20554 Washington, DC To: Talal 445...To: Talal Khalid Chief Executive Officer Telcast Networks, LLC 8 The Green, STE A, Suite 7044 Dover, DE 19901 Re: Official Correspondence from

United States of AmericaFederal Communications Commission

445 12th Street, SWWashington, DC 20554

February 4, 2020

VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED

To: Talal KhalidChief Executive OfficerTelcast Networks, LLC8 The Green, STE A, Suite 7044Dover, DE 19901

Re: Official Correspondence from the Federal Communications Commission

Dear Mr. Khalid,

We are writing to encourage Telcast Networks to assist the Federal Communications Commissionin stopping the flow of malicious robocalls originating from sources outside the United States.Combatting harmful and abusive robocallers is the Commission’s top consumer protection priority.Unfortunately, many of the worst offenders originate overseas. Using “spoofed” and falsified numbers,foreign robocallers often pose as American companies, and even the U.S. government, in order to deceiveand defraud American consumers.

Over the last year, one of the most prominent phone scams has involved individualsimpersonating agents from the Social Security Administration to trick people into divulging personalinformation or transferring money.1 In addition to falsely claiming to be government representatives,these callers often use spoofing technology to make the caller ID look like a government number. Thisscam cost consumers more than $19 million in the last year.2 There is good reason to believe that most ofthese “Social Security” calls came from foreign call centers.3

Tracebacks by the USTelecom Industry Traceback Group and the Commission have found thatTelcast Networks is being used as a gateway into the United States for many apparently illegal robocallsthat originate overseas. As the point of entry for this traffic into the U.S. telephone network, TelcastNetworks is uniquely situated to assist government and industry efforts to combat apparently illegal

Office of the Inspector General, Social Security Administration, Fraud Advisory: IG Warns Public About Caller ID“Spoofing” of Social Security fraud Hotline Phone Number (2019), https://oig.ssa.gov/newsroorn/newsreleases/april 1-advisory.2 Federal Trade Commission, Growing Wave of Social Security Imposters Overtakes IRS Scam (2019),https://www.ftc.gov/news-events/hlors/data-spotlighU2o I 9/04/growing-wave-social-seeurity-imposters-overtakes-irs-scam.

Herb Weisbaum, Get a Catifrom the Social Security Administration? It’s the Latest Government Imposter Scam(July 13, 2019), https://www.nhcnews.corn/hetter/lifestyle/get-call-social-security-administration-it-s-latestgovernment-imposter-ncna 1029031; Madeline Purdue, This Is Where Robocatis Are Coming Franz (and Where The)’Are Targeting) (July 9, 2019), https://www.usatoclay.com/story/tech/2t) I 9/07/09/where-rohocalls-come-from-and-where-they-targeU 1660503001/.

robocalls. Congress recently addressed the importance of industry efforts to trace back such calls to theirorigin in the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement Deterrence Act (TRACEDAct) by directing the Commission to register a consortium to conduct private-led efforts to trace backsuspected unlawful robocalls. Congress also encouraged the Commission to take appropriateenforcement actions for voice service providers that do not participate in private-led efforts to trace backthe origin of suspected unlawful robocalls or that originate or terminate substantial amounts of unlawfulrobocalls. We encourage Telcast Networks to take measures to prevent the flow of apparently illegaltraffic originating outside the United States.

In furtherance of this objective, the Commission requests information about business practicesregarding the foreign traffic that your company carries. Pursuant to our authority under Sections 227 and403 of the Communications Act (47 U.S.C. § 227, 403), we request that you provide responses to thefollowing questions:4

1. What technical and procedural processes does Telcast Networks have in place to detect oridentify call traffic that is likely to be illegal, particularly for calls with foreign origination(e.g., detecting unusual call patterns or large call volumes)?

2. What procedures does Telcast Networks employ to ensure that the Caller ID informationassociated with foreign call traffic has not been unlawfully spoofed?

3. What percentage of your company’s traffic comes from foreign sources?

4. What percentage of your clients are located in a country other than the United States?

5. Does Telcast Networks advertise its services in foreign countries?

6. Have you taken any actions in the last six months to either terminate or restrict foreign trafficthat you suspected to be illegal?

We request your detailed response by February 17, 2020. That response should be sentelectronically to Shana Yates at [email protected].

If we hope to stop the spread of robocalls, providers and government agencies must worktogether. We encourage Telcast Networks to remain vigilant, and we will continue to monitor yourcooperation with public and private efforts to identify the actors behind foreign robocalls and take lawfulactions to thwart unwanted and unlawful traffic.

Sincerely,

F-)Ro’enary C. HavldChiefEnforcement Bureau

We are issuing this letter as a courtesy, without prejudice to our position that this information can be requested,and must be produced, pursuant to our investigative authority under sections 4(1), 4(j), 227, and 403 of the Act, 47U.S.C. § 154(i), 154(j). 227, 403. If you make any request for confidentiality of certain information or documents,you must strictly comply with the requirements of 47 CFR § 0.459, including a Statement of the reasons forwithholding the materials from inspection.

Umted States of AmericajiP(‘ 1’edera1 Communications Commission

WW’s1 445 12th Street, WWashington, DC 20554

February 4, 2020

VIA CERTIFIED MAIL - RETURN RECEIPT REOUESTED

To: Karl DouthitChief Executive OfficerPirate!, LLC10572 CaIle Lee, Suite 123Los Alarnitos, CA 90720


Dear Mr. Douthit,

We are writing to encourage Pirate] to assist the Federal Communications Commission instopping the flow of malicious robocalls originating from sources outside the United States. Combattingharmful and abusive robocallers is the Commission’s top consumer protection priority. Unfortunately,many of the worst offenders originate overseas. Using “spoofed” and falsified numbers, foreignrobocallers often pose as American companies, and even the U.S. government, in order to deceive anddefraud American consumers.

Over the last year, one of the most prominent phone scams has involved individualsimpersonating agents from the Social Security Administration to trick people into divulging personalinformation or transferring money.’ In addition to falsely claiming to be government representatives,these callers often use spoofing technology to make the caller ID look like a government number. Thisscam cost consumers more than $19 million in the last year.2 There is good reason to believe that most ofthese “Social Security” calls came from foreign call centers.3

Tracebacks by the USTelecom Industry Traceback Group and the Commission have found thatPirate! is being used as a gateway into the United States for many apparently illegal robocalls thatoriginate overseas. As the point of entry for this traffic into the U.S. telephone network, Piratel isuniquely situated to assist government and industry efforts to combat apparently illegal robocalls.

Office of the Inspector General, Social Security Administration, Fraud Advisory: IG Warns Public About Caller ID“Spoofing” of Social Security Fraud Hotline Phone Number (2019), https://oi.ssa.gov/newsroom/newsreleases/april 1-advisory.2 federal Trade Commission, Growing Wave of Social Security Imposters Overtakes IRS Scam (2019),https://www.ftcgov/news-events/blois/data-spotlightJ20 I 9/04/erowing-wave-social-security-imposters-overtakes-irs-scam.

Herb Weisbaum, Get a Call from the Social Security Administration? It’s the Latest Government Imposter Scam(July 13, 2019).overnment-imposter-ncnal02903l; Madeline Purdue, This Is Where Robocalls Are Coining from (and Where TheyAre Targeting) (July 9, 2019), https://www.usatoday.com/story/tech/20 I 9/07/09/where-rohocalls-come-from-and-where-they-target! I 660503f)t) 1/.

Congress recently addressed the importance of industry efforts to trace back such calls to their origin inthe Pa]lone-Thune Telephone Robocall Abuse Criminal Enforcement Deterrence Act (TRACED Act) bydirecting the Commission to register a consortium to conduct private-led efforts to trace back suspectedunlawful robocalls. Congress also encouraged the Commission to take appropriate enforcement actionsfor voice service providers that do not participate in private-led efforts to trace back the origin ofsuspected unlawful robocalls or that originate or terminate substantial amounts of unlawful robocalls. Weencourage Piratel to take measures to prevent the flow of apparently illegal traffic originating outside theUnited States.


1. What technical and procedural processes does Piratel have in place to detect or identify calltraffic that is likely to be illegal, particularly for calls with foreign origination (e.g., detectingunusual call patterns or large call volumes)?

2. What procedures does Piratel employ to ensure that the Caller ID information associated withforeign call traffic has not been unlawfully spoofed?



5. Does Piratel advertise its services in foreign countries?



If we hope to stop the spread of robocalls, providers and government agencies must worktogether. We encourage Piratel to remain vigilant, and we will continue to monitor your cooperation withpublic and private efforts to identify the actors behind foreign robocalls and take lawful actions to thwartunwanted and unlawful traffic.

Sincerely,

Roary C. HoldChiefEnforcement Bureau

We are issuing this letter as a courtesy, without prejudice to our position that this information can be requested,and must be produced, pursuant to our investigative authority under sections 4(1). 4(j), 227, and 403 of the Act, 47U.S.C. § 154(i), 154(j), 227, 403. If you make any request for confidentiality of certain information or documents,you must strictly comply with the requirements of 47 CFR § 0.459, including a statement of the reasons forwithholding the materials from inspection.

United States of America

r( ) Federal Communications Commission445 12th Street, SW

Washington, DC 20554

February 4, 2020


To: Aaron LeonChief Executive OfficerThinQ, Inc.5420 Wade Park, Suite 100Raleigh, NC 27607


Dear Mr. Leon,

We are writing to encourage ThinQ to assist the Federal Communications Commission instopping the flow of malicious robocalls originating from sources outside the United States. Combattingharmful and abusive robocallers is the Commission’s top consumer protection priority. Unfortunately,many of the worst offenders originate overseas. Using “spoofed” and falsified numbers, foreignrobocallers often pose as American companies, and even the U.S. government, in order to deceive anddefraud American consumers.


Tracebacks by the USTelecom Industry Traceback Group and the Commission have found thatThinQ is being used as a gateway into the United States for many apparently illegal robocalls thatoriginate overseas. As the point of entry for this traffic into the U.S. telephone network, ThinQ isuniquely situated to assist government and industry efforts to combat apparently illegal robocalls.

Office of the Inspector General, Social Security Administration, Fraud Advisory: IG Warns Public About Caller ID“Spoofing” of Social Security Fraud Hotline Phone Number (2019). https://oig.ssa.gov/newsroom/newsreleases/april I-advisory.2 Federal Trade Commission, Growing Wave of Social Security Imposters Overtakes IRS Scam (2019),https://www.ftc.ov/news-events/hlogs/data-spotlighiI2() I 9/t)4/growing-wave-social-security-irnposters-overtakes-irs-scam.

Herb Weisbaum, Get a Cattfrom the Social Security Administration? It’s the Latest Government Imposter Scam(July 13, 2019), https://www.nhcnews.com/hetter/lifestyle/get-catl-social-security-adrninistration-it-s-latestgovernment-imposter-ncnalO29O3l; Madeline Purdue, This Is Where Robocalls Are Coming From (and Where TheyAre Targeting) (July 9, 2019), https://www.usatoday.com/story/tech/2() I 9/07/09/where-rohocalls-come-frorn-and-where-thev-tareetll 66050300 1/.

Congress recently addressed the importance of industry efforts to trace back such calls to their origin inthe Pallone-Thune Telephone Robocall Abuse Criminal Enforcement Deterrence Act (TRACED Act) bydirecting the Commission to register a consortium to conduct private-led efforts to trace back suspectedunlawful robocalls. Congress also encouraged the Commission to take appropriate enforcement actionsfor voice service providers that do not participate in private-led efforts to trace back the origin ofsuspected unlawful robocalls or that originate or terminate substantial amounts of unlawful robocalls. Weencourage ThinQ to take measures to prevent the flow of apparently illegal traffic originating outside theUnited States.


1. What technical and procedural processes does ThinQ have in place to detect or identify calltraffic that is likely to be illegal, particularly for calls with foreign origination (e.g., detectingunusual call patterns or large call volumes)?

2. What procedures does ThinQ employ to ensure that the Caller ID information associated withforeign call traffic has not been unlawfully spoofed?



5. Does ThinQ advertise its services in foreign countries?



If we hope to stop the spread of robocalls, providers and government agencies must worktogether. We encourage ThinQ to remain vigilant, and we will continue to monitor your cooperation withpublic and private efforts to identify the actors behind foreign robocalls and take lawful actions to thwartunwanted and unlawful traffic.

Sincerely,

Ros mary C./-IaroldChiefEnforcement Bureau

‘ We are issuing this letter as a courtesy, without prejudice to our position that this information can be requested,and must be produced, pursuant to our investigative authority under sections 4(i), 4(j), 227, and 403 of the Act, 47U.S.C. § 154(i), 154(j), 227, 403. If you make any request for confidentiality of certain information or documents,you must strictly comply with the requirements of 47 CFR § 0.459, including a statement of the reasons forwithholding the materials from inspection.



February 4, 2020


To: Andrew DeMattiaChief Executive OfficerTalkie Communications, Inc. U/b/a Talkie Fiber99 Talhot BlvdChestertown, MD 21620


Dear Mr. DeMattia,

We are writing to encourage Talkie Communications to assist the Federal CommunicationsCommission in stopping the flow of malicious robocalls originating from sources outside the UnitedStates. Combatting harmful and abusive robocallers is the Commission’s top consumer protectionpriority. Unfortunately, many of the worst offenders originate overseas. Using “spoofed” and falsifiednumbers, foreign robocallers often pose as American companies, and even the U.S. government, in orderto deceive and defraud American consumers.

Over the last year, one of the most prominent phone scams has involved individualsimpersonating agents from the Social Security Administration to trick people into divulging personalinformation or transferring money) In addition to falsely claiming to be government representatives,these callers often use spoofing technology to make the caller ID look like a government number. Thisscam cost consumers more than $19 million in the last year.2 There is good reason to believe that most ofthese “Social Security” calls came from foreign call centers.3

Tracebacks by the USTelecom Industry Traceback Group and the Commission have found thatTalkie Communications is being used as a gateway into the United States for many apparently iLlegalrobocalls that originate overseas. As the point of entry for this traffic into the U.S. telephone network,Talkie Communications is uniquely situated to assist government and industry efforts to combat

Office of the Inspector General, Social Security Administration, Fraud Advisory: IG Warns Public About Caller ID“Spoofing” of Social Security fraud Hotline Phone Number (2019), https://oig.ssa.gov/newsroom/newsreleases/april 1-advisory2 Federal Trade Commission, Growing Wave of Social Security Imposters Overtakes IRS Scam (2019),https://www.ftc.gov/news-events/blogs/data-spotliht]20 I 9/O4flzrowing-wave-social-security-imposters-overtakes-irs-scam.

Herb Weisbaum, Get a Call from the Social Security Administration? It’s the Latest Government Imposter Scam(July 13, 2019), https://www.nhcnews.com/hetter/lifestyle/get-calI-social-security-administration-it-s-latestovernment-imposter-ncnal02903l; Madeline Purdue, This Is Where Robocalls Are Coining From (and Where TheyAre Targeting) (July 9, 2019), https://www.usatoday.com/story/tech/20 I 9/07/09/where-rohocalls-come-from-and-where-they-target] 1660503001/.

apparently illegal robocalls. Congress recently addressed the importance of industry efforts to trace backsuch calls to their origin in the Pallone-Thune Telephone Robocall Abuse Criminal EnforcementDeterrence Act (TRACED Act) by directing the Commission to register a consortium to conduct private-led efforts to trace back suspected unlawful robocalls. Congress also encouraged the Commission to takeappropriate enforcement actions for voice service providers that do not participate in private-led efforts totrace back the origin of suspected unlawful robocalls or that originate or terminate substantial amounts ofunlawful robocalls. We encourage Talkie Communications to take measures to prevent the flow ofapparently illegal traffic originating outside the United States.


1. What technical and procedural processes does Talkie Communications have in place to detector identify call traffic that is likely to be illegal, particularly for calls with foreign origination(e.g., detecting unusual call patterns or large call volumes)?

2. What procedures does Talkie Communications employ to ensure that the Caller IDinformation associated with foreign call traffic has not been unlawfully spoofed?



5. Does Talkie Communications advertise its services in foreign countries?



If we hope to stop the spread of robocalls, providers and government agencies must worktogether. We encourage Talkie Communications to remain vigilant, and we will continue to monitor yourcooperation with public and private efforts to identify the actors behind foreign robocalls and take lawfulactions to thwart unwanted and unlawful traffic.

Sincerely,

Roseriary C. aroldChief’Enforcement Bureau

‘ We are issuing this letter as a courtesy, without prejudice to our position that this information can be requested,and must be produced, pursuant to our investigative authority under sections 4(i), 4(j), 227, and 403 of the Act, 47U.S.C. § 154(i), 154(j), 227, 403. If you make any request for confidentiality of certain information or documents,you must strictly comply with the requirements of 47 CFR § 0.459, including a statement of the reasons forwithholding the materials from inspection.

Unfed States of AmericaEcdciaI Communications Commission


February 4, 2020


To: Lamar CarterChief Executive OfficerAll Access Telecom, Inc.771 E U.S. Highway 80, Suite 201Forney, TX 75126


Dear Mr. Carter,

We are writing to encourage All Access Telecom to assist the Federal CommunicationsCommission in stopping the flow of malicious robocalls originating from sources outside the UnitedStates. Combatting harmful and abusive robocallers is the Commission’s top consumer protectionpriority. Unfortunately, many of the worst offenders originate overseas. Using “spoofed” and falsifiednumbers, foreign robocallers often pose as American companies, and even the U.S. government, in orderto deceive and defraud American consumers.


Tracebacks by the USTelecom Industry Traceback Group and the Commission have found thatAll Access Telecom is being used as a gateway into the United States for many apparently illegalrobocalls that originate overseas. As the point of entry for this traffic into the U.S. telephone network, AllAccess Telecom is uniquely situated to assist government and industry efforts to combat apparently

1 Office of the Inspector General, Social Security Administration, Fraud Advisory: IG Warns Public About Caller ID“Spoofing” of Social Security Fraud Hotline Phone Number (2019), https://oig.ssa. gov/newsroom/newsreleases/april 1-advisory.2 Federal Trade Commission, Growing Wave of Social Security Imposters Overtakes IRS Scam (2019),https://www.ftc.gov/news-events/blogs/data-spotlighU20 I 9/04/growing-wave-social-security-imposters-overtakes-irs-scam.

Herb Weisbaum, Get a Callfrom the Social Securiry Administration? It’s the Latest Government Imposter Scam(July 13, 2019),government-irnposter-ncnal 029031; Madeline Purdue, This Is Where Robocalls Are Coining From (and Where TheyAre Targeting) (July 9, 2019), https://www.usatoday.com/story/tech/20 I 9/07/09/where-rohocalls-come-from-and-where-thev-tareU 1660503001/.

illegal robocalls. Congress recently addressed the importance of industry efforts to trace back such callsto their origin in the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement Deterrence Act(TRACED Act) by directing the Commission to register a consortium to conduct private-led efforts totrace back suspected unlawful robocalls. Congress also encouraged the Commission to take appropriateenforcement actions for voice service providers that do not participate in private-led efforts to trace backthe origin of suspected unlawful robocalls or that originate or terminate substantial amounts of unlawfulrobocalls. We encourage All Access Telecom to take measures to prevent the flow of apparently illegaltraffic originating outside the United States.


1. What technical and procedural processes does All Access Telecom have in place to detect oridentify call traffic that is likely to be illegal, particularly for calls with foreign origination(e.g., detecting unusual call patterns or large call volumes)?

2. What procedures does All Access Telecom employ to eisure that the Caller ID informationassociated with foreign call traffic has not been unlawfully spoofed?



5. Does All Access Telecom advertise its services in foreign countries?



If we hope to stop the spread of robocalls, providers and government agencies must worktogether. We encourage All Access Telecom to remain vigilant, and we will continue to monitor yourcooperation with public and private efforts to identify the actors behind foreign robocalls and take lawfulactions to thwart unwanted and unlawful traffic.

Sincerely,

RoLLdChEnforcement Bureau

We are issuing this letter as a courtesy, without prejudice to our position that this information can be requested,and must be produced, pursuant to our investigative authority under sections 4(1), 4(j), 227, and 403 of the Act, 47U.S.C. § 154(i), 154(j), 227, 403. If you make any request for confidentiality of certain information or documents,you must strictly comply with the requirements of 47 CFR § 0.459, including a statement of the reasons forwithholding the materials from inspection.



February 4, 2020


To: Mark SaccenteChief Operating OfficerThird Base International Telecom LLC3949 Evans Avenue, Suite 301BFort Myers, FL 33901


Dear Mr. Saccente,

We are writing to encourage Third Base to assist the Federal Communications Commission instopping the flow of malicious robocalls originating from sources outside the United States. Combattingharmful and abusive robocallers is the Commission’s top consumer protection priority. Unfortunately,many of the worst offenders originate overseas. Using “spoofed” and falsified numbers, foreignrobocallers often pose as American companies, and even the U.S. government, in order to deceive anddefraud American consumers.


Tracebacks by the USTelecom Industry Traceback Group and the Commission have found thatThird Base is being used as a gateway into the United States for many apparently illegal robocalls thatoriginate overseas. As the point of entry for this traffic into the U.S. telephone network, Third Base isuniquely situated to assist government and industry efforts to combat apparently illegal robocalls.

Office of the Inspector General, Social Security Administration, Fraud Advisory: IG Warns Public About Caller ID“Spooling” of Social Security Fraud Hottine Phone Number (2019), https://oi.ssa.gov/newsroom/newsreleases/april I-advisory.2 Federal Trade Commission, Growing Wave of Social Security Imposters Overtakes IRS Scam (2019),https://www.tic.gov/news-events/blogs/data-spotlighU20 I 9/04/uowing-wave-social-security-imposters-overtakes-irs-scam.

Herb Weisbaum, Get a Call from the Social Security Administration? It’s the Latest Government Imposter Scam(July 13, 2019), https://www.nbcnews.com/better/lifestyle/get-catl-social-security-administration-it-s-latestgovernment-imposter-ncna1029031; Madeline Purdue, This Is Where Robocalls Are Coining From (and Where TheyAre Targeting) (July 9, 2019), https://www.usatoday.com/story/tech/20 I 9/07/09/where-robocalls-come-frorn-and-where-they-target.t 1 660503001/.

Congress recently addressed the importance of industry efforts to trace back such calls to their origin inthe Pallone-Thune Telephone Robocall Abuse Criminal Enforcement Deterrence Act (TRACED Act) bydirecting the Commission to register a consortium to conduct private-led efforts to trace back suspectedunlawful robocalls. Congress also encouraged the Commission to take appropriate enforcement actionsfor voice service providers that do not participate in private-led efforts to trace back the origin ofsuspected unlawful robocalls or that originate or terminate substantial amounts of unlawful robocalls. Weencourage Third Base to take measures to prevent the flow of apparently illegal traffic originating outsidethe United States.


1. What technical and procedural processes does Third Base have in place to detect or identifycall traffic that is likely to be illegal, particularly for calls with foreign origination (e.g.,detecting unusual call patterns or large call volumes)?

2. What procedures does Third Base employ to ensure that the Caller ID information associatedwith foreign call traffic has not been unlawfully spoofed?



5. Does Third Base advertise its services in foreign countries?



If we hope to stop the spread of robocalls, providers and government agencies must worktogether. We encourage Third Base to remain vigilant, and we will continue to monitor your cooperationwith public and private efforts to identify the actors behind foreign robocalls and take lawful actions tothwart unwanted and unlawful traffic.

Sincerely,

Ros ary C. aroldChiefEnforcement Bureau

We are issuing this letter as a courtesy, without prejudice to our position that this information can be requested,and must be produced, pursuant to our investigative authority under sections 4(i), 4(j), 227, and 403 of the Act, 47U.S.C. § 154(i), 154(j). 227, 403. If you make any request for confidentiality of certain information or documents,you must strictly comply with the requirements of 47 CFR § 0.459, including a statement of the reasons forwithholding the materials from inspection.

United states of AmericaFecic:1 Communications Commission


February 4, 2020


To: Globex TelecomdoBrick KanePresidentRobb Evans & Associates LLC11450 Sheldon StreetSun Valley, CA 91352-1121

Re: Official Correspondence from the federal Communications Commission

Dear Mr. Kane,

We are writing to encourage Globex Telecom to assist the Federal Communications Commissionin stopping the flow of malicious robocalls originating from sources outside the United States.Combatting harmful and abusive robocallers is the Commission’s top consumer protection priority.Unfortunately, many of the worst offenders originate overseas. Using “spoofed” and falsified numbers,foreign robocallers often pose as American companies, and even the U.S. government, in order to deceiveand defraud American consumers.


Tracebacks by the USTelecom Industry Traceback Group and the Commission have found thatGlobex Telecom is being used as a gateway into the United States for many apparently illegal robocalls

‘Office of the Inspector General, Social Security Administration, Fraud Advisory: IG Warns Public About Caller ID“Spoofing” of Social Security Fraud Hotline Phone Number (2019), https:/Ioig.ssa.gov/newsroornlnewsreleases/april 1-advisory.2 Federal Trade Commission, Growing Wave of Social Security Imposters Overtakes IRS Scam (2019),https://www.ftc.gov/news-events/blogs/data-spotlight]2t) I 9/04/erowing-wave-social-security-imposters-overtakes-irs-scam.

Herb Weisbaum, Get a Callfrom the Social Security Administration? It’s the Latest Government Imposter Scam(July 13, 2019), https://www.nhcnews.com/hetter/lifestyle/get-call-social-security-adrninistration-jt-s-latestgovernment-imposter-ncnalO29O3l; Madeline Purdue, This Is Where Robocalts Are Coining From (and Where TheyAre Targeting) (July 9, 2019), https://www.usatoday.com/story/tech/2t) I 9/07/09/where-rohocalls-come-from-and-where-thev-tareet/l 660503001/.

d

that originate overseas. As the point of entry for this traffic into the U.S. telephone network, GlobexTelecom is uniquely situated to assist government and industry efforts to combat apparently illegalrobocalls. Congress recently addressed the importance of industry efforts to trace back such calls to theirorigin in the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement Deterrence Act (TRACEDAct) by directing the Commission to register a consortium to conduct private-led efforts to trace backstispected unlawful robocalls. Congress also encouraged the Commission to take appropriateenforcement actions for voice service providers that do not participate in private-led efforts to trace backthe origin of suspected unlawfu] robocalls or that originate or terminate substantial amounts of unlawfulrobocalls. We encourage Globex Telecom to take measures to prevent the flow of apparently illegaltraffic originating outside the United States.


1. What technical and procedural processes does Globex Telecom have in place to detect oridentify call traffic that is likely to be illegal, particularly for calls with foreign origination(e.g., detecting unusual call pattems or large call volumes)?

2. What procedures does Globex Telecom employ to ensure that the Caller ID informationassociated with foreign call traffic has not been unlawfully spoofed?


4. What percentage of your c]ients are located in a country other than the United States?

5. Does Globex Telecom advertise its services in foreign countries?



If we hope to stop the spread of robocalls, providers and government agencies must worktogether. We encourage Globex Telecom to remain vigilant, and we will continue to monitor yourcooperation with public and private efforts to identify the actors behind foreign robocalls and take lawfulactions to thwart unwanted and unlawful traffic.

Sincerely,

HRosmary C. I4aroldChiefEnforcement Bureau

We are issuing this letter as a courtesy, without prejudice to our position that this information can be requested,and must be produced, pursuant to our investigative authority under sections 4(1), 4(j), 227, and 403 of the Act, 47U.S.C. § 154(i), 154(j), 227, 403. If you make any request for confidentiality of certain information or documents,you must strictly comply with the requirements of 47 CFR § 0.459, including a statement of the reasons forwithholding the materials from inspection.

Documents

20554 Washington, DC To: Talal 445...To: Talal Khalid Chief Executive Officer Telcast Networks, LLC 8 The Green, STE A, Suite 7044 Dover, DE 19901 Re: Official Correspondence from