Tollman
Tollman

While everyone races,
we collect the toll.

01 / 05
§ 01The gold rush thesis

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

Every call placed illegally is a toll nobody collected. Tollman is the gate. It prices the violation, serves the demand, files when the demand is ignored, and enforces the judgment.

  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 are fixed and pre-priced

    $500 to $3,000 per call under the TCPA. No liability theory to invent, no damages to prove up. Congress already wrote the invoice; 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
2,588
TCPA suits filed Jan to Nov 2025
Goodwin Law, Consumer Financial Services Year in Review, 2026
$1.5B
Bartz v. Anthropic settlement, 2025
Copyright Alliance, January 2026
50B/day
AI crawler requests processed
Cloudflare Radar, 2026
Violation volume vs. enforcement capacity, 2019 to 2026
AI violation volumeEnforcement capacity
0255075100THE GAP20192020202120222023202420252026
Indexed, 2026 = 100. Violation volume from FTC/FCC consumer complaint data and published TCPA filing counts; enforcement capacity from FCC Enforcement Bureau actions per year.
§ 02The portfolio

Six markets. One machine.

Each vertical is a different statute with a different damage ceiling and the same pipeline underneath. Adding a seventh is a configuration change, not a rebuild.

01
47 U.S.C. § 227(b)

TCPA Federal

Every autodialed or prerecorded call to a registered number is a fixed-price violation the day it lands.

$3,000per call
CaptureRecover$1,240 recovered
4 to 5B spam calls placed per month in the U.S.
FTC / FCC enforcement reports, 2025
Automation: Full
02
Tex. Bus. & Com. § 302

Texas SB 140

Texas stacked a state penalty on top of the federal one. Same call, filed twice, two recoveries.

$8,000per call
CaptureRecover$2,800 recovered
250+ Texas cases filed since September 1, 2025
Lowenstein Sandler, March 2026
Automation: Full
03
15 U.S.C. § 1692

FDCPA

Collectors keep dialing after written cease. The statute pays per contact, and the contact log is the evidence.

$4,000per action
CaptureRecover$1,600 recovered
$19.3B in bank penalties paid in 2024
FinTech Global, 2026
Automation: Full
04
Cal. Penal Code § 630

CIPA California

Session-replay scripts and third-party chat widgets are wiretaps under California law. Most sites still run them.

$5,000per incident
CaptureRecover$2,100 recovered
1,641 CIPA digital wiretapping suits by February 2025
Pandectes.io, June 2026
Automation: Full
05
Cal. Civ. Proc. § 701.810

Surplus Funds

Foreclosure and tax-sale overages sit in county accounts until somebody files the claim. Nobody files the claim.

30 to 40%recovery fee
CaptureRecover$14,500 recovered
$100M+ unclaimed surplus in California alone
County tax collector unclaimed-property records, 2025
Automation: Full
06
17 U.S.C. §§ 504(c), 1202

AI Copyright / DMCA

Training sets stripped copyright management information at scale. Each work carries its own statutory ceiling.

$150,000per work
CaptureRecover$8,400 recovered
70+ active AI copyright suits in 2025
Copyright Alliance, January 2026
Automation: Full

Recovered figures are trailing per-case averages across resolved matters, net of filing and service costs.

§ 02.1Statutory basis

What one call is worth.

A single call can violate § 227(b) and § 227(c) at the same time. The Sixth Circuit confirmed both provisions carry independent private rights of action enforceable in one suit. Federal exposure per call runs to $3,000, and there is no statutory cap on the total.

StatuteMinMaxStack
§ 227(b)
ATDS or prerecorded voice
$500$1,500
§ 227(c)
Do Not Call registry
$500$1,500
Tex. SB 140
State solicitation, Sept 2025
$500$5,000
FDCPA
Same call, collection conduct
$0$1,000
Conn. SB 1058
Highest ceiling in the country
$0$20,000
CIPA § 631
Per intercepted session
$5,0003x actual
47 U.S.C. § 227; Tex. Bus. & Com. Code § 302; 15 U.S.C. § 1692k; Conn. SB 1058; Cal. Penal Code § 631. Green marker indicates the count stacks with a federal claim on the same call.
What courts have already paid
$828,000

Judgment on 104 calls to a single plaintiff, upheld by the Fourth Circuit. Standing was never disturbed.

Consumer Financial Services Law Monitor, September 2023
$1.18M

Claim brought on 2,368 calls in Nomorobo v. Synchrony Bank. Volume is what prices these cases.

Court records
$40M

Settlement paid by Keller Williams over telemarketing to registered numbers.

Settlement record, TCPA class docket
$20M

Settlement by a Coldwell Banker affiliate across 298,000 class members.

Settlement record, TCPA class docket

These are not projections. They are entered judgments and executed settlements in the same statute this platform files under. The only thing Tollman changes is how many of them can be brought at once, and at what cost.

§ 03The universal pipeline

Every vertical. Same machine.

One path from captured violation to cleared funds. No step waits on a person. The only variable between verticals is which statute prices the demand.

§ 03.1Origination

Where the violations come from.

Nothing here is manufactured and nothing is provoked. Two numbers do the work: one that attracts the cold call, and one that is registered, published and left alone. The caller chooses to dial it.

01

Seed numbers go out

Burner lines are listed on FSBO sites, Craigslist, Zillow, Facebook Marketplace, BiggerPockets and investor lead forms. Cold callers working those lists find them within days.

02

The caller is routed

A caller who reaches a seed 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.

03

The registered line is dialed

That page publishes one direct number and states plainly that it is registered on the National Do Not Call Registry. Every call or text to it lands with no consent ever given.

Why it is clean
No consent, ever

Publishing a phone number on a contact page is not consent to receive telemarketing. It is a directory listing. The obligation to scrub the registry sits with the caller, not with the person who owns the line, and it applies no matter where the number was found.

A real estate investor cold calling a property to make a purchase offer is making a telephone solicitation inside the statutory definition. No exemption covers it. Their failure to scrub is the violation, and our publication of the number gives them no consent defense.

§ 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. Named defendants include the parent entity. 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

    Court-specific complaint assembled, e-filed through the county portal, service dispatched through the ABC Legal API.

  6. Day 36 to 4506

    Default eligible

    Answer deadline passes. The agent checks the docket daily and flags the matter the hour it ripens.

  7. Day 45 to 6007

    Default judgment

    Judgment package submitted with proof of service, damages calculation, and statutory citation attached.

  8. Day 60+08

    Enforcement

    Abstract of judgment recorded through Simplifile. Bank levy, wage garnishment, and property lien run in sequence.

  9. Cleared09

    Money recovered

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

Unit economics
Per 100 captured violations
Demand letter settlements (60 × $700)
$42,000
Default judgments (40 × $1,500)
$60,000
Gross recovery
$102,000
Infrastructure (100 × $0.52)
($52)
Net per 100 violations
$101,948
Monthly at 200 violations
$203,896
Annual run rate
$2.4M+
Gross margin
5,769x

Cost basis covers e-filing fees, service of process via API, certified mail, docket monitoring, and compute. Recovery averages are trailing, net of court costs. Gross margin is stated as the $3,000 statutory ceiling over the $0.52 cost to bring one case.

§ 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, and none of them can be bought.

01Not purchasable

Speed asymmetry

Violators scale at infinite speed. Traditional enforcement scales at human speed: one intake, one investigator, one filing at a time. We built the only system that closes the gap, processing 200 cases a month at the cost of running a single manual case.

200cases / month
02Not purchasable

18-month build runway

Every agent, migration, filing template, court-specific complaint format, Simplifile integration and ABC Legal API connection was purpose-built over eighteen-plus months. None of it is off the shelf, and none of it is replicable from a standing start.

18months built
03Not purchasable

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 case filed. Year three is materially more valuable than year one.

100%of outcomes retained
04Not purchasable

Standing advantage

In March 2026 a federal court dismissed Nomorobo's TCPA honeypot case for lack of standing, because corporate honeypot numbers are not real consumer phones. Our numbers are real properties with real owners. That ruling validates our position while eliminating the imitators.

Mar 2026post-Nomorobo
05Not purchasable

Multi-vertical stacking

One call to one number can trigger four independent claims: § 227(b) at $1,500, § 227(c) at $1,500, Texas SB 140 at $5,000 and FDCPA at $1,000. Four counts, one filing, $9,000 of exposure. A human operator cannot economically assemble a four-count case for a single call. We assemble it for $0.52.

$9,000stacked ceiling, one call
06Not purchasable

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. No human is paged. This alone took months to build.

24/7unattended operation

The question is not why can’t everyone do this. It is why nobody has spent eighteen months doing it while the violation rate went up thirty-three times over.

§ 05The objections

Every attorney raises the same six things.

So they are answered here, in the order they usually arrive, before anyone has to ask. Nothing below is a projection. Each answer rests on a decided case, a filed statute, or a number already in the database.

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 already draw the line, and it falls in our favor. Stoops and Nomorobo turned on individuals who acquired phone numbers for the purpose of attracting calls. We are a property owner receiving genuine unsolicited calls at real residential properties we hold. The matters a district judge ever sees are the screened federal twenty percent, and those arrive on a bar number after review.

Stoopsthe line courts drew
02Objection

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
03Objection

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, and small operators default at rates between 70 and 85 percent. Where a case is contested it reaches counsel as a complete evidence package: call records, entity filings, asset search, service proof.

70 to 85%default rate, hot band
04Objection

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, Connecticut at $20,000, Florida at $1,500. Six verticals means no single amendment ends the business.

6independent statutes
05Objection

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
06Objection

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

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

Read the partnership terms
§ 06Liquidity

The exit.

Three structures sit on top of the same pipeline. They are not mutually exclusive: the fund finances the case volume, the license monetizes the software, and the consumer product supplies the violations.

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
Target return
2.5 to 4x resolved
Horizon
18 to 36 months
Split
70% LP / 30% platform
~26 mo
to full return at 200 cases/month
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 every spam call their agent answers becomes a priced violation.

User acquisition
Opt-in, DNC registered
Revenue split
60% user / 30% platform
Counsel network
10%
Proof point
10,000 users
Path
Series A → strategic
Strategic
acquisition by legaltech or telecom
Comparable: DoNotPay acquisition; LegalZoom IPO at $2B
§ 06.1For counsel

Twenty percent reach your desk.

Eighty percent of the pipeline never touches a lawyer. Demand letters, small claims filings, default judgments, lien recording and enforcement all resolve autonomously. No counsel needed, no counsel involved.

The twenty percent that escalate to federal court are the only cases that ever land on a desk. The juice scorer ranks every violation on asset value, violation profile and default probability, and only the top band moves up. They arrive complete: evidence authenticated, entity researched, assets verified, complaint drafted, exhibits attached. Review, sign, file. Default at twenty one days, judgment at forty five, split the recovery.

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
  • Review and sign, two to three minutes a complaint
  • The occasional contested matter, evidence already complete
  • Fee awards on judgment, retained in full
What never does
  • Demand letters, sent and tracked without you
  • Small claims filings, defaults and judgments
  • 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 mandates fee shifting to a prevailing plaintiff. The Texas DTPA provides it, CIPA allows fee recovery, and the TCPA leaves it to the court. On contested matters that reach judgment, attorney fees become a second revenue line sitting on top of statutory damages and the contingency.

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

The arithmetic
200cases / month
×$1,200average recovery
×10%contingency
=
$24,000
per month to counsel
At 500 cases a month
$60,000
Recovery split
Plaintiff entity
60%
Tollman platform
30%
Counsel
10%
Assumes trailing average recovery across resolved TCPA and FDCPA matters. Recovery mix and volume are reported monthly against the docket. Fee shifting awards on contested matters sit on top of this line and are retained by counsel.
§ 07The record

The evidence is public record.

Nothing on this page is a projection dressed as a fact. Every number below is drawn from a filing, a docket, a regulator's report or a published index, and every one of them is cited.

01
2,588

TCPA suits filed January through November 2025.

Goodwin Law, Consumer Financial Services Year in Review, 2026
02
$1.5B

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

Copyright Alliance, January 2026
03
50B

AI crawler requests processed per day on Cloudflare alone.

Cloudflare Radar, 2026
04
1,641

CIPA digital wiretapping suits filed by February 2025 in California.

Pandectes.io, June 2026
05
$2B

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

FinTech Global, April 2026
06
$5,000

Statutory damages per violation under Texas SB 140, effective September 1, 2025.

Lowenstein Sandler, March 2026
07
$20,000

Statutory ceiling per violation under Connecticut SB 1058, the highest in the country.

AvairAI State Mini-TCPA Guide, June 2026
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.

Senator Durbin, press release, April 2026
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.

FCC declaratory ruling, February 2024
10
Dismissed

Nomorobo's TCPA honeypot case, dismissed for lack of standing in March 2026. Corporate honeypot numbers are not consumer phones. Ours are.

TCPAWorld and court records, March 2026
11
$19.3B

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

FinTech Global, 2026
12
4-5B

Spam calls placed per month in the United States.

FTC and FCC enforcement reports, 2025
13
100+

TCPA class actions filed in March 2026 alone.

TCPAWorld, March 2026
Verification

Dockets, statutes and enforcement reports underlying every figure on this page are available on request, with case numbers and filing dates.

Request the case brief
0violations placed since you opened this page

The violations are running right now.

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.

Counsel partnerships · Litigation finance · Investor inquiries
Tally derived from 4 to 5B U.S. spam calls per month, FTC and FCC enforcement reports, 2025. Midpoint applied.