The Mark Dobronski Rocket Mortgage dispute has moved beyond the usual arguments found in TCPA litigation.
The central question is now remarkably specific:
Did Mark Dobronski actually submit the online mortgage lead that Rocket Mortgage says created an agreement to arbitrate his TCPA claims?
Rocket Mortgage says its records show that an online inquiry was submitted using Dobronski’s telephone number.
Dobronski says he never submitted it.
That disagreement is significant because the alleged online submission reportedly contained not only marketing-consent language but also an arbitration agreement covering TCPA claims.
If Dobronski submitted the form, Rocket Mortgage may have a contractual basis for requiring arbitration.
If he did not, Rocket must first establish how an arbitration agreement could have been formed between the parties.
The dispute is Dobronski v. Rocket Mortgage, LLC, No. 25-12798, 2026 WL 2296669 (E.D. Mich. Aug. 10, 2026), which was reported by TCPAWorld on August 11, 2026.
The Alleged Calls Behind the Lawsuit
The underlying case began with allegations concerning repeated calls to Dobronski’s cellular telephone.
According to the TCPAWorld account, Dobronski alleged that he received approximately 20 calls between August 11 and August 19, 2025 from the same number.
He claimed the calls typically rang once and disconnected before he could answer.
After receiving the calls, Dobronski reportedly called the number back.
He allegedly reached an automated system identifying Rocket, selected an option, and was connected with an agent identified as Blake.
According to Dobronski, Blake explained that Rocket was attempting to reach him regarding refinancing.
Dobronski allegedly told the representative that his number was on the Do Not Call Registry, that he was not interested, and that Rocket should stop contacting him.
The allegations did not end there.
Dobronski reportedly received another call in September 2025, followed by a text message from a Rocket loan officer.
Those alleged communications became the basis for his TCPA lawsuit against Rocket Mortgage.
But Rocket Mortgage says there was a reason its systems were contacting the number.
Rocket Mortgage’s Online Lead Evidence
Rocket Mortgage relied on its internal records and a declaration from a Principal Data Analyst.
According to the evidence described by TCPAWorld, an individual visited a Rocket website on or around August 11, 2025 and submitted a mortgage inquiry.
The submission was allegedly associated with IP address 173.167.231.105.
The lead reportedly 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 Mortgage’s position was that the communications were connected to this online mortgage inquiry.
But the online lead allegedly did more than provide Rocket with a telephone number.
It allegedly created a contractual issue.
The Terms Allegedly Included TCPA Arbitration
According to the TCPAWorld report, the disclosure immediately above the “Confirm & continue” button stated that clicking the button constituted agreement to the website’s Terms of Use.
Those Terms allegedly included an agreement requiring arbitration of TCPA claims.
The disclosure also reportedly included consent language concerning marketing calls and text messages, including communications to numbers appearing on do-not-call lists.
The Terms allegedly covered TCPA and related state-law claims and operated under the Federal Arbitration Act.
That potentially gives Rocket Mortgage a powerful procedural defense.
But there is a major condition attached to that defense.
Rocket must establish that Dobronski actually agreed to the Terms.
Dobronski’s Position: I Never Filled Out the Form
Dobronski disputes Rocket Mortgage’s account at its foundation.
He submitted a sworn declaration denying that he submitted the mortgage inquiry.
According to TCPAWorld, he also denied authorizing another person to submit the inquiry for him.
His declaration reportedly denied:
- Using the disputed IP address
- Using the name “Test Testing”
- Having an Ann Arbor residence
- Having Comcast internet service
Dobronski also challenged Rocket’s interpretation of the IP evidence.
He reportedly identified 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 internet service.
That left the court with competing evidence.
Rocket Mortgage had electronic records indicating an online submission.
Dobronski had sworn testimony denying that he made the submission.
A Second Lead Becomes Part of Rocket’s Evidence
Rocket Mortgage also pointed to another online inquiry dated September 29, 2025.
According to TCPAWorld, that second lead allegedly contained the same name, telephone number, and state, although it came from a different IP address.
Rocket’s analyst reportedly testified that its systems connected both submissions to the same individual.
From Rocket Mortgage’s perspective, that additional record supported the argument that the online activity was associated with Dobronski.
But the evidence still did not conclusively answer the question of who actually submitted the forms.
That distinction became the heart of the arbitration dispute.
The Court Had to Address Formation First
Rocket Mortgage sought to compel arbitration.
Dobronski argued that the request should fail because he never entered into the alleged online agreement.
This created a threshold legal issue:
Was an arbitration agreement ever formed?
That question comes before asking whether the agreement should ultimately be enforced.
Magistrate Judge Altman treated Dobronski’s sworn declaration as competent evidence and concluded that there was a factual dispute concerning formation.
The magistrate judge therefore recommended denying Rocket Mortgage’s motion to compel arbitration without prejudice.
The ruling did not permanently eliminate Rocket’s arbitration argument.
Instead, it meant the company had not yet established the existence of the agreement strongly enough to compel arbitration at that stage.
Judge Behm Puts the Formation Question Front and Center
Rocket Mortgage objected to the proposed handling of the dispute.
Judge F. Kay Behm sustained Rocket’s objection and determined that the court needed to resolve the formation issue.
The ruling relied on Section 4 of the Federal Arbitration Act, which addresses disputes over whether an arbitration agreement was actually made.
The TCPAWorld report discusses Sixth Circuit precedent including Southard v. Newcomb Oil Co. and Boykin v. Family Dollar Stores of Michigan, LLC.
The significance is straightforward.
A defendant cannot necessarily jump directly from:
“Our website contains an arbitration clause”
to:
“The plaintiff must arbitrate.”
The defendant may first need to establish:
“The plaintiff actually entered into the agreement containing that clause.”
The TCPA Case Is Now Paused
The court’s decision resulted in several procedural changes.
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 also overruled without prejudice.
The case was placed in abeyance while the parties conduct targeted discovery.
The parties are also being directed toward a summary trial concerning whether the arbitration agreement was actually formed.
So the case is temporarily focused on one threshold issue rather than the ultimate merits of the TCPA claims.
Why the IP Address Matters
The disputed IP address could become an important piece of evidence.
Rocket Mortgage uses the IP information to support its contention that the online submission occurred.
Dobronski disputes the connection.
But an IP address does not necessarily identify the individual who was sitting behind the device.
It can identify the network connection from which activity occurred without establishing exactly who performed the activity.
TCPAWorld characterizes IP geolocation as “soft evidence” and emphasizes the value of preserving more detailed digital evidence when online leads are later used in litigation.
That distinction is especially important here because Rocket is not merely using the lead to explain a telephone call.
It is using the lead to establish a potential arbitration agreement.
What Additional Evidence Could Matter?
The dispute highlights the potential importance of comprehensive digital records.
Relevant evidence could include:
- Device fingerprints
- Session recordings
- TrustedForm certificates
- Jornaya records
- Precise timestamps
- Browser information
- Device information
- Other technical evidence linking the user to the online session
A basic database entry can demonstrate that certain information was entered.
More detailed technical evidence can potentially demonstrate who interacted with the website.
That distinction may ultimately determine whether Rocket Mortgage can enforce its alleged arbitration provision.
Why Dobronski’s Sworn Declaration Matters
Dobronski’s declaration does not establish by itself that he did not submit the lead.
However, it creates a direct factual dispute over the alleged transaction.
TCPAWorld cites Bazemore v. Papa John’s USA, Inc., 74 F.4th 795 (6th Cir. 2023) when discussing sworn evidence disputing contract formation.
The practical point is important.
A defendant relying on an online agreement may need more than a copy of the agreement itself when the plaintiff swears that they never entered into it.
The defendant may have to produce evidence showing that the particular plaintiff actually participated in the transaction.
Discovery Disputes Enter the Picture
The parties have also disagreed about the scope and handling of discovery.
According to TCPAWorld, Dobronski attempted to limit Rocket Mortgage’s discovery concerning his online activity while seeking broader discovery from Rocket.
The court rejected that approach and addressed procedural issues involving the Rule 26(f) conference and arguments that had not been properly presented.
The court instructed the parties to confer in good faith and attempt to resolve ordinary discovery disputes before asking the court to intervene.
Given the court’s focus on formation, those discovery proceedings could become particularly important.
Rocket Mortgage Still Has an Opportunity
The current ruling should not be characterized as a final defeat for Rocket Mortgage.
The motion to compel arbitration was denied without prejudice.
That leaves Rocket with an opportunity to develop additional evidence.
If Rocket can establish that Dobronski submitted the online form, or that an authorized person submitted it on his behalf, the alleged arbitration provision could potentially be enforced.
The question is therefore not whether Rocket has permanently lost arbitration.
The question is whether Rocket can prove the agreement existed.
Lessons for TCPA Defendants
The dispute provides several practical lessons for companies defending TCPA cases involving online leads.
Preserve the Complete Lead History
A simple CRM record may not be enough if the plaintiff later denies submitting the lead.
Preserve Technical Information
IP addresses can help, but additional information such as device fingerprints, timestamps, and session records can potentially provide a stronger evidentiary connection.
Preserve the Exact Consent Screen
When arbitration depends upon a particular disclosure presented immediately before a button is clicked, preserving the precise version of the form and Terms can become critical.
Prove Agreement Formation
An arbitration clause cannot necessarily be enforced simply because it exists somewhere in a website’s Terms.
The defendant may first have to show that the plaintiff actually accepted it.
Lessons for TCPA Plaintiffs
The case also provides an important lesson for plaintiffs.
A plaintiff disputing an online lead should understand that a simple denial may lead to additional discovery.
A defendant could possess multiple lead records, IP information, timestamps, device data, session recordings, or other evidence that may support its position.
At the same time, a plaintiff’s competent sworn testimony can place contract formation directly at issue when the plaintiff genuinely disputes participating in the transaction.
The outcome will ultimately depend on the evidence.
The Broader TCPA Arbitration Issue
The Mark Dobronski arbitration dispute illustrates a broader problem arising in modern TCPA litigation.
Online lead forms can simultaneously serve several functions.
They can document a consumer inquiry.
They can collect a telephone number.
They can record marketing consent.
They can incorporate Terms of Use.
And they can potentially create an arbitration agreement.
But all of those functions depend upon one fundamental premise:
The person involved actually completed the transaction.
When that premise is disputed, the digital evidence becomes critical.
Who Actually Submitted the Rocket Mortgage Lead?
The dispute ultimately comes down to a series of factual questions.
Someone allegedly accessed Rocket Mortgage’s website.
Someone allegedly entered Dobronski’s telephone number.
Someone allegedly entered mortgage information.
Someone allegedly clicked “Confirm & continue”.
But who was that person?
Rocket Mortgage says its records point to Dobronski.
Dobronski says they do not.
The court has therefore required the parties to investigate the formation issue before moving ahead with the arbitration question.
Final Takeaway
The Mark Dobronski Rocket Mortgage dispute is not simply another fight over unwanted calls.
It is a dispute over whether an online transaction occurred, who completed it, and whether that transaction created an enforceable TCPA arbitration agreement.
Dobronski alleges that Rocket Mortgage contacted his cellular telephone repeatedly and continued communicating with him after he allegedly requested that the contacts stop.
Rocket Mortgage points to an online mortgage inquiry that allegedly used Dobronski’s telephone number and incorporated Terms containing an arbitration provision.
Dobronski says he never submitted the inquiry.
That sworn denial created a factual dispute concerning whether an agreement was ever formed.
The court therefore did not immediately compel arbitration. Instead, the case has been placed on hold while targeted discovery addresses the formation issue and the parties prepare for further proceedings.
For Rocket Mortgage and other TCPA defendants, the lesson is significant:
A digital lead record may establish that an online submission exists, but it may not by itself establish who submitted it.
For TCPA plaintiffs, the case demonstrates that challenging an alleged online agreement can turn the litigation into an evidentiary battle over identity, digital records, and contract formation.
And for anyone following Mark Dobronski, Rocket Mortgage, TCPA litigation, online lead generation, and TCPA arbitration, the next phase of the case could determine whether the dispute remains before the federal court or ultimately moves to arbitration.
For now, the decisive question remains:
Can Rocket Mortgage prove that Mark Dobronski actually submitted the lead on which its arbitration defense depends?
Sources
Primary Source:[ TCPAWorld: “NO FORM, NO FORUM: Rocket Mortgage Must Prove Dobronski Filled Out the Lead Before It Gets Arbitration”](https://tcpaworld.com/2026/08/11/no-form-no-forum-rocket-mortgage-must-prove-dobronski-filled-out-the-lead-before-it-gets-arbitration/?utm_source=chatgpt.com), 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., Boykin v. Family Dollar Stores of Michigan, LLC, and Bazemore v. Papa John’s USA, Inc.
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. The court had not finally determined whether Dobronski submitted the disputed lead or entered into the alleged arbitration agreement.
