January 21, 2020 V IA ECFS Ms. Marlene H. Dortch Secretary Federal - PDF document

KELLEY DRYE & W ARREN LLP A LIMITED LIABILIT Y PARTNER SHIP WASHINGTON HARBOUR, SUITE 400 N E W Y O R K , N Y F A C S I M I L E 3050 K STREET, NW C H I C A G O , I L ( 2 0 2 ) 3 4 2 - 8 4 5 1 WASHINGTON, DC 20007 H O U S T O N , T X w w w . k e l l e y d r y e . c o m L O S A N G E L E S , C A S A N D I E G O , C A ( 2 0 2 ) 3 4 2 - 8 4 0 0 S T E V E N A . A U G U S T I N O S T A M F O R D , C T B R U S S E L S , B E L G I U M D I R E C T L I N E : ( 2 0 2 ) 3 4 2 - 8 6 1 2 , E MA I L : s a u g u s t i n o @ k e l l e y d r y e . c o m A F F I L I A T E O F F I C E M U M B A I , I N D I A January 21, 2020 V IA ECFS Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12 th Street, SW Washington, D.C. 20554 Re: NOTICE OF EX PARTE COMMUNICATION OF TRANSACTION NETWORK SERVICES, INC. CG Docket No. 17-59: Advanced Methods to Target and Eliminate Unlawful Robocalls WC Docket No. 17-97: Call Authentication Trust Anchor. Dear Ms. Dortch: On January 16, 2020, Jim Tyrrell, Senior Director, Product Marketing, and Lavinia Kennedy, Director, Product Management, with Transaction Network Services, Inc. (“TNS”), 1 along with outside counsel, Steven A. Augustino of Kelley Drye & Warren. LLP, met in person with various members of the Consumer and Government Affairs Bureau regarding topics raised in the above proceedings. In attendance from the Consumer and Governmental Affairs Bureau were: Patrick Webre, Chief; Mark Stone, Deputy Bureau Chief; Ed Bartholme, Associate Bureau Chief; Kurt Schroeder (by phone), Jerusha Burnett, Mika Savir, Aaron Garza, and Kristi Thornton (by phone). 1 TNS is a leading global provider of data communications and interoperability solutions. TNS offers a broad range of network connectivity and innovative value-added services which enable transactions and the exchange of information in diverse industries such as telecommunications, payment processing, and financial services markets. 4827-2052-4210v.1

KELLEY DRYE & W ARREN LLP Ms. Marlene H. Dortch January 21, 2020 Page 2 At the meeting TNS discussed its Identity Protection Services for identifying and protecting consumers from robocalls. TNS discussed the results of its September 2019 Robocall Investigation Report regarding trends in unlawful robocalling. In particular, TNS noted that:  Over 200 million calls per day are unwanted calls. Nearly 30% of all U.S. calls were assigned a negative score (nuisance, scam or fraud calls) in the first six months of the year, resulting in 200 million unwanted calls per day.  Tier 1 carriers continue to be a small part of the problem. 70% of all calls, positive and negative, come from tier one providers, yet a little over 10% of the calls from those carriers’ numbers are considered high-risk. The data suggest that while top carriers are making inroads in the fight against robocalls, VoIP providers and smaller regional carriers may need to take more aggressive action as bad actors shift focus to their networks.  High-risk calls are growing at a double-digit rate. Nuisance calls increased 38%, while high-risk calls grew at only 28% from third quarter last year to second quarter this year.  Robocall spoofers hijacking mobile numbers has more than doubled. 1 in 1,700 mobile numbers are now being hijacked by robocall spoofers every month, which is causing 2.5% of people who have had their number hijacked to disconnect or change their phone number.  Spoofing of VoIP numbers have shifted to spoofing of toll-free numbers. Using VoIP telephone numbers has dropped from 63% of the high-risk call volume to 52%, while toll-free has increased from 17% to 25% of the high-risk call volume.  Legitimate enterprise toll-free numbers are being spoofed. 70% of the calls from legitimate toll-free numbers are viewed as either nuisance or high-risk is confirmed by crowd-source sentiment.  Neighbor spoofing & snowshoe spamming more sophisticated. High risk (scam/fraud) calls using neighbor spoofing now accounts for 25% of all negative calls - up 6 percentage points from the prior year. TNS also discussed the TRACED Act and the many proceedings and reports that the Act requires. TNS stated that its data and insights would be helpful to the Commission as it implemented the TRACED Act and TNS offered to provide input where it could. In particular, TNS noted that its Call Authentication Hub for SHAKEN/STIR deployments could be helpful in meeting the TRACED Act’s implementation deadline for call authentication frameworks. With respect to call blocking services, TNS explained that its carrier partners ultimately determine 4827-2052-4210v.1

KELLEY DRYE & W ARREN LLP Ms. Marlene H. Dortch January 21, 2020 Page 3 whether to block a call, send it to voicemail or label a call, based on the scoring system TNS provides. TNS has found that each carrier approaches this balance differently and TNS supported allowing carriers continued discretion in determining the wishes of its own customer base. Finally, TNS discussed insights from its crowd-sourced feedback, and the fact that not all crowd-sourced feedback can be taken at face value as there are instances where calling parties provide positive feedback on spam calls. TNS explained that it monitors for such scenarios and uses its full range of analytics sources to ensure accurate scoring of originating calls. The attached presentation materials were distributed and discussed at the meeting. This ex parte notification is being filed electronically with your office pursuant to Section 1.1206 of the Commission’s Rules. Please do not hesitate to contact me with any questions or concerns. Respectfully submitted, Steven A. Augustino Counsel for Transaction Network Services, Inc. Attachment cc: FCC personnel listed above 4827-2052-4210v.1