Largest fine in FCC history. International auto warranty scam placed 5.19 billion calls to 550 million phones in just 3 months (Jan-Mar 2021), using 1.05 million spoofed caller IDs. Illinois was among the hardest-hit states. After FCC ordered carriers to stop carrying this traffic, illegal auto warranty calls dropped 99%. Demonstrates that carrier-level enforcement (blocking at the network) is the most effective tool against massive robocall operations.

Part of FTC Operation Stop Scam Calls — largest crackdown on illegal telemarketing in FTC history (180+ actions). Yodel initiated 1.4 billion calls using leads from consent farms, with 500+ million to DNC numbers. $1M penalty (suspended to $400K after partial payment). Banned from telemarketing permanently. Key lesson: buying leads from "consent farm" websites does NOT constitute valid prior express written consent under the TSR.

First legal action of the Anti-Robocall Multistate Litigation Task Force. Avid Telecom transmitted 24.5 billion calls (90%+ lasted under 15 seconds = robocalls), including 290 million to Illinois numbers and 7.5 billion to DNC-registered numbers. Used spoofed/invalid caller IDs including 8.4 million calls appearing to come from government agencies. VoIP providers that knowingly facilitate illegal traffic are now primary enforcement targets — not just the telemarketers themselves.

IL AG Raoul co-founded nationwide Anti-Robocall Litigation Task Force with all 51 AGs. Immediately issued civil investigative demands to 20 gateway providers responsible for majority of foreign robocall traffic into the US. Signals shift from targeting individual robocallers to going after the telecom infrastructure that enables them. Gateway VoIP providers are now on notice that "we just carry traffic" is not a defense.

Largest telemarketing penalty in DOJ history at the time. Dish made 66+ million illegal calls via authorized dealers to DNC-registered numbers and delivered prerecorded messages without consent. 11-year case (filed 2009) involving DOJ, FTC, and AGs of CA, IL, NC, and OH. IL AG Raoul co-plaintiff. $126M federal penalty + $84M to the four states. Demonstrates that companies are liable for their vendors' telemarketing violations — vicarious liability is real and expensive.