Prepared Statement of

The Federal Trade Commission

Before the 

United States Senate

Special Committee on Aging 

on 

Still Ringing off the Hook: An Update on Efforts to Combat Robocalls 

Washington, DC 

October 4, 2017 
1

Chairman Collins, Ranking Member Casey, 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 226 million active telephone numbers,4 has been 

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

 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. Life Management Services of Orange County, LLC, 6:16-CV-982-Orl 

(M.D. Fla. June 8, 2016) (FTC alleged defendants bombarded consumers with illegal prerecorded calls 

fraudulently pitching interest rate reduction and debt elimination schemes, in some instances targeting 

seniors), available at https://www.ftc.gov/enforcement/cases-proceedings/152-3216/life-management;

FTC v. Lifewatch Inc., 1:15-cv-05781 (N.D. Ill. June 20, 2015) (FTC and Florida Attorney General 

alleged defendants used blatantly illegal and fraudulent prerecorded calls to trick older consumers into 

signing up for medical alert systems with monthly monitoring fees), 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) (FTC and Florida Attorney General alleged 

defendants engaged in massive prerecorded call campaigns designed to defraud consumers, often seniors, 

into paying significant up-front fees for worthless credit card interest rate reduction programs), available 

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

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 2016 at 4 (Dec. 2016), available at

https://www.ftc.gov/reports/national-do-not-call-registry-data-book-fiscal-year-2016.
2

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

5 More recently,

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 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 2016 the FTC received more than 3.4 million robocall complaints and in 2017 the 

FTC received more than 3.5 million robocall complaints just between January and August.8 The 

FTC is using every tool at its disposal to fight these illegal calls.

9 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.

 5 For example, in fiscal year 2016, more than 17,000 telemarketers accessed the Do Not 

Call Registry. National Do Not Call Registry Data Book FY 2016 at 8 (Dec. 2016), available at

https://www.ftc.gov/reports/national-do-not-call-registry-data-book-fiscal-year-2016.

6 See Section II(A), infra.

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

8 Total unwanted-call complaints for the first eight months of 2017, including both 

robocall complaints and complaints from consumers whose phone numbers are registered on the Do Not 

Call Registry, exceed 5.5 million. On average, over 400,000 of these complaints each month are about 

robocalls.

9 See FTC Robocall Initiatives, http://www.ftc.gov/robocalls.
3

I. Law Enforcement

Since establishing the Do Not Call Registry in 2003,10 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 

131 enforcement actions seeking civil penalties,

11 restitution for victims of telemarketing scams, 

and disgorgement of ill-gotten gains against 429 corporations and 345 individuals. From the 124

cases that have been resolved thus far, the Commission has collected over $120 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.12 The robocall provisions cover prerecorded calls to all 

 10 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. 

11 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).

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

calls, such as calls placed by charities to its members and prior donors or those calls that are purely 

political, informational, or survey calls. See generally “Complying with the Telemarketing Sales Rule” 

(June 2016), available at https://www.ftc.gov/tips-advice/business-center/guidance/complyingtelemarketing-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).
4

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

robocalls.

13 From the 41 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 enforcement actions in this area.

1. Historic Victory in Dish Network

The FTC and our law enforcement partners recently achieved an historic win in the 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.

14 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.

15 The litigation centered on 

allegations that Dish and its telemarketers made tens of millions of calls—often robocalls16—to 

 13 The FTC filed 12 of the 45 cases before the rule change went into effect on September 1, 

2009. 

14 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-results-historic-decision-awarding280-million-civil.

15 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-network-formerly-knownechostar-multiple-do-not.

16 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. § 310.4(b)(1)(iv). An outbound telephone call is 
5

telephone numbers on the Do Not Call Registry and called consumers who previously asked 

Dish and its telemarketers to stop calling.17 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.

18 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.

19 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. Strategic Targeting of Robocall Violators

In response to growing consumer complaints about illegal robocalls, the FTC engages in 

strategic targeting to maximize impact, prioritizing targets that are causing the most harm to 

consumers. For example, in January 2017, the Commission filed two lawsuits, FTC v. Justin 

Ramsey and FTC v. Aaron Michael Jones, that shut down operations responsible for billions of 

 

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.

17 Id.

18 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-summary-judgment-ftc-caseagainst-dish. 

19 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-results-historic-decision-awarding280-million-civil.
6

illegal robocalls. The Ramsey and Jones defendants bombarded consumers with pitches for 

home security systems and extended auto warranties and compounded their illegal robocalls by 

dialing more that 70 million phone numbers that were registered on the Do Not Call Registry.

20

In June 2016, as part of the FTC’s work targeting telemarketers that use robocalls to 

defraud consumers, the FTC and the Florida Attorney General brought an action to shut down a 

company that allegedly blasted consumers with illegal robocalls touting bogus credit-card 

interest rate reduction and debt relief services.21 The FTC alleged that this scheme bilked 

consumers out of more than $23 million since 2013.22 In some instances, the defendants 

allegedly tailored their debt elimination pitch to consumers over age 60.23 

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

initiated nine 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.24 Many of the defendants in these cases are now banned 

 20 FTC v. Justin Ramsey, 9:17-cv-80032-KAM (S.D. Fl. 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/casesproceedings/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.” 

21 See FTC v. Life Management Services of Orange County, LLC, 6:16-CV-982-Orl (M.D. 

Fla. June 8, 2016), https://www.ftc.gov/enforcement/cases-proceedings/152-3216/life-management. We 

alleged that the defendants used fake company names that deceived consumers into thinking that the 

defendants had a relationship or affiliation with the consumers’ credit-card issuers.

22 See FTC v. Life Management Services of Orange County, LLC, 6:16-CV-982-Orl (M.D. 

Fla. May 1, 2017), D.E. #163. 

23 For example, one consumer stated that the telemarketer claimed to be offering “a 

program to help senior citizens eliminate their debt.” FTC v. Life Management Services of Orange 

County, LLC, 6:16-CV-982-Orl, Plaintiff’s Exhibit 7 (M.D. Fla. June 8, 2016).

24 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 
7

from robocalling or telemarketing.25 

3. 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

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 

 

Jones, 8:17-cv-00058 (M.D. Fla. Jan. 13, 2017), available at https://www.ftc.gov/enforcement/casesproceedings/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/consumereducationinfo-inc; FTC 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/usa-vacation-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/casesproceedings/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-usmarketing-llc-formerly-known-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.

25 See, e.g., 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/casesproceedings/142-3256/all-us-marketing-llc-formerly-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-cv-80032-KAM (S.D. Fla. Apr. 11, 2017), available at 

https://www.ftc.gov/enforcement/cases-proceedings/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/caribbean-cruise-line-inc (final 

stipulated order banning the Pacific Telecom defendants from robocalling and illegal telemarketing, as 

well as helping anyone else make such calls).
8

enforcement. In addition, defendants in four of our recent 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.26 

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.27 In another recent case, the 

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.28 

 26 See 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/casesproceedings/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-usmarketing-llc-formerly-known-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). In addition, the 

complaint in FTC v. Jones, alleged that the defendants assisted and facilitated others engaged in illegal 

spoofing. 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.

27 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/phlg-enterprises-llc.

28 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. 
9

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. 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. 

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

Seven of the nine most recent robocall enforcement actions the FTC has led involved 

collaboration with the Department of Justice or our state partners.29 The FTC also leads 

robocall law enforcement “sweeps”—coordinated, simultaneous law enforcement actions—in 

conjunction with state and federal partners.

30 Most recently, the FTC led a multinational 

robocall sweep announced in June 2016 that took action against operations estimated to be 

 

29 See supra n. 24. 

30 See, e.g., 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.
10

responsible for billions of illegal robocalls.31 The June 2016 sweep included thirty-nine actions 

taken by the FTC, the Canadian Radio-television 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. 

II. Policy and Market Stimulation Initiatives

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.32 That 

number has now more than quadrupled—so far in 2017 the FTC has received an average of 

400,000 robocall complaints per month.33

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, 

 31 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/ftcflorida-attorney-general-take-action-against-illegal-robocall and 

https://www.ftc.gov/system/files/attachments/press-releases/ftc-florida-attorney-general-take-actionagainst-illegal-robocall-operation/160614robocallenforcementactions.pdf (listing actions comprising the 

coordinated enforcement crackdown).

32 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.

33 See supra n. 8.
11

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

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

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

34 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. New Technologies Have Made Robocalls Extremely Inexpensive

Until relatively recently, telemarketing required significant capital investment in 

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

inexpensive international and 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: law-breaking telemarketers can place robocalls for a fraction of one cent 

 34 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.

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

36 Schulzrinne, Tr. at 24.

37 Herrmann, Tr. at 59-61.
12

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

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 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.40 Such a path makes it cumbersome to trace back to a 

call’s inception.41 All too often, this process to trace the call fails completely because one of the 

carriers in the chain has not retained the records necessary for a law enforcement investigation.42

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

that appears with an incoming phone call.43 While “Caller ID spoofing” has some beneficial 

uses,

44 it also allows telemarketers to deceive consumers by pretending to be an entity with a 

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

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

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

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

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

43 Schulzrinne, Tr. at 24-26.

44 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).
13

local phone number or a trusted institution such as a bank or government agency.45 In addition, 

telemarketers can change their phone numbers frequently in an attempt to avoid detection.46

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

are most likely to face prosecution.47 Indeed, the entities involved in the path of a robocall can 

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

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 led four public challenges to help 

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

Robocall Challenge48, 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. 

 45 Schulzrinne, Tr. at 21-22.

46 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.).

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

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

https://www.ftc.gov/news-events/press-releases/2013/04/ftc-announces-robocall-challenge-winners.
14

To date, “NomoRobo,” which reports blocking over 279 million calls, is being offered directly to 

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

iPhones.49 

The following year the FTC launched its second challenge—Zapping Rachel50—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, DectectaRobo51, 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 

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

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

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

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

 49 See https://www.nomorobo.com/ (last visited Sept. 22, 2017) 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. 

50 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. 

51 For more information on the Detectarobo challenge see https://www.ftc.gov/newsevents/contests/detectarobo.

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

https://www.ftc.gov/news-events/contests/robocalls-humanity-strikes-back. 
15

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.53 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.54

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.

55 

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. 

 53 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.tmobile.com/callprotection (last visited Sept. 22, 2017). 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/. 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-unwanted-calls-texts-and-faxes (listing available call 

blocking resources from a number of wireline providers) (last visited Sept. 22, 2017).

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

of the available call blocking apps, both for iOS devices: https://www.ctia.org/consumertips/robocalls/ios-robocall-blocking and for Android devices: https://www.ctia.org/consumertips/robocalls/android-robocall-blocking (last visited Sept. 22, 2017). 

 55 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/Robocall-Strike-Force-FinalReport.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/advocacy-filings/2015/01/ftc-staff-comment-federalcommunications-commission.
16

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

2016.56 

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 

are permitted to use to provide consumers additional relief.”57 In response, this spring the FCC 

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

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

what types of standards should govern providers engaged in call blocking.58 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.59

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

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

57 See id. at 40. 

58 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). 

59 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 
17

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.60 After discussions 

with the FTC and others, M3

AAWG leadership formed the Voice and Telephony Abuse Special 

Interest Group (“VTA SIG”) in 2014, a subgroup formed to apply M3AAWG’s expertise on 

messaging abuse to voice spam, such as robocalls.61 

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.

62 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.63

 

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.

 60 See M3

AAWG, Activities, https://www.m3aawg.org/ (last visited Sept. 22, 2017).

61 See M3

AAWG, Voice and Telephony Abuse Special Interest Group, 

https://www.m3aawg.org/voice-and-telephony-abuse-sig (last visited Sept. 22, 2017).

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

https://datatracker.ietf.org/wg/stir/charter/ (last visited Sept. 22, 2017).

63 See https://www.ucenet.org/ (last visited Sept. 22, 2017).
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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. The top six categories selected to date by consumers are the same for Do Not 

Call complaints and robocall complaints:

Reducing your debt (credit cards, mortgage, student loans)

Dropped call or no message

Vacation & timeshares

Warranties & protection plans

Calls pretending to be government, businesses, or family and friends

Medical & prescriptions

In addition to refining our complaint intake process, the FTC recently began a new 

initiative to help facilitate industry call-blocking solutions by increasing the amount and 

frequency of consumer complaint data that we make publicly available.

64 Beginning in August 

of this year, when consumers report Do Not Call or robocall 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 

 64 See https://www.ftc.gov/news-events/press-releases/2017/08/ftc-escalates-fight-againstillegal-robocalls-using-consumer. The complaint data is available at: https://www.ftc.gov/siteinformation/open-government/data-sets/do-not-call-data.
19

whether the call was a robocall.65 By making our available data more up-to-date and more 

robust, the FTC seeks to help telecommunications carriers and other industry partners that are 

implementing 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,66

available call blocking solutions,67 and how to identify common scams.68 The FTC 

 65 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.

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

national-do-not-call-registry. 

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

https://www.consumer.ftc.gov/articles/0548-blocking-unwanted-calls. 
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disseminates these tips through articles,69 blog posts,70 social media,71 infographics,72 videos,

73

audio,

74 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.75

IV. Next Steps and Conclusion

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

from legitimate telemarketers. But, 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.

 68 See, e.g., FTC Consumer Information Scam Alerts, https://www.consumer.ftc.gov/scamalerts. 

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

robocalls.

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

https://www.consumer.ftc.gov/blog/looking-block-unwanted-calls. 

71 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. 

72 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.

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

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

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

75 See Pass It On, http://www.consumer.ftc.gov/features/feature-0030-pass-it-on#identitytheft.
21

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

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.