Prepared Statement of

The Federal Trade Commission

Before the 

United States Senate

Special Committee on Aging

on

Combatting Illegal Robocalls: Initiatives to End the Epidemic

Washington, DC

June 10, 2015
1

Chairman Collins, Ranking Member McCaskill, 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, including those that target seniors.

2

 

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.

3

The Registry, which includes more than 217 million active telephone numbers,4 has been 

tremendously successful in protecting consumers’ privacy from the unwanted calls of tens of 

thousands of legitimate telemarketers who subscribe to the Registry each year.

5 More recently,

 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 See, e.g., FTC v. Worldwide Info. Servs., Inc., No. 14-cv-8-ORL-28DAB (M.D. Fla. Jan. 

13, 2014), available at https://www.ftc.gov/enforcement/cases-proceedings/132-3175/worldwide-infoservices-inc; see generally FTC v. Inbound Call Experts, LLC, et al, No. 14-cv-81395-KAM (S.D. Fla. 

Nov. 10, 2014), available at https://www.ftc.gov/enforcement/cases-proceedings/132-3135/inbound-callexperts-llc; FTC v. Consumer Collection Advocates, Corp., et al, No. 14-cv-62491-BB (S.D. Fla. Nov. 3, 

2014), available at https://www.ftc.gov/enforcement/cases-proceedings/142-3082/consumer-collectionadvocates-corp; FTC v. Instant Response Sys. LLC, et al, No. 113-cv-0976 (E.D.N.Y. Mar. 11, 2013), 

available at https://www.ftc.gov/enforcement/cases-proceedings/1223041/instant-response-systems-llcet-al. 

3 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. 

4 See National Do Not Call Registry Active Registrations and Complaint Figures. National 

Do Not Call Registry Data Book FY 2014 at 4 (Nov. 2014), available at 

https://www.ftc.gov/reports/national-do-not-call-registry-data-book-fiscal-year-2014.

5 For example, in fiscal year 2014, more than 26,000 telemarketers accessed the Do Not 

Call Registry. National Do Not Call Registry Data Book FY 2012 at 8 (Nov. 2014), available at

https://www.ftc.gov/reports/national-do-not-call-registry-data-book-fiscal-year-2014.
2

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.6 In 2008, the 

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

calls.7 

Illegal robocalls remain a significant consumer protection problem because they

repeatedly disturb consumers’ privacy and frequently peddle fraudulent goods and services that 

cause significant economic harm. The FTC is using every tool at its disposal to fight them.

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 

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

 6 See Section II(A), infra.

7 73 Fed. Reg. 51164 (Aug. 29, 2008); 16 C.F.R. Part 310.4(b)(1)(v). 

8 See FTC Robocall Initiatives, http://www.ftc.gov/robocalls (last visited June 2, 2015).

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-releases/2003/09/ftc-files-motion-stay-pendingappeal-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-chairmantimothy-j-muris. 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/press-releases/2003/09/statementftc-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-courtupholds-constitutionality-national-do-not-call. 
3

120 enforcement actions seeking civil penalties,

10 restitution for victims of telemarketing scams, 

and disgorgement of ill-gotten gains against 377 corporations and 298 individuals. From the 110 

cases that have been resolved thus far, the courts have awarded judgments of over $1 billion in 

equitable monetary relief and civil penalties, of which the Commission has collected over $100 

million.11

A. Robocall Law Enforcement

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

of robocalls selling a good or service.12 The robocall provisions cover prerecorded calls to all 

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

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

filing 37 cases against 121 companies and 90 individuals responsible for billions of illegal 

robocalls.

13 The 34 cases that have concluded thus far have resulted in judgments totaling more 

than $485 million in civil penalties, redress, or disgorgement.14

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

subject to civil penalties of up to $16,000 per violation. 15 U.S.C. § 45(m)(1)(A); 16 C.F.R. 1.98(d).

11 We appreciate the significant difference between the amounts ordered and collected. 

Fraudsters tend to rapidly dissipate ill-gotten gains. We strive to locate as much money as practicable in 

each case.

12 Like the other provisions of the TSR, the robocall provisions do not apply to non-sales 

calls, such as calls placed by charities or those that are purely political, informational, or survey calls. See 

generally “Complying with the Telemarketing Sales Rule” (Feb. 2011), 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. Part 310.4(b)(1)(v)(D), and for certain calls 

placed by telemarketers who solicit charitable contributions, 16 C.F.R. Part 310.4(b)(1)(v)(B).

13 The FTC filed 12 of the 37 cases before the rule change went into effect on September 1, 

2009. 

14 The agency has collected $28 million of the total judgments awarded. Some of the 

Commission’s early robocall cases were against companies with household names such as Talbots, Dish 

Network, and DIRECTV. See U.S. v. The Talbots, Inc., No. 10-cv-10698 (D. Mass. Apr. 27, 2010), 
4

Yet increasingly, fraudsters, who often hide in other countries in an attempt to escape 

detection and punishment, make robocalls that harass and defraud consumers. For example, in 

FTC v. Navestad, the Commission successfully traced and sued robocallers even after they

attempted to hide their identities through fake caller IDs, shifting foreign operations, and name 

changes. The court found that the defendants made in excess of eight million illegal robocalls

and ordered them to pay $30 million in civil penalties and give up more than $1.1 million in illgotten gains.

15

Accordingly, the Commission has sought to maximize the impact of its law enforcement 

efforts, and targeted those that facilitated the illegal conduct to strike a blow against many lawbreakers. For example, the Commission has pursued actions against “autodialers” or companies 

that provide the equipment or software necessary to send out millions of calls.16 The 

Commission has also filed suit against payment processors for assisting and facilitating 

robocallers by providing access to the financial networks.17 

 

available at https://www.ftc.gov/news-events/press-releases/2010/04/womens-clothing-retailer-talbotsits-telemarketer-pay-total; U.S. v. Dish Network, LLC, No. 3:09-cv-03073 (C.D. Ill. Feb. 4, 2010), 

available at https://www.ftc.gov/news-events/press-releases/2009/03/ftc-charges-dish-network-formerlyknown-echostar-multiple-do-not; U.S. v. DIRECTV, Inc., No. 09-02605 (C.D. Cal. Apr. 23, 2009), 

available at https://www.ftc.gov/news-events/press-releases/2009/04/directv-comcast-pay-total-321-

million-entity-specific-do-not-call. Although the Dish case remains in litigation, the Court granted partial 

summary judgment against Dish in January 2015. Press Release, Court Grants Partial Summary 

Judgment in FTC Case Against Dish Network, Finding Company Liable for Tens of Millions of 

Telemarketing Violations (Jan. 21, 2015), available at https://www.ftc.gov/news-events/pressreleases/2015/01/court-grants-partial-summary-judgment-ftc-case-against-dish. 

15 FTC v. Navestad, No. 09-CV-6329 (W.D.N.Y. Mar. 23, 2012), available at

https://www.ftc.gov/news-events/press-releases/2012/04/ftc-case-against-deceptive-robocallers-leadsrecord-30-million. 

16 See, e.g., FTC v. Asia Pac. Telecom, Inc., No. 1:10-3168 (N.D. Ill. Mar. 28, 2012), 

available at https://www.ftc.gov/news-events/press-releases/2012/03/ftc-action-puts-robocallers-outtelemarketing-business. 

17 In FTC v. WV Universal Mgmt., LLC, a Court held both the robocaller and its payment 

processor jointly liable for $1.7 million for peddling bogus credit card interest rate reduction services. 
5

B. Coordination with Civil 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. In addition, the FTC 

regularly works with the Federal Communications Commission (“FCC”), the Department of 

Justice, 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 practice of faking a call’s identifying 

information. 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. 

The Commission also coordinates with various partners to bring law enforcement actions. 

For example, in March 2015, the FTC joined forces with ten state Attorneys General to file suit

against Caribbean Cruise Lines and seven other companies for blasting billions of robocalls that 

attempted to sell consumers a cruise to the Bahamas.

18 In this ongoing suit, the FTC sued the 

telemarketer, the companies that placed the robocalls, and the companies that helped the 

telemarketer spoof its caller ID to hide its identity.

 

See Press Release, Court Finds Defendants in FTC’s Treasure Your Success “Rachel Robocalls” Case 

Liable for $1.7 Million (May 20, 2015), available at https://www.ftc.gov/news-events/pressreleases/2015/05/court-finds-defendants-ftcs-treasure-your-success-rachel; see also FTC v. Innovative 

Wealth Builders, Inc., No. 13-cv-00123 (M.D. Fla. June 5, 2013), available at

https://www.ftc.gov/enforcement/cases-proceedings/122-3127/innovative-wealth-builders-inc-et-al.

18 Press Release, FTC and Ten State Attorneys General Take Action Against Political 

Survey Robocallers Pitching Cruise Line Vacations to the Bahamas (March 4, 2015), available at 

https://www.ftc.gov/news-events/press-releases/2015/03/ftc-ten-state-attorneys-general-take-actionagainst-political. The state co-plaintiffs are Colorado, Florida, Indiana, Kansas, Mississippi, Missouri, 

North Carolina, Ohio, Tennessee, and Washington.
6

The FTC also leads robocall law enforcement “sweeps” – coordinated, simultaneous law 

enforcement actions – in conjunction with state and federal partners.

19 In 2012, the FTC and its 

partners mounted a concerted attack on illegal robocalls purporting to be from “Cardholder 

Services,” which falsely claimed they could reduce consumers’ credit card interest rates in 

exchange for an up-front fee, often hundreds of dollars. The FTC brought five cases against 

companies that were allegedly responsible for millions of these illegal calls. The Commission 

simultaneously announced that state law enforcement partners in Arizona, Arkansas, and Florida 

had filed separate law enforcement actions as part of the sweep.20

C. Referrals for Criminal Prosecution

Although the Commission does not have criminal law enforcement authority, it 

recognizes the importance of criminal prosecution in deterrence. Accordingly, the Commission 

routinely works with federal and state criminal law enforcers through its Criminal Liaison Unit 

(“CLU”). Since CLU’s launch in 2003, hundreds of fraudulent telemarketers have found 

 19 The following describe some of the telemarketing and robocall sweeps that the FTC and 

its law enforcement partners have conducted over the past several years: Press Release, FTC Leads Joint 

Law Enforcement Effort Against Companies that Allegedly Made Deceptive “Cardholder Services” 

Robocalls (Nov. 1, 2012), available at https://www.ftc.gov/news-events/press-releases/2012/11/ftc-leadsjoint-law-enforcement-effort-against-companies; Press Release, FTC Settlements Put Debt Relief 

Operations Out of Business (May 26, 2011), available at https://www.ftc.gov/news-events/pressreleases/2011/05/ftc-settlements-put-debt-relief-operations-out-business; Press Release, FTC Sues to Stop 

Robocalls with Deceptive Credit Card Interest-Rate Reduction Claims (Dec. 8, 2009), available at

https://www.ftc.gov/news-events/press-releases/2009/12/ftc-sues-stop-robocalls-deceptive-credit-cardinterest-rate; Press Release, FTC Cracks Down on Scammers Trying to Take Advantage of the Economic 

Downturn (July 1, 2009), available at https://www.ftc.gov/news-events/press-releases/2009/07/ftccracks-down-scammers-trying-take-advantage-economic-downturn; Press Release, FTC Announces 

“Operation Tele-PHONEY,” Agency’s Largest Telemarketing Sweep (May 20, 2008), available at

https://www.ftc.gov/news-events/press-releases/2008/05/ftc-announces-operation-tele-phoney-agencyslargest-telemarketing.

20 See Press Release, FTC Leads Joint Law Enforcement Effort Against Companies that 

Allegedly Made Deceptive “Cardholder Services” Robocalls (Nov. 1, 2012), available at

https://www.ftc.gov/news-events/press-releases/2012/11/ftc-leads-joint-law-enforcement-effort-againstcompanies.
7

themselves facing criminal charges and prison time. In the Voice Touch case, for example, 

robocallers pitched an auto warranty scam. The FTC case shut down the scam and the 

Commission was able to provide almost $3.2 million in redress to consumers as a result of the 

litigation.21 The Office of the U.S. Attorney for the Southern District of Illinois subsequently 

brought criminal charges; three of the fraud’s principals have pleaded guilty and gone to prison, 

with the two leaders of the scheme sentenced to five years in prison.

22

In Economic Relief Technologies, Kara Singleton Adams, the leader of a scam that used 

robocalls to sell worthless credit card interest rate reduction services, faced criminal prosecution 

from the Department of Justice after the Commission shut down her operation.

23 A federal jury 

in Atlanta convicted Adams on charges of wire fraud and conspiracy and the court sentenced her 

to more than 17 years of imprisonment in 2012. Three of her associates in the scheme also went 

to prison.24

II. Policy and Market Stimulation Initiatives

Despite the 2008 prohibition of unauthorized robocalls and the Commission’s vigorous 

 21 Press Release, FTC Returns Almost $3.2 Million to Auto Warranty Robocall Victims 

(Aug. 31, 2011), available at https://www.ftc.gov/news-events/press-releases/2011/08/ftc-returns-almost32-million-auto-warranty-robocall-victims; FTC v. Voice Touch, Inc., No. 09CV2929 (N.D. Ill. Aug. 23, 

2010), available at https://www.ftc.gov/news-events/press-releases/2010/08/auto-warranty-robocallerpay-23-million-sell-mercedes-consumer. 

22 Department of Justice (“DOJ”) Press Release, “Auto Warranty” Telemarketer Pleads 

Guilty (June 15, 2012), available at http://www.justice.gov/sites/default/files/usaosdil/legacy/2014/12/10/Auto%20Warranty%20Telemarketer%20Pleads%20Guilty.pdf; DOJ Press 

Release, Update on Transcontinental Warranty Case (Oct. 31, 2011), available at

http://www.justice.gov/usao/ils/Programs/VWA/transcontinental.html.

23 FTC v. Econ. Relief Techs., LLC, No. 09-CV-3347 (N.D. Ga. July 22, 2010), available at 

https://www.ftc.gov/news-events/press-releases/2012/09/ftc-sends-refunds-victims-robocall-credit-cardinterest-rate.

24 DOJ Press Release, Adams Sentenced to Over 17 Years in Prison for Multi-Million 

Dollar Telemarketing Fraud Scheme (Feb. 9, 2012), available at

http://www.justice.gov/archive/usao/gan/press/2012/02-09-12.html. 
8

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.25 That 

number has now more than doubled - the FTC currently receives approximately 150,000 robocall

complaints per month.26

A. Understanding the Landscape of the Robocall Problem

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. These efforts 

were ramped up on October 18, 2012, when the Commission hosted a public summit on 

robocalls to explore these issues (the “Robocall Summit”).

27 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 

 25 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.

26 National Do Not Call Registry Data Book FY 2014 at 5 (Nov. 2014), available at

https://www.ftc.gov/reports/national-do-not-call-registry-data-book-fiscal-year-2014. 

27 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.
9

caller ID information. The telephone network has its origins in a manual switchboard that 

allowed a human operator to make connections between two known entities.28 A small group of 

well-known carriers were in control and were highly regulated.29 Placing calls took significant 

time and money, and callers could not easily conceal their identities.

30

Now, anyone can build a viable telephone services business wherever there is an Internet

connection.31 As a result, the number of service providers has grown exponentially and now 

includes thousands of small companies all over the world.32 In addition, VoIP technology allows 

consumers to enjoy high-quality phone calls with people on the other side of the globe for an 

affordable price.33 With this efficiency came other changes: instead of a voice path between one 

wire pair, the call travels as data; identifying information can be spoofed; many different players 

are involved in the path of a single call; and the distance between the endpoints is not 

particularly important.34 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. New Technologies Have Made Robocalls Extremely Inexpensive

Until recently, telemarketing required significant capital investment in specialized 

hardware and labor.35 Now, robocallers benefit from automated dialing technology, inexpensive 

 28 Bellovin, Tr. at 12.

29 Schulzrinne, Tr. at 22; Rupy, Tr. at 46-47; Diggs, Tr. at 55.

30 Bellovin, Tr. at 12-17.

31 Herrman, Tr. at 60-61; Maxson, Tr. at 96.

32 Schulzrinne, Tr. at 22.

33 See, e.g., Bellovin, Tr. at 16-17.

34 Id. at 17.

35 Herrmann, Tr. at 58-59; Schulzrinne, Tr. at 24.
10

long distance calling rates, and the ability to move internationally and employ cheap labor.36

The only necessary equipment is a computer connected to the Internet.

37 The result: lawbreaking telemarketers can place robocalls for less than 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, placing automated calls, 

gathering consumers’ personal information, or selling products.38 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.39

Technology enables a cheap and scalable model for robocalls.40

 36 Schulzrinne, Tr. at 24.

37 Herrmann, Tr. at 59-61.

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

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

40 The PSTN is the “Public Switched Telephone Network.” It consists of transmission 

facilities (e.g., phone lines, fiber optic cables, microwave transmission links, cellular radios, 

communication satellites, etc.) and switching facilities (central office switches, databases for 800 number 

translation, gear for cellular handoffs, multiplexors, etc.).
11

2. New Technologies 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 the majority of calls. 

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

legacy carriers before reaching the end user.41 Each of these carriers knows which carrier passed 

a particular phone call onto its network, but likely knows little else about the origin of the call.42

Such a path makes it cumbersome to trace back to a call’s inception.43 All too often, this process

to trace the call fails completely because one of the carriers in the chain has not retained the 

records that would further an investigation.44

Second, new technologies allow callers to easily manipulate the caller ID information 

that appears with an incoming phone call.45 While “caller ID spoofing” has some beneficial 

uses,

46 it also allows robocallers 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.

47 In addition, 

robocallers can change their phone numbers frequently in an attempt to avoid detection.48

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

42 Panagia, Tr. at. 132; Maxson, Tr. at 100.

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

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

45 Schulzrinne, Tr. at 24-26.

46 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).

47 Schulzrinne, Tr. at 21-22.

48 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 
12

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

are most likely to face prosecution.49 Indeed, all of the many different 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 globe.

 

Truth in Caller ID Act, 47 U.S.C.§ 227(e); cf. 16 C.F.R. Part 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.).

49 Schulzrinne, Tr. at 21; Bellovin, Tr. at 16-17.
13

B. Need 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 held its first public contest in 

October 2012, offering a $50,000 prize to the individual or small team who proposed the best

technological solution that blocks robocalls on consumers’ landlines and mobile phones. After 

reviewing 798 submissions, the FTC announced three winning solutions on April 2, 2013.

50 Six 

months later, one of the solutions, Nomorobo, was made available to consumers, and it now 

reports having over 170,000 subscribers51 and has blocked over 24 million robocalls.

52 

Following on the success of the first challenge, the FTC conducted its second contest, “Zapping 

Rachel,” in August 2014, offering $17,000 in prizes focused on the open source advancement of 

honeypot design.

53 Zapping Rachel challenged contestants to build a more advanced honeypot, 

identify vulnerabilities in an existing honeypot, and analyze data from a honeypot. The FTC 

 50 See Press Release, FTC Announces Robocall Challenge Winners; Proposals Would Use 

Call Filter Software to Reduce Illegal Calls (Apr. 2, 2013), available at 

http:/www.ftc.gov/opa/2013/04/robocall.shtm.

51 See Alina Tugend, A Year Fighting Robocalls, and Finding the Right Parts, N.Y. TIMES, 

Dec. 26, 2014, available at http://www.nytimes.com/2014/12/27/your-money/a-year-of-shortcuts-thefight-against-robocalls-gains-ground.html?_r=0. 

52 See Nomorobo Home Page, https://www.nomorobo.com/ (last visited June 2, 2015).

53 In 2012, the FTC launched its robocall honeypot – a group of phone lines that amasses 

information on robocalls, such as the date and time the honeypot receives the robocall and a recording of 

the robocall. The FTC utilizes the honeypot to collect evidence against robocallers and facilitate a more 

rapid law enforcement response. 
14

held Zapping Rachel at DEF CON 22, one of the most established conferences for information

security experts, and announced five winners on August 28, 2014.

54

The FTC is conducting two new robocall contests this summer: DetectaRobo and 

Robocalls: Humanity Strikes Back. DetectaRobo was held in conjunction with the 2015 

National Day of Civic Hacking on June 6-7, 2015, and asked contestants to analyze data from a 

honeypot and create predictive algorithms that identify robocalls.55 Robocalls: Humanity 

Strikes Back will be held in two phases with the final phase taking place at DEF CON 23, 

August 5-9, 2015. It challenges contestants to build solutions that not only block robocalls from 

reaching consumers, but enable consumers to forward those unwanted robocalls to a crowdsource honeypot so that law enforcement and industry stakeholders can use the data collected.56 

The FTC anticipates that the 2015 robocall contests will continue to encourage private sector 

development of new technologies that will advance the fight against robocalls and foster new 

industry partners.

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

Since 2012, in addition to stimulating technological developments through public 

challenges, 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 

 54 See Press Release, FTC Announces Winners of “Zapping Rachel” Robocall Contest 

(Aug. 28, 2014), available at https://www.ftc.gov/news-events/press-releases/2014/08/ftc-announceswinners-zapping-rachel-robocall-contest. 

55 See Fed. Trade Comm’n, DetectaRobo, https://www.ftc.gov/detectarobo (last visited June 

2, 2015); Press Release, FTC Announces New Robocall Contests to Combat Illegal Automated Calls 

(Mar. 4, 2015), available at https://www.ftc.gov/news-events/press-releases/2015/03/ftc-announces-newrobocall-contests-combat-illegal-automated.

56 See Fed. Trade Comm’n, Robocalls: Humanity Strikes Back, 

https://www.ftc.gov/strikeback (last visited June 2, 2015); Press Release, FTC Announces New Robocall 

Contests to Combat Illegal Automated Calls (Mar. 4, 2015), available at https://www.ftc.gov/newsevents/press-releases/2015/03/ftc-announces-new-robocall-contests-combat-illegal-automated.
15

(“M3

AAWG”). M3AAWG is a consortium of industry, regulators, and academics focused on

developing solutions to mitigate various forms of messaging abuse such as email spam.57 After 

discussions 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.58 

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.

59 The FTC further promotes technical advancements by collaborating with its 

counterparts in other countries, through its leadership in the London Action Plan (“LAP”), an 

international syndicate of government agencies and private sector representatives focused on 

international spam enforcement cooperation.60 In fact, LAP, M3

AAWG, and VTA SIG are 

currently meeting in Dublin, Ireland. The FTC is taking a leadership role in facilitating LAP’s 

enforcement initiatives and organizing and running these conferences.

3. Policies to Facilitate Market Solutions

The Commission has long recognized the need for policies that facilitate the development 

of technological products. In January 2015, FTC staff submitted a response to the FCC’s request 

for public comment on whether there are legal or regulatory prohibitions that prevent telephone 

 57 See M3

AAWG, Activities, https://www.m3aawg.org/ (last visited June 2, 2015).

58 See M3

AAWG, Voice and Telephony Abuse Special Interest Group, 

https://www.m3aawg.org/vta-sig#About_VTASIG (last visited June 2, 2015).

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

https://datatracker.ietf.org/wg/stir/charter/ (last visited June 2, 2015).

60 See London Action Plan, http://londonactionplan.org/ (last visited June 2, 2015).
16

carriers from offering call-blocking technology.61 The FTC staff comment outlined the vital 

need for call-blocking technologies as an integral component to providing subscribers with relief 

from illegal unwanted calls, and indicated its view that no legal impediments existed to prevent 

the provision of such services to subscribers.

62

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. 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, whether 

the offer involves fraudulent credit card services, so-called auto warranty protection plans, or 

bogus vacation travel packages, 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 

 61 Fed. Commc’n Comm’n, Consumer and Governmental Affairs Bureau Seeks Comment 

on Robocalls and Call-Blocking Issues Raised by the National Association of Attorneys General on 

Behalf of Thirty-Nine Attorneys General, DA 14-1700 (Nov. 24, 2014), available at 

https://www.fcc.gov/document/cgb-seeks-comment-call-blocking-letter-attorneys-general. 

62 See Fed. Trade Comm’n, FTC Staff Comment Before the Federal Communications 

Commission on Public Notice DA 14-1700, Regarding the Issues Relating to Carrier Implementation of 

Call-Blocking Technology (Jan. 23, 2015), available at https://www.ftc.gov/policy/policyactions/advocacy-filings/2015/01/ftc-staff-comment-federal-communications-commission. On May 27, 

2015, FCC Chairman Wheeler announced a proposal for the FCC to crack down on unwanted robocalls 

and text messages, which will be voted on by the FCC Commission on June 18. The proposal encourages

robocall-blocking technologies and clarifies that carriers can, and should, offer consumers robocallblocking tools. Fed. Commc’n Comm’n, Another Win For Consumers, 

https://www.fcc.gov/blog/another-win-consumers (May 27, 2015, 14:28 EDT); Fed. Commc’n Comm’n, 

Fact Sheet on Consumer Protection Proposal (May 27, 2015), available at 

https://www.fcc.gov/document/fact-sheet-consumer-protection-proposal. 
17

consumers include how to place a phone number on the Do Not Call Registry, what to consider 

before asking a phone carrier to block calls, and how and where to report illegal robocalls.63 The 

FTC’s education materials also explain how robocallers use technology to make thousands of 

calls at minimal cost, send fake caller ID information, and conceal their locations. The FTC 

disseminates these tips through articles,

64 blog posts,65 social media,66 infographics,67 videos,68

audio,

69 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.70

The FTC updates its consumer education whenever it has new information to share. The 

Commission’s library of articles on robocall scams in English and Spanish also includes pieces 

describing credit card interest rate reduction scams, auto service contract and warranty fraud, and 

 63 See, e.g., National Do Not Call Registry, http://www.consumer.ftc.gov/articles/0108-

national-do-not-call-registry (last visited June 2, 2015).

64 See, e.g., FTC Robocall Microsite, http://www.consumer.ftc.gov/features/feature-0025-

robocalls (last visited June 2, 2015).

65 See, e.g., FTC Consumer Information Blog, http://www.consumer.ftc.gov/blog (last 

visited June 2, 2015); Bikram Bandy, Your top 5 Questions about unwanted calls and the National Do 

Not Call Registry (Mar. 9, 2015), http://www.consumer.ftc.gov/blog/your-top-5-questions-aboutunwanted-calls-and-national-do-not-call-registry. 

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

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

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

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

robocalls-infographic.pdf.

68 See, e.g., FTC Video and Media, http://www.consumer.ftc.gov/media (last visited June 2, 

2015).

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

http://www.consumer.ftc.gov/media/audio-0045-hang-robocalls (last visited June 2, 2015).

70 See Pass It On, http://www.consumer.ftc.gov/features/feature-0030-pass-it-on#identitytheft (last visited June 2, 2015).
18

travel-related schemes.71 When Robocall Challenge participants submitted to the Commission 

techniques they were using to successfully reduce illegal robocalls, the GSA and FTC used these

tips in a video with consumer suggestions about stopping unwanted robocalls.

72

IV. Next Steps and Conclusion

The Do Not Call Registry remains enormously successful in protecting consumers 

against unsolicited calls from legitimate telemarketers. But, as technology changes and 

fraudsters exploit those changes, 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 and securing the information 

necessary for prosecutions.

• Spur Innovation

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 

 71 See FTC Consumer Information, “Travel Tips” (May 2013), 

http://www.consumer.ftc.gov/articles/0046-travel-tips; FTC Consumer Information, “Auto Service 

Contracts and Warranties” (Aug. 2012), http://www.consumer.ftc.gov/articles/0054-auto-servicecontracts-and-warranties; FTC Consumer Information, “Credit Card Interest Rate Reduction Scams” 

(Feb. 2011), http://www.consumer.ftc.gov/articles/0131-credit-card-interest-rate-reduction-scams; see 

generally FTC Robocall Microsite, http://www.consumer.ftc.gov/features/feature-0025-robocalls (last 

visited June 2, 2015); FTC Robocall Microsite in Spanish, “Llamadas automáticas pregrabadas o 

robocalls,” http://www.consumidor.ftc.gov/destacado/destacado-s0025-llamadas-automaticas-pregrabadas-o-robocalls (last visited June 2, 2015).

72 Robocall Challenge: Consumer Tips & Tricks (Apr. 2, 2013), 

http://www.consumer.ftc.gov/media/video-0086-robocall-challenge-consumer-tips-tricks. 
19

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.

• Work with Congress 

o We stand ready to assist in your efforts to protect consumers.

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.