Court Grants Final Approval to $9.95 Million Gen Digital TCPA Settlement Over Norton and LifeLock Robocalls

The bottom line: prerecorded calls to wrong numbers remain one of the most costly and predictable sources of Telephone Consumer Protection Act (TCPA) liability.

Here is what happened

According to the final order, plaintiff Michelle Jackson filed a class action complaint against Gen Digital on February 18, 2025, asserting claims under the TCPA, 47 U.S.C. § 227.

The procedural history is short:

1. December 17, 2025: The parties signed a settlement agreement after mediation before a retired judge, Hon. Diane M. Welsh.
2. December 19, 2025: The parties filed the agreement with a motion for preliminary approval.
3. January 28, 2026: The court granted preliminary approval.
4. March 9, 2026: The plaintiff moved for attorneys' fees, costs, and an incentive award.
5. June 3, 2026: The plaintiff moved for final approval.
6. July 14, 2026: The court held the final fairness hearing and entered the final order.

The order states that it is not a finding on the validity of the claims asserted. Gen Digital resolved the case through settlement.

You can read the order here: Jackson v. Gen Digital final approval order.

The settlement class

The court certified, for settlement purposes only, a class of all persons in the United States:

1. to whom Gen Digital placed, or caused to be placed, a call regarding a LifeLock or Norton account,
2. directed to a cellular telephone number not assigned to a person who has or had a LifeLock or Norton account,
3. using an artificial or prerecorded voice,
4. from February 19, 2021 to October 30, 2025.

The terms

According to the order:

1. Gen Digital established a $9,950,000 non-reversionary fund. Non-reversionary means no unclaimed money goes back to the defendant.
2. Notice and administration costs are paid from the fund first.
3. The court awarded class counsel $3,316,666.66 in fees and $15,387.66 in costs.
4. The class representative receives a $15,000 incentive award.
5. Each class member who submitted a valid, timely claim receives payment under the agreement. Checks become void no fewer than 120 days after they are issued.

No class member objected to the settlement or the fee request. Seventeen people asked to be excluded.

The law

Section 227(b)(1)(A)(iii) of the TCPA prohibits calls to cell phones using an artificial or prerecorded voice without the called party's prior express consent, unless an exception applies. A customer's consent does not extend to a stranger who later has that number. When a number is reassigned or entered incorrectly, the new user has not consented.

Why it matters

This class is defined entirely by wrong numbers. The calls concerned real customer accounts, but they reached people who were not customers. That is a common pattern in account servicing, renewals, and collections. Similar wrong number settlements continue to appear, including the recent Concora Credit settlement.

The fee award alone was more than $3.3 million. Compliance controls that prevent wrong number calls cost far less.

What this means for you

1. Check numbers against the Federal Communications Commission's Reassigned Numbers Database before placing prerecorded calls.
2. Treat a "wrong number" response as an immediate stop for automated and prerecorded calls to that number.
3. Do not rely on account records alone. Confirm that the person you reach is the account holder.
4. Review how long contact data stays in your systems before it is verified again.
5. Hold vendors that call on your behalf to the same requirements.

Verify the number. Stop when you are told it is wrong. Document both steps.