The FTC alleges, in part that they were:
1) calling consumers whose phone numbers are on the National Do Not Call Registry;
2) calling consumers who had previously asked not to be called;
3) failing to transmit their caller ID information, as required;
4) “spoofing” or masking their caller ID information;
5) failing to promptly identify themselves, the purpose of their call, and/or the nature of the goods or services they were selling;
6) improperly abandoning calls; and
7) failing to make required disclosures in their robocalls.