The full letter can be found at https://www.fcc.gov/document/fcc-issues-robocall-cease-and-desist-letter-twilio https://www.fcc.gov/document/fcc-issues-robocall

The full letter can be found at https://www.fcc.gov/document/fcc-issues-robocall-cease-and-desist-letter-twilio https://www.fcc.gov/document/fcc-issues-robocall-cease-and-d... as a pdf. There are several spots in there where the FCC uses bold and italic. --- Some of the interesting parts: Dear Mr. Lawson: We have determined that Twilio Inc. (Twilio) is apparently originating illegal robocall traffic on behalf of one or more of its clients. As explained further below, this letter provides notice of important legal obligations and steps Twilio must take to address this apparently illegal traffic. Twilio should investigate the identified traffic and take the steps described below, including blocking the traffic if necessary, and take steps to prevent Twilio’s network from continuing to be a source of apparently illegal robocalls. Failure to comply with the steps outlined in this letter may result in downstream voice service providers blocking all of Twilio’s traffic, permanently. ... Applicable FCC Rules. This letter is based on FCC rules that apply to originating providers like Twilio. First, under the safe harbor set forth in section 64.1200(k)(4),4 any provider may block all traffic from an originating provider that, when notified by the Commission, fails to effectively mitigate illegal traffic within 48 hours or fails to implement effective measures to prevent new and renewing customers from using its network to originate illegal calls. This letter provides notice under section 64.1200(k)(4) and describes the mitigation steps you must take. Second, section 64.6305(e)5 permits providers to accept calls directly from an originating provider only if that originating provider’s filing appears in the FCC’s Robocall Mitigation Database. As explained below, if Twilio continues to transmit illegal robocalls, the Bureau may initiate proceedings to remove Twilio’s certification from the database, thereby requiring providers to cease accepting calls directly from Twilio. Third, sections 64.1200(n)6 and 64.6305 prescribe various additional obligations for mitigating and preventing illegal robocalls. We remind Twilio that failure to comply with any of these obligations may result in additional enforcement action pursuant to the Communications Act and the Commission’s rules.7 ... If after 48 hours Twilio continues to originate unlawful robocall traffic from the entities involved in this campaign, downstream U.S.-based voice service providers may begin blocking all calls from Twilio after notifying the Commission of their decision and providing a brief summary of their basis for making such a determination.15 Furthermore, if after 14 days, Twilio has not taken sufficient actions to prevent its network from continuing to be used to transmit illegal robocalls, then downstream U.S.-based providers may block calls following notice to the Commission.16 U.S.-based voice service providers may block ALL call traffic transmitting from Twilio’s network if it fails to act within either deadline.