Dialing Back: How Phone Companies Can End Unwanted

Dialing Back:

How Phone Companies Can

End Unwanted Robocalls

Maureen Mahoney

November 2015

Table of Contents

Acknowledgments ....................................................................................................................... ii

Executive Summary .................................................................................................................... 1

Why Americans Are Deluged with Robocalls .............................................................................. 3

1. The Do Not Call List Has Not Stopped Robocalls ........................................................ 3

2. Enforcement Is Challenging ......................................................................................... 3

3. Consumers Pay the Price ............................................................................................ 4

Phone Companies Can Dramatically Reduce Robocalls ............................................................. 5

1. Four Robocall Filtering Technologies ........................................................................... 6

2. Phone Companies Can Implement Robocall Filters ..................................................... 8

3. Phone Companies Should Use Anti-Spoofing Techniques .......................................... 9

Phone Companies’ Current Call Blocking Offerings Fall Short .................................................. 10

1. Few Services for Traditional Landline Customers, More for VoIP .............................. 10

2. Major Phone Companies Have Resisted Advanced Call Blocking Tools .................... 11

3. Ending Robocalls Will Benefit Phone Companies, Consumers .................................. 12

Recommendations .................................................................................................................... 13

Appendix: Phone Companies’ Current Call Blocking Options .................................................... 14

Notes ........................................................................................................................................ 17

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ACKNOWLEDGMENTS

This report is the result of a lot of hard work by many different people. I’m deeply indebted to

Michael McCauley and Susan Herold for their extensive review and edits to the piece, as well as

their helpful advice. Thanks to Elizabeth Foley, Elisa Odabashian, and Tim Marvin for helping to

guide this project to completion. Thanks also to Jason Mogus, Delara Derakhshani, Christina

Tetreault, Glenn Derene, and David Butler for their input, and Katherine Ammirati for her

excellent research. I’m thankful to Henning Schulzrinne and Payas Gupta for offering their

technical expertise. I also thank Jane Healey, Christine Young and Karim Salamah for their

careful fact-checking work. Of course, I am solely responsible for any errors. Finally, many

thanks to the experts who agreed to be interviewed for this report.

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Dialing Back: How Phone Companies Can End

Unwanted Robocalls

EXECUTIVE SUMMARY

The Do Not Call list, federal law enforcement efforts, and actions by the states have not been

enough to protect Americans from the flood of unwanted robocalls that have become rampant in

recent years. Hundreds of thousands of people complain each month to the Federal Trade

Commission (FTC) about unwanted calls,

and it’s estimated consumers lose $350 million a

year to phone scams.

Thanks to rapid advances in Internet technology, robocallers can make

thousands of auto-dialed calls per minute for a relatively low cost.

Robocall scammers easily

escape detection and punishment by operating overseas

or using software to disguise—or

spoof—their name and number.

The problem is so bad that federal agencies and Congress

have been exploring solutions to the unwanted robocall problem.

Technological solutions are necessary to address this problem. A number of leading experts

agree that phone companies have the power right now to implement technologies to

dramatically reduce robocalls.

Consumers Union surveyed a variety of experts and innovators and found there are at least four

proposed and existing robocall filtering technologies that phone companies could pursue to help

protect their customers from unwanted robocalls. One solution, the Primus Telemarketing

Guard, has been successfully implemented for traditional and broadband phone lines in

Canada,

which calls into question why similar technologies have not been offered in the United

States.

Consumers Union launched a nationwide grassroots campaign in February 2015 to convince

the major phone companies to offer customers free robocall blocking tools.

Over 500,000

Americans to date have signed the petition at EndRobocalls.org,

but the major phone

companies have failed to provide their customers with meaningful relief. Right now, consumers

with traditional analog landlines have only limited options to protect themselves from unwanted

calls, such as obtaining inadequate blocking services from their phone company, or buying a

phone or call blocking device that allows them to stop selected numbers.

And while many

smartphone users and those with Internet-based phone service now have access to advanced

third-party blocking tools,

the smartphone tools may work better if offered to consumers

through the phone companies.

Moreover, the advanced blocking tools may be more widely

used if provided directly by the carriers.

In June 2015 the Federal Communications Commission (FCC) made clear that phone

companies have the legal authority to offer call blocking tools to their customers,

and FCC

Chairman Tom Wheeler has urged them to do so.

But the top phone companies have resisted

offering advanced filtering technology to all of their customers, citing concerns that customers

may not receive wanted calls.

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Consumers Union interviewed a number of leading experts to find out what more phone

companies could do to block unwanted calls. We found that phone companies could pursue at

least four proposed or existing advanced filtering technologies that would provide customers

substantial protection from unwanted robocalls.

• Phone companies could easily offer a filtering service directly to consumers with modern

phone lines. For example, third-party companies have already developed smartphone

apps that block unwanted calls. And Nomorobo, a free robocall blocking service, is

currently available to many consumers with Internet-based service, or VoIP (Voice over

Internet Protocol).

● Filtering tools could also be offered to consumers with traditional landlines. The Primus

Telemarketing Guard has been available at no extra cost to traditional landline and VoIP

users in Canada for years. And, according to Primus Canada, it could potentially work

for traditional landline, VoIP, and wireless customers in the United States. Filters that

can block calls at the “gateway” between networks have also been proposed and could

potentially work for traditional landline, VoIP, and wireless customers.

● Companies have the technology to reduce call “spoofing”—the practice of disguising the

origin of robocalls on Caller ID.

This would improve telephone security and call filtering

techniques.

● Phone companies’ current robocall blocking offerings are insufficient and often costly for

customers.

● Filtering unwanted robocalls would also benefit phone companies by reducing customer

complaints and ultimately lowering customer turnover.

Recommendations:

● Phone companies should immediately offer free robocall-filtering services to all of their

customers based on latest available technology.

● Phone companies should immediately develop “Do Not Originate” techniques to reduce

spoofing by fraudulent callers.

● Phone companies should continue to pursue call authentication strategies as a long-

term solution to the spoofing problem.

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WHY AMERICANS ARE DELUGED WITH ROBOCALLS

• 217.9 million phone numbers are registered on the Do Not Call list;

• 305,000 complaints about Do Not Call violations were made in September 2014;

• The FTC has recovered less than 9 percent of the $1.2 billion in fines levied for “DNC

[Do Not Call] & Robocall” violations.

The Do Not Call List Has Not Stopped Robocalls

Federal regulatory efforts haven’t been enough to stop unwanted robocalls. In part because of

changing technology, the numbers of unwanted robocalls have soared,

and it has become

much harder for scammers to be held accountable. Many of the unwanted calls come from

overseas robocallers who don’t respect the Do Not Call list and don’t fear getting caught.

Moreover, because the registry is designed to protect consumers from unwanted telemarketing

calls,

consumers may receive legal, but unwanted, robocalls at home from politicians or other

groups.

Millions of Americans have placed their phone numbers on the Do Not Call Registry since it was

established in 2003 in the hopes that it would stop unwanted calls.

There are now nearly 218

million phone numbers on the registry.

The rules make it illegal for most commercial

telemarketers to contact numbers on the list without permission,

whether it is an auto-dialed or

a manually-dialed call.

Still, many types of calls are exempt from the Do Not Call list and other federal rules, so

consumers continue to get legal calls they don’t want. Live telemarketers

can autodial home

phones

for up to 18 months after the last time the consumer did business with that company.

And non-profits, pollsters and politicians are permitted to autodial home phones

on the DNC

list without first getting permission.

Recently, the FCC expanded the types of acceptable auto-dialed calls to cell phones. Now,

businesses may send a limited number

of informational robocalls to a cell phone for financial

reasons such as fraud, a data breach,

or pending money transfers.

Healthcare providers

may also send a limited number of robocalls to cell phones for appointment reminders,

prescription refills, pre- and post-care instructions, and billing.

Enforcement Is Challenging

Why is enforcement so difficult?

• Scammers hide their identities by placing “spoofed” calls through Internet-based

networks (VoIP);

• Calls placed over VoIP often must be traced through multiple carriers, making it time-

consuming to track down scammers;

• Many scammers are located overseas, where they are difficult to catch;

• Scammers try to spend their money as quickly as they get it, so it can be difficult to

recover.

Technological innovations have unleashed powerful economic incentives for scammers to

robocall consumers. New technology allows robocallers to make thousands of inexpensive auto-

dialed calls per minute.

For example, cloud hosting services and call-generation software

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platforms let telemarketers send calls without purchasing costly hardware.

All they need is a

disposable cell phone

or an account with a service that allows them to send these calls.

Others may set up fraudulent boiler rooms where live agents autodial consumers. Many of these

boiler rooms are located overseas where they are off-limits to detection and prosecution.

The

FTC doesn’t have the authority to force an overseas carrier to turn over their call records to

track down a scammer.

The Voice over Internet Protocol (VoIP) calls placed from overseas

cost the same as a call made from the United States, so there is no financial incentive for

scammers to set up shop in the U.S. where they can be more easily caught.

Another technology makes it harder to track down where robocalls originate. Call “spoofing”

disguises the caller’s name or number on Caller ID, and can be accomplished through the use

of an app.

While calls made on traditional landline phones correlate to a phone number tied to

a physical location,

scammers using VoIP technology can use applications so that it appears

they are calling from a different number. According to Vijay Balasubramaniyan of Pindrop

Security, a company that combats phone fraud for businesses: “You can use [a VoIP] app and

you can pretend to be anyone.”

There’s little chance scammers using VoIP will be caught, because it is extremely difficult to

track down the caller.

Calls placed over VoIP may be routed through several different carriers

before they reach the consumer.

According to the FTC’s Bikram Bandy, “It’s not uncommon to

see that these calls are routed through four, five, six networks.”

But, Bandy notes that the FTC

can often identify scammers by tracing credit card or debit card payments made by defrauded

consumers.

A variety of factors further inhibit law enforcement efforts. According to the FTC,

even if they find the scammers, they typically can recover only a small portion, if any, of the

money taken from consumers. The scammers try to spend the money as quickly as they can.

“Enforcement has problems in terms of scaling, the time it takes to get one of these guys,” said

Henning Schulzrinne, Levi Professor of Computer Science and Electrical Engineering at

Columbia University, and formerly the Chief Technology Officer of the FCC. Before the

authorities could track them down, “they would disappear.”

Consumers Pay the Price

• Estimated $350 million lost by Americans to phone scams annually;

• $19 million lost to the IRS scam alone.

“A few months ago I received a call from a ‘private caller.’ That's how my doctor shows

up, so I answered it. The caller said they were sending out new Medicare cards and

wanted to verify my information. She verified my name, address, etc. Then she said get

out your checkbook and read me the numbers on the bottom of the check. I knew this was

my bank account number so I said I don't have a checking account. She angrily replied,

you do too, it's with [a major bank]. Then I knew she already had too much info about me

and hung up.”

-- Gerald, Joshua, TX

Consumers are stuck paying the price for relentless robocalls, many of which are scams

designed to trick them out of their money. Americans lose an estimated $350 million a year to

phone scams. For example, consumers tell us that they frequently hear from the infamous

“Rachel from Cardholder Services,” a fraudulent robocall that promises to lower credit card

interest rates for a lump sum.

Consumers also report receiving robocalls from crooks trying to

charge them to activate “free” medical devices that a friend or family member has supposedly

purchased.

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These calls are not only annoying, they can be downright threatening. In recent years

consumers have received calls from scammers claiming to be Internal Revenue Service (IRS)

agents, demanding money to cover a fictional tax bill.

Some consumers report being

robocalled by debt collectors over money that they don’t owe.

And crooks masquerading as

tech support representatives try to fool consumers into paying them to fix a phony computer

problem, or to allow them to install software that will extract their personal information.

Spoofing makes scamming consumers out of their money even easier, since they are more

likely to pick up a call if they are tricked into believing it is legitimate. For example, IRS

scammers often spoof a Washington, D.C., area code, where the tax collection agency is

based.

Or scammers might spoof a consumer’s own phone number.

Their tricks may be

effective in part because people tend to have more faith in their Caller ID than, for example, an

email address. Research Scientist Payas Gupta of New York University Abu Dhabi et al. argue,

“[A]ttacks that utilize the telephone as a resource are more successful because people in the

past have trusted the telephony channel.”

Scammers have plenty of incentives to robocall consumers. Not only can they steal money from

the consumer, but they can sell credit card and other personal information they obtain from

victims to other criminals looking for new targets.

One scam victim can end up being

victimized multiple times.

PHONE COMPANIES CAN DRAMATICALLY REDUCE

ROBOCALLS

“There are at least eight technical solutions that, individually and in combination, can

reduce robocalls.”

–Prof. Henning Schulzrinne, former Chief Technology Officer of the

FCC

Experts argue that phone companies have the power right now to implement new technologies

to dramatically reduce robocalls. They have proposed or created at least four types of advanced

robocall-blockers that can stop unwanted calls with little intervention on the part of consumers.

One of these proposed solutions, the third-party filters that operate through “gateway”

technology, could potentially work for customers who use traditional landlines as well as those

who use cell phones or Voice over Internet Protocol (VoIP),

according to Henning Schulzrinne.

Another, the Primus Telemarketing Guard, has been offered to broadband and traditional

landline consumers in Canada for several years.

These tools could sort through calls to stop

unwanted robocalls so that consumers don’t have to manually block calls one by one.

Phone companies also have the tools to immediately reduce call spoofing. Carriers could

pursue Henning Schulzrinne’s conception of a “Do Not Originate”

list that would protect callers

from some of the most commonly-spoofed numbers, like the IRS. Placing a number on the Do

Not Originate list would tell companies to block calls with that number originating from certain

providers or gateways. In the next few years, carriers also should implement call authentication

strategies so that callers’ identities could be confirmed when placing calls,

and consumers

might once again trust their Caller ID.

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Four Robocall Filtering Technologies

Nomorobo

This filter works by blocking “blacklisted” numbers—phone numbers reported to the FTC for Do

Not Call list violations, and numbers that consumers report are used by robocallers.

Nomorobo works through a service called “simultaneous ring” that is free to most VoIP users

and lets a phone call ring in two locations at once. Currently, Nomorobo is only available to

consumers with VoIP service.

Customers can have a phone call ring on both their home and

cell phone at the same time. Subscribers arrange for incoming calls to reach their own number

and Nomorobo servers simultaneously. When Nomorobo identifies an unwanted call, it zaps the

call after the first ring.

Additionally, Nomorobo tries to identify calls that are highly likely to be spam by using a recently

developed system known as a “honeypot.”

Honeypot software collects information about calls

placed to a pre-designated group of phone numbers

—in this case, numbers that had been

abandoned by consumers for too many unsolicited calls. Since legitimate callers are probably

not calling an inactive number,

Nomorobo is able to blacklist numbers harvested from the

honeypot.

According to Payas Gupta, Research Scientist at New York University Abu Dhabi, “telephone

honeypots are promising” in reducing robocalls and recommends the phone companies and

security vendors use them. He explains, “When a call comes in, then one can provide a variety

of responses ranging from picking up the call, automated interaction with the caller, monitor the

calling patterns, recording the calls if legally allowed, etc.” further noting that “if the number is

spoofed, one can try to identify the source location by analyzing audio and calling patterns.”

Moreover, if used by carriers, honeypots could be even more effective in identifying unwanted

robocalls. Says Gupta, “Telcos could share information from the telephone honeypots and mark

unwanted calls in real time.”

Ultimately, Nomorobo runs all the collected data through an algorithm to identify suspicious

calls.

In this way, Nomorobo can even block “spoofed” calls. Company owner Aaron Foss

explains: “A robocaller might spoof a random number but when that fake number starts calling

5,000 people in an hour, well, humans don’t call like that.”

Callers identified by the algorithm

as suspicious are asked to input a number to prove they are not machines.

To ensure

legitimate robocalls like school closings and emergency notifications get through, they are

placed on a whitelist at the request of consumers.

About 280,000 consumers have subscribed to Nomorobo,

and many have reported positive

results. Michael from Tampa is one of the most enthusiastic. He reports that: “Since adding the

Nomorobo service, my phone has gone from ringing up to 20 times each day with useless calls,

down to allowing just the one or two calls each day that I really want to receive. The silence in

my home is gratifying, and Nomorobo does not seem to mistakenly block any calls that I want to

receive.”

Twenty-five of a group of forty volunteer testers for Consumer Reports gave the

service the highest rating on a scale of one to five, and an additional nine volunteers gave it four

or four and a half stars.

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Primus Telemarketing Guard

Primus Canada, an independent Internet and phone provider that provides services to hundreds

of thousands of Canadian customers, developed Telemarketing Guard, another filtering system

that tackles the problem of unwanted robocalls. It’s been available for free to Primus’s traditional

landline and broadband customers in Canada since 2007.

The system harnesses user feedback and its monitoring system to identify suspicious calling

patterns and screen unwanted calls before the customer’s phone rings. Customers using

Telemarketing Guard can also control their own blacklists and whitelists via an online portal. If a

call is suspicious but isn’t on the blacklist, then it is “greylisted,” and the consumer is able to

decide whether or not to take the call, block it, or send it to voicemail.

When a greylisted call comes in—those numbers that have been identified by other customers

as possible spam—the caller is asked to identify themselves to the recipient. They are invited to

press 1 and then record their name. The recording is played to the consumer, who can decide

to send it to voicemail, answer it, or hang up.

According to Brad Fisher, Senior Vice President of Marketing and Product at Primus Canada,

consumers receive at least 20 fewer telemarketing calls per month with the service.

The

service also helps customer retention for the phone company. It has been reported that 87

percent of customers cite the Telemarketing Guard as the main reason they continue to use

Primus Canada.

It’s rare that people making legitimate calls complain about getting intercepted by the

Telemarketing Guard, according to Fisher: “A caller can only be blocked if they are on the

customer’s personal blacklist.” He elaborates, “If a call is wrongly intercepted by the greylist, the

customer can accept the call and easily add that caller to their personal whitelist.”

Though Primus Canada says that its software is highly adaptable to US networks, phone

companies here do not offer it.

While a few companies expressed interest in the service after

Primus presented at a FTC Robocalls conference in 2012, they ultimately did not pursue it.

USTelecom speculated that the “legal impediment”—their concern that the software would

violate carrier obligations to avoid blocking calls—accounted for the lack of interest.

But the

FCC ruled in June 2015 that phone companies can legally use this type of software to block

robocalls.

Third-Party Filters for Gateway Technology

Companies could work with a third-party service to filter unwanted robocalls for consumers.

Schulzrinne notes that these filters could be extended to all customers by re-programming the

software on the computers that serve as a “gateway” between VoIP lines and the legacy

systems that deliver the calls to the consumers.

While these tools have not yet been brought

to market, as conceptualized, they could block or direct certain types of calls to voicemail, or to

another party based on information reported to carriers by consumers.

Schulzrinne says,

“They could start essentially making it possible for third parties to do filtering in a robust way.”

Phone companies could use third-party filters to screen unwanted robocalls on landline,

broadband, and cell phones.

It’s clear that phone companies could do more to work with third parties to address robocalls.

When discussing the role of gateway providers in stopping unwanted calls, Adam Panagia of

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AT&T

noted that “We’re really not there yet on sharing originating numbers that are involved in

robocalling campaigns . . . I think that’s somewhere we need to be and . . . the third-party

blocking applications . . . already have a lot of these numbers that are available. . . .[W]e need

to do a better job in sharing that intelligence across the industry.”

Smartphone Apps

Consumers can currently download a number of smartphone apps to block robocalls to their

smartphones.

But carriers could also offer that technology to customers directly. For example,

the Call Control app (14 day free trial, then $2.99 per month) builds its blacklist from information

collected about spam calls from its 10 million users. They also block numbers identified as spam

by the Indiana Attorney General’s office and the federal Do Not Call list. Finally, they use

algorithms to monitor call activity across their Call Control users to identify bad robocallers. For

example, Ben Sharpe of Call Control says, “We can tell if a telephone number of a large bank

has been hijacked and is being spoofed.”

100

PrivacyStar is another app that can automatically block calls they’ve identified as fraudulent. It

blocks spam calls, and has a green, yellow and red color-coded system for incoming calls to

indicate to the user whether the call is likely legitimate. The app also allows consumers to easily

report call violations to the FTC. To access all of the features of the service, consumers may be

charged a fee.

101

Jonathan Sasse of PrivacyStar says that if the scammer is “spoofing a number

like your own, we can block those. If they’re spoofing a number that’s otherwise inactive, or if it

belongs to a real business, we see abnormal activity, that’s an opportunity to blacklist.”

102

Schulzrinne points out that some of the apps don’t work as well as consumers would like and

have mixed ratings online.

103

He notes that “Current platforms aren’t really designed to make it

easy for third parties to inject themselves into the phone stream.”

104

But, he says, “With the

cooperation of carriers, [they] could work better than they do today.”

105

Phone Companies Can Implement Robocall Filters

Phone companies could offer filters to protect consumers from unwanted robocalls. According to

Schulzrinne, the third-party filters installed at network “gateways” potentially could be offered to

consumers with landline, VoIP, and wireless phones,

106

while Primus Canada argues that

Telemarketing Guard potentially could be offered to these three types of services in the United

States. Offering the technology associated with the smartphone apps to traditional landlines

would likely be more cost-intensive and would differ for each phone company.

107

Primus Canada’s Telemarketing Guard potentially could be used for landline, VoIP, and

wireless phones in the United States, according to the company.

108

“Telemarketing Guard does

not require customers to purchase or install any equipment or software, or any additional

features,” says Brad Fisher. Further, he notes that “The system works at the network level,

through very typical equipment.”

109

A software upgrade also would allow third-party gateway filters to work with major U.S. phone

companies, says Schulzrinne. These gateway filters have been conceptualized but not yet

developed.

110

Schulzrinne explains that they could be added as part of a software upgrade to

the modern gateways between the Internet-based lines through which robocallers send calls,

and the lines that actually deliver the call to the consumer. He says that interfaces at the

gateway could be configured to screen unwanted robocalls. The gateways are “designed to be

highly programmable,” and they feature interfaces to counter fraud.

111

According to Schulzrinne,

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adding new interfaces to these gateways to filter robocalls would not be very different from

steps the phone companies already take to address fraud.

112

When asked about the cost, he

said that it is “well within the realm of feasibility.”

113

App makers have reached out to phone companies about applying the technology. Says

Jonathan Sasse of PrivacyStar, “We’ve been trying to work with the carriers to improve the

situation if not stop it,” citing Sprint Prepaid, Boost, MetroPCS, Virgin Mobile, and TracFone as

companies for whom they have offered products for Android phones.

114

According to Sasse,

“We collaborate with the carrier on pricing, features and distribution.”

115

A spokesman for

TracFone, Evan Oei, says PrivacyStar’s Call Detector app is available to customers through the

Google Play store.

116

Ben Sharpe says that Call Control has discussed with carriers the option of applying

the technology that powers their smartphone app to the carriers’ systems to filter robocalls for all

landline, mobile and broadband consumers. According to Sharpe, the cost to integrate the

technology would depend on the carriers’ existing set up.

117

As for the prospect of applying similar technology to traditional landlines, Jonathan Sasse of

PrivacyStar envisions that consumers could go online to manage their account and stop

different types of calls, though he admits it would “require upgraded technology.”

118

He said the

required upgrade “isn’t trivial,” but depends on the carrier and the systems they have in place.

119

Similarly, Sharpe says that they have been offering technology “to the phone companies for the

last three or four years, and predicts options could be made available for customers to “access

their personal settings on their phone or web portal for their landline” and set up do not disturb

mode, personal whitelists and blacklists, as well as block private and unknown calls.

120

Nomorobo founder Aaron Foss has made his service available to VoIP customers that have

enabled the simultaneous ring service, even without their phone company’s cooperation.

121

Foss says his program theoretically could be used by all phone customers, saying carriers need

only switch on simultaneous ring for landline and wireless. According to Foss, this could be

handled through “software switches”—meaning the software that connects the lines through

which the call originated and those that actually deliver the call to the consumer.

122

Yet he

admits that phone companies may be reluctant or unwilling to make this upgrade because

traditional landline networks are old and unreliable.

123

As for the prospect of extending

simultaneous ring to traditional landlines, Schulzrinne notes that “Older landline systems may

not support simultaneous ringing or carriers may choose not to enable the feature.”

124

For its

part, USTelecom points out that phone companies are in the process of transitioning to Internet-

based networks, and “Even where it might be possible to deploy simultaneous ring within an

existing TDM network, it is not clear whether it could be accomplished while still being able to

offer a NoMoRobo-type solution on a cost effective basis to end users.”

125

Phone Companies Should Use Anti-Spoofing Techniques

To ensure effective robocall blocking, the phone companies also must use technology to identify

spoofed calls. The filtering tools described above could be even more effective if the phone

companies’ Caller ID could be trusted. Carriers should work to address spoofing to establish

telephone security. There are currently at least two promising options to do so.

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“Do Not Originate” to Reduce Spoofing

Phone companies could cut back on spoofing by developing a “Do Not Originate” list. As

described by Henning Schulzrinne, some carriers and third-party companies operate gateways

between the calls placed over VoIP and the traditional phone lines that deliver the calls to the

consumer. Commonly spoofed organizations, such as banks, law enforcement, or the IRS,

could place themselves on a list and notify the gateway keepers that calls featuring their

numbers that originate from certain gateways or providers are likely fraudulent and should be

stopped.

126

This technology would stop only the spoofed calls from numbers placed on the “Do

Not Originate” list.

127

Carriers already have the technology to implement such a system.

128

Adam Panagia of AT&T says of this proposal,

129

“In most cases I think that would be very

helpful,”

130

though cautions that it could inadvertently disrupt some legitimate calls.

131

Call Authentication to Address Spoofing

A group within the Internet Engineering Task Force (IETF), an open, standards-making

organization,

132

has been working to develop Internet standards so that callers and carriers can

confirm that they are the owner of a particular phone number.

133

A second, but related group in

the IETF is working on verifying the names that appear on Caller ID.

134

This would address the

problem of call spoofing that is so common with the spread of VoIP.

135

While these standards

would only apply to calls placed with VoIP technology, they would benefit consumers using all

types of phone lines because most fraudulent robocall attacks originate from VoIP.

136

AT&T and

Verizon have said that they are working with the IETF on these proposals.

137

Unfortunately, this process could take years and a great deal of coordination among countries to

implement—according to one recent estimate, five to seven years.

138

Schulzrinne notes that

these standards would require software upgrades.

139

Moreover, the standards are voluntary, not

mandatory so carriers would not be required to adopt them.

140

Nevertheless, this is a promising long-term solution to the illegal spoofing problem. Carriers

should continue to encourage the development of these standards and to implement them when

completed.

PHONE COMPANIES’ CURRENT CALL BLOCKING

OFFERINGS FALL SHORT

Few Services for Traditional Landline Customers, More for VoIP

Unfortunately, top U.S. phone companies do not offer their traditional landline customers —

approximately 50% of home phone users

141

—the type of advanced call-blockers described

above, and only limited options for those who want to block robocalls. For example, AT&T,

Verizon, and CenturyLink allow traditional landline customers to block just a small set of

numbers that they identify themselves, as well as anonymous calls. Not only is inputting

selected numbers a hassle, but it’s not always free.

142

Consumers tell us that only being able to block a few numbers makes these tools ineffective

against spoofers. Steve of Altadena, Calif., says, “I add a number to block a call and I never

hear from that one again. That’s because telemarketers use zillions of numbers, so blocking any

one of them is pointless. It’s like playing whack-a-mole.”

143

PAGE 10 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

Likewise, phone companies typically offer Anonymous Call Block and Call Trace. Costs vary for

these services, but traditional landline customers can pay $6 a month for Anonymous Call

Block.

144

Call Trace is usually charged on a per-use basis, but can cost up to $10.

145

These

tools can be useful in certain circumstances, but they fail to effectively and proactively block

many robocalls.

CenturyLink also offers a service called No Solicitation. It works by playing a recorded message

explaining that the customer does not accept unsolicited telemarketing calls. It invites the caller

to press one, or remain on the line.

146

However, the service does not disconnect the call if the

caller does not press one, so consumers may still receive unwanted robocalls.

147

Consumers who subscribe to VoIP phone service have more powerful call blocking options,

typically for no extra charge. For example, many VoIP subscribers, including AT&T U-verse and

Verizon FiOS customers, can sign up for Nomorobo, since it is enabled to work with any

“simultaneous ring” service.

148

Other options include AT&T U-verse’s “Call Screening” product,

which allows consumers to “whitelist” up to 20 numbers and block the rest.

149

Verizon FiOS

customers can block up to 100 numbers,

150

and the VoIP provider VOIPO has a service called

Telemarketer Block, which directs calls identified as telemarketers to voicemail.

151

VOIPO also

formed a partnership with Nomorobo to offer the service to its customers.

152

Still, options are limited for traditional landline customers, and the transition to fully IP based

networks could take several years.

153

Consumers may buy devices to plug into their landline

and VoIP phones to block unwanted calls. Some devices let consumers build blacklists of

unwanted numbers, while others allow them to block all calls except for a select number of

“whitelisted” numbers. Some work both ways. These devices typically cost between $50 and

$110. Many consumers who tested these devices for Consumer Reports reported that they liked

the protection offered by the call blockers.

154

Some phones, for home use

155

and wireless,

156

allow the consumer to enter or select numbers they would like to block. While these products

may offer much-needed robocall blocking to consumers, they typically put the responsibility on

consumers to enter the numbers to block or allow. Moreover, the stand-alone call blocking

devices are not free.

See the Appendix for more details on the limited call blocking options currently offered by major

phone carriers.

Major Phone Companies Have Resisted Advanced Call Blocking Tools

“Phone companies, please start letting your customers request to have robocalls

blocked.”

157

--FCC Chairman Tom Wheeler

AT&T, Verizon, and Century Link tell Consumers Union that they are doing everything they can

to stop unwanted calls. But the phone industry, despite pressure from lawmakers and

regulators, has resisted offering new, comprehensive options to all consumers to stop robocalls.

On June 18, 2015, the FCC voted to make it clear that phone companies can give their

customers the choice to use call blocking technologies. FCC Commissioner Mignon Clyburn

called the decision a “win” and said that call blocking tools are “exactly the type of offering that

we want to encourage carriers to provide.”

158

State attorneys general welcomed the FCC’s decision, and recently called on the carriers to

offer better tools to their customers. In July 2015, forty-five attorneys general sent a letter to

PAGE 11 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

AT&T, Verizon, CenturyLink, Sprint, and T-Mobile, and urged them to provide the latest call

blocking technology to their customers.

159

Federal lawmakers have also spoken out on the

issue. In August 2015, eight US senators instructed the FCC and the phone companies to work

together to create and offer advanced call blocking tools to consumers.

160

The telecom industry has so far resisted the pressure from lawmakers. The CTIA, which

represents the wireless companies, shrugged off responsibility for the robocall problem. In July

2015 they said: “[T]he attention to stop [robocalls] needs to focus on those bad actors who are

willfully and blatantly ignoring the laws.”

161

USTelecom responded to the FCC vote by reiterating

their commitment to stopping robocalls, but protested that: “[T]here is no single technological

solution to solving this problem[.]”

162

As part of the End Robocalls campaign, Consumers Union sent letters to AT&T, Verizon, and

CenturyLink, asking them to provide customers free robocall blocking tools.

163

The companies

responded that they were doing their best to stop robocalls, and that consumers could take

advantage of the offerings already available to them.

164

Verizon has suggested that “Educating

consumers about robocalls would go a long way toward ensuring that [consumers] are aware of

the various options available to guard against unwanted calls.”

165

Phone companies’ responses to the letter from the attorneys general haven’t been much

stronger. Both AT&T and CenturyLink have said that customers should use their existing call

blocking options,

166

but they offer only limited protection against unwanted calls. For its part,

Verizon raised concerns that advanced robocall blocking technology might block legitimate

calls, like emergency notices.

167

While Verizon’s concerns are understandable, tools like Primus Canada’s Telemarketing Guard

take steps to avoid blocking wanted robocalls. For example, the Telemarketing Guard relies on

customer feedback to “greylist” calls. It’s unlikely that consumers will flag emergency robocalls

as unwanted. And, Primus Canada’s experience is that legitimate callers have rarely been

intercepted.

168

Finally, while no robocall blocking technology will be perfect, consumers should

have the right to decide whether the benefits of any technology will outweigh any potential

downside. Consumers can be informed of any risks associated with the tools in the form of a

disclosure.

Ending Robocalls Will Benefit Phone Companies, Consumers

“Being able to trust the traffic that enters their networks would be a good thing for

[carriers].”

169

– Mustaque Ahamad, Professor, Georgia Institute of Technology College

of Computing, and Co-Founder of Pindrop Security

It’s in the best interest of the phone companies to immediately offer to customers the latest and

best technologies to end robocalls. As Primus Canada’s experience has shown, offering

effective call blocking tools can reduce customer turnover. It could also reduce the amount of

time spent dealing with problems consumers experience with robocalls. “The feedback from

telephone companies is that problems consumers experience with robocalls are the number one

customer complaint,” says Ben Sharpe of Call Control.

170

“This is a high value feature for our customers,” says Brad Fisher of the Telemarketing

Guard.

171

The VoIP provider VOIPO has even announced a partnership with Nomorobo to

reduce calls, showing that call blocking could be used as a selling point.

172

PAGE 12 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

Also, ending spoofing would be beneficial for phone companies, because there’s value in being

able to identify and deliver legitimate calls to their customers, says Professor Ahamad.

173

Jonathan Sasse of PrivacyStar points out that carriers “don’t want their networks to be polluted

from these calls.”

174

Carriers also spend a lot of money in fielding customer complaints about robocalls. Eric Burger,

Professor of Computer Science at Georgetown University, notes that handling customer

complaints is quite expensive—and illegal robocalls are the source of many of these complaints.

He notes that the money phone companies make from completing calls is outweighed by how

much it costs to deal with customer service calls, as it costs “dollars per minute” to address

consumers’ concerns.

175

Carriers should heed some of the lessons learned from the fight against email spam in the early

2000s, experts say. Consumers were overwhelmed with unwanted spam, but spam filters were

able to direct scammers and unsolicited messages to separate folders. Balasubramaniyan of

Pindrop Security says, “[T]hat’s exactly the way the security in the phone channel is also going

to go.”

176

RECOMMENDATIONS

● Phone companies should immediately offer free robocall filtering services to all

customers based on the latest technology.

● Phone companies should immediately develop “Do Not Originate” techniques to reduce

call spoofing.

● Phone companies should continue to pursue call authentication strategies as a long-

term solution to the spoofing problem.

PAGE 13 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

APPENDIX: PHONE COMPANIES’ CURRENT CALL

BLOCKING OPTIONS

This chart outlines the call blocking services available to customers of AT&T, Verizon, and

CenturyLink in July-October 2015, based on areas in California, Washington State, and

Pennsylvania, as well as general estimates. Where possible, information about the cost of the

service was obtained online or through an online chat with a customer service representative.

Customer service representatives provided additional information over the phone. Pricing and

availability is subject to change and may differ depending on the area and calling plan. This is

intended for reference purposes only. Please check with your phone company for the most

current and up-to-date prices.

AT&T

Service

Description

Landline

U-verse (VoIP)

Wireless

Call Block

Block unwanted

numbers

177

Block 10

individual and all

anonymous

numbers, $8.50

per month

178

Block 20

numbers,

179

free

180

Block 30

numbers, $4.99

per month

181

Call Screening

“Whitelist” certain

numbers, block

the rest

182

n/a

183

Block all but 20

selected

numbers,

184

free

185

n/a

186

Privacy Manager

Callers with

suppressed

Caller ID can be

connected after

providing their

name

187

Free

188

n/a

189

n/a

190

Anonymous Call

Rejection

Block numbers

with suppressed

Caller ID

191

$8.50 per month,

included with

Call Block at no

extra charge

192

Free

193

n/a

194

Do Not Disturb

Stops all calls

when enabled

195

n/a

196

Free

197

n/a

198

Call Trace

Dial *57 to report

an obscene call

to the police.

Caller must then

pursue issue with

authorities

199

Estimate of $4

per call

200

Free

for unsuccessful

attempts,

charges vary for

successful ones.

Not for

telemarketing

calls

201

$8.00 per

trace

202

n/a

203

PAGE 14 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

VERIZON

Service

Description

Landline

FiOS (VoIP)

Wireless

Call Block

Block unwanted

numbers

Block 6 or 12

numbers,

204

depending on

area,

205

$6 per

month

206

Block 100

numbers,

207

free

208

Block 5 numbers

for 90 days for

free. Block 20

permanently for

$5 per month.

209

Anonymous calls

blocked as well

under the $5

plan.

210

Anonymous Call

Rejection

Block calls with

suppressed

Caller ID

Approximately

$6 per month

211

Free

212

Can block

anonymous calls

through Call

Block service.

213

Call Trace

Can report calls

to Verizon,

“stored for

future action”

214

$10 per use

215

Free

216

n/a

217

Do Not Disturb

When enabled,

callers get

recorded

message or go

to voicemail

218

$6.10, but n/a to

new

customers

219

Can select 10

callers to be

allowed through.

Free

220

n/a

221

PAGE 15 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

CENTURYLINK

Service

Description

Basic Phone (Local

only)

222

Home Phone Plus

Call Rejection

Block unwanted

numbers

223

Block 12-15

numbers,

224

$6 per

month, with one-time

$7 fee.

225

Block up to

25 through

“Enhanced Call

Rejection,”

226

$6 per

month with one-time

$7 fee

227

Free (customers

can choose 10

services for no

additional cost)

228

Anonymous Call

Rejection

Block numbers w/out

Caller ID info

229

$6 per month

230

Free

Call Trace

Can report disturbing

calls. After three traces,

can request further

action from

CenturyLink

231

Up to $10 (if

successful)

232

Free

233

Do Not Disturb

Stop incoming calls

234

$3.95/month, one-

time fee of $7

235

Free

Caller ID with

Privacy+, Security

Screen

Privacy+ screens calls

with suppressed Caller

ID. They can be put

through after the caller

provides a name.

With

Security Screen, callers

can be connected after

providing their

number.

236

Up to 25

numbers

237

Privacy+: one-time

fee of $7

238

Security Screen:

$2.95 per month

239

Free

No Solicitation

Callers hear a

recording that asks

telemarketers to hang

up. Others are

instructed to press 1 to

continue, or stay on the

line.

240

$6.95 per month

241

Free

PAGE 16 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

NOTES

Federal Trade Commission, National Do Not Call Registry Data Book FY 2014 (Washington, DC: November

2014), 5, https://www.ftc.gov/system/files/documents/reports/national-do-not-call-registry-data-book-fiscal-year-

2014/dncdatabookfy2014.pdf.

Federal Trade Commission, Staff Report of the Bureau of Economics, Consumer Fraud in the United States, 2011:

The Third FTC Survey, by Keith B. Anderson (Washington, DC: April 2013),

https://www.ftc.gov/sites/default/files/documents/reports/consumer-fraud-united-states-2011-third-ftc-

survey/130419fraudsurvey_0.pdf. There were an estimated 3.5 million telemarketing fraud cases in 2011 (p. 38).

The median loss per case was $100 (p. 39). Therefore, an estimated $350 million was lost to telemarketing fraud in

2011.

Andrea Rock, “FCC on How to Eliminate Annoying Robocalls: FCC Rules Are Designed to Protect Consumers,

But the Onslaught Continues,” Consumer Reports, January 14,

2014, http://www.consumerreports.org/cro/news/2014/01/how-to-eliminate-annoying-robocalls/index.htm.

Ringing off the Hook: Examining the Proliferation of Unwanted Calls, Before the United States Senate Special

Comm. on Aging, 114

Cong. (2015) (testimony of the Federal Trade Commission),

12, http://www.aging.senate.gov/imo/media/doc/FTC_Greisman_6_10_15.pdf.

Ibid., 11.

See, for example, Federal Trade Commission, “Robocalls: All the Rage, An FTC Summit,” October 18, 2012,

https://www.ftc.gov/sites/default/files/documents/public_events/robocalls-all-rage-ftc-

summit/robocallsummittranscript.pdf; Ringing off the Hook: Examining the Proliferation of Unwanted Calls, Before

the United States Senate Special Comm. on Aging, 114

Cong.

(2015), http://www.aging.senate.gov/hearings/ringing-off-the-hook_examining-the-proliferation-of-unwanted-calls;

Federal Communications Commission, “Workshop to Focus on Robocall Blocking and Caller ID Spoofing,”

September 16, 2015, https://www.fcc.gov/events/workshop-focus-robocall-blocking-and-caller-id-spoofing.

Federal Trade Commission, “Robocalls: All the Rage,” 219.

Tim Marvin, “No More Complaining. Let’s End Robocalls!” Campaign Updates (blog), February 17, 2015,

http://consumersunion.org/campaign-updates/no-more-complaining-lets-end-robocalls/.

Consumers Union, “End Robocalls,” accessed September 18, 2015, EndRobocalls.org.

“Robocall Blocker Review: Is There Any Way to Eliminate Those Maddening Calls?” Consumer Reports, last

modified August 14, 2015, http://www.consumerreports.org/cro/magazine/2015/07/robocall-blocker-

review/index.htm on call blocking devices; “Cordless Phones with Call Block,” SmithGear, accessed September 1,

2015, http://www.smithgear.com/block-phone-calls.html for examples of phones that can block calls.

CTIA: The Wireless Association, “Blocking Robocalls,” Your Wireless Life (blog), accessed September 4, 2015,

http://www.ctia.org/your-wireless-life/consumer-tips/blocking-robocalls. See also “Supported Carriers,” Nomorobo,

accessed September 21, 2015, https://www.nomorobo.com/signup. Many consumers with Voice over Internet

Protocol (VoIP) service can obtain Nomorobo.

Ringing off the Hook, (comments of Henning Schulzrinne, approximately 59:38).

Federal Communications Commission, Declaratory Ruling and Order, CG Docket No. 02-278, WC Docket No.

07-135 (2015), 73, https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-72A1.doc.

Tom Wheeler, “Another Win for Consumers,” Official FCC Blog, May 27, 2015,

https://www.fcc.gov/blog/another-win-consumers.

Timothy P. McKone (Executive Vice President, Federal Relations, AT&T), letter to Tim Marvin, March 12,

2015, http://consumersunion.org/wp-content/uploads/2015/04/ATT_Response_robocalls_0315.pdf; John F. Jones

(VP Public Policy & Federal Legislative Affairs, CenturyLink), letter to Tim Marvin, March 16, 2015,

http://consumersunion.org/wp-content/uploads/2015/04/CentryLink_response_robocalls_0315.pdf; Donna Epps

(Vice President – Policy & Strategic Alliances, Verizon), letter to Tim Marvin, March 9, 2015,

http://consumersunion.org/wp-content/uploads/2015/04/Verizon_Response_robocalls_0315.pdf.

“Guide: Caller ID and Spoofing,” Federal Communications Commission, last modified December 30, 2014,

https://www.fcc.gov/guides/caller-id-and-spoofing.

Ringing off the Hook: Examining the Proliferation of Unwanted Calls, Before the United States Senate Special

Comm. on Aging, 114

Cong. at 6 (2015) (testimony of Henning Schulzrinne),

http://www.aging.senate.gov/imo/media/doc/Schulzrinne_6_10_15.pdf.

Federal Trade Commission, National Do Not Call Registry Data Book FY 2014, p. 4.

PAGE 17 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

Ibid., 5.

Federal Trade Commission, “FTC DNC and Robocall Enforcement,” provided to fact-checker Christine Young by

Mitchell Katz, September 28, 2015.

Federal Trade Commission, National Do Not Call Registry Data Book FY 2014, p. 4. Complaints about unwanted

calls soared from almost 600,000 in 2004 to 3.2 million in 2014. In 2012, complaints reached a peak of 3.8 million.

Bikram Bandy, “Your Top 5 Questions About Unwanted Calls and the National Do Not Call Registry,” Consumer

Information (blog), Federal Trade Commission, March 9, 2015, https://www.consumer.ftc.gov/blog/your-top-5-

questions-about-unwanted-calls-and-national-do-not-call-registry.

“National Do Not Call Registry,” Federal Trade Commission, accessed September 21, 2015,

https://www.donotcall.gov/.

“Consumer Information: National Do Not Call Registry,” Federal Trade Commission, accessed September 21,

2015, http://www.consumer.ftc.gov/articles/0108-national-do-not-call-registry.

Federal Communications Commission, 47 CFR Parts 64 and 68, Rules and Regulations Implementing the

Telephone Consumer Protection Act of 1991, 68 Fed. Reg. 44,144 (July 25, 2003) (to be codified at 47 C.F.R. Parts

64 and 68) http://www.gpo.gov/fdsys/pkg/FR-2003-07-25/pdf/03-18766.pdf.

Federal Trade Commission, National Do Not Call Registry Data Book FY 2014, p. 4.

Telemarketing Sales Rule, 16 C.F.R. § 310.4 (b)(iii)(B) (2015), http://www.ecfr.gov/cgi-bin/text-

idx?SID=e5b3e8329fb5cd9f55fe0bf675199b5f&mc=true&node=pt16.1.310&rgn=div5.

Consumers Union defines a “robocall” as an unsolicited call made with a computerized autodialer, featuring either

a pre-recorded message or a live agent.

47 C.F.R. § 64.1200(a)(3) (2015), http://www.ecfr.gov/cgi-bin/text-idx?rgn=div6&node=47:3.0.1.1.11.12 (federal

regulations place restrictions on pre-recorded calls to home and cellular phones. It is illegal for a telemarketer to

place a pre-recorded call to a home phone without permission).

C.F.R. § 64.1200(a)(1)(iii) (it is illegal for a telemarketer to autodial a wireless line without permission).

Telemarketing Sales Rule, 16 C.F.R. § 310.2(o) on the definition of the “established business relationship,” and

Telemarketing Sales Rule, 16 C.F.R. § 310.4 (b)(iii)(B)(ii) on the exemption for an “established business

relationship.”

47 C.F.R. § 64.1200 (a)(1)(iii) (these types of autodialed calls are not permitted to cellular phones).

“The Do Not Call Registry,” Federal Trade Commission, accessed August 29, 2015, https://www.ftc.gov/news-

events/media-resources/do-not-call-registry.

Federal Communications Commission, Declaratory Ruling and Order, CG Docket No. 02-278, WC Docket No.

07-135 (2015), 66, https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-72A1.doc.

Ibid., 63-4.

Ibid., 65.

Ibid., 71.

“FTC Challenges Innovators to Do Battle with Robocallers: Agency Offers $50,000 for Best Technical Solution

as Part of Ongoing Fight against Illegal Calls,” Federal Trade Commission, October 18, 2012,

https://www.ftc.gov/news-events/press-releases/2012/10/ftc-challenges-innovators-do-battle-robocallers.

Henning Schulzrinne (Levi Professor of Computer Science and Electrical Engineering, Columbia University), in

discussion with the author, June 4, 2015.

Federal Trade Commission, “Robocalls: All the Rage,” 234.

Schulzrinne, discussion.

Bikram Bandy, interview by Catherine Fredman, May 19, 2015.

Ringing off the Hook, testimony of Henning Schulzrinne, 2.

“Guide: Caller ID and Spoofing,” Federal Communications Commission.

Henning Schulzrinne, “Telephone Numbers in an IP Environment,” (presentation, IETF 92, Dallas, TX, March

26, 2015), approximately 23:05,

http://recordings.conf.meetecho.com/Playout/watch.jsp?recording=IETF92_MODERN&chapter=chapter_0.

Federal Trade Commission, “Robocalls: All the Rage,” 145.

Ibid., 133.

Eric Burger (Research Professor of Computer Science and Director, Georgetown Center for Secure

Communications, Georgetown University), in discussion with Consumers Union’s End Robocalls team, April 15,

2015.

Bandy, interview.

PAGE 18 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

Ibid.

Ringing off the Hook, testimony of Lois Greisman, p. 3, footnote 11.

Schulzrinne, discussion.

IRS: TIGTA Update Part II: Before the United States House of Representatives Committee on Government

Oversight and Reform, 114

Cong. at 6 (2015) (testimony of J. Russell George and Timothy P. Camus, TIGTA),

http://www.treasury.gov/tigta/congress/congress_06252015.pdf.

Consumer story submitted to Consumers Union at https://stori.es/share/stop-the-robocalls-campaign-story-form.

“FTC Sends Refund Checks Totaling More Than $700,000 to Consumers Who Lost Money in Robocall Scheme:

More Than 16,500 Checks Are Being Mailed This Week,” Federal Trade Commission, January 16, 2015,

https://www.ftc.gov/news-events/press-releases/2015/01/ftc-sends-refund-checks-totaling-more-700000-consumers-

who-lost.

Colleen Tressler, “To Robocall Scammers Who Lied about Free Medical Alert Devices: We’ve Got Your

Number,” Consumer Information (blog), Federal Trade Commission, January 13, 2014,

https://www.consumer.ftc.gov/blog/robocall-scammers-who-lied-about-free-medical-alert-devices-weve-got-your-

number.

“Tax Scams/Consumer Alerts,” Internal Revenue Service, last modified August 21, 2015,

http://www.irs.gov/uac/Tax-Scams-Consumer-Alerts.

“CFPB Sues Participants in Robo-Call Phantom Debt Collection Operation: Bureau Also Obtains a Temporary

Restraining Order to Halt Illegal Operation and Freeze Assets of Operation’s Leaders,” Consumer Financial

Protection Bureau, April 8, 2015, http://www.consumerfinance.gov/newsroom/cfpb-sues-participants-in-robo-call-

phantom-debt-collection-operation/.

“Tech Support Scams,” Federal Trade Commission, January 2014, http://www.consumer.ftc.gov/articles/0346-

tech-support-scams; Edward Wyatt, “Multinational Crackdown on Computer Con Artists,” New York Times,

October 3, 2012, http://www.nytimes.com/2012/10/04/business/multinational-crackdown-on-computer-con-

artists.html?_r=0.

“Tax Scams/Consumer Alerts,” Internal Revenue Service.

Bikram Bandy, “Getting Calls from Your Own Number?” Consumer Information (blog), Federal Trade

Commission, July 7, 2015, https://www.consumer.ftc.gov/blog/getting-calls-your-own-number.

Payas Gupta, Bharat Srinivasan, Vijay Balasubramaniyan, Mustaque Ahamad, “Phoneypot: Data-driven

Understanding of Telephony Threats,” Internet Society, 2015, p. 1,

http://www.internetsociety.org/sites/default/files/03_2_3.pdf.

Schulzrinne, discussion; Ringing off the Hook, testimony of Henning Schulzrinne, 1.

Ringing off the Hook, testimony of Henning Schulzrinne, 3.

Ibid., 6.

Federal Trade Commission, “Robocalls: All the Rage, An FTC Summit,” 219.

Ringing off the Hook, testimony of Henning Schulzrinne, 6.

Ibid., 5.

Aaron Foss (Inventor, Nomorobo), in discussion with Consumer Reports staff, March 31, 2015, Yonkers, NY.

“Supported Carriers,” Nomorobo, accessed September 21, 2015, https://www.nomorobo.com/signup.

Foss, discussion.

Aaron Foss, interview with the author, June 11, 2015.

“M3AAWG Telephony Honeypots: Benefits and Deployment Options,” Messaging, Malware and Mobile Anti-

Abuse Working Group, August 2014, 2,

https://www.m3aawg.org/sites/default/files/document/M3AAWG_Telephony_Honeypots_BP-2014-08.pdf.

Schulzrinne, discussion.

Payas Gupta (Research Scientist at New York University Abu Dhabi), in discussion with the author, June 3, 2015.

Aaron Foss, interview, June 11, 2015.

Aaron Foss, interview by Catherine Fredman, May 22, 2015.

Aaron Foss, “Ask me Anything,” Reddit, January 21, 2015,

https://www.reddit.com/r/IAmA/comments/2sax3w/iama_guy_that_fights_phone_scammers_telemarketers/.

Foss, discussion.

Ibid.

Consumer story submitted to Consumers Union at https://stori.es/share/tell-us-about-your-robocall-call-blocker.

PAGE 19 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

“Robocall-Blocker Review: Is There Any Way to Eliminate Those Maddening Calls?” Consumer Reports, last

modified August 14, 2015, http://www.consumerreports.org/cro/magazine/2015/07/robocall-blocker-

review/index.htm.

Federal Trade Commission, “Robocalls: All the Rage, An FTC Summit,” 219.

Brad Fisher (Senior Vice President of Marketing and Product at Primus Telecommunications Canada, Inc.), in

discussion with the author, June 24, 2015.

Fisher, discussion

Fisher, discussion.

Herb Weisbaum, “Why Aren’t Phone Companies Doing More to Stop Robocalls?” CNBC, July 17,

2013, http://www.cnbc.com/id/100887510.

Fisher, discussion.

Stopping Fraudulent Robocall Scams: Can More Be Done?, Before the United States Senate Subcomm. on

Consumer Protection, Product Safety, and Insurance,113

Cong. (2013) (statement of Matt Stein),

http://www.gpo.gov/fdsys/pkg/CHRG-113shrg85765/html/CHRG-113shrg85765.htm.

USTelecom, Detailed Response to Sen. McCaskill, p. 5,

http://www.mccaskill.senate.gov/imo/media/doc/RobocallDetailedResponsetoSen%20McCaskill.pdf. Linked to

“McCaskill Drafting Bill to Crack Down on Fraudulent Robocalls,” Senator Claire McCaskill, December 4, 2013,

http://www.mccaskill.senate.gov/media-center/news-releases/mccaskill-drafting-bill-to-crack-down-on-fraudulent-

robocalls.

Federal Communications Commission, Declaratory Ruling and Order, CG Docket No. 02-278, WC Docket No.

07-135 (2015), 73, https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-72A1.doc.

Ringing off the Hook, (comments of Henning Schulzrinne, approximately 1:09:50).

Ibid., approximately 58:48.

Schulzrinne, discussion.

Ringing off the Hook, testimony of Henning Schulzrinne, 6.

Federal Communications Commission, “Workshop to Focus on Robocall Blocking and Caller ID Spoofing,”

September 16, 2015, Washington, DC (comments of Jerusha Burnett, FCC, approximately 217:12),

https://www.fcc.gov/events/workshop-focus-robocall blocking-and-caller-id-spoofing.

FCC, “Workshop,” (comments of Adam Panagia, approximately 257:15).

CTIA, “Blocking Robocalls,” accessed September 4, 2015.

100

Sharpe, discussion.

101

“PrivacyStar: Block Calls and Caller ID,” Google Play Store, accessed June 21, 2015,

https://play.google.com/store/apps/details?id=com.privacystar.android&hl=en.

102

Sasse, discussion.

103

Ringing off the Hook, testimony of Henning Schulzrinne, 4.

104

Schulzrinne, discussion.

105

Ringing off the Hook (comments of Henning Schulzrinne, approximately 59:38).

106

Ringing off the Hook, testimony of Henning Schulzrinne, 6.

107

Sharpe, discussion; Sasse, discussion.

108

Heather McCulligh, Broadreach Communications, representing Primus Canada, email message to the author,

September 15, 2015.

109

Fisher, discussion.

110

Henning Schulzrinne, e-mail message to author, July 17, 2015.

111

Ringing off the Hook (comments of Henning Schulzrinne, approximately 1:10:35).

112

Ringing off the Hook, (comments of Henning Schulzrinne, approximately 1:10:45).

113

Ibid., approximately 1:10:57.

114

Sasse, e-mail message to author, October 5, 2015. These services are available on the Google Play store. See

“Metro Block-it,” Google Play, accessed October 6, 2015,

https://play.google.com/store/apps/details?id=com.privacystar.android.metro&hl=en; “CallWatch-

Boost/Virgin/Sprint,” Google Play, accessed October 6, 2015,

https://play.google.com/store/apps/details?id=com.privacystar.android.spg&hl=en; and “Call Detector,” Google

Play, accessed October 7, 2015,

https://play.google.com/store/apps/details?id=com.privacystar.android.tracfone&hl=en, for products designed for

MetroPCS, Boost, Virgin Mobile, Sprint Prepaid, and TracFone customers.

PAGE 20 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

115

Sasse, e-mail message to author, October 5, 2015. Sasse says that PrivacyStar also works with the top carriers on

billing integration, so that consumers can pay for the apps through their phone companies.

116

Evan Oei, email to fact checker Christine Young, September 23, 2015.

117

Sharpe, discussion.

118

Sasse, discussion.

119

Ibid.

120

Sharpe, discussion.

121

Foss, interview, June 11, 2015.

122

See Jyrki T.J. Penttinen, The Telecommunications Handbook: Engineering Guidelines for Fixed, Mobile and

Satellite Systems (John Wiley & Sons, 2015), 219 for a discussion of “softswitches.”

123

Aaron Foss, interview with the author, September 1, 2015.

124

Ringing off the Hook, testimony of Henning Schulzrinne, 4.

125

USTelecom, Detailed Response, 10.

126

Ringing off the Hook, testimony of Henning Schulzrinne, 6.

127

Ibid., 7.

128

Ibid.

129

FCC, “Workshop,” (comments of Henning Schulzrinne, approximately 238:20).

130

FCC, “Workshop,” (comments of Adam Panagia, approximately 239:40).

131

Ibid., approximately 240:30.

132

“About the IETF,” IETF, accessed August 30, 2015, http://ietf.org/about/.

133

“Charter for Working Group,” Security Telephony Identity Revisited (stir), IETF, accessed August 30, 2015,

https://datatracker.ietf.org/wg/stir/charter/ ; Ringing off the Hook, testimony of Henning Schulzrinne, 5.

134

Hadriel Kaplan, email to stir at ietf.org, “[stir] Calling Name Identity Trust (CNIT) mailing list,” August 27,

2013, http://www.ietf.org/mail-archive/web/stir/current/msg01500.html.

135

The IETF group is not the only organization working to address call spoofing. Martin C. Dolly of the Alliance for

Telecommunications Industry Solutions (ATIS) says that his organization is working on a proposal. FCC,

“Workshop,” approximately 79:30.

136

Ringing off the Hook, testimony of Henning Schulzrinne, 5.

137

McKone, letter to Tim Marvin; Epps, letter to Tim Marvin.

138

J. Scott Marcus, Richard Shockey, Review of Resource Public Key Infrastructure (RPKI) to Verify Ownership

and Authenticity of Telephone Caller ID over Voice over Internet Protocol, June 10, 2015, p. 31,

http://stakeholders.ofcom.org.uk/binaries/research/technology-research/2015/Ofcom_VoIP_RPKI_Report.pdf.

139

Ringing off the Hook, testimony of Henning Schulzrinne, 5.

140

Paul Hoffman, “What Is the IETF?” in The Tao of IETF: A Novice’s Guide to the Internet Engineering Task

Force, 2012, http://ietf.org/tao.html.

141

Federal Communications Commission, Report and Order, Order and Reconsideration, and Further Notice of

Proposed Rulemaking, GN Docket No. 13-5, RM-11358, WC Docket No. 05-25, RM-10593 at 170 (2015)

(statement of Commissioner Mignon Clyburn)

http://transition.fcc.gov/Daily_Releases/Daily_Business/2015/db0807/FCC-15-97A1.pdf.

142

See Appendix for a description of AT&T, Verizon, and CenturyLink’s call blocking offerings.

143

Consumer story submitted to Consumers Union at https://stori.es/share/tell-us-about-your-robocall-call-blocker.

144

For example, Verizon traditional landline service. Verizon representative, online chat with the author, August 6,

2015.

145

For example, Verizon traditional landline service. Verizon representative, online chat with the author, August 6,

2015.

146

“Use No Solicitation to Stop Sales Calls,” CenturyLink, accessed August 30, 2015,

http://www.centurylink.com/help/?assetid=287.

147

CenturyLink representative, online chat with the author, September 22, 2015.

148

Foss, discussion.

149

“Call Blocking and Call Screening for U-verse Voice,” AT&T, accessed August 30, 2015,

http://www.att.com/esupport/article.jsp?sid=KB401019&cv=814&br=BR&ct=9000976&pv=2.

150

“Incoming Call Block – FiOS Digital Voice,” Verizon, accessed August 30, 2015,

https://www.verizon.com/support/residential/phone/homephone/general+support/fios+voice+service/ad/129036.htm.

151

“Telemarketer Block,” Voipo, last modified January 30, 2014, http://www.voipo.com/help/article/telemarketer-

block-70.html.

PAGE 21 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

152

“Nomorobo Partners with VOIPO to Protect Subscribers From Annoying and Illegal Robocalls: Nomorobo’s

Simple-to-Activate Service Is Now a Key Featured Offered to VOIPO’s Existing Customer Base,” Yahoo! Finance,

July 8, 2014, http://finance.yahoo.com/news/nomorobo-partners-voipo-protect-subscribers-153929450.html.

153

“CenturyLink Announces Virtualization Plans as it Continues Integrating its Network into the Cloud,”

CenturyLink, October 19, 2015, http://news.centurylink.com/news/centurylink-announces-virtualization-plans-as-it-

continues-integrating-its-network-into-the-cloud.

154

“Robocall Blocker Review: Is There Any Way to Eliminate Those Maddening Calls?” Consumer Reports, last

modified August 14, 2015, http://www.consumerreports.org/cro/magazine/2015/07/robocall-blocker-

review/index.htm.

155

“Cordless Phones with Call Block,” SmithGear.

156

“Block Calls and Block or Filter Messages on Your iPhone, iPad, or iPod Touch,” Apple.com, accessed

September 1, 2015, https://support.apple.com/en-us/HT201229.

157

“June 2015 Open Commission Meeting,” Federal Communications Commission, June 18, 2015, approximately

2:17:00, https://www.fcc.gov/events/open-commission-meeting-june-2015, also available at

https://www.youtube.com/watch?v=Jj9TrhUkWQc&index=3&list=PL1AEE1B8B41B867D3.

158

Federal Communications Commission, Declaratory Ruling and Order, CG Docket No. 02-278, WC Docket No.

07-135, 108, (2015) (statement of Commissioner Mignon Clyburn)

https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-72A1.doc.

159

National Association of Attorneys General, letter to Randall Stephenson (AT&T), Lowell C. McAdam (Verizon),

Glen F. Post, III (CenturyLink), Marcelo Claure (Sprint), John Legere (T-Mobile), July 22, 2015,

http://www.oag.state.md.us/Press/NAAG_Call_Blocking.pdf.

160

Sens. Edward J. Markey, Ron Wyden, Tammy Baldwin, Jeff Merkley, Richard Blumenthal, Elizabeth Warren, Al

Franken, and Amy Klobuchar, letter to Tom Wheeler, August 5, 2015,

http://www.markey.senate.gov/imo/media/doc/2015-08-15-TCPA-FCC.pdf

161

Brad Gillen, “CTIA Statement in Response to Senator Blumenthal and Commissioner Rosenworcel Press

Conference on Robocalls,” CTIA Blog, July 13, 2015, http://blog.ctia.org/2015/07/13/ctiastatement-in-response-to-

senator-blumenthal-and-commissioner-rosenworcel-press-conference-on-robocalls/.

162

Jonathan Banks, “USTelecom Statement on FCC Robocall Order,” USTelecom, June 18,

2015, http://www.ustelecom.org/news/press-release/ustelecom-statement-fcc-robocall-order.

163

See, for example, Tim Marvin, letter to Lowell McAdam (Chairman and CEO of Verizon Communications, Inc.),

February 17, 2015, http://consumersunion.org/research/letter-to-verizon-to-provide-consumers-free-solutions-to-

block-robocalls/.

164

Epps, letter to Tim Marvin; McKone, letter to Tim Marvin; Jones, letter to Tim Marvin.

165

Epps, letter to Tim Marvin.

166

Dave Lieber, “Let's Force Phone Companies to Stop Unwanted Calls,” Dallas Morning News, last updated

August 31, 2015, http://www.dallasnews.com/investigations/watchdog/20150829-lets-force-phone-companies-to-

stop-unwanted-calls.ece; Karin Price Mueller, “Bamboozled: What Are Phone Companies Doing About Unwanted

and Annoying Robocalls?” NJ.com, July 30, 2015,

http://www.nj.com/business/index.ssf/2015/07/bamboozled_what_are_phone_companies_doing_about_un.html.

167

Lieber, “Let’s Force Phone Companies to Stop Unwanted Calls,” Dallas Morning News.

168

Federal Trade Commission, “Robocalls: All the Rage, An FTC Summit,” 228.

169

Mustaque Ahamad (Professor, College of Computing, Georgia Institute of Technology, and co-founder of

Pindrop Security), in discussion with the author, May 28, 2015.

170

Sharpe, discussion.

171

Fisher, discussion.

172

“Nomorobo Partners with VOIPO to Protect Subscribers From Annoying and Illegal Robocalls,”Yahoo! Finance.

173

Ahamad, discussion.

174

Sasse, discussion.

175

Burger, discussion.

176

Federal Trade Commission, “Robocalls: All the Rage,” 155.

177

“How to Use Call Block (*60) or Call Screening Features,” AT&T, accessed August 30, 2015,

http://www.att.com/esupport/article.jsp?sid=KB408880&cv=807&ct=9001834&pv=2

178

AT&T representative, phone call with Karim Salamah, August 17, 2015. Includes Anonymous Call Blocking.

Based on service to San Francisco, CA.

179

“Call Blocking and Call Screening for U-verse Voice,” AT&T.

PAGE 22 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

180

“List of U-verse Calling Features and Star Codes,” AT&T, accessed August 30, 2015,

http://www.att.com/esupport/article.jsp?sid=KB401850&cv=814.

181

“Smart Limits,” AT&T, accessed August 30, 2015, http://www.att.com/shop/wireless/smartlimits.html; “Smart

Limits Terms and Conditions,” AT&T, accessed August 30, 2015,

http://www.att.com/legal/terms.smartLimitsTerms.html.

182

“Call Blocking and Call Screening for U-verse Voice,” AT&T.

183

“How to Stop Unwanted Calls,” AT&T, accessed August 30, 2015,

http://www.att.com/esupport/article.jsp?sid=KB403232&cv=807. Options offered for AT&T local service are “Call

Block, Call Trace, Call Return, and Anonymous Call Rejection.”

184

“Call Blocking and Call Screening for U-verse Voice,” AT&T.

185

“List of U-verse Calling Features and Star Codes,” AT&T.

186

“Blocking Calls and Messages to Your Wireless Phone,” AT&T, accessed September 25, 2015,

http://www.att.com/esupport/article.jsp?sid=KB102428&cv=820. Smart Limits plan is the only service option

provided.

187

“Privacy Manager User Guide,” AT&T, accessed August 30, 2015, http://www.att.com/gen/general?pid=10211.

188

AT&T representative, phone call with the author, August 4, 2015. Based on service in Oakland, CA.

189

AT&T representative, online chat with the author, August 4, 2015.

190

“Blocking Calls and Messages to Your Wireless Phone,” AT&T. Smart Limits plan is the only service option

provided.

191

“List of U-verse Calling Features and Star Codes,” AT&T.

192

AT&T representative, phone call with Karim Salamah, August 17, 2015. Includes Anonymous Call Blocking.

Based on service to San Francisco, CA.

193

“List of U-verse Calling Features and Star Codes,” AT&T.

194

“Blocking Calls and Messages to Your Wireless Phone,” AT&T. Smart Limits plan is the only service option

provided.

195

“Do Not Disturb Feature for U-verse Voice,” AT&T, accessed September 4, 2015.

http://www.att.com/esupport/article.jsp?sid=KB401818&cv=814.

196

“How to Stop Unwanted Calls,” AT&T. Options offered for AT&T local service are “Call Block, Call

Trace, Call Return, and Anonymous Call Rejection.”

197

“Do Not Disturb Feature for U-verse Voice,” AT&T; “List of U-verse Calling Features and Star Codes,” AT&T.

198

“Blocking Calls and Messages to Your Wireless Phone,” AT&T. Smart Limits plan is the only service option

provided.

199

“Call Trace (*57) User Guide,” AT&T, accessed August 30, 2015,

http://www.att.com/esupport/article.jsp?sid=KB403269.

200

AT&T representative, phone call with the author, September 23, 2015. Asked for general estimate.

201

“Call Trace (*57) User Guide,” AT&T.

202

“Voice User Guide,” AT&T, accessed August 30, 2015,

http://www.att.com/media/att/2012/support/pdf/voice_user_guide.pdf; AT&T representative, online chat with the

author, September 28, 2015.

203

“Blocking Calls and Messages to Your Wireless Phone,” AT&T. Smart Limits plan is the only service option

provided.

204

“FiOS Digital Voice Features,” Verizon, accessed October 6, 2015,

http://www.verizon.com/home/phone/fiosdigitalvoice/%20-%20features

205

“Call Block,” Verizon, accessed August 30, 2015,

https://www.verizon.com/support/residential/phone/homephone/calling+features/call+block/call+block.htm.

Available to new customers, also depending on area.

206

Verizon representative, online chat with the author, August 6, 2015. This is an approximate estimate. Southern

California residents pay $11.95 per month, according to a Verizon representative, phone call with Karim Salamah,

August 18, 2015.

207

“Incoming Call Block – FiOS Digital Voice,” Verizon.

208

“FiOS Digital Voice Features,” Verizon, accessed October 6, 2015,

http://www.verizon.com/home/phone/fiosdigitalvoice/%20-%20features.

209

“Block Calls and Messages,” Verizon, accessed August 30, 2015,

https://wbillpay.verizonwireless.com/vzw/nos/safeguards/SafeguardProductDetails.action?productName=callMessa

PAGE 23 – DIALING BACK – NOVEMBER 2015 – WWW.ENDROBOCALLS.ORG

geBlocking ; “Usage Controls - Manage Blocked Contacts,” Verizon, August 30, 2015,

http://www.verizonwireless.com/support/block-numbers/.

210

Verizon representative, phone call with the author, August 31, 2015.

211

Verizon representative, online chat with the author, August 6, 2015.

212

“FiOS Digital Voice Features,” Verizon, accessed August 30, 2015,

http://www.verizon.com/home/phone/fiosdigitalvoice/%20-%20features; Verizon representative, phone call with

Karim Salamah, August 18, 2015.

213

Verizon representative, phone call with the author, August 31, 2015.

214

“Call Trace,” Verizon, accessed August 30, 2015,

https://www.verizon.com/support/residential/phone/homephone/calling+features/call+trace/call+trace.htm.

215

Verizon representative, online chat with the author, August 6, 2015.

216

Verizon representative, phone call with Karim Salamah, August 18, 2015.

217

Verizon representative, phone call with the author, July 17, 2015.

218

“Do Not Disturb,” Verizon, accessed August 30, 2015,

https://www.verizon.com/support/residential/phone/homephone/calling+features/do+not+disturb/do+not+disturb.ht

219

Verizon representative, phone call with the author, August 6, 2015. This service is being grandfathered. This

price is based on Pennsylvania.

220

“FiOS Digital Voice Features,” Verizon.

221

“Block Calls and Messages,” Verizon; “Usage Controls - Manage Blocked Contacts,” Verizon. Do Not Disturb is

not included in the offerings.

222

“Home Phone Plans,” CenturyLink, accessed October 6, 2015, http://www.centurylink.com/home/phone/

223

“Ways to block unwanted calls from your home phone,” CenturyLink, accessed August 30, 2015,

http://www.centurylink.com/help/help/index.php?assetid=183.

224

“Use Call Rejection to Block Calls You Don't Want,” CenturyLink, accessed October 6, 2015,

http://www.centurylink.com/help/?assetid=289.

225

CenturyLink representative, online chat with the author, October 7, 2015. Based on Seattle.

226

“Ways to block unwanted calls from your home phone,” CenturyLink.

227

CenturyLink representative, online chat with the author, September 23, 2015. Estimate.

228

CenturyLink representative, online chat with the author, July 22, 2015. Based on Seattle.

229

“Ways to block unwanted calls from your home phone,” CenturyLink.

230

CenturyLink representative, phone call with the author, August 7, 2015. Based on Seattle.

231

CenturyLink representative, phone call with the author, August 31, 2015. Based on Seattle.

232

Ibid.

233

Ibid.

234

“How to Use Calling Features to Block Unwanted Calls,” CenturyLink, accessed August 30, 2015,

http://www.centurylink.com/help/?assetid=233.

235

CenturyLink representative, online chat with the author, July 22, 2015. Based on Seattle.

236

“How to Use Calling Features to Block Unwanted Calls,” CenturyLink.

237

CenturyLink representative, phone call with Karim Salamah, August 27, 2015. Based on Seattle.

238

CenturyLink representative phone call with the author, August 27, 2015, based on Seattle.

239

CenturyLink representative, phone call with Karim Salamah, August 27, 2015. Based on Seattle.

240

“Use No Solicitation to Stop Sales Calls,” CenturyLink.

241

CenturyLink representative, online chat with the author, July 22, 2015. Based on Seattle.

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