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BRIAN M. BOYNTON 

Principal Deputy Assistant Attorney General, Civil Division 

ARUN G. RAO 

Deputy Assistant Attorney General, Civil Division 

AMANDA N. LISKAMM 

Director 

RACHAEL L. DOUD 

Assistant Director 

ZACHARY A. DIETERT 

Trial Attorney 

 Consumer Protection Branch 

 Civil Division, U.S. Department of Justice 

 450 5th Street, NW, Suite 6400-South 

 Washington, DC 20044-0386 

 Telephone: (202) 616-9027 

 Facsimile: (202) 514-8742 

 Email: Zachary.A.Dietert@usdoj.gov 

Attorneys for Plaintiff, United States of America 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

UNITED STATES OF AMERICA, 

 Plaintiff, 

 vs. 

XCAST LABS, INC., 

 Defendant. 

No. 23-cv-03646 

COMPLAINT FOR PERMANENT 

INJUNCTION, CIVIL PENALTIES, 

AND OTHER RELIEF AND 

DEMAND FOR JURY TRIAL 

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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(m)(1)(A), 13(b), 16(a), 

and 19 of the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. §§ 45 

(m)(1)(A), 53(b), 56(a), 57b, and Section 6 of the Telemarketing and Consumer 

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

obtain permanent injunctive relief, civil penalties, and other relief for Defendant’s 

acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and 

the FTC’s Telemarketing Sales Rule (“TSR”), as amended, 16 C.F.R. Pt. 310. 

SUMMARY OF ALLEGATIONS 

2. This case involves billions of illegal robocalls delivered to American 

consumers using services provided by Defendant XCast Labs, Inc. (“XCast”). As 

set forth in detail below, XCast has assisted its customers in making telemarketing 

calls to consumers that: (1) delivered a prerecorded message, in violation of 16 

C.F.R. § 310.4(b)(1)(v); (2) were placed to numbers listed on the National Do Not 

Call (DNC) Registry, in violation of 16 C.F.R. § 310.4(b)(1)(iii)(B); (3) failed to 

disclose the identity of the seller, in violation of 16 C.F.R. § 310.4(d)(1); (4) falsely 

claimed affiliations, including with government entities, in violation of 16 C.F.R. § 

310.3(a)(2)(vii); (5) made false or misleading statements to induce purchases or 

contributions, in violation of 16 C.F.R. § 310.3(a)(4); and (6) transmitted false or 

deceptive caller ID numbers, in violation of 16 C.F.R. § 310.4(a)(8)). 

JURISDICTION AND VENUE 

3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 

§§ 1331, 1337(a), and 1345. 

4. Venue is proper in this District under 28 U.S.C. § 1391(b)(1), (b)(2), 

(c)(2), (c)(3), and (d), and 15 U.S.C. § 53(b). 

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DEFENDANT 

5. Defendant XCast Labs, Inc. (“XCast”), is a California corporation 

with its principal place of business at 1880 Century Park East, Suite 612, Los 

Angeles, California. XCast transacts or has transacted business in this District and 

throughout the United States. 

COMMERCE 

6. At all times relevant to this Complaint, Defendant has maintained a 

substantial course of trade in or affecting commerce, as “commerce” is defined in 

Section 4 of the FTC Act, 15 U.S.C. § 44. 

THE TELEMARKETING SALES RULE AND THE NATIONAL DO 

NOT CALL REGISTRY 

7. Congress directed the FTC to prescribe rules prohibiting abusive and 

deceptive telemarketing acts or practices pursuant to the Telemarketing Act, 15 

U.S.C. §§ 6101–08. The FTC adopted the original TSR in 1995, extensively 

amended it in 2003, and amended certain provisions thereafter. 16 C.F.R. Pt. 310. 

8. 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. 

9. Consumers who receive telemarketing calls to their registered 

umbers can complain of Registry violations through a toll-free telephone call, 

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

10. The TSR defines “telemarketing” as a plan, program, or campaign 

hich is conducted to induce the purchase of goods or services or a charitable 

ontribution, by use of one or more telephones and which involves more than one 

nterstate telephone call. 16 C.F.R. § 310.2(gg). 

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11. 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). 

12. 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. § 310.2(dd). 

13. The FTC allows sellers, telemarketers, and other permitted 

organizations to access the Registry online at telemarketing.donotcall.gov, to pay 

any required fees, and to download the numbers not to call. 

14. Under the TSR, an “outbound phone 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). 

15. The TSR prohibits sellers and telemarketers from initiating an 

outbound phone call to a number on the Registry, unless the seller or telemarketer 

can demonstrate that it has obtained the call recipient’s express written agreement 

to receive such calls from it or can demonstrate that it already has an established 

business relationship with the call recipient. 16 C.F.R. § 310.4(b)(1)(iii)(B). 

16. The TSR prohibits initiating an outbound telephone call that delivers a 

prerecorded message to induce the purchase of any good or service, unless the 

seller or telemarketer has an express written agreement from the recipient to 

receive such prerecorded messages from it. 16 C.F.R. § 310.4(b)(1)(v). Calls 

delivering prerecorded messages are often referred to as “robocalls.” 

17. During an outbound telephone call to induce the purchase of goods or 

services, the TSR requires a telemarketer to disclose the identity of the seller 

truthfully, promptly, and in a clear and conspicuous manner to the person receiving 

the call. 16 C.F.R. § 310.4(d)(1). 

18. The TSR prohibits sellers and telemarketers from misrepresenting, 

directly or by implication, in the sale of goods or services, their affiliation with, or 

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endorsement or sponsorship by, any person or government entity. 16 C.F.R. § 

310.3(a)(2)(vii). 

19. The TSR prohibits sellers and telemarketers from making false or 

misleading statements to induce any person to pay for goods or services or to 

induce a charitable contribution. 16 C.F.R. § 310.3(a)(4). 

20. The TSR prohibits sellers and telemarketers from causing inaccurate 

caller ID information to be transmitted to call recipients. 16 C.F.R. § 310.4(a)(8). 

Transmitting inaccurate caller ID information is often referred to as “spoofing.” 

21. 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 a practice 

that violates the TSR. 

22. 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). 

23. 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 $50,120.00 for each violation of 

the TSR assessed after January 11, 2023, including penalties whose associated 

violation predated January 11, 2023. 

DEFENDANT’S BUSINESS ACTIVITES 

24. XCast is a nationwide provider of Voice over Internet Protocol (VoIP) 

services, including Session Initiation Protocol (SIP) termination. VoIP is 

technology that allows a person to make voice calls using a broadband internet 

connection as opposed to a regular (analog) phone line. In other words, VoIP calls 

are phone calls that are sent over the internet. 

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25. 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 often participate in transmitting a 

given call from its originator (often a telemarketer) to a termination point (most 

often a consumer’s telephone). 

26. XCast’s VoIP services include “origination” services. Origination is 

beginning the transmission of a call from the telemarketer or company which 

initiated the call. XCast also serves as a mid-stream provider, transmitting calls 

from and to other VoIP providers. 

27. Since at least January 1, 2018, XCast has, through its VoIP services, 

transmitted billions of illegal robocalls that sellers and telemarketers placed to 

American consumers in violation of the TSR. Some of these calls marketed goods 

and services with a history of deceptive sales practices, such as extended 

automobile warranties. 

28. Many of the illegal robocalls XCast has transmitted were fraudulent 

telemarketing scams. They include, for example, robocalls falsely claiming 

affiliations with government entities such as the Social Security Administration, 

threatening to cut off a call recipient’s utility service unless they make immediate 

payments, or claiming that a call recipient’s credit card has been charged and they 

must act promptly to have the charge refunded. 

29. XCast’s own records of the calls it transmits make clear that it has 

transmitted huge numbers of illegal calls. XCast’s call data records (“CDRs”) 

include information such as the exact date and time of a call, the calling number, 

the called number, and the exact duration of the call. CDRs that XCast has 

produced to the FTC of calls it transmitted for just three of its customers, for 

example, reveal that nearly two billion of those calls were placed to numbers on 

the National DNC Registry. 

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30. XCast’s CDRs are also rife with massive volumes of very shortduration calls, which are a distinct feature of fraudulent robocall campaigns. For 

example, CDRs XCast produced to the FTC show an average call duration of only 

about 6.5 seconds for nearly two billion calls that were placed to numbers on the 

National DNC Registry, with the overwhelming majority of those calls lasting less 

than ten seconds. 

31. On scores of occasions dating back to at least December 2018, 

USTelecom’s Industry Traceback Group (ITG), the official U.S. Federal 

Communications Commission (FCC)-designated consortium of telephone and 

broadband industry companies, has notified XCast that XCast routed and 

transmitted suspected illegal robocall traffic on behalf of upstream carriers or endusers. 

32. ITG notified XCast of these suspected illegal calls through 

“Traceback Requests,” which are emails ITG sends to voice service providers 

seeking assistance with identifying the source of suspicious traffic that the voice 

service provider routed or transmitted. 

33. An ITG “Traceback” is a network-based process that seeks out the 

source of suspicious traffic by beginning at a terminating voice service provider 

and systematically tracing a call to preceding providers. ITG finds that suspicious 

traffic “is identifiable by a pattern of voice calls that: (1) transit one or more Voice 

Service Provider networks and (2) have characteristics associated with abusive, 

unlawful, or fraudulent practices.” 

34. ITG sent XCast over 100 Traceback Requests in 2020 and over 90 

more in 2021. For dozens of these Traceback Requests, XCast served as either the 

originator of the suspected robocall or the point-of-entry (i.e., the first service 

provider within a call’s path to take an illegal robocall from a foreign service 

provider). 

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35. Many of the Traceback Requests that ITG sent XCast expressly noted 

that the calls at issue were perpetrating fraud. The Traceback Requests also 

provided additional details about the calls XCast had transmitted. They stated, for 

example, that some of the calls impersonated federal officials, threatened to cut off 

recipients’ utilities, and used corporate names without permission. The Traceback 

Requests also noted other problems with the calls XCast had transmitted, including 

that they delivered pre-recorded messages, failed to identify the caller or seller, and 

were delivered with spoofed caller ID information. 

36. To help XCast identify the source(s) of the suspected illegal robocall 

traffic and take effective steps to mitigate it, some of ITG’s Traceback Requests 

also provided XCast access to audio of the prerecorded messages and CDRs for 

each incident. 

37. In addition to the scores of Traceback Requests XCast received, law 

enforcement also put XCast on notice of numerous red flags relating to its 

provision of VoIP services to purveyors of unlawful robocalls. For example, in 

August 2019, XCast received a subpoena from federal prosecutors for information 

and call records relating to XCast’s customer E Sampark, a VoIP provider based in 

India that was subsequently indicted for conspiracy to commit wire fraud through a 

scheme involving fraudulent robocalls. In January 2021, XCast received a civil 

investigative demand (“CID”) from the FTC requesting information concerning its 

customers Dialcom aka Gudelor (a California based telecommunications provider) 

and RSCom Ltd. (a Canadian based telecommunications provider) and informing 

XCast that the records were being sought as part of an investigation into potential 

violations of the TSR. XCast also received additional subpoenas, CIDs, or other 

law enforcement inquiries alerting it to potentially illegal calls, including from 

state government agencies who indicated their requests related to potential illegal 

telemarketing. 

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38. XCast has also repeatedly received complaints from other sources, 

including multiple downstream providers, that it was transmitting illegal calls, 

including fraudulent scam robocalls and calls with spoofed caller ID information. 

39. On January 29, 2020, the FTC sent warning letters to XCast and a 

select group of other VoIP service providers to caution them that assisting and 

facilitating illegal telemarketing or robocalling was against the law and inform 

them of lawsuits the FTC and Department of Justice had brought against VoIP 

providers for allegedly assisting and facilitating illegal robocalls. Despite this 

warning that it could face liability for assisting and facilitating TSR violations, 

XCast continued to transmit hundreds of millions of illegal telemarketing calls to 

American consumers. 

40. Even after being alerted to red flags concerning the legality of specific 

customers’ calls, XCast continued to transmit calls for those customers. For 

example, XCast continued transmitting calls for E Sampark for more than a year 

after receiving a subpoena from federal prosecutors in August 2019 relating to that 

customer, and it continued transmitting calls for its customer RSCom for more than 

two years after it began receiving complaints, which was at least as early as March 

2019, that calls XCast transmitted for RSCom were illegal. 

41. XCast’s experience as a nationwide provider of VoIP services, the 

numerous indicia of unlawful robocall campaigns contained in its own records, and 

the repeated warnings and alerts it received from ITG, government officials, and 

others demonstrate that since at least January 1, 2018, XCast knew or consciously 

avoided knowing that providers were using XCast’s services to transmit calls that 

violated the TSR. 

42. Specifically, XCast received direct notice from multiple sources that 

its services were transmitting calls that failed to disclose the identity of the seller, 

falsely claimed affiliations, including with government entities, made false or 

misleading statements to induce purchases, and included spoofed caller ID 

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information. XCast also received direct notice that its services were transmitting 

robocalls and calls to numbers on the National DNC Registry. Based on the 

massive volumes of such calls, their short duration, and their often fraudulent 

nature, it should also have been clear to XCast that it was transmitting robocalls for 

which the sellers and telemarketers could not demonstrate, as the TSR requires, 

that they had obtained an express agreement from each call’s recipient to receive 

pre-recorded calls from that seller or telemarketer. These same factors should have 

also made clear to XCast that it was transmitting calls to phone numbers on the 

National DNC Registry belonging to consumers for whom the seller or 

telemarketer could not demonstrate having obtained an express agreement or 

having an established business relationship. 

43. Based on the facts and violations of law alleged in this Complaint, 

Plaintiff has reason to believe that Defendant is violating or is about to violate laws 

enforced by the Commission. 

COUNT I 

ASSISTING AND FACILITATING VIOLATIONS OF 

THE TELEMARKETING SALES RULE 

44. As described in paragraphs 7–43, above, Defendant XCast has, in 

numerous instances, provided substantial assistance and support, through the 

provision of VoIP services, to one or more “sellers” and/or “telemarketers” 

engaged in “telemarketing,” as defined by the TSR, 16 C.F.R. § 310.2, whom 

XCast knew or consciously avoided knowing: 

1) Initiated or caused the initiation of outbound 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); 

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

telephone numbers on the National DNC Registry to induce the 

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purchase of goods or services, in violation of 16 C.F.R. 

§ 310.4(b)(1)(iii)(B); 

3) Failed to disclose the identity of the seller of the goods or 

services truthfully, promptly, and in a clear and conspicuous 

manner to the person receiving the call, in violation of 16 

C.F.R. § 310.4(d)(1); 

4) Misrepresented, directly or by implication, in the sale of goods 

or services, the seller’s or telemarketer’s affiliation with, or 

endorsement or sponsorship by, a person or government entity, 

in violation of 16 C.F.R. § 310.3(a)(2)(vii); 

5) Made false or misleading statements to induce a person to pay 

for goods or services or to induce a charitable contribution, in 

violation of 16 C.F.R. § 310.3(a)(4); and 

6) Failed to transmit or cause to be transmitted the accurate 

telephone number and name of the telemarketer to any caller 

identification service in use by a recipient of a telemarketing 

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

45. Defendant’s substantial assistance and support violates the TSR, 16 

C.F.R. § 310.3(b). 

CONSUMER INJURY 

46. Consumers are suffering, have suffered, and will continue to suffer 

substantial injury as a result of Defendant’s violations of the TSR. 

47. Absent injunctive relief by this Court, Defendant is likely to continue 

to injure consumers and harm the public interest. 

THIS COURT’S POWER TO GRANT RELIEF 

48. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court 

to grant injunctive and other ancillary relief to prevent and remedy any violation of 

any provision of law enforced by the FTC. 

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49. Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A), as 

modified by Section 4 of the Federal Civil Penalties Inflation Adjustment Act of 

1990, 28 U.S. C. § 2461, the Federal Civil Penalties Inflation Adjustment Act of 

2015, Public Law 114-74, sec. 701, 129 Stat. 599 (2015), and Section 1.98(d) of 

the FTC’s Rule of Practice, 16 C.F.R. § 1.98(d), authorizes this Court to award 

monetary civil penalties of not more than $50,120.00 for each violation of the TSR 

assessed after January 11, 2023, including penalties whose associated violation 

predated January 11, 2023, that is made with actual knowledge or knowledge fairly 

implied on the basis of the objective circumstances that such act is unfair or 

deceptive and is prohibited by such rule. 

50. Defendant’s violations of the TSR described above were committed 

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

45(m)(1)(A). 

PRAYER FOR RELIEF 

Wherefore, Plaintiff requests that the Court: 

A. Enter a permanent injunction to prevent future violations of the FTC 

Act and the TSR by Defendant; 

B. Award Plaintiff monetary civil penalties from Defendant for every 

violation of the TSR; and 

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

proper. 

DEMAND FOR JURY TRIAL 

Plaintiff hereby demands a trial by jury of all issues so triable pursuant to 

Rule 38 of the Federal Rules of Civil Procedure. 

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Dated: May 12, 2023 Respectfully submitted, 

BRIAN M. BOYNTON 

Principal Deputy Assistant Attorney General 

ARUN G. RAO 

Deputy Assistant Attorney General 

AMANDA N. LISKAMM 

Director, Consumer Protection Branch 

RACHAEL L. DOUD 

Assistant Director 

/s/ Zachary A. Dietert 

ZACHARY A. DIETERT 

Trial Attorney 

Consumer Protection Branch 

Civil Division, U.S. Department of Justice 

450 5th Street, NW, Suite 6400-South 

Washington, DC 20044-0386 

Tel.: (202) 616-9027 

Fax: (202) 514-8742 

Email: Zachary.A.Dietert@usdoj.gov 

Counsel for Plaintiff United States of America 

f Counsel: 

HOMAS M. BIESTY 

RANCES KERN 

ederal Trade Commission 

00 Pennsylvania Ave., NW, Mailstop CC-5201 

ashington, DC 20580 

202) 326-3043 (Biesty) 

202) 326-2391 (Kern) 

biesty@ftc.gov 

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