Prepared Statement of 

The Federal Trade Commission 

Before the 

United States Senate 

Committee on Commerce, Science and Transportation 

Abusive Robocalls and How We Can Stop Them 

Washington, DC 

April 18, 2018 
 

 

 

 

 

 

 

 

Chairman Thune, Ranking Member Nelson, and members of the Committee, I am Lois 

Greisman, Associate Director of the Division of Marketing Practices, Bureau of Consumer 

Protection at the Federal Trade Commission (“Commission” or “FTC”).1 I appreciate the 

opportunity to appear before you today to discuss the Commission’s initiatives to fight illegal 

robocalls. 

In 2003, the FTC responded to enormous public frustration with unsolicited sales calls 

and amended the Telemarketing Sales Rule (“TSR”) to create a national Do Not Call Registry.2 

The Registry, which includes more than 229 million active telephone numbers,3 has been 

tremendously successful in protecting consumers’ privacy from unwanted calls by the thousands 

of legitimate telemarketers who subscribe to the Registry each year.4 Subsequently, changes in 

technology led to a new source of immense frustration—the blasting of prerecorded messages 

that primarily rely on Voice over Internet Protocol (“VoIP”) technology.5 In 2008, the 

1 The views expressed in this statement represent the views of the Commission. 

My oral presentation and responses to questions are my own and do not necessarily reflect the 

views of the Commission or any individual Commissioner. 

2 68 Fed. Reg. 4580 (Jan. 29, 2003); 16 C.F.R. Part 310. The FTC issued the TSR 

pursuant to the Telemarketing and Consumer Fraud and Abuse Prevention Act, 15 U.S.C. 

§§ 6101-6108. See generally The Telemarketing Sales Rule, 16 C.F.R. Part 310. 

3 See Do Not Call Registry Data Book 2017: Who is using the Do Not Call 

Registry available at https://www.ftc.gov/policy/reports/policy-reports/commission-staffreports/national-do-not-call-registry-data-book-fy-3. 

4 For example, in fiscal year 2017, more than 17,000 telemarketers accessed the Do 

Not Call Registry. See id. 

5 See Section II(A), infra. 
 

 

 

 

 

 

Commission responded by amending the TSR to prohibit the vast majority of prerecorded sales 

calls.6 

Illegal robocalls remain a significant consumer protection problem because they 

repeatedly disturb consumers’ privacy and frequently use fraud and deception to pitch goods and 

services, leading to significant economic harm. Illegal robocalls are also frequently used by 

criminal impostors posing as trusted officials or companies. Consumers are justifiably 

frustrated—in fiscal year 2017 the FTC received more than 4.5 million robocall complaints.7 

The FTC is using every tool at its disposal to fight these illegal calls.8 This testimony describes 

the Commission’s efforts to stop telemarketer violations, including our aggressive law 

enforcement, initiatives to spur technological solutions, and robust consumer and business 

outreach. 

I. Law Enforcement 

Since establishing the Do Not Call Registry in 2003,9 the Commission has fought 

vigorously to protect consumers’ privacy from unwanted calls. Indeed, since the Commission 

6 73 Fed. Reg. 51164 (Aug. 29, 2008); 16 C.F.R. § 310.4(b)(1)(v). 

7 The FTC’s fiscal year 2017 began October 1, 2016 and ended September 30, 

2017. Total unwanted-call complaints for FY 2017 including both robocall complaints and 

complaints about live calls from consumers whose phone numbers are registered on the Do Not 

Call Registry, exceed 7million. Note, however, that the FTC identified a technical problem with 

complaint submissions that resulted in artificially high complaint counts in July and August. See 

Do Not Call Registry Data Book 2017: Complaint Figures for FY 2017 available at 

https://www.ftc.gov/policy/reports/policy-reports/commission-staff-reports/national-do-not-callregistry-data-book-fy-1. 

8 See FTC Robocall Initiatives,https://www.consumer.ftc.gov/features/feature0025-robocalls. 

9 In 2003, two different district courts issued rulings enjoining the Do Not Call 

Registry. See Press Release, FTC Files Motion to Stay Pending Appeal in Oklahoma DNC 

Ruling (Mar. 24, 2003), available at https://www.ftc.gov/news-events/press-
 

 

 

began enforcing the Do Not Call provisions of the TSR in 2004, the Commission has brought 

135 enforcement actions seeking civil penalties,10 restitution for victims of telemarketing scams, 

and disgorgement of ill-gotten gains against 439 corporations and 356 individuals. From the 125 

cases that have been resolved thus far, the Commission has collected over $121 million in 

equitable monetary relief and civil penalties. 

A. Robocall Law Enforcement 

On September 1, 2009, TSR provisions went into effect prohibiting the vast majority of 

robocalls selling a good or service.11 The robocall provisions cover prerecorded calls to all 

consumers, including those who have not registered their phone number on the Do Not Call 

releases/2003/09/ftc-files-motion-stay-pending-appeal-oklahoma-dnc-ruling; Press Release, 

Statement of FTC Chairman Timothy J. Muris (Sept. 26, 2003), available at 

https://www.ftc.gov/news-events/press-releases/2003/09/statement-ftc-chairman-timothy-jmuris. Congress addressed the first decision in summary fashion by enacting HR 3161 in one 

day. See “HR 3161 (108th) Do-Not-Call-Registry bill,” 

http://www.govtrack.us/congress/bills/108/hr3161; Press Release, Statement of FTC Chairman 

Timothy J. Muris (Sept. 25, 2003), available at https://www.ftc.gov/news-events/pressreleases/2003/09/statement-ftc-chairman-timothy-j-muris-0. The 10th Circuit reversed the 

second district court decision on February 17, 2004. See Press Release, Appeals Court Upholds 

Constitutionality of National Do Not Call Registry (Feb. 17, 2004), available at 

https://www.ftc.gov/news-events/press-releases/2004/02/appeals-court-upholds-constitutionalitynational-do-not-call. 

10 As is true of all TSR violations, telemarketers who violate the Do Not Call 

provisions are subject to civil penalties of up to $40,000 per violation. 15 U.S.C. § 45(m)(1)(A); 

16 C.F.R. § 1.98(d). 

11 Like the other provisions of the TSR, the robocall provisions do not apply to nonsales calls, such as calls placed calls that are purely political, informational, or survey calls. 

Also, the provisions allow robocalls to members or prior donors of charities. See generally 

“Complying with the Telemarketing Sales Rule” (June 2016), available at 

https://www.ftc.gov/tips-advice/business-center/guidance/complying-telemarketing-sales-rule. 

Limited exceptions exist for calls that deliver a healthcare message made by an entity covered by 

the Health Insurance Portability and Accountability Act, 16 C.F.R. § 310.4(b)(1)(v)(D), and for 

certain calls placed by telemarketers who solicit charitable contributions, 16 C.F.R. § 

310.4(b)(1)(v)(B). 
 

 

 

 

 

Registry. The Commission has been aggressive in enforcing prohibitions against robocalls, 

filing 45 cases against 163 companies and 121 individuals responsible for billions of illegal 

robocalls.

12 From the 42 cases that have concluded thus far, the Commission has collected more 

than $29 million in civil penalties, redress, or disgorgement. Set forth below are details 

regarding several of our recent robocall enforcement actions. 

1. Recent Enforcement Activities 

i. Alliance Security 

Just a few weeks ago, the FTC filed a complaint and motion for preliminary injunction in 

federal district court alleging that Alliance Security Inc. (“Alliance”) and its founder, Jasjit “Jay” 

Gotra, directly and through its authorized telemarketers, called more than a million consumers 

whose numbers are on the Do Not Call Registry.13 Alliance installs home security systems, and 

makes outbound calls to solicit the sale of the systems and associated security monitoring 

services. 

The FTC’s complaint alleges that since 2014, Alliance and Gotra made or helped others 

make at least two million calls to consumers that violate the TSR, including more than a million 

12 The FTC filed 12 of the 45 cases before the rule change went into effect on 

September 1, 2009. 

13 Alliance and Gotra are recidivist violators of the Telemarketing Sales Rule that 

were under a 2014 FTC order for prior illegal calling practices. See U.S. v. Versatile Marketing 

Solutions, Inc., 1:14-cv-10612-PBS (D. Mass. Mar. 10, 2014) available at 

https://www.ftc.gov/enforcement/cases-proceedings/122-3162/versatile-marketing-solutions-incalso-dba-vms-alarms-et-al. Based on this pattern of behavior, the FTC’s most recent enforcement 

action seeks a preliminary and permanent injunction that bans Alliance and Gotra from 

telemarketing. FTC v. Jasjit Gotra, 1:18-cv-10548 (D. Mass. Mar. 23, 2018) available at 

https://www.ftc.gov/enforcement/cases-proceedings/x140022/jasjit-gotra-alliance-security. 

. 
 

 

 

 

 

 

 

 

calls to numbers on the DNC Registry.14 Many of these calls began as illegal robocalls using 

“spoofed” Caller ID numbers and information.15 Defendants then transferred the calls to a live 

agent, but continued to hide the identity of the caller—even taking pains to prohibit agents from 

naming Alliance.16 In some cases, Alliance’s agents deceptively held themselves out as a 

competitor, such as ADT, when calling consumers.17 Some consumers were so frustrated by the 

barrage of unwanted calls from Alliance that they scheduled an alarm installation just to plead in 

person for an end to the calls.18 

The FTC’s complaint alleges that Alliance’s disregard for consumers’ privacy went 

beyond the telephone and reached into their personal data.19 Alliance also performed 

undisclosed, unauthorized credit checks on consumers who received unsolicited telemarketing 

calls from Alliance or its telemarketers, in violation of the Fair Credit Reporting Act (“FCRA”), 15 

U.S.C. § 1681 et seq.

20 Alliance typically ran a credit check on every consumer who “pressed 1” 

14 FTC v. Jasjit Gotra, 1:18-cv-10548 (D. Mass. Mar. 23, 2018) available at 

https://www.ftc.gov/enforcement/cases-proceedings/x140022/jasjit-gotra-alliance-security. 

15 Id. 

16 Id. 

17 Id. 

18 Id. 

19 Id. 

20 To protect consumers’ privacy and safeguard their financial information, the 

FCRA prohibits unauthorized access to credit reports and credit scores. Under the FCRA, 15 

U.S.C. § 1681b(f), it is unlawful for any “person to use or obtain a consumer report for any 

purpose unless,” that person has a specific permissible purpose enumerated in 15 U.S.C. § 

1681b(a). 
 

 

 

 

 

 

 

 

 

 

 

in response to a call placed by Alliance or one of its telemarketers and expressed interest in 

obtaining an alarm system—without informing the consumer.21 

Two of Alliance’s authorized telemarketers and their principals agreed to settle charges 

that they made illegal calls on Alliance’s behalf.22 One telemarketer and its principal will be 

permanently barred from telemarketing and is subject to a civil penalty of $2,296,500, that is 

suspended based on inability to pay.23 The second telemarketer and its principal will be 

permanently banned from selling home security and medical alert devices, making robocalls or 

helping anyone else make them, using spoofed caller ID numbers, and calling phone numbers on 

the Do Not Call Registry, unless a consumer directly contacts the principal to request a call.24 

The second telemarketer is also subject to a civil penalty of $3,293,512, which will be partially 

suspended due to their inability to pay, upon payment of $300,000 to the Commission.25 The 

FTC is seeking strong injunctive relief and civil penalties against the remaining defendants, 

Alliance and Gotra, in federal district court.26 

21 FTC v. Jasjit Gotra, 1:18-cv-10548 (D. Mass. Mar. 23, 2018) available at 

https://www.ftc.gov/enforcement/cases-proceedings/x140022/jasjit-gotra-alliance-security. 

Indeed, the complaint further alleges that defendants attempted to pull credit reports or scores on 

President Trump and former President Obama, and Vice President Pence and former Vice 

President Biden, among others. 

22 Id. 

23 Id. 

24 Id. 

25 Id. 

26 Id. 
 

 

 

 

 

 

 

 

 

 

ii. Higher Goals Marketing 

In December 2017, the FTC filed an action in federal district court against Higher Goals 

Marketing LLC to halt an alleged debt-relief scam that defrauded numerous consumers 

struggling with credit card debt.27 The complaint alleges that the Higher Goals Marketing 

defendants used illegal robocalls to contact consumers, pitching their fake debt-relief services 

and charging hefty up-front fees, causing millions of dollars in injury.28 Defendants guaranteed 

that consumers would substantially and permanently lower their credit card interest rates, and 

would save thousands of dollars in interest payments.29 In reality, the complaint alleges, the 

scheme was unable to deliver the promised results to most consumers.30 Since the FTC filed this 

action, all defendants stipulated to a Preliminary Injunction, which the Court entered on 

December 28, 2017.31 Thanks to the filing of the FTC’s enforcement action, the defendants’ 

operation is shut down, and the Court has appointed a receiver to oversee the two corporate 

defendants.32 

27 See FTC v. Higher Goals Marketing LLC, 6:17-cv-02048-GAP-KRS (M.D. Fla. 

Dec. 4, 2017) available at https://www.ftc.gov/enforcement/cases-proceedings/172-3045/highergoals-marketing-llc. 

28 Id. 

29 Id. 

30 Id. The Commission also alleges that several defendants previously worked for a 

nearly identical telemarketing operation shut down in 2016 by court order at the request of the 

FTC. These defendants set up a new operation selling similar bogus credit-card interest-ratereduction services within weeks of the court order shuttering the earlier operation. Id. 

31 Id. 

32 See id. 
 

 

 

 

 

 

 

 

iii. Jones and Ramsey Cases 

Also in 2017, the Commission filed two lawsuits, FTC v. Justin Ramsey and FTC v. 

Aaron Michael Jones, that shut down operations responsible for billions of illegal robocalls. The 

Ramsey and Jones defendants bombarded consumers with robocalls pitching home security 

systems and extended auto warranties.33 The FTC obtained a settlement order in the Ramsey 

action that bans Ramsey and his company from placing robocalls to individuals to sell goods or 

services, initiating sales calls to numbers listed on the DNC Registry, and selling data lists 

containing phone numbers listed on the Registry.34 Ramsey and his company also agreed to a 

$2.2 million civil penalty, suspended upon payment of $65,000.35 In the Jones action, the court 

entered final orders permanently banning Jones and his companies from all telemarketing 

activities, including initiating robocalls, calling numbers on the DNC Registry, and selling data 

lists containing consumers’ phone numbers and other information.36 The default judgment order 

against Jones also imposes a $2.7 million civil penalty against him, payable to the Commission.37 

33 FTC v. Justin Ramsey, 9:17-cv-80032-KAM (S.D. Fla. Jan. 13, 2017), available 

at https://www.ftc.gov/enforcement/cases-proceedings/132-3254/justin-ramsey; FTC v. Michael 

Aaron Jones, 8:17-cv-00058 (M.D. Fla. Jan. 13, 2017), available at 

https://www.ftc.gov/enforcement/cases-proceedings/152-3152/allorey-inc. Evidence reviewed 

by FTC staff in connection with the Ramsey case indicated that a portion of the unlawful 

telemarketing calls targeted “distressed seniors.” 

34 FTC v. Justin Ramsey, 9:17-cv-80032-KAM (S.D. Fla. Apr. 11, 2017), available 

at https://www.ftc.gov/enforcement/cases-proceedings/132-3254/justin-ramsey. 

35 Id. 

36 FTC v. Michael Aaron Jones, 8:17-cv-00058 (M.D. Fla. May 31, 2017), available 

at https://www.ftc.gov/enforcement/cases-proceedings/152-3152/allorey-inc. 

37 Id. 
 

 

 

 

Over the past three years the FTC, often in conjunction with its law enforcement partners, 

initiated eleven new actions targeting defendants we alleged are responsible for billions of illegal 

robocalls hawking home security systems, free vacations, medical alert devices, energy savings, 

and credit card interest rate reductions.38 Many of the defendants in these cases are now banned 

from robocalling or telemarketing.39 

38 FTC v. Jasjit Gotra, 1:18-cv-10548 (D. Mass. Mar. 23, 2018) available at 

https://www.ftc.gov/enforcement/cases-proceedings/x140022/jasjit-gotra-alliance-security; FTC 

v. Higher Goals Marketing LLC, 6:17-cv-02048-GAP-KRS (M.D. Fla. Dec. 4, 2017) available 

at https://www.ftc.gov/enforcement/cases-proceedings/172-3045/higher-goals-marketing-llc; 

FTC v. Justin Ramsey, 9:17-cv-80032-KAM (S.D. Fla. Jan. 13, 2017), available at 

https://www.ftc.gov/enforcement/cases-proceedings/132-3254/justin-ramsey; FTC v. Michael 

Aaron Jones, 8:17-cv-00058 (M.D. Fla. Jan. 13, 2017), available at 

https://www.ftc.gov/enforcement/cases-proceedings/152-3152/allorey-inc; U.S. v. Consumer 

Education.info, Inc., 1:16-cv-02692 (D. Col. Nov. 1, 2016), available at 

https://www.ftc.gov/enforcement/cases-proceedings/152-3081/consumer-educationinfo-inc; FTC 

et al. v. Life Management Services of Orange County, LLC, 6:16-CV-982-Orl (M.D. Fla. June 8, 

2016), available at https://www.ftc.gov/enforcement/cases-proceedings/152-3216/lifemanagement; U.S. v. Lilly Management and Marketing, LLC, 6:16-cv-485-Orl (M.D. Fla. Mar. 

17, 2016), available at https://www.ftc.gov/enforcement/cases-proceedings/152-3115/usavacation-station; U.S. v. KFJ Marketing Inc., 2:16-cv-01643 (C.D. Cal. Mar. 10, 2016), available 

at https://www.ftc.gov/enforcement/cases-proceedings/152-3166/kfj-marketing-llc; FTC v. 

Lifewatch Inc., 1:15-cv-05781 (N.D. Ill. June 20, 2015), available at 

https://www.ftc.gov/enforcement/cases-proceedings/142-3123/lifewatch-inc; FTC v. All Us 

Marketing LLC, 6:15CV1016-0RL-28GJK (M.D. Fla. June 29, 2015), available at 

https://www.ftc.gov/enforcement/cases-proceedings/142-3256/all-us-marketing-llc-formerlyknown-payless-solutions-llc; FTC et al. v. Caribbean Cruise Line, Inc., 0:15-cv-60423 (S.D. Fla. 

Mar. 4, 2015), available at https://www.ftc.gov/enforcement/cases-proceedings/122-3196-

x150028/caribbean-cruise-line-inc. 

39 See, e.g., U.S. v. KFJ Marketing Inc., 2:16-cv-01643 (C.D. Cal. Nov. 7, 2017), 

available at https://www.ftc.gov/enforcement/cases-proceedings/152-3166/kfj-marketing-llc 

(final order permanently banning corporate defendants and individual ringleader from all 

telemarketing); FTC v. Michael Aaron Jones, 8:17-cv-00058 (M.D. Fla. May 31, 2017), 

available at https://www.ftc.gov/enforcement/cases-proceedings/152-3152/allorey-inc (final 

orders permanently banning Jones and related companies from all telemarketing activities, 

including initiating robocalls, calling numbers on the Do Not Call Registry, and selling data lists 

containing consumers’ phone numbers and other information); FTC v. All Us Marketing LLC, 

6:15CV1016-0RL-28GJK (M.D. Fla. May 22, 2017, June 8, 2016 and Nov. 1, 2016), available 

at https://www.ftc.gov/enforcement/cases-proceedings/142-3256/all-us-marketing-llc-formerly-
 

 

 

 

iv. Historic Victory in Dish Network 

In addition to initiating new enforcement actions, the FTC and our law enforcement 

partners also achieved an historic win in a long-running fight against unwanted calls and 

robocalls. On June 5, 2017, a federal district court in Illinois issued an order imposing the 

largest penalty ever issued in a Do Not Call case: $280 million against Dish Network.40 The 

Dish litigation began in 2009 when the Department of Justice brought an action on behalf of the 

FTC with the states of California, Illinois, North Carolina, and Ohio alleging millions of 

violations of the Telemarketing Sales Rule, the Telephone Consumer Protection Act (“TCPA”) 

and various state Do Not Call laws.41 The litigation centered on allegations that Dish and its 

telemarketers made tens of millions of calls—often robocalls42—to telephone numbers on the Do 

known-payless-solutions-llc (multiple final orders permanently banning most defendants from 

robocalling, telemarketing, and providing debt relief services); FTC v. Justin Ramsey, 9:17-cv80032-KAM (S.D. Fla. Apr. 11, 2017), available at https://www.ftc.gov/enforcement/casesproceedings/132-3254/justin-ramsey (stipulated order banning Ramsey and his company from 

placing robocalls to individuals to sell goods or services, initiating sales calls to numbers listed 

on the Do Not Call Registry, and selling data lists containing phone numbers listed on the 

Registry); FTC v. Caribbean Cruise Line, Inc., 0:15-cv-60423 (S.D. Fla. Feb. 17, 2017), 

available at https://www.ftc.gov/enforcement/cases-proceedings/122-3196-x150028/caribbeancruise-line-inc (final stipulated order banning the Pacific Telecom defendants from robocalling 

and illegal telemarketing, as well as helping anyone else make such calls). 

40 See U.S. v. Dish Network, LLC, No. 3:09-cv-03073 (C.D. Ill. June 6, 2017) 

available at https://www.ftc.gov/news-events/press-releases/2017/06/ftc-doj-case-resultshistoric-decision-awarding-280-million-civil. 

41 U.S. v. Dish Network, LLC, No. 3:09-cv-03073 (C.D. Ill. Mar. 25, 2009), 

available at https://www.ftc.gov/news-events/press-releases/2009/03/ftc-charges-dish-networkformerly-known-echostar-multiple-do-not. 

42 When the Dish case was filed in March of 2009, the robocall provision of the TSR 

was not yet in effect, thus the complaint reached Dish’s unlawful use of robocalls through a 

count alleging violations of the TSR’s abandoned call provisions. Since October 1, 2003, 

telemarketers have been prohibited from abandoning an outbound telephone call, and sellers are 

prohibited from causing a telemarketer to do so in violation of the TSR. 16 C.F.R. § 
 

 

 

 

 

Not Call Registry and called consumers who previously asked Dish and its telemarketers to stop 

calling.43 In January 2015, the Court found that Dish and its telemarketers had engaged in more 

than 66 million violations of the TSR and that Dish was responsible for calls made by its 

retailers.44 The $280 million penalty against Dish includes $168 million to the United States for 

violations of the TSR and $112 million to the states for violations of the TCPA and various state 

laws. The order also imposed strong injunctive relief that, among other provisions, requires Dish 

to hire a monitor to ensure that Dish and its retailers comply with telemarketing laws.45 The 

tireless efforts of DOJ and our state co-plaintiffs were invaluable in securing an outcome that 

takes a strong stand against companies who invade a consumer’s privacy through unwanted calls 

and robocalls. 

2. Reaching Violators Attempting to Avoid Detection 

Increasingly, the perpetrators behind these abusive and often fraudulent calls take steps to 

avoid detection, either by operating through a web of related entities, “spoofing” their Caller ID 

310.4(b)(1)(iv). An outbound telephone call is abandoned if a person answers it and the 

telemarketer does not connect the call to a sales representative within two (2) seconds of the 

person’s completed greeting. 16 C.F.R. § 310.4(b)(1)(iv). The use of robocalls, where a sales 

pitch to a live consumer begins with or is made entirely by a pre-recorded message, violates the 

TSR’s abandoned call prohibition because the telemarketer is not connecting the call to a sales 

representative within two (2) seconds of the person’s completed greeting. 

43 U.S. v. Dish Network, LLC, No. 3:09-cv-03073 (C.D. Ill. Mar. 25, 2009), 

available at https://www.ftc.gov/enforcement/cases-proceedings/052-3167/dish-network-llcunited-states-america-federal-trade. 

44 U.S. v. Dish Network, LLC, No. 3:09-cv-03073 (C.D. Ill. Jan. 21, 2015), available 

at https://www.ftc.gov/news-events/press-releases/2015/01/court-grants-partial-summaryjudgment-ftc-case-against-dish. 

45 See U.S. v. Dish Network, LLC, No. 3:09-cv-03073 (C.D. Ill. June 6, 2017) 

available at https://www.ftc.gov/news-events/press-releases/2017/06/ftc-doj-case-resultshistoric-decision-awarding-280-million-civil. 
 

 

 

 

information, or hiding overseas. The FTC uses every investigative and litigation tool at its 

disposal to cut through these deceptions. For example, the defendants in the Jones and Ramsey 

cases operated through a tangle of related individuals and entities to avoid detection by law 

enforcement. In addition, defendants in many of our robocall cases routinely hid their true name 

or phone number to deceive consumers and evade detection by law enforcement and the 

Commission included counts in its suits targeting this unlawful Caller ID spoofing.46 

The perpetrators behind many unlawful calls also seek to evade law enforcement by 

operating overseas. When consumers are victimized by fraudulent calls from international call 

centers, the Commission finds ways to stymie the scammers by cracking down on their U.S. 

enablers. In one recent case, the Commission filed suit against individuals and entities in the 

U.S. who were collecting money on behalf of telemarketers at India-based call centers operating 

government impostor scams that conned consumers into paying hundreds or thousands of dollars 

for taxes they did not owe, or fees for services they did not receive.47 In another recent case, the 

46 See FTC v. Jasjit Gotra, 1:18-cv-10548 (D. Mass. Mar. 23, 2018) available at 

https://www.ftc.gov/enforcement/cases-proceedings/x140022/jasjit-gotra-alliance-security; U.S. 

v. KFJ Marketing Inc., 2:16-cv-01643 (C.D. Cal. Mar. 10, 2016), available at 

https://www.ftc.gov/enforcement/cases-proceedings/152-3166/kfj-marketing-llc; FTC v. 

Lifewatch Inc., 1:15-cv-05781 (N.D. Ill. June 20, 2015), available at 

https://www.ftc.gov/enforcement/cases-proceedings/142-3123/lifewatch-inc; FTC v. All Us 

Marketing LLC, 6:15CV1016-0RL-28GJK (M.D. Fla. June 29, 2015), available at 

https://www.ftc.gov/enforcement/cases-proceedings/142-3256/all-us-marketing-llc-formerlyknown-payless-solutions-llc; FTC v. Caribbean Cruise Line, Inc., 0:15-cv-60423 (S.D. Fla. Mar. 

4, 2015), available at https://www.ftc.gov/enforcement/cases-proceedings/122-3196-

x150028/caribbean-cruise-line-inc. In each case, the FTC alleged that defendants failed to 

transmit complete and accurate Caller ID information in violation of 16 C.F.R. § 310.4(a)(8) or 

assisted others in doing the same. 

47 FTC v. PHLG Enterprises LLC, 8:17-cv-00220-RAL-AEP (M.D. Fla. Jan. 27, 

2017), available at https://www.ftc.gov/enforcement/cases-proceedings/152-3245-x170019/phlgenterprises-llc. 
 

 

 

 

 

 

 

Commission brought suit against the U.S. operators of a scam that relied on Peruvian call centers 

and sophisticated Caller ID spoofing to pressure Spanish speaking U.S. consumers into 

purchasing English-language learning materials of little value—and then posing as government 

officials to threaten and harass uninterested consumers into “purchasing” their products.48 

B. Coordination with Law Enforcement Partners 

As the law enforcement challenges associated with illegal telemarketing have increased, 

the FTC’s relationships with other agencies have become increasingly important. The 

Commission has robust, collaborative relationships with state law enforcers, including through 

the National Association of Attorneys General Do Not Call working group. The Commission 

coordinates with various partners to bring law enforcement actions. Many of the recent robocall 

enforcement actions the FTC has led involved collaboration with the Department of Justice or 

our state partners.49 The FTC also leads robocall law enforcement “sweeps”—coordinated, 

simultaneous law enforcement actions—in conjunction with state and federal partners.50 

48 FTC v. ABC Hispana Inc., 5:17-cv-00252-JGB-DTB (C.D. Cal. Apr. 19, 2017), 

available at https://www.ftc.gov/enforcement/cases-proceedings/152-3108/abc-hispana-inc-et-al. 

49 See supra n. 38. 

50 For example, the FTC led a multinational robocall sweep announced in June 2016 

that took action against operations estimated to be responsible for billions of illegal robocalls.50 

The June 2016 sweep included thirty-nine actions taken by the FTC, the Canadian Radiotelevision and Telecommunications Commission (CRTC), the United Kingdom’s Information 

Commissioner’s Office (ICO), as well as DOJ, the FCC and the attorney generals’ offices of 

Colorado, Florida, Indiana, Kansas, Mississippi, Missouri, North Carolina, Ohio, and 

Washington State, and the Tennessee Regulatory Authority. See Press Release, FTC, Florida 

Attorney General Take Action Against Illegal Robocall Operation (June 14, 2016), available at 

https://www.ftc.gov/news-events/press-releases/2016/06/ftc-florida-attorney-general-take-actionagainst-illegal-robocall and https://www.ftc.gov/system/files/attachments/press-releases/ftcflorida-attorney-general-take-action-against-illegal-robocalloperation/160614robocallenforcementactions.pdf (listing actions comprising the coordinated 

enforcement crackdown). 
 

 

 

 

In addition, the FTC regularly works with the Federal Communications Commission 

(“FCC”), the Department of Justice, the Internal Revenue Service (“IRS”), the U.S. Treasury 

Inspector General for Tax Administration (“TIGTA”), the U.S. Postal Inspection Service, and 

U.S. Attorneys’ Offices across the country. The Commission also coordinates with its 

counterparts in other countries on particular cases and broader strategic matters such as Caller ID 

spoofing. The FTC’s collaboration with its partners takes many forms, including sharing 

information and targets, assisting with investigations, and working collaboratively on long-term 

policy initiatives. Also, on May 17, for the third year in a row, the FTC is coordinating a 

meeting among stakeholders specifically to tackle Indian call-center fraud. 

Just last month,the FTC and FCC co-hosted a Joint Policy Forum on Illegal Robocalls on 

March 23, 2018.51 The purpose of the forum was to discuss the regulatory and enforcement 

challenges posed by illegal robocalls and what the FCC and FTC are doing to protect consumers 

and encourage the development of private-sector solutions.52 Discussion topics included the 

factors driving the volume of illegal robocalls; Caller ID spoofing; new threats to consumers, 

such as “neighbor spoofing”; protections for callers placing legal calls; FCC rulemakings; 

enforcement challenges; third-party solutions and other resources available to empower 

consumers; and industry efforts to develop Caller ID authentication.53 The forum included 

51 See Press Release, FTC and FCC to Host Joint Policy Forum on Illegal Robocalls 

(Mar. 22, 2018) available at https://www.ftc.gov/news-events/press-releases/2018/03/ftc-fcchost-joint-policy-forum-illegal-robocalls. 

52 Id. 

53 See Press Release, Agenda Announced for the March 23, 2018 FTC-FCC Joint 

Policy Forum on Fighting the Scourge of Illegal Robocalls (Mar. 19, 208) available at 

https://www.ftc.gov/news-events/press-releases/2018/03/ftc-fcc-host-joint-policy-forum-illegalrobocalls. 
 

 

 

 

 

 

policy and regulatory experts from both agencies, enforcement leaders from both agencies and 

the Florida Office of Attorney General, representatives from voice service providers, 

representatives from companies providing call-blocking solutions, as well as representatives 

from the call originators.54 

II. Policy and Market Stimulation Initiatives 

A. Understanding the Landscape of the Robocall Problem 

Despite the 2009 prohibition of unauthorized robocalls and the Commission’s vigorous 

enforcement efforts, technological advances have permitted law-breakers to make more robocalls 

for less money with a greater ability to hide their identity. For example, at the end of 2009, the 

FTC received approximately 63,000 complaints about illegal robocalls each month.55 That 

number has now more than quadrupled—in fiscal year 2017, the FTC received an average of 

nearly 400,000 robocall complaints per month.56 

Recognizing that law enforcement, while critical, is not enough to solve the problem, 

FTC staff has aggressively sought new strategies in ongoing discussions with academic experts, 

telecommunications carriers, industry coordinating bodies, technology and security companies, 

consumers, and counterparts at federal, state, and foreign government agencies. The 

Commission ramped up these efforts in October 2012, when the FTC hosted a public summit on 

54 Id. A video recording of the event is available on the FCC’s website at 

https://www.fcc.gov/fcc-ftc-robocalls-forum. 

55 National Do Not Call Registry Data Book FY 2010 at 5 (Nov. 2010), available at 

https://www.ftc.gov/reports/national-do-not-call-registry-data-book-fiscal-year-2010. Since that 

time, the FTC began separately tracking Do Not Call complaints and robocall complaints based 

on information provided by the consumer. 

56 See supra n. 8. 
 

 

 

 

 

robocalls to explore these issues (the “Robocall Summit”).57 Since then, as discussed below, the 

Commission has spurred the creation of specific groups of experts and industry members to work 

together and with international law enforcers to tackle this vexing consumer protection issue. 

Speakers at the Robocall Summit made clear that convergence between the legacy 

telephone system and the Internet has allowed robocallers to engage, at very little cost, in 

massive, unlawful robocall campaigns that cross international borders and hide behind spoofed 

Caller ID information. As a result, it is not only much cheaper to blast out robocalls; it is also 

easier to hide one’s identity when doing so. 

1. Technological Developments Have Made Robocalls Extremely 

Inexpensive 

Until relatively recently, telemarketing required significant capital investment in 

specialized hardware and labor.58 Now, robocallers benefit from automated dialing technology, 

inexpensive international and long distance calling rates, and the ability to move internationally 

and employ cheap labor.59 The only necessary equipment is a computer connected to the 

Internet.60 The result: law-breaking telemarketers can place robocalls for a fraction of one cent 

per minute. In addition, the cheap, widely available technology has resulted in a proliferation of 

entities available to perform any portion of the telemarketing process, including generating leads, 

57 See generally FTC Workshop, Robocalls: All the Rage (Oct. 18, 2012), available 

at https://www.ftc.gov/news-events/events-calendar/2012/10/robocalls-all-rage-ftc-summit. A 

transcript of the workshop (hereinafter “Tr.”) is available at 

https://www.ftc.gov/sites/default/files/documents/public_events/robocalls-all-rage-ftcsummit/robocallsummittranscript.pdf. 

58 Herrmann, Tr. at 58-59; Schulzrinne, Tr. at 24. 

59 Schulzrinne, Tr. at 24. 

60 Herrmann, Tr. at 59-61. 
 

 

 

 

 

 

placing automated calls, gathering consumers’ personal information, or selling products.61 

Because of the dramatic decrease in upfront capital investment and marginal cost, robocallers— 

like email spammers—can make a profit even if their contact rate is very low.62 

Technology enables a cheap and scalable model for robocalls. 

2. Technological Developments Have Made It Easier for Robocallers to 

Hide 

Technological changes have also affected the marketplace by enabling telemarketers to 

conceal their identities when they place calls. First, direct connections do not exist between 

every pair of carriers, so intermediate carriers are necessary to connect many calls. Thus, the 

typical call now takes a complex path, traversing the networks of multiple VoIP and legacy 

carriers before reaching the end user.63 These circuitous paths make it cumbersome to trace a 

61 Schulzrinne, Tr. at 20-21; Maxson, Tr. at 95-98. 

62 Schulzrinne, Tr. at 21; Bellovin, Tr. at 16-17. 

63 Panagia, Tr. at 130-32; Bellovin, Tr. at 17. 
 

 

 

 

 

 

 

 

 

call to its inception.64 All too often, this process to trace the call fails because one of the carriers 

in the chain has not retained the records necessary for a law enforcement investigation.65 

Second, callers can easily manipulate the Caller ID information that appears with an 

incoming phone call.66 While “Caller ID spoofing” has some beneficial uses,67 it also allows 

telemarketers to deceive consumers by pretending to be an entity with a local phone number or a 

trusted institution such as a bank or government agency.68 In addition, telemarketers can change 

their phone numbers frequently in an attempt to avoid detection.69 Today, many illegal callers 

rely on “neighbor spoofing”, the practice of using a Caller ID number that appears to be from a 

number local to the call recipient.70 

64 Schulzrinne, Tr. at 24-25; Maxson, Tr. at 100; Bash, Tr. at 104. Recently, 

USTelecom’s Industry Traceback Group has been able to assist law enforcement to traceback a 

call more quickly through the network. 

65 Panagia, Tr. at 160-61; see also id. at 132-133; Schulzrinne, Tr. at 21. 

66 Schulzrinne, Tr. at 24-26. 

67 See, e.g., Panagia, Tr. at 129 (AT&T allows the third party that performs AT&T’s 

customer service to “spoof” AT&T’s customer service line). 

68 Schulzrinne, Tr. at 21-22. 

69 Id. at 24-26; Maxson, Tr. at 97; Bash, Tr. at 103. Under the Truth in Caller ID 

Act, it is generally illegal to transmit misleading or inaccurate Caller ID information with intent 

to defraud. See Truth in Caller ID Act, 47 U.S.C.§ 227(e); cf. 16 C.F.R. § 310.4(a)(8) (the 

Telemarketing Sales Rule requires that sellers and telemarketers transmit or cause to be 

transmitted the telephone number and, when made available by the telemarketer’s carrier, the 

name of the telemarketer, to any caller identification service in use by a recipient of a 

telemarketing call, or transmit the customer service number of the seller on whose behalf the call 

is made and, when made available by the telemarketer’s seller, the name of the seller. Under this 

provision, it is not necessary to prove intent to defraud.). 

70 See FTC Consumer Information Blog, That’s Not Your Neighbor Calling 

https://www.consumer.ftc.gov/blog/2018/01/thats-not-your-neighbor-calling. 
 

 

 

Finally, new technologies allow robocallers to operate outside of jurisdictions where they 

are most likely to face prosecution.71 Indeed, the entities involved in the path of a robocall can 

be located in different countries, making investigations even more challenging. 

The path of a robocall can span the entire globe. 

B. Efforts to Stimulate Technological Solutions 

1. Robocall Contests 

Recognizing the need to spur the marketplace into developing technical solutions that 

protect American consumers from illegal robocalls, the FTC lead four public challenges to help 

tackle the unlawful robocalls that plague consumers. In 2012-2013, the FTC conducted its first 

71 Schulzrinne, Tr. at 21; Bellovin, Tr. at 16-17. 
 

 

 

 

 

 

Robocall Challenge72, and called upon the public to develop a consumer-facing solution that 

blocks illegal robocalls, applies to landlines and mobile phones, and operates on proprietary and 

non-proprietary platforms. In response, we received 798 submissions and partnered with experts 

in the field to judge the entries. One of the winners, “NomoRobo,” was on the market and 

available to consumers by October 2013—just 6 months after being named one of the winners. 

To date, “NomoRobo,” which reports blocking over 600 million calls, is being offered directly to 

consumers by a number of telecommunications providers and is now available as an app on 

iPhones.73 

The following year, the FTC launched its second challenge—Zapping Rachel74—which 

called upon information security experts to help create a robust robocall honeypot. Sixty teams 

and individuals signed up for one or more phase, and FTC staff obtained new insights that 

improved current robocall honeypot designs and connected new partners and stakeholders. 

In June 2015, the FTC sponsored its third challenge, DectectaRobo75, in which it called 

upon the public to analyze call data to create algorithms that could predict which calls were 

likely robocalls. Nineteen teams from all over the U.S. participated. Later in 2015, the FTC 

72 For more information on the first FTC Robocall Challenge, see 

https://www.ftc.gov/news-events/press-releases/2013/04/ftc-announces-robocall-challengewinners. 

73 See https://www.nomorobo.com/ (last visited April 4, 2018) and Robocall Strike 

Force, Robocall Strike Force Report at 17-18 (April 28, 2017), 

https://www.fcc.gov/file/12311/download (“Strike Force Report II”) at 17-18. 

74 A robocall honeypot is an information system designed to attract robocallers and 

help investigators and academics understand and combat illegal calls. For more information on 

the Zapping Rachel challenge see https://www.ftc.gov/news-events/contests/zapping-rachel. 

75 For more information on the Detectarobo challenge see 

https://www.ftc.gov/news-events/contests/detectarobo. 
 

 

 

 

 

 

challenged information security experts to create tools people could use to block and forward 

robocalls automatically to a honeypot as part of the Robocalls: Humanity Strikes Back 

challenge.76 Contestants built and submitted robocall solutions to the judges and finalists, then 

competed to “seed” their solutions and collect the highest number of robocalls. One of the 

winners of the Humanity Strikes Back challenge developed Robokiller, a call-blocking app 

available for iOS phones.77 

Each of the four challenges provided the Commission with an opportunity to promote 

industry dialogue and innovation in combatting illegal robocalls, develop industry partnerships, 

and refine its understanding of the robocall problem and potential solutions. More importantly, 

the challenges contributed to a shift in the development and availability of technological 

solutions in this area, particularly call-blocking and call-filtering products. A number of voice 

service providers now offer call-blocking or call-filtering products to some or all of their 

customers.78 In addition, there are a growing number of free or low-cost apps available for 

download on wireless devices that offer call-blocking and call-filtering solutions.79 

76 For more information on the Robocalls: Humanity Strikes Back challenge, see 

https://www.ftc.gov/news-events/contests/robocalls-humanity-strikes-back. 

77 See https://www.robokiller.com/ (last visited April 4, 2018). 

78 For example, in late 2016 AT&T launched “Call Protect”, which is a product 

available to many AT&T wireless customers that blocks fraud calls and flags others as potential 

“spam.” See http://about.att.com/story/att_call_protect.html. T-Mobile offers its wireless 

customers two free products, “Scam ID” and “Scam Block”, that flag and block unwanted calls. 

See http://explore.t-mobile.com/callprotection (last visited April 4, 2018). Verizon offers a 

product called “Caller Name ID” to its wireless customers that also attempts to flag and block 

unwanted calls. See https://www.verizonwireless.com/solutions-and-services/caller-name-id/ 

(last visited April 4, 2018). In addition, a number of carriers make Nomorobo available to their 

VoIP or cable line customers. See, e.g., https://www.fcc.gov/consumers/guides/stop-unwantedcalls-texts-and-faxes (listing available call blocking resources from a number of wireline 

providers) (last visitedApril 4, 2018). 
 

 

 

 

 

 

 

2. Coordinating with Technical Experts, Industry, and Other Stakeholders 

The FTC provided input to support the industry-led Robocall Strike Force, which is also 

working to deliver comprehensive solutions to prevent, detect, and filter unwanted robocalls.80 

In tandem with this effort, the FTC worked with a major carrier and federal law enforcement 

partners to help block IRS scam calls that were spoofing well-known IRS telephone numbers. 

The Strike Force expanded this effort and it contributed to a drop in IRS scam calls at the end of 

2016.81 

The Strike Force also found that, while several providers and third parties offered callblocking products, there was no widespread call-blocking solution spanning the networks. In 

order to provide proactive call-blocking services to customers, the Strike Force sought 

clarification from the FCC that “blocking presumptively illegal calls is one of the tools carriers 

79 The Cellular Telecommunications Industry Association (CTIA) maintains a list of 

hundreds of available call blocking apps (including a list of the top 15 apps as determined by 

CTIA), both for iOS devices: https://www.ctia.org/consumer-tips/robocalls/ios-robocall-blocking 

and for Android devices: https://www.ctia.org/consumer-tips/robocalls/android-robocallblocking (last visited April 4, 2018). 

80 The Robocall Strike Force developed in response to a call from the FCC to make 

better call blocking solutions available to consumers, quickly, and free of charge. See Robocall 

Strike Force, Robocall Strike Force Report at 1 (2016), https://transition.fcc.gov/cgb/RobocallStrike-Force-Final-Report.pdf. The FTC has long been a proponent of call blocking services as a 

critical tool to reduce unwanted calls and robocalls and strongly supports the Strike Force’s 

efforts. See e.g., FTC Staff, Comments Before the Federal Communications Commission on 

Public Notice DA 14-1700 Regarding Call Blocking, CG Docket No. 02-278; WC Docket No. 

07-135 (Jan. 23, 2015), available at https://www.ftc.gov/policy/policy-actions/advocacyfilings/2015/01/ftc-staff-comment-federal-communications-commission. 

81 See Robocall Strike Force, Robocall Strike Force Report at 32-33 (2016), 

https://transition.fcc.gov/cgb/Robocall-Strike-Force-Final-Report.pdf. 
 

 

 

 

 

 

are permitted to use to provide consumers additional relief.”82 In response, in March 2017, the 

FCC issued a Notice of Proposed Rule Making and Notice of Inquiry that sought to expand the 

categories of calls that voice service providers are authorized to block and invited comment on 

what types of standards should govern providers engaged in call blocking.83 The FTC filed a 

comment in response, supporting the NPRM’s efforts to expand the categories of calls that voice 

service providers are authorized to block and encouraging the FCC to allow for some provider 

flexibility when considering standards to govern provider-based blocking of presumptivelyillegal calls.84 In November 2017, the FCC issued a Report and Order that enabled voice service 

82 See id. at 40. 

83 Specifically, the FCC’s NPRM sought input on rulemaking proposals that would 

authorize two categories of provider-based call blocking: 1) when the subscriber to a particular 

telephone number requests that telecommunications providers block calls originating from that 

number; and 2) when the originating number is invalid, unallocated, or unassigned. See 

Advanced Methods to Target and Eliminate Unlawful Robocalls, Notice of Proposed 

Rulemaking and Notice of Inquiry, CG Docket No. 17-59, FCC 17-23 (released Mar. 23, 2017), 

published in 82 Fed. Reg. 22625 (May 17, 2017). 

84 See Comment of the FTC to the Federal Communications Commission, Advanced 

Methods to Target and Eliminate Unlawful Robocalls, Notice of Proposed Rulemaking and 

Notice of Inquiry, CG Docket No. 17-59, FCC 17-23 (July 3, 2017), available at 

https://www.ftc.gov/system/files/documents/advocacy_documents/ftc-staff-comment-federalcommunications-commission-supporting-fccs-proposed-expansionprovider/ftc_comment_to_fcc_re_nprm_noi_call_blocking_07032017.pdf. As call-blocking 

technology gains momentum, the FTC is mindful about concerns that bad actors may place 

telemarketing calls while spoofing an innocent consumer’s telephone number as the outbound 

caller ID number in an effort to evade detection or that the inadvertent blocking of legitimate 

calls may occur. These concerns were also raised by the FCC and addressed in the FTC’s 

Comment. 
 

 

 

 

 

 

 

 

providers to block certain categories of calls before they reach consumers’ phones as proposed 

by the Notice of Proposed Rulemaking.85 

Increased call-blocking and call-labeling tools for consumers has presented new 

challenges for call originators, some of which contend that their calls are being erroneously 

blocked or labeled. The FTC participates in several forums that seek to improve the 

communication between call originators and service providers. The FCC also recently sought 

input on how best to address the question of potential errors in call blocking and call labeling.86 

In response, the FTC filed a comment encouraging providers of call-blocking services to 

consider engaging in practices that could reduce the potential for inadvertently blocking wanted 

calls, such as communicating clearly to subscribers the types of calls that are being blocked, 

using plain and specific terms to label calls, and providing designated points of contact to handle 

questions about calls blocked in error.87 

The FTC also has engaged with technical experts, academics, and others through industry 

groups, such as the Messaging, Malware and Mobile Anti-Abuse Working Group (“M3AAWG”). 

M3AAWG is a consortium of industry, regulators, and academics focused on developing 

solutions to mitigate various forms of messaging abuse such as email spam.88 After discussions 

85 See Advanced Methods to Target and Eliminate Unlawful Robocalls, Report and 

Order and Further Notice of Proposed Rulemaking, CG Docket No. 17-59, FCC 17-151 (released 

Nov. 17, 2017). 

86 See id. 

87 See Comment of the FTC to the Federal Communications Commission, Advanced 

Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, FCC 17-151 (Jan 

23, 2018), available at https://www.ftc.gov/policy/advocacy/advocacy-filings/2018/01/ftc-staffcomment-federal-communications-commission. 

88 See M3

AAWG, Activities, https://www.m3aawg.org/ (last visited April 5, 2018). 
 

 

 

 

 

 

 

with the FTC and others, M3AAWG leadership formed the Voice and Telephony Abuse Special 

Interest Group (“VTA SIG”) in 2014, a subgroup formed to apply M3

AAWG’s expertise on 

messaging abuse to voice spam, such as robocalls.89 

Through the VTA SIG, the FTC coordinates with experts working on industry standards 

that will combat Caller ID spoofing by enabling the authentication of VoIP calls, such as the 

Internet Engineering Task Force’s working group called “STIR”—Secure Telephone Identity 

Revisited.90 The FTC further promotes technical advancements by collaborating with its 

counterparts in other countries, through its leadership in the Unsolicited Communications 

Enforcement Network (“UCENet”) an international syndicate of government agencies and 

private sector representatives focused on international spam enforcement cooperation.91 

3. Data Initiatives 

The Commission also engages in information sharing to help facilitate technological 

solutions such as call blocking and has taken steps to increase the quality and quantity of shared 

information. To that end, on September 28, 2016, the FTC updated its Do Not Call complaint 

intake process to provide a drop-down list of possible call categories for consumers to choose 

from to make it easier for consumers to report the subject of the call and to help the Commission 

identify trends. 

89 See M3

AAWG, Voice and Telephony Abuse Special Interest Group, 

https://www.m3aawg.org/voice-and-telephony-abuse-sig (last visited April 5, 2018). 

90 See Internet Eng’g Task Force, Secure Telephone Identity Revisited (STIR), 

https://datatracker.ietf.org/wg/stir/charter/ (last visited April 5, 2018). 

91 See https://www.ucenet.org/ (last visited April 5, 2018). 
 

 

 

 

 

Next, in fiscal year 2017, the FTC redesigned its annual National Do Not Call Registry 

Data Book.92 The Data Book now provides more information on robocall complaints, new 

information about the types of calls consumers reported to the FTC, and includes a complete 

state-by-state analysis.93 In addition, this year the FTC has developed a “mini site” on its 

website to make the information in the FY 2017 Data Book more accessible for the public, such 

as providing a webpage for each state.94 For the first time, the data behind the report is also 

available in data files on the new website.95 

One of the features of the new Data Book is a breakdown of the topics of calls reported to 

the FTC that it gathered from the FTC’s revised online complaint form: 

92 Press Release, FTC Releases FY 2017 National Do Not Call Registry Data Book 

and DNC Mini Site (Dec. 18, 2017) available at https://www.ftc.gov/news-events/pressreleases/2017/12/ftc-releases-fy-2017-national-do-not-call-registry-data-book-dnc. Excerpts 

from the Data Book are attached at Exhibit A. 

93 Id. 

94 Id. 

95 Id. 
 

 

 

 

 

 

FY 2017 COMPLAINTS BY TOPIC96 

The state-by-state analysis also includes the top 10 topics of consumer complaints per state.97 

In addition to refining our complaint intake process and upgrading our Data Book, the 

FTC recently began a new initiative to help improve industry call-blocking solutions by 

increasing the amount and frequency of consumer complaint data that we make publicly 

available.98 Beginning in August 2017, when consumers report Do Not Call or robocall 

96 See Do Not Call Registry Data Book 2017: Complaint Figures for FY 2017 

available at https://www.ftc.gov/reports/national-do-not-call-registry-data-book-fiscal-year2017. Not everyone who files a complaint reports a topic. 

97 See, e.g., Do Not Call Registry Data Book 2017: Alabama available at 

https://www.ftc.gov/reports/national-do-not-call-registry-data-book-fiscal-year-2017/alabama. 

98 See https://www.ftc.gov/news-events/press-releases/2017/08/ftc-escalates-fightagainst-illegal-robocalls-using-consumer. The complaint data is available at: 

https://www.ftc.gov/site-information/open-government/data-sets/do-not-call-data. 
 

 

 

violations to the FTC, the phone numbers consumers report are released each business day. The 

FTC is also releasing the following consumer-reported data: the date and time the unwanted call 

was received, the general subject matter of the call (such as debt reduction, energy, warranties, 

home security, etc.), and whether the call was a robocall.99 By making our available data more 

up-to-date and more robust, the FTC seeks to improve the functionality of call-blocking solutions 

for consumers that choose to use a call-blocking service or feature. 

The Commission is committed to continuing to work with industry and government 

partners to improve information sharing to combat illegal calls. 

III. Consumer Education 

Public education is also an essential tool in the FTC’s consumer protection and fraud 

prevention work. The Commission’s education and outreach program reaches tens of millions of 

people a year through our website, the media, and partner organizations that disseminate 

consumer information on the FTC’s behalf. 

The FTC delivers practical, plain language information on numerous issues in English 

and in Spanish. The Commission also uses law enforcement announcements as opportunities to 

remind consumers how to recognize a similar situation and report it to the FTC. In the case of 

robocalls, the FTC’s message to consumers is simple: if you answer a call and hear an unwanted 

recorded sales message—hang up. Period. Other key messages to consumers include how to 

place a phone number on the Do Not Call Registry, how and where to report illegal robocalls,100 

99 In the past, the Commission released a bi-weekly report that published only the 

telephone numbers that consumers complained about in their Do Not Call and robocall 

complaints. 

100 See, e.g., National Do Not Call Registry, 

http://www.consumer.ftc.gov/articles/0108-national-do-not-call-registry. 
 

 

 

 

 

 

 

 

 

 

 

available call blocking solutions,101 and how to identify common scams.102 The FTC 

disseminates these tips through articles,103 blog posts,104 social media,105 infographics,106 

videos,107 audio,108 and campaigns such as “Pass It On”—an innovative means of arming older 

consumers with information about scams that they can “pass on” to their friends and family 

members.109 

The FTC is taking additional steps to communicate information to consumers about the 

available call-blocking solutions that might reduce the amount of unwanted calls they receive. 

101 See, e.g., FTC Consumer Information Blocking Unwanted Calls 

https://www.consumer.ftc.gov/articles/0548-blocking-unwanted-calls. 

102 See, e.g., FTC Consumer Information Scam Alerts, 

https://www.consumer.ftc.gov/scam-alerts. 

103 See, e.g., FTC Robocall Microsite, http://www.consumer.ftc.gov/features/feature0025-robocalls. 

104 See, e.g., FTC Consumer Information Blog, Looking to Block Unwanted Calls? 

https://www.consumer.ftc.gov/blog/looking-block-unwanted-calls; FTC Consumer Information 

Blog, That’s Not Your Neighbor Calling https://www.consumer.ftc.gov/blog/2018/01/thats-notyour-neighbor-calling; FTC Consumer Information Blog,Apps to Stop Robocalls 

https://www.consumer.ftc.gov/blog/2017/10/apps-stop-robocalls. 

105 See, e.g., FTC Robocalls Facebook Q&A Transcript (Oct. 25, 2012), 

https://www.ftc.gov/sites/default/files/attachments/ftc-facebook-chats/1210robocallschallengefb.pdf. 

106 See, e.g., FTC Robocalls Infographic, 

https://www.ftc.gov/sites/default/files/documents/public_events/robocalls-all-rage-ftcsummit/pdf-0113-robocalls-infographic.pdf. 

107 See, e.g., FTC Video and Media, http://www.consumer.ftc.gov/media. 

108 See, e.g., FTC Consumer Information Audio, “Hang Up on Robocalls,” 

http://www.consumer.ftc.gov/media/audio-0045-hang-robocalls. 

109 See Pass It On, http://www.consumer.ftc.gov/features/feature-0030-pass-iton#identity-theft. 
 

 

 

 

 

 

 

On April 23, 2018, the FTC is co-hosting with the FCC a “Stop Illegal Robocalls Expo.”110 The 

Expo will feature innovative technologies, devices, and applications to minimize or eliminate the 

number of illegal robocalls consumers receive.111 The Expo is free and open to the public.112 In 

late March, the FTC also put out additional information on its websites regarding how to stop 

unwanted calls for different types of phone services: mobile, landline or VOIP.113 

IV. Next Steps and Conclusion 

The Do Not Call Registry continues to help protect consumers against unsolicited calls 

from legitimate telemarketers. However, as technology continues to develop and fraudsters 

exploit those developments, we must remain agile and creative. The Commission will continue 

its multifaceted efforts to fight illegal robocalls, including the following actions: 

 Continue Aggressive Law Enforcement 

o We will maintain our enforcement efforts, in coordination with state, federal, and 

international partners, to target high-volume offenders and pursue robocall 

gatekeepers in order to stop the largest number of illegal calls. 

o We will work with the telecommunications industry, encouraging carriers to be 

proactive in monitoring for illegal robocalls, blocking illegal calls, and securing 

the information necessary for prosecutions. 

 Spur Innovation 

110 See Press Release, FTC and FCC Seek Exhibitors for an Expo Featuring 

Technologies to Block Illegal Robocalls (Mar. 7, 2018) available at https://www.ftc.gov/newsevents/press-releases/2018/03/ftc-fcc-seek-exhibitors-expo-featuring-technologies-block-illegal. 

111 Id. 

112 Id. 

113 See FTC Consumer Information How to Stop Unwanted Calls available at 

https://www.consumer.ftc.gov/features/how-stop-unwanted-calls. A copy of this guidance is 

attached at Exhibit B. 
o We will work with industry leaders and other experts to further stimulate the 

development of technological solutions to protect consumers from illegal 

robocalls. 

o We will continue to encourage industry-wide coordination to create and deploy 

VoIP standards that incorporate robust authentication capabilities. Such 

coordination is the only way to ensure a future phone system with accurate and 

truthful calling information. 

 Engage in Ongoing Consumer Education 

o We will continue our broad outreach to consumers regarding the Do Not Call 

Registry as well as illegal robocalls and how best to fight them. 

Thank you for the opportunity to share some of the highlights regarding the FTC’s battle against 

illegal robocalls. We look forward to working with you on this important issue. 
EXHIBIT A 
Federal Trade Commission 

December 2017 

National 

Do Not Call 

Registry 

Data Book 

FY 2017 
The National Do Not Call Registry Data Book

The Data Book

The National Do Not Call Registry Data Book contains statistical data about phone numbers on the

Registry, telemarketers and sellers accessing phone numbers on the Registry, and complaints

consumers submit to the FTC about telemarketers allegedly violating the Do Not Call rules. Statistical

data on Do Not Call (DNC) complaints is based on unverified complaints reported by consumers, not on

a consumer survey.

New in FY 2017

x When reporting the total number of DNC complaints, the Data Book now breaks the

number down to show how many complaints were about robocalls and how many were

from live callers. With a few exceptions, telemarketing robocalls are illegal, whether or not

a number is on the Do Not Call Registry. As always, when it’s a live caller, we verify that the

consumer’s telephone number was on the Do Not Call Registry before we take the

complaint.

x The online complaint form now asks for the topic of the call, so this new informationis

included in the Data Book.

o Consumers can choose to report specific topics, such as reducing debt, vacation &

timeshares, and several other categories.Not everyone who files a complaint

reports a topic.

o The Data Book does not include statistics where a consumer chose “Other,” or topics

less likely to violate the Do Not Call Rules, such as debt collection, political, or

charitable calls.

x The Data Book now includes a stateͲbyͲstate analysis of DNC complaints, and it has a new,

more accurate way of reporting a consumer’s state:

o If consumers report their state, the Data Book always uses the state they report.

o If consumers do not report their state, the Data Book uses their area code.

o The stateͲbyͲstate analysis also includes the top 10 topics of consumer complaints.

x The underlying data in the report is available on our open government site at:

www.ftc.gov/ĚŽŶŽƚĐĂůůͲĚĂƚĂďŽŽŬϮϬϭϳ.

Inside the numbers

x States are ranked based on the number of registrations or complaints per 100,000 population.

Complaint figures include the total number of FY 2017 complaints submitted to the FTC.

Population estimates are based on 2016 U.S. Census population estimates (Table NSTͲEST2016Ͳ

01 – Annual Estimates of the Population for the United States, Regions, States, and Puerto Rico:

April 1, 2010 to July 1, 2016).

x For the purposes of this report, “active registrations” are those registrations consumers have

placed on the Registry that have not been subsequently deleted by the consumer or removed

by the FTC. The FTC removes numbers that have been disconnected and reassigned.
FY 2017 

NaƟonal Do Not Call Registry 

Who is using the Do Not Call Registry 

AcƟve RegistraƟons by Fiscal Year 

210M 

212M 

214M 

216M 

218M 

220M 

222M 

224M 

226M 

228M 

230M 229,816,164 

226,001,288 

222,841,544 

217,855,796 

213,400,641 

2013 2014 2015 2016 2017 

"AcƟve RegistraƟons" reflect the total number of phone numbers registered on the NaƟonal Do Not Call Registry for each fiscal year as of September 30, 2017. 

OrganizaƟons Accessing the Registry by Fiscal Year 

2013 2014 2015 2016 2017 

5 or Fewer Area Codes 

OrganizaƟons Who Paid 

Exempt OrganizaƟons 

Total 

24,182 23,049 20,075 17,634 15,536 

2,877 2,582 2,502 2,353 2,259 

598 585 521 503 543 

27,657 26,216 23,098 20,490 18,338 

Telemarketers and sellers can access up to five area codes on the Registry for free. To access more than five area codes, they must pay a fee. OrganizaƟons that are not selling goods 

or services are "exempt" and can access numbers on the Registry for free. This includes organizaƟons asking for charitable contribuƟons, raising money for poliƟcal purposes, or 

conducƟng surveys. It also includes organizaƟons calling only people they have an established business relaƟonship with or who have given the organizaƟon wriƩen permission to call. 
FY 2017 

NaƟonal Do Not Call Registry 

Complaint Figures by Year 

Complaints by Call Type and Fiscal Year 

Live Caller 

Robocall 7,157,370 

7M 

6M 

2,563,081 

5,340,234 

5M 

4M 

3,748,646 

4,501,967 

1,854,718 

3,578,710 

3,241,086 

3M 1,510,485 

1,388,470 

1,448,382 

2M 

3,401,614 

2,182,158 2,125,968 1M 

1,734,603 

0M 

2013 2014 2015 2016 2017 

The total includes complaints about robocalls, complaints about live callers, and complaints where the call type was not reported. The number of calls where a call type was not 

reported is relaƟvely small every year. The data is available at www.Ōc.gov/donotcall-databook2017. 
FY 2017 

NaƟonal Do Not Call Registry 

Complaint Figures for the Year 

Live Caller 

FY 2017 Complaints by Topic* Robocall 

Reducing debt 

VacaƟon & Ɵmeshares 

WarranƟes & protecƟon plans 

Imposters 

Medical & prescripƟons 

Energy, solar & uƟliƟes 

Computer & technical support 

Home security & alarms 

LoƩeries, prizes & sweepstakes 

Home improvement & cleaning 

Work from home 

*Not everyone who files a complaint reports a topic. 

39,159 5,439

40,663 

22,061 

21,225 

24,796 

67,678 

80,543 

51,616 

85,142 

71,672 

116,234 

179,925 

81,849 

223,119 

235,678 

51,403 

771,158 

60,928 

77,999 

66,993 

90,100 

Live Caller 

2,563,081 

Call Type Not Reported 

92,322 

Robocall 

4,501,967 

FY 2017 Complaints by Call Type 

FY 2017 Complaints by Month 

939,002 926,308 

900K 

800K 

700K 

600K 

500K 

400K 

300K 

200K 

100K 

0K 

October November December January February March April May June July August September 

268,526 

614,951 622,692

471,256

408,031 418,060

368,972 379,477

330,264 

218,897 196,978 203,863

156,277 

315,625 293,367

247,529 

232,017 235,288

239,057 225,687 

199,792 

139,321 135,323 143,798 

368,586 

341,351 343,969 

537,038 

602,592 

627,649 

652,342 659,101

727,562 

431,870 

The total includes complaints about robocalls, complaints about live callers, and complaints where the call type was not reported. The number of calls where a call type was not 

reported is relaƟvely small every month. The full data, as well as complaints reporƟng that the consumer asked the enƟty to stop calling, is available at 

www.Ōc.gov/donotcall-databook2017. The FTC idenƟfied a technical problem with complaint submissions that resulted in arƟficially high complaint counts in July and August. The FTC 

addressed the issue, and September’s figures reflect the adjustment. 
FY 2017 

NaƟonal Do Not Call Registry 

RegistraƟons by State 

State Rankings for NaƟonal Do Not Call Registry RegistraƟons per 100K PopulaƟon 

MO 

NM 

MN 

WA 

MD 

WV 

MA 

WY 

MT 

ME 

MS 

OH 

NH 

ND 

NV 

GA 

OR 

OK 

CO 

VA 

NC 

NY 

WI 

AR 

TN 

UT 

NE 

MI 

PA 

CA 

DE 

SD VT 

AZ 

KY 

TX 

AL 

LA 

KS 

SC 

NJ IN 

ID 

FL 

IA 

IL 

HI 

AK 

PR 

DC 

Rank 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

AcƟve RegistraƟons Consumer State AcƟve RegistraƟons per 100K PopulaƟon 

New Hampshire 

ConnecƟcut 

MassachuseƩs 

Maine 

New Jersey 

Kansas 

Colorado 

Vermont 

Michigan 

Wisconsin 

Pennsylvania 

Iowa 

Nebraska 

Delaware 

Ohio 

Wyoming 

Minnesota 

Illinois 

Maryland 

Rhode Island 

Montana 

Kentucky 

New Mexico 

Virginia 

South Dakota 

Oregon 

1,222,035 91,552 

3,183,068 89,001 

5,794,655 85,068 

1,092,143 82,025 

7,306,538 81,688 

2,359,523 81,159 

4,444,187 80,212 

500,495 80,131 

7,942,407 79,998 

4,621,662 79,977 

10,209,190 79,858 

2,490,336 79,444 

1,496,889 78,490 

746,072 78,364 

9,085,945 78,230 

457,902 78,207 

4,316,316 78,195 

9,960,663 77,808 

4,654,404 77,361 

813,061 76,963 

794,053 76,167 

3,329,393 75,037 

1,548,728 74,422 

6,189,394 73,580 

634,341 73,296 

2,971,402 72,589 

Rank 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

AcƟve RegistraƟons Consumer State AcƟve RegistraƟons per 100K PopulaƟon 

New York 

Washington 

Florida 

Tennessee 

Alabama 

Idaho 

North Dakota 

Georgia 

Oklahoma 

Arkansas 

West Virginia 

North Carolina 

Nevada 

Arizona 

Missouri 

California 

Utah 

Indiana 

South Carolina 

Louisiana 

Texas 

Mississippi 

Hawaii 

Alaska 

District of Columbia 

Puerto Rico 

14,052,247 71,168 

5,166,189 70,886 

14,605,866 70,859 

4,703,989 70,724 

3,393,619 69,780 

1,171,358 69,594 

524,414 69,188 

7,095,159 68,816 

2,675,174 68,182 

2,031,921 67,997 

1,240,873 67,766 

6,810,043 67,115 

1,955,039 66,497 

4,596,446 66,317 

4,040,559 66,315 

25,926,903 66,056 

1,938,175 63,521 

4,169,999 62,867 

3,063,994 61,760 

2,824,750 60,336 

15,469,941 55,522 

1,636,395 54,752 

781,815 54,728 

366,837 49,446 

620,154 91,042 

399,156 11,701 

The District of Columbia and Puerto Rico are included in the table but are not ranked. States are ranked based on the number of acƟve registraƟons per 100,000 populaƟon. AcƟve 

registraƟons include all phone numbers on the NaƟonal Do Not Call Registry as of September 30, 2017. PopulaƟon esƟmates are based on 2016 U.S. Census populaƟon esƟmates. 
FY 2017 

NaƟonal Do Not Call Registry 

Complaints by State 

State Rankings for NaƟonal Do Not Call Registry Complaints per 100K PopulaƟon 

MO 

NM 

MN 

WA 

MD 

WV 

MA 

WY 

MT 

ME 

MS 

OH 

NH 

ND 

NV 

GA 

OR 

OK 

CO 

VA 

NC 

NY 

WI 

AR 

TN 

UT 

NE 

MI 

PA 

CA 

DE 

SD VT 

AZ 

KY 

TX 

AL 

LA 

KS 

SC 

NJ IN 

ID 

FL 

IA 

IL 

HI 

AK 

PR 

DC 

Rank 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

Complaints per 100K Consumer State Complaints PopulaƟon 

New Jersey 

Delaware 

Florida 

Virginia 

New Hampshire 

Michigan 

ConnecƟcut 

Rhode Island 

Maryland 

Arizona 

Tennessee 

Vermont 

Ohio 

Nevada 

Georgia 

Colorado 

Illinois 

New York 

MassachuseƩs 

Oregon 

Nebraska 

Alabama 

Maine 

Utah 

Pennsylvania 

California 

321,393 3,593 

27,691 2,909 

588,021 2,853 

232,818 2,768 

36,401 2,727 

265,465 2,674 

94,440 2,641 

26,590 2,517 

150,346 2,499 

169,702 2,448 

158,896 2,389 

14,896 2,385 

276,667 2,382 

69,639 2,369 

242,242 2,349 

129,609 2,339 

295,218 2,306 

454,100 2,300 

156,006 2,290 

93,121 2,275 

43,255 2,268 

108,003 2,221 

29,495 2,215 

66,229 2,171 

271,832 2,126 

824,692 2,101 

Rank 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

Complaints per 100K Consumer State Complaints PopulaƟon 

Arkansas 

Montana 

Iowa 

Wyoming 

Texas 

South Carolina 

Idaho 

North Carolina 

Kansas 

Louisiana 

New Mexico 

Washington 

Indiana 

Wisconsin 

Minnesota 

Kentucky 

Oklahoma 

West Virginia 

South Dakota 

Mississippi 

North Dakota 

Missouri 

Hawaii 

Alaska 

District of Columbia 

Puerto Rico 

61,697 2,065 

21,211 2,035 

63,502 2,026 

11,808 2,017 

559,563 2,008 

99,620 2,008 

33,157 1,970 

199,407 1,965 

55,207 1,899 

86,267 1,843 

37,653 1,809 

125,689 1,725 

114,241 1,722 

98,352 1,702 

91,166 1,652 

72,110 1,625 

61,962 1,579 

28,738 1,569 

13,316 1,539 

39,969 1,337 

9,881 1,304 

74,102 1,216 

16,055 1,124 

3,041 410 

24,303 3,568 

1,638 48 

The District of Columbia and Puerto Rico are included in the table but are not ranked. States are ranked based on the number of complaints per 100,000 populaƟon. Complaints 

include the total number of FY 2017 complaints submiƩed to the FTC. PopulaƟon esƟmates are based on 2016 U.S. Census populaƟon esƟmates. 
FY 2017 

NaƟonal Do Not Call Registry Alabama

RegistraƟon and Complaint Figures by State 

Complaints by County 

Reducing debt 

WarranƟes & protecƟon plans 

Home security & alarms 

Imposters 

Medical & prescripƟons 

VacaƟon & Ɵmeshares 

Computer & technical support 

LoƩeries, prizes & sweepstakes 

Work from home 

Home improvement & cleaning 

13,673 

5,036 

3,973 

3,390 

3,305 

1,783 

1,386 

1,110 

584 

253 

Complaints by Topics* 

*Not everyone who files a complaint reports a topic. 

State Totals 

Complaints: 108,003 (#22 naƟonally, per 100K populaƟon) 

AcƟve RegistraƟons: 3,393,619 (#31 naƟonally, per 100K populaƟon) 

Complaints by Fiscal Year 

100K 108,003

81,834 

50K 66,812 

49,227 46,251 

0K 

2013 2014 2015 2016 2017 

AcƟve RegistraƟons by Fiscal Year 

3.13M 3.39M 3M 3.20M 3.28M 3.33M 

2M 

1M 

0M 

2013 2014 2015 2016 2017 

Complaints by Call Type 

Call Type Not Reported 

1,480 

Live Caller 

34,896 

Robocall 

71,627 
EXHIBIT B 
 

How to stop unwanted calls 

ON A MOBILE PHONE 

See what 

built-in features 

your phone has. 

Download a call-blocking app. 

• Some apps are free, but 

others charge a monthly fee. 

• Some apps will access 

your contacts. 

• Calls might be stopped, 

ring silently, or go straight 

to voicemail. 

See what services 

Report unwanted calls at

your carrier ofers. ftc.gov/complaint 

FEDERAL TRADE COMMISSION • ftc.gov/callsgov/calls 
How to stop unwanted calls 

IF YOU USE VOIP 

Look into 

internet-based 

services. Your carrier 

might be able to help. 

Some services 

are free, but 

others charge

 a monthly fee. 

Not sure if your home phone 

uses the internet (VOIP)? 

Check with your carrier. 

With blocking services, 

calls might be stopped, ring silently, 

or go straight to voicemail. 

Report unwanted calls at 

ftc.gov/complaint 

FEDERAL TRADE COMMISSION • ftc.gov/calls 
How to stop unwanted calls 

ON A LANDLINE 

See what services 

your carrier ofers. Install a call-blocking device. 

Some use blacklists to 

Some services 

are free, but 

others charge

 a monthly fee. 

• stop unwanted calls 

• divert calls to voicemail 

Some use whitelists of 

approved numbers. 

Report unwanted calls at 

ftc.gov/complaint 

FEDERAL TRADE COMMISSION • ftc. gov/calls