by Megan L. Brown , Scott D. Delacourt , Kevin G. Rupy , Kathleen E. Scott and Stephen Conley
At its July Open Commission meeting, the Federal Communications Commission's (FCC or Commission) voted to approve a Notice of Apparent Liability for Forfeiture (NAL) against Thomas Dorsher, ChariTel Inc, OnTel Inc, and ScammerBlaster Inc (collectively the "Dorsher Entities") for allegedly engaging in a toll-free robocall traffic pumping scheme, in violation of the Telephone Consumer Protection Act (TCPA), that used revenue generated from the scheme to fund dangerous telephony denial of service (TDoS) attacks. The $116 million proposed fine represents the FCC's first TCPA enforcement action targeting entities engaged in a toll-free traffic-pumping scheme, signaling the agency's willingness to take action against unlawful robocalls made to businesses.