>In response to the FCC’s enforcement action against Illum in October 2021, the CEO and Director of Illum, Prince Anand (Anand), who sometimes uses the alias “Frank Murphy,” Prince Anand Skype Chat, June 10, 2021 at 8:18:53 AM (“Frank Murphy” introduces himself as Prince Anand) (on file at EB-TCD-20-00030805) (Anand Skype Chat). created One Eye. Id. at October 24, 2021 at 8:16:14 AM and 8:16:21 AM (Anand telling Great Choice Telecom to expect a new sign up under the name “One Eye” that day).

> To deflect the FCC’s scrutiny, Anand intended to keep his name off One Eye’s corporate documents. Id. at 7:40:25 AM, 8:11:13 AM, 8:13:20 AM, 8:14:48 AM, 8:14:55 AM, 8:15:04 AM, 8:16:14 AM, 8:55:50 AM, 9:01:49 AM, 9:02:21 AM, and 9:02:26 AM (Anand explains that due to the Commission’s cease-and-desist letter he will “not be included in any companies” but will work “on the backend [sic]”).

> Kaushal Bhavsar, a director of Illum, became One Eye’s CEO. One Eye LLC Listing, Fed. Commc’ns Comm’n, Robocall Mitigation Database (Oct. 26, 2021), https://fccprod.servicenowservices.com/rmd?id=rmd_form&table... (showing Bhavsar as CEO of One Eye); Illum Telecommunication, https://www.illumtelecommunication.com/ (last visited July 14, 2023).

> Aashay Khandelwal, the Human Resource Representative for Illum, subsequently formed One Owl and became the CEO. See Illum Telecommunication, https://www.illumtelecommunication.com/ (last visited July 14, 2023); see also One Owl Telecom Inc. Listing, Fed. Commc’ns Comm’n, Robocall Mitigation Database (Apr. 25, 2022), https://fccprod.servicenowservices.com/rmd?id=rmd_form&table... (showing Khandelwal as the CEO of One Owl).

> Julya Barros, a seemingly close acquaintance of Anand, Compare @illum_telecom, Twitter, https://twitter.com/illum_telecom?lang=hi (as archived by Google and last visited May 16, 2023) (screenshots on file at EB-TCD-20-00030805), with Julya Barros (@julyabarross), Instagram, http://www.instagram.com/julyabarross (last visited July 14, 2023).became Vice President of Sales and Marketing at One Owl. See Julya Barros, LinkedIn, https://ae.linkedin.com/in/julya-barros-928008245 (last visited July 14, 2023) (screenshots on file at EB-TCD-20-00030805).

>One Owl and One Eye used the same IP address to conduct their business. March ITG Subpoena Response, supra note 4.

> One Owl and One Eye communicated under the same email domain, @oneeyetelecom.com. Compare Incorp Services Interrogatories Response at para. 15 (on file at EB-TCD-20-00030805) (Incorp Services Interrog.) (showing One Eye used the @oneeyetelecom.com domain), with id. at para. 3 and Ex. A (on file at EB-TCD-20-00030805) (showing One Owl used the @oneeyetelecom.com domain).

>The personnel connections between One Owl, One Eye, and Illum are summarized in the table below.

The FCC is just playing whack-a-mole as soon as it begins enforcement on a company, the people involved just get together with their buddies and form a new company.

This will never work to curb robocalls.

Instead, the US Government needs to do the following

1. Require a $10 million dollar 5 year bond to start one of these companies. If the company engages in facilitating robocalling, the bond is forfeit

2. Criminal charges and enforcement against the agents of these companies

3. Immigration action against the agents and associates of these companies including deportation and permanent visa bans.

Only then can the US government begin to combat this. Otherwise, doing more of the same is going to be completely ineffective and a waste of time and resources.