Federal Communications Commission Enforcement Bureau 45 L Street, NE Washington, DC 20554 October 21, 2021 VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED To: Prince Anand CEO PZ/Illum Telecommunication Telecommunication LLC 1950 W. Corporate Way Anaheim, CA 92801 cc: 90 Church St Floor 1 Suite 3514 New York, NY 10007 prianand309@illumtelecommunication.com prianand309@pztelecommunication.com Re: Official Correspondence from the Federal Communications Commission Dear Mr. Anand, We have determined that PZ/Illum Telecommunication Telecommunication LLC (PZ/Illum) is apparently originating 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 PZ/Illum’s traffic if you do not (1) take steps to “effectively mitigate illegal traffic within 48 hours,” and (2) inform the Commission and the Traceback Consortium within fourteen (14) days of the date of this letter (November 5, 2021) of the steps you have taken to “implement effective measures” to prevent customers from using your network to make illegal 1 calls. 0F Additionally, if you continue knowingly or negligently to originate illegal robocall campaigns after responding to this letter, we may remove your certification from the Robocall Mitigation Database thereby requiring all intermediate providers and terminating voice service providers to 2 cease accepting your traffic. 1F Basis for finding apparent violations. You are receiving this letter because our investigation revealed that PZ/Illum apparently originated multiple illegal robocall campaigns, as set forth in Attachment A. The Federal Communications Commission’s Enforcement Bureau (Bureau) works closely with the USTelecom’s Industry Traceback Group (Traceback Consortium), which is the registered 1 See 47 CFR § 64.1200(k)(4). 2 Call Authentication Trust Anchor, WC Docket No. 17-97, Second Report and Order, 36 FCC Rcd 1859, 1903, para. 83 & 1904, para. 86 (2020); 47 CFR § 64.6305. 1 3 industry consortium selected pursuant to the TRACED Act to conduct tracebacks.2F Between August 24, 2021 and October 15, 2021, Traceback Consortium investigated prerecorded voice message calls that voice service providers using honeypots (i.e. unassigned numbers held by providers to detect illegal 4 robocalls) and customers of YouMail had flagged as illegal robocalls made without consent.3F The Traceback Consortium conducted tracebacks and determined that PZ/Illum originated the calls. The Traceback Consortium previously notified you of these calls and provided you access to supporting data identifying each call, as indicated in Attachment A. Further, the numerous tracebacks to PZ/Illum as an originator indicate that you are apparently knowingly or negligently originating illegal robocall traffic. Under our rules (and as explained further below), providers that originate illegal robocall traffic face serious consequences, including blocking by downstream providers of all of the originating provider’s traffic. To avoid such blocking, you must take corrective actions immediately. Actions You Should Take Now. PZ/Illum should take the following steps to resolve this matter: 1. Promptly investigate the transmissions identified in Attachment A. 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. If you have evidence that the transmissions identified in Attachment A were legal calls, present that evidence to the Commission and the Traceback Consortium. 5. Within fourteen (14) days of the date of this letter (November 5, 2021), inform the Commission and the Traceback Consortium of the steps PZ/Illum is taking to prevent customers from using its network to transmit illegal robocalls (i.e. robocall mitigation 5 measures). 4F Failure to provide this information within 14 days shall be equivalent to 6 having failed to put effective measures in place. 5F Consequences for Failure to Comply. If after 48 hours of issuance of this letter PZ/Illum continues to route or transmit illegal robocall traffic from the entities involved in these campaigns, downstream U.S.-based voice service providers may begin blocking all calls from PZ/Illum after notifying the Commission of their decision and providing a brief summary of their basis for making such 7 a determination.6F If PZ/Illum fails to take sufficient mitigating actions to prevent new and renewing 3 Implementing Section 13(d) of the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (TRACED Act), EB Doclet No. 20-22, Report and Order, DA 21-1047 (EB 2021) (2021 Consortium Selection Order). See also Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence Act, Pub. L. No. 116-105, 133 Stat. 3274, Sec. 13(d) (2019) (TRACED Act). 4 See 47 U.S.C. § 227(b); 47 CFR § 64.1200(a). 5 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). 6 You are encouraged to reach out to the Commission before the deadline if you anticipate needing more time to execute this step. 7 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. 37; see also 47 CFR § 64.1200(k)(3)-(4). If the Commission identifies illegal traffic, based on information 2 customers from using its network to originate illegal robocalls, then downstream U.S.-based providers may block calls following notice to the Commission. Failure to act within the deadlines authorizes U.S.-based voice service providers to block ALL call traffic transmitting from your network, permanently. Furthermore, if you fail to take the actions listed above, or knowingly or negligently continue to originate unlawful robocall campaigns after responding to this letter, we may find that your certification in the Robocall Mitigation Database is deficient and direct the removal of your certification from the 8 database.7F Removal of a certification from the Robocall Mitigation Database requires all intermediate 9 providers and terminating voice service providers to immediately cease accepting all of your calls. 8F Continued origination of illegal robocalls following this notice will be used as evidence of a defective certification, and we may initiate proceedings to remove your certification from the Robocall 10 11 Mitigation Database.9F You will have an opportunity to respond to that notice.10F Please direct any inquiries or responses 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, 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). 8 See Call Authentication Trust Anchor, 36 FCC Rcd at 1905, para. 88. Robocall Mitigation Database, FCC, available at https://fccprod.servicenowservices.com/rmd?id=rmd_welcome (last visited Oct. 19, 2021) 9 47 CFR § 64.6305(c). See Call Authentication Trust Anchor, 36 FCC Rcd at 1904, para. 86; Wireline Competition Bureau Announces Opening of Robocall Mitigation Database and Provides Filing Instructions and Deadlines, WC Docket No. 17-97, Public Notice, DA 21-454 (WCB Apr. 20, 2021). 10 See Call Authentication Trust Anchor, 36 FCC Rcd at 1902, 1905, paras. 81, 88. 11 Id. at 1905, para. 88. 3 Telecommunications Consumers Division, Enforcement Bureau, FCC, at kristi.thompson@fcc.gov. A copy of this letter has been sent to the Traceback Consortium. Sincerely, Rosemary C. Harold Chief Enforcement Bureau Federal Communications Commission 4 ATTACHMENT A Customer Date of ITG Date of Call Caller ID Called Number Description Violation Notification Aug 25, 2021 47 USC 17:43 Aug 24, 2021 227(b); 47 SSA Imposter Aug 30, 2021 20:05 UTC CFR No Response 14:00 64.1200(a) Aug 25, 2021 47 USC 19:44 Aug 24, 2021 227(b); 47 SSA Imposter Aug 30, 2021 19:56 UTC CFR No Response 14:00 64.1200(a) 47 USC Aug 30, 2021 Aug 24, 2021 227(b); 47 SSA Imposter 14:00 19:49 UTC CFR No Response 64.1200(a) 47 USC Aug 30, 2021 Aug 24, 2021 227(b); 47 SSA Imposter 14:00 19:42 UTC CFR No Response 64.1200(a) 47 USC Aug 30, 2021 Aug 24, 2021 227(b); 47 SSA Imposter Edoro 14:21 19:38 UTC CFR Technologies 64.1200(a) 47 USC Aug 26, 2021 Aug 24, 2021 227(b); 47 SSA Imposter 15:26 19:38 UTC CFR No Response 64.1200(a) Aug 27, 2021 14:20 47 USC Aug 26, 2021 Aug 23, 2021 227(b); 47 CBP-Govt Imposter 15:00 14:12 UTC CFR Edoro Aug 26, 2021 64.1200(a) Technologies 14:46 5 47 USC Sep 01, 2021 Aug 31, 2021 227(b); 47 SSA Imposter Edoro 13:22 16:41 UTC CFR Technologies 64.1200(a) 47 USC Sep 01, 2021 Aug 31, 2021 227(b); 47 SSA Imposter Edoro 13:25 16:37 UTC CFR Technologies 64.1200(a) 47 USC Sep 01, 2021 Aug 31, 2021 227(b); 47 SSA Imposter Edoro 14:07 15:48 UTC CFR Technologies 64.1200(a) 47 USC Sep 01, 2021 Aug 31, 2021 227(b); 47 SSA Imposter Edoro 15:41 15:46 UTC CFR Technologies 64.1200(a) 47 USC Sep 01, 2021 Aug 31, 2021 227(b); 47 SSA Imposter Edoro 14:02 14:21 UTC CFR Technologies 64.1200(a) 47 USC Sep 01, 2021 Aug 31, 2021 227(b); 47 SSA Imposter Edoro 15:48 13:22 UTC CFR Technologies 64.1200(a) 47 USC Sep 07, 2021 Sep 03, 2021 227(b); 47 Arrest Warrant Scam 17:36 13:48 UTC CFR Q2Serves 64.1200(a) 47 USC Spinning Mantra Sep 14, 2021 Sep 07, 2021 227(b); 47 SSA Imposter Communications 12:10 21:11 UTC CFR Pvt. Ltd. 64.1200(a) 47 USC Spinning Mantra Sep 14, 2021 Sep 07, 2021 227(b); 47 SSA Imposter Communications 14:00 20:59 UTC CFR Pvt. Ltd. 64.1200(a) 6 47 USC Spinning Mantra Sep 08, 2021 Sep 07, 2021 227(b); 47 SSA Imposter Communications 16:39 19:12 UTC CFR Pvt. Ltd. 64.1200(a) 47 USC Spinning Mantra Sep 08, 2021 Sep 07, 2021 227(b); 47 SSA Imposter Communications 18:01 17:27 UTC CFR Pvt. Ltd 64.1200(a) 47 USC Spinning Mantra Sep 08, 2021 Sep 07, 2021 227(b); 47 SSA Imposter Communications 18:00 17:18 UTC CFR Pvt. Ltd. 64.1200(a) 47 USC Spinning Mantra Sep 08, 2021 Sep 07, 2021 227(b); 47 SSA Imposter Communications 15:05 16:20 UTC CFR Pvt. Ltd. 64.1200(a) 47 USC Spinning Mantra Sep 08, 2021 Sep 07, 2021 227(b); 47 SSA Imposter Communications 15:30 16:01 UTC CFR Pvt. Ltd. 64.1200(a) 47 USC Sep 14, 2021 Spinning Mantra Sep 07, 2021 227(b); 47 14:00 Sep 08, SSA Imposter Communications 15:49 UTC CFR 2021 16:06 Pvt. Ltd. 64.1200(a) 47 USC Spinning Mantra Sep 14, 2021 Sep 07, 2021 227(b); 47 SSA Imposter Communications 12:07 15:13 UTC CFR Pvt. Ltd. 64.1200(a) 47 USC Spinning Mantra Sep 14, 2021 Sep 07, 2021 227(b); 47 SSA Imposter Communications 14:00 15:02 UTC CFR Pvt. Ltd. 64.1200(a) 47 USC Sep 08, 2021 Sep 03, 2021 227(b); 47 CBP-Govt Imposter 16:13 14:32 UTC CFR No Response 64.1200(a) 7 Sep 08, 2021 47 USC Cyber 16:50 Sep 02, 2021 227(b); 47 SSA Imposter Futuristics Pvt. Sep 08, 2021 17:25 UTC CFR Ltd. 15:45 64.1200(a) 47 USC Cyber Sep 14, 2021 Sep 02, 2021 227(b); 47 SSA Imposter Futuristics Pvt. 12:08 15:28 UTC CFR Ltd. 64.1200(a) Sep 14, 2021 47 USC 14:00 Sep 01, 2021 227(b); 47 SSA Imposter Edoro Sep 08, 2021 17:24 UTC CFR Technologies 21:33 64.1200(a) 47 USC Sep 13, 2021 Sep 09, 2021 227(b); 47 SSA Imposter Iqbri Telecom 15:50 16:54 UTC CFR Pvt. Ltd. 64.1200(a) 47 USC Sep 10, 2021 Sep 09, 2021 227(b); 47 SSA Imposter Iqbri Telecom 17:48 17:15 UTC CFR Pvt. Ltd. 64.1200(a) 47 USC Sep 10, 2021 Sep 09, 2021 227(b); 47 SSA Imposter Iqbri Telecom 15:51 18:06 UTC CFR Pvt. Ltd. 64.1200(a) 47 USC Sep 10, 2021 Sep 09, 2021 227(b); 47 SSA Imposter Iqbri Telecom 15:47 14:06 UTC CFR Pvt. Ltd. 64.1200(a) 47 USC Globalite Sep 08, 2021 Sep 08, 2021 Federal Reserve 227(b); 47 Collaboration 17:15 17:15 UTC Imposter CFR Pvt. Ltd. 64.1200(a) 47 USC Globalite Sep 10, 2021 Sep 08, 2021 Federal Reserve 227(b); 47 Collaboration 17:52 16:56 UTC Imposter CFR Pvt. Ltd. 64.1200(a) 8 47 USC Sep 14, 2021 Sep 13, 2021 227(b); 47 Arrest Warrant 12:54 14:43 UTC CFR No Response 64.1200(a) 47 USC Sep 20, 2021 Sep 13, 2021 227(b); 47 Arrest Warrant 18:59 16:46 UTC CFR RD INFOTECH 64.1200(a) Sep 14, 2021 47 USC 18:57 Sep 13, 2021 227(b); 47 Arrest Warrant Iqbri Telecom Sep 14, 2021 16:34 UTC CFR Pvt. Ltd. 19:26 64.1200(a) 47 USC Sep 21, 2021 Sep 15, 2021 227(b); 47 Utility Disconnect Sam 14:00 16:57 UTC CFR Q2Serves 64.1200(a) 47 USC Cyber Sep 17, 2021 Sep 14, 2021 227(b); 47 CBP-Govt Imposter Futuristics Pvt. 05:20 14:34 UTC CFR Ltd. 64.1200(a) 47 USC Sep 17, 2021 Sep 16, 2021 227(b); 47 SSA Imposter AARV Services 13:32 15:23 UTC CFR Pvt. Ltd. 64.1200(a) 47 USC Sep 17, 2021 Sep 16, 2021 227(b); 47 SSA Imposter 13:32 19:26 UTC CFR No Response 64.1200(a) 47 USC Sep 17, 2021 Sep 16, 2021 227(b); 47 SSA Imposter 14:16 19:18 UTC CFR No Response 64.1200(a) 47 USC Sep 20, 2021 Sep 16, 2021 227(b); 47 SSA Imposter AARV Services 15:24 17:44 UTC CFR Pvt. Ltd. 64.1200(a) 9 47 USC Sep 17, 2021 Sep 16, 2021 227(b); 47 SSA Imposter 13:32 22:32 UTC CFR No Response 64.1200(a) 47 USC Sep 17, 2021 Sep 16, 2021 227(b); 47 SSA Imposter 17:50 21:23 UTC CFR No Response 64.1200(a) 47 USC Sep 20, 2021 Cyber Sep 02, 2021 227(b); 47 15:57 Sep 21, SSA Imposter Futuristics Pvt. 15:20 UTC CFR 2021 13:56 Ltd. 64.1200(a) 47 USC Sep 20, 2021 Sep 15, 2021 227(b); 47 SSA Imposter 18:53 15:11 UTC CFR RD INFOTECH 64.1200(a) 47 USC Sep 23, 2021 Sep 15, 2021 227(b); 47 SSA Imposter 14:00 17:54 UTC CFR RD INFOTECH 64.1200(a) Sep 21, 2021 47 USC 16:56 Sep 15, 2021 227(b); 47 SSA Imposter Sep 20, 2021 20:29 UTC CFR RD INFOTECH 20:47 64.1200(a) 47 USC Sep 20, 2021 Sep 15, 2021 227(b); 47 SSA Imposter 18:57 21:59 UTC CFR Coequence 64.1200(a) 47 USC Sept 20, 2021 Sep 15, 2021 227(b); 47 SSA Imposter 20:43 16:17 UTC CFR RD INFOTECH 64.1200(a) 47 USC Sep 20, 2021 Sep 15, 2021 227(b); 47 SSA Imposter 19:01 21:05 UTC CFR Coequence 64.1200(a) 10 47 USC Sep 20, 2021 Sep 15, 2021 227(b); 47 SSA Imposter 19:03 22:15 UTC CFR Coequence 64.1200(a) 47 USC Sep 21, 2021 Sep 20, 2021 227(b); 47 SSA Imposter 15:29 19:53 UTC CFR Go4Customer 64.1200(a) 47 USC Sep 21, 2021 Sep 20, 2021 227(b); 47 Arrest Warrant Scam 15:29 18:39 UTC CFR RD INFOTECH 64.1200(a) 47 USC Sep 21, 2021 Sep 20, 2021 227(b); 47 Arrest Warrant Scam Go4Customer / 16:02 15:11 UTC CFR CyFuture 64.1200(a) Sep 23, 2021 47 USC 12:26 Sep 20, 2021 227(b); 47 SSA Imposter Sep 23, 2021 20:09 UTC CFR RD INFOTECH 13:09 64.1200(a) Sep 30, 2021 47 USC 20:13 Sep 28, 2021 Credit Card Rate 227(b); 47 Sep 30, 2021 21:46 UTC Reduction Call CFR SAGA 22:23 64.1200(a) 47 USC Oct 07, 2021 Sep 28, 2021 Credit Card Rate 227(b); 47 18:34 21:26 UTC Reduction Call CFR SAGA 64.1200(a) 47 USC Sept 30, 2021 Sep 28, 2021 Credit Card Rate 227(b); 47 19:25 18:29 UTC Reduction Call CFR SAGA 64.1200(a) 47 USC Oct 01, 2021 Sep 29, 2021 Credit Card Rate 227(b); 47 01:09 15:28 UTC Reduction Call CFR SAGA 64.1200(a) 11 47 USC Oct 05, 2021 Oct 04, 2021 227(b); 47 SSA Imposter 12:49 22:58 UTC CFR Max Solutions 64.1200(a) 47 USC Oct 05, 2021 Oct 04, 2021 227(b); 47 SSA Imposter 13:57 22:19 UTC CFR Max Solutions 64.1200(a) 47 USC Oct 05, 2021 Oct 04, 2021 227(b); 47 SSA Imposter 13:23 20:09 UTC CFR Max Solutions 64.1200(a) 47 USC Oct 05, 2021 Oct 04, 2021 227(b); 47 SSA Imposter 13:20 19:13 UTC CFR Max Solutions 64.1200(a) 47 USC Oct 06, 2021 Oct 04, 2021 227(b); 47 SSA Imposter 14:15 18:30 UTC CFR Max Solutions 64.1200(a) 47 USC Oct 05, 2021 Oct 04, 2021 227(b); 47 SSA Imposter 12:44 19:07 UTC CFR Max Solutions 64.1200(a) 47 USC Oct 19, 2021 Oct 12, 2021 227(b); 47 Arrest Warrant Scam LINTECH 14:00 19:57 UTC CFR SOLUTIONS 64.1200(a) 47 USC Oct 13, 2021 Oct 12, 2021 227(b); 47 Arrest Warrant Scam LINTECH 15:55 19:25 UTC CFR SOLUTIONS 64.1200(a) 47 USC Oct 14, 2021 Oct 12, 2021 227(b); 47 Arrest Warrant Scam LINTECH 00:21 19:24 UTC CFR SOLUTIONS 64.1200(a) 12 47 USC Oct 13, 2021 Oct 12, 2021 227(b); 47 Arrest Warrant Scam LINTECH 16:54 19:05 UTC CFR SOLUTIONS 64.1200(a) 47 USC Oct 13, 2021 Oct 12, 2021 227(b); 47 Arrest Warrant Scam LINTECH 18:10 19:47 UTC CFR SOLUTIONS 64.1200(a) 47 USC Oct 13, 2021 Oct 12, 2021 227(b); 47 Arrest Warrant Scam LINTECH 18:43 19:41 UTC CFR SOLUTIONS 64.1200(a) Oct 13, 2021 47 USC 20:55 Oct 12, 2021 227(b); 47 Arrest Warrant Scam LINTECH Oct 13, 2021 19:37 UTC CFR SOLUTIONS 20:40 64.1200(a) 47 USC Oct 13, 2021 Oct 12, 2021 227(b); 47 Arrest Warrant Scam LINTECH 17:32 19:35 UTC CFR SOLUTIONS 64.1200(a) 47 USC Oct 13, 2021 Oct 12, 2021 227(b); 47 Arrest Warrant Scam LINTECH 16:57 21:27 UTC CFR SOLUTIONS 64.1200(a) 47 USC Oct 13, 2021 Oct 12, 2021 227(b); 47 Arrest Warrant Scam LINTECH 17:41 21:01 UTC CFR SOLUTIONS 64.1200(a) 47 USC Oct 15, 2021 Oct 13, 2021 227(b); 47 Arrest Warrant Scam LINTECH 14:08 16:49 UTC CFR SOLUTIONS 64.1200(a) 13