Federal Communications Commission Enforcement Bureau 45 L Street, NE Washington, DC 20554 April 13, 2021 VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED To: Omar Luna CEO R Squared Telecom LLC 526 S Main St. Suite 802 Akron, OH 44311 omar.luna@rsquaredtelecom.com Re: Official Correspondence from the Federal Communications Commission Dear Mr. Luna, We have determined that R Squared Telecom LLC (R Squared) 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 apparently illegal robocalls. As noted below, downstream voice service providers will be authorized to block all of R Squared s 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 (April 27, 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 R Squared apparently transmitted multiple illegal robocall campaigns from the sources listed in Attachment A. Actions You Should Take Now. R Squared 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 (April 27, 2021), inform the Commission and the Traceback Consortium of the steps R Squared is taking to prevent 1 See 47 CFR § 64.1200(k)(4). customers from using its network to transmit illegal robocalls.2 You must also include a declaration attesting to the truthfulness and accuracy of your response under section 1.17 of the Commission s rules.3 Failure to provide this information within 14 days shall be equivalent to having failed to put effective measures in place.4 Consequences for Failure to Comply. If after 48 hours of issuance of this letter R Squared 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 R Squared after notifying the Commission of their decision and providing a brief summary of their basis for making such a determination.5 Furthermore, if R Squared 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 deadlines may result in the Commission issuing a notice to all U.S.-based voice service providers that they may permanently block ALL call traffic transmitting from your network. Please direct any inquiries regarding this letter to 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 Call Blocking Safe Harbor Report and Order, 35 FCC Rcd at 7630, para. 43. 3 47 CFR § 1.17. See also 47 CFR § 1.16 (describing the format such declarations). 4 You are encouraged to reach out to the Commission before the deadline if you anticipate needing more time to execute this step. 5 In July 2020, the Commission adopted the Call Blocking Safe Harbor Report and Order, which authorized voice service providers to block illegal robocalls. 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 (2020) (Call Blocking Safe Harbor Report and Order); 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 Dawz Telecom Mar. 19, 2021 Auto Warranty Sales 47 U.S.C. § 227(b); 47 CFR § Robocall 64.1200 Mash Telecom Mar. 16, 2021 Auto Warranty Sales 47 U.S.C. § 227(b); 47 CFR § Robocall 64.1200 Mash Telecom Mar. 16, 2021 Auto Warranty Sales 47 U.S.C. § 227(b); 47 CFR § Robocall 64.1200 Mash Telecom Mar. 15, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Reduction Robocalls 64.1200 Mash Telecom Mar. 15, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Reduction Robocalls 64.1200 Mash Telecom Mar. 15, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Reduction Robocalls 64.1200 Mash Telecom Mar. 15, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Reduction Robocalls 64.1200 Mash Telecom Mar. 11, 2021 Auto Warranty Sales 47 U.S.C. § 227(b); 47 CFR § Robocall 64.1200 Mash Telecom Mar. 10, 2021 Customer Service Imposter 47 U.S.C. § 227(b); 47 CFR § Offering Discount on 64.1200 Monthly Bill Mash Telecom Mar. 10, 2021 Auto Warranty Sales 47 U.S.C. § 227(b); 47 CFR § Robocall 64.1200 4 Mash Telecom Mar. 8, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Reduction Robocalls 64.1200 Marketing Mar. 8, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Maestros Reduction Robocalls 64.1200 Marketing Mar. 8, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Maestros Reduction Robocalls 64.1200 Mash Telecom Feb. 16, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Reduction Robocalls 64.1200 Mash Telecom Feb. 16, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Reduction Robocalls 64.1200 Mash Telecom Feb. 10, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Reduction Robocalls 64.1200 Mash Telecom Feb. 9, 2021 Fraudulent Google Business 47 U.S.C. § 227(b); 47 CFR § Listing Offer 64.1200 Mash Telecom Feb. 9, 2021 Fraudulent Google Business 47 U.S.C. § 227(b); 47 CFR § Listing Offer 64.1200 Mash Telecom Feb. 9, 2021 Auto Warranty Sales 47 U.S.C. § 227(b); 47 CFR § Robocall 64.1200 Mash Telecom Feb. 8, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Reduction Robocalls 64.1200 Mash Telecom Feb. 8, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Reduction Robocalls 64.1200 5 Mash Telecom Feb. 8, 2021 Fraudulent Credit Card Rate 47 U.S.C. § 227(b); 47 CFR § Reduction Robocalls 64.1200 Omiz Solutions Feb. 2, 2021 Social Security 47 U.S.C. § 227(b); 47 CFR § Administration Imposter 64.1200 Robocall 6