On February 6, 2024, the Enforcement Bureau (“Bureau”) released a Public Notice notifying all U.S.-based voice service providers that, pursuant to Section 64.1200(k)(4), they may block voice calls or cease to accept traffic from Lingo Telecom, LLC ( “Lingo”) after notifying the Commission of their decision and providing a brief summary of their basis for making such a determination, if Lingo either fails to effectively mitigate its illegal traffic within 48 hours of the date of the Public Notice, or if Lingo fails to implement effective measures to prevent new and renewing customers from using its network to originate illegal calls within 14 days of the date of the Public Notice.
The Public Notice identifies Lingo as the apparent originator of a series of spoofed deepfake illegal robocalls placed on January 21, 2024 (two days before the NH Presidential Primary Election), in which callers received AI-voiced messages from a voice made to sound like President Joe Biden, and appeared to be originating from an individual with ties to the NH Democrats. The Public Notice was issued contemporaneously with a cease-and-desist letter (“Letter”) directed towards Lingo that sets forth investigation and mitigation requirements for the company. Lingo is required to: (1) promptly investigate the traffic identified in the Letter; (2) block or cease accepting the identified traffic and substantially similar traffic on an ongoing basis (unless it determines that the identified traffic is legal and provides a reasonable explanation to support that conclusion); and (3) report the results of the investigation to the Bureau within 14 days of the date of the Letter. If Lingo fails to comply with the aforementioned requirements, the Bureau may ultimately issue a Final Determination Order requiring downstream voice service providers to block and cease accepting all traffic from Lingo.
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