A dispute between Mark Dobronski and Rocket Mortgage, LLC has developed into a legal fight over something more fundamental than whether certain calls violated the TCPA.
Before the court can determine whether Rocket Mortgage is liable for the alleged communications, it may first have to answer a threshold question:
Did Dobronski actually submit the online mortgage lead that Rocket Mortgage says created an arbitration agreement?
Rocket Mortgage maintains that its records connect Dobronski’s telephone number to an online mortgage inquiry.
Dobronski denies submitting the inquiry.
That disagreement has become central because the online form allegedly contained language providing both marketing consent and an agreement to arbitrate TCPA claims.
If Dobronski submitted the form, Rocket Mortgage had an argument that he agreed to arbitration.
If he did not, the entire arbitration theory becomes much more difficult to establish.
The dispute is Dobronski v. Rocket Mortgage, LLC, No. 25-12798, 2026 WL 2296669 (E.D. Mich. Aug. 10, 2026), which was discussed by TCPAWorld in an article published August 11, 2026.
The case provides an interesting examination of TCPA litigation, online lead generation, arbitration agreements, digital evidence, and the Federal Arbitration Act.
How the Rocket Mortgage TCPA Dispute Started
The underlying allegations involve a series of calls to Dobronski’s cell phone.
According to the TCPAWorld account, Dobronski alleged that he received approximately 20 calls from the same number between August 11 and August 19, 2025.
The calls allegedly followed a similar pattern.
His phone would ring once, and the call would disconnect before he could answer.
Dobronski eventually returned the call.
He says he reached an automated interactive voice response system identifying Rocket. After pressing 1, he was reportedly connected with an individual identified as Blake.
According to Dobronski, Blake explained that Rocket was trying to reach 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.
Despite that alleged request, Dobronski says another call arrived in September 2025.
A text message from a Rocket loan officer allegedly followed.
Those communications form the basis of the TCPA dispute.
But Rocket Mortgage offered another explanation for the calls.
Rocket Mortgage’s Version: An Online Mortgage Inquiry
Rocket Mortgage relied on its internal records and submitted a declaration from a Principal Data Analyst.
According to the declaration described by TCPAWorld, a user visited a Rocket website on or around August 11, 2025 using IP address 173.167.231.105.
That user allegedly submitted a mortgage inquiry.
The lead allegedly included:
- The name “Test Testing”
- Dobronski’s telephone number
- A Michigan property
- A purchase-loan request
- A requested loan amount of $250,000
- A click on “Confirm & continue”
Rocket’s position was therefore that its communications were connected to an online mortgage inquiry rather than being unexplained unsolicited contacts.
The company’s records allegedly connected Dobronski’s telephone number with the lead.
But Rocket’s evidence contained another feature that became particularly important.
The online submission allegedly included an arbitration agreement.
The Arbitration Language Could Change the Entire Case
The arbitration issue is important because the disclosure allegedly appeared directly above the “Confirm & continue” button.
According to the court record as summarized by TCPAWorld, clicking the button indicated agreement to the website’s Terms of Use.
Those Terms allegedly contained an agreement to arbitrate TCPA claims.
The disclosure also allegedly included consent to receive marketing calls and text messages, including communications to numbers appearing on a do-not-call list.
The Terms reportedly covered TCPA and similar state-law claims and were governed by the Federal Arbitration Act.
That potentially gave Rocket Mortgage a significant procedural defense.
If Dobronski personally completed the form, Rocket could argue that he accepted the Terms and agreed to resolve covered claims through arbitration.
But there was an obvious obstacle.
Dobronski says he never completed the form.
Dobronski’s Sworn Denial Creates a Formation Dispute
Dobronski submitted a sworn declaration disputing Rocket Mortgage’s account.
According to TCPAWorld, he denied:
- Personally submitting the mortgage inquiry
- Authorizing anyone to submit it for him
- Using the disputed IP address
- Using the name “Test Testing”
- Having a residence in Ann Arbor
- Having Comcast internet service
He also challenged the significance of Rocket’s IP evidence.
Dobronski reportedly pointed to public IP lookup information associating the August IP address with a Comcast connection at the Humane Society in Ann Arbor.
His position was that he had neither an Ann Arbor residence nor Comcast internet service.
That created two competing versions of events.
Rocket Mortgage had its electronic business records and lead information.
Dobronski had sworn testimony denying that he created the online transaction.
And that factual conflict became critical because an arbitration agreement cannot simply be enforced against someone who never agreed to it.
Rocket Mortgage Points to a Second Inquiry
Rocket Mortgage did not rely exclusively on the August lead.
According to TCPAWorld, the company also produced evidence concerning another inquiry dated September 29, 2025.
The second lead 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.
From Rocket’s perspective, the second inquiry strengthened the argument that the information was associated with Dobronski.
But it did not eliminate his sworn denial.
The fundamental question remained:
Can Rocket Mortgage establish that Dobronski himself, or someone authorized to act for him, actually submitted the online form?
The Court’s First Question Was Not Whether Arbitration Was Enforceable
The arbitration dispute became particularly significant because the court was not initially deciding whether the arbitration clause itself was enforceable.
The first question was even more basic:
Was an arbitration agreement ever formed between Dobronski and Rocket Mortgage?
Magistrate Judge Altman treated Dobronski’s sworn declaration as competent evidence and determined that a factual dispute existed concerning formation.
The magistrate judge concluded that Rocket had not established that Dobronski himself entered into the alleged arbitration agreement and recommended denying the motion to compel arbitration without prejudice.
That did not permanently eliminate Rocket’s arbitration argument.
Instead, it meant the formation dispute needed to be resolved.
Rocket Mortgage Successfully Challenges the Procedure
Rocket Mortgage objected to the proposed approach.
Judge F. Kay Behm sustained Rocket’s objection and determined that the court first needed to address whether the arbitration agreement had actually been formed.
The reason was Section 4 of the Federal Arbitration Act.
When a party disputes whether an arbitration agreement was made, the FAA requires the court to determine that issue.
The TCPAWorld discussion cites Sixth Circuit authority including Southard v. Newcomb Oil Co. and Boykin v. Family Dollar Stores of Michigan, LLC when explaining why formation must be addressed before other issues proceed.
The Boykin decision is particularly relevant because, as described by TCPAWorld, the existence of an arbitration agreement should be resolved before the court moves into other questions, including the underlying merits.
That procedural determination changed the direction of the litigation.
The Case Is Now About Formation Before Merits
Following Judge Behm’s ruling, several things happened.
- 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.
That leaves the case centered on a very specific factual question:
Did Dobronski, or someone acting on his behalf, submit the Rocket Mortgage form?
The answer could determine what happens to the broader TCPA lawsuit.
If Rocket Proves Dobronski Submitted the Form, Arbitration Could Follow
The consequences of proving formation could be significant.
According to TCPAWorld, Dobronski has not primarily challenged the arbitration clause by arguing that it is inherently unenforceable or that it fails to cover his claims.
His central argument is different.
He says he never entered into the transaction.
That makes formation the critical issue.
If Rocket Mortgage ultimately establishes that Dobronski personally submitted the form, or that an authorized person submitted it for him, the arbitration provision could potentially become enforceable, subject to the court’s ultimate findings.
The TCPA claims could then proceed toward arbitration instead of federal court litigation.
The IP Address Does Not Necessarily Identify the Person
The disputed IP address is one of the more interesting aspects of the Rocket Mortgage TCPA lawsuit.
An IP address can provide information about the network connection used during an online transaction.
But an IP address does not necessarily identify the individual person who was sitting behind the device.
That distinction is particularly important here.
Rocket Mortgage had an IP address associated with the alleged mortgage submission.
Dobronski responded with information suggesting that the IP address was associated with a Comcast connection at a Humane Society location in Ann Arbor.
He simultaneously denied having any connection to the location or Comcast service.
The result was an evidentiary dispute.
TCPAWorld characterizes IP geolocation as “soft evidence” and discusses the importance of preserving additional digital evidence when online lead records are expected to establish consent or contract formation.
What Stronger Digital Evidence Could Look Like
The Dobronski case demonstrates why companies defending TCPA online lead cases may need to preserve more than a basic CRM record.
TCPAWorld identifies several categories of potentially useful evidence, including:
- Device fingerprints
- Session recordings
- TrustedForm certificates
- Jornaya records
- Precise timestamps
- Other technical information capable of connecting an actual person to the online transaction
There is an important difference between proving:
A telephone number was entered into an online form.
And proving:
Who actually entered the telephone number and accepted the Terms?
The second question is what Rocket Mortgage now needs to address.
Why Dobronski’s Sworn Statement Matters
The case also illustrates the importance of sworn testimony when contract formation is disputed.
TCPAWorld discusses Bazemore v. Papa John’s USA, Inc., 74 F.4th 795 (6th Cir. 2023) in connection with sworn testimony challenging the formation of an arbitration agreement.
A defendant should therefore not necessarily assume that its business records automatically resolve the dispute.
If a plaintiff provides competent sworn evidence stating:
“I never submitted this form,”
the court may need to examine the factual dispute before compelling arbitration.
That does not mean a sworn denial automatically defeats an arbitration motion.
Rather, it means the defendant may need sufficient evidence to establish that the agreement was actually formed.
Discovery Becomes Another Battleground
The parties also disagreed over discovery.
According to TCPAWorld, Dobronski attempted in his response briefing to restrict Rocket’s discovery into his online activity while seeking broader discovery from Rocket.
The court rejected that approach.
The court identified issues including the absence of a demonstrated Rule 26(f) conference, procedural problems, and arguments that had not been properly presented.
The parties were instructed to confer in good faith and attempt to resolve straightforward discovery issues before bringing them to the court.
Although this dispute is secondary to the arbitration issue, it demonstrates the importance of procedural compliance when litigation has been narrowed to a specific factual question.
Rocket Mortgage Has Not Yet Won Arbitration, But It Has Gained Ground
It would be easy to look at the denial of Rocket Mortgage’s motion to compel arbitration and treat it as a straightforward loss.
That would oversimplify the ruling.
The court did not permanently reject Rocket’s arbitration theory.
Instead, the court put the merits on hold and directed the parties to focus on whether the agreement was actually formed.
Rocket therefore has another opportunity to establish that Dobronski entered into the alleged agreement.
The company’s motions remain capable of being renewed after the formation issue is resolved.
That makes the case particularly significant for Rocket Mortgage arbitration and broader TCPA defense strategy.
A defendant can lose an immediate motion to compel arbitration while still securing a meaningful procedural advantage.
Lessons for Companies Defending TCPA Online Lead Cases
The dispute offers several practical lessons for companies facing TCPA claims based on online leads.
1. Preserve More Than a CRM Entry
A basic lead record may not be enough if the consumer denies ever submitting the form.
Technical evidence connecting the user to the transaction can become critical.
2. Don’t Treat an IP Address as Definitive Identification
An IP address identifies a network connection, not necessarily a particular person.
Additional evidence can help establish who actually participated in the transaction.
3. Preserve the Consent Process
Where marketing consent or arbitration language is presented near a submission button, defendants should preserve evidence showing what the user allegedly saw and accepted.
4. Prove Formation Before Assuming Enforcement
An arbitration provision is useful only if the defendant can establish that the plaintiff actually agreed to it.
5. Arbitration Does Not Always Happen Immediately
When formation is disputed, targeted discovery and potentially a factual determination may have to occur before arbitration can proceed.
The Plaintiff’s Perspective Is Different
The case also presents important considerations for TCPA plaintiffs.
A plaintiff disputing arbitration should understand that simply denying an online transaction does not automatically resolve the issue.
A defendant may possess:
- Lead records
- Telephone numbers
- IP addresses
- Timestamps
- Multiple submissions
- Device information
- Session data
- Consent records
The stronger the defendant’s technical evidence, the more difficult a bare denial may become.
At the same time, the Dobronski dispute shows why a plaintiff who genuinely did not submit a disputed lead may need competent evidence supporting that position.
Ultimately, the formation issue turns on evidence.
Why the Dobronski v. Rocket Mortgage Case Matters
The importance of this dispute goes beyond Mark Dobronski and Rocket Mortgage.
Online lead generation has become an important source of evidence in TCPA litigation.
Companies can use online forms to establish:
- Consumer interest
- Consent
- Telephone numbers
- Marketing authorization
- Arbitration agreements
- Terms of Use acceptance
But the existence of an electronic record does not necessarily answer every legal question.
The most important question may be identity.
Who entered the information?
Who clicked “Confirm & continue”?
Who accepted the Terms?
Who agreed to arbitration?
Those questions become especially important when the consumer denies ever participating in the transaction.
The Case Now Comes Down to One Question
Strip away the motions, declarations, IP addresses, arbitration clauses, and procedural arguments, and the dispute comes down to one central issue.
Did Mark Dobronski actually submit the Rocket Mortgage form?
Rocket Mortgage says its records connect a user to Dobronski’s telephone number.
Dobronski says he did not submit the lead.
The August inquiry allegedly used the name “Testq Testing”, involved a Michigan property, requested a $250,000 purchase loan, and was connected to the disputed IP address.
A second September inquiry allegedly contained matching identifying information.
Dobronski disputes the connection.
The court has therefore directed the parties toward targeted discovery before the case can move forward.
Until that formation question is resolved, the parties cannot simply bypass it and proceed directly to the underlying TCPA claims.
Final Takeaway
The Mark Dobronski Rocket Mortgage dispute is ultimately about whether the evidence can establish that an online contract was actually created.
Dobronski alleges that Rocket repeatedly called his cell phone and continued contacting him after he allegedly asked the company to stop.
Rocket Mortgage says its records show an online mortgage inquiry associated with Dobronski’s telephone number.
That inquiry allegedly contained both consent language and an arbitration agreement covering TCPA-related claims.
Dobronski says he never submitted it.
His sworn declaration was sufficient to create a factual dispute over whether the arbitration agreement was ever formed.
As a result, the federal court did not simply send the Rocket Mortgage TCPA lawsuit to arbitration.
Instead, the merits were placed on hold while the parties focus on targeted discovery and the factual question of whether the alleged arbitration agreement was actually formed.
For TCPA defendants, the case delivers a straightforward lesson:
Having a lead record is not necessarily the same thing as proving who created it.
For TCPA plaintiffs, the case demonstrates that a sworn denial can place contract formation directly in dispute, but the ultimate outcome depends on the evidence.
And for anyone following Mark Dobronski, Rocket Mortgage, TCPA arbitration, and online lead litigation, the next stage of this case may prove more consequential than the initial arbitration motion.
The question is no longer simply whether Rocket Mortgage has an arbitration agreement.
The real question is whether Rocket Mortgage can prove that 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 provided 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 appropriate. They should not automatically be treated as established facts.
The existence of a lawsuit, motion, declaration, discovery dispute, arbitration request, or court ruling does not establish that every allegation made by either party is true.
The descriptions of the alleged mortgage inquiries, IP address, name “Test Testing,” telephone number, property information, loan amount, consent language, and arbitration provision are based on the TCPAWorld report and the court proceedings described therein. This article does not independently establish who submitted the disputed forms.
At the time of the reported decision, the central factual question remained unresolved: whether Dobronski, or someone acting on his behalf, submitted the Rocket Mortgage inquiry.
Nothing in this article should be construed as a determination that any individual or company engaged in unlawful conduct unless and to the extent such conduct has been established by a competent court.
