Federal Communications Commission Enforcement Bureau 45 L Street, NE Washington, DC 20554 March 22, 2022 VIA ELECTRONIC DELIVERY AND CERTIFIED MAIL - RETURN RECEIPT REQUESTED To: Mr. Avi Lonstein CEO Airespring, Inc. 7800 Woodley Ave. Van Nuys, CA 91406 Cc: Mr. Rod Rummelsburg General Counsel rod@airespring.com Re: Official Correspondence from the Federal Communications Commission Dear Mr. Lonstein: We have determined that Airespring, Inc. (“Airespring”) 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 Airespring’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 (Tuesday, April 5, 2022), 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 Airespring apparently transmitted multiple illegal robocall campaigns from the sources listed in Attachment A. Actions You Should Take Now. Airespring 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. 1 See 47 CFR § 64.1200(k)(4). 5. Within fourteen (14) days of the date of this letter (Tuesday, April 5, 2022), inform the Commission and the Traceback Consortium of the steps Airespring is taking to prevent 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 Airespring 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 Airespring after notifying the Commission of their decision and providing a brief summary of their basis for making such a determination.5 Furthermore, if Airespring 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 authorizes U.S.-based voice service providers to block all call traffic transmitting from your network, permanently. Please direct any inquiries or responses regarding this letter to Lisa Zaina, Supervisor Attorney Advisor, Telecommunications Consumers Division, Enforcement Bureau, FCC, at lisa.zaina@fcc.gov or (202) 418-2803; and cc: to Kristi Thompson, Division Chief, Telecommunications Consumers Division, Enforcement Bureau, FCC, at kristi.thompson@fcc.gov and Monica Echevarria, Attorney Advisor, 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 47 CFR § 1.17. See also 47 CFR § 1.16 (describing the format of 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. Call Blocking Safe Habor Report and Order, 35 FCC Rcd 7614; 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 prov ide 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 monica.echevarria@fcc.gov. A copy of this letter has been sent to the Traceback Consortium. Sincerely, Loyaan A. Egal Acting Bureau Chief Enforcement Bureau Federal Communications Commission 3 ATTACHMENT A Customer Date of Call Date of ITG Caller ID Called Number Description Violation Notification Skytel Digicom Dec 03, 2021 Dec 07, 2021 Amazon- 47 USC 15:18 UTC 17:10 UTC AuthorizeOrder 227(b); 47 CFR 64.1200(a) Twiching Dec 07, 2021 Dec 08, 2021 SSA-KindlyPressOne 47 USC 14:31 UTC 18:29 UTC 227(b); 47 CFR 64.1200(a) Skycall Services - India Dec 07, 2021 Dec 09, 2021 Amazon- 47 USC 12:55 UTC 21:32 UTC SuspiciousCharge 227(b); 47 CFR 64.1200(a) Skycall Services - India Dec 09, 2021 Dec 10, 2021 Amazon- 47 USC 18:38 UTC 19:19 UTC SuspiciousCharge 227(b); 47 CFR 64.1200(a) Skycall Services - India Dec 09, 2021 Dec 10, 2021 Amazon- 47 USC 16:54 UTC 21:12 UTC SuspiciousCharge-P1 227(b); 47 CFR 64.1200(a) Skycall Services - India Dec 09, 2021 Dec 10, 2021 Amazon- 47 USC 22:57 UTC 20:02 UTC SuspiciousCharge-P1 227(b); 47 CFR 64.1200(a) Skytel Digicom Dec 09, 2021 Dec 10, 2021 Amazon- 47 USC 21:08 UTC 20:15 UTC SuspiciousCharge-P1 227(b); 47 CFR 64.1200(a) Skycall Services - India Dec 09, 2021 Dec 10, 2021 Amazon- 47 USC 18:14 UTC 19:58 UTC SuspiciousCharge-P1 227(b); 47 4 CFR 64.1200(a) Skytel Digicom Dec 09, 2021 Dec 10, 2021 Amazon- 47 USC 15:15 UTC 20:03 UTC SuspiciousCharge-P1 227(b); 47 CFR 64.1200(a) Skycall Services - India Dec 09, 2021 Dec 10, 2021 Amazon- 47 USC 13:06 UTC 20:00 UTC SuspiciousCharge-P1 227(b); 47 CFR 64.1200(a) Skycall Services - India Dec 09, 2021 Dec 10, 2021 Amazon- 47 USC 19:03 UTC 20:11 UTC SuspiciousCharge-P1 227(b); 47 CFR 64.1200(a) Skytel Digicom Dec 09, 2021 Dec 10, 2021 Amazon- 47 USC 17:18 UTC 20:39 UTC SuspiciousCharge-P1 227(b); 47 CFR 64.1200(a) Skycall Services - India Dec 09, 2021 Dec 12, 2021 Amazon- 47 USC 16:10 UTC 02:22 UTC SuspiciousCharge-P1 227(b); 47 CFR 64.1200(a) Skycall Services - India Dec 09, 2021 Dec 13, 2021 Amazon- 47 USC 15:26 UTC 13:18 UTC SuspiciousCharge-P1 227(b); 47 CFR 64.1200(a) Evenvoip Telecom Dec 10, 2021 Dec 13, 2021 Amazon- 47 USC 22:42 UTC 18:30 UTC AuthorizeOrder 227(b); 47 CFR 64.1200(a) Skycall Services - India Dec 10, 2021 Dec 14, 2021 Amazon- 47 USC 12:52 UTC 20:51 UTC SuspiciousCharge 227(b); 47 CFR 64.1200(a) Skycall Services - India Dec 09, 2021 Dec 14, 2021 Amazon- 47 USC 20:11 UTC 17:30 UTC SuspiciousCharge 227(b); 47 5 CFR 64.1200(a) Skycall Services - India Dec 09, 2021 Dec 14, 2021 Amazon- 47 USC 20:14 UTC 12:53 UTC SuspiciousCharge 227(b); 47 CFR 64.1200(a) Softtop Limited Dec 19, 2021 Dec 20, 2021 Amazon- 47 USC 18:37 UTC 15:37 UTC AuthorizeOrder 227(b); 47 CFR 64.1200(a) Softtop Limited Dec 19, 2021 Dec 20, 2021 Amazon- 47 USC 18:32 UTC 18:11 UTC AuthorizeOrder 227(b); 47 CFR 64.1200(a) Evenvoip Telecom Jan 12, 2022 Jan 13, 2022 LegalDept-Action-P1 47 USC 22:41 UTC 16:05 UTC 227(b); 47 CFR 64.1200(a) Evenvoip Telecom Jan 12, 2022 Jan 13, 2022 LegalDept-Action-P1 47 USC 21:02 UTC 18:13 UTC 227(b); 47 CFR 64.1200(a) Evenvoip Telecom Jan 12, 2022 Jan 13, 2022 LegalDept-Action-P1 47 USC 20:49 UTC 16:06 UTC 227(b); 47 CFR 64.1200(a) Evenvoip Telecom Jan 12, 2022 Jan 13, 2022 LegalDept-Action-P1 47 USC 20:54 UTC 17:12 UTC 227(b); 47 CFR 64.1200(a) Trikon Electronics Pvt. Jan 24, 2022 Feb 10, 2022 Bank-Impers-P2 47 USC Ltd. 17:43 UTC 14:19 UTC 227(b); 47 CFR 64.1200(a) 6