United States of America

 FEDERAL TRADE COMMISSION 

East Central Region

1111 Superior Avenue, Suite 200 Jon Miller Steiger

Cleveland, Ohio 44114 Director

(216) 263Ͳ3455



March 17, 2023 

CEASE AND DESIST DEMAND 

VIA EMAIL TO: 

none@USAC.org 

Telcast Network LLC 

Talal Khalid, CEO 

8 The Green Ste A, Suite #7044 

Dover, DE 19901 

c/o National Registered Agents, Inc. 

We have determined that Telcast Network LLC is apparently routing and transmitting 

illegal robocall traffic, directly or indirectly, for entities involved in the following campaigns: 

x Amazon-AuthorizeOrder 

x AutoWarrantyExtend 

x AutoWarranty-ExtendOrReinst 

x Solar-EnergyAdvocates 

x SSA-P1-TexasFraud (GovtImpers) 

More specifically, our investigation revealed that Telcast Network LLC apparently routed and 

transmitted illegal robocalls, as set forth in Attachment A. 

The Federal Trade Commission (FTC) works closely with USTelecom’s Industry 

Traceback Group (ITG), which is the registered industry consortium selected pursuant to the 

TRACED Act to conduct tracebacks.1 Between March 5, 2021, and August 24, 2022, ITG 

investigated 9 prerecorded voice message calls that law enforcement, voice service providers 

using honeypots (i.e., unassigned numbers held by providers to detect illegal robocalls), and 

customers of YouMail had flagged as illegal robocalls made without consent of the called party.2 

ITG conducted tracebacks and determined that Telcast Network LLC routed and transmitted the 

calls. ITG previously notified you of these calls and provided you access to supporting data 

identifying each call—including a recording of the illegal robocall—as indicated in Attachment 

1 See Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence Act, Pub. 

L. No. 116-105, 133 Stat. 3274, Sec. 13(d) (2019) (TRACED Act).

2 See 16 C.F.R. § 310.4(b)(1)(v). 
A. Further, the numerous traceback notices directed to Telcast Network LLC indicate that you 

are apparently routing and transmitting illegal robocall traffic knowingly. IF YOU ARE 

ENGAGED IN THESE ACTIVITIES, THEN YOU MUST IMMEDIATELY CEASE AND 

DESIST FROM ENGAGING IN THEM. 

The FTC, the nation’s consumer protection agency, enforces the Federal Trade 

Commission Act (FTC Act), 15 U.S.C. § 45 et seq., which prohibits unfair or deceptive acts or 

practices in or affecting commerce. The FTC also enforces the Telemarketing Sales Rule (TSR), 

16 C.F.R. Part 310, which prohibits deceptive and abusive telemarketing practices. Section 

310.3(b) of the TSR prohibits “assisting and facilitating” certain specified conduct.3 Under that 

provision, it is unlawful for any person or entity 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 act or practice that violates Sections 310.3(a), (c), or (d), or 

Section 310.4 of this Rule.” These Sections prohibit, among others, the following conduct: 

x Making a false or misleading statement to induce any person to pay for goods or services 

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

x Misrepresenting a seller or telemarketer’s affiliation with any government entity 

(16 C.F.R. § 310.3(a)(2)(vii)); 

x Transmitting false or deceptive caller ID numbers (16 C.F.R. § 310.4(a)(8)); 

x Initiating or causing the initiation of calls that deliver prerecorded messages,4

 unless the 

person called provided the seller express written permission to call (16 C.F.R. 

§ 310.4(b)(1)(v)); and 

x Initiating or causing the initiation of telemarketing calls to numbers listed on the National 

Do Not Call Registry, unless the person called provided express written permission to 

receive calls from the seller or the seller had an existing business relationship with the 

person called (16 C.F.R. § 310.4(b)(1)(iii)(B)). 

The FTC can obtain civil penalties for TSR violations. Each illegal call is subject to a 

maximum civil penalty of $50,120. See 16 C.F.R. § 1.98. In addition, a violation of the TSR is a 

violation of Section 5 of the FTC Act. See 15 U.S.C. §§ 6102(c), 57a(d)(3), 45(a). Accordingly, 

the FTC has authority to seek both preliminary and permanent injunctive relief to address TSR 

violations. See 15 U.S.C. § 53(b). The FTC may also seek the refund of money or payment of 

damages to address TSR violations. See 15 U.S.C. § 57b(b). 

Combatting illegal telemarketing is a top priority for the FTC, with a special emphasis on 

halting illegal robocalls.5

 We want you to be aware that the FTC has, for example, brought 

assisting and facilitating claims against technology companies that knowingly provided software 

3 A copy of the TSR is attached as Attachment B. 

4

 These calls are often referred to as “robocalls.” 

5 In 2022, the FTC received more than 2.7 million complaints about unwanted calls, including 

more than 1.61 million robocall complaints. The FTC maintains an interactive Tableau Public 

web page that publishes details about do not call complaints on a quarterly basis. See 

https://public.tableau.com/profile/federal.trade.commission#!/vizhome/DoNotCallComplaints/M 

aps. 

2 
 

 

 

 

and servers used by illegal robocallers, even though these technology companies did not contract 

directly with the illegal robocallers. See FTC v. James B. Christiano, Case No. 8:18-cv-00936 

(C.D. Cal. May 31, 2018). 

We also bring to your attention that the FTC has sued VoIP service providers for 

allegedly violating the TSR. In FTC v. Educare, the FTC alleged that defendant Globex 

Telecom, Inc. assisted and facilitated telemarketers it knew, or consciously avoided knowing, 

were violating the TSR’s prohibitions on calls delivering prerecorded messages. See FTC v. 

Educare Centre Services, Inc., No. 3:19-cv-00196-KC (W.D. Tex. Dec. 3, 2019).6 In September, 

2020, Globex Telecom and its associates agreed to pay $2.1 million to settle the FTC lawsuit, 

and Globex Telecom’s former CEO and President was banned from telemarketing to the U.S. 

and was subject to a permanent court order.7 Similarly, in FTC v. Alcazar Networks, Inc., the 

FTC alleged that Alcazar Networks, Inc. and its founder and sole owner assisted and facilitated 

telemarketers responsible for tens of millions of illegal telemarketing calls, including robocalls 

and spoofed calls that displayed “911” as the caller ID. See FTC v. Alcazar Networks Inc., et al., 

No. 6:20-cv-2200 (M.D. Fla. Dec. 3, 2020).8 As part of their settlement with the FTC in January 

2021, the defendants agreed to a permanent injunction that prohibits similar misconduct in the 

future and requires them to screen and monitor their customers, as well as imposing a monetary 

penalty.9 

The FTC has business educational materials that can assist you in complying with the 

TSR. See https://www.ftc.gov/tips-advice/business-center/guidance/complying-telemarketingsales-rule. 

In addition to FTC regulations and the FTC’s actions against providers of VoIP services, 

you should also be aware that the United States Department of Justice (DOJ), state attorneys 

general, and other agencies have brought civil actions against VoIP companies and their owners. 

In two cases, DOJ alleged that the defendants were committing and conspiring to commit wire 

fraud by knowingly transmitting robocalls that impersonated federal government agencies.10 In 

August 2020, a federal district court entered a permanent court order barring the defendants from 

conveying telephone calls into the U.S. telephone system.11 State cases have had similar 

impacts.12 

6 A copy of the FTC’s Amended Complaint is attached as Attachment C. 

7 See https://www.ftc.gov/news-events/press-releases/2020/09/globex-telecom-associates-willpay-21-million-settling-ftcs-first. 8

 A copy of the FTC’s Complaint is attached as Attachment D.

9 See https://www.ftc.gov/news-events/press-releases/2020/12/ftc-takes-action-against-secondvoip-service-provider. 10 See https://www.justice.gov/opa/pr/department-justice-files-actions-stop-telecom-carrierswho-facilitated-hundreds-millions. 11 See https://www.justice.gov/opa/pr/district-court-enters-permanent-injunction-shutting-downtelecom-carriers-who-facilitated. 12 For example, the Vermont and Michigan Attorneys General have brought successful actions 

against VoIP providers who route scam robocall traffic. See 

https://ago.vermont.gov/blog/2022/08/02/vermont-joins-nationwide-anti-robocall-task-force; 

3 
Within three business days, please send a message to FTC attorneys Fil Maria de Banate 

and Christian M. Capece, via electronic mail at fdebanate@ftc.gov and ccapece@ftc.gov, 

certifying that Telcast Network LLC has ceased engaging in the activities described above that 

may subject it to liability under the TSR or the FTC Act. Please direct any inquiries regarding 

this letter to Mr. de Banate and Mr. Capece by email or by telephone at 216.263.3413 or 

216.263.3419. 

Sincerely, 

JONATHA Digitally signed by

JONATHAN STEIGER 

N STEIGER Date: 2023.03.17

___________________ 15:42:12 -04'00' 

Jon Miller Steiger 

Director 

Enclosures: 

Attachment A (Chart of illegal robocalls) 

Attachment B (TSR) 

Attachment C (Educare Amended Complaint) 

Attachment D (Alcazar Complaint) 

https://www.michigan.gov/ag/news/press-releases/2020/08/07/ag-nessel-announces-settlementeliminating-telecom-carrier-responsible-for-illegal-robocalls; 

https://www.michigan.gov/documents/ag/Assurance_of_Voluntary_Compliance_-

_All_Access_Telecom_FINAL_9-11-20_702047_7.pdf. 

4 
ATTACHMENT A 
Date of ITG 

Notification Date of Call Caller ID Robocall Campaign Identifier Link to Robocall Recording 

8/24/2022 8/22/2022 6465687381 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/publ

ttachments/1006872 

11/16/2021 11/11/2021 9403498115 AutoWarrantyExtend https://portal2.tracebacks.org/api/publ

ttachments/560748 

11/16/2021 11/11/2021 5419377770 AutoWarrantyExtend https://portal2.tracebacks.org/api/publ

ttachments/560754 

9/19/2021 9/13/2021 8453860945 Solar-EnergyAdvocates https://portal2.tracebacks.org/api/publ

ttachments/447377 

9/17/2021 9/13/2021 5752169376 Solar-EnergyAdvocates https://portal2.tracebacks.org/api/publ

ttachments/447375 

3/13/2021 3/11/2021 6015944925 SSA-P1-TexasFraud (GovtImpers) https://portal2.tracebacks.org/api/publ

ttachments/66151 

3/11/2021 3/9/2021 2527134705 AutoWarranty-ExtendOrReinst https://portal2.tracebacks.org/api/publ

ttachments/65173 

3/10/2021 3/9/2021 9144606078 AutoWarranty-ExtendOrReinst https://portal2.tracebacks.org/api/publ

ttachments/65171 

3/5/2021 3/4/2021 3474737164 AutoWarranty-ExtendOrReinst https://portal2.tracebacks.org/api/publ

ttachments/64023