Convoso Engages

From: David Frankel <dfrankel@zipdx.com>
Sent: Friday, February 16, 2024 10:46 AM
To: ‘Tammy Glover Fowler’ <tgloverfowler@convoso.com>
Cc: ‘Meg Mananian’ <mmananian@convoso.com>; ‘Josh Stevens’ <jstevens@mslawgroup.com>
Subject: RE: Seeking Convoso’s Help with Relentless Calling

Thanks for your response Tammy.

You are welcome to use whatever means you wish to clean up your calling. I just want to see far fewer calls that lack proper consent. So far today I’ve gotten 24 Convoso-signed calls. Examples:

To one of my numbers: Hello. This is Alex from the health scout on a recorded line. Am I speaking with Valerie? Hello?  Six minutes earlier, you called the same number with:

Hi. This is Louie from Health Scout. Am I speaking with Valerie? Hello? Hello? Yesterday you called and said this: Hello. This is Anna calling from the Health Scout. Disability on a recorded line. Am I speaking with Valerie? Isn’t it apparent that Valerie isn’t here?

To another number: Hi. Am I speaking with Michael? This is Gibson Bill calling from EverQuote calling on a recorded line. Yesterday you called and said this: May I speak with Michael? This is Leandra Roblett of EverQuote calling on a recorded line about the life insurance quote you requested.

To another number: Hello. May I speak to Charles? I’m calling to check if you already received this healthy food product. That’s good. I’m calling in Dubred Wilson. Okay, sir. Did you happen to receive this help if we’d called us last week? Okay. Okay. No worries. Because I can help you receive this at no additional cost if we have the Medicare A and B active, sir. Do you have it active? Medicare? Hello? Hello, sir? Yesterday you also called this number: Hello. Good day. My name is Amy. May I speak with Charles? Hi, sir. This is Amy. By the way, I’m calling regarding the updated benefits from your health care provider. Just wanna double check only if you have received the newly increased allowances like healthy food card and flex card or not yet.  And the day before you said this: Hello. Good day. This is Alex from the health account on a recorded line. Am I speaking with Charles so Charles, I was reaching to you because based on the information that we have here, you may very much qualify to receive this newly and upgraded additional benefit at no additional cost. And upon checking here, Charles, do you have your Medicare parts a and b, sir, I told you during this call that I did not consent (AUDIO); you HUNG UP ON ME and then called back twice more. This number has been mine for months and is on the DNC list. Your lead is obviously defective. Are you checking the Reassigned Numbers Database?

You appear to be making aggressive use of ANI rotation – the 24 calls today have come from 24 distinct calling numbers. When you call the same number over and over, you usually use a different number for each call. That’s further frustrating to the called party.

David Frankel

On Wed, Feb 21, 2024 at 12:42 AM David Frankel <dfrankel@zipdx.com> wrote:

Hi again Tammy –

Your signature says “Compliance Officer” so I’m assuming you are the right person for my concerns.

Let’s take a look at just one example from today. In the space of less than eight hours, I received SIXTEEN Convoso A-attested calls to my telephone number 1-817-775-8280. On the fifth call, I told your agent that I did not consent to these calls. Still, you called back eleven more times.

You are calling this number, on average, TWICE PER HOUR!

The calls came from six different calling numbers. All have the same OrigID in the STIR/SHAKEN identity header, suggesting they all come from the same call source.

Can you help my understand why this is happening? Can you get it to stop? Do you disagree that this behavior would tremendously frustrate any call recipient? Especially when the number has been on the Federal DNC list for more than a year? Is there something wrong with my data, analysis, or methodology?

Do you have any suggestions for a more constructive and effective way for me to address this problem?

David

On Wed, Feb 21, 2024 at 9:32 AM Tammy Glover Fowler <tgloverfowler@convoso.com> wrote:

Good morning,

Let’s make sure we don’t develop an ongoing conversation with him.

I recommend that we ask toJosh write him next as a final comment, reinforcing that we’re working on this and using our own resources.

Tammy Glover Fowler
Compliance Officer
Convoso

…and…

From: Tammy Glover Fowler <tgloverfowler@convoso.com>
Sent: Wednesday, February 21, 2024 7:42 AM
To: David Frankel <dfrankel@zipdx.com>
Cc: Josh Stevens <jstevens@mslawgroup.com>; Meg Mananian <mmananian@convoso.com>; Tammy Glover Fowler <tgloverfowler@convoso.com>
Subject: Re: Seeking Convoso’s Help with Relentless Calling

David,

In my haste and with the distraction of a family matter here at my home, I accidentally included you on the email recommending that we do not develop an ongoing relationship with you. Please do not be offended by this.

We intend to resolve this using our own resources. Respectfully, we do not intend to develop a working relationship with a vendor on this matter.

We appreciate your data and will use it accordingly. Again, I did not intend to include you in the email.

Thank you.

Tammy Glover Fowler
Compliance Officer
Convoso

From: David Frankel <dfrankel@zipdx.com>
Date: Wednesday, February 21, 2024 at 10:30 AM
To: ‘Tammy Glover Fowler’ <tgloverfowler@convoso.com>
Cc: Josh Stevens <jstevens@mslawgroup.com>, ‘Meg Mananian’ <mmananian@convoso.com>
Subject: RE: Seeking Convoso’s Help with Relentless Calling

Tammy,

My singular objective is getting these non-compliant calls to cease. As I told you before, you can use whatever resources and tools you want.

And you are correct – you probably do not want to go down the rabbit hole that DMS Group followed – a year-long dialog that parallelled their relentless calling. If you haven’t already seen it, look here: https://legalcallsonly.org/robocall-radar/#relentless for links to my correspondence with them, as well as my initial commentary about Convoso.

“We’re working on it” is something I have heard many times from non-compliant callers and their enablers. It conveys no sense of urgency and I take it as a brush-off. Since you know you are doing something improper, you should CEASE CALLING until you correct the defects in your process. At this point, you are certainly ON NOTICE that a significant number of your calls do not follow the regulations.

At no expense, you can get access to RRAPTOR summary information that will show you in real-time how many Convoso-signed calls I am receiving. So far today (since midnight UTC), I’ve gotten 280 calls from 264 different ANIs. 277 of those calls are to numbers on the Federal DNC list. Just ask and I’ll give you a RRAPTOR log-in. (Our paid service gives you more call details and I appreciate that you don’t see a need for that.) What’s the downside, other than you’d then have to admit that you have visibility to more data about your calling? It seems that ignoring the data is burying your head in the sand.

I know you’re anxious for a “final comment” but as long as you continue to barrage me with calls, you shouldn’t be surprised to hear from me. I’m happy to work with you cooperatively, but I’m not happy to continue to get your calls. I am not seeking to be your vendor. Please tell me how I can be more constructive.

David Frankel

From: Josh Stevens <jstevens@mslawgroup.com>
Sent: Wednesday, February 21, 2024 10:58 AM
To: David Frankel <dfrankel@zipdx.com>; ‘Tammy Glover Fowler’ <tgloverfowler@convoso.com>
Cc: ‘Meg Mananian’ <mmananian@convoso.com>; Michele Shuster <mshuster@mslawgroup.com>
Subject: Re: Seeking Convoso’s Help with Relentless Calling

Hi David,

Thank you for reaching out about these concerning calls. Convoso provides a cloud-based communications platform that is used by businesses to call and text with consumers. Convoso does not initiate calls itself.

Although Convoso is not interested at this time in obtaining the RRAPTOR services, it takes your concerns seriously and has initiated an internal investigation to determine whether the calls were initiated using the Convoso platform and, if validated, to take steps to address them in accordance with its robocall mitigation plan.

If you have any additional questions or concerns, please feel free to reach out to Michele Shuster (cc’d) and/or myself. Additionally, Michele and I are interested in whether the RRAPTOR service is available for law firm use. Perhaps we can have that discussion in a separate thread.

Thank you,

Josh

Josh Stevens | CECP | CIPP/US
Partner | Mac Murray & Shuster LLP
4555 Lake Forest Drive, Suite 650, Cincinnati, Ohio 45242
P: 513.563.3020  D: 614.289.5698  M: 606.620.6651
jstevens@mslawgroup.com | mslawgroup.com

Thanks Josh – I’m of course anxious to hear what the investigation reveals.

I am quite certain that the calls were initiated via Convoso – each one is signed with Convoso’s SHAKEN certificate, which is cryptographically protected by public/private key infrastructure. Only if Convoso’s private key were compromised would it be possible to successfully forge Convoso’s signature.

David Frankel