Analysis · FCC & rulemaking
Operation Robocall Roundup Phase 2: State AGs Put Four Major Carriers on Notice
Members of the Anti-Robocall Multistate Litigation Task Force, a bipartisan group of state attorneys general, launched the second phase of "Operation Robocall Roundup" on December 3, 2025. The Task Force sent notices to four of the largest voice providers: Inteliquent, Bandwidth, Lumen and Peerless. Pennsylvania Attorney General Dave Sunday announced the action. You can read the Task Force notice letter to Inteliquent.
On this page
The bottom line: state enforcers are turning from smaller carriers to larger ones, and they are using traceback data to do it.
What happened
According to the Pennsylvania Attorney General, the Task Force directed the four providers to investigate illegal robocalls within their networks. The announcement includes a summary of suspected illegal robocall activity, including:
- Inteliquent: 9,712 traceback notices since 2019, an estimated 450 million "Amazon" or "Apple" imposter robocalls, and 1.425 billion "Social Security Administration" or "IRS" (Internal Revenue Service) imposter robocalls.
- Bandwidth: 3,060 traceback notices, 162.7 million and 301 million.
- Peerless: 5,662 traceback notices, 210.7 million and 585.3 million.
- Lumen: 7,265 traceback notices, 261.5 million and 886.2 million.
The imposter numbers are estimates over periods of three to four years. They are the Task Force's findings, not court findings. (The release states "3.060" for Bandwidth, which we read as 3,060.)
The Inteliquent letter warns the company to review its customers' traffic, consider its robocall mitigation plan, Know Your Customer and onboarding practices, and stop transmitting illegal traffic for its customers.
Phase one results
In August 2025, the Task Force sent warning letters to 37 smaller providers. According to the release, after the letters went out, 13 companies were removed from the Federal Communications Commission (FCC) Robocall Mitigation Database, 19 stopped appearing in traceback results, and at least four terminated contracts with high-risk customers.
Why it matters
A notice letter is not a lawsuit. But the Task Force has sued before, and the letters create a record that a provider knew about suspect traffic. For large carriers, that record matters in any future case.
What this means for you
- Treat every traceback request as a compliance event and document your response.
- Review your high-volume customers, especially any showing repeat tracebacks.
- Update your Know Your Customer and onboarding procedures, and apply them to your existing customers.
- Keep your Robocall Mitigation Database filing current and accurate.
- If you buy wholesale routes, ask your carriers how they handle Task Force notices.
State attorneys general are watching the networks, not just the callers.
Not legal advice. TCPA.com provides general information, not legal advice, and is not a substitute for the advice of an attorney. Do not rely on it. Verify any action with your own licensed lawyer before you take it. See our Terms of Use.
