United States of America

 FEDERAL TRADE COMMISSION 

East Central Region 

1111 Superior Avenue, Suite 200 Jon Miller Steiger

Cleveland, Ohio 44114 Director

(216) 263‐3455

April 4, 2023 

CEASE AND DESIST DEMAND 

VIA EMAIL TO: 

info@incorp.com 

Range, Inc., also d/b/a Range Telecom 

Chris Rubini, CEO 

919 North Market Street 

Suite 950 

Wilmington, DE 19801 

c/o Incorp Services, Registered Agent, 

We have determined that Range, Inc., also d/b/a Range Telecom, is apparently routing 

and transmitting illegal robocall traffic, directly or indirectly, for entities involved in the 

following campaigns: 

 Amazon-AuthorizeOrder 

 Amazon-SuspiciousCharge-P1 

 CreditCard-RateReduction 

 CreditCard-ZeroInterest 

 Debt Reduction Services 

 Discount-Avail50% 

 Hotel-ComplimentaryStay 

 Legal-Enforcement-Notice 

 SSA-CalltheSSA 

 SSA-P1-TexasFraud (GovtImpers) 

 SSA-P2-Impers 

 StudentLoan-FederalSuspension 

 Travel-Brand-Impers 

 Utility-30MinDisconnect 

 Utility-Discount 

More specifically, our investigation revealed that Range Telecom 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 January 8, 2021, and July 7, 2022, ITG 

investigated 45 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 Range Telecom 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 A. Further, 

the numerous traceback notices directed to Range Telecom 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: 

 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)); 

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

(16 C.F.R. § 310.3(a)(2)(vii)); 

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

 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 

 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, 

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).

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

4

 These calls are often referred to as “robocalls.” 

2 
 

 

 

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 

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. 

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. 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. 

3 
 

___________________ 

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 

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 Range Telecom 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, 

Jon Miller Steiger 

Director 

Enclosures: 

Attachment A (Chart of illegal robocalls) 

Attachment B (TSR) 

Attachment C (Educare Amended Complaint) 

Attachment D (Alcazar Complaint) 

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; 

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 

7/7/2022 7/6/2022 6012853780 Amazon-SuspiciousCharge-P1 https://portal2.tracebacks.org/api/pub

attachments/948016 

4/22/2022 4/20/2022 8043770351 Travel-Brand-Impers https://portal2.tracebacks.org/api/pub

attachments/819788 

4/6/2022 4/5/2022 5105887766 SSA-P2-Impers https://portal2.tracebacks.org/api/pub

attachments/797786 

4/6/2022 4/4/2022 9302020008 SSA-P2-Impers https://portal2.tracebacks.org/api/pub

attachments/797787 

3/8/2022 3/4/2022 9254884128 Travel-Brand-Impers https://portal2.tracebacks.org/api/pub

attachments/735557 

2/25/2022 2/21/2022 6628783754 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pub

attachments/707395 

2/22/2022 2/21/2022 5415686319 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pub

attachments/707390 

2/22/2022 2/20/2022 6014142112 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pub

attachments/707393 

2/22/2022 2/21/2022 4432459888 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pub

attachments/707405 

2/22/2022 2/21/2022 7085942375 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pub

attachments/707409 

2/22/2022 2/21/2022 4044916059 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pub

attachments/707413 

2/11/2022 2/8/2022 5412552023 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pub

attachments/683852 

11/8/2021 11/4/2021 4422100660 Hotel-ComplimentaryStay https://portal2.tracebacks.org/api/pub

attachments/552355 

10/29/2021 10/28/2021 6628349161 SSA-P1-TexasFraud (GovtImpers) https://portal2.tracebacks.org/api/pub

attachments/543058 
10/8/2021 10/7/2021 8322190186 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pub

attachments/500505 

10/1/2021 9/30/2021 6612499613 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pub

attachments/487131 

10/1/2021 9/30/2021 3522838791 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pub

attachments/487132 

9/14/2021 9/13/2021 5409157123 Legal-Enforcement-Notice https://portal2.tracebacks.org/api/pub

attachments/447364 

9/7/2021 9/6/2021 4132629840 Legal-Enforcement-Notice https://portal2.tracebacks.org/api/pub

attachments/431173 

9/7/2021 8/31/2021 3026047019 CreditCard-RateReduction https://portal2.tracebacks.org/api/pub

attachments/431193 

9/7/2021 8/31/2021 8436972865 CreditCard-RateReduction https://portal2.tracebacks.org/api/pub

attachments/431198 

9/7/2021 8/31/2021 4193096528 CreditCard-RateReduction https://portal2.tracebacks.org/api/pub

attachments/431203 

9/7/2021 8/30/2021 8045108799 CreditCard-RateReduction https://portal2.tracebacks.org/api/pub

attachments/431210 

8/31/2021 8/28/2021 6317556000 Utility-30MinDisconnect https://portal2.tracebacks.org/api/pub

attachments/409294 

8/6/2021 7/30/2021 6052014668 CreditCard-ZeroInterest https://portal2.tracebacks.org/api/pub

attachments/314194 

8/4/2021 7/29/2021 3372013793 CreditCard-ZeroInterest https://portal2.tracebacks.org/api/pub

attachments/318824 

8/2/2021 7/30/2021 4234522072 CreditCard-ZeroInterest https://portal2.tracebacks.org/api/pub

attachments/314197 

8/2/2021 7/30/2021 8472012276 CreditCard-ZeroInterest https://portal2.tracebacks.org/api/pub

attachments/314200 

8/2/2021 7/30/2021 2123831435 CreditCard-ZeroInterest https://portal2.tracebacks.org/api/pub

attachments/314205 
7/29/2021 7/26/2021 4109373474 CreditCard-ZeroInterest https://portal2.tracebacks.org/api/pub

attachments/303960 

7/28/2021 7/27/2021 6614285474 CreditCard-ZeroInterest https://portal2.tracebacks.org/api/pub

attachments/303957 

7/28/2021 7/26/2021 7029945502 CreditCard-ZeroInterest https://portal2.tracebacks.org/api/pub

attachments/303964 

7/28/2021 7/27/2021 3147063808 CreditCard-ZeroInterest https://portal2.tracebacks.org/api/pub

attachments/303967 

4/19/2021 3/31/2021 5152077273 Debt Reduction Services https://portal2.tracebacks.org/api/pub

attachments/101127 

3/29/2021 3/27/2021 2408024923 Utility-Discount https://portal2.tracebacks.org/api/pub

attachments/80122 

3/29/2021 3/27/2021 4192854394 Utility-Discount https://portal2.tracebacks.org/api/pub

attachments/80128 

3/25/2021 3/23/2021 2159104483 Utility-Discount https://portal2.tracebacks.org/api/pub

attachments/73738 

3/22/2021 3/20/2021 7736757831 Utility-Discount https://portal2.tracebacks.org/api/pub

attachments/70577 

3/22/2021 3/20/2021 7732452718 Utility-Discount https://portal2.tracebacks.org/api/pub

attachments/70579 

2/24/2021 2/23/2021 7192802087 SSA-CalltheSSA https://portal2.tracebacks.org/api/pub

attachments/60681 

2/11/2021 2/10/2021 7323793698 Discount-Avail50% https://portal2.tracebacks.org/api/pub

attachments/55640 

2/11/2021 2/10/2021 8033189661 Discount-Avail50% https://portal2.tracebacks.org/api/pub

attachments/55641 

2/11/2021 2/10/2021 7085074219 Discount-Avail50% https://portal2.tracebacks.org/api/pub

attachments/55642 

1/9/2021 1/6/2021 7704328876 StudentLoan-FederalSuspension https://portal2.tracebacks.org/api/pub

attachments/27775 
1/8/2021 1/6/2021 3184488390 StudentLoan-FederalSuspension https://portal2.tracebacks.org/api/pub

attachments/27755