Mark Dobronski vs. Rocket Mortgage: The TCPA Arbitration Question That Could Decide the Case

The Mark Dobronski Rocket Mortgage dispute has taken an unusual turn.

What began as a TCPA lawsuit over allegedly unwanted calls and a text message has become a dispute over whether an online mortgage inquiry was ever submitted by Dobronski in the first place.

That question matters because Rocket Mortgage says the alleged online submission contained an arbitration agreement covering TCPA claims.

Dobronski says he never submitted the form.

So before the court can determine whether the alleged arbitration agreement should be enforced, it first has to determine whether Dobronski actually entered into the agreement at all.

The case is Dobronski v. Rocket Mortgage, LLC, No. 25-12798, 2026 WL 2296669 (E.D. Mich. Aug. 10, 2026), and the dispute was examined by TCPAWorld in its August 11, 2026 report.

The case provides a useful look at how TCPA litigation, online lead generation, digital evidence, consent, and arbitration can collide when a consumer disputes ever completing the online form on which a defendant’s arbitration defense depends.

The Alleged Calls That Started the TCPA Lawsuit

According to the TCPAWorld account, Dobronski alleged that he received approximately 20 calls between August 11 and August 19, 2025 from the same number.

The calls allegedly had a peculiar pattern.

The telephone would ring once before the call disconnected.

Eventually, Dobronski called the number back.

He says the call reached an automated interactive voice response system identifying Rocket. After selecting the appropriate option, he was connected with an agent identified as Blake.

According to Dobronski’s account, Blake told him Rocket was trying to reach him about refinancing.

Dobronski allegedly told the representative that his number was listed on the Do Not Call Registry, that he was not interested, and that Rocket should stop calling.

According to his allegations, however, the communications did not stop.

He says another call came in during September 2025, followed by a text from a Rocket loan officer.

Those alleged communications formed the foundation of the Rocket Mortgage TCPA lawsuit.

But Rocket Mortgage presented a different explanation for the communications.

Rocket Mortgage Says There Was an Online Mortgage Lead

Rocket Mortgage relied on its internal records to explain why Dobronski’s telephone number was being contacted.

According to the evidence summarized by TCPAWorld, a user visited a Rocket website 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 inquiry
• A requested loan amount of $250,000
• A subsequent click on “Confirm & continue”

Rocket Mortgage’s position was therefore that the telephone number was connected to an online mortgage inquiry.

But the lead allegedly contained something that became even more important to the litigation.

It contained language tied to consent and arbitration.

The Arbitration Provision at the Center of the Dispute

According to the court record as described by TCPAWorld, language appearing immediately above the “Confirm & continue” button stated that clicking the button constituted agreement to the website’s Terms of Use.

Those Terms allegedly contained an agreement to arbitrate TCPA claims.

The disclosure reportedly also authorized marketing calls and text messages, including communications to numbers appearing on a do-not-call list.

The Terms allegedly covered TCPA and related state-law claims and were governed by the Federal Arbitration Act.

That gave Rocket Mortgage an obvious procedural argument.

If Dobronski completed the form and accepted the Terms, Rocket could argue that he agreed to resolve covered claims through arbitration.

But that argument depends on proving one essential fact:

Dobronski had to actually enter into the agreement.

And according to Dobronski, he did not.

Dobronski’s Sworn Denial

Dobronski responded with a sworn declaration challenging the alleged online transaction.

According to TCPAWorld, he denied:

• Submitting the mortgage inquiry
• Authorizing someone else 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

Dobronski also challenged the significance of the IP evidence.

He reportedly pointed to public information connecting 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 service.

That created a direct evidentiary conflict.

Rocket Mortgage had a digital record.

Dobronski had sworn testimony denying that he created the record.

The court therefore faced a question that could not simply be answered by pointing to the existence of the lead.

Rocket Mortgage Points to a Second Inquiry

Rocket Mortgage also presented evidence concerning another inquiry dated September 29, 2025.

According to the TCPAWorld report, the second lead allegedly contained the same:

• Name
• Telephone number
• State

But it was associated with a different IP address.

Rocket’s analyst reportedly testified that the company’s systems linked the two submissions to the same individual.

From Rocket Mortgage’s perspective, the second record strengthened its argument that the online activity was connected to Dobronski.

But Dobronski continued to dispute that he had submitted either inquiry.

The issue therefore became whether Rocket could produce enough evidence to demonstrate that Dobronski, or someone authorized to act on his behalf, actually submitted the form.

The Court Asked a More Fundamental Question

The arbitration dispute is important because it involves the difference between whether an arbitration clause is enforceable and whether an arbitration agreement was ever formed.

Rocket Mortgage’s position depended on the alleged online agreement.

Dobronski’s position was that he never completed the transaction.

That meant the court had to address formation first.

Magistrate Judge Altman treated Dobronski’s sworn declaration as competent evidence and found a factual dispute concerning whether the agreement had been formed.

The magistrate judge therefore recommended denying Rocket Mortgage’s motion to compel arbitration without prejudice.

The key point was not that the arbitration provision had been declared invalid.

Rather, Rocket had not yet established that Dobronski himself entered into it.

Judge Behm Orders the Formation Question to Take Priority

Rocket Mortgage objected to the proposed handling of the arbitration issue.

Judge F. Kay Behm sustained Rocket’s objection and concluded that the court needed to resolve the formation issue first.

The decision involved Section 4 of the Federal Arbitration Act, which addresses disputes over whether an arbitration agreement was actually made.

The TCPAWorld report discusses Sixth Circuit decisions including Southard v. Newcomb Oil Co. and Boykin v. Family Dollar Stores of Michigan, LLC in explaining the importance of determining contract formation before proceeding further.

That procedural distinction matters.

Rocket Mortgage may have an arbitration provision.

But the company still has to establish that the provision became part of an agreement with Dobronski.

The TCPA Case Is Now Focused on Formation

Following the ruling, the case moved into a more targeted phase.

Rocket’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 pursue targeted discovery.

The parties are being directed toward a summary trial concerning the formation of the alleged arbitration agreement.

The immediate question is therefore narrow but potentially decisive:

Did Mark Dobronski submit the Rocket Mortgage form, or did someone acting on his behalf submit it?

Why the IP Evidence Is Not Enough by Itself

The dispute also highlights a recurring issue in online lead litigation.

An IP address can help identify a network connection used during an online transaction.

But an IP address does not necessarily establish the identity of the individual who was using that connection.

Here, Rocket Mortgage had an IP address associated with the alleged lead.

Dobronski countered by pointing to information associating the IP address with a Comcast connection at a Humane Society location in Ann Arbor, while denying any relationship to that location or provider.

That created an evidentiary gap that may require additional digital evidence to resolve.

TCPAWorld describes IP geolocation as “soft evidence” and emphasizes the importance of preserving additional technical records when online lead submissions are expected to become evidence in litigation.

What Could Strengthen Rocket Mortgage’s Evidence?

The dispute demonstrates why an online lead record may need to be supported by other digital evidence.

Potentially useful evidence can include:

• Device fingerprints
• Session recordings
• TrustedForm certificates
• Jornaya records
• Precise timestamps
• Browser or device information
• Other technical records connecting a person or device to the submission

The distinction is important.

A company’s system may show that a telephone number was entered into a form.

But that does not necessarily answer the more difficult question:

Who actually entered the number?

That question becomes even more important when the online form allegedly creates an arbitration agreement.

A Sworn Denial Can Create a Formation Dispute

The case also demonstrates why sworn testimony can matter in TCPA arbitration disputes.

A plaintiff’s denial does not automatically invalidate an arbitration agreement.

But when a plaintiff provides competent sworn evidence that he never entered into the transaction, the court may have to address that factual dispute before compelling arbitration.

TCPAWorld cites Bazemore v. Papa John’s USA, Inc., 74 F.4th 795 (6th Cir. 2023) when discussing the significance of sworn evidence concerning contract formation.

In practical terms, Rocket Mortgage cannot necessarily rely on the existence of its business records alone if Dobronski has created a genuine factual dispute over whether he was the person who submitted the lead.

Discovery Has Become Part of the Fight

The parties have also disagreed over the scope and procedure of discovery.

According to TCPAWorld, Dobronski sought to limit Rocket Mortgage’s discovery into his online activity while seeking broader discovery from Rocket.

The court rejected that approach.

The proceedings also involved issues concerning the lack of a demonstrated Rule 26(f) conference, procedural deficiencies, and arguments that had not been properly presented.

The court instructed the parties to confer in good faith and attempt to resolve ordinary discovery issues before asking the court to intervene.

That instruction is significant because the court has already identified the central factual issue that discovery should address.

Rocket Mortgage Has Not Lost Its Arbitration Argument

The ruling should not be characterized as a final rejection of Rocket Mortgage arbitration.

The motion to compel was denied without prejudice.

That means Rocket Mortgage may have another opportunity to seek arbitration if it can establish that an agreement was actually formed.

The court has not simply ruled that the arbitration clause can never apply.

Instead, the parties must first establish whether Dobronski entered into the agreement containing that clause.

If Rocket ultimately proves that Dobronski completed the form or authorized someone else to do so, the arbitration issue could take on a very different posture.

Lessons for TCPA Defendants

The Dobronski v. Rocket Mortgage dispute provides several lessons for businesses defending TCPA claims based on online leads.

Preserve the Complete Lead Record

A basic CRM entry may not be enough if the consumer disputes submitting the form.

Preserve Technical Information

Device data, session information, timestamps, and other digital records may provide stronger evidence of who actually completed the transaction.

Don’t Overstate IP Evidence

An IP address can identify a network connection without necessarily identifying the individual user.

Preserve the Consent and Arbitration Screen

Companies should be able to demonstrate what the user allegedly saw before clicking a submission button.

Prove Formation First

A defendant seeking arbitration may need to establish that the plaintiff actually entered into the agreement before the court can enforce it.

Lessons for TCPA Plaintiffs

The case also provides an important lesson for plaintiffs challenging an arbitration defense.

A genuine dispute over whether an online transaction ever occurred can put contract formation directly at issue.

But simply denying that a form was submitted does not necessarily resolve the dispute.

Rocket Mortgage may have access to multiple categories of evidence, including:

• Lead records
• IP information
• Telephone numbers
• Timestamps
• Device data
• Session records
• Consent records
• Multiple related submissions

The ultimate outcome will depend on whether the evidence establishes that Dobronski actually participated in the transaction.

Why the Case Matters Beyond Dobronski

The significance of the Mark Dobronski Rocket Mortgage case extends beyond the immediate parties.

Online lead forms are increasingly important in TCPA litigation because they can potentially establish consumer interest, consent, marketing authorization, Terms of Use acceptance, and arbitration agreements.

But an electronic record does not always resolve the identity question.

A record can show that information was entered.

It may not show with certainty who entered it.

That distinction can become critical when a consumer denies ever visiting the website or submitting the form.

The case therefore raises several questions:

Who entered the telephone number?

Who clicked “Confirm & continue”?

Who accepted the Terms of Use?

Who provided marketing consent?

Who agreed to arbitration?

Those questions may ultimately determine whether Dobronski’s TCPA claims proceed in federal court or move into arbitration.

The Central Question Remains Unanswered

At this stage, the parties maintain fundamentally different positions.

Rocket Mortgage says its records connect Dobronski’s telephone number to an online mortgage inquiry.

Dobronski says he never submitted it.

The August inquiry allegedly involved the name “Testq Testing,” a Michigan property, a $250,000 purchase-loan request, and the disputed IP address.

Rocket also relies on a September inquiry containing matching information.

Dobronski disputes those connections.

The court has therefore directed the parties toward targeted discovery and a factual determination concerning whether the alleged arbitration agreement was actually formed.

The underlying TCPA merits remain secondary until that threshold issue is addressed.

Final Takeaway

The Mark Dobronski vs. Rocket Mortgage dispute is ultimately a fight over proof.

Dobronski alleges that Rocket Mortgage contacted his cell phone repeatedly and continued communicating with him after he allegedly requested that the calls stop.

Rocket Mortgage says the communications were connected to an online mortgage inquiry using Dobronski’s telephone number.

That alleged inquiry contained language concerning marketing consent and arbitration of TCPA claims.

Dobronski says he never submitted the form.

His sworn denial created a factual dispute over whether the alleged arbitration agreement was ever formed.

The federal court therefore did not immediately compel arbitration. Instead, it directed the parties to investigate the formation issue through targeted discovery before the case proceeds further.

For Rocket Mortgage and other companies defending TCPA online lead claims, the lesson is straightforward:

A lead record can establish that information entered a system, but proving who created that record can be an entirely different matter.

For TCPA plaintiffs, the case demonstrates that a genuine dispute over contract formation can prevent an arbitration provision from being enforced immediately.

And for anyone following Mark Dobronski, Rocket Mortgage, TCPA arbitration, online mortgage leads, and TCPA litigation, the next stage of this case may be more important than the initial arbitration motion.

The question now is not simply whether Rocket Mortgage has an arbitration clause.

It is whether Rocket Mortgage can prove that Mark 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”](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., 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 for informational and commentary purposes only. Statements attributed to the parties, attorneys, witnesses, or TCPAWorld are presented as allegations, arguments, testimony, or commentary where applicable.

The court’s reported ruling did not resolve whether Dobronski actually submitted the disputed Rocket Mortgage lead. That issue remained subject to further proceedings and discovery.