Anti-Robocall Principles

Over the years, AT&T has developed a series of complementary call blocking options to ensure that customers across its voice platforms—post-paid mobile wireless, interconnected VoIP, and legacy telephone services—have a well-equipped “toolbox” to fight the scourge of illegal and unwanted calls.
https://ecfsapi.fcc.gov/file/1013013483922/1.29.2020 Comments for Call Blocking Report.pdf

See AT&T's February 2020 update to the FCC.

AT&T’s global fraud team utilizes a network-based analytics system to block traffic that it believes to be illegal based on calling patterns and other data.
https://ecfsapi.fcc.gov/file/1013013483922/1.29.2020%20Comments%20for%20Call%20Blocking%20Report.pdf

Each and every telephone number that AT&T blocks through its network blocking programs is the subject of a careful, labor-intensive investigation as a matter of quality control in order to eliminate false positives.
https://ecfsapi.fcc.gov/file/1013013483922/1.29.2020%20Comments%20for%20Call%20Blocking%20Report.pdf

AT&T appropriately vets its commercial customers. AT&T also takes steps to weed out potential customers who would engage in illegal activity on its network and, in the event AT&T were to identify a customer engaged in suspect activity, AT&T takes steps to investigate and eliminate any illegal or prohibited behavior, including, but not limited to, termination of service.
https://ecfsapi.fcc.gov/file/10924398519486/9.24.2018%20Robocall%20Record%20Refresh%20Comments.pdf

AT&T has started adding a requirement to cooperate in traceback to its contracts.

AT&T actively seeks to root out suspected illegal robocalls at their source as a founding member of USTelecom's Industry Traceback Group, through which we regularly identify and investigate suspected high-volume robocall operations to refer to federal and state law enforcement.

https://ecfsapi.fcc.gov/file/10710280773614/7.10.%202019%20Starks%20Response%20FINAL.pdf

AT&T communicates regularly with the State Attorneys General through the USTelecom Traceback group process.

https://www.ustelecom.org/wp-content/uploads/2020/01/ITG-2019-Progress-Report.pdf

Bandwidth predominately acts as an underlying wholesale communications services provider and as such it is not in a position to offer call labeling and call blocking services to consumers directly. Nevertheless, in its role as an underlying carrier Bandwidth does block clearly illegal and improper calls at the network level based on such things like calls that do not include originating calling information or attempt to utilize invalid TNs.

Bandwidth is deploying STIR/SHAKEN in its network and with willing partners who are also positioned to exchange IP-based STIR/SHAKEN traffic with Bandwidth. See e.g.: https://www.prnewswire.com/news-releases/bandwidth-announces-successful-implementation-of-stirshaken-call-authentication-regime-with-verizon-300973241.html

In addition to tools to support appropriate network-level call blocking, Bandwidth's operations fraud team works to review each report submitted (from public or other carriers) related to abusive robocalling using Bandwidth services. After such review, Bandwidth's fraud team notifies the corresponding customer that sent the traffic and work to ensure the traffic is stopped. In addition to reactive measures such as these, Bandwidth also compiles data on a regular basis aggregating traffic statistics such as average call duration, abandons, and short call percentages by customer account. This information is then combined with a variety of data points including any consumer complaints made to/by government entities such as the FTC and IRS associated with phone numbers on the customer's account and then run through analytics designed to identify the customers most in need of review and intervention.

As discussed in Principle #3, the Bandwidth Fraud Team actively monitors MOUs, Call Durations, ANI(CallerID) validation for anomalies and actively blocks calls with found anomalies. Additionally, if these types of calls are coming from an identified source, tickets are opened with the identified source to address the identified issue(s).. When our investigations and data analysis indicated illegal or inappropriate traffic, measures to stop robocalling traffic, like removing accounts, educating end users to stop sending unlawful robocall traffic, are taken. In addition to our own detection and mitigation efforts, we also supply all of our customers with the Bandwidth Fraud Mitigation Best Practices documentation, so all Bandwidth customers can take steps to reduce their attack surface and prevent hacking that may result in unlawful robocalling from their networks. When our investigations confirm an unlawful robocall-like campaign exists , we immediately take steps block this traffic and alert any identified sources.

Bandwidth has a dedicated Risk team that reviews all new and existing customer opportunities and then Bandwidth works to monitor each account for legal compliance once on-boarded. Each prospective customer is asked to complete a form with their legal name and any DBAs, business address (including any prior address in the last three years). The Risk Team then reviews the submission and associated internal notes, validates the information provided and products requested, and asks follow-up questions of the prospect. Reviews are in-depth and regularly include steps such as - viewing the street address on Google Street view to determine whether it is a business address, private home, or post office; requesting and reviewing sample call detail records to determine traffic statistics and flag anomalies; conducting an in-depth review of the prospect website, social media pages such as LinkedIn, consumer websites such as the BBB, and looking for prior litigation or disciplinary actions from the FCC, FTC, or state Attorneys General associated with the business. If we suspect a prospect is providing an invalid or virtual address, our team will send an unannounced letter via FedEx to the address provided requesting the prospect sign and return the form validating their address.

Bandwidth has always had enforceable terms in its contracts that require compliance with applicable laws. It has adopted additional customer contract language that also requires implementation of and participation in established Industry Traceback best practices and procedures

While Bandwidth has never been a member of the US Telecom Association, it was a very early voluntary participant in the group that has become the ITG. It is now an official Steering Committee Member of the ITG and regularly participates in traceback investigations and ITG membership activities and events.

Bandwidth has a well established set of systems, processes and procedures to manage law enforcement inquiries and consumer complaints. It was an original signatory to the State Attorney Generals' Anti-Robocalling Principles as well.

CenturyLink recently completed updates to its network to enable Nomorobo for all consumer VoIP customers, which we make available at no charge. The service is highly effective at blocking robocalls.

CenturyLink's implementation of STIR/SHAKEN call authentication technology began in 2019. It is continuing work to deploy throughout its IP networks.

CenturyLink operates one of the nation's largest networks. It continually monitors and analyzes traffic patterns, identifying and blocking illegal mass calling campaigns to protect its network and customers.

CenturyLink's fraud department investigates suspicious traffic and coordinates with other major providers, as well as specialized data companies, to help identify, label, and block illegal traffic.

CenturyLink policy does not provide commercial service to anonymous customers or fictitious companies.

CenturyLink prohibits use of its wholesale or retail service for illegal calling. It has also adopted a policy of requiring, within its conditions of service, that wholesale customers cooperate in traceback investigations.

CenturyLink is proud to have been a founding member of the Industry Traceback Group and serves on its Executive Committee.

CenturyLink has a long history of cooperation with state law enforcement and is committed to helping authorities pursue scammers and illegal robocall operators.

At no additional cost, Charter provides its Spectrum mobile and Spectrum Voice residential subscribers with easy-to-use call blocking tools and notifies its customers of their availability. These tools provide Spectrum Voice residential subscribers with the ability to accept selected callers, block unwanted callers, and block anonymous calls at the network-level. Today, Spectrum Mobile customers have device-level phone number blacklisting tools that are natively available through most mobile device operating systems. By fourth quarter 2020, Charter plans to offer residential voice subscribers with call labeling tools and the means to block illegal and unwanted robocalls at the network level by default. Charter is also currently engaged in product development to provide Spectrum mobile customers with enhanced call-blocking tools by the end of 2020. Charter uses best efforts to ensure that tools that are offered safeguard customers personal, proprietary and location information.

https://ecfsapi.fcc.gov/file/10128540203531/Charter%20Comments%20for%20CGB%20Report%20(1-28-20).pdf

Charter successfully implemented SHAKEN STIR call authentication at the end of 2019.

Charter plans to implement and utilize new analytic tools in late 2020 that will enable us to analyze high-volume voice network traffic to identify and monitor patterns consistent with robocalls.

Charter is scheduled to implement new analytic tools in late 2020 that will enable us to detect patterns consistent with illegal robocalls over our network and will seek to identify the party that is using its network to originate, route, or terminate these calls and take appropriate action.

Charter is capable of identifying new commercial VoIP customers and continues to work to strengthen internal processes regarding confirmation of the identity of new commercial VoIP customers.

Charter is approaching new agreements proactively, adding traceback language, and will be complying on new and renegotiated contracts.

As a gold member of the Industry Traceback Group, Charter is committed to protecting networks and consumers from fraudulent and abusive robocall traffic. Charter participates in traceback investigations initiated through the Industry Traceback Group or directly from government entities. Charter has dedicated points of contacts for addressing traceback requests and follows the Industry Traceback Group's policies and procedures as to ensure prompt responses.

Charter has dedicated points of contacts for bringing significant recognized scams and trends in illegal robocalling to Attorneys General attention.

Comcast offers the following tools and functionality to its Xfinity Voice subscribers for free: (1) compatibility with Nomorobo; (2) call blocking at its network edge (i.e., invalid codes and unallocated numbers) pursuant to the FCC's 2017 call blocking order; (3) selective call rejection that enables a customer to block up to 25 calling numbers; and (4) anonymous call rejection, which has been activated by more than 40% of Xfinity Voice subscribers. Comcast also blocks numbers from originating on its network based on the Do Not Originate (DNO) list maintained by USTelecom. Comcast has more than 1,000 such DNO numbers currently blocked in its switches.
https://www.xfinity.com/support/articles/voice-unwanted-calls

Calls originating with Comcast's residential Xfinity Voice customers are digitally signed pursuant to the STIR/SHAKEN protocol. Comcast digitally verifies calls to Xfinity Voice customers to extent that the originating service provider has agreed to interconnect with Comcast via an Internet Protocol interconnection (which is required for STIR/SHAKEN implementation) and signs the call pursuant to the STIR/SHAKEN protocol. Calls between Comcast Xfinity Voice customers are both signed and verified.

https://corporate.comcast.com/press/releases/att-comcast-announce-anti-robocalling-fraud-milestone-believed-to-be-nations-first

https://www.usatoday.com/story/tech/talkingtech/2019/04/17/t-mobile-comcast-turn-call-verification-fight-robocall-epidemic/3490265002/

https://docs.fcc.gov/public/attachments/DOC-361231A1.pdf" rel="noopener" target="_blank">https://docs.fcc.gov/public/attachments/DOC-361231A1.pdf">https://docs.fcc.gov/public/attachments/DOC-361231A1.pdf

https://www.businesswire.com/news/home/20191209005701/en/FCC-Chairman-Pai-CRTC-Chairman-Scott-Complete

https://www.cnet.com/news/t-mobile-and-comcast-broaden-anti-robocall-feature

https://corporate.comcast.com/stories/xfinity-mobile-hiya-thwart-mobile-robocalls

https://newsroom.sprint.com/sprint-and-comcast-start-rollout-anti-robocall-technology.htm

Comcast monitors traffic through its fraud processes, as well as know-your-customer efforts that look for calling patterns indicative of abusive robocalling.

Comcast investigates calls and calling patterns identified pursuant to the monitoring described in Principle #3.

Comcast does not contract with Business Voice customers without information about the customer's identity.

Comcast has developed a traceback amendment for use with its wholesale contracts. Some, but not all, wholesale customers have returned a signed amendment to Comcast.

Comcast has participated in the Industry Traceback Group (ITG) since its inception, and is a Platinum Level Executive Committee member of the ITG.

Comcast answers subpoenas and CIDs produced by State AG offices. Comcast has participated in educational robocall-related meetings and calls with individual State AG offices and with groups of AGs. Comcast recently participated in a robocall panel hosted by AG Tong in Connecticut.

We are actively testing solutions with multiple vendor partners that would meet this principle. For best results, we intend to select and implement any solution(s) in coordination with our final vendor selection and implementation of STIR/SHAKEN.

We have successfully tested the implementation of STIR/SHAKEN with several vendors. We are finalizing our plan and vendor selection efforts in 2020. Upon selection of a vendor, we will implement our final solution and move toward interoperability with our carrier partners.

We have tools in place that monitor and potentially mitigate suspected fraudulent voice traffic. Specific to robocalling analytics today this is more done as a result of customer inquiries or capacity issues that may be generated by an influx of robocalls. As we deploy our vendor partner solutions around call blocking and labeling more tools may be introduced.

We investigate any suspicious calls or patterns and work with our carrier partners and the Industry Traceback Group in an attempt to identify the party that is using its network to originate, route, or terminate these calls and take appropriate action.

We routinely collect information including, but not limited to, physical business location, contact person(s) and federal tax ID as part of our account verification process.

We have adopted standard language to be amended into relevant contracts upon renewal and included in all new contracts, as appropriate. We are proactively reaching out to key carrier partners to amend contracts prior to the renewal period.

We are a ready and willing to fully cooperate in these efforts. We have executed our statement of intent to participate in and follow the Industry Traceback Group policies and procedures. We have established internal protocols and appropriate escalations in order to investigate and provide timely feedback to our carrier partners.

We participate in regular calls and meetings with USTelecom, industry and the joint Attorneys General group. We intend to respond to all information requests, such as this one, in a timely fashion.

Frontier provides customers with Neustar's enhanced caller ID, powered by Neustar. This feature, which is free to all customers with caller ID, applies a series of analytics to score the call’s likelihood of being fraudulent. The analytics then determine the caller ID message displayed on the caller ID. If the call is assessed as potentially fraudulent, Frontier’s system displays a potential spam warning on the customer’s caller ID. Frontier also offers customers free call blocking through Nomorobo, as well as anonymous call rejection (blocks calls from blocked caller ID), and selective call rejection (blocks calls from any number a customer designates). More information is available here:https://investor.frontier.com/file/Index?KeyFile=401518416 and here: https://frontier.com/corporate/responsibility/policy-blog/robocall

Frontier has deployed SHAKEN/STIR on its IP network. More information is available here:https://investor.frontier.com/file/Index?KeyFile=401518416

Frontier studies network traffic and usage, which includes reviewing traffic for high-volume activity which might indicate robocalling.

Frontier investigates any suspicious traffic on its network and investigates complaints from customers about robocalls. Frontier also investigates suspicious calls through its participation in the Industry Traceback Group.

Frontier confirms the identity of commercial customers consistent with the Principles.

Frontier now includes a provision requiring traceback cooperation in its commercial contracts.

Frontier is a founding Silver member of the Industry Traceback Group and a member of the Executive Committee. Frontier fully cooperates in all traceback investigations for which its assistance is sought.

Frontier responds promptly to inquiries from State Attorneys General.

Pending completed negotiations with third party vendor. Per the statute, we will be offering at least the basic call blocking service of calling numbers scored as -4 and -5, and possibly -3. These scores are scored by a third party vendor. We will tweak the blocked call types during trial and watch for false negative blocks, which are less than 5% stated by third party vendor.

STIR/SHAKEN is still in it's infancy and the authentication authorities do not have systems in place yet to be able to certify. It is anticipated to be available within 2020. When available we will be adding the capability. This will allow us to block spoofed calls and ensure that numbers that are passed are truly originated on the network the incoming user was attached to.

We are currently negotiating with a third party vendor to monitor and analyze any suspicious traffic.

Pending completed negotiations with third party vendor. We will be adhering to our current standard process of reviewing suspicious patterns via alerts from third party vendor.

We will be confirming based on the STIR/SHAKEN certs and technology. Exact capabilities have yet to be determined.

Pending completed negotiations with third party vendor. Third party vendor offers traceback cooperation when required by law.

We will cooperate with all relevant laws.

Sprint recently introduced a new spam detection and blocking application called Call Screener. Call Screener replaces Sprint’s previous anti-robocall service called Premium Caller ID. Call Screener is installed by default on new Android devices and is available for voluntary download on iOS devices. Sprint and its analytics partner, Transaction Network Services (“TNS”), offer Call Screener Basic free of charge. It allows Sprint customers to identify and block calls determined by TNS to be high risk. Blocked calls are sent to voicemail, so a legitimate caller that is inaccurately categorized as high risk still has the opportunity to leave a voicemail for the customer if the customer has activated voicemail. More information about Call Screener is available at https://www.sprint.com/en/shop/services/screener.html

In 2019 Sprint deployed STIR/SHAKEN functionality in its network equipment and began testing with other carriers. So far in 2020 Sprint has undertaken full-scale cross-network STIR/SHAKEN deployment with two major carriers and expects to have STIR/SHAKEN on all calls with those carriers soon. Sprint is ready to test with several additional major carriers that have indicated readiness and will begin testing with others once they indicate their readiness to test with Sprint.

Sprint monitors its network for suspicious and fraudulent activity and works with U.S. Telecom’s Industry Traceback Group to share information and identify illegal robocallers. Sprint is evaluating additional measures it can take to enhance its capabilities to detect and block robocalls.

Sprint is an active partner with the Federal Communications Commission, Federal Trade Commission, and the Industry Traceback Group to investigate suspicious calls, whether flagged by Sprint customers or flagged by other entities seeking information from Sprint.

Sprint routinely gathers information regarding the identity of commercial customers.

The vast majority of Sprint’s traffic is already exchanged with carriers participating in robocall traceback through U.S. Telecom’s Industry Traceback Group and with other carriers that have agreed to the Anti-Robocall Principles. Sprint encourages its other traffic exchange partners to participate in traceback and will work to include traceback requirements in future agreements with other traffic exchange partners.

Sprint has been an active leader in industry traceback efforts for several years. Sprint is a Gold sponsor of the U.S. Telecom Industry Traceback Group. Sprint actively participates in coordinating tracebacks and performing tracebacks for calls that traverse the Sprint network.

Sprint has worked with state attorneys general on a one-on-one basis and in industry meetings to provide assistance in the state efforts against illegal robocalls. Sprint is committed to continuing to do so.

In March 2017, T-Mobile became the first voice service provider to deploy free scam protection at the network level:https://www.t-mobile.com/news/scam-block

T-Mobile was the first wireless provider to deploy STIR/SHAKEN standards on its network in November 2018 (https://www.t-mobile.com/news/t-mobile-fights-scam-calls) and the first to implement cross-network STIR/SHAKEN authentication (https://www.t-mobile.com/news/inter-carrier-stir-shaken-launch).

T-Mobile’s protections update constantly, every four to six minutes:https://www.t-mobile.com/news/scamblockparty

See response to Principle #3.

T-Mobile does not offer a stand-alone commercial (enterprise) VoIP service. T-Mobile's customer base is predominantly mobile.

T-Mobile requires traceback cooperation in contracts.

T-Mobile is an executive committee member of the Industry Traceback Group.

In addition to signing on to the anti-robocall principles and responding to letters and other requests such as this, T-Mobile sent representatives to meet in person with state attorneys general in Philadelphia in November 2018 and met with Colorado Attorney General Phil Weiser in Washington, DC in March 2019 to discuss robocalls.

Twilio is working with carrier partners to block and label calls.

Twilio has performed SHAKEN/STIR test calls with all carrier partners and is ready to start verifying incoming calls that are delivered from carrier partners with SHAKEN PASSporTs. For outgoing calls, Twilio will work closely with carrier partners as they become ready to accept production traffic with SHAKEN PASSporTs.

Twilio analyzes and monitors traffic with an internal software tool and in partnership with a third-party vendor.

Twilio is both a steering committee member and an executive committee member of USTelecom's ITG; Twilio's fraud department investigates suspicious activity; Twilio strictly enforces our AUP to stop any illegal activity.

Twilio customers must provide a certain amount of information upon account initiation. Twilio then requires additional information as the customer scales. In addition, Twilio is piloting Branded by Twilio which collects from commercial customers identifying information and displays to the end-user who is calling and why.

Twilio updated its Acceptable Use Policy requiring participation in traceback.

Twilio is both a steering committee member and an executive committee member of USTelecom's ITG. Twilio's head of fraud is a direct point of contact to detect and terminate illegal robocalls.

Twilio communicates with State Attorneys General (AGs) through its participation in USTelecom and ITG. Twilio also endeavors to alert law enforcement and state AGs if it discovers illegal activity on our Platform.

We have labeling in place today. We are working on call blocking and targeting to be ready in Q2 this year.

We have implemented within the U.S. Cellular VoLTE network and we are in active technical discussions with national carriers for SIP interconnection to use STIR/SHAKEN on exchanged traffic.

We are using a vendor, TNS and their Call Guardian product to provide analytics to inform customers whether to accept a call.

See response to Principle #3.

This is for enterprise VoIP customers/PBX and does not apply for U.S. Cellular network.

We will require traceback cooperation in all future contracts at the time of contract renewal.

We are members of US Telecom traceback group.

We have cooperated with the Attorney General for the State of Missouri in a robocalling investigation and we will continue to cooperate with such requests as they are received from any other State Attorney General within our operating footprint.

Verizon first deployed its free Spam Alerts robocall labeling service to wireline customers in early 2018. Wireless customers have had free robocall blocking and tagging from Verizon's Call Filter service since March 2019; previously, subscribers to our Caller Name ID service could opt into a robocall blocking feature.

Verizon finished implementing STIR/SHAKEN for its wireless customers in March 2019. We have been using the authentication status of on-net calls (Verizon Wireless to Verizon Wireless) since the summer of 2019 to improve the analytics in our Call Filter blocking/labeling service. We have been working with service providers who are also first-movers to begin exchanging signed calls with them and have begun to exchange signed traffic with four service providers. We are well underway deploying STIR/SHAKEN to the wireline platforms. Verizon also is supporting the industry efforts to establish the industry certificate issuance regime and interfaces needed for the entire ecosystem to implement STIR/SHAKEN.

For more than a year, Verizon has had an extensive "know your customer" program that analyzes traffic from both wholesale and retail customer in order to identify patterns associated with potentially illegal robocalling. Verizon developed a set of “best practices” that define and set measurable objectives for characteristics associated with suspicious robocalling that we have shared with others in the industry.

In addition to the "know your customer" activities, Verizon operates a dynamic honeypot robocall monitoring program, which utilizes thousands of telephone numbers to receive, record, and analyze thousands of illegal scam and unwanted robocalls daily. Verizon's analysts are industry leaders, including work addressing the "Wangiri" (one-ring) scam involving international traffic and on identifying and addressing the problem of ringless voicemails.

This is a standard practice for both wholesale customers and retail commercial customers.

Verizon has a program for requiring its existing wholesale customer base to sign a contract amendment committing them to participate in industry traceback and to implement similar agreements with their upstream customers. This same requirement is also in our agreements with new customers.

Verizon is a founding member of the industry-led private traceback consortium that USTelecom established several years ago. We contribute to that effort not only by responding to tracebacks, but also by referring suspicious robocall campaigns to the traceback group. We are financial contributors to the traceback group at a "Platinum" level.

Verizon has historically forged cooperative and collaborative relationships with various attorneys general for both enforcement and policy development purposes, and we look forward to continued and accelerated collaboration via the upcoming law enforcement teleconferences and other activities that the industry traceback consortium is organizing.

This is available in two pieces of our telephony hardware

We are registered for SHAKEN with the STI-PA, iconective; and currently signing TDM calls using out-of-band signaling through the Transnexus network

We are monitoring and analyzing traffic through the Transnexus network

We are investigating and identifying suspicious calls through the Transnexus network

We are a small rural LEC in Southern Illinois. We personally know our customer

We would traceback through the Transnexus out-of-band network when necessary. Transnexus is also a CA for the STI-GA

There have been no requests, but we would gladly cooperate in traceback investigations

Absolutely, we would communicate with SAG

WIN is in trials with a vendor for a customer-choice blocking product and has implemented network-level call blocking based on reasonable analytics. WIN has also implemented no-charge spam labeling (by engaging a prominent national vendor in mid-2019). Finally, for VoIP residential customers, WIN has made available no-charge, easy-to-use call blocking and labeling tools and provides customers with straightforward information regarding how to implement and use these tools. WIN protects customers’ personal, proprietary, and location information relating to the use of these tools.

WIN has evaluated implementation issues and is nearing finalization of an agreement with a prominent commercial vendor to implement STIR/SHAKEN, with turn-up currently expected this year.

WIN continuously monitors and analyzes high-volume voice network traffic and other key indicators to identify and monitor patterns consistent with robocalling.

WIN’s reasonable-analytics-based call blocking system provides significant assistance in detecting traffic patterns indicative of illegal/unwanted robocalls. If a calling pattern indicative of illegal robocalling is identified, or if WIN has a reasonable basis to believe robocalls are hitting its network, it takes appropriate action under the circumstances.

WIN records are capable of confirming the identity of new commercial VoIP customers, including information as to physical business location, contact person(s), state or country of incorporation, federal tax ID, and the nature of the customer’s business.

WIN has been executing explicit bilateral Traceback Cooperation provisions in amendments to contracts and renegotiated agreements with other carriers. On a parallel basis, WIN has informed carriers that pre-existing provisions of WIN’s standard contract, can, and will be, construed to require Traceback Cooperation.

WIN has an experienced group of network experts dedicated to robocall issues, part of whose duties include provision of prompt, complete responses to traceback requests from law enforcement and from USTelecom’s Industry Traceback Group. Windstream actively cooperates in Traceback Investigations and is a one of the founding members of the Traceback Group.

WIN communicates with State AGs via US Telecom’s Traceback Group regarding new scams and trends in robocalling and its remedies and directly (e.g., WIN has cooperated with State AGs in several state regulatory/legislative robocall initiatives).