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Glossary · Compliance

What is Litigator scrub?

  • Also called: litigation scrub, tcpa litigator list

Reviewed by Sujan ThapaliyaLast updated

Definition

A litigator scrub screens a calling list against numbers associated with serial telemarketing plaintiffs and known complaint filers, so those numbers are suppressed before dialing. It is risk management layered on top of do-not-call compliance, not a substitute for it.
The three STIR/SHAKEN attestation levels, which underpin how litigator scrub behaves in practice: A asserts both that the carrier knows the customer and that the customer may use the calling number, B asserts the customer only, and C asserts neither. A shared number pool can reach B at best, which is why number ownership keeps recurring in these definitions.
Attestation is the backdrop to most caller-ID and deliverability terms, litigator scrub included.

In practice

How litigator scrub actually works

A small number of individuals file a disproportionate share of telemarketing claims, and their numbers circulate in commercially maintained lists. Removing them removes a measurable share of exposure at trivial cost.

It is not a defence. Scrubbing plaintiffs from a list that should not be called at all reduces the chance of being sued without making the calling lawful.

Most operations run it as a final step after do-not-call scrubbing and internal suppression, immediately before the list is loaded.

The lists themselves are commercially maintained and imperfect, which is worth knowing before relying on one. They lag new filings, they include people whose only offence was complaining once, and none of them is authoritative. Treat a scrub as reducing exposure by a useful margin rather than as a clean bill of health.

Worked example

It runs last, after registry and internal suppression, on the list that would otherwise be dialled. Scrubbing plaintiffs from a list you should not be calling reduces the chance of being sued without making the calls lawful.

Litigator scrub: common questions

Is a litigator scrub legally required?
No. It is a commercial risk control, not a compliance obligation. The required steps are registry scrubbing, internal suppression and consent.
Does scrubbing litigators make my campaign compliant?
No, and treating it that way is dangerous. It reduces the probability of being sued by a professional plaintiff; it does nothing about whether the calls were lawful.
When should the scrub run?
Last, immediately before loading — after registry and internal suppression, so it applies to the list that would otherwise be dialled.

Sources

  1. Combating Spoofed Robocalls with Caller ID Authentication — Federal Communications CommissionThe STIR/SHAKEN framework, the attestation levels carriers sign calls with, and the mandate requiring providers to authenticate caller ID.
  2. 47 U.S.C. § 227 — Restrictions on the use of telephone equipment — Cornell Legal Information InstituteThe Telephone Consumer Protection Act itself — the consent requirements, calling-hours limits, and private right of action.
  3. ITU-T Recommendation E.164 — The international public telecommunication numbering plan — International Telecommunication UnionThe international number format, the 15-digit maximum, and how country codes and national numbers compose.

See litigator scrub in the product

An auto dialer is any system that places outbound calls without a person keying digits. There are four modes — power, preview, progressive and predictive — and they differ in how many calls run per rep and who hears the phone ring first. All four are in the base product here, switchable per campaign.

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