What TCPA and Litigator Scrub filtering through DNC.COM covers

TCPA and Litigator Scrub are not the same thing

Both filters are available through the DNC.COM integration in VICIdial, but they address different risks. The TCPA scrub identifies numbers that require prior written consent before being contacted with an autodialer under the Telephone Consumer Protection Act (TCPA). The Litigator Scrub identifies numbers associated with individuals who have filed or are known to pursue TCPA lawsuits.

Dialing a number that should have been caught by the TCPA scrub can result in a consent violation. Dialing a number that should have been caught by the Litigator Scrub can result in a lawsuit, even if you technically had consent. They protect against different failure modes.

How the TCPA scrub works

The TCPA places strict limits on calling mobile numbers using an automatic telephone dialing system (ATDS) without Express written consent. The TCPA scrub through DNC.COM cross-references your Lead list against a database of numbers where consent has not been established or documented.

VICIdial's DNC.COM integration includes a batch cellphone filtering component specifically for TCPA compliance. This runs during list filtering and flags or removes numbers that fall into the high-risk category before they ever enter your Campaign or Hopper.

How the Litigator Scrub works

The Litigator Scrub — also called DNC litigator filtering — cross-references your list against a database of phone numbers belonging to known TCPA plaintiffs and litigation-prone individuals. These are people who have sued telemarketers before and are likely to do so again.

A single TCPA lawsuit can cost tens of thousands of dollars. The Litigator Scrub is a low-cost filter that removes the numbers most likely to generate that exposure. For high-volume Predictive dialing operations, a Litigator Scrub before every list load is standard practice.

How these filters fit into the full DNC.COM filtering flow

flowchart TD
  A[Lead List Loaded] --> B[DNC.COM Scrubbing Utility]
  B --> C[State DNC Check]
  B --> D[Federal FTC DNC Check]
  B --> E[Internal DNC Check]
  B --> F[TCPA Scrub - cellphone consent check]
  B --> G[Litigator Scrub - known plaintiffs]
  C --> H{Match found?}
  D --> H
  E --> H
  F --> H
  G --> H
  H -- Yes --> I[Number removed or flagged]
  H -- No --> J[Number cleared for dialing]

All five filters — state State DNC list, federal FTC, Internal DNC, TCPA, and Litigator — run through the same DNC.COM web admin utility in VICIdial. You can apply any combination depending on your campaign type and jurisdiction. The inbound DID scrubbing option applies the same filters to incoming calls.

Which campaigns need which filters

• Outbound telemarketing to consumers: state + federal DNC + TCPA scrub at minimum
• High-volume Predictive dialing campaigns: add Litigator Scrub to reduce lawsuit risk
• Blended inbound/outbound operations: enable inbound DID scrubbing to flag DNC-listed callers on inbound lines

For a broader look at how DNC.COM integrates with VICIdial's filtering architecture, see what the DNC.COM integration adds to VICIdial filtering. For the full compliance framework, read the VICIdial compliance overview.

VICIfast configures DNC.COM integration as part of managed onboarding. See pricing to get started.