O’Reilly $18.8M TCPA Settlement: Reassigned Numbers and DNC Risk Lessons

O’Reilly $18.8M TCPA Settlement: Reassigned Numbers and DNC Risk Lessons

Your CRM may show a valid number, an old customer record, and prior consent for marketing texts. But it cannot confirm who uses that number today.

That issue is central to Bryan v. O’Reilly Automotive, Inc., where O’Reilly agreed to a proposed class settlement capped at $18,842,577 over allegations that marketing texts were sent without consent to numbers on the National Do Not Call Registry after those numbers had been reassigned to new users.

The issue centers on reassignment. A number may have belonged to a customer who consented to messages, then later been assigned to someone else. The new user could receive texts tied to the previous customer’s record.

That creates a data problem before it becomes a compliance problem.

The court granted preliminary approval on June 29, 2026, with final approval scheduled for November 5, 2026. O’Reilly denies the allegations, and the court has not found a TCPA violation.

For outbound teams, the practical question is: How do you know yesterday’s consent still belongs with today’s phone number?

Why Reassigned Numbers Put Old Consent Records at Risk

Phone consent belongs to a person and a specific interaction, but your CRM may retain it after that person stops using the number. If the number is permanently disconnected and reassigned, your database may still show valid formatting, stored consent, text capability, and prior engagement without indicating that a new subscriber now uses the number now uses the number.

The FCC created the Reassigned Numbers Database to help callers determine whether a number was permanently disconnected after a date supplied with the query. The database may also support a TCPA safe harbor in certain circumstances when callers receive a “no” response and meet the applicable FCC requirements.

RND data does not identify the current subscriber, but it provides another data point for evaluating whether older consent remains reliable. Teams using older customer or lead records should understand how reassigned number TCPA risk develops after a number changes hands.

What the O'Reilly Settlement Actually Covers

The court-authorized settlement covers people whose numbers were on the National Do Not Call Registry for at least 30 days, who received more than one O’Reilly text within 12 months, and whose numbers had been reassigned before those messages.

The alleged conduct occurred from April 15, 2021, through June 29, 2026. Claims may be denied if the recipient made an online or in-store O’Reilly purchase within the previous 18 months, which could affect the consent analysis.

The $18,842,577 settlement is an aggregate cap covering valid payments, administration costs, any service award, and attorney fees and expenses. Class counsel may request up to $6,280,859 in fees and costs, subject to court approval.

The settlement terms explain who may fall within the class, but they do not resolve every legal question surrounding DNC claims based on text messages.

The Legal Treatment of DNC Text Claims Is Still Contested

The O’Reilly settlement should not be read as a court ruling that every marketing text to a DNC-listed number creates TCPA liability.

Another 2026 case makes that especially clear.

On July 14, 2026, the U.S. Court of Appeals for the Seventh Circuit decided Steidinger v. Blackstone Medical Services. The court held that the private right of action under Section 227(c)(5) of the TCPA does not cover unwanted text messages because that provision refers specifically to receiving telephone calls.

The O’Reilly settlement received preliminary approval on June 29. That was about two weeks before the Seventh Circuit issued Steidinger.

The two developments should make compliance teams cautious about broad conclusions. The legal treatment of text messages under different TCPA provisions and regulations can depend on the claim and jurisdiction.

Your operational takeaway does not require predicting how every court will rule.

Keep phone ownership changes, consent records, DNC status, opt-outs, and campaign rules visible before outreach begins.

How Wrong Number Texts Can Enter a Marketing Workflow

Reassigned-number problems rarely arrive labeled as reassigned-number problems.

Retail Loyalty and Reactivation Lists

A customer joined a loyalty program two years ago and entered a mobile number. The customer later changed numbers.

Your CRM still stores the original number and consent record.

A reactivation campaign sees a valid mobile number and sends an offer. The message reaches the new subscriber instead.

Franchise Lead Lists

A franchisor sends older lead records to several locations.

One lead originally requested information and supplied a phone number. Months later the number changes hands.

The franchise location receives the lead with no warning that the phone history may have changed since consent was collected.

Call Center Campaign Files

A client sends a call center a file containing thousands of customer records.

The call center sees names, numbers, and consent dates. It may have no direct relationship with those customers and no way to know whether each number still belongs to the same person.

These cases show why checking whether a phone number works is different from checking what happened to that number after consent was collected.

5 Checks Before Calling or Texting Older Phone Records

Teams handling older leads or customer records should complete these checks before adding them to an outbound campaign.

1. Confirm the Consent Source and Date

Verify where consent came from and when it was obtained. Do not rely on a CRM creation or file upload date unless it reflects the relevant customer interaction.

2. Review the Phone Number

Check validity, line status, carrier, and line type. A disconnected result may justify removing or reviewing the record. An active result does not prove the intended customer still controls the number.

3. Compare the Number With the Consent Date

Submit the number and approved consent or last-known-contact date to the RND. A later permanent disconnection may indicate that the original record requires further review.

4. Run DNC and Internal Suppression Checks

RND and DNC screening answer different questions. Review applicable National and state DNC lists, internal do-not-contact records, opt-outs, revocations, and other campaign restrictions.

5. Save the Results

Keep enough information to reconstruct the decision, including:

• Phone number
• Consent source and date
• RND and DNC results
• Query date
• Campaign name
• Final action

This history helps compliance teams review complaints and confirm which checks were completed before outreach.

How Searchbug Can Check Reassigned Numbers and DNC Status Before Outreach

Two different checks can support this workflow because reassignment and DNC status are separate data questions.

Check Whether the Number Was Disconnected After Consent

Searchbug’s Reassigned Numbers Database API can submit a phone number and approved date to the FCC’s RND.

The query may return yes, no, or no data based on available FCC records.

A result can help your team decide whether an older phone record should continue through the campaign process or move to another review step.

The RND does not identify the current subscriber. It does not prove who owns the number today. It also does not replace consent records or other TCPA controls.

Check DNC Status Before the Record Reaches Outreach

Searchbug’s Do-Not-Call List API can help screen phone numbers for applicable DNC data as part of a pre-campaign workflow.

Teams can use that result alongside RND data, internal suppression lists, opt-out records, and campaign rules.

A DNC result does not determine whether an exemption applies or decide whether a particular call or text is lawful. Compliance or legal teams still need to apply the company’s policies to the specific campaign.

Used together, the checks answer two different questions:

Did something happen to this number after consent was obtained?

Does the number now appear on a list that affects outreach?

That distinction matters when teams are working with older customer records or purchased lead files.

TL;DR

O’Reilly agreed to a proposed $18.8 million settlement over alleged texts to reassigned numbers on the National DNC Registry. Final approval is pending, and the court has not found O’Reilly liable. Teams should verify consent, check for reassignment, screen DNC and internal suppression lists, and retain results. Searchbug’s RND API and DNC Check can support these checks but do not replace legal review.

Create a free Searchbug API Test Account with $10 in credits to test the relevant checks with your workflow. Teams reviewing larger files or working without an API can also use Bulk Processing.

Editorial Note: This article provides general information and does not constitute legal advice. TCPA requirements and the treatment of text messages can depend on the claim, jurisdiction, consent record, technology used, and other facts. Organizations should consult qualified counsel when setting outreach and suppression policies.