Case 6:22-cv-00798-PGB-GJK Document 1 Filed 04/26/22 Page 1 of 27 PageID 1
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`UNITED STATES DISTRICT COURT
`IN THE MIDDLE DISTRICT OF FLORIDA
`ORLANDO DIVISION
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`Plaintiff,
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`v.
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`Defendants.
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`
`
` Case No. ____________
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`
` COMPLAINT FOR PERMANENT
` INJUNCTION, CIVIL PENALTIES,
` AND OTHER RELIEF
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`UNITED STATES OF AMERICA,
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`VOIP TERMINATOR, INC., a corporation,
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`BLMARKETING, INC., a corporation, and
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`
`MUHAMMAD USMAN KHAN, individually and
`as an officer of VOIP TERMINATOR, INC. and
`BLMARKETING, INC.,
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`
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`Plaintiff, the United States of America, acting upon notification and authorization to the
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`
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`Attorney General by the Federal Trade Commission (“FTC”), pursuant to Section 16(a)(1) of the
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`Federal Trade Commission Act (“FTC Act”), 15 U.S.C. § 56(a)(1), for its Complaint alleges:
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`1.
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`Plaintiff brings this action under Sections 5(a), 5(m)(1)(A), 13(b) and 16(a) of the
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`FTC Act, 15 U.S.C. §§ 45(a), 45(m)(1)(A), 53(b) and 56(a), and Section 6 of the Telemarketing
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`and Consumer Fraud and Abuse Prevention Act (“Telemarketing Act”), 15 U.S.C. § 6105, which
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`authorize the FTC to seek, and the Court to order, permanent injunctive relief, monetary relief,
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`and other equitable relief from Defendants for their violations of Section 5(a) of the FTC Act, 15
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`U.S.C. § 45(a), and the FTC’s Telemarketing Sales Rule (“TSR” or “Rule”), as amended, 16
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`C.F.R. Part 310.
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`SUMMARY OF CASE
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`2.
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`At all times material to this Complaint, Defendants provided Voice over Internet
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`Protocol (“VoIP”) services, which enable transmission of telephone calls over the internet.
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`3.
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`Defendants assisted and facilitated violations of the TSR by continuing to
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`provide VoIP services to their customers even after knowing or consciously avoiding knowing
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`their customers were using Defendants’ services to initiate calls that: (a) were placed to
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`numbers on the National Do Not Call Registry; (b) delivered prerecorded messages; and (c)
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`displayed spoofed caller ID numbers, including providing services to callers perpetrating scams
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`related to credit card interest rate reduction, tech support, and the COVID-19 pandemic.
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`JURISDICTION AND VENUE
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`4.
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`This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a),
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`and 1345.
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`5.
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`Venue is proper in this District under 28 U.S.C. § 1391 (b)(2), (c)(2), (c)(3), and
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`(d), and 15 U.S.C. § 53(b).
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`DEFENDANTS
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`6.
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`Defendant VoIP Terminator, Inc. (“VoIP Terminator”) is a former Florida
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`corporation with its principal place of business at 250 International Parkway, Suite 108, Lake
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`Mary, FL 32746. It was dissolved on May 25, 2021. VoIP Terminator transacted business in this
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`District and throughout the United States.
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`7.
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`VoIP Terminator was an interconnected VoIP service provider. As an
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`interconnected VoIP service provider, VoIP Terminator provided information services pursuant
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`to 47 U.S.C. § 153 of the Communications Act of 1934, as amended.
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`8.
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`Defendant BLMarketing, Inc. (“BLMarketing”) is a former Virginia corporation
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`with its principal place of business at 6564 Loisdale Road, Suite 600-D, Springfield, VA 22150.
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`It was administratively terminated on January 31, 2020. BLMarketing transacted business in this
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`District and throughout the United States.
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`9.
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`Defendant Muhammad Usman Khan (“Khan”) is the founder, sole owner, and
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`president of VoIP Terminator and the founder, sole owner, and director of BLMarketing. At all
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`times relevant to this Complaint, acting alone or in concert with others, he has formulated,
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`directed, controlled, had the authority to control, or participated in the acts and practices of VoIP
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`Terminator and BLMarketing, including the acts and practices set forth in this Complaint.
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`Defendant Khan resides in Islamabad, Pakistan, and in connection with the matters alleged
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`herein, transacts or has transacted business in this District and throughout the United States.
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`COMMON ENTERPRISE
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`10.
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`Defendants BLMarketing and VoIP Terminator (collectively, “Corporate
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`Defendants”) have operated as a common enterprise while engaging in the unlawful acts and
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`practices and other violations of law alleged below. Corporate Defendants have conducted the
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`business practices described below through interrelated companies that have common ownership,
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`officers, managers, business functions, employees, and addresses. Because these Corporate
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`Defendants have operated as a common enterprise, each of them is liable for the acts and
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`practices alleged below.
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`COMMERCE
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`11. At all times relevant to this Complaint, Defendants have maintained a substantial
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`course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act,
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`15 U.S.C. § 44.
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`THE TELEMARKETING SALES RULE
`AND THE NATIONAL DO NOT CALL REGISTRY
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`12.
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`In 1994, Congress directed the FTC to prescribe rules prohibiting abusive and
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`deceptive telemarketing acts or practices pursuant to the Telemarketing Act, 15 U.S.C. §§
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`61016108. The FTC adopted the original TSR in 1995, extensively amended it in 2003, and
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`amended certain provisions thereafter. 16 C.F.R. Part 310.
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`13.
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`Among other things, the 2003 amendments to the TSR established a do not call
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`registry, maintained by the FTC (the “National DNC Registry” or “Registry”), of consumers who
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`do not wish to receive certain types of telemarketing calls. Consumers can register their
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`telephone numbers on the Registry without charge either through a toll-free telephone call or
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`online at donotcall.gov.
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`14.
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`Consumers who receive telemarketing calls to their registered numbers can
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`complain of Registry violations the same way they registered, through a toll-free telephone call
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`or online at donotcall.gov, or by otherwise contacting law enforcement authorities.
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`15.
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`The TSR defines “telemarketing” as a plan, program or campaign which is
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`conducted to induce the purchase of goods or services or a charitable contribution, by use of one
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`or more telephones and which involves more than one interstate telephone call. 16 C.F.R. §
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`310.2(gg).
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`16.
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`Under the TSR, a “telemarketer” is any person who, in connection with
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`telemarketing, initiates or receives telephone calls to or from a customer or donor. 16 C.F.R. §
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`310.2(ff).
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`17.
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`A “seller” means any person who, in connection with a telemarketing transaction
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`provides, offers to provide, or arranges for others to provide goods or services to the customer in
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`exchange for consideration. 16 C.F.R. § 301.2(dd).
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`18.
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`The FTC allows sellers, telemarketers, and other permitted organizations to access
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`the Registry online at telemarketing.donotcall.gov, to pay any required fee(s), and to download
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`the numbers not to call.
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`19.
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`Under the TSR, an “outbound telephone call” means a telephone call initiated by
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`a telemarketer to induce the purchase of goods or services or to solicit a charitable contribution.
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`16 C.F.R. § 310.2(x).
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`20.
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`The TSR prohibits sellers and telemarketers from initiating an outbound telephone
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`call to numbers on the Registry. 16 C.F.R. § 310.4(b)(1)(iii)(B).
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`21.
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`As amended, effective September 1, 2009, the TSR prohibits initiating an
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`outbound telephone call that delivers a prerecorded message to induce the purchase of any good
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`or service. 16 C.F.R. § 310.4(b)(1)(v). Calls delivering prerecorded messages are commonly
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`called “robocalls.”
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`22.
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`The TSR requires that sellers and telemarketers transmit or cause to be
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`transmitted the telephone number of the telemarketer and, when made available by the
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`telemarketer’s carrier, the name of the telemarketer (“caller ID information”), to any caller
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`identification service in use by a recipient of a telemarketing call, or transmit the customer
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`service number of the seller on whose behalf the call is made and, when made available by the
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`telemarketer’s carrier, the name of the seller. 16 C.F.R. § 310.4(a)(8). Transmitting inaccurate
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`caller ID information, or causing inaccurate caller ID information to be transmitted, violates the
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`TSR and is commonly called “spoofing.”
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`23.
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`It is a violation of the TSR for any person to provide substantial assistance or
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`support to any seller or telemarketer when that person knows or consciously avoids knowing that
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`the seller or telemarketer is engaged in any practice that violates Sections 310.3(a), (c) or (d) or
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`310.4 of the TSR. 16 C.F.R. § 310.3(b).
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`24.
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`Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), and
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`Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation of the TSR constitutes an
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`unfair or deceptive act or practice in or affecting commerce, in violation of Section 5(a) of the
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`FTC Act, 15 U.S.C. § 45(a).
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`25.
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`Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), and Section 18(d)(3)
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`of the FTC Act, 15 U.S.C. § 57a(d)(3) authorize this Court to award monetary civil penalties of
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`not more than $43,792 for each violation of the Telemarketing Sales Rule assessed after January
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`13, 2021, including penalties whose associated violation predated January 13, 2021.
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`26.
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`Defendants’ violations of the TSR set forth below were committed with the
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`knowledge required by Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A).
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`DEFENDANTS’ BUSINESS ACTIVITIES
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`27.
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`Voice over Internet Protocol is technology that allows a person to make voice
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`calls using a broadband internet connection instead of a regular (analog) phone line. In other
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`words, VoIP calls are phone calls that are sent and received over the internet. Telemarketers who
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`blast illegal prerecorded calls and other marketing calls to millions of American consumers
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`typically use VoIP service providers to transmit those calls. Multiple VoIP providers typically
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`participate in transmitting a given call from its originator (often a telemarketer) to a termination
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`point (most often a consumer’s telephone).
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`28.
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`Defendants were nationwide providers of VoIP services, including “origination”
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`and “termination” services. Origination is beginning the transmission of a call from the
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`telemarketer or company who initiated it; termination is sending the call to its ultimate
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`destination. Defendants also served as a mid-stream providers, transmitting calls from and to
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`other VoIP providers.
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`29.
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`In addition to transmitting calls, VoIP Terminator provided Interexchange carrier
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`services, which give companies the ability to purchase VoIP lines ultimately destined for phone
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`numbers in the United States, and the ability to sell those VoIP lines to their customers, such as
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`telemarketing call centers.
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`30.
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`Defendants conducted most of their business from Pakistan. Their business in
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`Pakistan began over a decade ago. A 2020 copy of the Defendants’ website
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`(www.voipterminator.com.pk) declared that VoIP Terminator has provided “call center
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`solutions” since 2007. The website also claimed that VoIP Terminator had “offices in all major
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`cities of Pakistan,” and that VoIP Terminator was a “leading global provider of wholesale VoIP
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`services to businesses big and small seeking to gain a premium international reach at an
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`incredibly low cost.” Moreover, the website said, “VoIP Terminator has been producing
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`residential solar sales leads since 2012,” and that VoIP Terminator “generate[d] leads in all 50
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`states, Canada and Australia.”
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`31.
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`Defendants’ business activities in the United States began when Defendant Khan
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`created BLMarketing in 2015. BLMarketing originally sold internet marketing services, such as
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`search engine optimization, to its customers; it later transitioned to providing VoIP services.
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`When he created BLMarketing, Khan, a citizen and resident of Pakistan, provided a U.S. mail
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`drop address for himself and the corporation: 5900 Barclay Dr., Box 150261, Alexandria,
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`Virginia 22315. Khan also purchased a virtual address: 6564 Loisdale Court, Suite 600-D,
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`Springfield, VA 22150. Khan used these addresses to open depository accounts for
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`BLMarketing.
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`32.
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`Khan was BLMarketing’s sole employee. At all times relevant to this Complaint,
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`Khan conducted BLMarketing’s business operations online from Pakistan. Khan’s sister (who
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`was also BLMarketing’s Registered Agent) and nephew occasionally picked up mail for
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`BLMarketing in Virginia, and Khan’s sister would send it to Khan in Pakistan.
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`33.
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`In about 2018, Khan began to transition BLMarketing’s business: he started
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`offering VoIP services to call center customers. At about the same time, Khan created VoIP
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`Terminator in Florida. Khan designated himself as President, his wife as Vice President, and
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`Tahir Malik (“Malik”) as Registered Agent of VoIP Terminator. Malik was an acquaintance of
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`Khan’s who helped Khan incorporate and run VoIP Terminator in Florida.
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`34.
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`Khan intended VoIP Terminator to enter into contracts to buy VoIP lines from
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`larger carriers, and then sell access to those VoIP lines to offshore call center customers. VoIP
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`Terminator’s call center customers would then use those VoIP lines as a U.S. point of entry for
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`the call centers’ telemarketing calls.
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`35.
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`Khan traveled to Florida in April 2018 to set up an office and bank accounts for
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`VoIP Terminator.
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`36. Malik located and leased office space at 250 International Parkway, Suite 108,
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`Lake Mary, Florida. Both Malik’s and Khan’s names were on the lease.
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`37.
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`During Khan’s April 2018 visit, Khan and Malik went together to TD Bank and
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`co-signed account-opening documents for VoIP Terminator.
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`38.
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`As early as 2016, Khan, on behalf of BLMarketing, began purchasing VoIP lines
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`from larger carriers in the United States. For example, on October 31, 2016, BLMarketing
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`entered into contracts with Alcazar Networks, Inc.1 (“Alcazar”), for direct voice termination and
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`interexchange carrier services. Direct voice termination services allow telemarketers to use VoIP
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`to call phone numbers in the United States. Interexchange carrier services allow smaller carriers
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`to purchase VoIP lines from larger carriers and then either sell those lines to other carriers or
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`telemarketing call centers.
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`39.
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`VoIP Terminator offered numerous services in the telemarketing ecosystem,
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`including predictive dialers, Private Branch Exchange hosting (“PBX”), DID/Virtual numbers,
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`ringless voicemail, and call center leads.
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`40.
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`Predictive dialer services included hosted, free open source software and
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`wholesale termination that VoIP Terminator offered to install and host for call center customers.
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`Wholesale termination services give call center customers access to VoIP lines to call phone
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`numbers in the United States.
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`1 Alcazar Networks Inc. is a VoIP service provider and former FTC defendant. On December 3, 2020, Alcazar settled
`FTC charges that it had facilitated tens of millions of illegal telemarketing phone calls, including some calls from
`overseas and some that displayed spoofed caller ID numbers. See FTC v. Alcazar Networks, Inc., et al., No. 6:20-
`cv2200 (M.D. Fla. Dec. 3, 2020); see also Press Release, Federal Trade Commission, FTC Takes Action Against
`Second VoIP Service Provider for Facilitating Illegal Telemarketing Robocalls (Dec. 3, 2020),
`https://www.ftc.gov/news-events/press-releases/2020/12/ftc-takes-action-against-second-voip-service-provider.
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`41.
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`42.
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`PBX provides companies with local networks for their internal communications.
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`DID/Virtual numbers are the numbers that appear on consumers’ phones when a
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`call is received. Call centers purchase these numbers and route them through their dialers to
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`phone numbers in the United States, including to cell phone numbers and Skype internet-based
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`phone numbers.
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`43.
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`Ringless voicemail services are systems VoIP Terminator’s customers could
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`purchase that would allow them to record voicemails and transmit these phone calls directly to
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`voicemail inboxes in the United States without causing the consumers’ phones to ring.
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`44.
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`Call center lead services are VoIP Terminator’s ability to generate leads—
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`consumers’ phone numbers—for its call center customers.
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`45.
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`Providing VoIP services to a telemarketer constitutes the provision of substantial
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`support and assistance to a telemarketer under the TSR. Providing VoIP Terminator’s related
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`services (predictive dialing, PBX hosting, ringless voicemail, DID services, etc.) also constitutes
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`the provision of substantial support and assistance to a telemarketer under the TSR.
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`46.
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`The majority, if not all, of the services VoIP Terminator provided to call centers
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`and other customers were run out of VoIP Terminator in Pakistan.
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`47.
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`The website www.voipterminator.com.pk identified the company as “VoIP
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`Terminator Pakistan.” Defendant Khan also referred to the company as “VoIP Terminator
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`Pakistan.” VoIP Terminator Pakistan is an association of persons organized under the laws of
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`Pakistan, also doing business as Sip Tech and VT Group. Khan testified that VoIP Terminator
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`Pakistan was still operating in Pakistan, as of July 2021, and said it was no longer providing
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`VoIP services.
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`48.
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`According to Defendant Khan, VoIP Terminator used to have approximately
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`thirty employees in Pakistan. Approximately 75 percent of VoIP Terminator’s employees in
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`Pakistan were technical engineers. The remaining 25 percent were in administrative or sales
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`roles.
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`49.
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`In Pakistan, Khan ran most of VoIP Terminator’s day-to-day operations. Khan
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`also accompanied his salespeople when they met with prospective clients.
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`50.
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`VoIP Terminator’s offices in Florida and Pakistan supported each other’s business
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`operations. For example, customers would come to VoIP Terminator in Pakistan to have dialers
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`installed for them on hosted servers. VoIP Terminator in Florida would then provide the
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`customers with VoIP lines, which served as a point of entry to United States phones.
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`51.
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`According to Khan’s sworn testimony, the customers to whom VoIP Terminator
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`provided dialers were call centers located in the Philippines, Pakistan, and Bangladesh. VoIP
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`Terminator’s call center customers were telemarketers who used the dialers provided by VoIP
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`Terminator to call phone numbers in the United States.
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`52.
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`VoIP Terminator and “VoIP Terminator Pakistan” used interchangeable
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`addresses. For example, the website www.voipterminator.com.pk, until at least October 2020,
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`listed its “headquaters” [sic] on its home page as its Florida address and its “offshore office” as
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`its Pakistani address. Also, the headquarters address VoIP Terminator listed on its “Contact”
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`page was 6564 Loisdale Court, Suite 600-D, Springfield, Virginia (BLMarketing’s mail drop).
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`Here are screenshots of the bottom of VoIP Terminator’s home page and contact page:
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`53.
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`Khan testified that by 2018 he had stopped doing business under the name
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`BLMarketing and transitioned his business to VoIP Terminator. However, in March 2019, Khan
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`entered into a contract to provide VoIP services to a Pakistani call center called TransData
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`International (“TransData”). The Master Services Agreement was between “BLMarketing, Inc. a
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`Virginia, USA corporation (VoIP Terminator)” and TransData. BLMarketing’s address in
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`Springfield, Virginia appears on the contract.
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`54.
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`Khan did not affirmatively close BLMarketing; the State of Virginia
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`administratively terminated the company on January 31, 2020.
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`Defendants Knew, or Consciously Avoided Knowing, That They Were Assisting and
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`Facilitating Illegal Recorded Telemarketing Calls
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`55.
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`On March 15, 2018, the Federal Communications Commission issued a subpoena
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`to Khan and “BL Marketing Inc. dba VOIPterminator,” requesting identifying information for a
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`customer that routed or placed a particular “unlawful robocall” on Defendants’ network to
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`consumers in the United States. The FCC has defined “robocalls” as “calls made with an
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`autodialer or that contain a message made with a prerecorded or artificial voice.” See
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`https://www.fcc.gov/consumers/guides/stop-unwanted-robocalls-and-texts.
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`56.
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`Khan responded to the FCC via email on March 19, 2018. He signed a certificate
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`of compliance as president of the company, providing the address 6564 Loisdale Court, Suite
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`600-D, Springfield, Virginia (BLMarketing’s address), and the email address
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`mkhan@voipterminator.com.
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`57.
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`In his response to the FCC, Khan identified the customer that routed or placed the
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`unlawful robocall in question as Steps Ahead Global Contact Solutions (“SAGCS”) and attached
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`a Master Services Agreement between SAGCS and “VOIPterminator – product of BL Marketing
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`INC.” SAGCS was a call center customer of the Defendants located at 233 Campo Sioco, Baguio
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`City, Philippines. It was operated by Philippines-based telemarketer James Joseph Servas
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`(“Servas”). At all times relevant to this Complaint, Servas was Khan’s contact for SAGCS.
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`58.
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`The Master Services Agreement between BLMarketing, Inc. and SAGCS was
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`created by Khan on September 9, 2016. Khan emailed the Master Services Agreement to
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`Servas’s email, tole.cosmetics@gmail.com, for Servas’s signature. On September 13, 2016,
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`Servas and Khan electronically signed the Master Services Agreement.
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`59.
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`Under the Master Services Agreement between Defendants and Servas,
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`Defendants would supply termination, origination, and trunking telecommunications services
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`and SMS services to SAGCS. Paragraph nine stated in part:
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`Customer represents that they are aware of the Do Not Call (“DNC”) laws and
`agrees that any Services purchased from VoIP Terminator will be in compliance
`with those laws. Customer is aware that VoIP Terminator offers TeleBlock
`service which checks all calls with the appropriate DNC lists, and that
`TeleBlock service has a specific charge and involves a separate TeleBlock
`contract. Some information regarding DNC in the U.S. is at
`www.ftc.gov/opa/2008/040dncfyi.shtm; in the UK is at www.tpsonline.org, and
`in Canada is at http://en.wikipedia.org/wiki/Canadian_Do_Not_Call_List. This
`information is not all-inclusive, and it is the responsibility of the Customer to
`comply with all applicable laws.
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`60.
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`Servas’s companies never used the TeleBlock services offered by Defendants.
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`After learning that Servas’s company was sending unlawful telemarketing calls into the United
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`States, Khan chose not to stop transmitting Servas’s calls. Rather, Khan continued to do business
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`with Servas until April 2020.
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`61.
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`During the investigational hearing conducted by the FTC, Khan testified that
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`probably only one percent of call center customers used TeleBlock services to check all of their
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`calls against the DNC Registry. Khan testified that Defendants’ call center customers would
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`represent that they were scrubbing their calls, but Khan never asked any of Defendants’ call
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`center customers for evidence that they were excluding calls to phone numbers on any DNC lists.
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`Khan also testified that Defendants had no policies for monitoring, reviewing, or analyzing
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`consumer complaints reported to or published by any state or federal government agency. When
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`Defendants received complaints, Khan was solely responsible for investigating the complaint,
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`providing requested information, and taking responsive actions against Defendants’ call center
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`customers, if any.
`
`
`
`14
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`

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`Case 6:22-cv-00798-PGB-GJK Document 1 Filed 04/26/22 Page 15 of 27 PageID 15
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`62.
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`By no later than April 2018, Khan knew, or consciously avoided knowing, that
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`Servas was using Defendants’ services for calls that violated the TSR. According to Khan, he
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`warned Servas that he would cancel Servas’s contract if there were more complaints.
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`63.
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`In August 2019, Khan received a CID from the Missouri Attorney General’s
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`Office about potential violations of Missouri law concerning illegal telemarketing, including
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`calls to numbers on Missouri’s Do Not Call list. In an email to the attorney general’s office dated
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`September 5, 2019, Khan apologized for an error in his subpoena response. He said: “I am so so
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`sorry. Too many requests everyday [sic] regarding DNCs.”
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`64.
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`The FCC issued a second subpoena to Khan, as president of VoIP Terminator, on
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`November 20, 2019. That subpoena placed Khan on notice that the FCC was still investigating
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`the illegal conduct (“apparent unlawful robocalls”) of at least two of Khan’s customers, Pakistani
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`call centers TransData and Global BPO Limited.
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`65.
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`The FCC issued a third subpoena to Khan as president of VoIP Terminator on
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`January 15, 2020. That subpoena also concerned continuing unlawful calls made by TransData.
`
`66.
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`USTelecom is a trade association that represents “technology providers,
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`innovators, suppliers and manufacturers” in the broadband industry.
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`https://www.ustelecom.org/ustelecom-community/our-members/. Among other things,
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`USTelecom collects data about illegal calls, and conducts “tracebacks” to determine the path a
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`call has taken, from its origin to its destination. When conducting a traceback inquiry,
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`USTelecom notifies its participating members about a complaint, and requests information about
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`the source of individual calls. It is then able to identify the route that a specific call travels, from
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`its point of origin to its destination.
`
`
`
`15
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`

`

`Case 6:22-cv-00798-PGB-GJK Document 1 Filed 04/26/22 Page 16 of 27 PageID 16
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`67.
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`On March 13, 2020, USTelecom notified Defendants via email that spoofed calls
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`playing recorded messages were being transmitted through Defendants’ network offering “air
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`duct cleaning to filter out corona virus.” Air duct cleaning does not filter out coronavirus.
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`USTelecom flagged the calls (which were made on March 12) as illegal spoofed robocalls to
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`numbers on the DNC list.
`
`68.
`
`The first paragraph of every USTelecom traceback inquiry states: “We are writing
`
`to request your assistance on industry efforts focused on our shared interest of protecting
`
`consumers from fraudulent, abusive or potentially unlawful robocalls.” The second paragraph
`
`says:
`
`A member of USTelecom’s Industry Traceback Group recently received traffic
`from your network that has been deemed suspicious, and we are seeking your
`assistance in order to identify its origin (call details with date(s) are listed below).
`We request that you assist industry stakeholders who are engaging in traceback
`efforts in order to help identify the source of this potentially fraudulent, abusive or
`unlawful network traffic. To assist us in our efforts, we are asking that you
`respond to this traceback inquiry as soon as possible, but no later than three
`business days from now.
`
`
`69.
`
`USTelecom identified “VoIP Terminator/BLMarketing” as the “point of entry”
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`VoIP provider (i.e., the provider responsible for bringing a call into the United States) for several
`
`allegedly unlawful spoofed prerecorded calls that offered air duct cleaning to filter coronavirus
`
`particles (a fictitious service). The March 13, 2020 email included a traceback inquiry
`
`concerning four of the seven allegedly unlawful prerecorded calls. Here is a part of the traceback
`
`inquiry that identifies the calls and the customer’s calling campaign:
`
`
`
`16
`
`

`

`Case 6:22-cv-00798-PGB-GJK Document 1 Filed 04/26/22 Page 17 of 27 PageID 17
`
`
`
`70.
`
`One of the HVAC-Corona call campaigns played the following message:
`
`Recommend sanitizing your ducts and air filters to protect your loved ones from
`the Corona virus. For only $159 our highly trained technicians will do a full air
`duct cleaning and sanitation to make sure the air you breathe is free of bacteria.
`So don't hesitate. Press zero and have your duct system cleaned and sanitized
`now. Press nine to be removed from this list.
`
`That recording is available at: https://directory.youmail.com/directory/phone/6185649533.
`
`71.
`
`Defendant Khan was responsible for investigating and responding to traceback
`
`inquiries from USTelecom. Khan responded to the inquiries through an online portal provided by
`
`USTelecom. Recipients of traceback inquiries can input the call source details for the unlawful
`
`calls in question.
`
`72.
`
`Through the USTelecom portal, Khan identified the customer responsible for the
`
`HVAC-Corona call campaign as a call center located in Pakistan named Oberlo Peer BPO. He
`
`also notified USTelecom that he had “advised customer to remove traffic.”
`
`
`
`17
`
`

`

`Case 6:22-cv-00798-PGB-GJK Document 1 Filed 04/26/22 Page 18 of 27 PageID 18
`
`73.
`
`On March 16, 2020, Khan received a traceback inquiry for three additional calls
`
`related to the same illegal coronavirus spoofed prerecorded call campaign. Khan responded as he
`
`had before: “advised customer to remove traffic.”
`
`74.
`
`From July 2019 to December 2020, USTelecom sent Defendants traceback
`
`notices for seventy unlawful telemarketing campaigns. Those traceback notices flagged unlawful
`
`prerecorded call campaigns involving credit card interest rate reduction, tech support scams, and
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`COVID-related air duct cleaning, among others. Most, if not all of these campaigns, involved
`
`spoofed caller IDs. Those traceback notices flagged the following unlawful campaigns, among
`
`others:
`
`
`
`
`
`
`
`
`
`18
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`

`

`Case 6:22-cv-00798-PGB-GJK Document 1 Filed 04/26/22 Page 19 of 27 PageID 19
`Case 6:22-cv-00798-PGB-GJK Document1 Filed 04/26/22 Page 19 of 27 PagelD 19
`
`Call Details for Incident #1271 (new)
`Date/Time:
`2019-12-10 15:50:00 UTC
`417545511520
`+17547826996
`CCIRR-CCHolder
`
`Recorded voice says you qualify for zero percent interest, press 1 to complete the process.
`Calls using recorded voice not permitted to wireless numbers. Calling entity not identified. No
`tol-free call-back numberleft in voicemail. Calling numberis neighbor-spoofed so BLOCKING
`THE ANI is NOT effective.
`
`Call Details for Incident #1397 (new)
`Date/Time:
`2020-01-20 15:40:00 UTC
`Ta:
`413102935443
`From:
`413107921451
`CCIRR-MemberSyvcs
`
`Campaign:
`
`Recorded voice offers lowerinterest rate, press 1 to speak to Member Services Department.
`Calls using recorded voice not permitted to wireless numbers. Calling entity not identified. No
`toll-free call-back number left in voicemail. Calling number is neighbor-spoofed so BLOCKING
`THE ANI is NOT effective. This call is just one example of millions of similar calls. Originators
`please search your records for similar traffic and address with your customer.
`
`Call Details for Incident #1518 (new)
`Date/Time:
`2020-02-05 17:27:00 UTC
`+13147992826
`413148973406
`CCIRR-Alice
`
`Automated voice offers zero interest and says press 1 to connect to live rep. Unsolicited calls
`using automated or prerecorded voice not permitted to wireless numbers. Message does nat
`identify calling entity. No toll-free call-back number in message. Caller-ID is neighbor-spoofed
`80 ANI blocking is not an effective mitigation approach._Latest calls placed after providerin
`Pakistan indicated caller was no longer spoofing but that is not the case. This call is just one
`example of millions of similar calls. Originators please search your records for similar tr