Robocall Mitigation Program


Volli Communications Inc Responding to Second Report and Order, FCC 20-136, at 18, para. 38 with Robocall Mitigation Plan described herein under Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence Act, Pub. L. No. 116-105 (2019) (TRACED Act) and Call Authentication Trust Anchor, WC Docket No. 17-97, Second Report and Order, FCC 20-136, at 18, para. 38 (Sept. 29, 2020) (Second STIR/SHAKEN Order).

Volli Communications Inc is employing Extension of implementation deadline. Qualifying for an extension under § 64.6304 - Extension of implementation deadline.

(a) Small voice service providers. (1) Small voice service providers are exempt from the requirements of § 64.6301 through June 30, 2023.

(2) For purposes of this paragraph (a), “small voice service provider” means a provider that has 100,000 or fewer voice service subscriber lines (counting the total of all business and residential fixed subscriber lines and mobile phones and aggregated over all of the provider's affiliates).

Business Name: Volli Communications Inc. (

Previous Business Name: Digital Telephone Alliance Inc.

Business Address: 790 Windmiller Dr., Pickerington, OH 43147

Other DBA Names: FortiCall Phone Service (, NetLines (, SIPMadeEasy (

Foreign Voice Service Provider: No

Implementation: No STIR/SHAKEN Implementation – Performing Robocall Mitigation

Intermediate Provider: No

Robocall Mitigation Contact Name: Michael L. Parmley

Contact Title: Director of Information Services

Contact Department: Engineering

Contact Business Address: 790 Windmiller Dr., Pickerington, OH 43147

Contact Email:

Contact Telephone Number: 614-300-2973

Robocall Mitigation Program:

  1. Traceback Cooperation. Volli Communications Inc will fully participate in traceback requests. We have established as a contact email address for any traceback requests that will create a ticket with the highest priority requiring a response within one business hour. We keep Call Detail Records including the originating IP Address of all calls for a period of one calendar year.
  2. Subscriber vetting practices. Volli Communications verifies subscribers through credit card validation, address validation, email validation and website validation. Companies also must provide contact persons and a verifiable business name.
  3. Allowable outbound caller ID numbers are limited to numbers purchased through us from one of our carriers such as Verizon, Lumen/L{3}, Comwave or an aggregator named VoIP Innovations. Businesses may apply to have a limited number of other outbound caller ID numbers allowed only if they can prove via a phone bill or contract that those numbers are assigned to them and only after we have verified them via a callback.
  4. Robocall Calling Pattern detection. Volli Communications analyzes and reports unusual traffic by any subscriber every hour, comparing such things as outbound call volume, short duration call percentage, calls that receive SIP Code 403 percentage, calls that receive SIP Code 607/608 percentage and total percentage of SIP Code 200s. Each variable will trigger an urgent ticket to for immediate investigation and possible suspension as follows:
    1. If the percentage of short duration calls (calls less than 6 seconds) exceeds more than 20% and over 120 calls in any one-hour period.
    2. If the percentage of SIP 200 calls (Call completions) is below 50 percent and over 120 calls in any one hour period.
    3. If the combined percentage of SIP Code 403, 607 and 608 exceeds 20 percent and over 120 calls in any one-hour period.
    4. If the total number of outbound calls increases by over 100% and over 120 calls in any one-hour period as compared to the same day of week and hour of day for that same customer established previously.
  5. Volli Communication Inc is currently entertaining offers from TransNexus and NeuStar to provide us with STIR/SHAKEN Certificates and is planning upon implementing one of those solutions within the current calendar year.
  6. Volli Communication Inc has already purchased and installed the STIR/SHAKEN module for OpenSIPS version 3.1 and is in the process of conducting testing of the implementation.