On August 12, a coalition of Attorneys General announced "Operation Robocall Roundup" — a multistate enforcement action aimed squarely at voice service providers accused of transmitting illegal robocalls. This time, the regulators aren't just chasing the scammers themselves; they're going after the telecom infrastructure that enables them.
Who's in the Crosshairs?
The Anti-Robocall Litigation Task Force sent warning letters to 37 voice providers, alleging they knowingly or recklessly allowed unlawful robocalls to pass through their networks. The list includes both domestic and foreign companies, such as DigitalOcean LLC, Infinity SIP LLC, TheVisionConnect, and Whisl Telecom LLC (along with its affiliates). The full roster reads like a who's-who of lesser-known carriers, but the message is clear: if you open your pipes to junk calls, the AGs are coming for you.
Why This Matters
1. Expanding the target zone
Traditionally, enforcement has focused on the entities originating
illegal calls. This sweep underscores that state AGs are now
holding upstream enablers accountable—anyone in the call path
who "should have known" they were facilitating
violations. The FTC has long taken the position
— and acted on it—that telecom providers, including
VoIP providers, can be liable under the Telemarketing Sales Rule
(TSR) for "assisting and facilitating" illegal
telemarketing.
What's new here is that this is the first formal, coordinated effort by state Attorneys General to apply that same theory to voice providers. While there have been a few one-off state settlements in the past, this marks the first time a multistate AG coalition has publicly and explicitly asserted TSR-style liability against telecom intermediaries. In other words: the states are now playing the FTC's game—just with more players on the field.
2. Compliance is a chain, not a link
For advertisers, marketers, and their counsel, this means vendor
due diligence isn't optional. If your campaigns rely on
third-party voice providers, you should know exactly what
they're doing to detect and block suspect traffic.
3. Brand risk isn't abstract
Even if your business isn't the one dialing, being associated
with illegal robocalls can damage consumer trust and invite
regulatory scrutiny.
What's Next
The warning letters give these companies a short window to respond and demonstrate corrective measures. Failure to act could lead to lawsuits, fines, or being effectively cut off from legitimate telecom partners. Given the Task Force's growing coordination with the FCC and FTC, we can expect similar sweeps in other sectors where bad actors exploit intermediaries.
Key Takeaway
If you are an advertiser, agency, or telecom intermediary, now is the time to review your compliance programs. Scrutinize your call routing partners. Document your vetting procedures. And recognize that TSR-style liability is no longer just a federal concern — for the first time, state Attorneys General are formally and collectively taking that position. This expands your exposure from one cop on the beat to dozens, all working in tandem.
This alert provides general coverage of its subject area. We provide it with the understanding that Frankfurt Kurnit Klein & Selz is not engaged herein in rendering legal advice, and shall not be liable for any damages resulting from any error, inaccuracy, or omission. Our attorneys practice law only in jurisdictions in which they are properly authorized to do so. We do not seek to represent clients in other jurisdictions.
