The Mark Dobronski Rocket Mortgage dispute is no
longer simply about whether a series of alleged calls violated the
Telephone Consumer Protection Act. The bigger question now is whether
Dobronski ever entered into the online transaction that Rocket Mortgage
says created an agreement requiring him to arbitrate his TCPA claims.
Rocket Mortgage says its records show that an online mortgage inquiry
was submitted using Dobronski’s telephone number. Dobronski says he
never submitted the inquiry. That disagreement has become the central
issue because the alleged online form contained language concerning
marketing consent and arbitration of TCPA claims. If
Rocket Mortgage can prove that Dobronski actually submitted the form,
the company could have a path toward arbitration. If it cannot establish
that he entered into the agreement, the arbitration argument becomes
much more complicated. 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 report.
The case provides a useful example of how TCPA lawsuits, online
lead generation, digital evidence, consent, and arbitration
agreements can collide in federal court.
The Alleged Calls
Behind the TCPA Lawsuit
The dispute began with alleged calls to Dobronski’s cell phone.
According to the TCPAWorld account, Dobronski claimed he received
approximately 20 calls between August 11 and August 19,
2025, from the same number. The calls allegedly followed a
peculiar pattern. His phone would ring once, then disconnect before he
could answer. Dobronski eventually called the number back. He says the
call reached an automated interactive voice response system identifying
Rocket. After pressing 1, he was connected to an
individual identified as Blake. According to Dobronski,
Blake explained that Rocket was trying to contact him about
refinancing. Dobronski allegedly responded that his
number was registered on the Do Not Call Registry, that
he was not interested, and that Rocket should stop contacting him.
According to his account, another call arrived in September 2025,
followed by a text from a Rocket loan officer. Those alleged
communications became the foundation of the Mark Dobronski TCPA
lawsuit. Rocket Mortgage, however, says there was an online
lead behind the communications.
Rocket Mortgage’s Online
Lead Evidence
Rocket Mortgage submitted a declaration from a Principal Data
Analyst concerning its records. According to the evidence
described by TCPAWorld, a user visited a Rocket website on or around
August 11, 2025, using IP address
173.167.231.105. The user allegedly submitted a
mortgage inquiry containing:
- 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”
Rocket Mortgage’s position was that these records explained why the
company contacted Dobronski. The company was not relying solely on the
fact that his number appeared somewhere in a database. It pointed to an
alleged online mortgage submission containing specific information. But
the lead allegedly did more than provide contact information. It also
contained an arbitration agreement.
The Alleged
Rocket Mortgage Arbitration Agreement
According to the court record as summarized by TCPAWorld, the
disclosure positioned above the “Confirm &
continue” button stated that clicking the button constituted
acceptance of the website’s Terms of Use. Those Terms allegedly included
an agreement to arbitrate TCPA claims. The disclosure
also allegedly authorized marketing calls and text messages, including
communications to numbers listed on a do-not-call registry. The Terms
reportedly covered TCPA claims and related state-law claims and were
governed by the Federal Arbitration Act. That gave
Rocket Mortgage an obvious procedural argument. If Dobronski had
submitted the form, Rocket could argue that he accepted the Terms and
agreed to resolve covered claims through arbitration. But Dobronski
disputed the starting point entirely. He says he never submitted
the form.
Dobronski’s
Sworn Declaration Challenges the Lead
Dobronski responded with a sworn declaration
disputing Rocket Mortgage’s version of events. According to TCPAWorld,
he denied:
- Submitting the mortgage inquiry himself
- Authorizing anyone to submit it for him
- Using the disputed IP address
- Using the name “Test Testing”
- Having an Ann Arbor residence
- Having Comcast internet service
Dobronski also challenged Rocket’s IP evidence. He reportedly pointed
to public information associating the disputed IP address with a
Comcast connection at the Humane Society in Ann Arbor.
Dobronski maintained that he had no Ann Arbor residence and no Comcast
service. That created a direct factual conflict. Rocket Mortgage had
electronic business records connecting the lead to Dobronski’s telephone
number. Dobronski had sworn testimony saying he never created the
transaction. That conflict is why the arbitration issue became much more
complicated than simply producing a copy of the Terms of Use.
Rocket Mortgage
Points to a Second Inquiry
Rocket Mortgage also produced evidence concerning another lead dated
September 29, 2025. According to TCPAWorld, the second
inquiry allegedly contained:
- The same name
- The same telephone number
- The same state
- A different IP address
Rocket’s analyst reportedly testified that its systems connected the
two submissions to the same individual. The second lead
therefore provided Rocket with additional evidence supporting its
position. But it still did not eliminate Dobronski’s denial. The
fundamental question remained whether Dobronski actually submitted
either inquiry or authorized someone else to do so.
The
Real Issue: Was an Arbitration Agreement Ever Formed?
This distinction became critical before the court. The issue was not
initially whether the arbitration provision was enforceable. The court
first had to determine whether an arbitration agreement existed between
the parties at all. Magistrate Judge Altman treated Dobronski’s sworn
declaration as competent evidence and found that a factual dispute
existed concerning formation. The magistrate judge recommended denying
Rocket Mortgage’s motion to compel arbitration without
prejudice, concluding that Rocket had not established that
Dobronski himself entered into the alleged agreement. That did not
permanently close the door on arbitration. Instead, it meant the
formation issue had to be addressed first.
Rocket Mortgage
Wins on the Procedural Question
Rocket Mortgage challenged the proposed procedure. Judge F.
Kay Behm sustained Rocket’s objection and determined that the
court needed to resolve the formation issue before moving forward on
other questions. The reason was Section 4 of the Federal
Arbitration Act. When the making of an arbitration agreement is
disputed, the court must determine whether the agreement was actually
made. The TCPAWorld discussion references Sixth Circuit decisions
including Southard v. Newcomb Oil Co. and
Boykin v. Family Dollar Stores of Michigan, LLC in
explaining this requirement. The practical effect was significant. The
court was not going to assume that the arbitration agreement applied
simply because Rocket possessed a lead record containing arbitration
language. Rocket first needed to address whether Dobronski actually
entered into the transaction.
The TCPA Case Is Now on Hold
Following Judge Behm’s ruling:
- 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
proceeds. - The parties were directed toward a summary trial concerning
formation of the alleged arbitration agreement.
So the immediate issue is extremely narrow:
Did Dobronski, or someone acting on his behalf, submit the
Rocket Mortgage form?
That answer could determine whether the underlying TCPA claims remain
in federal court or eventually proceed through arbitration.
Why the IP
Address Is Not the End of the Story
The disputed IP evidence is one of the most interesting parts of the
Rocket Mortgage TCPA lawsuit. An IP address can
identify a network connection. It does not necessarily identify the
person who used that connection. Rocket Mortgage has an IP address
associated with the alleged submission. Dobronski has challenged the
significance of that information by pointing to evidence connecting the
address to a Comcast connection at a Humane Society location in Ann
Arbor. He denies having a connection to that location or using Comcast.
That leaves a critical evidentiary gap: An IP address may show
where a connection originated, but who actually completed the mortgage
form? TCPAWorld describes IP geolocation as “soft
evidence” and emphasizes the potential importance of preserving
additional digital evidence in online lead disputes.
What Could
Give Rocket Mortgage Stronger Evidence?
The case demonstrates why companies defending TCPA claims may need
more than a simple lead record. TCPAWorld identifies evidence such
as:
- Device fingerprints
- Session recordings
- TrustedForm certificates
- Jornaya records
- Precise timestamps
- Other technical information connecting an individual to the online
transaction
The distinction is important. A lead record may establish that a
telephone number was entered into a form. It does not necessarily
establish who entered it. For an arbitration dispute,
the defendant may ultimately need to establish who:
- Entered the information
- Clicked “Confirm & continue”
- Accepted the Terms
- Provided consent
- Agreed to arbitration
Dobronski’s
Sworn Denial Has Legal Significance
The case also highlights why a sworn denial can matter in an
arbitration dispute. TCPAWorld references Bazemore v. Papa
John’s USA, Inc., 74 F.4th 795 (6th Cir. 2023) when discussing
sworn evidence challenging contract formation. A sworn denial does not
automatically defeat arbitration. But when a plaintiff competently
denies entering into an agreement, the defendant may need additional
evidence demonstrating that the agreement was actually formed. That is
the distinction at the heart of the Dobronski case. Rocket Mortgage has
records. Dobronski disputes whether those records reflect an online
transaction he personally made. The court therefore needs to determine
what the evidence establishes.
Discovery Adds
Another Layer to the Dispute
The parties have also disagreed about discovery. According to
TCPAWorld, Dobronski attempted through his briefing to limit Rocket
Mortgage’s discovery into his online activity while seeking broader
discovery from Rocket. The court rejected that approach. Issues included
the lack of a demonstrated Rule 26(f) conference,
procedural problems, and arguments that had not been properly presented.
The court instructed the parties to confer in good
faith and attempt to resolve straightforward discovery issues
before seeking judicial intervention. That matters because the court has
now narrowed the litigation around the formation question.
Rocket
Mortgage Has Not Lost the Arbitration Argument
The denial of Rocket Mortgage’s motion to compel arbitration should
not be confused with a permanent rejection of arbitration. The motion
was denied without prejudice. The court did not
determine that the arbitration provision could never apply to Dobronski.
Instead, it determined that the formation question must be answered
first. That gives Rocket Mortgage an opportunity to develop additional
evidence during targeted discovery. If the company can establish that
Dobronski submitted the form or authorized someone else to submit it,
Rocket may be able to renew its arbitration position. That makes the
case particularly relevant to Rocket Mortgage
arbitration and other TCPA cases involving online leads.
Lessons for
Companies Defending TCPA Claims
The dispute highlights several practical issues for TCPA
defendants.
Preserve the Entire
Online Transaction
A basic CRM record may not be enough when the consumer denies
submitting the lead.
Don’t Depend Only on IP
Evidence
An IP address can identify a connection without proving the identity
of the person using it.
Preserve Consent and
Arbitration Evidence
Companies should preserve the exact Terms, disclosures, consent
language, and submission process associated with the alleged
transaction.
Prove Contract Formation
Before enforcing an arbitration provision, the defendant may need to
establish that the plaintiff actually agreed to it.
Expect Discovery
When Formation Is Disputed
A genuine dispute over contract formation can require targeted
discovery and potentially a factual determination before arbitration can
proceed.
What the Case Means for
TCPA Plaintiffs
The same case carries lessons for plaintiffs challenging TCPA
arbitration agreements. A simple denial may not end the dispute
if the defendant possesses extensive digital evidence. That evidence
could include:
- Lead records
- Telephone numbers
- IP addresses
- Timestamps
- Multiple submissions
- Device information
- Session records
- Consent records
However, where a plaintiff genuinely did not submit an online lead, a
competent sworn declaration can place the formation of the alleged
agreement directly at issue. Ultimately, the evidence has to answer the
question of who actually participated in the transaction.
Why
This Case Matters Beyond Dobronski and Rocket Mortgage
The implications of Dobronski v. Rocket Mortgage
extend beyond this particular lawsuit. Online lead generation is
increasingly important in TCPA litigation because companies may use
these forms to establish:
- Consumer interest
- Telephone numbers
- Marketing consent
- Authorization for calls and texts
- Acceptance of Terms of Use
- Arbitration agreements
But an electronic record does not automatically establish the
identity of the person who created it. That is the central lesson
emerging from this case. The important questions are: Who
submitted the information? Who clicked the
button? Who accepted the Terms? Who
gave consent? Who agreed to arbitration? The
answers can determine whether a TCPA plaintiff gets to pursue a case in
federal court or must instead proceed through arbitration.
The
Bottom Line: Rocket Mortgage Still Has Something to Prove
At this stage, the dispute comes down to competing evidence. Rocket
Mortgage says its records connect Dobronski’s telephone number to an
online mortgage inquiry. Dobronski says he never submitted the inquiry.
The August lead allegedly used “Testq Testing,”
involved a Michigan property, requested a $250,000 purchase
loan, and was connected to the disputed IP address. Rocket also
identified a September inquiry with matching information. Dobronski
disputes the connection. The court has therefore ordered the parties to
focus on the formation issue before the underlying TCPA claims move
forward. The result is a case that is about much more than whether
Rocket Mortgage received an online lead. It is about whether the company
can prove who actually created that lead and agreed to its
Terms.
Final Takeaway
The Mark Dobronski Rocket Mortgage case presents a
straightforward legal problem with potentially significant consequences.
Dobronski alleges that Rocket Mortgage made repeated calls to his cell
phone and continued contacting him after he allegedly asked the company
to stop. Rocket Mortgage says its records show that an online mortgage
inquiry was submitted using Dobronski’s telephone number. That inquiry
allegedly contained marketing consent and a TCPA arbitration
agreement. Dobronski says he never submitted the form. His
sworn declaration created a factual dispute over whether the agreement
was ever formed. The federal court therefore did not immediately compel
arbitration. Instead, it placed the case on hold while the parties
conduct targeted discovery concerning formation. For companies defending
TCPA claims, the lesson is clear: A lead record can show that
information was submitted, but proving who submitted it is another
matter. For plaintiffs, the case demonstrates that a genuine
dispute over contract formation can prevent immediate arbitration. And
for anyone tracking Mark Dobronski, Rocket Mortgage, TCPA
arbitration, and online lead litigation, the next stage of this
case could determine whether the underlying claims remain in federal
court or ultimately move to arbitration. The question is no longer
simply whether Rocket Mortgage has an arbitration clause. The question
is whether it can prove that Mark Dobronski actually agreed to
it.
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 for informational and commentary purposes
only. Statements attributed to the parties, attorneys,
witnesses, or TCPAWorld are presented as allegations, arguments,
testimony, or commentary, not necessarily as established facts. The
central issue described here, whether Dobronski or someone
acting for him submitted the Rocket Mortgage lead, remained
subject to further proceedings at the time of the reported decision.
