Jonathan Grabb, Ethics Counsel (Florida State Bar): ” The term ‘buying leads’ can mean different things depending on the context. For example, if you’re purchasing a database of names from public records—say, individuals denied social security benefits—that’s one type of lead. In this case, you could use that list for direct mail campaigns. This approach doesn’t require you to be a ‘qualifying provider’ or go through the legal hoops associated with lawyer referral services. However, for direct mail campaigns, you must disclose how you obtained the recipient’s information.
Now, if a marketing company offers you leads but refuses to disclose how they got them—citing trade secrets—that’s a red flag. As an attorney, you’re responsible for telling potential clients where their information came from. For targeted email campaigns or mailers, you may only need minimal data, like names and emails, paired with relevant facts (e.g., they were at Camp Lejeune). Just ensure the scope of your knowledge matches the information disclosed.”