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Wednesday, October 7, 2026

FCC Rewrites TCPA Revocation Rules as Courts Split on DNC and Text Messages

The FCC has changed how consumers can revoke consent to be called or texted under the TCPA, allowing revocation through any reasonable means. Separately, courts delivered mixed rulings this week on whether text messages count as calls for do-not-call purposes and who can sue over national DNC violations.

1Lookup Signal Report

58.0% of numbers checked today came back mobile, down from 67.7%

Across 2,867 checks run on the 1Lookup platform on 2026-10-07, mobile numbers made up 58.0% of results, down 9.7 points from the trailing seven-day average of 67.7%. Landline numbers rose to 26.5%, up 7.2 points from their 19.3% baseline. Active phone numbers rose to 91.2% of checks, up 2.5 points from 88.7%. Email deliverability held at 91.4% deliverable against 2,233 checks, with 2.2% undeliverable.

Phone line types

2,867 checks

  • mobile58%
  • landline26.5%
  • other line types15.5%

Phone number status

2,867 checks

  • active91.2%
  • other line types8.8%

Email deliverability

2,233 checks

  • deliverable91.4%
  • undeliverable2.2%
  • other line types6.4%

Measured across every completed lookup on the 1Lookup platform for this UTC day. Aggregate only: no customer, organisation or lookup input is published, and any bucket too thin to be anonymous is withheld.

  1. 01

    FCC changes TCPA revocation rules to allow any reasonable means of consent withdrawal

    A webinar sponsored by CSS Impact covered the FCC's rewrite of TCPA revocation rules. Panelists said consumers can now revoke consent through text, email, or verbal requests, not just the method originally used to give consent. This affects debt collection agencies, financial institutions, and healthcare providers that rely on consumer consent to call or text.

    Why it matters: If a prospect revokes consent by any reasonable means, including a text or spoken request, a business must honor it even if that was not the original channel used. Call and text programs that only track revocation through one channel are now out of step with the rule.

  2. 02

    FCC orders providers to block digital solutions tied to robocall violations

    The FCC issued an order directing providers to block certain digital solutions over robocall violations. The order was covered by Broadband Breakfast and documented on the FCC's own site.

    Why it matters: Providers tied to robocall violations can be cut off at the network level. Businesses using third-party calling platforms should confirm their provider is not at risk of an FCC blocking order affecting call delivery.

  3. 03

    Maryland judge grants summary judgment to collector, dismisses do-not-call claim in TCPA text suit

    A District Court judge in Maryland ruled for the defendant on both claims in a consumer's TCPA lawsuit over debt collection text messages. The court found the texting platform was not an autodialer and that collection messages are not telephone solicitations. The plaintiff had several accounts with a lender.

    Why it matters: This ruling supports the position that debt collection texts are not telephone solicitations under the TCPA and that certain texting platforms do not qualify as autodialers. Collectors sending account-related texts have a favorable precedent to point to.

  4. 04

    California federal courts keep holding that text messages count as calls for DNC purposes

    A wave of new suits nationally have held that the TCPA's DNC provisions do not apply to text messages, but California federal courts remain a holdout. In Combs v. UG, 2026 WL 2970636 (C.D. Cal. Oct. 2, 2026), the court held that SMS messages are calls for DNC purposes.

    Why it matters: Businesses texting prospects in California should not assume DNC rules only apply to voice calls. California federal courts are treating SMS as calls, while courts in other parts of the country are going the other way.

  5. 05

    Court holds a phone's DNC

    A court held that whether a cellular phone qualifies as residential for TCPA DNC purposes turns on how the phone was used at the time it was registered on the DNC list. The question of whether a phone used for both personal and business purposes can support a DNC claim is in wide dispute, with some courts holding a cellular phone can never be residential under the DNC rules.

    Why it matters: Businesses facing a DNC claim over a cell number should check how that number was used when it was first registered on the DNC list, since that registration-time use can determine whether the claim holds up.

  6. 06

    Florida federal court finds no private right of action for national DNC claims

    A Middle District of Florida ruling in Internicola v. MortgagePros, LLC, No. 6:25-CV-01613-AGM-LHP (M.D. Fla. September 24, 2026), established that there is no private right of action for national DNC claims. Daniel Internicola had registered his number on the DNC Registry.

    Why it matters: In the Middle District of Florida, a consumer cannot bring a private lawsuit over national DNC registry violations alone, narrowing one avenue of TCPA litigation exposure for callers in that jurisdiction.

Questions people asked today

Does the TCPA DNC rule apply to text messages in California?
Yes, as of early October 2026 California federal courts are holding that SMS messages count as calls for DNC purposes, per the Combs v. UG ruling, 2026 WL 2970636 (C.D. Cal. Oct. 2, 2026), even as courts elsewhere hold the opposite.
Can a consumer sue directly over a national DNC registry violation in Florida?
A Middle District of Florida ruling in Internicola v. MortgagePros found there is no private right of action for national DNC claims, meaning a consumer cannot bring that specific claim on their own in that court.
How did the FCC change TCPA consent revocation rules?
The FCC now allows consumers to revoke consent through any reasonable means, including text, email, or verbal request, rather than requiring the original consent channel to be used.
What share of numbers checked on 1Lookup today were mobile?
Of 2,867 checks run on the platform on 2026-10-07, 58.0% came back mobile, down 9.7 points from the trailing seven-day average of 67.7%, while landline checks rose to 26.5%, up 7.2 points.

Check your own numbers against this

Why are my calls showing as spam likely? · What share of phone numbers are VOIP? · How many numbers are invalid or disconnected?