Client Advisory | General Regulatory & Legal Advisory

New Frontier for Robocall Enforcement Emerges: In a Carrier vs Carrier Lawsuit, Frontier Communications Alleges VoIP Provider, Mobi Telecom, Purposefully Fails to Implement Illegal Robocalling Mitigation Efforts Resulting in Damages Inflicted Upon Frontier

Frontier Communications recently filed suit against voice provider Mobi Telecom for violating Connecticut unfair trade practices law by “intentionally and recklessly” facilitating illegal robocalls. This suit highlights the emerging threat of private litigation that seeks to stave off relentless scam calls and adds yet another dimension to the complex, expansive, and evolving “Robocall Mitigation Enforcement Ecosystem” described in our firm’s recent Educational Advisory:

U.S. Robocall Mitigation Ecosystem Demands All Telecommunications Companies Pay Attention as New Threats Emerge and Compliance Balloons Well Beyond Mere FCC Compliance


Frontier argues that Mobi creates a “safe haven” for robocallers by allowing them to make illegal calls without any attempts to mitigate or block the calls. This incentivizes robocallers to do business with Mobi, which Frontier argues unfairly inflates Mobi’s revenue and burdens the customers of other companies with an onslaught of scam calls.

Frontier also states that Mobi’s conduct is “so far divorced from the norm and what is required under the law and FCC regulations.” The Federal Communications Commission (FCC) has made a recent effort to curb the massive amount of robocalls received by consumers by requiring telecommunications carriers to, among other things, verify the sources of calls and terminate the ones detected as spam. Frontier believes that Mobi is engaged in “willful blindness” by failing to implement these FCC-mandated robocall mitigation techniques.

This suit could set a precedent for similar private, non-FCC actions brought against voice providers who fail to comply with the latest anti-scam call strategies. Consumers are clearly fed up with the barrage of robocalls they receive on a regular basis. Their dissatisfaction, like here, may encourage providers to take up arms in the courtroom against other providers who facilitate the illegal calls being made to their customers.

It is vital that all voice providers take a hard look at their robocall mitigation procedures. This suit tells us that providers have more to worry about than mere FCC compliance; private enforcement actions under state consumer protection laws are starting to take shape and may cost providers millions in legal fees. It is better to take action now to ensure compliance than to pay for it later.

If your company would like to have your robocall mitigation strategies reviewed in light of the emerging and existing enforcement techniques, please contact us!


The CommLaw Group Can Help!

Given the complexity and evolving nature of the FCC’s rules, regulations and industry policies & procedures around Robocall Mitigation and Compliance issues (e.g., Stir/Shaken, TRACED Act, FCC Rules & Regulations, US Telecom Industry group, ATIS, NECA, VoIP Numbering Waivers, Know Your Customer and the private sector ecosystem), as well as the increased risk of business disputes, consumer protection enforcement by state attorneys general, and even civil litigation, and anticipating the potential torrent of client questions and concerns, The CommLaw Group formed a “Robocall Mitigation Response Team” to help clients (old and new) tackle their unique responsibilities.


Michael Donahue — Tel: 703-714-1319 / E-mail:

Rob Jackson – Tel: 703-714-1316 / E-mail:

Ron Quirk – Tel: 703-714-1305 / E-mail:


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