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Tollman
Tollman/ tollman.ai

While everyone races,
we collect the toll.

A legal-operations and evidence platform for six consumer-protection workflows. It identifies potentially actionable claims, assembles auditable evidence packages, automates the administrative work, and routes eligible matters through jurisdiction-specific review, resolution and enforcement.

Held01 / 05
§ 00What is built, live, modeled, and still gating
As of July 25, 2026

The first workflow is operational and the calls arriving against it are real. Legal validation and jurisdictional expansion remain gating items, and the recovery figures are not yet a history. This page never presents them as one. Everything on it falls into one of these columns, and each number carries the label of the column it belongs to.

Built01 / 04
Infrastructure, shipped and running
  • Six enforcement workflows configured on one codebase
  • Capture, entity research, asset search, document generation
  • Court-specific document templates, filing integration by jurisdiction
  • Self-healing browser agent under 24/7 outcome monitoring
  • 18+ months of build behind it
Live02 / 04
In operation today
  • Unsolicited calls arriving at owned-property numbers
  • Communications captured, screened for eligibility, logged to the entity record
  • Demand letters issuing on the fourteen-day clock
  • Docket monitoring running against filed matters
Modeled03 / 04
Not yet a record, stated as assumptions
  • Settlement and default judgment averages
  • The 60/40 resolution mix, and the filed-matter default rate
  • The 30% collection rate applied to entered judgments
  • Filing and service cost, carried in bands by venue
  • Per-case, monthly and annual figures, and every return horizon
GatingOpen before the next rung, not after
04 / 04
  • Written ethics opinions from bar-admitted regulatory counsel in every filing state, required before any fee arrangement is operationalized
  • The per-entity monthly matter ceiling, set with counsel before the next rung is funded and deliberately unset here
  • The standing structure on these facts, argued but not yet adjudicated
  • Jurisdictional expansion: filing integration, service rules and small claims eligibility cleared state by state
  • A resolved-matter history: no cohort has completed a full collection cycle, which is why every recovery figure on this page is modeled
§ 00.1The operating record, and what it reports
Values dated at delivery

Thirteen figures govern whether the model above is a forecast or a measurement, and they are the thirteen below. Their values are reconciled to the operating log and furnished dated, in full, including the ones that read zero. None of them is estimated, and none is printed on a public page ahead of the reconciliation.

Intake
  • Calls received on owned-property numbersvalue not published
  • Calls screened for eligibilityvalue not published
  • Qualifying matters openedvalue not published
  • Unique defendant entitiesvalue not published
Demand and resolution
  • Demands issuedvalue not published
  • Responses receivedvalue not published
  • Settlements signedvalue not published
  • Cash collectedvalue not published
Court
  • Complaints filedvalue not published
  • Default judgments enteredvalue not published
  • Contested mattersvalue not published
  • Filing rejection ratevalue not published
  • Human interventions per matter, averagevalue not published
External figures cited throughout are drawn from public dockets, regulator reports and published indices, and each carries its source inline. Modeled figures are computed at the assumptions set out in § 03, priced across a downside, base and upside case in § 06.3, and move as resolved matters accumulate.
§ 01The gold rush thesis

Everyone is sprinting into the red ocean. We’re standing at the toll.

The AI build-out produces potential violations faster than any regulator can absorb them. Tollman is the layer that prices that exhaust: it identifies potentially actionable claims, assembles an auditable evidence package, serves the demand, and routes what escalates through jurisdiction-specific counsel review.

  1. 01

    Everyone is building the agent

    Thousands of companies are racing into the same water with the same models. Feature parity in weeks. Margin compression to zero. That is the red ocean.

  2. 02

    Nobody is building the enforcement layer

    The one market that grows as the ocean gets bloodier is the market for consequences. More agents means more calls, more scrapes, more violations, and the same number of regulators.

  3. 03

    Statutory damages reduce, but do not eliminate, damages litigation

    Federal statutory damages for a proven TCPA violation generally begin at $500 and may reach $1,500 where a court finds the violation knowing or willful. Liability still has to be established, and the count can still be contested: how many violations occurred, whether separate contacts are separate violations, whether conduct was willful, and whether a claimant is statutorily eligible. What a plaintiff does not have to build is a damages case from scratch. Congress already wrote the invoice, and almost nobody sends it.

  4. 04

    Our market is their violation rate

    We monetize the exhaust of the entire AI build-out. Every competitor in the red ocean expands our addressable market by operating.

Why now
50B/day
AI crawler requests processed
Unwanted call volume vs. public enforcement actions, 2019 to 2026
Unwanted call volumePublic enforcement actions
0255075100THE GAP20192020202120222023202420252026
Illustrative index, 2026 = 100. Not a published series: the shape is derived from FTC and FCC consumer complaint volume and published TCPA filing counts, with the enforcement line derived from FCC Enforcement Bureau actions per year. Call volume is not violation volume, and an enforcement action is not a collection. The chart is shown to make the direction of the divergence legible, and no figure on this page is computed from it.
§ 02The portfolio

Six workflows. One evidence layer.

Six enforcement and recovery workflows, each a different statute with a different damage ceiling and the same evidence and document layer underneath. The reusable part is real. Everything above it is configured separately: origination, standing, evidence, registration, venue, remedies, counsel requirement and collection period all differ workflow to workflow, and legal review is a required control point in every one of them.

0147 U.S.C. § 227(b), (c)

TCPA Federal

A qualifying call can create a statutory claim when received. Section 227(b) reaches artificial or prerecorded voice and qualifying automated dialing without the required consent. Section 227(c) separately reaches repeated solicitations to registered residential subscribers.

$500 to $1,500per proven call
Statutory maximum available on proof, not a price. $1,500 requires a finding that the violation was knowing or willful.
Capture → Recover$600 realized, § 03
2.3B unwanted robocalls placed per month in the U.S.
Automation posture
  • Evidenceoperational
  • Documentoperational
  • Filingjurisdiction-dependent
  • Legal reviewrequired
  • Collectionpartial
02Tex. Bus. & Com. § 302

Texas SB 140

A qualifying Texas call may support both federal and state causes of action. Availability and cumulative recovery depend on the statutory elements, the plaintiff's status and the court's treatment of overlapping remedies.

$5,000state maximum, per call
Statutory maximum available on proof, not a price. Cumulative recovery alongside a federal count is not automatic and has not been settled in every Texas venue.
Capture → RecoverNot modeled
State private right of action effective September 1, 2025
Automation posture
  • Evidenceoperational
  • Documentoperational
  • Filingjurisdiction-dependent
  • Legal reviewrequired
  • Collectionpartial
0315 U.S.C. § 1692

FDCPA

FDCPA matters require a participating consumer with a qualifying personal debt and covered collection conduct. They do not arise from the property-number origination method used for investor-call matters.

$1,000statutory maximum, per action
Statutory maximum available on proof, not a price. Separate origination. This is a consumer-side workflow and does not stack onto a seed-property call.
Capture → RecoverNot modeled
Actual damages and fee-shifting sit on top of the statutory cap
Automation posture
  • Evidenceoperational
  • Documentoperational
  • Filingjurisdiction-dependent
  • Legal reviewrequired
  • Intake and consentrequired
04Cal. Penal Code §§ 631, 637.2

CIPA California

Session-replay and third-party chat technologies have generated substantial CIPA litigation in California. Liability remains fact and technology specific, with courts examining consent, vendor role, contemporaneous interception and the nature of the communication.

$5,000per proven violation, or 3x actual
Statutory maximum available on proof, not a price. Cal. Penal Code § 637.2 awards the greater of the two. Outcomes in this vertical are contested and split across California courts.
Capture → RecoverNot modeled
1,641 digital wiretapping suits filed by February 2025, 83% in California
Automation posture
  • Evidenceoperational
  • Documentoperational
  • Filingjurisdiction-dependent
  • Legal reviewrequired
  • Liability analysisrequired
05Cal. Civ. Proc. § 701.810

Surplus Funds

Foreclosure and tax-sale overages sit in county accounts until a claimant files. Fee caps, claim windows and who may file for another person are set state by state and several states restrict it outright.

30 to 40%recovery fee, where permitted
Statutory maximum available on proof, not a price. Fee ceilings and licensing requirements vary by state and are the gating item, not claim supply.
Capture → RecoverNot modeled
County-held unclaimed surplus, recorded in public tax collector ledgers
Automation posture
  • Evidenceoperational
  • Documentoperational
  • Filingjurisdiction-dependent
  • Legal reviewrequired
  • Fee-cap compliancerequired
0617 U.S.C. §§ 504(c), 1202

AI Copyright / DMCA

Copyright Act remedies vary by claim. Eligible infringement claims may support statutory damages generally ranging from $750 to $30,000 per infringed work, with up to $150,000 for willful infringement. DMCA § 1202 claims carry separate elements and remedies.

$750 to $30,000per work, § 504(c)
Statutory maximum available on proof, not a price. Up to $150,000 per work on a willfulness finding. Registration and timing conditions apply. § 1202 is a distinct claim with its own elements.
Capture → RecoverNot modeled
70+ active AI copyright suits pending in United States courts, 2025
Automation posture
  • Evidenceoperational
  • Documentoperational
  • Filingjurisdiction-dependent
  • Legal reviewrequired
  • Registration and ownershiprequired
OperationalPartial or jurisdiction-dependentHuman control point, required

Ceilings are statutory maximums available on proof and are not expected recoveries. Only the federal telephone workflow carries a published unit model, derived line by line in § 03 and modeled, not a record of resolved matters. The other five read Not modeled until a workflow-specific model exists for each.

§ 02.1Statutory basis

What one call can be worth.

Federal statutory damages generally begin at $500 for a proven TCPA violation and may reach $1,500 where a court finds the violation knowing or willful. Certain fact patterns may support separate claims under § 227(b) and § 227(c), subject to each provision’s independent elements. Whether both counts survive on a single call, and whether a court permits cumulative recovery across federal and state claims, is decided matter by matter and venue by venue.

StatuteMinMaxSame call
§ 227(b)
Artificial or prerecorded voice, qualifying autodialer
$500$1,500
§ 227(c)
Repeated solicitation to a registered subscriber
up to $500$1,500
Tex. SB 140
State solicitation, effective Sept 2025
$500$5,000
Conn. SB 1058
Highest state ceiling in the country
$0$20,000
CIPA § 637.2
Per proven violation, the greater of the two
$5,0003x actual
FDCPA
Separate origination, participating consumer only
$0$1,000
Every statute in the table links to its primary text. Maximums are ceilings available on proof of the statutory elements, not expected awards. The green marker means the count may arise on the same call as a federal claim; it is not a representation that a court will permit cumulative recovery. FDCPA is marked separate because it requires a participating consumer with a qualifying personal debt and covered collection conduct, and does not arise from the property-number origination used for investor-call matters.
What the courts have already done
$61M

Class judgment against Dish Network on 51,119 do-not-call violations. The jury set $400 per call; the district court trebled it to $1,200 on a willfulness finding. Affirmed by the Fourth Circuit, standing intact.

$75.5M

Capital One and three collection agencies, on automated calls to cell phones without consent. One of the largest TCPA settlements on record.

$20M

Settlement fund in the Coldwell Banker affiliate telemarketing action, distributed across approximately 298,494 class members.

$925M

Jury verdict on 1,850,440 calls at the $500 statutory figure. The Ninth Circuit affirmed liability but remanded on whether an aggregate award of that size offends due process, and the award was reduced on remand. The ceiling is real and courts also police it. We model recovery well below it.

Three of these are entered judgments and executed settlements under the same statute this platform files under. The fourth is the cautionary one, and it is on the page on purpose: a court will cut an aggregate award it considers disproportionate. Tollman models recovery per matter far below any statutory ceiling for exactly that reason. What the platform changes is how many qualifying matters can be assembled at once, and at what cost per matter.

§ 03The universal pipeline

One evidence platform. Six configured workflows.

One path from captured claim to cleared funds. Legal review sits at defined control points; the administrative work between them runs unattended. The shared infrastructure stays constant, while eligibility, evidence, damages, venue and legal controls are configured separately for each workflow. The unit model below prices the federal telephone workflow only.

§ 03.1Origination

Where the violations come from.

Nothing here is manufactured and nothing is provoked. Numbers belong one to one to real owners of real property, are registered, and are left alone. The caller chooses to dial. Whether that call supports a claim is decided on review, not on arrival.

01

Claims originate with real owners

Claims originate from unsolicited communications received by participating property owners and consumers. Nothing is placed, provoked or purchased.

02

No solicitation is returned

A caller who reaches an owner line hears a short greeting and receives an automatic text with a link to a personal contact page. No pitch, no offer, no invitation to call back.

03

Eligibility is reviewed first

Consent history, registry status, purpose of the call and injury are reviewed before any demand is issued or any matter is filed. Matters that do not clear that review do not advance.

The consent question
Two obligations, not one

Publishing a phone number on a contact page is not consent to receive telemarketing. It is a directory listing. Telemarketers may carry independent registry-scrubbing and consent-compliance obligations that apply no matter where the number was found. A claimant still has to establish every element the private cause of action requires. The caller’s duty does not discharge the claimant’s burden of proof.

Certain unsolicited investor calls seeking to induce a property transaction may qualify as telephone solicitations, depending on the call’s content, purpose and governing jurisdiction. Where a call does qualify and the line is registered, publication of the number supplies no consent defense. Whether a given call qualifies is a matter-level determination made on the recording and on the caller’s own script, and it is made before anything is sent.

§ 03.2The filing path
  1. Trigger01

    Violation captured

    Call recorded, number matched against DNC registration, caller ID resolved to a legal entity. Evidence package opens automatically.

  2. Day 002

    Entity researched and scored

    Caller ID resolved through Secretary of State filings, property holdings pulled from ATTOM Data, litigation history checked on PACER. Every defendant carries a 0 to 100 collectibility score before a demand is ever sent, and only the top band is filed.

    Hot · 70+ · fileWarm · 40 to 69 · demand onlyCold · under 40 · archive
  3. Day 103

    Demand letter sent

    Statutory demand generated and served with a 14-day response window. Potentially responsible entities, including parent or affiliated entities where supported by evidence and applicable law, are identified for legal review. Certified mail and email, both tracked.

  4. Day 1 to 1404

    Fork: paid or silent

    Roughly six in ten resolve here. The rest advance without a human touching the file.

    Paid · matter closed · 60%No response · advance · 40%
  5. Day 1505

    Small claims filed

    A court-specific complaint is assembled and filed in the correct venue, and service is effected on the named defendants.

  6. Day 21 to 4506

    Default eligible

    Certain uncontested matters become default-eligible roughly twenty one to forty five days after effective service. The clock runs from service, not from filing, and the window is set by the court. The agent checks the docket daily and flags the matter the hour it ripens.

  7. Court-dependent07

    Default judgment sought

    A judgment package is submitted with proof of service, damages calculation and statutory citation. Entry is a judicial act, not a filing step. Some courts enter on the papers within days; others calendar a hearing weeks out or require a damages showing first.

  8. Post-judgment08

    Enforcement

    Where permitted, a judgment may be recorded to create a lien against non-exempt real property owned by the judgment debtor. Priority, duration, collectibility and enforcement vary by jurisdiction and asset. Levy and garnishment follow only where reachable assets exist.

  9. Cleared09

    Money recovered

    Funds land where collection succeeds. The matter closes, and the entity, its assets and its call pattern stay in the database permanently.

Unit economics
Per 100 captured violations
Modeled
Demand settlements (60 × $700), cash
$42,000
Judgments entered (40 × $1,500), face value
$60,000
Cash realization on judgments at 30%
($42,000)
Realized recovery
$60,000
Processing and document generation (100 × $0.52)
($52)
Certified mail (100 × $8.50)
($850)
Filing and service (40 × $300, base venue)
($12,000)
Contribution margin per 100
$47,098
Monthly at 200 violations
$94,196
Annualized
$1.13M
Per matter
$471
What this line excludes
  • Counsel review, contested matters and appearance time
  • Collection and enforcement expense beyond the filing line
  • Consumer acquisition and number deployment
  • Engineering, compliance and supervision
  • Corporate overhead, insurance and reserves

This is contribution margin after direct case costs. It is not EBITDA, and it is not distributable proceeds.

Demand settlements are modeled at full cash realization on receipt. The model does not currently apply a settlement payment default or timing discount, and a signed settlement can still meet delayed payment, an installment default, a returned payment, a rescission dispute, documentation failure, enforcement expense or an insolvent counterparty. Entered judgments are not cash at all. Seventy percent of every judgment is written off before a single downstream figure on this site is calculated, and what survives enforces only where the debtor holds reachable, non-exempt assets and the jurisdiction permits recording.

$0.52 of processing per matter against $700 to $1,500 of gross recovery, and $600 realized per matter after the write-down above.

$0.52 covers compute, document generation and docket monitoring only. Filing and service are modeled at $300 per filed matter, the middle of the band in § 03.3, and are charged only to the 40 matters that reach a court. Judgment collection is modeled at 30%, the conservative middle of the 25 to 40% range reported on small claims defaults. No settlement payment default or timing discount is applied, which is an assumption rather than a finding. Settlement and judgment averages are modeled at the stated assumptions and are not a record of resolved matters. This is an illustrative management case, not validated operating performance. Downside and upside cases are in § 06.

§ 03.3Court cost, by venue

One filing fee does not exist.

Small claims filing and service is the largest variable cost in the model and the one that moves most between jurisdictions. Published schedules run from fee-waived to several hundred dollars before service, and a failed first attempt puts the whole line through twice. The model carries the middle of the base band, not the cheapest venue available.

Court-published small claims fee schedules. The Consumer Financial Protection Bureau has documented small claims filing fees ranging from $35 to $499 across surveyed jurisdictions. Service of process is quoted separately and varies by county and by number of defendants.
Low-cost venue
$100 to $175

Fee-waived or low-fee small claims, first-attempt service.

Base venue, modeled
$250 to $400

The $300 carried in the model above. Filing plus one served defendant.

High-cost or re-service
$500 to $750

Higher-fee venues, multiple defendants, failed first service.

What the model assumes
Constant unit cost, for illustration only

The model holds variable processing cost constant across volume so that scenarios stay comparable. It does not assume that legal, compliance, supervision or customer acquisition costs remain constant at scale. Those are the costs that grow with headcount, and they grow.

Court absorption is the real ceiling on throughput, which is why volume above the current rung spreads across workflows and across small claims dockets in many states rather than stacking in a single venue. Actual costs will be measured by cohort and by jurisdiction as matters resolve, and the model will be rebuilt on those measurements rather than on these assumptions.

§ 04The defensibility

Why can’t everyone do this?

This is the first question any partner asks, so here is the answer before it is asked. Six things stand between this machine and a copy of it. One of them is an open legal question, and it is marked as one.

01Cost position

Speed asymmetry

Violators scale at machine speed. Conventional enforcement scales at human speed: one intake, one investigator, one filing at a time. The unit cost of assembling an evidenced matter here is a rounding error against manual intake, which is what makes a 200 matter month economic at all.

200matters / month, current model
02Time lead

18-month build runway

Every agent, migration, filing template, court-specific complaint format, e-recording path and service integration was purpose-built over eighteen-plus months. None of it is off the shelf. A well-funded team could rebuild it; the moat is the eighteen months and the accumulated jurisdictional detail, not impossibility.

18months built
03Compounds

Compounding case database

Every violation logged. Every entity researched. Every outcome recorded. The database of violators, their assets, their call patterns and their litigation history compounds with each matter filed. Year three is materially more valuable than year one.

100%of outcomes retained
04Open question

Standing structure

In March 2026 a federal court dismissed Nomorobo's TCPA honeypot case for lack of standing, holding that numbers maintained principally to generate litigation sit outside the statute's zone of interests. That decision highlights the risk rather than resolving it in our favour. Tollman's structure is designed to distinguish genuine property-owner communications from standalone corporate honeypots. That distinction has not yet been adjudicated and requires jurisdiction-specific counsel review before scale.

Unadjudicatedstructure, counsel review pending
05Cost position

Multi-workflow coverage

A single call may present more than one theory: § 227(b) where an artificial or prerecorded voice or qualifying autodialer is used without consent, and § 227(c) where a registered subscriber receives repeated solicitations. A state count may also be available. Whether more than one count survives, and whether a court permits cumulative recovery, is decided matter by matter. What the machine changes is that assembling the alternative theories costs the same as assembling one.

2+theories assembled per matter
06Time lead

Self-healing browser agent

Playwright and Claude monitor every outcome around the clock: DNC registrations, court filings, lien recordings, live listings. When a portal changes or a submission fails, the agent retries and repairs itself. Administrative failure does not page a human. Legal decisions still do.

24/7unattended administrative operation
04 · Nomorobo dismissal, March 2026, reported by TCPAWorld and the docket. Neither decision has been applied to a property-owner origination structure.

The question isn’t why can’t everyone do this. It’s why nobody did while violations went up 33x.

§ 05The objections

Every attorney raises the same nine things.

So they are answered here, in the order they usually arrive, before anyone has to ask. Each answer rests on a decided case, a filed statute or a rule of professional conduct. Where an answer rests on a modeling assumption instead, it says so and points to the case where that assumption is priced.

01Objection

“You will be labeled a professional plaintiff.”

397 serial plaintiffs drove the majority of TCPA litigation in 2025. Courts know the pattern and they do not like it.

The answer

Courts have drawn a line, and the structure is built to sit on the right side of it rather than to argue it away. Stoops and Nomorobo both turned on numbers acquired or maintained principally to attract calls. Claims here originate from unsolicited communications received by property owners and participating consumers at numbers that exist for the property or the person, and eligibility, consent history, DNC status, purpose of use and injury are reviewed before any demand issues. That distinction has not yet been adjudicated on these facts, and it is cleared with bar-admitted counsel state by state before matters are opened there. The matters a district judge ever sees are the screened federal band, and those arrive on a bar number after independent review.

Stoopsthe line courts drew
02Objection

“The standing argument gets weaker the more you file.”

At 200 cases a month the property owner framing holds. At 2,000 a court starts reading the pattern itself as the evidence of purpose, and the growth path on this page becomes the opposing brief.

The answer

That is the correct read, and it is why throughput is constrained by structure rather than by appetite. Standing quality degrades with scale if origination ever shifts toward generating contacts rather than receiving them, so the governing rule is a hard ceiling on matters per month per claimant entity. Growth comes from more genuine claimants, not from more contact per claimant: additional owned properties, and above that participating consumers who registered their own numbers and did not want the call. The standing argument and the scaling thesis have to stay congruent at every funding stage, and the per entity ceiling is set with counsel before the next rung is funded, not after.

Per entitymonthly ceiling, set with counsel
03Objection

“Self represented filings get scrutinized harshly.”

True in federal court, and the record is unkind. Andrew Perrong was sanctioned from the bench and ordered to write an apology letter.

The answer

That scrutiny is a federal court problem, and no federal case is ever filed without counsel. Small claims is a self represented forum by design: many states bar lawyers from appearing there at all, the record is a form and an exhibit set, and the docket runs on volume. The twenty percent that escalate carry a bar number, follow local rules, and arrive through the same channel as any other matter on the docket.

0federal filings without counsel
04Objection

“What if the defendant shows up and fights?”

A contested case costs time the economics do not obviously support.

The answer

Collectibility scoring runs before anything is filed. Well capitalized defendants score warm or cold and receive a demand letter only. The hot band is small operators, where an uncontested resolution is the likeliest outcome. How likely is a modeling assumption rather than an observed result, and it is priced as one: § 06.3 runs filed-matter default at 25, 50 and 75 percent across the three cases, and the downside column also carries a quarter of filed matters as contested at zero recovery. Where a matter is contested it reaches counsel as a complete evidence package, and counsel is compensated for that work separately from the contingency line.

25 / 50 / 75%default rate, priced across three cases
05Objection

“A default judgment is not money.”

The collectibility band that defaults is thin LLCs with no attachable assets. A judgment against an entity that dissolves is a piece of paper, and a model that books entered judgments as revenue is a model that has never collected one.

The answer

Agreed, which is why nothing on this page books an entered judgment as recovery. Published experience on small claims default collection runs between 25 and 40 percent. The model applies 30, the conservative middle, to every judgment entered, and every downstream figure on the site is built on the number after that write down rather than before it. Demand letter settlements carry no discount because they are paid in cash. Where permitted, a judgment may be recorded to create a lien against non-exempt real property owned by the judgment debtor. Priority, duration, collectibility and enforcement vary by jurisdiction and asset, which is exactly why the write down is applied to every judgment rather than to the ones that look difficult. The § 03 table carries the write down as its own line so it can be checked rather than taken, and § 06.3 prices collection at 10, 30 and 45 percent across the three cases.

30%collection applied to every judgment
06Objection

“Congress could weaken the TCPA.”

Statutory risk sits under the whole model.

The answer

The private right of action can only be removed by amendment, and Congress is moving the other way. PACRA was reintroduced on April 14, 2026 to extend do not call protection to businesses, lower the trigger from two calls to one, and reverse Facebook v. Duguid. State statutes sit outside federal reach entirely: Texas at $5,000 and Connecticut at $20,000. The reverse happens too, and we price for it: Florida gutted its own mini-TCPA with HB 761 in May 2023, narrowing the trigger and adding a fifteen day cure window, so Florida is worked as a federal and FDCPA jurisdiction rather than an FTSA one. Six workflows across independent statutes means no single amendment ends the business.

6independent statutes
07Objection

“They will claim consent.”

Consent is the standard TCPA defense and it defeats most claims.

The answer

No consent was ever given. The contact page attached to each seed number is informational. It carries no form, no opt in, no checkbox, and no invitation to call. The burden of proving prior express written consent falls on the defendant, and there is nothing on the record for them to point to.

Defendantcarries the burden
08Objection

“Section 227(c) requires two calls.”

A do not call registry claim needs more than one contact within twelve months.

The answer

The entity database records every contact from every caller. The 227(c) count is only raised once a second contact from the same entity is confirmed on the record. Prerecorded voice and autodialer claims under 227(b) carry no such requirement and stand on a single call.

§ 227(b)stands on one call
09Objection

“This looks like fee splitting and unlicensed practice.”

Rule 4-5.4 bars sharing legal fees with a non-lawyer, and Fla. Stat. § 454.23 makes practicing law without a license a third degree felony. A platform taking thirty percent of a recovery is the first thing the bar would look at.

The answer

Tollman is not a participant in anyone's legal fee. Every claim is held by the claimant, the party that received the call and carries statutory standing: an owner entity on the property matters, the individual consumer on the consumer product. The claimant brings its own claim as the injured party and takes its own recovery. Tollman is compensated for evidence, workflow and administrative services under a written agreement with that claimant, subject to applicable restrictions on assignment, fee sharing and legal services, and not out of counsel's fee. No claim is treated as assigned to the platform in any jurisdiction unless assignment is validated for that statute and that state. Counsel's contingency is paid by the client from the client's recovery under a written engagement, and counsel retains sole professional judgment over what is filed, what is settled and what is declined. Nothing pre-suit is legal advice to a third party: demand letters issue from the claimant on its own behalf, and small claims is a self represented forum in which a party appearing for itself is not practicing law. That structure is the argument, not the clearance. A written ethics opinion from bar-admitted regulatory counsel in each filing state is required before any fee arrangement is operationalized, and no percentage is fixed until those opinions are in hand.

Written opinionrequired in every filing state

If a tenth objection exists, we want it on the table before the next case is filed, not after.

Read the partnership terms
§ 06Liquidity

The exit.

The consumer rung is priced first, because it is the only version of scale that makes the standing argument stronger rather than weaker. Three structures then sit on top of the same pipeline, and they are not mutually exclusive: the fund finances the case volume, the license monetizes the software, and the consumer product supplies the violations.

§ 06.1The consumer rung

10,000 users. One exit.

The seeded network proves the machine. The consumer product is what makes it scale without the legal predicate degrading: every user is a real person who genuinely did not want the call, holding a number they use, on a registry they joined themselves. Volume stops coming from more publication and starts coming from more plaintiffs.

At ten thousand active users the platform is no longer a case portfolio. It is a distribution business with a statutory revenue line underneath it, and it prices accordingly.

Active users
10,000
Recovered matters / user / year
7.5
Realized recovery / matter
$600
Platform share
30%
Platform revenue, modeled
$13.5M
$1,350 of platform revenue per active user per year, from 7.5 recovered matters at the $600 realized average in § 03. That is roughly seven percent of the unwanted calls a single line receives in a year converting to a recovered matter, at the national average of about 106 unwanted calls per line. Modeled at stated assumptions; not a record of resolved matters.
Conservative5x
$67.5M
Base8x
$108M
Strategic15x
$202.5M
Revenue multiples, not ARR multiples. The underlying revenue is realized contingency recovery: non-contracted, collection dependent and priced at a discount to recurring subscription revenue by any buyer who reads the schedule. The range is stated rather than a point estimate for that reason.
Counsel equity
$5.4M
5% at base
$10.13M
5% at strategic

For reviewing pre-packaged complaints and enabling federal court filing. Passive equity, active returns. Any equity participation is documented separately from the contingency engagement and is subject to the ethics review set out below.

§ 06.2What capital converts into
Capital deployed
$5M
Matter throughput
2,000 / mo
Portfolio contribution margin
$11.3M
Modeled linear at the unit economics in § 03: $471 of contribution margin per matter, after certified mail, court filing and service at a base venue, and after a 30% collection rate applied to every judgment entered. Variable cost per matter does not move with volume because there is no headcount in that loop; legal, compliance, supervision and acquisition cost are not held constant and are not modeled here. Capital and court absorption are the binding constraints at this scale, which is why throughput is spread across six workflows and small claims dockets in multiple states rather than concentrated in one venue.
Where the money actually lands
Gross claimed exposure
24,000 matters at the $1,500 statutory ceiling. What is demanded, not what is owed.
$36.0M
Gross settlement and judgment proceeds
Settlements at $700 plus judgments entered at $1,500 face value.
$24.5M
Cash realization
Settlements convert in full. Judgments convert at the modeled 30%.
$14.4M
Variable case costs
Processing, certified mail, and filing and service at a base venue.
($3.1M)
Contribution margin
The figure carried on the plate above and in § 03. This is where the model currently ends.
$11.3M
Legal and collection expense
Counsel review, contested matters, appearance time, post-judgment enforcement.
Not modeled
Corporate operating expense
Engineering, compliance, supervision, acquisition, insurance and reserves.
Not modeled
Platform EBITDA or distributable proceeds
Measured by cohort once matters resolve. Nothing on this site reports it.
Not modeled
LP share of distributable proceeds
Set by the definitive waterfall, after preferred return, fees and reserves. It cannot be derived before the line above exists.
Not modeled
Platform share of distributable proceeds
Same constraint. What the platform keeps is what survives the waterfall, not a percentage of margin.
Not modeled
Modeled at the funded rung, 24,000 matters a year, on the management case assumptions. Every line above the margin is derived from the § 03 table; every line below it is left blank because there is no operating history to derive it from. Contribution margin is not EBITDA and is not distributable proceeds.
Portfolio, partner, platform
Portfolio contribution margin
$11.3M

Earned by the claim portfolio. Not revenue of the platform, and not distributable cash.

Notional LP allocation, 70%
$7.91M

A split of the margin above, shown to size the partner's position. Not a projected distribution.

Notional platform allocation, 30%
$3.39M

The same split from the other side, before every expense line marked not modeled.

An illustrative allocation of portfolio contribution margin at the funded rung, before the expense lines shown as not modeled above and before any preferred return, management fee, reserve policy or waterfall the definitive documents may carry. These are not projected distributions and should not be read as distributable cash. Portfolio proceeds are recovered on claims held by the claimants, partner allocations are computed from those proceeds, and platform revenue is a third figure again. The site does not net them together anywhere.
What the $5M buys
01$1.25M
Case filing and service reserve

Court fees and service on filed matters, carried from filing to collection.

02$750K
Counsel and contested-matter reserve

Review retainers, appearance time and the contested share of the docket.

03$1.0M
Consumer acquisition and number deployment

The consumer rung in § 06.1, where volume stops depending on seeding.

04$1.0M
Engineering and compliance

Jurisdictional expansion, filing integrations, evidence and audit controls.

05$500K
Collection and enforcement reserve

Post-judgment recording, levy and garnishment on entered judgments.

06$500K
General working capital

Operating float across the collection lag described in § 06.3.

An illustrative allocation of a $5M raise, not a committed use of proceeds. The categories are the ones the model actually consumes capital through; the split between them is set in the definitive documents and is expected to move with the venue mix and the jurisdictions opened first.
Path 0101 / 03

Litigation fund

Raise against the case portfolio the way a litigation finance partner already underwrites mass claims.

Raise
$5M
Deployed across
TCPA · FDCPA · CIPA
Category target
2.5 to 4x resolved
Category horizon
18 to 36 months
Split
70% LP / 30% platform
Not published
No investor return period is stated until a cohort level monthly cash flow model exists. The category target and horizon above describe the vehicle class, not a Tollman projection.
Structure comparable: Burford Capital, Omni Bridgeway
Path 0202 / 03

SaaS licensing

License the autonomous enforcement pipeline to plaintiff firms that already want the volume and cannot staff it.

Price
$2,500 / firm / month
Included
Evidence, research, complaints
At 50 firms
$125K MRR
ARR
$1.5M
Multiple
10x ARR, regtech comp
$15M
exit at fifty licensed firms
Multiple comparable: public regtech / legaltech SaaS
Path 0303 / 03

Consumer · RingBounty

The consumer-facing version. Users opt in, we register their numbers, and the system screens every answered call for a potentially actionable statutory claim.

User acquisition
Opt-in, DNC registered
User keeps
The majority of recovery
Counsel
Contingency, by engagement
Proof point
10,000 users
Path
Series A → strategic
Strategic
acquisition by legaltech or telecom
Comparable: LegalZoom, public at roughly $4.5B on debut, 2021
§ 06.3Sensitivity

Three cases. One is ours.

Every figure elsewhere on this site runs on the management case in the right-hand column. It is an illustrative management case and not a record of validated operating performance, and it is the most favourable of the four on two variables: it assumes every filed matter reaches entry of judgment, because matters are scored for default probability before they are filed, and it carries no contested rate for the same reason.

That screening assumption is the single thing in this model most worth testing, so the base case does not grant it. Under base assumptions the same pipeline earns $120 a matter rather than $471, and the funded rung returns $2.88M rather than $11.3M.

The downside is negative, and it is negative for one reason: filing cost. At a $500 venue with a tenth of entered judgments collecting, the filing decision inverts and the economics live entirely in the demand letter. The unconstrained arithmetic is shown because the constrained version is an operating decision rather than a projection.

Cash conversion

Contribution margin earned in a period is not cash in that period. Demand settlements clear in weeks. Entered judgments convert over the collection window in the table above, six to twenty four months depending on the case, and only where the debtor holds reachable assets. Working capital has to carry the filing and service cost of every matter from the day it is filed to the day it collects, which is why the raise is sized on deployment rather than on margin.

AssumptionDownsideBaseUpsideManagement
Demand settlement rate15%35%60%60%
Average settlement$350$550$700$700
Default rate, filed matters25%50%75%100%
Judgment cash collection10%30%45%30%
Filing and service$500$300$135$300
Contested rate, filed matters25%10%5%0%
Average collection time24 mo12 mo6 mo12 mo
Contribution margin / 100($35,761)$12,011$54,936$47,098
Per matter($358)$120$549$471
Annualized at 2,000 / mo($8.58M)$2.88M$13.18M$11.30M
Per 100 matters. Settlements are modeled as cash on receipt. Contested matters are modeled at zero recovery and carry counsel expense that is not included in any column. Filing and service is charged only on matters actually filed, at the venue bands in § 03.3. Illustrative management case, not validated operating performance.
§ 06.4For counsel

Twenty percent reach your desk.

Eighty percent of the pipeline is modeled to resolve outside the federal filing workflow. Demand letters, small claims filings, default applications, lien recording and enforcement run as administrative work in forums where a claimant appears on their own behalf. Where a jurisdiction requires counsel for any of that work, restricts who may appear, or requires an entity to be represented, counsel is engaged for it, and that share sits inside the eighty rather than outside it. The determination is made state by state before a matter is filed there, not after.

The twenty percent that escalate to federal court are the ones that land on a desk. The scorer ranks every violation on asset value, violation profile and default probability, and only the top band moves up. Counsel receives a structured draft package: source evidence, proposed claims, entity records and jurisdictional inputs. Counsel independently evaluates, revises, approves or rejects each filing. Nothing issues under a bar number that counsel has not decided to issue.

So the proposition is not “help us file everything.” It is “screen a thousand violations down to the twenty worth federal court, deliver them pre-built, and handle everything else.”

What reaches you
  • Federal matters only, the scored top band
  • A complete draft package for independent review, revision, approval or rejection
  • The occasional contested matter, evidence already assembled
  • Court awarded fees, handled under the engagement agreement and applicable law, not included in modeled counsel compensation
What does not
  • Demand letters, sent and tracked without you
  • Small claims filings and defaults, where the forum permits the claimant to appear
  • Evidence collection, entity research, asset investigation
  • Lien recording, levy and enforcement

The machine does the work. Counsel gets the cases worth their time.

Fee shifting

The FDCPA provides reasonable attorney fees and costs to a successful plaintiff. Certain Texas and California causes of action may also permit fee recovery where their separate statutory requirements are satisfied. The TCPA itself does not provide a general prevailing plaintiff attorney fee remedy, so no TCPA fee award is included anywhere in the model.

Structure is whatever clears your bar: formal referral agreement or co counsel.

The arithmetic
200violations captured / month
×20%escalate to federal
×$600realized recovery / matter
×10%contingency
=
$2,400
per month on the escalated band
As counsel of record on the full portfolio
$12,000
At 500 violations a month, escalated band
$6,000
Fee shifting on contested matters
Separate, not modeled
What the contingency line excludes
  • Hourly review retainers and minimum monthly fees
  • Compensation for contested matters and appearances
  • Court awarded fees, handled under the engagement agreement and applicable law, not included in modeled counsel compensation
  • Any equity participation, documented separately

Whatever compensation structure counsel requires sits on top of the contingency line, not inside it. The figure above is the contingency alone.

Recovery structure
  • ClaimantThe participating owner or consumer who holds the claim and possesses statutory standing
  • Tollman platformProvides evidence, workflow and administrative services under a written agreement, subject to applicable restrictions on assignment, fee sharing and legal services
  • CounselRepresents the claimant where required, under a separate engagement agreement

Percentages are set out in the partner memorandum rather than here, and are not fixed until the opinions below are in hand.

Ethics review, before operationalizing

Revenue sharing arrangements are subject to state bar ethics rules which vary by jurisdiction. A written ethics opinion from bar-admitted regulatory counsel in each filing state is required before operationalizing any fee arrangement. This is infrastructure. The legal structure wraps around it.

Recovery averages are modeled at the assumptions set out in § 03 and are not a record of resolved matters. The counsel line runs on $600 realized per matter, after the 30% collection rate applied to entered judgments, not on the gross average. Realized recovery mix and volume are reported monthly against the docket once matters resolve. Fee shifting awards on contested matters sit on top of this line and are retained by counsel.
Representation, appearance rights and the unauthorized practice of law are governed state by state. Nothing here represents that a filing may be made, a forum entered or a matter handled in any jurisdiction without locally admitted counsel where that jurisdiction requires one. Each filing state is cleared with bar-admitted counsel in that state before matters are opened there, and no fee arrangement is treated as settled until the written opinions described above are in hand. Fla. Stat. § 454.23; see § 05, objection 07.
01Firms of record

Every federal matter issues under one bar number, so the scored band from this pipeline is a single firm’s docket rather than a network’s. There is no referral panel behind this and no list being worked. The seat is filled once, and the licensing path above is a separate software business that does not touch it.

§ 07The record

The evidence is public record.

This page separates the two kinds of number and never blends them. Everything below is external record: a filing, a docket, a regulator's report or a published index. Every one is cited. The recovery, throughput and return figures elsewhere are modeled at stated assumptions and are labeled as modeled wherever they appear.

01
2,588

TCPA suits filed January through November 2025.

02
$1.5B

Settlement in Bartz v. Anthropic, 2025. The price the market now puts on training-data liability.

03
50B

AI crawler requests processed per day on Cloudflare alone.

04
1,641

Digital wiretapping suits filed across 28 states by February 2025, 83% of them in California under CIPA.

05
$2B

United States RegTech investment in Q1 2026, up 28% year over year.

FinTech Global RegTech deal tracker, April 2026
06
$5,000

Maximum civil penalty per violation under Texas Bus. & Com. Code ch. 302, as amended by SB 140, with the state private right of action effective September 1, 2025.

07
$20,000

Maximum penalty per violation under Connecticut SB 1058, signed June 2023 and effective October 1, 2023. The highest state telemarketing penalty in the country, and enforced by the state rather than through a private award.

08
PACRA

Reintroduced April 14, 2026 by Senator Durbin with Representatives Schakowsky and Mullin. Extends registry protection to businesses, drops the private right of action trigger from two calls to one, and restores the pre-Duguid autodialer definition. Introduced, not enacted.

09
Artificial

FCC ruling, February 2024: an AI generated voice is an artificial voice under the TCPA. A synthetic call placed without consent violates the statute regardless of how it was dialed.

10
70%

Share of debt collection suits in state courts resolved by default judgment because the defendant never appeared. Different case type, different defendant population: this is context for how state courts behave when nobody answers, not evidence of a TCPA default rate. Filed-matter default is modeled at 25, 50 and 75 percent in § 06.3.

11
$6,790

Collected on the specific TCPA and do not call forfeiture orders covered by the cited FOIA response, which total $208.4M and run from 2015 through March 2019. Not a figure for agency collections generally, and not a statement about any period outside that response. The FCC refers unpaid forfeitures to the DOJ, which does not prioritize them.

Wall Street Journal FOIA request to the FCC, reported March 2019; Kelley Drye CommLaw Monitor on referral authority
12
$19.3B

Penalties paid by banks in 2024 across consumer-protection actions.

FinTech Global penalty tracker, 2026
13
2.3B

Unwanted robocalls placed per month in the United States, counting the telemarketing and scam categories only. Total robocall volume is higher, at 4.25B, but includes consented alerts and reminders.

14
70+

Active AI copyright suits pending in United States courts in 2025, each carrying statutory ceilings of $150,000 per infringed work.

Bartz v. Anthropic and related dockets; Copyright Alliance case tracker, January 2026
15
100+

TCPA class actions filed in March 2026 alone.

TCPAWorld, March 2026
Verification

Each citation links to the publisher’s own page for the figure wherever that page is stable. Where it is not, the citation stands unlinked rather than pointing at a summary of it, and the underlying report, docket or filing is available on request with case numbers and dates.

Request the case brief
0unwanted robocalls placed since you opened this page

The violations are happening right now. The gate determines who collects.

Every hour that passes is violations being committed against property you own, numbers you control and rights you already have. The machine is built. The only open question is whether you’re running it.

One counsel partnership · Litigation finance · Investor inquiries
Tally runs at 887 per second, derived from the 2.3B monthly telemarketing and scam robocalls that made up roughly 55 to 60% of U.S. robocall volume through 2026. Source: YouMail Robocall Index, June 2026. Total robocall volume, including consented alerts and reminders, was 4.25B; that larger figure is not used here.