Federal Communications Commission Enforcement Bureau 45 L Street, NE Washington, DC 20554 March 17, 2021 VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED To: Josh Justice CEO Stratics Networks 762 Upper James St Suite 287 Hamilton, ON L9C 3A2 Canada cc: andrew.iler@straticsnetworks.com Re: Official Correspondence from the Federal Communications Commission Dear Mr. Justice, We have determined that Stratics Networks (Stratics) is apparently transmitting illegal robocall traffic on behalf of one or more of its clients. You should investigate and, if necessary, cease transmitting such traffic immediately and take steps to prevent your network from continuing to be a source of apparent illegal robocalls. As noted below, downstream voice service providers will be authorized to block all of Stratics traffic if you do not take steps to  effectively mitigate illegal traffic within 48 hours, or if you fail to inform the Commission and the Traceback Consortium within fourteen (14) days of this letter (March 31, 2021) of the steps you have taken to  implement effective measures to prevent customers from using your network to make illegal calls.1 Why You Are Receiving This Notification. You are receiving this letter because one or more investigations conducted by the Commission, in conjunction with the Traceback Consortium, revealed that Stratics apparently transmitted multiple illegal robocall campaigns from the sources listed in Attachment A. Actions You Should Take Now. Stratics should take the following steps to resolve this matter: 1. Promptly investigate the transmissions identified above. 2. If necessary,  effectively mitigate the identified unlawful traffic by determining the source of the traffic and preventing that source from continuing to originate such traffic. 3. Implement effective safeguards to prevent customers from using your network as a platform to originate illegal calls. 4. Within 48 hours, inform the Commission and the Traceback Consortium of steps taken to mitigate the identified apparent illegal traffic. 5. Within fourteen (14) days of the date of this letter (March 31, 2021), inform the Commission and the Traceback Consortium of the steps Stratics is taking to prevent 1 See 47 CFR § 64.1200(k)(4). customers from using its network to transmit illegal robocalls.2 Failure to provide this information within 14 days shall be equivalent to having failed to put effective measures in place.3 Consequences for Failure to Comply. If after 48 hours of issuance of this letter Stratics continues to route or transmit harmful robocall traffic from the entities involved in these campaigns, downstream U.S.-based voice service providers may begin blocking all calls from Stratics after notifying the Commission of their decision and providing a brief summary of their basis for making such a determination.4 Furthermore, if Stratics fails to take sufficient mitigating actions to prevent its network from continuing to be used to transmit illegal robocalls, then downstream U.S.-based providers may block calls following notice to the Commission. Failure to act within the deadline may result in the Commission issuing a notice to all U.S.-based voice service providers that they may block ALL call traffic transmitting from your network, permanently. Please direct any inquiries regarding this letter to Daniel Stepanicich, Attorney Advisor, Telecommunications Consumers Division, Enforcement Bureau, FCC, at daniel.stepanicich@fcc.gov or (202) 418-7451; and cc: to Kristi Thompson, Division Chief, Telecommunications Consumers Division, 2 See Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, Third Report and Order, Order on Reconsideration, and Fourth Further Notice of Proposed Rulemaking, 35 FCC Rcd 7614, 7630, para. 43 (2020) (Call Blocking Safe Harbor Report and Order) 3 You are encouraged to reach out to the Commission before the deadline if you anticipate needing more time to execute this step. 4 In July 2020, the Commission adopted the Call Blocking Safe Harbor Report and Order, which authorized voice service providers to block illegal robocalls. Call Blocking Safe Harbor Report and Order, 35 FCC Rcd at 7628, para. 36; see also 47 CFR § 64.1200(k)(3)-(4). If the Commission identifies illegal traffic, based on information obtained through traceback such as that provided by the Traceback Consortium, the Commission may notify the voice service provider that it is transmitting identified probable illegal calls (or  bad traffic ) and, upon receipt of notification, the voice service provider should investigate promptly and take any steps that may be necessary to prevent the illegal caller from continuing to use the network to make such calls. Furthermore, if the notified voice service provider fails to take effective mitigation measures within 48 hours, any downstream voice service provider may block the calls from the notified provider. Call Blocking Safe Harbor Report and Order, 35 FCC Rcd at 7628- 29, para. 39. Any voice service provider that decides to block traffic from the bad actor provider must notify the Commission of its decision and provide a brief summary of its basis for making such a determination prior to initiating blocking. Id. at 7630, para. 42; 47 CFR § 64.1200(k)(4). If the notified voice service provider fails to implement effective measures to prevent new and renewing customers from using its network to originate illegal calls, other downstream voice service providers may block the calls from the notified provider. Call Blocking Safe Harbor Report and Order, 35 FCC Rcd at 7630 para. 43; 47 CFR § 64.1200(k)(3)-(4). A voice service provider that decides to block traffic from the bad actor provider must notify the Commission of its decision and provide a brief summary of its basis for making such a determination prior to initiating blocking. Id. at 7630, para. 43; 47 CFR § 64.1200(k)(4). 2 Enforcement Bureau, FCC, at kristi.thompson@fcc.gov. A copy of this letter has been sent to the Traceback Consortium. Sincerely, Kristi Thompson Division Chief Telecommunications Consumers Division Enforcement Bureau Federal Communications Commission 3 ATTACHMENT A Customer Date of Call Caller ID Called Number Description Violation Fraudulent Student 47 U.S.C. § 227(b); 47 CFR § PubClub February 8, 2021 Loan Robocalls 64.1200 Fraudulent Student 47 U.S.C. § 227(b); 47 CFR § PubClub February 8, 2021 Loan Robocalls 64.1200 Fraudulent Student 47 U.S.C. § 227(b); 47 CFR § PubClub February 8, 2021 Loan Robocalls 64.1200 Fraudulent Student 47 U.S.C. § 227(b); 47 CFR § Omar Talamantes Inc. January 28, 2021 Loan Robocalls 64.1200 Fraudulent Utility 47 U.S.C. § 227(b); 47 CFR § Greenvoice Telecom November 4, 2020 Services Robocall 64.1200 Fraudulent Utility 47 U.S.C. § 227(b); 47 CFR § Greenvoice Telecom October 9, 2020 Services Robocall 64.1200 Care Advocacy COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § Solutions September 28, 2020 Robocall 64.1200 Fraudulent Sweepstakes 47 U.S.C. § 227(b); 47 CFR § Emarket September 28, 2020 Robocall 64.1200 Fraudulent Sweepstakes 47 U.S.C. § 227(b); 47 CFR § Emarket September 28, 2020 Robocall 64.1200 2020 Election 47 U.S.C. § 227(b); 47 CFR § Expert Vendor September 24, 2020 Related Robocall 64.1200 Patriots for American 2020 Election 47 U.S.C. § 227(b); 47 CFR § Leadership September 24, 2020 Related Robocall 64.1200 Patriots for American 2020 Election 47 U.S.C. § 227(b); 47 CFR § Leadership September 24, 2020 Related Robocall 64.1200 4 Fraudulent Sweepstakes 47 U.S.C. § 227(b); 47 CFR § Nitzke Enterprize September 23, 2020 Robocall 64.1200 Fraudulent Sweepstakes 47 U.S.C. § 227(b); 47 CFR § Nitzke Enterprise September 23, 2020 Robocall 64.1200 Fraudulent Sweepstakes 47 U.S.C. § 227(b); 47 CFR § Nitzke Enterprise September 23, 2020 Robocall 64.1200 Fraudulent Sweepstakes 47 U.S.C. § 227(b); 47 CFR § Progressive Promoting September 14, 2020 Robocall 64.1200 Fraudulent Sweepstakes 47 U.S.C. § 227(b); 47 CFR § Progressive Promoting September 14, 2020 Robocall 64.1200 Fraudulent Sweepstakes 47 U.S.C. § 227(b); 47 CFR § Progressive Promoting September 11, 2020 Robocall 64.1200 Fraudulent DirectTV 47 U.S.C. § 227(b); 47 CFR § Shamoon Ahmad September 4, 2020 Discount Robocall 64.1200 Fraudulent DirectTV 47 U.S.C. § 227(b); 47 CFR § Technest Limited September 3, 2020 Discount Robocall 64.1200 Fraudulent DirectTV 47 U.S.C. § 227(b); 47 CFR § Technest Limited September 3, 2020 Discount Robocall 64.1200 Fraudulent DirectTV 47 U.S.C. § 227(b); 47 CFR § Technest Limited September 3, 2020 Discount Robocall 64.1200 Fraudulent Social Security Administration 47 U.S.C. § 227(b); 47 CFR § No Response September 1, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response August 21, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response August 17, 2020 Robocall 64.1200 5 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response August 17, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response August 10, 2020 Robocall 64.1200 Fraudulent Credit Card Customer 47 U.S.C. § 227(b); 47 CFR § No Response July 23, 2020 Support Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § Netlatitude Inc. July 2, 2020 Robocall 64.1200 Fraudulent Social Security Administration Third Base International Enforcement 47 U.S.C. § 227(b); 47 CFR § Telecom, LLC June 26, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response June 12, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response June 8, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response June 8, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response June 2, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response June 2, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response June 1, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response May 26, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response May 26, 2020 Robocall 64.1200 6 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response May 18, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Response May 13, 2020 Robocall 64.1200 Fraudulent Social Security Administration 47 U.S.C. § 227(b); 47 CFR § No Response May 7, 2020 Robocall 64.1200 No Customer COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § Information April 29, 2020 Robocall 64.1200 No Customer COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § Information April 28, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Record of Traffic April 28, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Record of Traffic April 28, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § Netlatitude Inc. April 24, 2020 Robocall 64.1200 Fraudulent Social Security Administration 47 U.S.C. § 227(b); 47 CFR § RSCom / NGP Telecom April 20, 2020 Robocall 64.1200 RealEstate- 47 U.S.C. § 227(b); 47 CFR § National Home Buyers April 13, 2020 CoronaStillBuying 64.1200 DebtReduction- 47 U.S.C. § 227(b); 47 CFR § Netlatitude Inc. April 13, 2020 CoronaHardship 64.1200 RealEstate / Buy During COVID-19 47 U.S.C. § 227(b); 47 CFR § National Home Buyers April 13, 2020 Robocall 64.1200 RealEstate / Buy During COVID-19 47 U.S.C. § 227(b); 47 CFR § No Record of Traffic April 12, 2020 Robocall 64.1200 7 RealEstate / Buy During COVID-19 47 U.S.C. § 227(b); 47 CFR § National Home Buyers April 11, 2020 Robocall 64.1200 Health Insurance / COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § Health Innovations April 10, 2020 Robocall 64.1200 Health Insurance / COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § Health Innovations April 10, 2020 Robocall 64.1200 Health Insurance / COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § No Records of Traffic April 10, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § Netlatitude Inc. April 9, 2020 Robocall 64.1200 COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § Netlatitude Inc. April 9, 2020 Robocall 64.1200 Health Insurance / Lead Gen Marketing COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § Inc. April 2, 2020 Robocall 64.1200 Health Insurance / Lead Gen Marketing COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § Inc. April 2, 2020 Robocall 64.1200 Health Insurance / Lead Gen Marketing COVID-19 Related 47 U.S.C. § 227(b); 47 CFR § Inc. April 2, 2020 Robocall 64.1200 Fraudulent Medicare 47 U.S.C. § 227(b); 47 CFR § Telesero / Fiducia February 4, 2020 Benefits Robocall 64.1200 Fraudulent Social Security Administration 47 U.S.C. § 227(b); 47 CFR § No Response January 31, 2020 Robocall 64.1200 Robocall Campaign 47 U.S.C. § 227(b); 47 CFR § No Response August 13, 2019 Targeting Arizona 64.1200 8 Robocall Campaign 47 U.S.C. § 227(b); 47 CFR § No Response August 13, 2019 Targeting Arizona 64.1200 Robocall Campaign 47 U.S.C. § 227(b); 47 CFR § No Response August 13, 2019 Targeting Arizona 64.1200 Robocall Campaign 47 U.S.C. § 227(b); 47 CFR § No Response August 13, 2019 Targeting Arizona 64.1200 Fraudulent Student 47 U.S.C. § 227(b); 47 CFR § No Response July 30, 2019 Loan Advisor 64.1200 9