Caller ID used to be a nice-to-havelike a name tag at a conference. Helpful, polite, and occasionally ignored.
After Dobronski v. SelectQuote, a growing number of marketers are treating caller ID like a legal seatbelt:
you might not think about it until the moment you really, really need it.
The short version: courts have started letting consumers sue under the Telephone Consumer Protection Act (TCPA)
when telemarketing outreach fails to transmit required caller identification information under the FCC’s caller ID rule.
And yesdepending on the facts and the courtthis can extend beyond voice calls to marketing texts, too.
What happened in Dobronski v. SelectQuote (in plain English)
The dispute sits at the intersection of three things that love to argue: telemarketing, technology, and statutory interpretation.
The plaintiff alleged that telemarketing outreach did not comply with the FCC’s caller ID requirementsspecifically
47 C.F.R. § 64.1601(e), the rule that says telemarketers must transmit caller identification information, including
a number consumers can use to make a do-not-call request during regular business hours, and (when the telemarketer’s
carrier makes it available) the name of the telemarketer.
Historically, many businesses treated the caller ID rule like a “compliance best practice” rather than
a “someone can sue me for this” rule. Dobronski changed that vibe. In 2025, an Eastern District of Michigan decision
widely discussed as Dobronski v. SelectQuote Insurance Services concluded that § 64.1601(e) fits within the
TCPA’s privacy-focused subsection (47 U.S.C. § 227(c))and that matters because § 227(c)(5) provides a private right
of action for violations of regulations prescribed under § 227(c).
Translation: the argument isn’t “should courts invent a right to sue?” It’s “did Congress already create a right to sue
for this category of regulation?” Dobronski’s answer leaned toward “yes,” at least for § 64.1601(e), and that answer
is now echoing through other cases.
The caller ID rule: what it actually requires (and what it doesn’t)
Let’s ground this in the rule text, because caller ID litigation tends to thrive in the gap between what companies
think they’re sending and what consumers actually receive.
Rule #1: Telemarketers must transmit caller identification information
The FCC rule says any person or entity that engages in telemarketing must transmit caller identification information.
For this paragraph, caller ID must include either CPN (Calling Party Number) or ANI (Automatic Number Identification),
andwhen available by the telemarketer’s carrierthe name of the telemarketer.
Rule #2: You can show the seller’s name and number instead (if you do it right)
The rule includes a practical workaround: it is not a violation to substitute the name of the seller on whose behalf
the telemarketing call is placed and the seller’s customer service telephone number. That’s the “call center calling
on behalf of Brand X” concept, and it’s supposed to help consumers understand who is behind the call.
The catch is that the substitution must still function like a real identity. If the displayed number is a dead end,
or it can’t accept do-not-call requests during regular business hours, you’re wandering into lawsuit country while
wearing shoes made of banana peels.
Rule #3: The displayed number must allow do-not-call requests during regular business hours
This is the part businesses sometimes underestimate. The rule isn’t just “show a number.” It’s “show a number that
lets an individual make a do-not-call request during regular business hours.” In other words, your caller ID can’t be
a decorative phone numberlike a fake fireplace that looks cozy but doesn’t heat anything.
Rule #4: Telemarketers can’t block caller ID transmission
The regulation prohibits telemarketers from blocking the transmission of caller identification information.
If you’re doing outbound sales, the “anonymous” setting is not your friend.
A reality check: “We tried” may matterif you can prove it
Regulators have acknowledged that caller ID can be dropped somewhere between a call center and a consumer’s device,
even when the telemarketer arranged to transmit the correct information. That’s not a universal get-out-of-jail-free
cardbut it highlights why documentation, vendor controls, and technical testing matter. If your defense is “we did
everything available,” you’ll need receipts, not vibes.
Why Dobronski mattered: the private right of action debate
The TCPA is famously litigated, but not every rule connected to the TCPA is automatically enforceable by consumers.
The statute has specific private enforcement provisionsmost notably:
- 47 U.S.C. § 227(b)(3) for certain robocalls/ATDS/prerecorded voice violations, and
- 47 U.S.C. § 227(c)(5) for violations of regulations prescribed under the “privacy rights” subsection (Do Not Call and related protections).
For years, defendants argued that the caller ID rule (47 C.F.R. § 64.1601(e)) was not the kind of rule consumers could
enforce through § 227(c)(5). Some courts agreed, often reasoning that caller ID is more technical/procedural, or that
the FCC didn’t explicitly say “private lawsuits allowed.”
Dobronski pushed back with a different lens: focus on where the FCC got authority to promulgate § 64.1601(e).
If § 64.1601(e) lives under § 227(c), then § 227(c)(5)’s private right of action can apply. This line of reasoning
treats caller ID as a privacy-protection toolsomething that helps consumers identify callers, make complaints,
and enforce do-not-call preferences.
The practical result is less academic than it sounds: if courts continue to treat § 64.1601(e) as a § 227(c) regulation,
companies can face claims (including class claims) based on caller ID transmission failures, even when the calls or texts
were manually dialed and even when the content wasn’t a prerecorded robocall.
Caller ID rules and marketing texts: the “wait, this covers SMS?” moment
One reason this topic is catching fire is that modern FCC definitions don’t treat “caller identification” as purely
a voice-call concept. The FCC’s definitions for caller identification information and caller identification service
explicitly reference both voice calls and text messages sent using a text messaging service.
That definitional language has been used by plaintiffs to argue that if you’re sending marketing texts,
you may have obligations that resemble caller ID complianceespecially where the platform, carrier, or messaging setup
can pass identifying information and the consumer alleges it didn’t happen.
Courts have begun to grapple with this in follow-on litigation. For example, a 2025 decision out of the Eastern District
of Pennsylvania (Newell v. JR Capital) discussed § 64.1601(e) and concluded (at least at the pleadings stage)
that a private right of action exists for alleged violations and that the caller ID requirement can apply to text messages,
relying in part on the regulatory definitions tying caller identification to texts.
If you’re thinking, “But texts don’t show ‘caller ID’ the way calls do,” you’re not wrong. Text identity shows up through
different pipes: long codes, toll-free numbers, short codes, 10DLC registration, sender IDs, carrier filtering, and platform
metadata. That complexity is exactly why this issue can sneak up on otherwise careful compliance programs.
What “compliance” looks like now for marketers and lead generators
The businesses most exposed aren’t just giant brands with in-house call centers. It’s the whole ecosystem:
lead generation shops, affiliates, marketing platforms, call centers, and any seller using third parties “on behalf of”
the brand. When courts talk about calls made “by or on behalf of” an entity, they are describing the exact structure
of modern performance marketing.
1) Treat outbound identity like a product feature, not a settings page
Make a list of every outbound channel you use: voice, SMS, MMS, ringless voicemail (if applicable), and any hybrid tools.
For each channel, document:
- What number appears to consumers
- What name appears (CNAM or other display name), if any
- Whether the number is answered during regular business hours
- How a consumer can submit a do-not-call request (agent, IVR, menu option, or recorded request)
- Who controls the carrier-level settings (you, vendor, platform, or call center)
2) Make sure the displayed number is “callable” for do-not-call requests
The caller ID rule is allergic to unreachable numbers. If your caller ID points to a number that:
(a) never connects, (b) routes to a message saying “not in service,” or (c) reaches a maze that never lets a consumer
request do-not-call treatment, you are inviting the kind of screenshot-based evidence plaintiffs love.
Practical best practice: do periodic testing from multiple carriers, not just internal test lines.
Carrier behavior can vary, and the consumer’s experience is what ends up in the complaint.
3) Decide whether you are showing the telemarketer’s identity or the seller’s identity
The rule allows substitution of the seller’s name and customer service number. That can reduce confusion for consumers,
but it increases the seller’s ownership of the compliance experience. If you substitute the seller’s identity, the seller
must be ready to take do-not-call requests and route them to the right suppression list quickly.
4) Put vendor controls in writingand verify them
Many caller ID problems happen because “the platform handles it” becomes a faith-based statement.
Contracts should require vendors and call centers to:
- Transmit caller ID info for outbound marketing
- Maintain consistent identity parameters across campaigns
- Support do-not-call requests through the displayed number
- Provide logs and technical evidence of transmission settings
- Notify you before changing numbers, routing, or display-name behavior
Then verify. Ask for test results, screenshots, and carrier-level documentation. “Trust, but verify” is not paranoia;
it’s what keeps you out of “we didn’t know our vendor did that” deposition territory.
5) Don’t forget the FTC’s Telemarketing Sales Rule (TSR) alignment
While Dobronski is framed as a TCPA/FCC caller ID issue, the FTC’s Telemarketing Sales Rule also includes caller ID
transmission requirements for telemarketing. Regulators have long emphasized that caller ID helps consumers decide
which calls to take and helps them file complaints when they believe telemarketing rules were violated.
How plaintiffs may frame these claims (and what defenses can look like)
A typical caller ID lawsuit pitch after Dobronski-style reasoning will try to check a few boxes:
- Multiple contacts: For § 227(c)(5), the statute references more than one call within a 12-month period by or on behalf of the same entity.
- A clear rule violation: No caller ID name when available, blocked ID, or a number that can’t be used to make a do-not-call request during regular business hours.
- “On behalf of” theories: The seller is responsible even if an affiliate, platform, or call center pressed “send.”
- Proof by screenshots: Plaintiffs often rely on phone logs, screenshots, and carrier behavior as their “this is what I saw” evidence.
Defenses vary by jurisdiction and facts, but common themes include:
- Authority arguments: § 64.1601(e) was not prescribed under § 227(c), so § 227(c)(5) shouldn’t apply (this is where courts may split).
- Compliance evidence: Documentation that the business took all available steps to transmit caller ID information and any failure was isolated or outside its control.
- Vicarious liability limits: Challenging whether the seller can be tied to the specific outreach or whether the vendor acted outside authorization.
- Standing/causation issues: Arguing that the alleged harm is not traceable to the claimed technical deficiency (fact-specific and not always successful).
One more wrinkle: the FCC has continued to propose and evaluate updates to TCPA-related rules, including identification
and revocation concepts for certain categories of calls and messages. Even if a future rulemaking changes the landscape,
existing claims can still target prior conductso “we’ll wait and see” is not a great compliance strategy.
A practical action plan: 10 steps to reduce caller ID risk fast
- Inventory every outbound calling and texting pathway (internal + vendors).
- Standardize the displayed identity approach: telemarketer identity vs seller identity.
- Confirm caller ID name behavior (CNAM) where applicable and document what is “available by the carrier.”
- Test displayed identity across major carriers and multiple devices (iOS/Android, different networks).
- Verify the displayed number is answered during regular business hours with a clear do-not-call request method.
- Synchronize do-not-call processing so requests taken at the seller number reach suppression lists quickly.
- Lock down vendor change controls (numbers, routing, display name, sender profiles).
- Log and retain proof of transmission settings and testing (your “if sued, show your work” file).
- Train call center agents and support teams to recognize and honor do-not-call requests immediately.
- Monitor litigation trends and FCC activity so your program evolves as courts interpret these rules.
Conclusion: Caller ID is no longer “just IT”it’s a legal control
Dobronski v. SelectQuote didn’t invent caller ID obligations. Those have existed for years.
What changed is the enforcement posture: courts are increasingly willing to treat the caller ID rule as something
consumers can enforce through the TCPA’s private right of action framework, at least in some jurisdictions and contexts.
If your outreach program depends on vendors, rotating numbers, fast-moving lead gen, or large-scale texting,
caller ID compliance deserves the same attention you give consent, opt-outs, and do-not-call suppression.
Because in modern telemarketing litigation, “identity” isn’t a courtesyit’s evidence.
Field notes: of real-world experiences and lessons learned
You can read a rule and still get surprised by how it behaves in the wildespecially when carriers, platforms,
and device interfaces all add their own “helpful” layers. Here are common experiences compliance teams and
marketers run into after they start taking caller ID rules seriously.
The “Our number is fine” trap
A team will confidently say, “We show a valid callback number,” and they’ll even dial it internally to confirm it works.
Then a complaint arrives with a screenshot: the number displayed to the consumer isn’t the same number the team tested.
Why? Because the platform rotated numbers, a vendor used a different pool for a specific campaign, or a carrier-level
setting swapped the displayed number for a default outbound identity. The lesson: test the consumer experience,
not just the configuration you believe you deployed.
CNAM: the mysterious case of the disappearing name
Caller name (CNAM) is where optimism goes to be humbled. Businesses often set a display name and assume it shows everywhere.
In reality, name presentation can depend on carrier support, databases, updates, and whether the call is treated as wireless,
VoIP, or something in between. Some teams discover their “name” shows as a generic label, or not at all, on certain networks.
If a court fight turns on whether the name was “available by the telemarketer’s carrier,” you want contemporaneous records
showing what was configured, what carriers supported, and what your testing showed at the time.
The do-not-call request that went to voicemail purgatory
One of the most painful stories is when a seller substitutes its customer service number as caller IDbut the number is routed
to an after-hours message, or an IVR that never gives a clear do-not-call option. A consumer calls back, tries to opt out,
gives up, and later claims the number didn’t “permit” a do-not-call request during regular business hours. Even if you think
“they could have stayed on the line longer,” plaintiffs tend to argue that the rule expects a workable path, not a scavenger hunt.
The fix is boring and effective: a simple menu option like “Press 2 to be placed on our do-not-call list,” plus a ticketing
workflow that feeds suppression lists quickly.
Texting identity is a compliance relay race, and someone always drops the baton
With marketing texts, the most common experience is a gap between what the brand thinks the recipient sees and what the phone
actually displays. A message might include a brand name in the body, a link, and an opt-out instructionyet the claim is that
required identifying information wasn’t transmitted through the caller ID pathway the rule contemplates. Whether that theory
wins depends on the court, the messaging setup, and evolving interpretations. The practical takeaway isn’t “panic”; it’s “map
your stack.” Know which entity controls sender identity, what metadata is passed, and how that aligns with regulatory definitions.
Then document it.
The best compliance upgrade is also the most customer-friendly
The easiest way to reduce caller ID risk often improves consumer trust: show a recognizable identity and provide an easy off-ramp.
When consumers can tell who is contacting them and can stop it without friction, complaints dropand litigation risk tends to follow.
That’s not magic. It’s just the rare moment where doing the right thing is also the cheapest thing.
Bottom line: the new wave of caller ID claims is forcing businesses to treat identity transmission like a measurable control.
If you can demonstrate consistent identity, reachable callback numbers, easy do-not-call processing, and careful vendor oversight,
you’re in a much stronger positionboth to prevent problems and to defend them.
