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Case 3:23-cv-00313-BAS-KSC Document 1 Filed 02/16/23 PageID.1 Page 1 of 33 

BRIAN M. BOYNTON 

Principal Deputy Assistant Attorney General, Civil Division 

AMANDA N. LISKAMM 

Director, Consumer Protection Branch 

LISA K. HSIAO 

Assistant Director 

DANIEL K. CRANE-HIRSCH (MA Bar No. 643302; NY Bar No. 4151015) 

Senior Trial Attorney 

MATTHEW A. ROBINSON (DC Bar No. 1780280) 

ZACHARY A. DIETERT (DC Bar No. 1003784) 

Trial Attorneys 

Consumer Protection Branch 

Civil Division, U.S. Department of Justice 

450 5th Street, NW, Suite 6400-South 

Washington, DC 20044-0386 

Telephone: (202) 305-4342 (Robinson) 

(202) 616-9027 (Dietert) 

(202) 646-8242 (Crane-Hirsch) 

Attorneys for Plaintiff United States of America 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF CALIFORNIA 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

STRATICS NETWORKS INC., A 

CORPORATION, 

NETLATITUDE, INC., A 

CORPORATION, 

KURT HANNIGAN, INDIVIDUALLY 

AND AS AN OFFICER AND OWNER 

Case No.: 

COMPLAINT FOR PERMANENT 

INJUNCTION, MONETARY 

RELIEF, CIVIL PENALTIES, AND 

OTHER RELIEF 

DEMAND FOR JURY TRIAL 

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Case 3:23-cv-00313-BAS-KSC Document 1 Filed 02/16/23 PageID.2 Page 2 of 33 

OF NETLATITUDE, INC., 

ATLAS MARKETING PARTNERS, 

INC., A CORPORATION, 

ATLAS INVESTMENT VENTURES 

LLC, A LIMITED LIABILITY 

COMPANY, 

KASM, A CORPORATION, ALSO 

D/B/A KASM, INC., 

TEK VENTURES, LLC, A LIMITED 

LIABILITY COMPANY, ALSO D/B/A 

PROVIDENT SOLUTIONS, 

ACE BUSINESS SOLUTIONS LLC, A 

CORPORATION, 

ERIC PETERSEN, INDIVIDUALLY 

AND AS AN OFFICER AND OWNER 

OF ATLAS MARKETING PARTNERS, 

INC., ATLAS INVESTMENT 

VENTURES LLC, AND TEK 

VENTURES, LLC, 

TODD DIROBERTO, INDIVIDUALLY 

AND AS AN OFFICER AND OWNER 

OF ATLAS MARKETING PARTNERS, 

INC., ATLAS INVESTMENT 

VENTURES LLC, AND TEK 

VENTURES, LLC, 

KENAN AZZEH, INDIVIDUALLY 

AND AS AN OFFICER AND OWNER 

OF KASM, AND 

SANDRA BARNES, INDIVIDUALLY 

AND AS AN OFFICER AND OWNER 

OF ACE BUSINESS SOLUTIONS LLC, 

Defendants. 

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Case 3:23-cv-00313-BAS-KSC Document 1 Filed 02/16/23 PageID.3 Page 3 of 33 

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

to the Attorney General by the Federal Trade Commission (“FTC” or “Commission”), 

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), 16(a), and 

19 of the FTC Act, 15 U.S.C. §§ 45(a), 45(m)(1)(A), 53(b), 56(a), and 57b, and Section 6 

of the Telemarketing and Consumer Fraud and Abuse Prevention Act (“Telemarketing 

Act”), 15 U.S.C. § 6105, for permanent injunctive relief, monetary relief, civil penalties, 

and other relief for Defendants’ 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. Part 310. 

SUMMARY OF CASE 

2. Defendants Stratics Networks Inc. (“Stratics Networks”) and Netlatitude, 

Inc. (“Netlatitude”) provided and implemented technology to initiate outbound robocalls 

to consumers’ phones to illegally telemarket various goods and services, including other 

Defendants’ debt relief services. 

3. These marketing schemes bombarded consumers with tens of millions of 

“ringless voicemails.” A ringless voicemail is a prerecorded message delivered to 

consumers by calling their phone numbers in a way that typically does not cause their 

phones to ring. 

4. Several of the Defendants in this case have violated or assisted violations of 

various provisions of the TSR by placing or facilitating robocalls—including calls 

delivering ringless voicemails—that use prerecorded messages to induce purchases from 

consumers who have not agreed receive such messages, that are placed to phone numbers 

listed on the National Do Not Call Registry, and that fail to promptly and truthfully 

disclose the sellers’ identities. Some of the Defendants have also violated both the TSR 

and Section 5 of the FTC Act by misrepresenting material aspects of their debt relief 

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Case 3:23-cv-00313-BAS-KSC Document 1 Filed 02/16/23 PageID.4 Page 4 of 33 

services and have violated the TSR by requesting and receiving consumers’ payments for 

debt relief services before those consumers’ debts have been reduced or renegotiated. 

5. To stop and prevent the recurrence of these violations, including the 

unlawful conduct that clutters consumers’ voicemail boxes with unwanted and deceptive 

marketing pitches, the United States seeks injunctive, monetary, and other relief and civil 

penalties. 

JURISDICTION AND VENUE 

6. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 

1337(a), and 1345, and 1355, and 15 U.S.C. § 53(b). This action arises under 15 U.S.C. § 

45(a). 

7. Venue is proper in this district under 28 U.S.C. § 1391(b)(1), (b)(2), (b)(3), 

(c)(1), (c)(2), (c)(3), and (d), and 15 U.S.C. § 53(b). 

DEFENDANTS 

8. Stratics Networks Inc. (“Stratics Networks”) is a Canadian corporation 

with a registered office address of 762 Upper James Street, Suite 287, Hamilton ON L9C 

3A2. Stratics Networks is owned by Josh Justice and is an international provider of mass 

telecommunication services, which have included ringless voicemail (RVM) platform 

service, wholesale Session Initiation Protocol (SIP) termination (outbound calling using 

Voice Over Internet Protocol (VoIP) technology) services, outbound interactive voice 

response (IVR), voice broadcasting, SMS texting, call center software, and various 

telephony devices used in the lead generation industry. Stratics Networks, in connection 

with the matters alleged herein, transacts or has transacted business in this district and 

throughout the United States. At all times relevant to this Complaint, acting alone or in 

concert with others, Stratics Networks has assisted and facilitated the initiation of 

outbound telephone calls to consumers in this district and throughout the United States to 

induce them to purchase goods and services. 

9. Netlatitude, Inc. (“Netlatitude”) is a Texas corporation with a registered 

office located at 11917 Knippwood Lane in Houston, Texas 77024. Netlatitude is a 

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Case 3:23-cv-00313-BAS-KSC Document 1 Filed 02/16/23 PageID.5 Page 5 of 33 

telecommunications services company offering, among other things, VoIP services, 

including ringless voicemail and wholesale SIP termination. Netlatitude, in connection 

with the matter alleged herein, routes and transmits outbound telephone calls for lead 

generation telemarketing robocall campaigns related to debt relief services. Also in 

connection with the matters alleged herein, Netlatitude transacts or has transacted 

business in this district and throughout the United States. At all times relevant to this 

Complaint, acting alone or in concert with others, Netlatitude has assisted and facilitated 

the initiation of outbound telephone calls to induce consumers to purchase debt relief 

services. 

10. Kurt S. Hannigan (“Hannigan”) is the President of Netlatitude and a 

resident of Texas. Hannigan established Netlatitude’s wholesale SIP termination services 

account with Stratics Networks and served as its point of contact for billing and account 

inquiries. Hannigan, in connection with the matters alleged herein, transacts or has 

transacted business in this district and throughout the United States. Also, at all times 

relevant to this Complaint, acting alone or in concert with others, Hannigan has 

formulated, directed, controlled, had the authority to control, or participated in the acts 

and practices of Netlatitude, including the acts or practices set forth in this Complaint. 

Through his direct participation in, and control over, Netlatitude, Hannigan has had 

knowledge of the acts and practices constituting the violations alleged herein, had control 

over them, and directly participated in them. 

11. Tek Ventures, LLC, also doing business as Provident Solutions 

(“Provident Solutions”), is a California limited liability company with its principal place 

of business at 1660 Hotel Circle North, Suite 616, San Diego, California 92108. 

Provident Solutions offers debt relief services to consumers seeking to reduce their credit 

card debts. Provident Solutions, in connection with the matters alleged herein, transacts 

or has transacted business in this district and throughout the United States. 

12. Atlas Marketing Partners, Inc. (“Atlas Marketing”) is a Nevada 

corporation with its principal place of business at 1660 Hotel Circle North, Suite 620, San 

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Case 3:23-cv-00313-BAS-KSC Document 1 Filed 02/16/23 PageID.6 Page 6 of 33 

Diego, California 92108. Atlas Marketing is a marketing company principally engaged in 

lead generation, through outbound telephone calls, including robocalls, to sell debt relief 

services for Provident Solutions. Atlas Marketing is a seller and telemarketer that 

initiated outbound telephone calls to induce consumers to purchase Provident Solutions’ 

debt relief services. Atlas Marketing, in connection with the matters alleged herein, 

transacts or has transacted business in this district and throughout the United States. 

13. Atlas Investment Ventures, LLC (“Atlas Investment”) is a California 

limited liability company with its principal place of business at 1660 Hotel Circle North, 

Suite 620, San Diego, California, 92108. Atlas Investment employed telemarketers that 

received inbound telephone calls from consumers responding to outbound telephone 

calls, including robocalls, to induce consumers to purchase Provident Solutions’ debt 

relief services. Atlas Investment, in connection with the matters alleged herein, transacts 

or has transacted business in this district and throughout the United States. 

14. Eric Petersen (“Petersen”) is a co-owner of Atlas Marketing, Atlas 

Investment, and Provident Solutions. He resides in San Diego, California. Through his 

direct participation in, and control over, Atlas Marketing, Atlas Investment, and 

Provident Solutions, Petersen has had knowledge of the acts and practices constituting 

the violations alleged herein, had control over them, and directly participated in them. 

15. Todd DiRoberto (“DiRoberto”) is a co-owner of Atlas Marketing, Atlas 

Investment, and Provident Solutions. He resides in San Diego, California. Through his 

direct participation in, and control over, Atlas Marketing, Atlas Investment, and 

Provident Solutions, DiRoberto has had knowledge of the acts and practices constituting 

the violations alleged herein, had control over them, and directly participated in them. 

16. Ace Business Solutions LLC (“Ace”) is a Nevada limited liability company 

with its principal place of business at 1911 Ginori Court, Henderson, Nevada 89014. Ace 

is a purported subcontractor for Provident Solutions and provides debt relief services, 

including debt validation letter writing services, and requests, receives, and processes 

payments from Provident Solutions’ customers for debt relief services. Ace, in 

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Case 3:23-cv-00313-BAS-KSC Document 1 Filed 02/16/23 PageID.7 Page 7 of 33 

connection with the matters alleged herein, transacts or has transacted business in this 

district and throughout the United States. 

17. Sandra Barnes (“Barnes”) is the owner and director of Ace. Through her 

direct participation in and control over Ace, Barnes has had knowledge of the acts and 

practices constituting the violations alleged herein, had control over them, and directly 

participated in them. 

18. Kasm, also d/b/a Kasm, Inc., (“Kasm”) is a California corporation with its 

principal place of business at 1106 Second Street, Suite 348, Encinitas, California 92024. 

Kasm conducted marketing and lead generation for debt relief services on behalf of Atlas 

Investment from 2013 to March 2021. Kasm, in connection with the matters alleged 

herein, transacts or has transacted business in this district and throughout the United 

States. 

19. Kenan Azzeh (“Azzeh”) is the owner and director of Kasm. He resides in 

Carlsbad, California. As Kasm’s owner and director, Azzeh provided marketing services 

to Atlas Marketing from early to mid-2013 to March 2021. Through his direct 

participation in, and control over, the marketing practices of Atlas Marketing, Atlas 

Investment, and Provident Solutions, Azzeh has had knowledge of the acts and practices 

constituting the violations alleged herein, had control over them, and directly participated 

in them. 

COMMON ENTERPRISE 

20. Defendants Atlas Marketing, Atlas Investment, and Provident Solutions 

(collectively, “Atlas Defendants”) have operated as a common enterprise while engaging 

in the violations of the TSR alleged herein. The Atlas Defendants have conducted the 

business practices described herein through an interrelated network of companies that 

have common ownership, officers, business locations, and business functions, and that 

have engaged in a common scheme to engage in telemarketing to sell debt relief services. 

Because the Atlas Defendants have operated as a common enterprise, each of them is 

jointly and severally liable for the acts and practices alleged below. At all times relevant 

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Case 3:23-cv-00313-BAS-KSC Document 1 Filed 02/16/23 PageID.8 Page 8 of 33 

to this Complaint, Defendants Petersen and DiRoberto have formulated, directed, 

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

Atlas Defendants that constitute the common enterprise. 

COMMERCE 

21. 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, 15 U.S.C. § 44. 

THE TELEMARKETING SALES RULE AND 

THE NATIONAL DO NOT CALL REGISTRY 

22. 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. §§ 6101-6108. The FTC adopted the original TSR in 1995, extensively amended it 

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

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

call registry, maintained by the FTC (the “National DNC Registry” or “DNC Registry”), 

of consumers who do not wish to receive certain types of telemarketing calls. Consumers 

can register their telephone numbers on the DNC Registry without charge either through 

a toll-free telephone call or online at donotcall.gov. 

24. 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. 

25. 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). 

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Case 3:23-cv-00313-BAS-KSC Document 1 Filed 02/16/23 PageID.9 Page 9 of 33 

26. 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). 

27. 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). 

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

access the DNC Registry online at telemarketing.donotcall.gov to pay any required fees 

and to download the numbers not to call. 

29. 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). 

30. The TSR prohibits sellers and telemarketers from initiating an outbound 

telephone call to numbers on the DNC Registry unless the seller (1) has obtained the 

consumer’s express agreement, in writing, to place such calls, or (2) has an established 

business relationship with that consumer, and the consumer has not stated that he or she 

does not wish to receive such calls. 16 C.F.R. § 310.4(b)(1)(iii)(B). 

31. 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 unless the seller has obtained from the recipient of the call an express 

agreement, in writing, that evidences the willingness of the recipient of the call to receive 

calls that deliver prerecorded messages by or on behalf of a specific seller. The express 

agreement must include the recipient’s telephone number and signature, must be obtained 

after a clear and conspicuous disclosure that the purpose of the agreement is to authorize 

the seller to place prerecorded calls to such person, and must be obtained without 

requiring, directly or indirectly, that the agreement be executed as a condition of 

purchasing any good or service. 16 C.F.R. § 310.4(b)(1)(v). Calls delivering prerecorded 

messages are commonly called “robocalls.” 

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32. The TSR requires telemarketers in an outbound telephone call or internal or 

external upsell to induce the purchase of goods or services 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). 

33. The TSR prohibits sellers and telemarketers from 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). 

34. The TSR prohibits sellers and telemarketers from misrepresenting, directly 

or by implication, any material aspect of any debt relief service, including, but not limited 

to, the amount of money or the percentage of the debt amount that a customer may save 

by using such service and the amount of time necessary to achieve the represented 

results. 16 C.F.R. § 310.3(a)(2)(x). 

35. Under the TSR, a “debt relief service” is any program or service represented, 

directly or by implication, to renegotiate, settle, or in any way alter the terms of payment 

or other terms of the debt between a person and one or more unsecured creditors, 

including, but not limited to, a reduction in the balance, interest rate, or fees owed by a 

person to an unsecured creditor or debt collector. 16 C.F.R. § 310.2(o). 

36. The TSR prohibits sellers and telemarketers from requesting or receiving 

payment of any fee or consideration for any debt relief service until and unless: 

a. The seller or telemarketer has renegotiated, settled, reduced, or otherwise 

altered the terms of at least one debt pursuant to a settlement agreement, 

debt management plan, or other such valid contractual agreement executed 

by the customer; 

b. The customer has made at least one payment pursuant to that settlement 

agreement, debt management plan, or other valid contractual agreement 

between the customer and the creditor or debt collector; and 

c. To the extent that debts enrolled in a service are renegotiated, settled, 

reduced, or otherwise altered individually, the fee or consideration either: 

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Case 3:23-cv-00313-BAS-KSC Document 1 Filed 02/16/23 PageID.11 Page 11 of 33 

i. Bears the same proportional relationship to the total fee for 

renegotiating, settling, reducing, or altering the terms of the entire 

debt balance as the individual debt amount bears to the entire debt 

amount. The individual debt amount and the entire debt amount are 

those owed at the time the debt was enrolled in the service; or 

ii. Is a percentage of the amount saved as a result of the renegotiation, 

settlement, reduction, or alteration. The percentage charged cannot 

change from one individual debt to another. The amount saved is the 

difference between the amount owed at the time the debt was enrolled 

in the service and the amount actually paid to satisfy the debt. 16 

C.F.R. § 310.4(a)(5)(i). 

37. 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). 

38. 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). 

DEFENDANTS’ BUSINESS ACTIVITIES 

Stratics Networks’ Ringless Voicemail (RVM) Platform Service 

39. Stratics Networks offers its customers the use of its ringless voicemail 

(RVM) platform service, which uses phone calls to deliver prerecorded voice messages 

(i.e., robocalls) en masse to consumers, ostensibly without causing the recipient’s phone 

to ring and without giving recipients the opportunity to answer or block the incoming 

prerecorded message. 

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40. Stratics Networks, has advertised online that it is the “U.S. Inventor[] of 

Ringless Voicemail & Unlimited Ringless Voicemail Drops.”1 

41. Despite Stratics Networks’ description of its voicemail technology as 

“ringless,” the delivery of a prerecorded message to cellular telephone subscribers’ 

voicemail box may trigger an audible and visual notification that alerts recipients that 

they have new voicemails. In fact, Stratics Networks stated in its own terms of service 

that RVMs “may in some circumstances make a partial ring or line ‘tap’ or ‘ping’ on a 

recipient’s phone.” 

42. Stratics Networks’ RVM platform enables customers to upload prerecorded 

messages, lists of recipients’ cell phone numbers, and caller IDs to transmit along with 

each prerecorded message. 

43. Stratics Networks has access to the prerecorded messages its customers 

upload to its RVM platform and reserves the right to audit its customers’ accounts in its 

terms and conditions of service, but it does not conduct due diligence to ensure that the 

messages actually identified the seller or caller, or to prohibit the transmission of 

prerecorded messages that failed to do so, or to ensure that that the call recipient had 

given express consent to receive the call. 

44. Stratics Networks’ RVM platform also allowed, but did not require, its 

customers to scrub lists of uploaded cell phone numbers against the National DNC 

Registry and state do-not-call lists. 

45. Stratics Networks maintained and/or generated transmission records for its 

customers. These transmission records include the customer’s calling number (caller ID), 

the recipient’s cell phone number, the duration of the call, the date and time of the 

delivery, and the disposition (i.e., that the prerecorded message reached the consumer’s 

voicemail inbox). 

1 See https://www.linkedin.com/company/stratics-networks (accessed Jan. 29, 2022). 

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Stratics Networks’ Wholesale SIP Termination Service 

46. Stratics Networks’ wholesale SIP termination (outbound calling) service 

routed and transmitted outbound telephone calls, including robocalls, to a recipient’s 

telephone number, and it provided its customers, including upstream voice service 

providers and/or end-users, with the ability to route and transmit such calls. 

47. Since at least 2013, Stratics Networks resold wholesale SIP termination 

service to other voice service providers, including Defendant Netlatitude and other 

providers that have delivered unlawful robocalls. 

48. Stratics Networks claims to have terminated its provision of wholesale SIP 

termination service in December 2020. 

Stratics Networks’ RVM Customers Operated Robocall Campaigns in Violation of 

the TSR 

49. Many of Stratics Networks’ RVM customers, including but not limited to 

the Atlas Defendants, (who are discussed in further detail at Paragraphs 59 through 84 

below) are “sellers” and/or “telemarketers” and were engaged in “telemarketing” as those 

terms are defined in the TSR, 16 C.F.R. § 310.2. 

50. Stratics Networks’ RVM customers include sellers and/or telemarketers that 

initiated or caused others to initiate outbound telephone calls delivering a prerecorded 

message to consumers to induce the purchase of goods or services. 

51. Stratics Networks’ RVM customers have engaged in telemarketing by a 

plan, program, or campaign conducted to induce the purchase of goods and services by 

the use of one or more telephones and which involves more than one interstate telephone 

call. 

52. At all times relevant to this Complaint, Stratics Networks’ RVM customers 

have maintained a substantial course of trade or business in the offering for sale of goods 

or services via the telephone, in or affecting commerce, as “commerce” is defined in 

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

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53. Stratics Networks and its RVM customers are responsible for bombarding 

American consumers in this district and throughout the United States with millions of 

illegal robocalls, all delivered utilizing Stratics Networks’ RVM platform service. 

54. These illegal robocalls pitched a variety of consumer goods and services, 

including homebuying services, credit card and student debt relief services, and health 

insurance. Stratics Networks’ RVM customers also utilized Stratics Networks’ RVM 

platform service to deliver robocalls to consumers associated with fake lawsuit scams, 

fraudulent sweepstakes, or cable television discount offers. 

55. In numerous instances, when these outbound telephone calls delivered 

prerecorded messages offering goods or services, Stratics Networks’ RVM customers did 

not have a signed, express agreement, in writing, that evidences the willingness of the 

recipient of the call to receive calls that deliver prerecorded messages by or on behalf of 

the seller whose goods or services were being offered. Stratics Networks’ RVM 

customers nevertheless initiated these robocalls to consumers residing in this district and 

throughout the United States. 

56. Despite acknowledging in its terms and conditions of service that its 

customers must “obtain the prior written consent from each recipient to contact such 

recipient” “[w]here required by applicable law or regulation,” Stratics Networks did not 

have evidence of such consent and did not request or require that its customers submit 

such evidence. 

57. In the course of the telemarketing robocall campaigns described above, 

Stratics Networks’ RVM customers also initiated or caused the initiation of millions of 

outbound telephone calls to numbers that had been on the DNC Registry for more than 31 

days. In numerous instances, Stratics Networks and its RVM customers did not scrub the 

lists of uploaded recipient phone numbers against the DNC Registry, or make sure they 

were scrubbed before they were uploaded onto the RVM platform. In numerous 

instances, at the time of these calls, Stratics Networks’ RVM customers also did not have 

a written agreement from consumers on the DNC Registry to receive such calls; nor did 

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they have a pre-existing or established business relationship with them. Stratics Networks 

and its RVM customers nevertheless initiated these calls to consumers residing in this 

district and throughout the United States. 

58. In the course of the telemarketing robocall campaigns described above, in 

numerous, if not all, instances, Stratics Networks’ RVM customers failed to disclose to 

consumers, truthfully, promptly, and in a clear and conspicuous manner, the identity of 

the seller of the goods or services. 

The Atlas Defendants’ Telemarketing Campaign Violated the TSR 

The Atlas Defendants’ Ringless Voicemail Operation 

59. Among the robocalls delivered via Stratics Networks’ RVM platform were 

millions of calls marketing the Atlas Defendants’ debt relief services. 

60. The Atlas Defendants are “sellers” and “telemarketers” of “debt relief 

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

61. The Atlas Defendants are sellers and telemarketers that initiated or caused 

the initiation of outbound telephone calls, including calls delivering prerecorded 

messages to consumers in the United States to induce the purchase of credit card debt 

relief services, and that received inbound calls from consumers. 

62. The Atlas Defendants have engaged in telemarketing by a plan, program, or 

campaign conducted to induce the purchase of credit card debt relief services by the use 

of one or more telephones and which involves more than one interstate telephone call. 

63. Since at least January 2019, the Atlas Defendants have maintained a 

substantial course of trade or business in the offering for sale of goods or services via the 

telephone, in or affecting commerce, as “commerce” is defined in Section 4 of the FTC 

Act, 15 U.S.C. § 44. 

64. In 2013, the Atlas Defendants hired Azzeh, doing business under his own 

company—Kasm—to provide marketing services. Azzeh conducted lead generation for 

the Atlas Defendants, including by managing direct mail campaigns, purchasing live 

transfers, and delivering ringless voicemails. Azzeh continued to work for the Atlas 

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Defendants until April 30, 2021. During this time, Azzeh and Kasm were “telemarketers” 

on behalf of the Atlas Defendants and initiated millions of outbound telephone calls 

delivering prerecorded messages to consumers to induce the purchase of the Atlas 

Defendants’ debt relief services. 

65. Between at least September 2019, and November 2020, Azzeh purchased 

access to Stratics Networks’ RVM platform service to place lead generation robocalls 

pitching the Atlas Defendants’ credit card debt relief services. 

66. Many of the Atlas Defendants’ robocalls represented to consumers that they 

are following up on a previous “offer” or “notice” for a plan to “resolve [the consumer’s] 

credit card debt in 24 months with affordable repayment options.” For example, 

consumers received the following robocall, or a substantially similar version, which 

Azzeh delivered on behalf of the Atlas Defendants using Stratics Networks’ RVM 

platform service: 

Hi, this is Sara. I’m following up on an offer we sent regarding your 

eligibility for our new 2020 debt relief program. This program has 

affordable repayment options and, in most cases, can have you out of credit 

card debt in 24 months or less. You can reach me at 855-914-2203. Again 

that’s 855-914-2203. 

67. The outbound calls delivering prerecorded messages to induce the purchase 

of debt relief services include more than 23 million such calls that Atlas Marketing 

initiated or caused the initiation of using Stratics Networks’ RVM platform service 

between August 17 and November 20, 2020. 

68. Azzeh, Petersen, and an Atlas Investment employee drafted scripts for the 

Atlas Defendants’ prerecorded messages. Azzeh’s wife, Krista Azzeh, recorded the 

messages. Azzeh then uploaded audio files of the prerecorded messages and lists of 

consumers’ cellular telephone numbers onto Stratics Networks’ RVM platform. 

69. In numerous, if not all, instances, at the time these outbound telephone calls 

delivered prerecorded messages offering debt relief services, the Atlas Defendants did not 

have a signed, express agreement, in writing, that evidenced the willingness of the 

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recipient of the call to receive calls that deliver prerecorded messages by or on behalf of 

the Atlas Defendants. The Atlas Defendants did not obtain prior express written consent 

from consumers to deliver prerecorded messages to them. Nonetheless, Azzeh used 

Stratics Networks’ RVM platform, on behalf of the Atlas Defendants, to deliver 

prerecorded messages to consumers residing in this district and throughout the United 

States. 

70. In addition, the Atlas Defendants’ prerecorded messages failed to disclose to 

consumers, truthfully, promptly, and in a clear and conspicuous manner, the identity of 

the seller of the debt relief service. 

The Atlas Defendants’ Debt Relief Services Program 

71. In numerous instances, consumers that called back the Atlas Defendants 

after receiving a ringless voicemail were connected to live telemarketers, employed by 

Atlas Investment, who once again failed to disclose to consumers, truthfully, promptly, 

and in a clear and conspicuous manner, the identity of the seller of the debt relief service. 

Instead, Atlas Investment’s live telemarketers routinely identified themselves as 

representatives of “Consumer Services.” 

72. Atlas Investment’s telemarketers used the name “Consumer Services” as a 

buffer to avoid revealing and tainting the actual business. 

73. Consumers who signed up for the Atlas Defendants’ debt relief service were 

told the company’s name was “Provident Solutions.” 

74. Atlas Investment’s live telemarketers typically interviewed interested 

consumers about their credit card debt to determine how much they could afford to pay 

for debt relief services each month, and then transferred interested consumers to more 

senior agents to register consumers for the debt relief program. Atlas Investment’s live 

telemarketers also instructed consumers to provide their personal information, such as 

bank account and routing numbers, so that Atlas Defendants could collect payment from 

consumers for the debt relief service. 

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75. In numerous instances, consumers were subsequently transferred (or called 

at a later time) for quality control calls, wherein another live telemarketer verified the 

consumer’s banking information, payment amount, and draft date. The quality control 

calls were conducted by Ace employees. 

76. In numerous instances, Atlas Investment’s live telemarketers represented to 

consumers that some of their monthly payment would be used to pay the consumer’s 

debts. 

77. During the quality control calls, however, Ace typically asked consumers to 

affirm that they understood the monthly payments were for the Atlas Defendants’ fees 

only. In numerous instances, the discrepancy between the representations made during 

the sales pitch and quality control calls led to consumer confusion. 

78. The Atlas Defendants purportedly subcontracted the debt relief service 

program to Barnes and her company, Ace. Barnes and Ace were “sellers” that, in 

connection with the Atlas Defendants’ telemarketing, provided debt validation letter 

writing services to consumers in exchange for consideration. Barnes and Ace were also 

“telemarketers” that, in connection with telemarketing, initiated or received telephone 

calls to or from customers. 

79. The Atlas Defendants’ debt relief services, carried out by Ace, consisted of a 

series of debt validation letters sent by Ace to consumers’ creditors challenging the 

validity of the consumers’ debt, regardless of whether the consumers believed the debt 

was, in fact, invalid. 

80. In numerous instances, Ace requested and received monthly bank 

withdrawals from consumers approximately 30 days after the consumers enrolled in the 

Atlas Defendants’ debt relief services program, regardless of whether Ace had sent a debt 

validation letter for the consumers at that time. Frequently, no debt validation letter had 

been sent at that time. After Ace received consumers’ payments, it distributed a 

percentage of the fees back to the Atlas Defendants. 

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81. Thus, in numerous instances, Ace and the Atlas Defendants received fees 

they caused to be drawn from consumers’ bank accounts within 30 days of their 

enrollment in the debt relief program, but before Ace had undertaken any efforts to 

renegotiate, settle, reduce, or otherwise alter the terms of at least one debt pursuant to a 

settlement agreement, debt management plan, or any other valid contractual agreement 

executed by the customer. In numerous instances, Ace and the Atlas Defendants 

continued to receive monthly fees from consumers for many months despite never 

renegotiating, settling, reducing, or otherwise altering the terms of the consumer’s debt. 

82. In numerous instances, the Atlas Defendants charged consumers between 

$6,000 and $8,000 for multiple debt validation letters over 36 to 48 months, despite the 

representations in Atlas Marketing’s ringless voicemail messages that “in most cases” its 

debt relief program “can have [consumers] out of credit card debt in 24 months or less.” 

The Atlas Defendants knew from experience that most consumers would not be out of 

credit card debt within 24 months or less, and Petersen has admitted as much in an FTC 

investigational hearing. 

83. Most of the Atlas Defendants’ customers did not complete the program, and 

many filed for bankruptcy. 

84. The Atlas Defendants, Petersen, DiRoberto, Ace, and Barnes have received 

or reviewed consumer complaints and correspondence that allege violations of federal 

telemarketing regulations and that consumers have been misled by telemarketers’ 

representations. The Atlas Defendants, Petersen, DiRoberto, Ace, and Barnes knew or 

had knowledge fairly implied on the basis of objective circumstances that their activities 

were covered by the TSR and violated it, as demonstrated by, among other things, their 

receipt of such complaints; their engagement of and interactions with telemarketing 

compliance legal counsel; DiRoberto’s involvement in prior TSR enforcement litigation, 

including United States v. Dish Network, LLC, No. 09-3073 (C.D. Ill.); and Petersen’s 

FTC investigational hearing testimony concerning these defendants’ debt relief services, 

billing practices, and representations to consumers. 

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Stratics Networks Knew or Consciously Avoided Knowing it Was Assisting and 

Facilitating its RVM Customers’ TSR Violations 

85. Stratics Networks has provided substantial assistance or support to 

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

86. Stratics Networks provided substantial assistance and support to its RVM 

customers, including Atlas Marketing, by, among other things, providing them with the 

means to initiate outbound telephone calls that deliver a prerecorded message to induce 

the purchase of goods or services in this district and throughout the United States via its 

RVM platform service. 

87. By July 2017, if not earlier, Stratics was aware of the FTC’s enforcement of 

the TSR, particularly with respect to ringless voicemails, and thus knew or should have 

known that between 2018 and 2020, the FTC filed and publicized a case against, 

settlement with, and court judgment against defendants that violated the TSR through 

illegal robocall campaigns that delivered ringless voicemails. Stratics Networks thus had 

knowledge or knowledge fairly implied that ringless voicemails are covered by the TSR. 

88. Stratics Networks had direct knowledge of, and the right to control, the 

robocalls alleged herein that utilized its RVM service, as the prerecorded messages are 

delivered only after audio files of the prerecorded messages are uploaded and stored on 

Stratics Networks’ RVM platform. Further, Stratics Networks permitted and enabled its 

RVM customers, including Atlas Marketing, to deliver millions of prerecorded messages 

without requiring and ensuring that they obtain prior express written consent from 

recipients, scrub lists of uploaded phone numbers against the DNC Registry, or otherwise 

comply with the TSR. 

89. Stratics Networks created transmission records of the prerecorded messages 

delivered via its RVM platform, which included, among other things, the recipients’ 

phone numbers, call duration, date and time. 

90. Since at least September 2019, Stratics Networks knew or consciously 

avoided knowing that its RVM customers were violating the TSR in their telemarketing 

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robocall campaigns to induce the purchase of goods or services. Stratics Networks knew 

or consciously avoiding knowing that, among other things, its RVM customers initiated 

outbound telephone calls: 

a. that delivered prerecorded messages offering goods or services, without 

having a signed, express agreement, in writing, that evidences the 

willingness of the recipient of the call to receive calls that deliver 

prerecorded messages by or on behalf of the seller whose goods or services 

were being offered; 

b. to numbers listed on the National DNC Registry to induce the purchase of 

goods or services, without having a written agreement from consumers to 

receive such calls or a pre-existing or established business relationship with 

them; 

c. that failed to disclose the identity of the seller of goods or services truthfully, 

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

call. 

Traceback Requests Regarding RVM Customers’ Robocall Campaigns 

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

Communications Commission (FCC)-designated consortium of telephone and broadband 

industry companies working to determine the sources of and stop illegal robocalls, 

repeatedly alerted Stratics Networks to likely illegal robocalls delivered using its RVM 

platform. 

92. USTelecom’s ITG sends emails to voice service providers seeking assistance 

with identifying the source of suspicious traffic, and it refers to these emails as 

“Traceback Requests.” 

93. USTelecom’s ITG defines a “Traceback” as follows: 

A network-based process that seeks out the source of Suspicious Traffic. 

Beginning at a terminating Voice Service Provider, a call is systematically 

traced from one Voice Service Provider to the preceding Voice Service 

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Provider networks until a Non-Cooperative Voice Service Provider and/or 

the originating Voice Service Provider or originating customer is identified. 

94. USTelecom’s ITG identifies as “Suspicious Traffic” “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 (including, but not limited to, 

lack of header information, volumetric anomalies, calling or called party information 

modification, complaints received from called parties, law enforcement, third-party 

aggregators, or call transcripts).” 

95. Stratics Networks received numerous Traceback Requests from 

USTelecom’s ITG alerting it to suspected illegal robocall traffic delivered via Stratics 

Networks’ RVM platform service and seeking its assistance in identifying the source(s) 

(i.e., upstream carrier or originating end-user) of these “likely illegal” robocalls, 

including over 30 such requests between August 2019 and February 2021. 

96. These Traceback Requests to Stratics Networks identified likely illegal 

robocalls that were being conducted through Stratics Networks’ RVM platform in 

connection with telemarketing campaigns that related to a variety of topics, including 

homebuying services, credit card and student debt relief services, health insurance, cable 

television discounts, fake lawsuit scams, and fraudulent sweepstakes winner notifications. 

97. The Traceback Requests to Stratics Networks concerned robocall 

telemarketing campaigns conducted over Stratics Networks’ RVM platform by several of 

its RVM customers, including Atlas Marketing, Telecord, Telesero, Health Innovations, 

National Homebuyers, Elite Processing, Deltracon, Technest Limited, Shamoon Ahmad, 

Progressive Promoting, Nitzke Enterprize, Care Advocacy Solutions, and PubClub. 

98. USTelecom’s ITG Traceback Requests to Stratics Networks provided call 

detail records (i.e., the date, time, and called from and called to numbers) for suspicious 

robocall incidents, and they also included additional details describing the characteristics 

of the prerecorded messages associated with abusive, unlawful, or fraudulent practices, 

including notes in some of the Traceback Requests that the calls had prerecorded 

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messages, did not identify the calling party, were placed to numbers on the National Do 

Not Call Registry, were “likely FRAUD,” or involved attempts to extort money from 

consumers. 

99. USTelecom’s ITG Traceback Requests gave Stratics Networks access to 

audio recordings of the prerecorded messages at issue to assist it in identifying the 

robocalls’ source. Stratics Networks also had access to the prerecorded audio messages 

its customers uploaded to its RVM platform, which it had the right to audit pursuant to its 

terms and conditions of service. The audio recordings demonstrated that prerecorded 

messages delivered via Stratics Networks’ RVM platform failed to disclose to consumers, 

truthfully, promptly, and in a clear and conspicuous manner, the identity of the seller of 

goods or services. 

100. Despite USTelecom’s requests that Stratics Networks provide the identity of 

the end-user responsible for the suspected illegal robocalls identified in the Traceback 

Requests, in several instances, Stratics Networks failed to do so. 

101. In some instances, even when Stratics Networks did identify the RVM 

customers responsible for these illegal robocalls, Stratics Networks allowed these RVM 

customers to open additional accounts and/or continue utilizing its RVM platform service 

for several weeks or months without suspending or terminating their RVM accounts. 

102. In some instances, Stratics Networks did not suspend these RVM customers’ 

accounts until after it received a civil investigative demand from the FTC in November 

2020 inquiring about prerecorded messages delivered using its RVM platform service. 

103. Notwithstanding the foregoing Traceback Requests, Stratics Networks 

continued to permit its RVM customers to utilize its RVM platform service to deliver 

prerecorded messages offering goods and services without requiring and verifying that 

any of the RVM customers had obtained prior express written consent from recipients or 

that the prerecorded messages disclose the identity of the seller of goods or services. 

Stratics Networks also continued to allow its RVM customers to turn off features in the 

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RVM platform that could prevent the delivery of prerecorded messages to numbers on 

the DNC Registry. 

104. Several of US Telecom’s ITG’s Traceback Requests to Stratics Networks 

concerned robocalls delivered over Stratics Networks’ RVM platform as part of the Atlas 

Defendants’ debt relief telemarketing campaign, including Traceback Requests Stratics 

Networks received between April and June 2020. These Traceback Requests indicated 

that they concerned a “DebtReduction-Hardship” or “DebtReduction-CoronaHardship” 

campaign, and they noted that the robocalls delivered prerecorded messages offering preapproved loans and did not identify the caller. 

105. Notwithstanding Stratics Networks’ representation to US Telecom’s ITG in 

response to a April 29, 2020 traceback request that it “ha[d] taken immediate action and 

triggered a full investigation” into the Traceback Request and “also suspended traffic,” 

Stratics Networks permitted Atlas Marketing to continue using its RVM platform service 

to deliver millions more robocalls for over five more months. 

106. Accordingly, by no later than on or about April 29, 2020, Stratics Networks 

knew or consciously avoided knowing that Atlas Marketing utilized its RVM platform 

service to deliver prerecorded messages offering debt relief services without requiring it 

to obtain prior express written consent from recipients or disclose the identity of the seller 

of the debt relief services. 

107. After April 29, 2020, Stratics Networks permitted Atlas Marketing to use its 

RVM service to deliver more than 23 million additional ringless voicemail robocalls to 

American consumers. 

108. On October 26, 2020, the FTC issued a CID to The Stratics Group, Inc. 

d/b/a/ Stratics Networks Inc. requesting, inter alia, information concerning certain 

wholesale SIP termination and RVM customers that had originated, initiated, or routed 

telephone calls using Stratics Networks’ services. The CID stated that the purpose of its 

investigation was to determine, among other things, whether persons or entities initiated, 

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caused the initiation of, or assisted the initiation of outbound telephone calls that violated 

the TSR. Stratics Networks acknowledged the CID on November 5, 2020. 

109. As described above, even after Stratics Networks acknowledged the FTC’s 

CID, it continued to provide RVM platform service to telemarketers that placed outbound 

telephone calls that delivered prerecorded messages (i.e., robocalls) to induce the 

purchase of goods or services in violation of the TSR. 

Netlatitude’s Customers Operated Telemarketing Campaigns in Violation of the 

TSR 

110. Between at least June 2015 and September 2020, Netlatitude purchased 

access to Stratics Networks’ wholesale SIP termination (outbound calling) service to 

route and transmit robocalls, including lead-generation robocalls pitching debt relief 

services and COVID-19 pandemic-related rebate and cash incentive programs. 

111. Netlatitude also routed and transmitted lead generation robocalls utilizing 

SIP termination (outbound calling) service not provided by Stratics Networks. For 

example, in April 2020, Netlatitude routed such calls using SIP termination service from 

Alcazar Networks, Inc., a nationwide provider of interconnected VoIP services that the 

FTC later sued for assisting and facilitating tens of millions of illegal telemarketing 

robocalls. See FTC v. Alcazar Networks, et al., No. 6:20-cv-02200 (M.D. Fla. filed Dec. 

3, 2020). 

112. Many of these outbound telephone calls that Netlatitude routed and 

transmitted between January 2020 and April 2021 were on behalf of its customer Fortress 

Leads S De Rl De Cv (“Fortress Leads”), which operated lead generation ringless 

voicemail robocall campaigns originating outside of the United States. Netlatitude served 

as the U.S. Point of Entry (i.e., first voice service provider within a call’s path to transmit 

an illegal robocall from a foreign voice service provider and place the call on the U.S. 

public switched telephone network) for these robocall campaigns. 

113. Netlatitude’s customers, including Fortress Leads, were “telemarketers” 

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

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114. Many of the ringless voicemail robocalls routed and transmitted by 

Netlatitude through Stratics Networks’ SIP termination network told consumers that they 

were qualified or pre-approved for programs that would lower or eliminate their loan 

payments or balances. For example, on April 9, 2020, Netlatitude routed and transmitted 

a telemarketing robocall via Stratics Networks’ SIP termination network that stated the 

following: 

Hey, it’s Kyla with processing. I was just calling to let you know that we do have 

your pre-approved amount for the hardship program. Um...it is up to $55,000, so 

just give me a call and we can go over the details. My number is 877-224-

0244...and you can speak to me or any one of the representatives. Just in the case, 

the number again is 877-224-0244. I look forward to hearing from you and have a 

great day. 

115. Many calls that Netlatitude routed and transmitted, including through 

Stratics Networks’ SIP termination network, delivered unlawful prerecorded messages to 

induce the purchase of goods or services and failed to disclose the identity of the seller, in 

violation of the TSR. This was true, for example, of most, if not all, of more than 

136,000 robocalls Netlatitude routed and transmitted to consumers using Stratics 

Networks’ SIP termination service on just two days in September 2020. 

116. Many of the calls that Netlatitude routed, and transmitted, including through 

Stratics Networks’ SIP termination network, were placed to numbers that had been listed 

on the National Do Not Call Registry for more than 31 days, in violation of the TSR. This 

was true of many of the more than 136,000 robocalls Netlatitude routed and transmitted 

to consumers using Stratics Networks’ SIP termination service on just two days in 

September 2020. 

Stratics Networks and Netlatitude Knew or Consciously Avoided Knowing They 

Were Assisting and Facilitating Netlatitude’s Customers’ TSR Violations 

117. On April 13, 2020, USTelecom’s ITG sent Stratics Networks a Traceback 

Request seeking its assistance in identifying the sources of certain suspected illegal 

robocalls routed through Stratics Networks that the request described as prerecorded 

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messages offering pre-approved loans that did not identify the caller and that were placed 

to numbers on the National Do Not Call Registry. 

118. In response, Stratics Networks informed US Telecom’s ITG on April 16, 

2020, that the calls at issue in the traceback request originated from Netlatitude, and that 

Kurt Hannigan was responsible for them. 

119. Stratics Networks nevertheless continued providing its SIP termination 

service to Netlatitude and enabling Netlatitude to continue routing its customers’ illegal 

robocalls for several additional months, until September 2020. 

120. From April 2020 through September 3, 2020, Stratics Networks received 

eight Traceback Requests concerning suspected illegal robocall traffic it received from 

Netlatitude. Over this time period, Stratics Networks repeatedly identified Netlatitude as 

the source of these calls, but it refused to take appropriate steps to eliminate the illegal 

robocall traffic it received from Netlatitude. Stratics Networks thus knew or consciously 

avoided knowing that Netlatitude was using Stratics Networks’ service to transmit illegal 

robocalls. 

121. USTelecom’s ITG also sent Netlatitude more than a dozen Traceback 

Requests regarding its suspicious traffic, including requests sent between April and July 

2020. In each Traceback Request notification email, the ITG included call details for 

each incident and a description of the associated campaign. 

122. In response to a Traceback Request sent on May 2, 2020, Hannigan 

identified the customer as foreign telemarketer Fortress Leads. On May 5, 2020, 

USTelecom’s ITG responded to Hannigan and asked him and his customer to review and 

comply with applicable US regulations, including general prohibitions and restrictions on 

calls to wireless numbers using a prerecorded voice and requirements that voicemails 

must identify the entity responsible for the call. 

123. On or before May 5, 2020, Netlatitude knew or consciously avoided 

knowing that it was routing and transmitting illegal robocall traffic. Despite receiving 

more than a dozen Traceback Requests from USTelecom’s ITG, Netlatitude refused to 

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take appropriate steps to cease transmitting this traffic. It continued to route and transmit 

numerous robocalls delivering unlawful prerecorded messages without obtaining 

consumers’ prior consent, which failed to identify the seller and which were sent even to 

numbers that were listed on the National Do Not Call Registry. 

124. 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, and that consumers will continue to be injured by those ongoing 

violations, because, among other things, Defendants: (a) have shown a pattern and 

practice of continuing to assist and facilitate violations of the TSR, even after learning of 

the violations; (b) remain active in the telecommunications or debt relief services 

industries and maintain the means, ability, and incentive to resume their unlawful 

conduct; (c) have repeatedly ignored law enforcement agencies’ and trade associations 

warnings about suspected illegal robocall traffic routed across their networks; (d) have 

suspended customers violating telemarketing laws only after repeated warnings from law 

enforcement agencies or trade associations; and/or (e) have failed to fully respond to 

CIDs issued by the Commission. 

VIOLATIONS OF THE FTC ACT 

125. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or 

deceptive acts or practices in or affecting commerce.” 

126. Misrepresentations or deceptive omissions of material fact constitute 

deceptive acts or practices prohibited by Section 5(a) of the FTC Act. 

Count I (The Atlas Defendants, Petersen, DiRoberto, Kasm, Azzeh) 

Misrepresentations Regarding Debt Relief Service 

127. Paragraphs 1 through 126 are incorporated as if set forth fully herein. 

128. In numerous instances, in connection with the advertising, marketing, 

promotion, offering for sale, or sale of a debt relief service, the Atlas Defendants and 

Defendants Petersen, DiRoberto, Kasm, and Azzeh have represented, directly or 

indirectly, expressly or by implication, that: 

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a. Consumers who purchase their debt relief service can be out of credit card 

debt in 24 months or less; and/or 

b. Consumers’ monthly payments for debt relief service would be applied 

toward consumer’s debt. 

129. In truth and in fact, in numerous instances in which the Atlas Defendants 

and Defendants Petersen, DiRoberto, Kasm, and Azzeh have made those representations: 

a. Consumers who purchase their debt relief service are not out of credit card 

debt in 24 months or less; and/or 

b. Consumers’ monthly payments for debt relief service were not applied 

toward consumers debt. 

130. Therefore, the representations of the Atlas Defendants and Defendants 

Petersen, DiRoberto, Kasm, and Azzeh are false or misleading and constitute a deceptive 

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

Count II (Stratics Networks, Netlatitude & Hannigan) 

Assisting and Facilitating Violations of the Telemarketing Sales Rule 

131. Paragraphs 1 through 126 are incorporated as if set forth fully herein. 

132. As set forth above, Defendants Stratics Networks, Netlatitude, and Hannigan 

have, in numerous instances, provided substantial assistance and support, by providing 

RVM platform and/or wholesale SIP termination service to one or more “sellers” and/or 

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

that Stratics Networks, Netlatitude, and Hannigan knew, or consciously avoided 

knowing: 

a. 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); 

b. 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); 

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c. 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); and 

133. Stratics Networks, Netlatitude, and Hannigan’s substantial assistance 

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

Count III (Atlas Defendants, Petersen, DiRoberto, Kasm & Azzeh) 

Initiating Unlawful Prerecorded Messages 

134. Paragraphs 1 through 126 are incorporated as if set forth fully herein. 

135. As set forth above, in numerous instances, in connection with telemarketing, 

Atlas Defendants, Petersen, DiRoberto, Kasm, and Azzeh have engaged in initiating or 

causing the initiation of outbound telephone calls that deliver prerecorded messages to 

induce the sale of debt relief services. 

136. The acts or practices of Atlas Defendants, Petersen, DiRoberto, Kasm, and 

Azzeh are abusive telemarketing acts or practices that violate the TSR, 16 C.F.R. § 

310.4(b)(1)(v)(A). 

Count IV (Atlas Defendants, Petersen, DiRoberto, Kasm & Azzeh) 

Failure to Make Oral Disclosure Required by the TSR 

137. Paragraphs 1 through 126 are incorporated as if set forth fully herein. 

138. As set forth above, in numerous instances since at least September 12, 2019, 

in connection with telemarketing, Atlas Defendants, Petersen, DiRoberto, Kasm, and 

Azzeh have engaged in initiating or causing the initiation of outbound telephone calls that 

failed to disclose the identity of the seller of the debt relief services truthfully, promptly, 

and in a clear and conspicuous manner to the person receiving the call. 

139. The acts or practices of Atlas Defendants, Petersen, DiRoberto, Kasm, and 

Azzeh are abusive telemarketing acts or practices that violate the TSR, 16 C.F.R. § 

310.4(d)(1). 

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Count V (Atlas Defendants, Petersen, DiRoberto, Kasm & Azzeh) 

Misrepresentations of Material Aspects of a Debt Relief Service 

140. Paragraphs 1 through 126 are incorporated as if set forth fully herein. 

141. As set forth above, in numerous instances since September 12, 2019, in 

connection with the telemarketing of a debt relief service, Atlas Defendants, Petersen, 

DiRoberto, Kasm and Azzeh have misrepresented, directly or indirectly, expressly or by 

implication, material aspects of their debt relief service, including that: 

a. Consumers who purchase their debt relief service can be out of credit card 

debt in 24 months or less; and/or 

b. Consumers’ monthly payments for debt relief service would be applied 

toward consumer’s debt. 

142. The acts or practices of Atlas Defendants, Petersen, DiRoberto, Kasm, and 

Azzeh are deceptive telemarketing acts or practices that violate the TSR, 16 C.F.R. § 

310.3(a)(2)(x). 

Count VI (Atlas Defendants, Petersen, DiRoberto, Ace & Barnes) 

Charging or Receiving a Fee in Advance of Providing a Debt Relief Service 

143. Paragraphs 1 through 126 are incorporated as if set forth fully herein. 

144. As set forth above, in numerous instances since September 12, 2019, in 

connection with the telemarketing of a debt relief service, Atlas Defendants, Petersen, 

DiRoberto, Ace, and Barnes have requested or received payment of a fee or consideration 

for a debt relief service before: (a) they have renegotiated, settled, reduced, or otherwise 

altered the terms of at least one debt pursuant to a settlement agreement, debt 

management plan, or other such valid contractual agreement executed by the consumer; 

and (b) the consumer has made at least one payment pursuant to that agreement. 

145. The acts or practices of Atlas Defendants, Petersen, DiRoberto, Ace, and 

Barnes, as set forth above, are abusive telemarketing acts or practices that violate the 

TSR, 16 C.F.R. § 310.4(a)(5)(i). 

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CONSUMER INJURY 

146. Consumers have suffered and will suffer substantial injury as a result of 

Defendants’ violations of the TSR and the FTC Act. Absent injunctive relief by this 

Court, Defendants are likely to continue to injure consumers and harm the public interest. 

THIS COURT’S POWER TO GRANT RELIEF 

147. 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. 

148. 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 

$46,517 for each violation of the TSR assessed after January 10, 2022, including 

penalties whose associated violation predated January 10, 2022, that is made with actual 

knowledge or knowledge fairly implied on the basis of objective circumstances that such 

act is unfair or deceptive and is prohibited by such rule. 

149. Defendants’ 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 this Court: 

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

FTC Act by Defendants; 

B. Award monetary and other relief within the Court’s power to grant; 

C. Award Plaintiff monetary civil penalties for every violation of the 

Telemarketing Sales Rule; and 

D. Award Plaintiff such other and additional relief the Court may determine to 

be just and proper. 

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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. 

Dated: February 16, 2023 

FOR FEDERAL TRADE 

COMMISSION: 

Christopher E. Brown 

Suzanne Barth 

Attorneys 

Federal Trade Commission 

Washington, DC 20580 

(202) 326-2825 (Brown) 

(202) 701-6600 (Barth) 

(202) 326-3395 (fax) 

cbrown3@ftc.gov 

sbarth@ftc.gov 

Respectfully submitted, 

FOR PLAINTIFF 

THE UNITED STATES OF AMERICA: 

BRIAN M. BOYNTON 

Principal Deputy Assistant Attorney General 

AMANDA N. LISKAMM 

Director, Consumer Protection Branch 

LISA K. HSIAO 

Assistant Director 

DANIEL K. CRANE-HIRSCH 

Senior Trial Attorney 

/s Matthew A. Robinson 

MATTHEW A. ROBINSON 

ZACHARY A. DIETERT 

Trial Attorneys 

Civil Division, U.S. Department of Justice 

450 5th Street, NW, Suite 6400-South 

Washington, DC 20044-0386 

Tel.: (202) 305-4342 (Robinson) 

(202) 616-9027 (Dietert) 

(202) 646-8242 (Crane-Hirsch) 

Fax: (202) 514-8742 

Email: Matthew.A.Robinson@usdoj.gov 

Zachary.A.Dietert@usdoj.gov 

Daniel.Crane-Hirsch@usdoj.gov 

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