Register.com Robo-Dialed Phones That Didn’t Even Belong to Their Customers Anymore

The People on the Other End of the Line

Picture it: you get a new phone number. Maybe you just switched carriers. Maybe you moved cities. The number is yours, clean, unconnected to whoever had it before. Then your phone rings. A robot voice addresses you with the wrong name, or asks about a domain registration you’ve never heard of, or delivers some automated pitch for a service you didn’t ask about and don’t want. You hang up. It rings again. And again. Across four and a half years, this happened at least 1,652 times to people holding those reassigned numbers.

You didn’t consent to be called. You never signed up for anything from Register.com. You’re not a customer. You’re just someone who had the misfortune of inheriting a phone number the company never bothered to check was still attached to the same person. The federal government maintains a database for exactly this purpose, the Reassigned Numbers Database, so that companies can verify before they dial. Register.com kept dialing anyway.

There is no line item in a legal settlement for the low-grade violation of your evening being interrupted by a robot. There is no compensation for the creeping suspicion that someone, somewhere, has your number and won’t stop using it. There is nothing in this $1.5 million fund for the erosion of a basic expectation: that your phone is yours, that the calls on it are meant for you, and that the entities behind those calls respected your right to say no before they ever dialed.

The TCPA was written because Congress understood that automated calls are not a minor inconvenience. They are a form of trespass into the most personal communication device most people own. For every person who filed a claim in this case, there may be others who never knew they had legal rights here at all, people who just muted their phones and moved on, absorbing the intrusion as the cost of living in a world where corporations automate first and ask permission never.

What the Documents Actually Say

These are direct quotes from the court-filed settlement documents. Nothing has been paraphrased.

“Register.com states that from February 12, 2021 through November 24, 2025 it placed 1,652 calls in connection with which it used an artificial or prerecorded voice to 453 telephone numbers assigned to a cellular telephone service after the telephone numbers were permanently disconnected and made available for reassignment per the Federal Communications [Reassigned Numbers Database].”

• This is Register.com’s own disclosed figure, not a plaintiff estimate. The company itself acknowledged the scope of calls made to reassigned numbers during this period.
• The Reassigned Numbers Database is a federally maintained system. A company that dials numbers listed in that database as reassigned cannot claim it had no way of knowing the numbers belonged to different people.
• At the TCPA’s baseline of $500 per violation, 1,652 calls represents a maximum statutory exposure of $826,000. At the willful violation rate of $1,500 per call, the maximum exposure climbs to $2,478,000, significantly more than the $1.5 million settlement.

“This Order, the Agreement, and any and all negotiations, statements, documents, and proceedings in connection with this settlement are not, and will not be construed as, an admission by Defendant of any liability or wrongdoing in this or in any other proceeding.”

• This is the standard liability shield language embedded in the final approval order. It means Register.com/Network Solutions pays $1.5 million while the court simultaneously records that this payment proves nothing about whether they did anything wrong.
• This clause protects the company from the settlement being cited as evidence of wrongdoing in any future lawsuit. Future plaintiffs would have to start from scratch.

“Ms. Lewis filed a class action lawsuit against Register.com alleging that Register.com violated the TCPA by placing certain calls to cellular telephone numbers in connection with which Register.com used an artificial or prerecorded voice absent prior express consent.”

• “Absent prior express consent” is the core legal violation. Under the TCPA, prior express consent is a complete defense. Register.com could not produce that consent for these 453 reassigned numbers because there was none to produce: the people holding those numbers had never interacted with the company.

“On July 25, 2025, Register.com, Inc., merged into Network Solutions, LLC and Network Solutions, LLC is the surviving entity. Any of the subject telephone calls made on or after July 25, 2025 would have been made by Network Solutions, LLC.”

• The misconduct window runs through November 24, 2025, meaning the conduct continued for at least four months after the corporate merger closed. The new entity, Network Solutions, LLC, was still making robocalls to reassigned numbers after absorbing Register.com.
• The merger means any future TCPA violations would be attributable to Network Solutions, LLC, a larger entity with greater resources and, potentially, a larger call volume.

• This is the court’s own language from the final approval order, citing the settlement favorably. The framing is relative: “exceeds some other settlements” is a low bar in a legal landscape where TCPA settlements routinely pay out pennies per class member.
• The settlement provides a theoretical $3,300+ per affected phone number before deductions, which is genuinely higher than many TCPA class settlements. Whether individual claimants see anywhere near that amount depends on how many file claims.

Four and a Half Years of Robocalls

They Had a Database. They Didn’t Use It.

The existence of the Reassigned Numbers Database is not a secret. The FCC created and mandated it specifically so that companies using autodialing systems could verify, before each call, whether a number had been reassigned. Register.com’s own figures reveal a decision, whether passive or active, to keep operating without adequately checking that database.

• The federal Reassigned Numbers Database was created to give companies a definitive, accessible tool to avoid calling the wrong people. Querying it costs money and takes time. Not querying it saves both. The documented outcome here, 1,652 calls to 453 reassigned numbers over nearly five years, is consistent with a business operation that did not build compliant number-checking into its automated calling workflow.
• Robocalls using artificial or prerecorded voice are cheap to deploy at scale. The marginal cost of each additional call is effectively zero once the system is running. The profit motive to maximize outreach is built into the technology itself, and the TCPA’s per-call damages structure exists precisely because Congress understood the economics: companies will call more people than they should unless the penalty per call exceeds the profit per call.
• The $1,500,000 settlement is the price Register.com agreed to pay to make this go away. The settlement does not disclose what revenue the underlying calling campaign generated, so the ratio of penalty to profit cannot be precisely stated. What is documented is that the company chose settlement over disclosure of those figures.

The Database Existed. The Compliance Did Not.

The TCPA’s protections for reassigned number recipients exist in an enforcement environment where companies bear the technical burden of checking databases before they call, but enforcement only triggers after harm has occurred and someone files a lawsuit.

• The TCPA provides that prior express consent is a complete defense. Companies that maintain accurate, current consent records and verify number reassignment before calling can avoid liability entirely. The burden is on the company to obtain and verify consent; it is not on the recipient to proactively tell the company to stop. Register.com’s inability to assert a consent defense for 453 reassigned numbers indicates a gap in its consent-verification infrastructure.
• The Reassigned Numbers Database is a relatively recent regulatory tool. While it closes a prior gap, companies are not automatically penalized for failing to query it; they face liability only after a plaintiff files suit and proves the call was made to a reassigned number post-disconnection. This means companies that do not query the database face consequences only if someone sues them, a reactive enforcement model that rewards non-compliance until caught.
• The four-and-a-half-year duration of the class period, February 2021 through November 2025, reflects how long a TCPA violation can continue before class action litigation forces a reckoning. No regulator proactively discovered this pattern. A single private plaintiff, Tiffany Lewis, had to bring a federal lawsuit to surface it.

What the Autodialer Implied vs. What Was True

Every robocall made to a reassigned number carried an implicit false premise: that the person answering had a relationship with Register.com and had agreed to be contacted. The documented facts show the opposite was true for all 453 of these numbers.

$1.5 Million Is the Price of Not Going to Court

The settlement resolves claims without Register.com admitting a single thing, and the math between the gross fund and what individual class members actually receive reveals the structural limits of class action as a deterrence tool.

• The gross settlement fund is $1,500,000. From that, attorney fees can take up to one-third of the fund, approximately $500,000. Add the $10,000 incentive award to Tiffany Lewis, plus up to $25,000 in documented litigation costs, plus Kroll LLC’s administration fees. The money available for actual class members could be substantially below $1 million depending on notice and administration costs.
• The settlement covers 453 potentially affected phone numbers. If every number holder files a valid claim, the per-claimant payout from the remaining fund could approach the advertised $3,300+. But class action participation rates are notoriously low. If only a fraction of the 453 file claims, each individual may receive more, but the unclaimed money in a non-reversionary fund is redistributed among claimants or handled per the settlement agreement’s terms. The company does not benefit from low participation; but its total payment does not increase either.
• The no-admission-of-liability clause is standard but consequential. Network Solutions, LLC, which absorbed Register.com on July 25, 2025, faces no legal record of wrongdoing. Future TCPA plaintiffs who are harmed by Network Solutions cannot point to this settlement as evidence of a pattern; they must start from zero.
• At the willful violation maximum of $1,500 per call, the 1,652 documented calls generate a theoretical ceiling of $2,478,000 in statutory damages, which is $978,000 more than the settlement. The company settled for below even its maximum exposure. Whether that represents a reasonable litigation compromise or a below-market resolution is a judgment the court made in approving the settlement; but the gap is real.

• The court’s own language acknowledges that TCPA statutory damages are “too small to incentivize individual actions.” This is an accurate statement, and it is also an indictment of the entire enforcement model. The people harmed by these calls will never pursue their individual claims. The only mechanism that makes corporate accountability happen here is a class action, and the class action resolved for less than the willful-violation maximum, with no admission of fault, before any jury heard the evidence.