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`IN CLERK'S OFFICE
`U.S. DISTRICT COURT E.D.N.Y.
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`UNITED STATES DISTRICT COURT
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`EASTERN DISTRICT OF NEW YORK
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`* JAN 2 8 2020
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`.‘k
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`BROOKLYN 0mm;
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`UNITED STATES OF AMERICA,
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`COMPLAINT
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`V.
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`
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`Plaintiff,
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`Defendants.
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`NICHOLAS PALUMBO, NATASHA
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`PALUMBO, ECOMMERCE NATIONAL, LLC
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`d/b/a Tollfreedealscom, and SIP RETAIL d/b/a
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`sipretailcom,
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`Plaintiff, the UNITED STATES OF AMERICA, by and through the undersigned
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`attorneys, hereby alleges as follows:
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`INTRODUCTION
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`1.
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`The United States brings this action for a temporary restraining order, preliminary
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`and permanent injunctions, and other equitable relief pursuant to 18 U.S.C. § 1345, in order to
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`enjoin the ongoing commission of criminal wire fraud in violation of 18 U.S.C. § 1343 and
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`conspiracy to commit wire fraud in Violation of 18 U.S.C. § 1349. The United States seeks to
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`prevent continuing and substantial injury to the victims of fraud.
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`2.
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`Since at least 2016 and continuing through the present, Defendants, together with
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`one or more co-ccnspirators, have used the US. telephone system to engage in predatory wire
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`fraud schemes that victimize individuals throughout the United States, including individuals within
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`the Eastern District of New York and significant numbers of elderly and vuinerable victims.
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`Defendants are VoIP1 carriers, and their principals, that serve as “gateway carriers,”2 facilitating
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`the delivery of millions of fraudulent “robocalls
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`every day from foreign call centers and foreign
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`”3
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`,VoIP carriers to the U.S. telecommunications system and ultimately to phones throughout the
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`United States. The Defendants thus provide foreign fraudsters the means to access the U.S.
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`telephone system, knowingly passing millions of fraudulent rohocalls intended to deceive the
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`recipient into: (1) answering or returning the call, and (2) paying money to the perpetrators of the
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`schemes.
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`3.
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`Through these robocalls, fraudsters operating overseas impersonate government
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`entities and well—known businesses by “spoofing”4 legitimate phone numbers and sending
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`recorded messages that are transmitted across the internet to telephones throughout the United
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`States. These robocalls purport to be from federal government agencies, elements of foreign
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`governments, and legitimate businesses, conveying alarming messages, such as that the call
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`recipient’s social security number or other personal information has been compromised or
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`otherwise connected to criminal activity; the recipient faces imminent arrest; the recipient’s
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`assets are being frozen; the recipient’s bank and credit accounts have suspect activity; the
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`recipient’s benefits are being stopped; the recipient faces imminent deportation; or combinations -
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`1 VoIP stands for voice-over-internet protocol and allows users to place phone calls over
`a broadband internet connection.
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`2 As set forth in greater detail herein, “gateway carriers” are the first in a chain of VolP
`carriers located in the United States that facilitate the delivery of foreign VoIP calls to recipients
`in the United States.
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`3 “Robocall” means a call made through an automated process that places large volumes
`of telephone calls over the internet in order to deliver recorded messages, in contrast to calls
`placed one at a time by a live person.
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`4 The practice of making a false number appear on the recipient’s caller ID is known as
`“spoofing.”
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`of these things—all lies intended to induce potential Victims to speak to the fraudsters. When
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`individuals answer the calls or return voicemail messages, the fraudsters offer to “resolve” these
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`legal matters by immediate transfers of funds to settle the purported legal obligation, or to hold
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`the individual’s assets only temporarily while the crisis resolves. ‘In reality, the individual is
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`neither under investigation nor in legal jeopardy, and the same threatening robocall was made
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`simultaneously to thousands of other US. telephones.
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`4.
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`Not only do Defendants deliver vast numbers of fraudulent robocalls every day,
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`but they also participate in the fraudulent schemes by providing return-calling services the
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`fraudsters use to establish contact with potential victims. Robocall messages will often provide
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`domestic and toll—free call—back numbers; potential victims who call these numbers connect to
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`the overseas fraudsters, who then try to extort and defraud the potential victims.
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`5.
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`Defendants profit from these fraudulent robocall schemes by receiving payment
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`from their conconspirators for the services Defendants provide. Often, these payments consist of
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`victim proceeds, a portion of which is deposited directly into Defendants“ accounts in the United
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`States, before the remainder is transmitted to the fraudsters overseas.
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`6.
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`Since at least 2016 and continuing through the present, as a result of their
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`conduct, Defendants and their couconspirators have defrauded numerous victims out of millions
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`of dollars, including victims in the Eastern District of New York.
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`7.
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`For the reasons stated herein, the United States requests injunctive relief pursuant
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`to 18 U.S.C. § 1345 to enjoin Defendants’ ongoing schemes to commit wire fraud in violation of
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`18 U.S.C. § 1343 and conspiracy to commit wire fraud in violation of 18 U.S.C. § 1349. 5
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`5 This case is one of two cases being filed simultaneously in which the United States
`Department of Justice, for the first time, seeks to enjoin telecommunications companies from
`participating in robocalling fraud schemes pursuant to 18 U.S.C. § 1345.
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`3
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`JURISDICTION AND VENUE
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`3
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`8.
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`The Court has subject matter jurisdiction over this action pursuant to 18 U.S.C.
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`§1345 and 28 U.S.C. §§ 1331 and 1345.
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`9.
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`Venue lies in this district pursuant to 28 U.S.C. § 1391(b)(2).
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`10.
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`Plaintiff is the United States of America.
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`PARTIES
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`I 1.
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`Defendants Nicholas and Natasha Palumbo own and control Econnnerce
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`National, LLC, doing business as TollFreeDeals.com and SIP Retail, LLC, also doing business
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`as SipRetail.com (the “Corporate Defendants”), which the Palumbos utilize in furtherance of the
`fraudulent robocall schemes. The Palumbos operate the Corporate Defendants from their home
`in Paradise Valley, Arizona, and on information and belief, the Palurnbos operate SIP Retail as
`an alter ego ofEcommerce. From their home in Paradise Valley, Arizona, the Palumbos operate
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`the Corporate Defendants as fraudulent enterprises.
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`12.
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`Defendant Ecommerce is a‘ corporation organized and existing under the laws of
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`the State of Arizona. Ecommerce does business as TollFreeDeais.001n, and will be referred to
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`throughout this Complaint as TollFreeDeals. TollFreeDeals’ principal place of business is
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`located at the Palumbos’ home in Paradise Valley, Arizona. Nicholas Palumbo is the Chief
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`Executive Officer of TollFreeDeals and Natasha Palurnbo is the Vice President of Business
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`Development.
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`13.
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`Defendant SIP Retail, LLC, also doing business as SipRetail.com (“SIP Retail”),
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`is a ceiporation organized and existing under the laws of the State of Arizona. SIP Retail’s
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`principal place of business is located at the Palumbos’ home in Paradise Valley, Arizona.
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`Natasha Palumbo is the Chief Executive Officer of SIP Retail. SIP Retail provides VoIP carrier
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`services for some of the same customers as TollFreeDeals, including foreign VolP carriers that
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`transmit millions of calls every week destined for the phones of residents of the Eastern District
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`of New York.
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`OVERVIEW OF THE ROBOCALLING FRAUD SCHEMES
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`A. Robocalling Fraud Targeting Individual in the United States
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`14.
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`The robocalling fraud schemes in which the Defendants are engaged share the
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`same characteristics. Individuals at call centers located abroad, many ofwhich-are operating out
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`of India, are bombarding the US. teiephone system daily with millions of robocalls intended to
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`defraud individuals in the United States. Many of these fraudsters impersonate US. government
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`officials, foreign government officials, or well-known American businesses, in order to tln‘eaten,
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`defraud, and extort money from robocall recipients. Robocalling technology, which allows
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`fraudsters to send millions of calls per day all transmitting the same pro-recorded, fraudulent
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`message, enables fraudsters to cast a wide net for elderly and vulnerable victims who are
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`particularly susceptible to the threatening messages the fraudsters are sending. Even if only a
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`small percentage of the recipients of a fraudulent call center’s robocalls connect with potential
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`victims, the fraudsters can still reap huge profits from their schemes.
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`15.
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`Foreign fraudsters operate many different scams targeting individuals in the
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`United States, butthe Defendants’ robocall schemes include the following categories of
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`impersonation scams:
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`a. Social Securit Administration "SSA” Im asters: Defendants transmit recorded
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`
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`messages in which SSA imposters falsely claim that the call recipient’s social
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`security number has been used in criminal activity, the recipient’s Social Security
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`benefits will be suspended, the recipient has failed to appear'before a grand jury
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`and faces imminent arrest, or the recipient’s social security number will be
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`tenninated. When a recipient calls back or connects to the fraudster, the fraudster
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`claims to be an SSA employee and typically tells the individual to transfer
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`substantial fiJnds to the SSA for safekeeping until a new social security number
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`can be issued, at which point the funds purportedly will be returned.
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`b.
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`Internal Revenue Service “IRS” Im esters: Defendants transmit recorded
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`messages in which IRS imposters falsely claim that the call recipient has been
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`implicated in tax fraud, has avoided attempts to enforce criminal laws, has
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`avoided court appearances, or the recipient faces imminent arrest. When a
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`recipient calls back or connects to the fraudster, the fraudster claims to be an IRS
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`or Treasury employee and typically directs the recipient to transfer funds to the
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`IRS to resolve various fictitious tax and legal liabilities, or for safekeeping in
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`order to avoid seizure of assets.
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`United States Citizensht and Immi ration Services
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`1111 asters:
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`Defendants transmit recorded messages in which USCIS imposters falsely claim
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`that the recipient has failed to fill out immigration forms correctly, the recipient
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`faces imminent arrest or deportation, the recipient’s home country has taken
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`formal action against the recipient that may result in deportation, or the recipient
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`has transferred money in a way that will result in deportation. When a recipient
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`calls back or connects to the fraudster, the fraudster claims to be a USCIS
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`employee and typically tells the recipient to pay various fees 01' fines to avoid
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`immigration consequences.
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`(1. Tech Support Imposters: Defendants transmit recorded messages in which
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`fraudsters operating tech support scams impersonate various well-known tech
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`i iii || i|Ii i.
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`companies such as Apple or Microsoft, and falsely claim that the recipient has
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`computer Security problems that require assistance. When an individual connects
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`with the fraudster, the fraudster instructs the individual to pay for fictitious tech
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`support and computer security services, and to allow the fraudster remote access
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`to the victim’s bank accounts.
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`e. Lean Approval Scams: Defendants transmit recorded messages in which
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`fraudsters operating loan approval scams impersonate a “lender” offering a great,
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`guaranteed rate on a “pie—approved” loan. When a customer connects with the
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`fraudster, the fraudster will emphasize that a poor credit history does not matter,
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`and all the call recipient has to do to secure the pre—approved loan is pay a one—
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`time fee up front.
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`16.
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`These robocails are often “spoofed” so that they falsely appear on a victim’s
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`caller ID to originate from US. federal government agency phone numbers, such as the SSA’s
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`main customer service number, local police departments, 91 1, or the actual customer service
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`phone numbers of legitimate US. businesses. These “spoofed” numbers are used to disguise the
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`origin of the robocalls and the caller’s identities, and to cloak them with the authority of
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`government agencies or large businesses to induce potential victims to answer or return the calls.
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`In reality, the calls originate from fraudsters operating abroad, and have no connection to any
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`US. government agency or other legitimate enterprise.
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`17.
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`Individuals who answer or return these calls eventually speak to live fraudsters
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`who tell the individuals lies intended to frighten and confuse them so that the fraudsters may
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`begin to control their behavior and isolate them from authorities, friends, and family members.
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`These lies often include that the individual’s social security number or other personal
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`information has been implicated in criminal activity, that the individual faces imminent arrest or
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`deportation, and that the individual’s assets are about to be forfeited to the government. Once an
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`individual is overcome by fear and panic, the fraudsters keep them on the phone and offer
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`reassurances that the individual’s purported legal probiems can be resolved through payment of
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`money, or that the individual’s money must be transferred to the government agency the
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`fraudsters are impersonating. The fraudsters often claim that the victim’s payment will be
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`returned in the immediate future. In reality, once the fraudsters are convinced they have extorted
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`as much money as possible from the victim, they drop all contact, leaving the victim without
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`meaningful recourse. Fraudsters receive victims” money through retail gift cards, bank wires,
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`cash payments, cryptocurrency transfers, and other methods.
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`18.
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`Since October 2018, the most prolific robocalling scam impersonating US.
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`government officialseand one engaged in by Defendants—is impersonation ,of the SSA. For
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`example, a robocall sent to millions of phones in the United States in early 2019 contained the
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`following message:
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`Hello this call is from Department of Social Security Administration the reason
`you have received this phone call from our department is to inform you that there
`is a legal enforcement actions filed on your social security number for fraudulent
`activities so when you get this message kindly call back at the earliest possible on
`our number before we begin with the legal proceedings that is 619—XXX—XXXX I
`repeat 619—XXX-XXXX thank you.
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`l9.
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`SSA received more than 465,000 complaints about fraudulent telephone
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`impersonation of the Administration from October 1, 2018 through September 30, 2019. Losses
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`associated with these complaints exceed $14 million. Similarly, the Federal Trade Commission
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`(“FTC”) reported that during 2018, its Consumer Sentinel database received more than 39,000
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`fraud complaints about SSA imposters, with estimated victim losses of approximately $11.5
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`million; for 2019, the FTC reported that SSA imposter call complaints rose to approximately
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`166,000 with associated losses of more than $37 million. 6 Complaint numbers substantially
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`underrepresent the extent of the problem, because most victims do not report their losses to the
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`government.
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`B. How Calls From Foreign Fraudsters Reach U.S. Telephones
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`20.
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`The Defendants’ robocaliing fraud schemes, which involve rohocalls that
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`originate abroad and target individuals in the United States, are all dependent on VoIP and
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`related technology to create the calls. VoIP calls use a broadband Internet connection w as
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`opposed to an analog phone line e to place telephone calls locally, long distance, and
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`internationally, without regard to whether the call recipient uses a cellular phone or a traditional,
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`wired phone. The robocalling fraud schemes also require U.S. based telecommunications
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`companies — referred to as “gateway carriers” m to introduce the foreign phone traffic into the
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`U.S. phone system. A foreign call center or telecommunications company that places VolP calls
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`to US. telephones must have a relationship with a U.S. gateway carrier. From the gateway
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`carrier, most VoIP calls will pass through a series of U.S.-based VolP carriers before reaching a
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`consumer—facing “common carrier” such as AT&.T or Verizon, and ultimately a potential
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`‘Victim’s phone. One of the Defendants” roles in the fraudulent schemes is to serve as a gateway
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`carrier for the fraudulent robocalls.
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`21.
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`Each provider in the chain that transmits a VOIP call maintains records, primarily
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`for billing reasons, of all of the calls that pass through it. These records include the following
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`information:
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`the date and time of the call, the destination number (intended recipient), the source
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`6 Regarding government imposter fraud more broadly and not limited just to SSA
`imposters, the FTC’S Consumer Sentinel database contains 255,223 complaints reflecting
`$128,479,054 in losses for 2018, and 389,563 complaints reflecting $152,946,623 in losses for
`2019.
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`number from which the call was placed (sometimes a real number and sometimes a spoofed
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`number), the name of the company that sent the call to the provider, and the downstream
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`company to which the provider sent the call. These records are generated automatically as a call
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`is routed through telecommunications infrastructure in a manner that achieves the lowest cost to
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`transmit a given call, known in the industry as “least—cost routing.” Calls may be traced through
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`these records back to their gateway carrier, and thus to their foreign source. The
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`telecommunications industry refers to this process as “traceback.”
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`22.
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`Tracebacks of many different robocalling fraud schemes have led to the
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`identification of Defendants as a gateway carrier willing to transmit huge volumes of fraudulent
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`robocalls into the country, despite clear indicia of fraud in the call traffic and actual notice of
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`fratid.
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`DEFENDANTS’ ONGOING PARTICIPATION IN ROBOCALLING FRAUD SCHEMES
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`23.
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`' Since at least 2016, and continuing through the present, Defendants have
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`knowingly provided U.S.;bou11d calling services to foreign fraudsters operating robocall scams,
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`acting as a gateway carrier and passing robocalls into the US. telephone system by the millions.
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`The Defendants are paid for each call they pass into and through the U.S. phone system. In
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`addition, the Defendants have provided return—calling services to the fraudsters operating the
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`robocall scams, for which Defendants are also paid, enabling fraudsters to establish contact with
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`unwitting individuals after the individuals are deceived by a robocall.
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`24.
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`There is substantial evidence of the Defendants’ knowledge of the fraudulent
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`nature of the calls they transmit, including call records showing high percentages of short~
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`duration, unanswered calls7 passing through their systems by the millions; thousands of spodfed
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`calls originating from overseas, purporting to be from “911” and similar numbers; dozens of
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`complaints and warnings from other telecommunications companies about fraud, spoofing, and
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`short~duration “junk” calls; repeated warnings and inquiries from a teieeommunications industry
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`trade group about the fraudulent robocalls passing through the Defendants’ system; and receipt
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`of payment from their foreign customers in the form of large, suspicious cash deposits by various
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`individuals throughout the United States directly into Defendants’ bank accounts.
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`A. Defendants Knowingly Introduce Fraudulent Robocalls into the U.S. Telephone
`System
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`25.
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`Defendants provide inbound VoIP calling to the United States telecommunication
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`system (referred to in the industry as “U.S. call termination”) to customers located both here in
`the United States and abroad. Defendants provide unrestricted VoIP calling, meaning they do
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`not monitor or restrict the inbound calls a customer can place for either volume of calls or call
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`duration. Defendants are paid for each call they pass into and through the U.S. phone system.
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`26.
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`Defendants specifically market their services to foreign call centers and foreign
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`VoIP carriers looking to transmit high volumes of robocalls to individuals in the United States.
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`The TollFreeDeals website states “TollFreeDeals.com is your premier connection for call center
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`and dialer termination. We are always looking for the best call center routes in the telecom
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`industry. We specialize in short call duration traffic 01' call center traffic. We understand there is
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`a need for it and we want to help you find all the channels you need!”
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`7 Short-duration and unanswered calls include calls where recipients immediately hang
`up and calls that do not connect, because robocalls are sent to numerous telephone numbers that
`are not in service.
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`ll“
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`27.
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`The FAQs on the TollFreeDeals website state, “Do you handle CC (Call
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`Center-)fDialer Traffic? Yes — unlike many carriers we will handle your dialer and call center
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`VoIP termination minutes. If you are looking for USA Dialer, Canada Dialer, or Australia Dialer
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`please fill out our online interop form to test our routes.”
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`28.
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`Defendants regularly transmit massive volumes of short duration calls. For
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`example, over 23 days in May and June of 2019, TollFreeDeals transmitted more than 720
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`million calls. Of those calls, more than 425 million, or 59% of the total calls, lasted less than one
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`second in duration. In the telecommunications industry, high volumes of short-duration and
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`unanswered calls are indicative of robocalls that are unwanted by the recipients, often because
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`they are fraudulent. More than 24 million of those calls were placed to phone numbers with area
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`codes in the Eastern District of New York. As Defendants’ phone records show the ultimate
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`destination number of every VOIP call they transmit, Defendants know they transmit fraudulent
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`calls to potential Victims in the Eastern District of New York.
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`29.
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`During May and June of 2019, the Palumbos facilitated the delivery of more than
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`182 million calls through TollFreeDeals from a single India-based VoIP carrier co-conspirator to
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`phones in the United States. One thousand different source numbers (the number from which a
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`call is placed, and that shows up on the recipient’s caller ID) accounted for more than 90% of
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`those calls. According to data obtained from a robocall blocking company about calls identified
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`as fraudulent robocalls in 2019, 79% of those 1000 source numbers have been identified as
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`sending fraudulent robocalls. Consequently, TollFreeDeals transmitted an estimated 143 million
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`fraudulent robocalls on behalf of that single India-based co-conspirator during May and June of
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`2019. Of those calls, an estimated 20% were Social Security imposter calls, 35% were loan
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`approval scams, and 14% were Microsoft refund scams. The remaining calls were a mixture of
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`IRS imposter, US Treasury imposter, miscellaneous tech support imposter and other schemes.
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`30.
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`Defendants’ knowledge of the fraudulent nature of the telephone calls they deliver
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`to potential Victims on behalf of their co—conspirators is also evidenced by the numerous
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`complaints, inquiries, and warnings regarding fraudulent robocalls that Defendants received from
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`other telecommunications carriers and a telecommunications industry trade association since at
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`least 2017. Despite receiving these complaints, inquiries, and warnings, Defendants nevertheless
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`continued to transmit massive volumes of fraudulent robocalls from their co—conspirators to
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`potential victims in the United States.
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`31.
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`For example, in May 2017, AT&T notified Nicholas Palumbo that it had traced
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`back to TollFreeDeals robocalls received by its customers that spoofed phone numbers belonging
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`to USCIS and the Office of the Inspector General of the US. Department of Homeland Security
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`(“DHS—OIG”). AT&T informed Nicholas Palumbo that the callers who spoke to AT&T’s
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`customers impersonated US. Immigration Officers, and that AT&T had confirmed with USCIS
`and DHS—OIG that those agencies did not use any of the phone numbers at issue as a legitimate
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`outbound caller ID. Nicholas Palumbo responded that the calls were transmitted to
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`TollFreeDeals from an India-based VoIP carrier, and that he had blocked those two specific
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`phone numbers. Blocking specific numbers is an ineffective means to stop fraudsters who are
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`willing and have the ability to spoof any number as the caller ID number for their fraud calls.
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`32.
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`In February 2019, AT&T notified Nicholas Palumbo that it had traced back 19
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`separate calls to AT&T customers that spoofed a USCIS phone number in order to “extort
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`money from our customers.” In Nicholas Palumbo’s response to AT&T,- he acknowledged that
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`those calls were transmitted to TollFreeDeals from the same India—based VoIP carrier that had
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`13
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`Case 1:20-cv-00473-EK-RLM Document 1 Filed 01/28/20 Page 14 of 22 PageID #: 14
`Case 1:20-cv-OO473-EK-RLM Document 1 Filed 01/28/20 Page 14 of 22 PageID #: 14
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`transmitted spoofed USCIS calls in 2017. Despite repeated warnings from AT&T that this
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`foreign VoIP carrier was transmitting fraudulent govemrnent-impersonation robocalls, the
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`Palurnbos continued transmitting VoIP calls on behalf of this customer through at least as
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`recently as June 2019.
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`33.
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`The Palumbos have also received numerous warnings from telecommunications
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`industry trade association USTelecom that both TollFreeDeals.com and SIP Retail have
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`transmitted fraudulent robocails, including government impersonation robocalls.
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`34.
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`From May 2019 through January 2020, TollFreeDeais received 144 notifications
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`from USTelecorn that a fraudulent robocall had been traced back to TollFreeDeals. Of these
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`notifications, 83 referenced SSA imposter fraud calls, 24 referenced Tech Support imposter fraud
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`calls, ten referenced IRS imposter fraud calls, and one referenced USClS impersonation fraud
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`calls. Each of these emails were sent to Nicholas Palumbo at his @toilfreedeais.com email
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`address. Each email stated that a suspicious call had been traced back to TollFreeDeals’s
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`network and provided the call date, time and the source and destination phone numbers, to allow
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`TollFreeDeais to identify the specific call at issue in its call logs (referred to in the industry as
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`“call detail records”). Each email also provided a link to USTeiecorn’s web—based traceback
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`portal, Where further information was provided about the specific fraudulent call at issue,
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`included a recording of the fraudulent voicemail message that was sent to the recipient’s phone.
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`in every case, either the email itself or the traceback portal included a short description of the
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`type of fraud at issue and the details of the fraudulent robocall campaign, such as:
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`Captured recordings suggest these calls are perpetrating a SERiOUS FRAUD.
`Caller is impersonating a federal official. Automated voice claims suspicious
`activity on your social security number; press 1. Calls are from apparently random
`8XX numbers or other geographic numbers. Call volume estimated at over a million
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`Iiii
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`iie
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`ii
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`iiiIII II I
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`Case 1:20-cv-00473-EK-RLM Document 1 Filed 01/28/20 Page 15 of 22 PageID #: 15
`Case 1:20-cv-00473-EK-RLM Document 1 Filed 01/28/20 Page 15 of 22 PageID #: 15
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`per day. Because Caller-ID changes with each call, blocking the ANI [“Automatic
`Number Identification”3} is not effective.
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`35.
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`After receiving each of these notifications from USTelecom, Nicholas Palum‘oo
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`logged into the USTelecom portal and provided information regarding the customers of
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`ToilFreeDeals that had transmitted the fraudulent calls. Many of these fraudulent calis
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`repeatedly traced back to the same Indiawbased customers of ToilFreeDeals.
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`36.
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`From August 2019 through January 2020, USTelecom also notified SIP Retail of
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`35 tracebacks of fraudulent robocalls, including 19 tracebacks of SSA impersonation fraud calls,
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`three tracebacks of Tech Support impersonation fraud calls, and one traceback of USCIS
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`Impersonation fraud calls. Those notifications were emailed to help@sipretail.com. Upon
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`information and belief, the Palumbos are the only individuals who monitor email traffic to
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`@sipretail.corn domain email addresses. SIP Retaii logged into the USTeiecorn traceback portal
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`and notified USTelecom that all 10 of the SSA impersonation caiis were sent to SIP Retail by
`two India-based companies. Both ofthese companies were also sending fraudulent SSA
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`imposter call traffic through TollFreeDealscom, as the Paiumbos have been notified by
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`USTelecom on multiple occasions.
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`37.
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`Further, Defendants regularly receive payment from their customers in the form
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`of substantial cash deposits directly into Ecommerce’s bank account, from locations throughout
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`the United States raising red flags about the nature of the business of De'fendants’ customers.
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`B. Defendants Provide Toll-Free Services for Roboeail Schemes
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`38.
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`Not only do Defendants knowingly pass fraudulent robocaiis by the millions into
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`the US. telephone system, but they also provide return-calling services to fraudsters so that
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`8 ANI refers to the origination telephone number from which a call is placed.
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`15
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`Case 1:20-cv-00473-EK-RLM Document 1 Filed 01/28/20 Page 16 of 22 PageID #: 16
`Case 1:20-cv-OO473-EK-RLM Document 1 Filed 01/28/20 Page 16 of 22 PageID #: 16
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`potential victims can call them back. These toll-free telephone numbers and related services are
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`provided in the robocall message as call—back numbers, and appear to be US. telephone numbers
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`and thus enable fraudsters to further deceive individuals about the robocall’s origin and the
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`identities and locations of the fraudsters at the other end of the call. In reality, What appears to
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`the individual to be a US. telephone number is just a telephone number that Defendants register
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`to an internet address designated by the fraudsters. Thus, the toll-free numbers can be used to
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`ring telephones anywhere in the world.
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`39. While toll—free numbers used for return—calling purposes cannot be “spoofed” like
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`outgoing robocalls, the use of a US. toll-free number in Defendants’ robocalls schemes serves
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`much the same purpose as spoofingwdeception. The toll—free services provided by Defendants
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`use VoIP technology to direct potential victims’ return calls from the United States to the foreign
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`fraudsters’ call centers.
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`The Defendants have knowingly provided toll-free numbers and
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`associated calling services to foreign robocall fraudsters.
`40.
`All toll-free numbers in the United States are administered by Somos, ln