$10 Million Lesson: Informational Robocalls Can Still Trigger TCPA Class Actions

Even well-intentioned customer outreach can still trigger expensive exposure under the Telephone Consumer Protection Act (TCPA), particularly when prerecorded calls are involved.

That risk is illustrated by the recent $9.95 million TCPA class settlement in Jackson v. Gen. Digit. Inc., No. CV-25-00535-PHX-MTL, 2026 U.S. Dist. LEXIS 15471 (D. Ariz. Jan. 28, 2026). Gen Digital, the parent company of LifeLock and Norton, resolved claims that it used artificial or prerecorded voice calls to reach cell phone numbers not assigned to its customers.

According to the court’s preliminary approval of the settlement, the calls were placed to approximately 300,000 cell phone numbers that had been disconnected and later reassigned to new subscribers, causing the calls to reach unintended recipients.

The content of the calls makes the case especially interesting. They were not marketing messages but rather calls related to LifeLock or Norton accounts that were meant to notify customers about potential identity theft events, a form of outreach many businesses assume presents limited TCPA risk.

That assumption proved incorrect. Plaintiffs alleged the calls violated the TCPA because Gen Digital used a prerecorded voice to call cell phones without the required consent once the numbers had been reassigned. In short, the method of communication, not the message itself, drove the liability risk.

The case reinforces that prerecorded calls remain among the most legally risky communication tools under the TCPA. They are easy to prove and particularly problematic when used at scale, even when the calls are informational rather than sales-related.

One of the most effective ways to reduce this risk is to avoid prerecorded calls altogether, especially for informational messages. Where possible, text messaging is a safer alternative. Texts generally carry lower litigation risk and avoid many of the proof issues that drive TCPA class actions.

And don’t forget about the FCC’s Reassigned Numbers Database—scrubbing calling lists is also critical to reducing exposure from reassigned or wrong numbers.