Robocall Mitigation Plan

Service Description

SUMOFIBER provides interconnected Voice over Internet Protocol service (Hosted PBX) to residential and business customers in our service areas. We deliver voice service through partnerships with upstream carriers and use industry standard signaling and routing.

Know Your Customer

We sell voice service to end users, not to call originators or traffic pumping operations. Before activating service, we:

• Verify customer identity using name, address, and payment information
• Confirm the customer has a legitimate use case for the requested service
• Screen for indicators of potential abuse, including unusual order patterns
• Maintain records of customer identity for the duration of service and a reasonable period after

STIR/SHAKEN Implementation

We support STIR/SHAKEN caller ID authentication on our voice service. Calls originating from our network are signed in accordance with the framework. We work with our upstream voice partners to ensure proper attestation and to validate inbound calls.

Where direct STIR/SHAKEN signing is performed by an upstream partner, we maintain documentation of that arrangement and ensure our certificate and attestation logic comply with current FCC requirements.

Traffic Monitoring

We monitor outbound voice traffic for patterns consistent with illegal robocalling, including:

• Unusually high call volumes from a single customer
• Short call durations consistent with auto-dialing
• Spoofed or invalid caller ID information
• Calls to numbers on do not call registries
• Patterns flagged by industry traceback efforts

Response to Illegal Traffic

When we identify likely illegal robocall traffic from a customer, we:

• Investigate the activity
• Contact the customer to obtain an explanation and require corrective action
• Restrict, suspend, or terminate the customer's service if the activity continues or if it presents an immediate risk
• Cooperate with the Industry Traceback Group and government investigators
• Block traffic from sources that fail to comply

Cooperation with Investigations

We respond to traceback requests from the Industry Traceback Group, the Federal Communications Commission, the Federal Trade Commission, state attorneys general, and law enforcement agencies in a timely manner. We provide records that help identify the source of suspected illegal calls, as permitted by law.

Customer Education

We educate business customers about their obligations when using our voice service, including:

• Restrictions on robocalling under the Telephone Consumer Protection Act (TCPA)
• Caller ID accuracy requirements
• Do not call registry obligations
• Consent requirements for marketing calls and texts

Database Registration

We maintain an active filing in the Federal Communications Commission's Robocall Mitigation Database. Our filing includes the contact information for our robocall mitigation point of contact and a description of our mitigation practices.

Reporting

If you believe you have received an illegal robocall from a number on our network, you can report it to:

You can also file a complaint with the Federal Communications Commission at fcc.gov/complaints or with the Federal Trade Commission at donotcall.gov.

Updates

This plan is reviewed and updated regularly. The current version is posted on our website and is also filed with the Federal Communications Commission Robocall Mitigation Database.