Case 2:20-cv-00474-BMC Document 1 Filed 01/28/20 Page 1 of 24 PageID #: 1
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`UNITED STATES DISTRICT COURT
`
`EASTERN DISTRICT OF NEW YORK
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`FILED
`. ^ IN CLERK'S OFFICE
`U.S. DISTRICT COURT E.D.N.Y.
`* JAN 2 8 2020 ^
`
`BROOKLYN OFFICE
`
`UNITED STATES OF AMERICA,
`
`Plaintiff,
`
`V.
`
`JON KAHEN, a/k/a JON KAEN, GLOBAL
`VOICECOM, INC., GLOBAL
`TELECOMMUNICATION SERVICES INC., and
`KAT TELECOM, INC.,
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`Defendants.
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`COMPLAINT
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`Civil Action No.
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`cv
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`iar;
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`COGAN, J.
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`Plaintiff, the UNITED STATES OF AMERICA, by and through the undersigned attorneys,
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`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 2017 and continuing through the present, Defendant John Kahen,
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`a/k/a Jon Kaen ("Kaen"), together with one or more co-conspirators, has used the U.S. telephone
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`system to engage in predatory wire fraud schemes that victimize individuals throughout the United
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`States, including individuals within the Eastern District of New York and significant numbers of
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`elderly and vulnerable victims. Kaen controls various corporate entities that he utilizes in
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`furtherance of the fraudulent scheme, including Defendants Global Voicecom, Inc.; Global
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`1
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`Telecommunications Services Inc.; and KAT Telecom, Inc. (the "Corporate Defendants," and
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`together with Kaen, the "Defendants). The Corporate Defendants, based in New York, are VoIP'
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`carriers that serve as "gateway carriers"^ facilitate the delivery of millions of fraudulent
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`"robocalls"^ every day from foreign call centers and foreign VoIP carriers to the U.S.
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`telecommunications system and ultimately to phones throughout the United States. The
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`Defendants thus provide foreign fraudsters the means to access the U.S. telephone system,
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`knowingly passing millions of fraudulent robocalls intended to deceive the recipient into: (I)
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`answering or returning the call, and (2) paying money to the perpetrators of the 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'"' 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 assets
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`are being frozen; the recipient's bank and credit accounts have suspect activity; the recipient's
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`' VoIP stands for voice-over-internet protocol and allows users to place phone calls over a
`broadband internet connection.
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`^ As set forth in further detail herein, "gateway" carriers are the first in a chain of VoIP carriers
`located in the United States that facilitate the delivery of foreign VoIP calls to receipients in the
`United States.
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`^ "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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`The practice of making a false number appear on the recipient's caller ID is known as
`"spoofing."
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`benefits are being stopped; the recipient faces imminent deportation; or combinations of these
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`things—all lies intended to induce potential victims to speak to the fraudsters. When individuals
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`answer the calls or return voicemail messages, the fraudsters offer to "resolve" these legal matters
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`by immediate transfers of funds to settle the purported legal obligation, or to hold the individual's
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`assets only temporarily while the crisis resolves. In reality, the individual is neither under
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`investigation nor in legal jeopardy, and the same threatening robocall was made simultaneously to
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`thousands of other U.S. telephones.
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`4.
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`Not only do Defendants deliver vast numbers of fraudulent robocalls every day, but
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`they also participate in the fraudulent schemes by providing return-calling services to the fraudsters
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`used to establish contact with potential victims. Robocall messages will often provide domestic
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`and toll-free call-back numbers; potential victims who call these numbers connect to the overseas
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`fraudsters, who then try to extort and defraud the potential victims.
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`5.
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`The Defendants profit from these fraudulent robocall schemes by receiving
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`payment from their co-conspirators for the services Defendants provide. In addition, on at least
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`one occasion Defendants received a direct payment from a victim of one of the fraudulent schemes.
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`6.
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`Since 2017 and continuing through the present, as a result of their conduct.
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`Defendants and their co-conspirators have defrauded numerous victims out of millions of dollars,
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`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 scheme 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.^
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`^ 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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`JURISDICTION AND VENUE
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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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`11.
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`Defendant Kaen resides in Nassau County, New York, in the Eastern District of
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`New York. Kaen controls Defendants Global Voicecom, Inc., Global Telecommunication
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`Services Inc., and KAT Telecom, Inc., which he uses in furtherance of the fraudulent robocall
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`scheme. Kaen operates the Corporate Defendants as a single enterprise from his home in the
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`Eastern District of New York. One or more of the Defendants also conducts business as "IP Dish."
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`12.
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`Defendant Global Voicecom, Inc. is a New York corporation. The New York
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`Department of State, Division of Corporations Entity Information database identifies Global
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`Voicecom's principal executive office as being located in Great Neck, New York, in the Eastern
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`District of New York, and Kaen as the corporation's Chief Executive Officer.
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`13.
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`Defendant Global Telecommunication Services Inc. is a New York corporation.
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`Global Telecommunication Service's principal place of business is located in Great Neck, New
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`York, in the Eastern District of New York.
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`14.
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`Defendant KAT Telecom, Inc. is a New York corporation. KAT Telecom's
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`principal place of business is located in Great Neck, New York, within the Eastern District of New
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`York.
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`OVERVIEW OF THE ROBOCALLING FRAUD SCHEMES
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`A. Robocalling Fraud Targeting Individuals in the United States
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`15.
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`The robocalling fraud schemes in which the Defendants are engaged share the same
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`characteristics. Individuals at call centers located abroad, many of which are operating out of
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`India, are bombarding the U.S. telephone system every day with millions of robocalls intended to
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`defraud individuals in the United States. Many of these fraudsters impersonate U.S. government
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`officials, foreign government officials, or well-known American businesses, in order to threaten,
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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 pre-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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`16.
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`Foreign fraudsters operate many different schemes targeting individuals in the
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`United States, but the Defendants' robocall schemes include the following categories of
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`impersonation scams:
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`a. Social Security Administration ("SSA ") Imposters: Defendants transmit recorded
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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 individual's Social Security
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`benefits will be suspended, the individual has failed to appear before a grand jury
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`and face imminent arrest, or the individiual's social security number will be
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`terminated. When a call recipient calls back or connects to the fraudster, the
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`fraudster claims to be an SSA employee and typically tells the individual to transfer
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`substantial funds to the SSA for safekeeping until a new social security number can
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`be issued, at which point the individual's funds purportedly will be returned.
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`b. Internal Revenue Service ("IRS") and Treasury Imvosters: Defendants transmit
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`recorded messages in which IRS imposters falsely claim that the call recipient has
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`been implicated in tax fraud, the individual has avoided attempts to enforce criminal
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`laws, the individual has avoided court appearances, or the individual faces
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`imminent arrest. When a recipient calls back or connects to the fraudster, the
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`fraudster claims to be an IRS or Treasury employee and typically tells the recipient
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`to transfer funds to the IRS to resolve various fictitious tax and legal liabilities, or
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`for safekeeping in order to avoid seizure of assets.
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`c. United States Citizenship and Immisration Services CUSCIS") Imvosters:
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`Defendants transmit recorded messages in which USCIS imposters falsely claim
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`that the call recipient has failed to fill out immigration forms correctly, the
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`individual faces imminent arrest or deportation, that the individual's home country
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`has taken formal action that may result in deportation, or the individual has
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`transferred money in a way that will result in deportation. When a call recipient
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`calls back or connects to the fraudster, the fraudster claims to be a USCIS employee
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`and typically tells the individual to pay various fees or fines to avoid immigration
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`consequences.
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`d. Foreisn Government Imvosters: Defendants transmit recorded messages in which
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`foreign government imposters, often in foreign languages, falsely claim to be from
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`the U.S.-based consulate of a foreign government and that the call recipient faces
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`problems with immigration status or a passport. When a call recipient calls back
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`or connects to the fraudster, the fraudster falsely claims that the individual must
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`pay various fees or fines in order to avoid immigration consequences such as
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`deportation.
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`e. Tech Support Imposters: Defendants transmit recorded messages in which
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`fraudsters operating tech support scams impersonate various well-knovm tech
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`companies such as Apple or Microsoft, and falsely claim that the call 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 to
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`the victim's bank accounts.
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`17.
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`These robocalls are often "spoofed" so that they falsely appear on a victim's caller
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`ID to originate from U.S. federal government agency phone numbers, such as the SSA's main
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`customer service number, from local police departments, 911, or from the actual customer service
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`phone numbers of legitimate U.S. businesses. These "spoofed" numbers are used to disguise the
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`origin of the robocalls and the callers' 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 U.S.
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`government agency or other legitimate enterprise.
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`18.
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`Individuals who answer or otherwise respond to these calls eventually speak to live
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`fraudsters who tell the individuals lies intended to frighten and confuse them so that the fraudsters
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`may 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 information
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`has been implicated in criminal activity, that the individual faces imminent arrest or deportation,
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`and that the individual's assets are about to be forfeited to the government. Once an individual is
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`overcome by fear and panic, the fraudsters keep them on the phone and offer reassurances that the
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`individual's purported legal problems can be resolved through payment of money, or that the
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`individual's money must be transferred for safekeeping to the government agency the fraudsters
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`are impersonating. The fraudsters often claim that the victim's payment will be retumed to them
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`in the immediate future. In reality, once the fraudsters are convinced they have extorted as much
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`money as possible from the victim, they drop all contact, leaving the victim without meaningful
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`recourse. Fraudsters receive victims' money through retail gift cards, bank wires, cash payments,
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`cryptocurrency transfers, and other methods.
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`19.
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`Since October 2018, the most prolific robocalling scam impersonating U.S.
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`government officials—and 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]-pCXXX]
`I repeat 619-[XXX]-[XXXX] thank you.
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`20.
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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 for 2018, its Consumer Sentinel database received more than 39,000 fraud
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`complaints about SSA imposter calls, with estimated losses of approximately $11.5 million; for
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`2019, the FTC reported that SSA imposter call complaints rose to approximately 166,000 with
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`associated losses of more than $37 million.^ Complaint numbers substantially underrepresent the
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`extent of the problem, because most victims do not report their losses to the government.
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`B. How Calls From Foreign Fraudsters Reach U.S. Telephones
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`21.
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`The Defendants' robocalling fraud schemes, which involve robocalls that originate
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`abroad and target individuals in the United States, are all dependent on VoIP and related
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`technology to create the calls. VoIP calls use a broadband intemet connection—as opposed to an
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`analog phone line—^to place telephone calls locally, long distance, and internationally, without
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`regard to whether the call recipient uses a cellular phone or a traditional, wired phone. The
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`robocalling fraud schemes also require U.S.-based telecommunications companies—^referred to as
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`"gateway carriers"—^to introduce the foreign phone traffic into the U.S. phone system. A foreign
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`call center or telecommunications company that places VoIP calls to U.S. telephones must have a
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`relationship with a U.S. gateway carrier. From the gateway carrier, most VoIP calls will pass
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`through a series of U.S.-based VoIP carriers before reaching a consumer-facing "common carrier"
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`such as AT&T or Verizon, and ultimately a potential victim's phone. One of the Defendants' roles
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`in the fraudulent schemes is to serve as a gateway carrier for the fraudulent robocalls.
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`22.
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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 follo'wing
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`information: the date and time of the call, the destination number (intended recipient), the source
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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 dovmstream company
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`to which the provider sent the call. These records are generated automatically as a call is routed
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`^ 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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`through telecommunications infrastructure in a manner that achieves the lowest cost to transmit a
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`given call, known in the industry as "least-cost routing." Calls may be traced through these records
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`back to their gateway carrier, and thus to their foreign source. The telecommunications industry
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`refers to this tracing process as "traceback."
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`23.
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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 fraud.
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`DEFENDANTS^ ONGOING PARTICIPATION IN ROBOCALLING FRAUD SCHEMES
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`24.
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`Since at least 2017, the Defendants have knowingly provided U.S.-bound calling
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`services to foreign fraudsters operating robocall scams, acting as a gateway carrier and passing
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`robocalls into the U.S. telephone system by the millions. The Defendants are paid for each call
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`they pass into and through the U.S. telephone system. In addition, the Defendants have provided
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`return-calling services to the fraudsters operating the robocall scams, for which Defendants are
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`also paid, enabling the fraudsters to establish contact with unwitting individuals after the
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`individuals are deceived by a robocall.
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`25.
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`There is substantial evidence of the Defendants' knowledge of the fraudulent nature
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`of the calls they transmit, including call records showing high percentages of short-duration,
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`unanswered calls^ passing through their systems by the millions; thousands of spoofed calls
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`purporting to be from "911" and similar numbers originating from overseas; dozens of complaints,
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`warnings, and inquiries from vendors and other telecommunications companies about fraud,
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`spoofing, and short-duration "junk" calls; repeated warnings and inquiries from an industry trade
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`^ 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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`group about the scam robocalls passing through the Defendants' system; and receipt of numerous
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`complaints from common-carrier telecommunications companies whose customers were victims
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`of these fraud schemes.
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`A. Defendants Knowingly Introduce Fraudulent Robocalls into the U.S. Telephone
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`System
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`26.
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`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 they
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`are fraudulent. Defendants regularly transmit massive volumes of such calls. For example, the
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`Government's investigation has revealed a sample of more than 7.7 million calls that Defendant
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`Global Voicecom routed through a single downstream VoIP carrier over 19 days in May and June
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`2019, months after Kaen's response to the FCC. Of those calls, approximately 86%, more than
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`6.6 million calls, were one second or less in duration, indicating exceedingly high levels of junk
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`and fraudulent robocalls. Moreover, a small sample of approximately 330,000 of these calls was
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`examined in greater detail; of these approximately 330,000 calls in that 19-day period, more than
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`270,000 (approximately 81%) were from source numbers (the numbers appearing on the
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`recipients' caller IDs) identified as fraudulent robocalls. Similarly, of the more than 106,000
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`robocalls spoofing the SSA's toll-free customer service number in January and February 2019 that
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`Defendant Global Voicecom transmitted into the United States, nearly 60% had a call duration of
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`less than one second, and another 38% were between one and 60 seconds in duration. During that
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`same period in January and February 2019, Defendant Global Voicecom also ran through its
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`systems thousands of calls spoofing 911, 1911, and 11911, with similar short call durations.
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`27.
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`Since 2017, significant numbers of fraudulent robocalls have been traced back to
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`the Defendants and brought to their attention. For example, U.S. common carrier AT&T has
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`11
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`notified Defendants on numerous occasions about fraud traced back to Defendants' operations.
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`These notices include a November 16, 2017, email to IP Dish:
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`The following calls to AT&T cell phone customers were received using the spoofed
`caller ID numbers of a non-working number at the US Department of Homeland
`Security headquarters. Callers impersonated US Citizenship and Immigration[ ]
`Services personnel and defrauded an AT&T customer of $1,450....
`Pursuant to the customer and carrier network fraud protection provisions of the
`Telecommunication Act and the Telephone Records Privacy Protection Act (47
`use 222(d)(2)), could you provide the name(s) of your upstream carriers? We are
`tracing these calls to their source so they can be stopped.
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`AT&T sent similar emails about USCIS impersonation scams to Defendants Kaen and Global
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`Voicecom in September 2017, November 2017, April 2018, and July 2018. Similarly, AT&T
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`emailed Defendants about SSA and other imposter robocalls on January 29, 2019:
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`We have been receiving AT&T customers complaints about spoofing fraud from
`your network. In the first complaint calls are originating from a toll free number
`owned by the US Social Security Administration. Callers falsely claim to be US
`Government officials and attempt to extort money from our customers. We have
`verified this number is not out-pulsed as a legitimate caller ID by the real US Social
`Security Administration....
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`In the second complaint calls are originating from the toll free number of DirecTV
`(AT&T). Callers falsely claim to be AT&T/DirecTV technical reps and social
`engineer remote access to our customer's computers in order to make fraudulent
`wire transfers from online banking applications....
`Could you provide the names and contact numbers of the parties that sent these
`calls to your network.
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`AT&T sent similar warning notices about SSA imposter calls to Defendants Kaen and Global
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`Voicecom in February 2019 and May 2019.
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`28.
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`Another VoIP carrier that received call traffic from Defendants, Peerless Network,
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`Inc., sent even more warning notices and inquiries to Defendants. For example. Peerless Network
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`sent a warning notice about spoofed calls in September 2018 with a request that Defendants
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`investigate and "take the appropriate action." Peerless Network sent approximately 12 of these
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`warning notices between September 2018 and March 2019.
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`12
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`29.
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`Not only have other telecommunications companies provided warnings and notices
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`to Defendants as a result of tracebacks, but a leading industry trade group, USTelecom, has done
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`the same. For example, USTelecom traced back an August 19,2019 robocall that originated from
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`India and came through Defendant Global Voicecom as the gateway carrier. The robocall was
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`also routed through Defendant KAT Telecom. This robocall stated that there was "suspicious
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`activity" associated with the individual's social security number. USTelecom provided the
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`following warning notice in its correspondence to Defendant Global Voicecom on August 27,
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`2019:
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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 per day. Because Caller-ID changes with each call, blocking the ANI^ is
`not effective.
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`Blocking specific telephone numbers is an ineffective means to stop fraudsters who are willing—
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`and have the ready ability—^to spoof any number as the caller ID number for their fraudulent
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`robocalls. For example, in January and February 2019, Defendants transmitted fraudulent
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`robocalls spoofing 911,1911, and 11911. Nevertheless, if the Defendants responded at all to these
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`notices and warnings from other telecommunications-industry actors, they routinely responded
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`that the "offending" number had been blocked, as though the spoofed telephone number and not
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`the caller were responsible for the fraud.
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`30.
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`Similarly, USTelecom traced an October 3, 2019 robocall to Defendant Global
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`Voicecom as the gateway carrier. This robocall also originated from India. USTelecom provided
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`^ "ANI" means "Automatic Number Identification," and for these purposes refers to the
`purported source number for the call.
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`13
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`the following warning notice in its October 11, 2019 correspondence to Defendant Global
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`Voicecom:
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`Captured recordings suggest these calls are perpetrating a SERIOUS FRAUD.
`Calls placed from specific numbers obtained by scammers, using an automated
`voice to inform called party that they are in trouble with IRS and will be arrested.
`Called party is instructed to call back to speak to an agent... We are using traceback
`to try to find the source(s) of the millions of outbound calls that are being made to
`initiate the scam.
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`USTelecom's records indicate that this robocall was transcribed in part as follows:
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`This call is from Federal Tax and audit division of internal revenue services. This
`message is intended to contact you regarding an enforcement action executed by
`the US treasury intending your serious attention. Ignoring this will be an intentional
`second attempt to avoid initial appearance before a magistrate judge or a grand jury
`for federal criminal offense. This is a final attempt to reach you to resolve this issue
`immediately and to speak to a federal agent to call us back on 510-[XXX]-[XXXX].
`I repeat 510-[XXX]-[XXXX].
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`USTelecom identified Defendants as the gateway carrier for foreign fraudulent robocalls on at
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`least eighteen other occasions in the latter half of 2019 alone, each time providing similar warning
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`notices about the nature of the scam robocalls. USTelecom's records indicate that on nearly all of
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`these 2019 tracebacks, the scam robocalls came from the same company in India.
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`31.
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`Defendants transmitted another group of fraudulent robocalls that spoofed the
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`phone number for a foreign government consulate in New York, New York. These calls conveyed
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`foreign-language messages about problems with the individual's immigration status or passport.
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`Like with SSA imposter robocalls and other U.S. govemment-imposter scams, individuals who
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`returned the calls to the consulate imposters were told lies intended to frighten them and make
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`them think there are imminent consequences for involvement in criminal activity, and that funds
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`must be transferred to the fraudsters to resolve the matters. Like with the SSA imposter scams,
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`once the fraudsters are convinced they have extorted as much money as possible, they drop all
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`contact with the victim. In 2018, the FCC traced this consulate imposter scam back to Kaen and
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`14
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`Case 2:20-cv-00474-BMC Document 1 Filed 01/28/20 Page 15 of 24 PageID #: 15
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`IP Dish, who informed the FCC that the calls came from a Hong Kong entity that was making tens
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`of thousands of calls per day. The FTC's Consumer Sentinel database reflects more than 1,000
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`complaints related to the spoofed phone number of the consulate. These complaints relate
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`hundreds of thousands of dollars in victim losses. Defendants continue to conduct business with
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`this Hong Kong entity more than a year later.
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`32.
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`Despite these notices and numerous others. Defendants continue to pass fraudulent
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`robocalls into the U.S. telephone system to millions of U.S. telephones every day.
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`B. Defendants Provide Return-Calling and Toll-Free Services for Robocall Schemes
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`33.
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`Not only do Defendants knowingly pass fraudulent robocalls by the millions into
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`the U.S. telephone system, but they also provide return-calling services to fraudsters so that
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`potential victims can call them back. These toll-free and direct-inward-dial ("DID") telephone
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`numbers^ and related services are provided in the robocall message as call-back numbers, and
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`appear to be U.S. telephone numbers and thus enable fraudsters to further deceive individuals
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`about the robocall's origin and the identities and locations of the fraudsters at the other end of the
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`call. In reality, what appears to the individual to be a U.S. telephone number is actually a telephone
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`number that Defendants register to an internet address designated by the foreign fraudsters. Thus,
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`the DID and toll-free numbers can be used to ring telephones anywhere in the world.
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`34.
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`While DID and toll-free numbers used for return-calling purposes cannot be
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`"spoofed" like outgoing robocalls, the use of a U.S. DID or toll-free number in Defendants'
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`robocalls schemes serves much the same purpose as spoofing—deception. The DID and toll-free
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`services provided by Defendants use VoIP technology to direct potential victims' retum calls from
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`^ As applicable to the fraud schemes, direct-inward-dial numbers are phone numbers with U.S.
`area codes that are routed to fraudulent call centers in foreign countries through VoIP
`technology.
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`15
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`

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`Case 2:20-cv-00474-BMC Document 1 Filed 01/28/20 Page 16 of 24 PageID #: 16
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`the United States to the foreign fraudsters' call centers. The Defendants have knowingly provided
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`hundreds of these DID and toll-free numbers and associated calling services to foreign robocall
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`fraudsters.
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`1. DID Numbers Used to Further Robocalling Fraud Schemes
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`35.
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`Like telephone numbers used to make U.S.-bound robocalls, DID numbers can be
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`traced to identify their providers and users. This process was used to identify DID numbers
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`provided by the Defendants for use in the fraudulent robocall schemes. For example, records
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`obtained from one U.S. company demonstrate that it assigned 902 DID telephone numbers to
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`Defendant Global Voicecom. Approximately 55% of these DID telephone numbers are associated
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`with more than 28,000 complaints in the FTC's Consumer Sentinel database. One of the 902 DID
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`telephone numbers appeared in a robocall sent to millions of U.S. telephones in early 2019:
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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 b