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: 

support@northwestregisteredagent.com 

Cherry Voice Inc. 

Justin Hannah, CEO 

1903 South Greeley Highway 

Suite 336 

Cheyenne, WY 82007 

c/o Northwest Registered Agent Service Inc. 

We have determined that Cherry Voice Inc. is apparently routing and transmitting illegal 

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

x Amazon-AuthorizeOrder 

x Amazon-SuspiciousCharge 

x Amazon-SuspiciousCharge-P1 

x CCIRR-P1FinancialImpers 

x Chinese-PackageDelivery 

x Discount-Avail50% 

x Discount-DirecTV50 

x Legal-Enforcement-Notice 

x PayPal-Impers 

x SSA-KindlyPressOne 

x SSA-Suspended 

x Utility-30MinDisconnect 

More specifically, our investigation revealed that Cherry Voice Inc. 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 14, 2021, and November 4, 2022, ITG 

investigated 43 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 Cherry Voice Inc. 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 Cherry Voice Inc. 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 

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 
 

 

 

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. 

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

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 
 

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 Cherry Voice Inc. 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

___________________ 12:55:46 -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) 

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 

11/4/2022 11/1/2022 8382030996 Chinese-PackageDelivery https://portal2.tracebacks.org/api/pu

tachments/1116621 

11/4/2022 11/1/2022 8382037165 Chinese-PackageDelivery https://portal2.tracebacks.org/api/pu

tachments/1116622 

11/4/2022 11/1/2022 8382031048 Chinese-PackageDelivery https://portal2.tracebacks.org/api/pu

tachments/1116624 

11/4/2022 11/1/2022 8382033136 Chinese-PackageDelivery https://portal2.tracebacks.org/api/pu

tachments/1116627 

11/4/2022 11/1/2022 8382036334 Chinese-PackageDelivery https://portal2.tracebacks.org/api/pu

tachments/1116628 

11/4/2022 11/1/2022 8382037820 Chinese-PackageDelivery https://portal2.tracebacks.org/api/pu

tachments/1116630 

11/4/2022 11/1/2022 8382036109 Chinese-PackageDelivery https://portal2.tracebacks.org/api/pu

tachments/1116632 

11/4/2022 11/1/2022 8382030705 Chinese-PackageDelivery https://portal2.tracebacks.org/api/pu

tachments/1116635 

7/19/2022 7/18/2022 8666514146 Discount-DirecTV50 https://portal2.tracebacks.org/api/pu

tachments/961450 

7/11/2022 7/9/2022 4127330625 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pu

tachments/951283 

3/31/2022 3/29/2022 5183040968 Amazon-SuspiciousCharge-P1 https://portal2.tracebacks.org/api/pu

tachments/788999 

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

tachments/707413 

2/18/2022 2/14/2022 4802182612 Amazon-SuspiciousCharge-P1 https://portal2.tracebacks.org/api/pu

tachments/698020 

2/18/2022 2/15/2022 2073301298 Amazon-SuspiciousCharge-P1 https://portal2.tracebacks.org/api/pu

tachments/698026 

2/17/2022 2/15/2022 9284751221 Amazon-SuspiciousCharge https://portal2.tracebacks.org/api/pu

tachments/701187 
1/18/2022 1/17/2022 3365698936 SSA-Suspended https://portal2.tracebacks.org/api/pu

tachments/638896 

12/30/2021 12/28/2021 5187474255 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pu

tachments/616814 

12/28/2021 12/27/2021 5207626238 Amazon-SuspiciousCharge-P1 https://portal2.tracebacks.org/api/pu

tachments/615290 

12/17/2021 12/10/2021 8502174661 SSA-Suspended https://portal2.tracebacks.org/api/pu

tachments/598188 

12/15/2021 12/13/2021 6625592490 SSA-Suspended https://portal2.tracebacks.org/api/pu

tachments/598179 

12/15/2021 12/13/2021 9174785403 SSA-Suspended https://portal2.tracebacks.org/api/pu

tachments/598202 

12/14/2021 12/11/2021 3054677821 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pu

tachments/594965 

12/14/2021 12/9/2021 4092899966 Amazon-SuspiciousCharge https://portal2.tracebacks.org/api/pu

tachments/595127 

12/14/2021 12/13/2021 6013317551 SSA-Suspended https://portal2.tracebacks.org/api/pu

tachments/598178 

12/14/2021 12/9/2021 8592957850 SSA-Suspended https://portal2.tracebacks.org/api/pu

tachments/598182 

12/14/2021 12/13/2021 8592750967 SSA-Suspended https://portal2.tracebacks.org/api/pu

tachments/598186 

12/14/2021 12/13/2021 2169525765 SSA-Suspended https://portal2.tracebacks.org/api/pu

tachments/598194 

12/14/2021 12/9/2021 6789727678 SSA-Suspended https://portal2.tracebacks.org/api/pu

tachments/598198 

12/13/2021 12/9/2021 6019961491 Amazon-SuspiciousCharge-P1 https://portal2.tracebacks.org/api/pu

tachments/591012 

12/9/2021 12/6/2021 2708415527 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pu

tachments/582925 

12/9/2021 12/2/2021 6813623077 PayPal-Impers https://portal2.tracebacks.org/api/pu

tachments/582994 
11/20/2021 11/18/2021 4233166173 Amazon-AuthorizeOrder https://portal2.tracebacks.org/api/pu

tachments/565725 

10/15/2021 10/14/2021 8137654004 Utility-30MinDisconnect https://portal2.tracebacks.org/api/pu

tachments/520026 

9/1/2021 8/25/2021 2149316277 Legal-Enforcement-Notice https://portal2.tracebacks.org/api/pu

tachments/392276 

8/25/2021 8/23/2021 5635425626 SSA-KindlyPressOne https://portal2.tracebacks.org/api/pu

tachments/383719 

8/24/2021 8/20/2021 2145324411 SSA-KindlyPressOne https://portal2.tracebacks.org/api/pu

tachments/383705 

8/24/2021 8/23/2021 5753027606 SSA-KindlyPressOne https://portal2.tracebacks.org/api/pu

tachments/383710 

8/18/2021 8/17/2021 7733017749 SSA-KindlyPressOne https://portal2.tracebacks.org/api/pu

tachments/373777 

8/5/2021 8/2/2021 2819232197 SSA-KindlyPressOne https://portal2.tracebacks.org/api/pu

tachments/316444 

5/18/2021 5/17/2021 9788981941 CCIRR-P1FinancialImpers https://portal2.tracebacks.org/api/pu

tachments/132842 

3/8/2021 3/3/2021 4699055128 CCIRR-P1FinancialImpers https://portal2.tracebacks.org/api/pu

tachments/63707 

3/5/2021 3/4/2021 7865830134 CCIRR-P1FinancialImpers https://portal2.tracebacks.org/api/pu

tachments/64038 

1/14/2021 1/14/2021 8667979774 Discount-Avail50% https://portal2.tracebacks.org/api/pu

tachments/28198