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JS 44 (Rev. 04/21) Case 6:22-cv-00798 Document 1-1 Filed 04/26/22 Page 1 of 2 PageID 28 CIVIL COVER SHEET

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as 

provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the 

purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) 

I. (a) PLAINTIFFS DEFENDANTS 

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant 

(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY) 

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF

THE TRACT OF LAND INVOLVED. 

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known) 

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff 

(For Diversity Cases Only) and One Box for Defendant)

1 U.S. Government 3 Federal Question PTF DEF PTF DEF 

Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4 

of Business In This State 

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5 

Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State 

Citizen or Subject of a 3 3 Foreign Nation 6 6 

Foreign Country 

IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions. 

CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES 

110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act 

120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC 

130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a)) 

140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment 

150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust 

& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking 

151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce 

152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation 

Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and 

(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations 

153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit 

of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692) 

160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer 

190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act 

195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV 

196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/ 

362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange 

Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions 

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts 

210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters 

220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information 

230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act 

240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration 

245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure 

290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION Act/Review or Appeal of 

Employment Other: 462 Naturalization Application Agency Decision 

446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of 

Other 550 Civil Rights Actions State Statutes 

448 Education 555 Prison Condition 

560 Civil Detainee -

Conditions of 

Confinement 

V. ORIGIN (Place an “X” in One Box Only) 

1 Original 

Proceeding 

2 Removed from 

State Court 

3 Remanded from 

Appellate Court 

4 Reinstated or 

Reopened 

5 Transferred from 

Another District 

(specify) 

6 Multidistrict 

Litigation -

Transfer 

8 Multidistrict 

Litigation -

Direct File 

VI. CAUSE OF ACTION 

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity): 

Brief description of cause: 

VII. REQUESTED IN 

COMPLAINT: 

CHECK IF THIS IS A CLASS ACTION 

UNDER RULE 23, F.R.Cv.P. 

DEMAND $ CHECK YES only if demanded in complaint: 

JURY DEMAND: Yes No 

VIII. RELATED CASE(S) 

IF ANY (See instructions): 

JUDGE DOCKET NUMBER 

DATE SIGNATURE OF ATTORNEY OF RECORD 

26 USC 7609 

INTELLECTUAL 

Seminole United States

Ellen Bowden McIntyre, US Department of Justice, PO 

Box 386, Washington, DC 20044, 202-451-7731

VOIP Terminator, Inc., BLMarketing, Inc., and Muhammad 

Usman Khan

none, pro se representation by Muhammad Usman Khan

✖

✖

15 USC §§ 45(a) & (m), 53(b) & 56(a) Defendants violated the Telemarketing Act and the Telemarketing Sales Rule by providing improper voice over internet protocol services. ✖

✖

April 26, 2022 s/ Ellen Bowden McIntyre

FOR OFFICE USE ONLY 

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE 
JS 44 Reverse (Rev. 04/21) Case 6:22-cv-00798 Document 1-1 Filed 04/26/22 Page 2 of 2 PageID 29 

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44 

Authority For Civil Cover Sheet 

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as 

required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is 

required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of 

Court for each civil complaint filed. The attorney filing a case should complete the form as follows: 

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use 

only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then 

the official, giving both name and title.

 (b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the 

time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land 

condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.) 

(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting 

in this section "(see attachment)". 

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X" 

in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below. 

United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here. 

United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box. 

Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment 

to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes 

precedence, and box 1 or 2 should be marked. 

Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the 

citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity 

cases.) 

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this 

section for each principal party. 

IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code 

that is most applicable. Click here for: Nature of Suit Code Descriptions. 

V. Origin. Place an "X" in one of the seven boxes. 

Original Proceedings. (1) Cases which originate in the United States district courts. 

Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441. 

Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing 

date. 

Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date. 

Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or 

multidistrict litigation transfers.

Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. 

Section 1407. 

Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket. 

PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to 

changes in statute. 

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional 

statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service. 

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P. 

Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction. 

Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded. 

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket 

numbers and the corresponding judge names for such cases. 

Date and Attorney Signature. Date and sign the civil cover sheet. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 1 of 27 PageID 1 

UNITED STATES DISTRICT COURT 

IN THE MIDDLE DISTRICT OF FLORIDA 

ORLANDO DIVISION 

UNITED STATES OF AMERICA, Case No. ____________ 

Plaintiff, 

COMPLAINT FOR PERMANENT 

v. INJUNCTION, CIVIL PENALTIES, 

AND OTHER RELIEF 

VOIP TERMINATOR, INC., a corporation, 

BLMARKETING, INC., a corporation, and 

MUHAMMAD USMAN KHAN, individually and 

as an officer of VOIP TERMINATOR, INC. and 

BLMARKETING, INC., 

Defendants. 

Plaintiff, the United States of America, acting upon notification and authorization to the 

Attorney General by the Federal Trade Commission (“FTC”), pursuant to Section 16(a)(1) of the 

Federal Trade Commission Act (“FTC Act”), 15 U.S.C. § 56(a)(1), for its Complaint alleges: 

1. Plaintiff brings this action under Sections 5(a), 5(m)(1)(A), 13(b) and 16(a) of the 

FTC Act, 15 U.S.C. §§ 45(a), 45(m)(1)(A), 53(b) and 56(a), and Section 6 of the Telemarketing 

and Consumer Fraud and Abuse Prevention Act (“Telemarketing Act”), 15 U.S.C. § 6105, which 

authorize the FTC to seek, and the Court to order, permanent injunctive relief, monetary relief, 

and other equitable relief from Defendants for their violations of Section 5(a) of the FTC Act, 15 

U.S.C. § 45(a), and the FTC’s Telemarketing Sales Rule (“TSR” or “Rule”), as amended, 16 

C.F.R. Part 310. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 2 of 27 PageID 2 

SUMMARY OF CASE 

2. At all times material to this Complaint, Defendants provided Voice over Internet 

Protocol (“VoIP”) services, which enable transmission of telephone calls over the internet. 

3. Defendants assisted and facilitated violations of the TSR by continuing to 

provide VoIP services to their customers even after knowing or consciously avoiding knowing 

their customers were using Defendants’ services to initiate calls that: (a) were placed to 

numbers on the National Do Not Call Registry; (b) delivered prerecorded messages; and (c) 

displayed spoofed caller ID numbers, including providing services to callers perpetrating scams 

related to credit card interest rate reduction, tech support, and the COVID-19 pandemic. 

JURISDICTION AND VENUE 

4. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a), 

and 1345. 

5. Venue is proper in this District under 28 U.S.C. § 1391 (b)(2), (c)(2), (c)(3), and 

(d), and 15 U.S.C. § 53(b). 

DEFENDANTS 

6. Defendant VoIP Terminator, Inc. (“VoIP Terminator”) is a former Florida 

corporation with its principal place of business at 250 International Parkway, Suite 108, Lake 

Mary, FL 32746. It was dissolved on May 25, 2021. VoIP Terminator transacted business in this 

District and throughout the United States. 

7. VoIP Terminator was an interconnected VoIP service provider. As an 

interconnected VoIP service provider, VoIP Terminator provided information services pursuant 

to 47 U.S.C. § 153 of the Communications Act of 1934, as amended. 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 3 of 27 PageID 3 

8. Defendant BLMarketing, Inc. (“BLMarketing”) is a former Virginia corporation 

with its principal place of business at 6564 Loisdale Road, Suite 600-D, Springfield, VA 22150. 

It was administratively terminated on January 31, 2020. BLMarketing transacted business in this 

District and throughout the United States. 

9. Defendant Muhammad Usman Khan (“Khan”) is the founder, sole owner, and 

president of VoIP Terminator and the founder, sole owner, and director of BLMarketing. At all 

times relevant to this Complaint, acting alone or in concert with others, he has formulated, 

directed, controlled, had the authority to control, or participated in the acts and practices of VoIP 

Terminator and BLMarketing, including the acts and practices set forth in this Complaint. 

Defendant Khan resides in Islamabad, Pakistan, and in connection with the matters alleged 

herein, transacts or has transacted business in this District and throughout the United States. 

COMMON ENTERPRISE 

10. Defendants BLMarketing and VoIP Terminator (collectively, “Corporate 

Defendants”) have operated as a common enterprise while engaging in the unlawful acts and 

practices and other violations of law alleged below. Corporate Defendants have conducted the 

business practices described below through interrelated companies that have common ownership, 

officers, managers, business functions, employees, and addresses. Because these Corporate 

Defendants have operated as a common enterprise, each of them is liable for the acts and 

practices alleged below. 

COMMERCE 

11. At all times relevant to this Complaint, Defendants have maintained a substantial 

course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act, 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 4 of 27 PageID 4 

15 U.S.C. § 44. 

THE TELEMARKETING SALES RULE 

AND THE NATIONAL DO NOT CALL REGISTRY 

12. In 1994, Congress directed the FTC to prescribe rules prohibiting abusive and 

deceptive telemarketing acts or practices pursuant to the Telemarketing Act, 15 U.S.C. §§ 

61016108. The FTC adopted the original TSR in 1995, extensively amended it in 2003, and 

amended certain provisions thereafter. 16 C.F.R. Part 310. 

13. Among other things, the 2003 amendments to the TSR established a do not call 

registry, maintained by the FTC (the “National DNC Registry” or “Registry”), of consumers who 

do not wish to receive certain types of telemarketing calls. Consumers can register their 

telephone numbers on the Registry without charge either through a toll-free telephone call or 

online at donotcall.gov. 

14. Consumers who receive telemarketing calls to their registered numbers can 

complain of Registry violations the same way they registered, through a toll-free telephone call 

or online at donotcall.gov, or by otherwise contacting law enforcement authorities. 

15. The TSR defines “telemarketing” as a plan, program or campaign which is 

conducted to induce the purchase of goods or services or a charitable contribution, by use of one 

or more telephones and which involves more than one interstate telephone call. 16 C.F.R. § 

310.2(gg). 

16. Under the TSR, a “telemarketer” is any person who, in connection with 

telemarketing, initiates or receives telephone calls to or from a customer or donor. 16 C.F.R. § 

310.2(ff). 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 5 of 27 PageID 5 

17. A “seller” means any person who, in connection with a telemarketing transaction 

provides, offers to provide, or arranges for others to provide goods or services to the customer in 

exchange for consideration. 16 C.F.R. § 301.2(dd). 

18. The FTC allows sellers, telemarketers, and other permitted organizations to access 

the Registry online at telemarketing.donotcall.gov, to pay any required fee(s), and to download 

the numbers not to call. 

19. Under the TSR, an “outbound telephone call” means a telephone call initiated by 

a telemarketer to induce the purchase of goods or services or to solicit a charitable contribution. 

16 C.F.R. § 310.2(x). 

20. The TSR prohibits sellers and telemarketers from initiating an outbound telephone 

call to numbers on the Registry. 16 C.F.R. § 310.4(b)(1)(iii)(B). 

21. As amended, effective September 1, 2009, the TSR prohibits initiating an 

outbound telephone call that delivers a prerecorded message to induce the purchase of any good 

or service. 16 C.F.R. § 310.4(b)(1)(v). Calls delivering prerecorded messages are commonly 

called “robocalls.” 

22. The TSR requires that sellers and telemarketers transmit or cause to be 

transmitted the telephone number of the telemarketer and, when made available by the 

telemarketer’s carrier, the name of the telemarketer (“caller ID information”), 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 carrier, the name of the seller. 16 C.F.R. § 310.4(a)(8). Transmitting inaccurate 

caller ID information, or causing inaccurate caller ID information to be transmitted, violates the 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 6 of 27 PageID 6 

TSR and is commonly called “spoofing.” 

23. It is a violation of the TSR for any person to provide substantial assistance or 

support to any seller or telemarketer when that person knows or consciously avoids knowing that 

the seller or telemarketer is engaged in any practice that violates Sections 310.3(a), (c) or (d) or 

310.4 of the TSR. 16 C.F.R. § 310.3(b). 

24. Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), and 

Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation of the TSR constitutes an 

unfair or deceptive act or practice in or affecting commerce, in violation of Section 5(a) of the 

FTC Act, 15 U.S.C. § 45(a). 

25. Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), and Section 18(d)(3) 

of the FTC Act, 15 U.S.C. § 57a(d)(3) authorize this Court to award monetary civil penalties of 

not more than $43,792 for each violation of the Telemarketing Sales Rule assessed after January 

13, 2021, including penalties whose associated violation predated January 13, 2021. 

26. Defendants’ violations of the TSR set forth below were committed with the 

knowledge required by Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A). 

DEFENDANTS’ BUSINESS ACTIVITIES 

27. Voice over Internet Protocol is technology that allows a person to make voice 

calls using a broadband internet connection instead of a regular (analog) phone line. In other 

words, VoIP calls are phone calls that are sent and received over the internet. Telemarketers who 

blast illegal prerecorded calls and other marketing calls to millions of American consumers 

typically use VoIP service providers to transmit those calls. Multiple VoIP providers typically 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 7 of 27 PageID 7 

participate in transmitting a given call from its originator (often a telemarketer) to a termination 

point (most often a consumer’s telephone). 

28. Defendants were nationwide providers of VoIP services, including “origination” 

and “termination” services. Origination is beginning the transmission of a call from the 

telemarketer or company who initiated it; termination is sending the call to its ultimate 

destination. Defendants also served as a mid-stream providers, transmitting calls from and to 

other VoIP providers. 

29. In addition to transmitting calls, VoIP Terminator provided Interexchange carrier 

services, which give companies the ability to purchase VoIP lines ultimately destined for phone 

numbers in the United States, and the ability to sell those VoIP lines to their customers, such as 

telemarketing call centers. 

30. Defendants conducted most of their business from Pakistan. Their business in 

Pakistan began over a decade ago. A 2020 copy of the Defendants’ website 

(www.voipterminator.com.pk) declared that VoIP Terminator has provided “call center 

solutions” since 2007. The website also claimed that VoIP Terminator had “offices in all major 

cities of Pakistan,” and that VoIP Terminator was a “leading global provider of wholesale VoIP 

services to businesses big and small seeking to gain a premium international reach at an 

incredibly low cost.” Moreover, the website said, “VoIP Terminator has been producing 

residential solar sales leads since 2012,” and that VoIP Terminator “generate[d] leads in all 50 

states, Canada and Australia.” 

31. Defendants’ business activities in the United States began when Defendant Khan 

created BLMarketing in 2015. BLMarketing originally sold internet marketing services, such as 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 8 of 27 PageID 8 

search engine optimization, to its customers; it later transitioned to providing VoIP services. 

When he created BLMarketing, Khan, a citizen and resident of Pakistan, provided a U.S. mail 

drop address for himself and the corporation: 5900 Barclay Dr., Box 150261, Alexandria, 

Virginia 22315. Khan also purchased a virtual address: 6564 Loisdale Court, Suite 600-D, 

Springfield, VA 22150. Khan used these addresses to open depository accounts for 

BLMarketing. 

32. Khan was BLMarketing’s sole employee. At all times relevant to this Complaint, 

Khan conducted BLMarketing’s business operations online from Pakistan. Khan’s sister (who 

was also BLMarketing’s Registered Agent) and nephew occasionally picked up mail for 

BLMarketing in Virginia, and Khan’s sister would send it to Khan in Pakistan. 

33. In about 2018, Khan began to transition BLMarketing’s business: he started 

offering VoIP services to call center customers. At about the same time, Khan created VoIP 

Terminator in Florida. Khan designated himself as President, his wife as Vice President, and 

Tahir Malik (“Malik”) as Registered Agent of VoIP Terminator. Malik was an acquaintance of 

Khan’s who helped Khan incorporate and run VoIP Terminator in Florida. 

34. Khan intended VoIP Terminator to enter into contracts to buy VoIP lines from 

larger carriers, and then sell access to those VoIP lines to offshore call center customers. VoIP 

Terminator’s call center customers would then use those VoIP lines as a U.S. point of entry for 

the call centers’ telemarketing calls. 

35. Khan traveled to Florida in April 2018 to set up an office and bank accounts for 

VoIP Terminator. 

36. Malik located and leased office space at 250 International Parkway, Suite 108, 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 9 of 27 PageID 9 

Lake Mary, Florida. Both Malik’s and Khan’s names were on the lease. 

37. During Khan’s April 2018 visit, Khan and Malik went together to TD Bank and 

co-signed account-opening documents for VoIP Terminator. 

38. As early as 2016, Khan, on behalf of BLMarketing, began purchasing VoIP lines 

from larger carriers in the United States. For example, on October 31, 2016, BLMarketing 

entered into contracts with Alcazar Networks, Inc.1 (“Alcazar”), for direct voice termination and 

interexchange carrier services. Direct voice termination services allow telemarketers to use VoIP 

to call phone numbers in the United States. Interexchange carrier services allow smaller carriers 

to purchase VoIP lines from larger carriers and then either sell those lines to other carriers or 

telemarketing call centers. 

39. VoIP Terminator offered numerous services in the telemarketing ecosystem, 

including predictive dialers, Private Branch Exchange hosting (“PBX”), DID/Virtual numbers, 

ringless voicemail, and call center leads. 

40. Predictive dialer services included hosted, free open source software and 

wholesale termination that VoIP Terminator offered to install and host for call center customers. 

Wholesale termination services give call center customers access to VoIP lines to call phone 

numbers in the United States. 

1 Alcazar Networks Inc. is a VoIP service provider and former FTC defendant. On December 3, 2020, Alcazar settled 

FTC charges that it had facilitated tens of millions of illegal telemarketing phone calls, including some calls from 

overseas and some that displayed spoofed caller ID numbers. See FTC v. Alcazar Networks, Inc., et al., No. 6:20-

cv2200 (M.D. Fla. Dec. 3, 2020); see also Press Release, Federal Trade Commission, FTC Takes Action Against 

Second VoIP Service Provider for Facilitating Illegal Telemarketing Robocalls (Dec. 3, 2020), 

https://www.ftc.gov/news-events/press-releases/2020/12/ftc-takes-action-against-second-voip-service-provider. 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 10 of 27 PageID 10 

41. PBX provides companies with local networks for their internal communications. 

42. DID/Virtual numbers are the numbers that appear on consumers’ phones when a 

call is received. Call centers purchase these numbers and route them through their dialers to 

phone numbers in the United States, including to cell phone numbers and Skype internet-based 

phone numbers. 

43. Ringless voicemail services are systems VoIP Terminator’s customers could 

purchase that would allow them to record voicemails and transmit these phone calls directly to 

voicemail inboxes in the United States without causing the consumers’ phones to ring. 

44. Call center lead services are VoIP Terminator’s ability to generate leads— 

consumers’ phone numbers—for its call center customers. 

45. Providing VoIP services to a telemarketer constitutes the provision of substantial 

support and assistance to a telemarketer under the TSR. Providing VoIP Terminator’s related 

services (predictive dialing, PBX hosting, ringless voicemail, DID services, etc.) also constitutes 

the provision of substantial support and assistance to a telemarketer under the TSR. 

46. The majority, if not all, of the services VoIP Terminator provided to call centers 

and other customers were run out of VoIP Terminator in Pakistan. 

47. The website www.voipterminator.com.pk identified the company as “VoIP 

Terminator Pakistan.” Defendant Khan also referred to the company as “VoIP Terminator 

Pakistan.” VoIP Terminator Pakistan is an association of persons organized under the laws of 

Pakistan, also doing business as Sip Tech and VT Group. Khan testified that VoIP Terminator 

Pakistan was still operating in Pakistan, as of July 2021, and said it was no longer providing 

VoIP services. 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 11 of 27 PageID 11 

48. According to Defendant Khan, VoIP Terminator used to have approximately 

thirty employees in Pakistan. Approximately 75 percent of VoIP Terminator’s employees in 

Pakistan were technical engineers. The remaining 25 percent were in administrative or sales 

roles. 

49. In Pakistan, Khan ran most of VoIP Terminator’s day-to-day operations. Khan 

also accompanied his salespeople when they met with prospective clients. 

50. VoIP Terminator’s offices in Florida and Pakistan supported each other’s business 

operations. For example, customers would come to VoIP Terminator in Pakistan to have dialers 

installed for them on hosted servers. VoIP Terminator in Florida would then provide the 

customers with VoIP lines, which served as a point of entry to United States phones. 

51. According to Khan’s sworn testimony, the customers to whom VoIP Terminator 

provided dialers were call centers located in the Philippines, Pakistan, and Bangladesh. VoIP 

Terminator’s call center customers were telemarketers who used the dialers provided by VoIP 

Terminator to call phone numbers in the United States. 

52. VoIP Terminator and “VoIP Terminator Pakistan” used interchangeable 

addresses. For example, the website www.voipterminator.com.pk, until at least October 2020, 

listed its “headquaters” [sic] on its home page as its Florida address and its “offshore office” as 

its Pakistani address. Also, the headquarters address VoIP Terminator listed on its “Contact” 

page was 6564 Loisdale Court, Suite 600-D, Springfield, Virginia (BLMarketing’s mail drop). 

Here are screenshots of the bottom of VoIP Terminator’s home page and contact page: 

11 
 

 

 

 

 

 

 

 

 

0 @ @ ® @ 

Phone Headquaters Offshore Office Business Hours Email 

Office: +92 315 9652886 6564 Lolsdale Court Al-Habib Plaza. 2nd Floor. Monday-Friday: 7am - 7pm Sales@VolpTermlnator.com 

Offshore Office (Islamabad): Suite 600-0 Adjacent to Chinar Hospital Saturday: 1 0am - 5pm Suppon@Vo1pTermmator.com 

+92 51 8356219 Springfield, VA 22150 Mam PWD Road, Islamabad Sunday: 12pm - 4pm HR@VoipTerminator.com 

United States 

Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 12 of 27 PageID 12 

53. Khan testified that by 2018 he had stopped doing business under the name 

BLMarketing and transitioned his business to VoIP Terminator. However, in March 2019, Khan 

entered into a contract to provide VoIP services to a Pakistani call center called TransData 

International (“TransData”). The Master Services Agreement was between “BLMarketing, Inc. a 

Virginia, USA corporation (VoIP Terminator)” and TransData. BLMarketing’s address in 

Springfield, Virginia appears on the contract. 

54. Khan did not affirmatively close BLMarketing; the State of Virginia 

administratively terminated the company on January 31, 2020. 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 13 of 27 PageID 13 

Defendants Knew, or Consciously Avoided Knowing, That They Were Assisting and 

Facilitating Illegal Recorded Telemarketing Calls 

55. On March 15, 2018, the Federal Communications Commission issued a subpoena 

to Khan and “BL Marketing Inc. dba VOIPterminator,” requesting identifying information for a 

customer that routed or placed a particular “unlawful robocall” on Defendants’ network to 

consumers in the United States. The FCC has defined “robocalls” as “calls made with an 

autodialer or that contain a message made with a prerecorded or artificial voice.” See 

https://www.fcc.gov/consumers/guides/stop-unwanted-robocalls-and-texts. 

56. Khan responded to the FCC via email on March 19, 2018. He signed a certificate 

of compliance as president of the company, providing the address 6564 Loisdale Court, Suite 

600-D, Springfield, Virginia (BLMarketing’s address), and the email address 

mkhan@voipterminator.com. 

57. In his response to the FCC, Khan identified the customer that routed or placed the 

unlawful robocall in question as Steps Ahead Global Contact Solutions (“SAGCS”) and attached 

a Master Services Agreement between SAGCS and “VOIPterminator – product of BL Marketing 

INC.” SAGCS was a call center customer of the Defendants located at 233 Campo Sioco, Baguio 

City, Philippines. It was operated by Philippines-based telemarketer James Joseph Servas 

(“Servas”). At all times relevant to this Complaint, Servas was Khan’s contact for SAGCS. 

58. The Master Services Agreement between BLMarketing, Inc. and SAGCS was 

created by Khan on September 9, 2016. Khan emailed the Master Services Agreement to 

Servas’s email, tole.cosmetics@gmail.com, for Servas’s signature. On September 13, 2016, 

Servas and Khan electronically signed the Master Services Agreement. 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 14 of 27 PageID 14 

59. Under the Master Services Agreement between Defendants and Servas, 

Defendants would supply termination, origination, and trunking telecommunications services 

and SMS services to SAGCS. Paragraph nine stated in part: 

Customer represents that they are aware of the Do Not Call (“DNC”) laws and 

agrees that any Services purchased from VoIP Terminator will be in compliance 

with those laws. Customer is aware that VoIP Terminator offers TeleBlock 

service which checks all calls with the appropriate DNC lists, and that 

TeleBlock service has a specific charge and involves a separate TeleBlock 

contract. Some information regarding DNC in the U.S. is at 

www.ftc.gov/opa/2008/040dncfyi.shtm; in the UK is at www.tpsonline.org, and 

in Canada is at http://en.wikipedia.org/wiki/Canadian_Do_Not_Call_List. This 

information is not all-inclusive, and it is the responsibility of the Customer to 

comply with all applicable laws. 

60. Servas’s companies never used the TeleBlock services offered by Defendants. 

After learning that Servas’s company was sending unlawful telemarketing calls into the United 

States, Khan chose not to stop transmitting Servas’s calls. Rather, Khan continued to do business 

with Servas until April 2020. 

61. During the investigational hearing conducted by the FTC, Khan testified that 

probably only one percent of call center customers used TeleBlock services to check all of their 

calls against the DNC Registry. Khan testified that Defendants’ call center customers would 

represent that they were scrubbing their calls, but Khan never asked any of Defendants’ call 

center customers for evidence that they were excluding calls to phone numbers on any DNC lists. 

Khan also testified that Defendants had no policies for monitoring, reviewing, or analyzing 

consumer complaints reported to or published by any state or federal government agency. When 

Defendants received complaints, Khan was solely responsible for investigating the complaint, 

providing requested information, and taking responsive actions against Defendants’ call center 

customers, if any. 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 15 of 27 PageID 15 

62. By no later than April 2018, Khan knew, or consciously avoided knowing, that 

Servas was using Defendants’ services for calls that violated the TSR. According to Khan, he 

warned Servas that he would cancel Servas’s contract if there were more complaints. 

63. In August 2019, Khan received a CID from the Missouri Attorney General’s 

Office about potential violations of Missouri law concerning illegal telemarketing, including 

calls to numbers on Missouri’s Do Not Call list. In an email to the attorney general’s office dated 

September 5, 2019, Khan apologized for an error in his subpoena response. He said: “I am so so 

sorry. Too many requests everyday [sic] regarding DNCs.” 

64. The FCC issued a second subpoena to Khan, as president of VoIP Terminator, on 

November 20, 2019. That subpoena placed Khan on notice that the FCC was still investigating 

the illegal conduct (“apparent unlawful robocalls”) of at least two of Khan’s customers, Pakistani 

call centers TransData and Global BPO Limited. 

65. The FCC issued a third subpoena to Khan as president of VoIP Terminator on 

January 15, 2020. That subpoena also concerned continuing unlawful calls made by TransData. 

66. USTelecom is a trade association that represents “technology providers, 

innovators, suppliers and manufacturers” in the broadband industry. 

https://www.ustelecom.org/ustelecom-community/our-members/. Among other things, 

USTelecom collects data about illegal calls, and conducts “tracebacks” to determine the path a 

call has taken, from its origin to its destination. When conducting a traceback inquiry, 

USTelecom notifies its participating members about a complaint, and requests information about 

the source of individual calls. It is then able to identify the route that a specific call travels, from 

its point of origin to its destination. 

15 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 16 of 27 PageID 16 

67. On March 13, 2020, USTelecom notified Defendants via email that spoofed calls 

playing recorded messages were being transmitted through Defendants’ network offering “air 

duct cleaning to filter out corona virus.” Air duct cleaning does not filter out coronavirus. 

USTelecom flagged the calls (which were made on March 12) as illegal spoofed robocalls to 

numbers on the DNC list. 

68. The first paragraph of every USTelecom traceback inquiry states: “We are writing 

to request your assistance on industry efforts focused on our shared interest of protecting 

consumers from fraudulent, abusive or potentially unlawful robocalls.” The second paragraph 

says: 

A member of USTelecom’s Industry Traceback Group recently received traffic 

from your network that has been deemed suspicious, and we are seeking your 

assistance in order to identify its origin (call details with date(s) are listed below). 

We request that you assist industry stakeholders who are engaging in traceback 

efforts in order to help identify the source of this potentially fraudulent, abusive or 

unlawful network traffic. To assist us in our efforts, we are asking that you 

respond to this traceback inquiry as soon as possible, but no later than three 

business days from now. 

69. USTelecom identified “VoIP Terminator/BLMarketing” as the “point of entry” 

VoIP provider (i.e., the provider responsible for bringing a call into the United States) for several 

allegedly unlawful spoofed prerecorded calls that offered air duct cleaning to filter coronavirus 

particles (a fictitious service). The March 13, 2020 email included a traceback inquiry 

concerning four of the seven allegedly unlawful prerecorded calls. Here is a part of the traceback 

inquiry that identifies the calls and the customer’s calling campaign: 

16 
 

 

 

 

 

 

 

 

 

 

 

 

Call Details for Incident #1813 (2h35m ago) 

Date/Time: 

To: 

From: 

Campaign: 

2020-03-12 21:39:00 UTC 

+13035034926 

+17048991150 

HVAC-Corona 

Offer of air duct cleaning to filter out corona virus. Recorded message played to wireless 

subscribers. Calls to numbers on DNC list. Caller is not named in recorded message, nor is tollfree number provided for callback. Caller-ID is spoofed and apparently random on each call. 

Blocking the ANI is not effective mitigation. 

Call Details for Incident #1814 (2h35m ago) 

Date/Time: 

To: 

From: 

Campaign: 

2020-03-12 21:40:00 UTC 

+130350391 10 

+12512438528 

HVAC-Corona 

(see description above) 

Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 17 of 27 PageID 17 

70. One of the HVAC-Corona call campaigns played the following message: 

Recommend sanitizing your ducts and air filters to protect your loved ones from 

the Corona virus. For only $159 our highly trained technicians will do a full air 

duct cleaning and sanitation to make sure the air you breathe is free of bacteria. 

So don't hesitate. Press zero and have your duct system cleaned and sanitized 

now. Press nine to be removed from this list. 

That recording is available at: https://directory.youmail.com/directory/phone/6185649533. 

71. Defendant Khan was responsible for investigating and responding to traceback 

inquiries from USTelecom. Khan responded to the inquiries through an online portal provided by 

USTelecom. Recipients of traceback inquiries can input the call source details for the unlawful 

calls in question. 

72. Through the USTelecom portal, Khan identified the customer responsible for the 

HVAC-Corona call campaign as a call center located in Pakistan named Oberlo Peer BPO. He 

also notified USTelecom that he had “advised customer to remove traffic.” 

17 
 

 

 

 

 

 

 

 

 

 

 

 

Submit y ou r response v ia o ur secure o n-li ne portal: 

httns· / /tracelu,ck 11steleron1 Q[Q /EotDJ /I ooin /c·sNYO!IIUhHKhPAfilllYieZJ iihidA3BviYlli3onPYP 

w51CvdxliiolvwRBKdknJYGJ ?t- HHW2Zeonz 

( URL is a private login; do not share.) 

Call Details for Incident #676 (new) 

Date/Time: 

To : 

From: 

Campaign : 

2019-08-0 1 14:20:00 UTC 

+12197184311 

+12195165599 

VisaAle,t 

Automated voice offering zero percent int erest rate, identified as t he alert 

system with Visa MasterCard Account Services. Caller ID is spoofed with a 

random NPA so blockin9 t he AN! is not effective. Many caller-IDs are invalid. 

Millions of calls daily. Calls are ille9al because they are automated calls to 

mobiles, t hey use improper caller-ID, they do not identify the caller at the 

beginning of the message, they do not give an operable call-back number. 

Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 18 of 27 PageID 18 

73. On March 16, 2020, Khan received a traceback inquiry for three additional calls 

related to the same illegal coronavirus spoofed prerecorded call campaign. Khan responded as he 

had before: “advised customer to remove traffic.” 

74. From July 2019 to December 2020, USTelecom sent Defendants traceback 

notices for seventy unlawful telemarketing campaigns. Those traceback notices flagged unlawful 

prerecorded call campaigns involving credit card interest rate reduction, tech support scams, and 

COVID-related air duct cleaning, among others. Most, if not all of these campaigns, involved 

spoofed caller IDs. Those traceback notices flagged the following unlawful campaigns, among 

others: 

18 
 

 

 

 

 

 

Call Details for Incident #1271 (new) 

Date/Time: 

To: 

Frorn: 

campaign: 

2019-12-10 15:50:00 UTC 

+1754551'520 

+17547826996 

CCIRR-CCHolder 

Recorded voice says you qualify for zero percent interest, press 1 to complete the process. 

Calls using recorded voice not permitted to wireless numbers. Calling entity not identified. No 

toll-free call-back number left in voicemail. Calling number is neighbcr-spoofed so BLOCKING 

THE ANI is NOT effective. 

Call Details for Incident #1397 (new) 

To: 

Fron: 

Campaign: 

2020-J l-20 15.40.00 l!TC 

+13102935443 

• 1'3.1 07921451 

CCIRR-MemberSvcs 

ReCOfded voioe offers lower interest rate. press 1 to speak to Member Seivices Department. 

Calls using recorded voice not permitted to wire:ess numbers. Calfing entity not identified. No 

toll-free call-oock number left in voicemail. Calling number is nei~hbor-spoofed so BLOCKING 

THE ANI is NOT effecive. This call is just one example of millions of similar calls. Originators 

please search your records for similar traffic and address with yo Jr customer. 

Call Details for Incident #1518 (new) 

Date/Time: 

To: 

from: 

Campaign: 

2020-02-0517:27:00 lJTC 

+1 3147992826 

+1 3148975406 

CORR-Alice 

Automated voice offers zero interest and says press 1 tc connect to li',e rep. Unsolicited calls 

U$ing .:iutornated °' prerecord~ voice not pem11itted to wirelC$:. num~. Me:.:..-lgc doe:. not 

identify calling entity. No toll-free call--back ,umber in message. Caller-ID is neighbor-spoofed 

so ANI blocking is not an effective mitigatia, approach.Latest calls plaoed after provider in 

Pat istan indicated caller was no longer spoofing but tnal is not the case. This call is just one 

example of millicns of similar :alls. Originators please search your records for similar traffic and 

aa<1ress wtth yot. r customer. 

Call Details for Incident #1623 (neN) 

Date/Time: 

Tn· 

From: 

Campaig,: 

2020-02-1515:59:00 lJTC 

+130..'\97:l'\?51 

+16027652334 

TechSupp,rt-CTL 

Fraudsters spoofing a Cen:urylink employee or retail number catling consuners impersonating 

Centurylink as part of a Tech support scam attempting to g3in control of their PC, order 

AWU£Ull item:s, ulJl.:tifl rirn:111001 c.latc:i, iu:sh:111 m;;:dw-cm:, c lc. 

Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 19 of 27 PageID 19 

19 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Call Details for Incident #1682 (new) 

Date/Time: 

To: 

From: 

Campaign: 

2020-02-18 21:55:00 lJTC 

• 12699254890 

+ 12699254444 

CCI RR-Generic 

Recorded or artificial voice offering credit card interest rate reduction service. Typically does not 

identify, or mis-identifies, the calling party. Frequently uses spoofed caller-ID. Often does not 

honor do-not-call restrictions. 

Call Details for Traceback 13964 (new) 

Date/Time: 

To: 

From: 

Campaign: 

2020-12-29 22:o6 UTC 

+15088642810 

• 17155271 051 

CCIRR - VisaAlert 

FRAUD. Automated voice offering zero _.,t interest rate, identified as lhe alert system with Visa MasterCard Account 

Services. Caller ID is spoofed with a random NPA so blocking the ANI is not effective. Many caller-IDs are invalid. Millions of 

cals daily. Calls are illegal because they are automated calls to mobiles, they use improper ~ r-lD, they do not idenbfy the 

caler at !he beginrw,g or !he messoge, !hey do not give M operable call-back number. This cal is just one example of milions 

or similar calls. Originators please search your records ror smiilar traffic ond address with your cuslomer. 

Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 20 of 27 PageID 20 

75. Khan responded to 42 of USTelecom’s traceback notices. Khan entered into 

USTelecom’s response portal the customer information for 18 of Defendants’ call center 

customers. Khan notified USTelecom that the customers were call centers in Bangladesh, 

Pakistan, and the United States. Khan wrote that Defendants had removed one customer in July 

of 2019. In February 2020, Khan told USTelecom that another customer’s unlawful robocall 

went through during a maintenance window for a new system Defendants were implementing. 

Khan also responded that Defendants removed two additional customers in April 2020 and 

implemented a system that automatically detects and blocks spoofing and invalid ANIs. For most 

of the tracebacks, though, Khan reported that Defendants simply “advised the customer[s] to 

remove [unlawful] traffic.” Defendants did not answer 28 of the traceback inquires. 

76. USTelecom was concerned that Defendants did not stem the tide of illegal calls 

traversing its network. In March 2020, this prompted US Telecom to email a company that sent 

phone traffic through Defendants’ system. The email stated: 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 21 of 27 PageID 21 

We are writing because your upstream customer VOIP Terminator (aka BL 

Marketing) continues to appear regularly in our tracebacks of apparently illegal 

robocalls despite our ongoing notifications to them. 

... 

For much of 2019, they did not respond to traceback requests. Beginning in 

February of 2020, they have consistently responded, indicating primarily that the 

calls, now associated with multiple CCIRR2 campaigns as well as those associated 

with Tech Support scams and marketing related to Coronavirus, are coming from 

various customers of theirs in Pakistan. VOIP Terminator has not disputed the 

illegality of the calls. 

77. On April 2, 2020, the FTC issued Civil Investigative Demands (“CIDs”) to VoIP 

Terminator and BLMarketing, requesting information about Defendants’ customers who were 

the subject of USTelecom tracebacks concerning, inter alia, the HVAC-Corona campaign. In 

that CID, the FTC identified the subject of the investigation as an inquiry into whether VoIP 

Terminator and BLMarketing had assisted and facilitated violations of the TSR regarding 

specific customers or subscribers. 

78. In response to the April 2, 2020 CID, VoIP Terminator, through counsel, 

identified the entities involved with the HVAC-Corona campaign as Oberlo Peer BPO, Tole 

Cosmetics, and James Joseph Servas. VoIP Terminator represented that Oberlo Peer BPO used 

the same means and source payment as Tole Cosmetics and Servas. VoIP Terminator also 

represented that it had conducted business with Servas from July 2019 until August 2019, and 

with Tole Cosmetics from October 2019 until March 2020. VoIP terminator also produced the 

same 2016 Master Services Agreement—signed by Servas, using a Tole Cosmetics email 

address—that he had produced in response to the FCC’s 2018 subpoena. 

2 CCIRR stands for Credit Card Interest Rate Reduction. 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 22 of 27 PageID 22 

79. Also, in response to the April 2, 2020 CID, VoIP Terminator produced call detail 

records that he represented “related to” Oberlo Peer BPO, Tole Cosmetics, and James Servas. 

Additional call detail records related to a separate unlawful call campaign (playing a prerecorded 

message offering zero-percent interest loans) perpetrated by Shirazi Quereshi, who owned 

TransData. An FTC analysis of the 126 million total calls in the call detail records concluded that 

more than 78 million of those calls were made to numbers on the DNC Registry. More than 26 

million such calls were made after January 13, 2020. 

80. On April 3, 2020, the FCC and FTC issued a joint warning letter to Khan and 

VoIP Terminator dba BLMarketing. The letter noted that Defendants were “apparently routing 

and transmitting Novel Coronavirus (COVID-19) scam robocall traffic originating from Oberlo 

Peer BPO.” It requested that Defendants cease routing and transmitting traffic from Oberlo Peer 

BPO immediately, and warned that if Defendants did not take steps to block traffic within 48 

hours of the letter’s date, the FCC would authorize voice providers to block all calls from VoIP 

Terminator, and take any other steps needed to prevent further transmission of unlawful calls. 

81. Khan responded to the FCC via email. He told the FCC that “the day 

[USTelecom] identified and requested the traceback we blocked the customer and is not allowed 

to route traffic anymore.” However, as stated above, USTelecom’s response portal indicates that 

after Khan received the first traceback notice from USTelecom concerning the HVAC-Corona 

spoofed call campaign, Khan advised his customer to remove the illegal traffic. He did not block 

the customer. Likewise, Khan testified under oath at the FTC’s investigational hearing that 

Defendants’ usual business practice, after receiving notice of illegal telemarketing activities, was 

to ask call center customers to cease their illegal conduct, not to block the customer. It was only 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 23 of 27 PageID 23 

after Khan received the joint FCC/FTC letter threatening to block all of Defendants’ calls that 

Defendants stopped providing VoIP services to Servas and his company, Oberlo Peer BPO. 

82. Servas’s telemarketing campaigns, including the spoofed recorded calls related to 

the coronavirus, involved millions of interstate telephone calls from 2018 to 2020. Servas’s 

companies dialed many of these calls from foreign call centers, using internet service to connect 

to Defendants’ VoIP servers, in order to reach consumers in Florida and through the United 

States. 

83. Based on the facts and violations of law alleged in this Complaint, the FTC has 

reason to believe that Defendants are violating or are about to violate laws enforced by the 

Commission because, among other things: Defendants engaged in their unlawful acts and 

practices repeatedly over a period of at least three years; Defendants continued their unlawful 

acts or practices despite knowledge of government investigations into their conduct; Defendants 

stopped their unlawful conduct only after they received a Civil Investigative Demand from the 

FTC; Defendants remain in business in Pakistan and maintain the means, ability, and incentive to 

resume their unlawful conduct. 

COUNT I 

Assisting and Facilitating Violations of the Telemarketing Sales Rule 

84. Defendants provided substantial assistance or support to “seller[s]” and/or 

“telemarketer[s]” engaged in “telemarketing,” as defined by the TSR, 16 C.F.R. § 310.2. 

85. In numerous instances, in connection with telemarketing, those sellers and/or 

telemarketers: 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 24 of 27 PageID 24 

a) Initiated or caused the initiation of outbound telephone calls to telephone 

numbers on the National DNC Registry to induce the purchase of goods or 

services, in violation of 16 C.F.R. § 310.4(b)(1)(iii)(B); 

b) Initiated or caused the initiation of outbound telephone calls that delivered 

prerecorded messages to induce the purchase of goods or services in violation of 

16 C.F.R. § 310.4(b)(1)(v); and 

c) Failed to transmit or cause to be transmitted to caller identification 

services the telephone number and name of the telemarketer making the call, or 

the customer service number and name of the seller on whose behalf the 

telemarketer called, in violation of 16 C.F.R. § 310.4(a)(8). 

86. At all relevant times, Defendants knew, or consciously avoided knowing, that the 

sellers or telemarketers for whom Defendants provided VoIP services were making the unlawful 

calls described in paragraphs 56 to 84, which violated § 310.4 of the TSR. 

87. Defendants’ substantial assistance and support, as alleged in paragraphs 27 to 84, 

above, violates the TSR, 16 C.F.R. § 310.3(b). 

CONSUMER INJURY 

88. Consumers have suffered and will continue to suffer substantial injury as a result 

of Defendants’ violations of the TSR. Absent injunctive relief by this Court, Defendants are 

likely to continue to injure consumers and harm the public interest. 

89. Based on the facts and violations of law alleged in this Complaint, the FTC has 

reason to believe that Defendants are violating or are about to violate laws enforced by the FTC, 

and that consumers will continue to be injured by those ongoing violations, because, among 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 25 of 27 PageID 25 

other things: (a) Defendants have shown a pattern and practice of continuing to assist and 

facilitate violations of the TSR, even after learning of the violations; (b) Defendants remain 

active in Pakistan under the same brand name and maintain the means, ability, and incentive to 

resume their unlawful conduct; (c) Defendants have repeatedly ignored law enforcement 

agencies’ and trade associations’ warnings about illegal calls originating with their customers, 

and (d) Defendants have only blocked violating customers after repeated warnings from law 

enforcement agencies or trade associations, choosing instead to warn rather than block customers 

originating illegal calls. 

PRAYER FOR RELIEF 

Wherefore, Plaintiff requests that the Court: 

A. Award Plaintiff monetary civil penalties from each Defendant for every violation 

of the TSR, 

B. Enter a permanent injunction to prevent future violations of the FTC Act and the 

TSR by Defendants, 

C. Award other relief within the Court’s power to grant, and 

D. Award any additional relief as the Court determines to be just and proper. 

Respectfully submitted, 

Dated: April 26, 2022 BRIAN M. BOYNTON 

Principal Deputy Attorney General 

Civil Division 

ARUN G. RAO 

Deputy Assistant Attorney General 

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Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 26 of 27 PageID 26 

ROGER B. HANDBERG 

United States Attorney 

Middle District of Florida 

s/ Lacy R. Harwell, Jr. 

LACY R. HARWELL, JR. 

Chief, Civil Division 

Florida Bar No. 714623 

400 N. Tampa Street, Suite 3200 

GUSTAV W. EYLER 

Director 

Consumer Protection Branch 

LISA K. HSIAO 

Assistant Director 

s/ Ellen Bowden McIntyre 

ELLEN BOWDEN MCINTYRE 

ZACHARY A. DIETERT 

Trial Attorneys Appearing Pursuant to 28 U.S.C. § 517 

Consumer Protection Branch 

U.S. Department of Justice 

P.O. Box 386 

Washington, DC 20044 

Phone: (202) 451-7731 

ellen.bowden.mcintyre@usdoj.gov 

(202) 616-9027 

zachary.a.dietert@usdoj.gov 

Attorneys for Plaintiff 

UNITED STATES OF AMERICA 

26 
 

 

 

 

 

 

 

Case 6:22-cv-00798 Document 1 Filed 04/26/22 Page 27 of 27 PageID 27 

CERTIFICATE OF SERVICE 

I certify that a true and correct copy of the foregoing is being served by electronic mail and 

U.S. Mail on April 26, 2022 to the following: 

Muhammmed Usman Khan 

Individually and as an officer of VOIP Terminator, Inc., and BLMarketing, Inc. 

House Number 1301 Service Road D121 

Islamabad, Pakistan 

Email: mkhan@voipterminator.com 

usman@khans.pk 

s/ Ellen Bowden McIntyre 

Trial Attorney 

27