“The Federal Trade Commission published a biennial report to Congress focusing on the use of the Do Not Call Registry by both consumers and businesses over the past two years. The report also highlights how the FTC is responding to new technologies that have increased the number of illegal robocalls made to telephone numbers on the Do Not Call Registry. As of September 2013, more than 223 million active numbers were registered for Do Not Call, an increase of more than 5.8 million registrations from the previous fiscal year. The Biennial Report to Congress Under the Do Not Call Registry Fee Extension Act of 2007 notes the FTC recently launched a mobile-friendly way for consumers to sign up for Do Not Call and register Do Not Call complaints, and that the agency received 27 percent of its registrations from mobile devices. During fiscal year 2013, a total of 2,875 businesses and other entities paid more than $14 million to access the Do Not Call Registry. Another 27,626 entities were provided access, but are exempt from paying fees (because they access five or fewer area codes free of charge or are a charity). The report notes that voice over internet protocol (VoIP), caller ID spoofing, and automated dialing technology have made it easier for individuals and companies who disregard the law to make high volumes of calls at very little cost. This led to an increase in illegal robocalls, which peaked at approximately 200,000 complaints to the FTC per month at the end of fiscal year 2012.”