From the Performance Marketing Insider archive. Originally published March 2019. Revisited October 2026.

Bot Form Fills Are Destroying the Lead Generation Industry. What Can Be Done?

Fake leads came with real phone numbers attached, and real people got the calls. Consumer advocates are still citing this post in front of the FCC.

By Pesach Lattin

This post first ran on Performance Marketing Insider (performinsiders.com), the affiliate and lead generation trade site Pesach Lattin published from 2011 to 2020. The original text was lost when that site went dark. This page sits at the same address the old links point to, keeps the original headline and date, rebuilds the subject from the public record, and says what happened next.

This 2019 post is the most-cited thing Performance Marketing Insider ever published, and not by the industry. It shows up in filings and libraries from the Electronic Privacy Information Center, the Consumer Federation of America, which cited it in 2022 comments to the FCC on robotexts, the National Consumer Law Center and Consumer Action. The people fighting robocalls understood the point faster than the people selling leads.

The problem

A lead is supposed to be a person who asked to hear from you. A bot form fill is software submitting that form instead, often with a real person's name and phone number scraped from somewhere else. The lead buyer pays for it. The call center dials it. And the human whose number it was gets a call they never consented to, which under the TCPA can cost $500 to $1,500 per violation. The fraud hits the buyer's wallet and the consumer's phone at the same time.

What could be done, then and now

The fixes in 2019 were consent certificates, session replay, bot screening and, above all, knowing who generated the lead. The industry built tools. TrustedForm and Jornaya became the standard for proving a consumer actually filled out a form. In December 2025 ActiveProspect launched bot detection in TrustedForm, and its CEO said some sites showed almost entirely bot-submitted leads. In January 2026 ActiveProspect bought Jornaya from Verisk, putting the two main consent-proof vendors under one owner.

How it aged

Regulators tried. In December 2023 the FCC adopted a one-to-one consent rule meant to stop a single form from authorizing calls from dozens of sellers. On January 24, 2025, three days before it took effect, the 11th Circuit vacated it, and the FCC later restored the old rules. The bots did not need a court ruling. In 2026 the problem in this headline is bigger, the regulatory fix is dead, and the answer is still the one from 2019: if you buy leads you cannot trace, you are buying the lawsuit too.

This page rebuilds a March 2019 Performance Marketing Insider post whose original text is not available. Facts come from the 11th Circuit's 2025 decision as analyzed by Kelley Drye and Morrison Foerster, Womble Bond Dickinson on the FCC's repeal, ActiveProspect's own statements, and TCPAWorld. Disclosures: the author co-founded LeadsCon; Troutman Amin, which publishes TCPAWorld, underwrites some of the author's ADOTAT work; Anura's Rich Kahn is a source on other ADOTAT reporting.