Merchant Account Underwriting Tools


This case involves billions of robocalls dialed using software and servers provided by Defendant James “Jamie” Christiano and his companies: Defendants NetDot Solutions, Inc. and TeraMESH Networks, Inc. At least one billon of those robocalls were programmed to transfer to a call center run by the other set of defendants in this case, Defendant Andrew “Andy” Salisbury and his call center businesses all named World Connection.

Salisbury’s WConnection Enterprise and Jones’s other businesses and clients are responsible for bombarding American consumers in all fifty states and the District of Columbia with billions of illegal robocalls, all dialed through Christiano’s TelWeb platform.

These robocalls pitched numerous different consumer goods and services, including reverse mortgages, tax debt relief, “pain cream,” timeshares, vacation services, credit card debt relief, student loan debt relief, home security systems, solar energy and solar panels, extended auto warranties, medical pendants, and others.

The statistics in the following table demonstrate the magnitude of the illegal telemarketing that Salisbury, Jones, and their businesses and customers, including the WConnection Enterprise, conducted through TelWeb. The figures in this table represent only calls that were actually connected to a consumer or voicemail system; many more illegal calls were initiated through TelWeb but not connected.

Time Period Outbound Calls Connected (mostly unlawful robocalls) Calls Connected to Numbers on the Nat’l DNC Registry
Annual averages for 2014 through May 2016 883 million calls per year average 157 million calls per year average
January 2014 to March 2014 More than 329 million calls More than 32 million calls
January 2015 to March 2015 More than 222 million calls More than 40 million calls
June 1, 2015 to May 5, 2016 More than 700 million calls More than 150 million calls


On top of these violations, 64 million of the connected calls dialed through TelWeb between January 2016 and May 2016 were placed using spoofed caller ID numbers, using a specific type of spoofing called “Neighbor Spoofing.”

Neighbor spoofing is when a caller spoofs the area code and exchange of a consumer’s phone number so that the consumer thinks the call is coming from someone near them. For 54 million of these calls, Jones’s Red Hill Robocall enterprise generated an outbound caller ID for the outbound calls by adding 128 to the number being called.



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