Washington, DC - Do you have one of those massive white boards that takes up the entire wall of your conference room? You may need it to follow the machinations that multiple defendants allegedly engaged in so they could bombard consumers with robocalls by the billions. (Yes, that’s with a “b.”) The FTC has gone to court to put a stop to their illegal activities.

Filed in federal court in California, the FTC lawsuit alleges that defendant James Christiano and companies he controls operate TelWeb, a dialing platform with the capacity to blast people with a staggering number of robocalls. In fact, calls made with TelWeb have been so pervasive that they’ve been an issue in no fewer than eight previous FTC law enforcement actions. Take out a marker to draw some connectors on your white board because several of the names mentioned in the FTC complaint have cropped up before. For example, according to the lawsuit, Christiano is a long-time business associate of Aaron Michael Jones. That name should ring a bell with FTC watchers because Jones is a recidivist robocaller who was banned from the industry as part of a $2.7 million default judgment in 2017 and has been sued again in 2018 for deceptive practices related to robocalls targeting small business owners.

The FTC alleges that a Christiano-controlled company, NetDotSolutions, licensed software to Jones – which he resold to his clients – that allowed them to place robocalls pitching everything from home security systems to car warranties to purported debt relief services. According to the complaint, most (if not all) telemarketing calls made using Christiano’s TelWeb platform flowed through Jones and his business partners as resellers. One of those business partners is a guy named Andrew Salisbury, named in this action as a defendant. Then there’s TeraMESH Networks, a company the FTC says leased computer server rack space to Jones that enabled him to host, maintain, and update the TelWeb software.

In addition to his role in Jones’s robocalling ring, the FTC says defendant Salisbury is president and part owner of World Connection, a call center outfit that enters the picture when consumers “press 1” in response to a robocall. The complaint alleges that millions of calls that were transferred to World Connection after a consumer pressed 1 used “neighbor spoofing” – an illegal technique that falsifies the caller ID number to make it look like the call is coming from the consumer’s area. According to the FTC, to facilitate the operation, World Connection and its clients often turned to a fellow named Justin Ramsey. Time to draw another connection because Ramsey – another recidivist robocaller – settled a lawsuit with the FTC in 2017 and is named as a defendant in an action filed in 2018. Who is Ramsey’s co-defendant in that pending case? Aaron Michael Jones.

Flow charts and corporate structures aside, the FTC says the upshot was that consumers – many of whom are on the National Do Not Call Registry – have been targeted with more than a billion illegal robocalls each year. The complaint charges Christiano, NetDotSolutions, and TeraMESH with assisting and facilitating: 1) illegal robocalls, 2) calls to number on the Do Not Call Registry, 3) calls with spoofed caller ID numbers, and 4) abandoned calls that occurred when the TelWeb system hung up on consumers who answered.

Keep those markers out because there’s more for the white board. The lawsuit also charges that Salisbury and three companies related to World Connection initiated or caused the initiation of illegal robocalls, calls to numbers on the DNC Registry, and calls with spoofed caller IDs. The FTC is seeking a court order to stop the defendants’ illegal conduct and impose civil penalties.

The case was just filed, but it’s a good reminder that the Telemarketing Sale Rule prohibits pretty much all commercial robocalls unless consumers have given their express written consent to get those calls.