Robocall Mitigation Plan for Zoto Dialer
Website: www.zotodialer.com
Company: Zoto Dialer, LLC
Date: July 14th, 2025
Version: 1.0
1. Overview
Zoto Dialer is committed to preventing the origination, transmission, and termination of illegal robocalls on its platform. This Robocall Mitigation Plan outlines the policies, technical safeguards, and monitoring processes we employ to ensure that all traffic originating from our system complies with applicable federal and state regulations, including the TRACED Act and the FCC’s Robocall Mitigation Database requirements.
2. Call Authentication (STIR/SHAKEN)

• Zoto Dialer uses interconnected VoIP systems that support SIP-based traffic.

• We are actively working with upstream providers who are STIR/SHAKEN compliant and support authenticated call delivery.

• For calls that cannot be authenticated via STIR/SHAKEN (e.g., TDM or legacy interconnects), we implement alternate mitigation measures.

3. Robocall Mitigation Measures
Zoto Dialer employs a layered approach to mitigate illegal robocalls:

• Know Your Customer (KYC):
  All clients must submit verified business identification and pass KYC verification, including EIN and legal documentation.

• Traffic Monitoring and Analytics:
  Our systems continuously analyze call patterns and volume spikes to detect suspicious behavior (e.g., high calls-per-minute, short-duration calls, unusual routing behavior).

• Blacklist/Spam List Integration:
  We utilize multiple real-time databases and blacklists (e.g., Hiya, Nomorobo, TNS Call Guardian) to prevent known bad actors from accessing our system.

• Pre-Call Validation:
  Calls are screened before transmission for improper caller ID formatting, non-working DIDs, and known scam number patterns.

• Outbound Dialing Controls:

  • Call-per-second (CPS) throttling

  • Maximum concurrent call limits

  • Time-of-day restrictions

  • List scrubbing tools to avoid DNC (Do Not Call) violations

• Customer Education and Enforcement:
  All customers are provided onboarding materials and compliance guidelines. Violations of our terms of service (e.g., engaging in illegal robocalling) result in immediate suspension and investigation.

4. Complaint Handling and Traceback

• Zoto Dialer cooperates fully with the Industry Traceback Group (ITG) and law enforcement agencies.

• Complaints or traceback requests are responded to within 24 hours.

• A dedicated compliance team investigates all flagged activity and takes remedial actions, including call block, customer warnings, or account termination.

5. Point of Contact
Robocall Mitigation Compliance Officer
Name: Aidan Sowa
Email: compliance@zotodialer.com
6. Certification Statement
We certify that Zoto Dialer takes reasonable steps to ensure that our platform does not originate illegal robocalls. We will maintain this mitigation plan and update it regularly as required by the FCC.