What appears at first to be another TCPA lawsuit involving unwanted calls has turned into a much more fundamental dispute between Mark Dobronski and Rocket Mortgage, LLC.
The central issue is not yet whether Rocket Mortgage violated the TCPA.
It is whether Rocket Mortgage can prove that Dobronski ever entered into the online transaction that the company says created an agreement to arbitrate his claims.
Rocket Mortgage says its records show that an online mortgage lead was submitted using Dobronski’s telephone number.
Dobronski says he never submitted the lead.
That disagreement matters because the alleged online submission supposedly contained language providing both marketing consent and an arbitration agreement covering TCPA claims.
If Rocket can establish that Dobronski actually completed the form, the arbitration provision could become highly significant.
If it cannot, the company’s effort to move the TCPA case into arbitration faces a basic contract-formation problem.
The dispute is Dobronski v. Rocket Mortgage, LLC, No. 25-12798, 2026 WL 2296669 (E.D. Mich. Aug. 10, 2026), discussed by TCPAWorld in its August 11, 2026 article.
The case offers a revealing look at the increasingly important relationship between TCPA litigation, online lead generation, digital records, consent, arbitration, and the Federal Arbitration Act.
The Alleged Calls That Started the Dispute
The controversy began with communications that Dobronski says he never wanted.
According to the TCPAWorld account, Dobronski alleged that he received approximately 20 calls between August 11 and August 19, 2025, all apparently coming from the same number.
The alleged pattern was unusual.
The phone would ring once and then disconnect before Dobronski could answer.
Eventually, he called the number back.
Dobronski says the call reached an automated interactive voice response system identifying Rocket. After selecting 1, he was connected with an agent identified as Blake.
According to Dobronski’s account, Blake said Rocket was trying to reach him regarding refinancing.
Dobronski allegedly explained that his number was registered on the Do Not Call Registry, that he had no interest in the offer, and that Rocket should stop calling him.
The alleged communications did not end there.
Dobronski says another call came in during September 2025, followed by a text message from a Rocket loan officer.
Those alleged contacts became the foundation of the TCPA lawsuit.
But Rocket Mortgage’s defense rests on a different version of how the relationship began.
Rocket Mortgage Says the Contact Was Connected to an Online Lead
Rocket Mortgage relied on company records to explain why Dobronski’s number appeared in its system.
A declaration from a Principal Data Analyst reportedly described an online mortgage inquiry submitted on or around August 11, 2025.
The inquiry allegedly came from IP address 173.167.231.105.
The information reportedly included:
- The name “Test Testing”
- Dobronski’s telephone number
- A Michigan property
- A purchase-loan inquiry
- A requested loan amount of $250,000
- A click on “Confirm & continue”
From Rocket Mortgage’s perspective, those records supplied an explanation for the subsequent communications.
The company wasn’t simply calling a number without any apparent connection to a mortgage inquiry.
According to its evidence, an online user had submitted information that included Dobronski’s telephone number.
But the lead contained something even more consequential.
It allegedly included an agreement to arbitrate.
The Online Form Allegedly Included a TCPA Arbitration Agreement
The arbitration issue stems from the language associated with the “Confirm & continue” button.
According to the court record as summarized by TCPAWorld, the disclosure above the button stated that clicking it constituted agreement to the website’s Terms of Use.
Those Terms allegedly contained an agreement to arbitrate TCPA claims.
The disclosure also reportedly provided consent to marketing communications, including calls and text messages even where a telephone number appeared on a do-not-call list.
The Terms allegedly covered TCPA and related state-law claims and were governed by the Federal Arbitration Act.
That potentially gave Rocket Mortgage a powerful procedural argument.
If Dobronski had actually submitted the lead, Rocket could argue that he accepted the Terms and agreed to resolve covered claims through arbitration.
But Rocket faced one significant problem.
Dobronski says he never submitted the lead.
Dobronski Directly Challenges Rocket’s Evidence
Dobronski did not merely argue that the arbitration clause was unfair.
His position was more fundamental.
He submitted a sworn declaration denying that he created the online transaction.
According to TCPAWorld, Dobronski denied:
- Submitting the mortgage inquiry
- Authorizing another person to submit it
- Using the identified IP address
- Using the name “Test Testing”
- Having an Ann Arbor residence
- Having Comcast internet service
He also challenged Rocket’s interpretation of the IP evidence.
Dobronski reportedly cited public IP information connecting the disputed August address to a Comcast connection at the Humane Society in Ann Arbor.
He maintained that he had no Ann Arbor residence and did not use Comcast internet service.
That put the parties’ evidence in direct conflict.
Rocket Mortgage had its electronic business records.
Dobronski had sworn testimony denying that those records represented a transaction he made.
The issue was therefore no longer simply whether Rocket possessed an arbitration clause.
The issue became whether Dobronski ever agreed to it.
A Second Lead Added Another Layer to the Dispute
Rocket Mortgage also produced evidence concerning a second inquiry dated September 29, 2025.
According to the TCPAWorld report, that inquiry allegedly contained:
- The same name
- The same telephone number
- The same state
- A different IP address
Rocket’s analyst reportedly testified that the company’s systems associated both submissions with the same individual.
That evidence supported Rocket’s position that the online activity was connected.
But it did not automatically resolve Dobronski’s denial.
The court therefore faced a classic formation dispute:
Rocket Mortgage said its records showed an online transaction.
Dobronski said he never made it.
And if Dobronski did not make the transaction, Rocket could not simply assume that the arbitration provision applied to him.
The Court Had to Deal With Contract Formation First
This distinction is crucial.
The court was not initially deciding whether Rocket Mortgage’s arbitration clause was legally enforceable in the abstract.
It first had to determine whether an agreement existed at all.
Magistrate Judge Altman treated Dobronski’s sworn declaration as competent evidence and concluded that there was a factual dispute regarding formation.
The magistrate judge recommended denying Rocket’s motion to compel arbitration without prejudice, finding that Rocket had not established that Dobronski himself entered into the arbitration agreement.
That was not necessarily a final rejection of arbitration.
Instead, it left the formation issue open.
Rocket Mortgage Challenges the Initial Procedure
Rocket Mortgage objected to that approach.
Judge F. Kay Behm sustained Rocket’s objection and determined that the court needed to address the formation issue first.
The reason was Section 4 of the Federal Arbitration Act.
When the making of an arbitration agreement is disputed, the court must determine whether that agreement was actually made.
The TCPAWorld article discusses Sixth Circuit precedent including Southard v. Newcomb Oil Co. and Boykin v. Family Dollar Stores of Michigan, LLC in explaining this procedural requirement.
The principle is important:
A court cannot simply enforce an arbitration agreement before resolving a genuine dispute over whether the plaintiff ever entered into that agreement.
That ruling effectively placed the underlying TCPA claims on the back burner.
The TCPA Merits Are Now Waiting Behind the Arbitration Question
Following Judge Behm’s decision:
- Rocket Mortgage’s motion to compel arbitration was denied without prejudice.
- The first motion to dismiss was denied as moot.
- The second motion to dismiss was denied without prejudice.
- Other objections were overruled without prejudice.
- The case was placed in abeyance while targeted discovery takes place.
- The parties were directed toward a summary trial concerning formation of the alleged arbitration agreement.
The result is a much narrower dispute.
The immediate question is:
Did Dobronski, or someone authorized to act for him, submit the Rocket Mortgage form?
That answer could determine whether the broader TCPA claims remain in federal court or move toward arbitration.
What If Rocket Mortgage Proves the Lead Was Dobronski’s?
The consequences could be substantial.
According to TCPAWorld, Dobronski’s primary challenge is not that the arbitration clause inherently fails.
His argument is that he never entered into the underlying transaction.
That distinction matters.
If Rocket Mortgage ultimately establishes that Dobronski personally submitted the form, or that someone acting with his authority submitted it, the arbitration provision could potentially become enforceable, depending on the court’s ultimate findings.
The underlying TCPA claims could then be pushed toward arbitration rather than federal court litigation.
In other words, the lead itself may determine the forum in which the TCPA dispute is ultimately heard.
The Disputed IP Address May Not Be Enough
The role of the IP address raises another important issue for TCPA online lead litigation.
An IP address can identify a network connection.
It does not necessarily establish the identity of the person who used that connection.
Rocket Mortgage has the disputed IP address.
Dobronski has challenged the connection by pointing to information associating it with a Comcast connection at an Ann Arbor Humane Society location.
He denies living there or using Comcast.
That creates a gap between:
Where the connection may have originated
and
Who actually submitted the mortgage inquiry.
TCPAWorld describes IP geolocation as “soft evidence” and emphasizes the importance of preserving additional technical evidence when online leads are being used to establish consent or arbitration.
What Could Provide Stronger Proof?
The case illustrates why a basic lead record may not always be enough.
TCPAWorld points to several forms of evidence that could potentially provide a stronger connection between a lead and an actual person:
- Device fingerprints
- Session recordings
- TrustedForm certificates
- Jornaya records
- Precise timestamps
- Other technical records linking a person to the online transaction
The distinction is critical.
A database can establish that a phone number appears in a lead.
But a defendant may need stronger evidence to establish:
Who entered that number?
Who clicked the button?
Who accepted the Terms?
Who agreed to arbitration?
Those are separate questions.
A Sworn Denial Can Put Arbitration Formation at Issue
Another important feature of the case is Dobronski’s sworn declaration.
TCPAWorld discusses Bazemore v. Papa John’s USA, Inc., 74 F.4th 795 (6th Cir. 2023) in connection with sworn evidence disputing contract formation.
The takeaway is not that a plaintiff can defeat arbitration simply by saying, “I never agreed.”
Rather, a competent sworn denial can create a factual issue that the defendant must address with evidence.
Business records may be important.
But if those records are directly challenged by sworn testimony, the court may need to determine which evidence establishes whether an agreement was actually formed.
Discovery Becomes Part of the Fight
The parties also became involved in a discovery dispute.
According to TCPAWorld, Dobronski attempted through his briefing to limit Rocket’s discovery concerning his online activity while seeking broader discovery from Rocket.
The court rejected that approach.
The court noted issues involving the lack of a demonstrated Rule 26(f) conference, procedural deficiencies, and arguments that had not been properly presented.
The parties were instructed to confer in good faith and work through straightforward discovery disputes before asking the court to intervene.
That procedural ruling may seem less dramatic than the arbitration issue, but it reinforces an important point.
Once a court narrows litigation to a specific formation question, the parties need to focus their discovery and arguments on that question.
Rocket Mortgage’s Arbitration Argument Is Still Alive
It would be misleading to describe Rocket Mortgage’s position as permanently defeated.
The company’s motion to compel arbitration was denied without prejudice.
The court did not determine that arbitration was impossible.
Instead, the court determined that the formation issue must be resolved first.
That gives Rocket an opportunity to develop additional evidence and potentially renew its arbitration position after targeted discovery.
For Rocket Mortgage arbitration, that procedural distinction matters.
The company has not yet obtained arbitration.
But it has successfully shifted the litigation toward a threshold determination that could ultimately decide the forum.
Lessons for TCPA Defendants
The Dobronski v. Rocket Mortgage dispute provides several lessons for companies relying on online leads.
Preserve the Complete Digital Trail
A CRM record showing a telephone number may not be sufficient if the consumer denies submitting the form.
Don’t Rely Solely on IP Information
An IP address can identify a connection without identifying the actual person.
Preserve the Exact Consent Experience
Companies should preserve evidence showing the language presented to the user, including the Terms and consent disclosures associated with the submission.
Establish Formation
An arbitration clause only becomes useful if the defendant can prove that the plaintiff actually agreed to it.
Expect Formation Disputes to Take Time
When a plaintiff disputes entering into the agreement, targeted discovery and potentially a factual hearing may come before arbitration.
There Are Lessons for TCPA Plaintiffs Too
The dispute is not necessarily a one-sided lesson for defendants.
Plaintiffs challenging Rocket Mortgage arbitration or another online arbitration agreement should recognize that defendants may possess extensive digital records.
Those records could include:
- Lead submissions
- Telephone numbers
- IP addresses
- Timestamps
- Multiple inquiries
- Device information
- Session records
- Consent records
A defendant with comprehensive technical evidence may be in a much stronger position than one relying on a basic lead database.
But where the consumer genuinely did not submit the lead, competent evidence challenging the alleged transaction can put contract formation squarely before the court.
Again, the deciding factor is evidence.
Why Online Lead Generation Matters in TCPA Litigation
The broader importance of the case comes from how frequently online lead generation intersects with TCPA disputes.
Online forms can allegedly establish:
- Consumer interest
- Telephone numbers
- Marketing consent
- Authorization for communications
- Acceptance of Terms of Use
- Arbitration agreements
But the existence of an electronic record does not automatically establish who created it.
The Mark Dobronski Rocket Mortgage case puts that problem directly in front of the court.
The critical questions are not simply whether the lead exists.
They are:
Who submitted it?
Who clicked “Confirm & continue”?
Who accepted the Terms?
Who consented to communications?
Who agreed to arbitration?
Those questions can determine whether a defendant gets to move a TCPA dispute out of federal court.
Everything Comes Back to the Alleged Mortgage Lead
At this stage, the litigation can be reduced to a single factual conflict.
Rocket Mortgage says its records connect Dobronski’s telephone number to an online mortgage inquiry.
Dobronski says he never submitted it.
The August lead allegedly used the name “Testq Testing,” involved a Michigan property, requested a $250,000 purchase loan, and was associated with the disputed IP address.
Rocket also identified another September inquiry containing matching information.
Dobronski disputes the connection.
The federal court has therefore directed the parties toward targeted discovery and a determination of whether the alleged agreement was actually formed.
The underlying TCPA claims remain behind that threshold question.
Final Takeaway: No Form, No Arbitration?
The Mark Dobronski Rocket Mortgage dispute illustrates a basic but important principle of online contracting.
An arbitration provision cannot simply be imposed on someone who never agreed to it.
Rocket Mortgage says its records demonstrate that an online mortgage lead was submitted using Dobronski’s telephone number.
Dobronski says he never submitted the form.
That form allegedly contained marketing consent and a TCPA arbitration agreement.
His sworn declaration was enough to create a factual dispute concerning whether the agreement was actually formed.
The federal court therefore did not immediately compel arbitration.
Instead, the court placed the underlying case on hold while the parties focused on targeted discovery and the formation issue.
For Rocket Mortgage and other companies defending TCPA claims, the message is straightforward:
A lead record may show that information was submitted. It does not necessarily prove who submitted it.
For plaintiffs, the case demonstrates that a genuine, supported denial of contract formation can force the defendant to prove the connection.
And for anyone following Mark Dobronski, Rocket Mortgage, TCPA arbitration, and online lead litigation, the next phase may ultimately determine whether this case is litigated in federal court or sent to arbitration.
The real battle is therefore not simply over whether an arbitration clause exists.
It is over whether Mark Dobronski ever agreed to it in the first place.
Sources
Primary Source: TCPAWorld: “NO FORM, NO FORUM: Rocket Mortgage Must Prove Dobronski Filled Out the Lead Before It Gets Arbitration”, published August 11, 2026.
Case: Dobronski v. Rocket Mortgage, LLC, No. 25-12798, 2026 WL 2296669 (E.D. Mich. Aug. 10, 2026).
Authorities Discussed: Southard v. Newcomb Oil Co., No. 19-5187 (6th Cir. Nov. 12, 2019); Boykin v. Family Dollar Stores of Michigan, LLC, 3 F.4th 832 (6th Cir. 2021); and Bazemore v. Papa John’s USA, Inc., 74 F.4th 795 (6th Cir. 2023).
Disclaimer
This article is intended for informational and commentary purposes only.
Statements attributed to Mark Dobronski, Rocket Mortgage, attorneys, witnesses, or other participants are presented as allegations, arguments, testimony, or characterizations where applicable. They should not be treated as independently established facts unless supported by a judicial finding or other reliable evidence.
The existence of litigation, motions, declarations, discovery disputes, arbitration requests, or court orders does not establish that every allegation made by either party is true.
The descriptions concerning the alleged mortgage inquiries, IP address, name “Test Testing,” telephone number, Michigan property, $250,000 loan amount, consent language, and arbitration provision are based on the TCPAWorld report and the proceedings described there.
This article does not independently establish who submitted the disputed mortgage forms.
At the time of the reported decision, the central factual issue remained unresolved: whether Dobronski, or someone acting with his authority, actually submitted the Rocket Mortgage inquiry.
Nothing in this article should be interpreted as a determination that any individual or company engaged in unlawful conduct unless and to the extent that such conduct has been established by a competent court.
