On December 3, 2025, the Anti-Robocall Multistate Litigation Task Force, a bipartisan coalition of 51 Attorneys General, announced the launch of “Phase 2” of Operation Robocall Roundup. Moving beyond the smaller “gateway” providers targeted in previous actions, this new phase focuses on four of the largest voice service providers in the United States: Inteliquent (a Sinch company), Bandwidth Inc., Lumen Technologies, and Peerless Network (an Infobip company).

The Anti-Robocall Multistate Litigation Task Force is led by North Carolina Attorney General Jeff Jackson, Indiana Attorney General Todd Rokita, and Ohio Attorney General Dave Yost.  This enforcement specifically targets the infrastructure used to deliver voice calls, which the Attorney Generals assert have been used to facilitate “imposter” scams that erode consumer trust in major brands, including Amazon and Apple, the Internal Revenue Service, the Social Security Administration, financial institutions, and others.

The Allegations: Targeting the “Backbone”

The Attorneys General have issued Notice Letters to these four carriers, alleging they have knowingly routed and transmitted billions of illegal robocalls. Unlike “Phase 1” of the operation, which targeted smaller VoIP operators often used as entry points for foreign traffic, Phase 2 targets the “transit” and “backbone” carriers that form the core of the U.S. telephone network.

The Task Force cites data from the Industry Traceback Group (ITG), alleging that these providers continued to route illegal traffic despite receiving thousands of notices identifying fraud on their networks. Notably, the traffic that these carriers are accused of “routing” did not all originate on their networks.  To the contrary, the traffic apparently originated on 40 or more other carriers, including national carriers like AT&T, Google, and T-Mobile, and certain international carriers, and was then passed to these intermediate carriers for further routing.  Nevertheless, the Attorneys General take the position that these large intermediate carriers maintain a “position, prominence, and dominance in this space” such that they are able “to do more—and should do more—to reevaluate its choice to accept call traffic from recurring bad actors, either directly or indirectly, in order to meaningfully mitigate the identified and suspected illegal call traffic that those bad actors are being permitted to route across the U.S. telephone network. . . .”

The specific allegations against each carrier are detailed in the letters linked below:

• Inteliquent: The Task Force cites 9,712 traceback notices sent to Inteliquent since 2019. The letter alleges the carrier facilitated approximately 1.8 billion imposter calls, including 450 million purporting to be from Amazon or Apple and 1.4 billion impersonating the Social Security Administration (SSA) or IRS.
• Lumen:  The letter cites 7,265 traceback notices. It specifically notes a recent spike in activity, alleging that in December 2024 alone, Lumen facilitated 35.7% of all tracebacks related to financial services imposter robocalls.
• Peerless Network: Facing 5,662 traceback notices, Peerless is alleged to have facilitated nearly 800 million imposter calls. The letter highlights the carrier’s role in accepting traffic from foreign upstream providers.
• Bandwidth: The Task Force cites 3,060 traceback notices. While the total volume is lower than the others, the allegations are significant for the ecommerce sector, with over 162 million Amazon/Apple imposter calls cited.

Carrier Responses

The Attorney Generals have demanded a response from the four carriers within 35 days explaining how they will do more to mitigate unlawful traffic and signaled that they may be willing to initiate litigation if the responses are insufficient.  As of the publication of this post on December 5, 2025, we are not aware that any of the four targeted carriers have issued a specific public response or rebuttal to the Notice Letters.  

The Ecommerce Innovation Alliance will continue to monitor the responses from these carriers and any subsequent legal actions taken by the Task Force.

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