On July 7, a bipartisan coalition of 49 state attorneys general (AGs) sent a letter to the Federal Communications Commission (FCC) urging the adoption of stronger measures to combat illegal robocalls. The letter represents another action by the state AGs’ Anti-Robocall Multistate Litigation Task Force, which was established in 2022 to crack down on illegal robocalls.

Background

According to the National Association of Attorneys General, in 2025, Americans received approximately 29.6 billion scam robocalls and texts and lost nearly $2 billion to these scams.

Illegal robocalls — automated calls delivering prerecorded or artificial voice messages — remain a persistent consumer protection problem. The alleged scams are costly: consumers lost an estimated $789 million to robocall fraud in 2024, and the Federal Trade Commission reported that total consumer losses to scams, including fraudulent calls and texts, exceeded $12.5 billion that same year.

In March 2026, the FCC proposed new regulations to increase transparency and reporting requirements for companies that sell phone numbers, with the goal of reducing scammers’ ability to obtain numbers for illegal robocall campaigns.

The Coalition’s Recommendations

In reply comments to the FCC, the 49-state coalition expressed support for the agency’s proposed measures and offered additional recommendations to close existing loopholes. The coalition’s key recommendations include:

• Broaden the definition of “telephone number reseller.” The AGs recommend expanding the proposed definition to capture one-way outbound “termination” services and businesses that sell standalone telephone numbers without a connection to a communications service.
• Prohibit the resale of standalone telephone numbers not tethered to a communications service, consistent with the FCC’s existing ban on the sale of toll-free (800) numbers.
• Prohibit number cycling. The AGs cite enforcement examples — including a case involving an alleged 17.3 million calls in a single day at a nearly 1-to-1 ratio of calls to unique numbers — as evidence that number cycling is used to evade robocall analytics.
• Restrict abuse of trial numbers. Scammers have been exploiting trial service offerings, and the coalition recommends imposing usage caps, prohibiting free trials, monitoring for suspicious activity, and mandating know-your-customer practices for trial accounts.

Why It Matters

This development signals continued and intensifying regulatory scrutiny of the telecommunications supply chain that allegedly enables illegal robocalls. Companies engaged in telemarketing, automated calling, or the sale and assignment of phone numbers should take note of several key points:

• Expanded definitions may broaden liability. If the FCC adopts the coalition’s recommendation to widen the definition of “telephone number resellers,” companies further up the supply chain could face heightened compliance obligations and enforcement exposure.
• State AGs remain aggressive. The 49-state coalition and the ongoing work of the Anti-Robocall Litigation Task Force underscore that state attorneys general view robocall enforcement as a high priority and are actively coordinating enforcement strategies.
• Compliance programs warrant review. Companies that use automated calling technology or purchase phone numbers should review their compliance programs, vendor agreements, and due diligence procedures in light of the FCC’s proposed rules and the coalition’s recommendations.

Troutman Pepper Locke State Attorneys General Team

	Ashley Taylor – Co-leader and Firm Vice Chair Ashley is co-leader of the firm’s nationally ranked State Attorneys General practice, vice chair of the firm, and a partner in its Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. He helps his clients navigate the complexities involved with multistate attorneys general investigations and enforcement actions, federal agency actions, and accompanying litigation.
	Clay Friedman – Co-leader Clay co-leads the firm’s State Attorneys General practice and is nationally ranked by Chambers USA for AG Government Relations and in Best Lawyers for Advertising Law. He has dedicated his entire career to state attorney general and federal work, serving for nearly a decade in a senior role and more than 25+ years in private practice. Clay focuses his practice on helping industry-leading companies mitigate the risks associated with state and federal regulatory investigations and associated litigation.
	Chris Carlson Chris advises clients on regulatory, civil, and criminal investigations and litigation. With a background as an assistant attorney general, he provides practical guidance to clients with matters involving state attorneys general and federal regulatory agencies.
	Lauren Fincher Lauren has vast experience handling state attorneys general investigations, navigating complex regulatory compliance matters, and providing strategic counsel in enforcement actions across various industries. She helps clients manage high-stakes regulatory matters and guides them through complex legal landscapes.
	Stephen Piepgrass Stephen leads the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, representing clients in single and multistate enforcement actions, including inquiries and investigations involving state attorneys general and other state and federal governmental enforcement bodies including the CFPB and FTC. He regularly represents clients in highly regulated sectors such as financial services, emerging technologies, health care, insurance, and education.
	Michael Yaghi Mike handles high-profile investigations led by state attorneys general, the FTC, and other federal and state regulatory bodies. He assists clients through these complex government inquiries, assisting them throughout the entire life cycle of investigations, from regulatory enforcement through formal litigation.
	Matthew J. Berns Drawing on his experience in senior leadership roles in the New Jersey Attorney General’s and Governor’s Offices and as a trial attorney for the U.S. Department of Justice, Matt provides an insider’s perspective when guiding clients through complex government investigations, litigation, and other actions.
	Jeff Johnson Jeff helps clients navigate complex regulatory and litigation challenges with local, state, and federal authorities. His clients benefit from his decade of broad litigation experience, understanding of emerging state and federal regulatory issues, and strong relationships with attorneys general across the U.S. In addition to handling cases from trial through state or federal appeals, Jeff serves as amicus counsel in advancing legal rules to support his clients’ vital interests.
	Jay Myers Jay assists clients in heavily regulated industries, including health care, energy, insurance, emerging industries, and data privacy. He provides both regulatory legal advice and government relations strategies. Jay’s past and current clients include Fortune 10 companies, startups, nonprofits, industry associations, and advocacy groups. Recognizing that state government matters are often complex and multifaceted, he utilizes regulatory guidance, government advocacy, or both in tandem to deliver tailored solutions for each client’s unique needs.
	Zoe Schloss Zoe represents clients in litigation and government investigations. As former deputy attorney general for the Delaware Department of Justice, she is an experienced litigator who understands the enforcement priorities that impact her clients. Zoe works with individuals and corporate entities in highly regulated industries, including financial services, health care, and energy.
	Jessica Birdsong Jessica is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. She received her J.D. from the University of Richmond School of Law, magna cum laude, where she served as associate articles editor of the Journal of Law & Technology.
	Sydney Goldberg Sydney is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. She advises clients on regulatory compliance and state attorney general (AG) investigations in highly regulated industries, including health care and life sciences. She routinely helps clients navigate alcohol compliance and licensing issues, helping proactively manage regulatory risk.
	Troy Homesley Troy is an accomplished litigator who has represented and defended clients across a wide range of complex, high-stakes disputes at both the trial and appellate levels. He has represented technology companies, business executives, law firms, investment funds, high-ranking federal officials, international non-profits, and asylum seekers. Troy draws on his broad litigation experience to advise clients before litigation arises, while claims are pending or threatened, and leading up to and through trial and appeals.
	Namrata Kang Namrata (Nam) is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, based in the Washington, D.C. office. She routinely advises clients on a wide variety of state and federal regulatory matters, with a particular emphasis on state consumer protection laws relating to consumer financial services and marketing and advertising. Nam’s experience transcends multiple industries, including financial services, telecommunications, media, and sports betting.
	Michael Lafleur Michael is an associate in the firm’s Regulatory Investigations, Strategy, and Enforcement Practice Group. Based out of the firm’s Boston office, Mike has deep experience in litigation, investigations, and other regulatory matters involving state-level regulators and state attorneys general.
	William LaRosa Bill represents clients in complex regulatory investigations, state attorneys general matters, and enforcement proceedings. He draws on his experience as a former assistant U.S. attorney and as a private-sector litigator advising corporations in high-stakes litigation and regulatory investigations, including multistate AG investigations.
	Philip Nickerson Philip’s diverse practice includes representation of financial, tech, real estate, and energy companies in a range of government investigation and litigation matters. With experience obtaining favorable results for clients as a first and second-chair litigator in state and federal trial courts, arguing before federal courts of appeal, and representing clients in arbitration proceedings, he understands the importance of tailoring litigation strategy to align with clients’ goals.
	Lane Page Lane represents financial institutions and other clients in federal and state regulatory investigations and complex civil litigation. He is particularly focused on consumer protection and fair lending issues.
	Dascher Pasco Dascher provides strategic counsel and representation to clients navigating regulatory compliance, enforcement, and high-stakes litigation. She regularly represents clients in both single and multistate state attorney general (AG) investigations and enforcement actions, as well as before other state enforcement bodies and local government agencies.
	Kyara Rivera Rivera Kyara is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. She received her J.D. from the University of Richmond School of Law, cum laude, where she served as publications and online editor of the Public Interest Law Review.
	Timothy Shyu Timothy advises clients on regulatory compliance and enforcement in highly regulated industries, including health care and life sciences, data privacy and cybersecurity, and emerging technology. He assists companies in navigating complex investigations and enforcement actions, helping them mitigate regulatory risk proactively.
	Trey Smith Trey focuses his practice on representing and advising regulated utilities before state public utility commissions. He routinely helps clients obtain certificates of public convenience and necessity for transmission infrastructure. In this role, Trey works with his clients’ subject-matter experts to manage administrative proceedings, including by preparing initial filings; responding to discovery requests; drafting rebuttal testimony; and litigating any disputed issues.
	Daniel Waltz Dan helps clients navigate all aspects highly regulated relationships between industry participants and federal, state and local governments. Whether engaging with regulators, negotiating transactions or representing clients in the courtroom, he delivers solutions that help his clients achieve their strategic goals.
	Stephanie Kozol Stephanie is Troutman Pepper Locke’s senior government relations manager in the state attorneys general department.