Complainer, are flags within the screening process. They are not separate standalone Searchbug products.

The signals answer different questions:

• DNC Check: Is the number on an applicable Do Not Call registry?
• DNC Complainer flag: Is there prior complaint activity associated with the number?
• TCPA Litigator flag: Is there a TCPA litigation indicator associated with the number?

Use these results to decide when a record needs closer review. They should not be treated as an automatic yes or no on whether to call.

Phone Validator  

Searchbug Phone Validator can return information such as phone status, line type, carrier, state, time zone, and available compliance-related indicators.

For small outbound teams, this helps answer basic questions about a number before it enters a campaign. It can also surface DNC Complainer and TCPA Litigator flags where available.

The goal is to give the caller more information before dialing rather than relying only on the data supplied with the lead.

DNC Check  

Searchbug DNC Check screens phone numbers against the National Do Not Call Registry and supported state DNC lists.

The screening can also return DNC Complainer and TCPA Litigator indicators.

A DNC result should still be reviewed with the purpose of the call, consent records, applicable exemptions, internal DNC requests, and other requirements that apply to the campaign.

TCPA Litigator Flag  

The TCPA Litigator flag identifies a phone number associated with TCPA litigation based on Searchbug’s available data.

It is a risk signal within Phone Validator and DNC screening, not a separate product and not a legal determination.

A positive flag does not establish that the person is a repeat filer. It also does not determine whether a proposed call would violate the TCPA.

For a small calling team, the value is knowing that the litigation indicator exists before an agent makes contact.

DNC Complainer Flag  

The DNC Complainer flag is also part of Searchbug’s phone screening and is different from ordinary DNC registration.

It indicates prior complaint activity associated with the phone number based on Searchbug’s available data.

The flag does not determine whether a complaint was valid or whether future contact is prohibited. Review it alongside DNC status, consent records, suppression lists, and the rest of the lead information before calling.

What Pre-Call Screening Cannot Tell You  

No single data flag determines whether an outbound call is compliant.

A TCPA Litigator result does not prove that a new call would violate the TCPA. A complaint indicator does not establish the outcome of a past complaint. A clean result does not guarantee that a call is compliant.

Businesses still need to manage consent, opt-outs, internal DNC requests, and applicable state rules.

Screening gives your team more information, but someone still has to decide whether the call meets your compliance rules.  

What to Check Before a Number Enters Your Dialer  

Before adding a number to an outbound campaign:

• Confirm that the phone number is valid and active.
• Make sure the record belongs in the intended campaign.
• Check applicable federal and state DNC status.
• Review available DNC complaint indicators.
• Review available TCPA litigation indicators.
• Confirm when and how consent was collected when required.
• Check internal DNC and suppression lists.
• Check whether the number may have been reassigned when prior consent is being relied on.
• Hold unclear or higher-risk records for additional review before dialing.
• Keep records of the checks completed.

The checks you need will vary based on the campaign, where you are calling, and how consent was collected. The goal is to answer as many questions as possible before an agent makes contact.

TL;DR  

CompliancePoint found that repeat filers represented 21.3% of plaintiffs but accounted for 49.2% of cases in its 2024 TCPA dataset. That concentration does not mean repeat filers have done anything improper, and a TCPA litigation indicator alone does not determine whether a business should contact someone.

For small call centers, lead generators, and independent agents, the practical takeaway is to review as much information as possible before dialing. DNC status, complaint history, TCPA litigation indicators, consent records, internal suppression lists, and other applicable compliance checks can help identify numbers that may need closer review.

Pre-call screening does not determine whether a call is compliant, but it gives outbound teams more information before making contact. Finding those signals before dialing can also provide a record of what was checked if a complaint or demand letter comes later.

Create a free Searchbug API Test Account with $10 in credits to test Phone Validator and available phone compliance checks. Searchbug also offers Bulk Processing for teams that need to screen larger calling lists.

Editorial Note  : This article is for general informational purposes and does not provide legal advice. TCPA and telemarketing requirements can vary based on the communication, consent, technology used, jurisdiction, and other facts. Businesses should consult qualified legal counsel about their specific compliance obligations.