Offshore Outsourcing & Scammer
Blog about offshore outsourcing and scammer in the outsourcing industry
Scammer from U.S. - Mel Puleo - cmpuleoconsulting.com
by Rudolf Faix Saturday, March 12, 2016 5:16 AM

C.M. PuleoAs more a scammer is in need of earning some money as more unbelievable are coming their offers. One of this scammers is Mel Puleo from cmpuleoconsulting.com. Everybody should know that the margin in the electronics industry are very tight. As more vendors are coming up on the market as lower coming the average prices and margins. That happens in each industry and not only in the electronics and solar industry.

Some background information about prices and margins are getting found by a Google search. For example is written at CleanTechnica from February 2014:

However, prices vary tremendously by region. “Common residential system prices ranged from less than $3.00/W to just above $7.00/W,” the Solar Energy Industries Association wrote in 2014 regarding 2013 figures. The story hasn’t changed much since then, even though prices on both ends have come down.

Woodlawn Associates shows the possible margins a little bit better in their article The Economics of Residential Solar Installation:

The average dealer in our most recent project had revenue of $4.60 per Watt DC ($5.54 per Watt AC) over the past 12 months. The typical dealer had a cost to install of $3.71 per Watt — 80% of revenue. Earlier this year, we found dealers spend an average of 17% of revenue to acquire customers. This leaves only 3% for general and administrative expenses and profit, suggesting typical installer profits are slim. Consider that over the past year Real Goods Solar, the only publically traded firm in the residential installation industry, had G&A expenses alone that averaged 6% of revenue. (Real Goods also lost money during this period.)

The above example shows that not more than 15% - 17% from the complete costs of a solar system can get used for acquiring customers. Don't forget that the costs from Mel Puleo and her C.M. Puleo Consulting company are already included in these costs as he is nothing else running than a consulting company and the trading company makes already no earnings by paying these commission rates. Who will work for free?

By observing the facts from above you need to take a look at the spam offer from Mel Puleo - C.M. Puleo Consulting:

From: Mel Puleo, Solar [mailto:mel@cmpuleoconsulting.com]
Sent: Friday, March 11, 2016 7:33 PM
Subject: Re: Highest Payout for Solar campaign up to 7K/sale

To whom it may concern:

Our company is seeking experienced Telemarketing center in sales. The solar energy industry is growing rapidly in CA and we are building our sales team to meet the demand.

Compensation for each sale can range from $4K to $10K and beyond.

This is the most competitive Compensation in the industry bar none.

$500.00 commission is paid upfront the following week on every sale, the rest gets paid out on install [30/35 days out from the date of sale]

Our Floor commissions include “NO Adders”, this means you keep 100% of your earned compensation, no other Company offers this, and can typically eat away at your overall commission by 30 to 60%.

We will only entertain nothing less than 10 agents to start.

If you're 100% confident, you have killer closers & you feel that your center has what it takes to close over the phone, we have the best trainer in the industry “BAR NONE” that will walk you by the hand until you can fly on your own.

We are also looking for Appointment Setters, call for comp plan.

Feel free to contact us via skype or thru the phone listed below.

I hope to hear from you soon.

Thank you.
--

Best Regards,

Mel Puleo

President

C.M. Puleo Consulting

Contact #: (305)-527-8085

mel@cmpuleoconsulting.com

skype: carmine-puleo

The scam gets already shown in the above sentence "Compensation for each sale can range from $4K to $10K and beyond", because a typical solar energy installation for house has less than 5kW and has a usually price range of less than US$ 20,000. If we calculate from this price the maximum from 17% total paid commission than we get including the earnings from C.M. Puleo Consulting only US$ 3,400 and not US$ 4,000 like written in the email offer for the center.

If we take a look at the site Recruiter about the average income from a solar sales representative, than we'll find there the following statement:

A Solar Sales Representative or Assessor gets a compensation ranging between 64000 and 96000 depending on experience and domain knowledge. Solar Sales Representatives and Assessors earn a compensation of Eighty Four Thousand Four Hundred dollars each year.

An average income from US$ 84,400 per year equals to US$ 7,033 per month. Such a sales person needs only to sell two solar systems per month to be a profit for his company if the commission for each sale is US$ 4,000.

As the salary from the sales representative cannot get replaced with telemarketing agents how many sales such a sales representative needs to make per day that the telemarketer and the sales representative are able to earn their income?

Don't forget that from the before calculated total possible commission of US$ 3,400 per sale has to get paid the telemarketer, the sales representative and C. M.Puleo Consulting Company. I hope everybody sees now the scam in the offer above.

Real companies are going offshore for increasing their earnings by lowering their cost per sale and not to spend more. Especially in the technical industry are the margins very tight and each company tries to reduce their own costs. For this reason is already the offer from C.M. Puleo nothing else than a big lie. Under these circumstances are coming the complaints about C.M. Puleo Consulting believable which get found at:

A few from the complains listed above got written by the same person, but that does not make them unbelievable. Combined with the other complaints they are making sense. Especially the Ripoff Report from August 2, 2012 where Mel Puleo complains David Hjorth shows the fails and/or scam history from Mel Puleo:

All the above facts are showing what C. M. Puleo is understanding under business: Having an idea and the earnings, others should risk their hard earned money, doing the work and cry for their earnings because they will not get paid and the investment will never returned. I call such a behavior scam.

The domain registration data of cmpuleoconsulting.com:

Domain Name: cmpuleoconsulting.com
Registry Domain ID: 1777649011_DOMAIN_COM-VRSN
Registrar WHOIS Server: whois.networksolutions.com
Registrar URL: http://www.networksolutions.com/en_US/
Updated Date: 2016-01-29T00:48:49Z
Creation Date: 2013-02-01T04:45:09Z
Registrar Registration Expiration Date: 2017-02-01T04:45:09Z
Registrar: NETWORK SOLUTIONS, LLC.
Registrar IANA ID: 2
Registrar Abuse Contact Email: abuse@web.com
Registrar Abuse Contact Phone: +1.8003337680
Reseller: 
Domain Status: clientTransferProhibited http://icann.org/epp#clientTransferProhibited
Registry Registrant ID:
Registrant Name: Carmelo Puleo
Registrant Organization: C.M. Puleo Consulting LLC
Registrant Street: 3551 NE 169 St Condo 402A 
Registrant City: North Miami Beach
Registrant State/Province: FL
Registrant Postal Code: 33160
Registrant Country: US
Registrant Phone: +1.3055278085
Registrant Phone Ext.:
Registrant Fax: 
Registrant Fax Ext.:
Registrant Email: melpoint83@gmail.com
Registry Admin ID:
Admin Name: Carmelo Puleo
Admin Organization: C.M. Puleo Consulting LLC
Admin Street: 3551 NE 169 St Condo 402A 
Admin City: North Miami Beach
Admin State/Province: FL
Admin Postal Code: 33160
Admin Country: US
Admin Phone: +1.3055278085
Admin Phone Ext.:
Admin Fax: 
Admin Fax Ext.:
Admin Email: melpoint83@gmail.com
Registry Tech ID:
Tech Name: Carmelo Puleo
Tech Organization: C.M. Puleo Consulting LLC
Tech Street: 3551 NE 169 St Condo 402A 
Tech City: North Miami Beach
Tech State/Province: FL
Tech Postal Code: 33160
Tech Country: US
Tech Phone: +1.3055278085
Tech Phone Ext.:
Tech Fax: 
Tech Fax Ext.:
Tech Email: melpoint83@gmail.com
Name Server: ns14.wixdns.net
Name Server: ns15.wixdns.net
DNSSEC: Unsigned
URL of the ICANN WHOIS Data Problem Reporting System: http://wdprs.internic.net/ 
>>> Last update of WHOIS database: 2016-01-29T00:48:49Z <<<

Update March 12, 2016: A Mel from using the IP address from Costa Rica 190.108.73.13 sent the following message using the contact function of my blog:

Remove this immediately!! or my lawyer will be contacting you on monday morning!!! This is ridicules!!!! My wife and I work ungodly hrs, and for someone who clearly has just way to-much time on their hands to sit behind a PC and make up all this bullshit is beyond what words can describe! I need to know who was the person who placed this as we will spare no expense to go after them legally!!


http://blog.wwpa.com/post/2016/03/12/scammer-from-u-s-mel-puleo-cmpuleoconsulting-com.aspx

 

Author information

Name: Mel
E-mail: melp82@gmail.com
IP address: 190.108.73.13
User-agent: Mozilla/5.0 (Macintosh; Intel Mac OS X 10_9_5) AppleWebKit/601.4.4 (KHTML, like Gecko) Version/9.0.3 Safari/537.86.4

Already the content of the message shows the character from the person. Instead of explaining where I'm wrong with my opinion, he is threatens only with legal action. The only problem is that he needs to show some evidence in front of the law court. He should also read the full legal disclaimer from this site for knowing my address too. He will need it for selecting the court and in front of the court.

 

Scam free campaigns - only 3 brokers got found during the last year
by Rudolf Faix Friday, March 11, 2016 8:14 AM

Not one outsourcing client takes the risk for searching and hiring a call center broker or consultant from abroad. If an outsourcing company is searching abroad then they are searching for a call center directly, which is able to run their campaign, have a high success rate and not for a man in the middle who only likes to earn money by an easy way. A real client goes offshore for saving money and not for entertaining man in the middle, scammers or brokers from low wage countries. If a client hires a broker than he hire one, which is for him all the time reachable to complain, hit and bite him for the case something is running wrong with his campaign.

Brokers and consultants are getting paid from the outsourcing client and not from the center. They are responsible for running the outsourced campaign successful as they have selected the center for the clients campaign. For these reason they are even not allowed to take some money from the centers - it could be construed as a bribe. Offering and taking bribes is in the civilized world a crime and the fines are high. Depending on the case both, the one who is offering and the one who is accepting bribes, can even end up in jail.

Not one broker or consultant allows other brokers, consultants or "middle men" of any kind redistributing their campaigns unless otherwise approved by themselves. Not one reputable businessman charges any start up or up-front fees what so ever to launch their campaign. Real campaign brokers required to make their contracts directly with the call center and call center owner and that they have direct access to the sales floor, managers and agents when requested. They also insist that the call center receives and keeps 100% of the commissions. No payment should ever be given to a third party by the contracted center.

99.99% of the outsourcing offers found in the social networks are nothing else than scam. These scams have already destroyed the main part of the offshore outsourcing industry as even outsourcing clients got scammed, leads and data got sold many times. For these reasons the data protection law got raised during the last 10 until 15 years. Until now are trying my special friends, the scammers, offering impossible and invented campaigns against a huge invention fee. Everywhere, where you get asked to pay something - however the fee gets called - you'll get only scammed. Real clients are not taking money from the centers and they are able to pay their hired staff. The scammers are only confirming their scam with their "consultancy fee", "security deposit", "royalty" or however the fee gets called. These fees are nothing else than inventions from the scammers, which are too lazy doing a normal work.

Since more than one year I'm active warning from the scammers found at the social networks. During this time I have only found three real campaign brokers, which I list here. Please don't waste your and their time by asking them for any non-voice campaigns, like form fillings, inbound campaigns etc. Such campaigns are only existing in the dreams from the scammers. Remember all data are protected by law and not one company has their data on paper or need to convert them manually. Already the question for such campaigns is disqualifying yourself, because it shows that you have no idea from call center work, law in the different countries and you are for this reason not a trustful partner for any outsourcing client.

Scam free call center campaigns are available from:

  • Deep Blue MarketingDeep Blue Markteting
    Deep Blue Marketing (DBM) is a BPO promoting organization from the capital of Denmark, Copenhagen with area in Spain, Madrid and roots in the Dominican Rep and US where the greater part of our customers are from. DBM has a high effectiveness rate with regards to finding suitable call communities for practical crusades around the world, other than can make quick results for any item that is perfect in the call focus industry, not just that we just work with leaders which makes the outcomes everybody is searching for.

  • Ian HainesIan Haines Consulting
    Ian Haines Consulting is the lead accomplice for a Telemarketing Business Consultancy situated in the South West of England. Ian Haines Consulting is had practical experience in three principle zones - Call Center Broking Services, abnormal state Business Development Services and Call Center CS and Sales Process Consultancy.
    Ian Haines Consulting is included in the UK telebusiness industry since the early 1990's and worked for various division driving call focus outsourcers for the most part in senior business improvement and operational parts. They work with little to medium estimated outsource call focus organizations both in the UK and in South Africa and the Philippines.

  • Kathy Sisk Enterprises Inc.Kathy Sisk Enterprises
    Kathy Sisk Enterprises Inc. is viewed as one of the quickest developing preparing, counseling and adjusting firms in the call focus industry. With their differences, it would take a few organizations to match every one of our abilities when counseling, preparing, and adjusting your inbound and outbound call focus needs.

 

Advance Billing, Advance Payment and Payout US$ 10/Agent/Hour
by Rudolf Faix Wednesday, January 13, 2016 10:11 AM

Don't worry! We're from the InternetSounds good? Does it not sound too good to be true? Think about it. The center owner needs only to pay the travel costs of the trainer!

You are right. Sure, it is a plain advance fee scam. It is the newest idea from the well-known scammer Christine Wisner. Scam reports about Christine Wisner are getting already found at:

Let us take first a look at the terms the scammers are using for their unbelievable offers:

  • Advance Billing
    A billing is every time in advance and does not include an "advance payment". Nobody will pay before he gets a bill. For this reason is a bill nothing else than a simple form without any value if the bill does not get accepted from the recipient. You don't have any guarantee that the bill will get paid.

    Let us take an example: Even the supermarket cashier makes your bill in advance, before he receives the payment. At this time the supermarket cashier even does not know if you are able to pay the sum. That is called "advance billing". The only difference between the scam offers from the social networks and the supermarket is that the customer has to pay the bill before leaving with the purchased goods the supermarket.

  • Advance Payment
    Let me use the same supermarket example for the "Advance payment". If you enter the supermarket and before you take the shopping cart you have to pay the goods which you like to buy. Afterwards you collect your merchandise and go to the cashier again. The cashier will check if you have not taken more than you have paid in advance. For the case you have taken more than you have paid you need to pay the difference. You'll get some money back for the case you did not find all the goods you liked to buy.

    Would you choose such a supermarket for your daily needs? If your answer is no then ask yourself why someone should be someone so stupid and pay you before you did the work? Do you really think that others are silly? A successful business owner does not give you money as a gift. He is only successful because he knows his business and is not irrational acting.

Only scammers are writing such offers into the social networks and are hoping to find a senseless person which is paying their advance fee (however they are calling it - security deposit, consultancy fee, VoIP costs, etc.):

PRE-PAYMENT ON THE FIRST DAY OF GOING LIVE.
CONTRACT TIME : 1 YEAR
CLIENT CAN STOP THE PROCESS WITH OUT ANY NOTICE DURING THE FIRST 15 DAYS TRIAL PERIOD
AFTER FIRST 15 DAYS IT WILL BE A 1 YEAR CONTRACT.
MAN POWER : 30 AGENTS, 3 TEAM LEADER , 2 QUALITY HEAD.
AFTER 15 DAYS OF TRIAL , IT WILL BE MONTHLY PRE-PAYED BILLING CYCLE.
CLIENT MUST BE GIVEN FULL DAILER ACCESS
** NO CALLS MUST BE EDITED
** PAPER WORKS AND DOCUMENTATION WILL BE DONE IN PERSON BETWEEN STARTEC TELICOM AND THE CONTACT CENTRE.

Startec Telecom, full name Startec Global Communications Corp, shares are getting traded at the NASDAQ. At their NASDAQ profile is written:

STARTEC is a rapidly growing, facilities-based international long distance carrier which markets its services to select ethnic U.S. residential communities that have significant international long distance usage. Additionally, to maximize the efficiency of its network

At Startec's company profile is written:

Building on that tradition, Startec is dedicated to being the leading provider of communication services to communities around the globe. Startec services connect worldwide communities spanning the Pacific Rim, Middle East, North Africa, Russia, Central Europe, and North and South America. We provide our services through a flexible network of owned and leased facilities, operating and termination agreements, and resale arrangements. Startec technology assets include an extensive network of IP gateways, international gateways, domestic switches and ownership in undersea fiber optic cables.

Does anybody believe that such a company hires a broker or consultant from Kolkota, India which is a well-known scammer?

Does anyone believe that such a company like Startec Global Telecom is sending a trainer on the costs of the call center from Hongkong to an unknown call center placed in the area of Hyderabad, India?

Such a business behavior would destroy the reputation of a company. The share values of Startec Global Telecom would in such a case go down to the area of the penny stocks and the responsible person would get fired.

Such a company knows how to hire staff, freelancers and subcontractors. If such a company hires someone than the hired one would get paid from them and not opposite round. As such a company is dealing with VoIP they would even make the recordings by themselves and you would even not have the chance to manipulate or edit them. For this reason and the reasons found above is the offer nothing else than a scam.

This scam gets initiated from Christine Wisner and afterwards she changes her identity to Joslyn March and uses the Skype ID joslyn.paul103. At this profile is written that she is from Toronto, Canada. She likes to get a flight ticket from Hongkong to your place while she is chatting from Kolkota, India. Here is her Skype profile:

Skype profile of the scammer Joslyn March - joslyn.paul103

The picture in the above profile got stolen from a photo model and should hide her real nationality.

By searching at Google for the exact phrase "client can stop the process with out any notice during the first 15 days trial period" I found another offer at the already well-known scammer platform SaveBpo.com:

The complete offer of the "US INBOUND CUSTOMER CARE SERVICE WITH VERY GOOD PAYOUT" campaign (.pdf) is the following:

CAMPAIGN : CUSTOMER CARE SERVICE
PAYOUT : $10 / Hour / AGENT
TIMING : 24 X 7
NUMBER OF AGENTS : 10 agents 24 x 7
ADVANCE BILLING : 15 DAYS PRE-PAYMENT ON THE FIRST DAY OF GOING LIVE.
CONTRACT TIME : 1 YEAR
TRAINING : PROVIDED BY CLIENT ( 5 DAYS ). UNPAID TRAINING
PROCESS DETAILS : CUSTOMER CARE SERVICE. INBOUND CALLS AND EMAIL.
CENTRE MUST COVER THE EXPENSE FOR CLIENTS CENTRE VISIT
CLIENT CAN STOP THE PROCESS WITH OUT ANY NOTICE DURING THE FIRST 15 DAYS TRIAL PERIOD
AFTER FIRST 15 DAYS IT WILL BE A 1 YEAR CONTRACT.
MAN POWER : 30 AGENTS, 3 TEAM LEADER , 2 QUALITY HEAD.
AFTER 15 DAYS OF TRIAL , IT WILL BE MONTHLY PRE-PAYED BILLING CYCLE.
CLIENT MUST BE GIVEN FULL DAILER ACCESS
** NO CALLS MUST BE EDIATED
** PAPER WORKS AND DOCUMENTATION WILL BE DONE IN PERSON BETWEEN xxxxxxxxxx AND THE CONTACT CENTRE.
COMMERCIAL PART IS INVOLVED PLEASE FEEL FREE TO CONTACT ME

Here gets even offered $10 per hour per agent for a not existing campaign. Which support can get given to the caller if the agent cannot get access to the customer database? Remember that AT&T had to pay a fine of US$ 25,000,000 for copied/stolen customer data during an outsourcing process. Why shall one company take the risk to get fined like AT&T?

The next question is why a company likes to outsource some telemarketing campaigns offshore? The answer is very simple, they like to save money by taking advantage of a lower wage in the offshore country. If we take a look at the average payment for telemarketers in the USA then the offered payment is the same like in the USA. By taking a look at PayScale Telemarketer Salary for the United States, than we see that the average salary is $10.07 and the minimum is $7.86 (data from September 2015):

PayScale Telemarketer Salary for the United States - September 2015

By looking at the data above, we see that telemarketers can get hired for less than $8 per hour. So why should hire a company from the U.S. a broker or consultant from India and offer a higher payment for the telemarketers. A company from the United States can hire and fire in the U.S. telemarketers for less and how they need them. Even the fee for the man-in-the-middle, the useless broker or consultant from India, can get saved in such a case.

Additional gets the same campaign under the tite "US Telecom Customer Service Inbound Only One Slot Available" (.pdf) found at the scammer platform BPO Project World from India. At this site shows the scammer how urgent he needs already money, because he writes that only one slot is remaining on this not existing campaign. Additional have even 12 amateur or "like to be" call centers asked for more information.

Update Jan. 18, 2017: Links to http://www.bpoprojectworld.in/us-telecom-customer-service-inbound-only-one-slot-available/ and http://www.savebpo.com/project/us-inbound-customer-care-service-good-payout/ removed as they are already returning error 404 - not found.

 

The Marketing Source - Robbie Middleton - sent a bad joke instead of a proof
by Rudolf Faix Monday, September 7, 2015 1:57 AM

In each of the articles about the Caribbean Cruise Line (CCL) – Virtual Voice Technology (VVT) is getting found that the center is guilty by themselves if they are accepting the conditions from The Marketing Source. Business is a risk and not a sandpit where nothing can happen. Even in the email from Robbie Middleton is stated gets found that this campaign “is a VERY tough campaign with tight margins”.

The campaign gets offered as none voice campaign where the agent does not need to speak. That is nothing else than a misleading promotion, because if we take a look at the article “FTC Statement Virtual Voice Technology - CallAssistant, L.C. - submitted by The Marketing Source - Vance Vogel” then we can read that the agent is free in his choice to speak or playing prerecorded messages. The background of the FTC-rule is that it has to be a life agent to be available that the live agent has to speak with the called one if a recording is not available for answering a specific question. It will be seldom happen, but it can happen.

The statement that only Lars is offering the CCL campaign is not correct. Robbie Middleton has simple forgotten that he is offering the campaign at BPO Friends by himself too. Everybody can be sure that other companies have voice systems too, which are conform to the FTC rules.  TMS is not the only company, which has access to such a system. It is only used as an argument for their rip-off. US$ 200/week system costs + VoIP (up to $ 275) for 12 seats (24 connections) are nothing else than profiteering.

We have built for an Austrian satellite TV broadcaster a similar system with click to dial, manual selection of prerecordings and a few more features like play and win, live quiz, dating, shopping, etc. in a multi-language system (German, English, French, Spanish, Polnish), for € 1,450 (~US$ 1,615) including server hardware. This system has assigned 2,200 phone numbers, on this system are working 250 agents and a few full automated services like every 50th caller goes live into the studio, each 100th caller is winning a price, etc. at the same time.

It is not forbidden to make a bad deal. Everybody, who accepting a bad deal, is guilty by himself if he lose money in such a case. It is only from a company expected to recognize a good and a bad deal. If a company defends such a bad deal then such a company is in my opinion very suspect and there seems to be a reason why they are defending such a bad deal. Mostly is the reason that they are earning by themselves.

The construction of the included proof from the email shows more that it is a fake instead of a proof.  I think that CCL and TMS have enough experience in front of the law court collected to know how a proof has to look like. In this case the proof consists of pictures (one company header, and one picture for each “invoice” line), which seems to be from different sources. Such a construction is nowhere accepted as a proof for anything. All necessary parts for an official invoice are missing. It seems even to be a secret to whom the invoice got sent.

In a fair and transparent business is it usage that as soon as a customer likes to use his own or rented systems has the customer to pay the bill for it. How the customer makes his calculation in this case is the problem of the customer and not the problem of the service provider. Already the promotion of the campaign is misleading because there is written “The base rate is $ 2.25 per transfer with additional performance incentives based on quality” (BPO Friends - Robbie Middleton, .pdf (187.38 kb)). In such a case the rate cannot be lower than $ 2.25 for the >60 seconds transfer, but if we take a look at the document VVT CPD Explanation.docx (17.84 kb) we see that the base rate can be lower too.

The email from Robbie Middleton in reaction to my article "Slavery offer: CCL VVT none Voice or Semi-Voice campaign - The Marketing Source - Vance Vogel":

On Fri, Sep 4, 2015 at 6:05 PM, Robbie Middleton <rmiddleton@themarketingsource.com> wrote:

Rudolph,

What your source neglected to tell you is that there is a list of requirements VVT sends centers at the time of campaign implementation and VVT makes NO claims that this is an easy campaign at any time.  VVT does not even recruit centers at all.  Every center VVt have has either approached VVT via word of mouth or through Lars.  Lars is the ONLY approved broker for the VVT campaign.  VVT actually tell the centers that this is a VERY tough campaign with tight margins and very clearly state all charges.  99% of all center that fail, do so because they do not follow our guidelines.  It is absolutely, positively cheaper and easier to dial using the centers own VOIP and dialer, unfortunately this is ILLEGAL per the TCPA laws as well as infractions of the Telemarketing Sales Rule that would undoubtedly occur if the call centers were not regulated.    TMS and/or VVT receives no profit Login and VOIP charges.  I have copied the most recent invoice for logins associated with 4 centers Lars has referred and feel free to confirm the same with the company that invoices us as well as Lars.  This is the actual amount deducted from the centers commissions and not a penny more.  You can see that VVT IS CHARGED $10/login.  VVT pre-pays this expense on behalf of the centers so they do not have any up-front expense of their own.  VVT provides Leads, VOIP and Logins so they can LAUNCH without investing ANY of their own money.    VVT then deducts this Login and VOIP expense from the centers earned commissions.  There is no charge for leads.  We disperse the amount VVT loads each for VOIP each week evenly amongst all centers based on their percentage of total logins.  We do not profit from this expense either.  Regarding “CPD” and what your source failed to tell you is that VVT is paid by the cruise line on a CPD (Cost Per Deal) basis.  Each centers quality is tracked separately and a quantitative measure of quality is attached to their transfers in terms of “CPD”.  We cannot let centers send calls “at will” with no concern for quality as many of them (even with the CPD +/- structure in place) send calls with no customer on the line, transfer answering machines, transfer customers that requested DNC, etc….. I will send you the complete VVT launch e-mail just as I would a prospective center so you can see the truth.  The fact that VVT must implement so many rules and guidelines is indeed most unfortunate, but don’t let your source fool you into thinking we are “screwing” them.  Rules and guidelines are in place to adhere to all applicable laws and to protect VVT from unethical centers.  We have centers that have been doing the campaign for more than 3 years now and while it isn’t easy, it CAN be profitable when guidelines are adhered to. 

The above email had the following five pictures included as shown belown: 

Invoice header of SunBridge Systems
One line of the invoice from Sunbridge Systems
Another line of the invoice from Sunbridge Systems
Another line of the invoice from Sunbridge Systems
Another line of the invoice from Sunbridge Systems

The invoice header seems to be a fake because I did not find until now one IT company frome the U.S.

  • where the office phone number is hidden for privacy reasons from the public phone directory

  • where the office phone number is assigned to Google voice

  • where tel2name.com gives the result: 727-753-9323 - Deane Arteaga Wisteria Cir New Port Richey, Florida instead of Sun Bridge Systems LLC.

  • which writes their own domain name in the heaer of the invoice wrong
    (subbridgesystems.com instead of sunbridgesystems.com)

  • which needs to hide the ownership of their domain behind a privacy service

  • which makes since 2 years and 5 months promotions at her homepage for their registrar Godaddy

  • which has since 2 years and 5 months a homepage with the amazing content
    Screenshot from the homepage of sunbridgesystems.com

  • Buzzfile.com says about SUN BRIDGE SYSTEMS LLC:
    Sun Bridge Systems is located in Oldsmar, Florida. This organization primarily operates in the Business Services, nec business / industry within the Business Services sector. This organization has been operating for approximately 2 years. Sun Bridge Systems is estimated to generate $ 49,000 in annual revenues, and employs approximately 1 people at this single location.

SUN BRIDGE SYSTEMS, LLC is really a company and is listed at Floridas Department of State Division of Corporations (.pdf (119.20 kb)). The company got founded on March 11, 2013 at 5520 Rio Vista Dr., Clearwater, FL. 33760 (Link, .pdf (43.19 kb)) and relocated on April 1, 2014 to 518 Lakewood Dr., Oldsmar, FL 34677 (Link, .pdf (3.30 kb)).

Interesting is that LookUpBear (.pdf (118.69 kb)) tell us that the company SUN BRIDGE SYSTEMS, LLC is listed "under the heading Construction/Contractors which includes businesses that may offer home improvement construction, home construction, roofers, manufacturing of building materials". I know that we all would search for a telcommunications company in exactly this category!

Screenshot from the entry Sun Bridge Systems, LLC from LookUpBear

Update Jan. 18, 2017: Link to http://bpofriends.com/profiles/blogs/vvt-free-cruise-non-voice-process removed as it already returns error 404 - not found.

FTC Statement Virtual Voice Technology - CallAssistant - from Vance Vogel
by Rudolf Faix Saturday, September 5, 2015 2:32 AM

Mr. Vance Vogel, CEO and founder of The Marketing Source, has submitted together with an explanation that they are using CallAssistant instead of Avatar systems, the following statement of the FTC from September 11, 2009 (I have only removed the page breaks):

UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
WASHINGTON, D.C. 20580
Federal Trade Commission
Division of Marketing Practices
September 11, 2009

Dear Mr. Bills:

You have requested an informal staff opinion as to the applicability to 2008 amendments to the Telemarketing Sales Rule (“TSR”) to a particular technology used by CallAssistant, L.C.(“CallAssistant”). The amendments at issue impose new restrictions on the use of prerecorded messages in telemarketing. 16 C.F.R. § 310.4(b)(1)(v); 73 Fed. Reg. 15204 (Aug. 29, 2008).

Specifically, these amendments require, as of December 1, 2008, that any outbound telemarketing call that delivers a prerecorded message include: (1) if the call could be answered in person by a consumer, an automated interactive voice and/or keypress-activated opt-out mechanism that the call recipient can use at any time during the message to assert a Do Not Call request pursuant to § 310.4(b)(1)(iii)(A); and (2) if the call could be answered by an answering machine or voicemail service, a toll-free telephone number that the call recipient can use to assert a Do Not Call request pursuant to § 310.4(b)(1)(iii)(A). Additionally, as of September 1, 2009, the amendments prohibit any outbound telemarketing call that delivers a prerecorded message unless the seller has obtained from the recipient of the call an express agreement, in writing, that evidences the willingness of the recipient of the call to receive calls that deliver prerecorded messages by or on behalf of that seller and includes such person’s telephone number and signature.

As described in your letter, CallAssistant uses technology that enables its calling agents to interact with the recipient of a call using his or her own voice or by substituting appropriate audio recording of a response. According to your letter, when used to place outbound telemarketing calls, this technology works as follows:

A live agent using the System places a call to a consumer and hears the consumer greeting. In response to the greeting, the agent may elect to speak to the call recipient using his or her voice, or may press a button to play an appropriate recorded script segment. After the agent’s response, the agent listens to the consumer customer’s reply. After listening to the consumer’s reply, the live agent again chooses whether to speak to the call recipient in his or her own voice, or another recording. At all times, even during the playing of any recorded segment, the agent retains the power to interrupt any recorded message to listen to the consumer and respond appropriately.

In adopting the 2008 amendments, the Commission 1 recognized that in the future prerecorded message might eliminate the objections that prompted the adoption of the these rules and justify exemptions permitting interactive prerecorded messages:

[T]he Commission notes that it is aware that the technology used in making prerecorded messages interactive is rapidly evolving, and that affordable technological advances may eventually permit the widespread use of interactive messages that are essentially indistinguishable from conversing with a human being. Accordingly, nothing in this notice should be interpreted to foreclose the possibility of petitions seeking further amendment of the TSR or exemption from the provisions adopted here.

73 Fed. Reg. 51180 (Aug. 29, 2008).

Furthermore, according to your description, “live agents hear every word spoken by the call recipient, and determine what is said” in response. A single agent always stays with a call from beginning to end.

You seek an opinion as to whether the amended TSR provisions on the use of prerecorded messages in telemarketing apply to CallAssistant’s calls that employ the technology summarized above. Based on the description of the technology included in your letter, the staff of the Federal Trade Commission has concluded that the 2008 TSR amendments cited above do not prohibit telemarketing calls using this technology if the calls that otherwise comply with the TSR and other applicable law. The 2008 amendments at 16 C.F.R. § 310.4(b)(1)(v) prohibit calls that deliver a prerecorded message and do not allow interaction with call recipients in a manner virtually indistinguishable from calls conducted by live operators. Unlike the technology that you describe, the delivery of prerecorded messages in such calls does not involve a live agent who controls the content and continuity of what is said to respond to concerns, questions, comments – or demands – of the call recipient.

In adopting the 2008 TSR amendments, the Commission noted that the intrusion of a telemarketing call on a consumer’s right to privacy “may be exacerbated immeasurably when there is no human being on the other end of the line.” 73 Fed. Reg. at 51180. The Commission observed that special restrictions on prerecorded telemarketing messages were warranted because they “convert the telephone from an instrument for two-way conversations into a oneway device for transmitting advertisements.” Id.1 Consequently, in Staff’s view, the concerns about prerecorded messages addressed in the 2008 TSR amendments do not apply to the calls described above, in which a live human being continuously interacts with the recipient of a call in a two-way conversation, but is permitted to respond by selecting recorded statements.

Nevertheless, the use of such technology in a campaign to induce the sales of goods or services, or charitable donations is “telemarketing” under the Telemarketing and Consumer Fraud and Abuse Prevention Act, 15 U.S.C. § 6106(4), and therefore must comply with the Rule’s other requirements and prohibitions. In particular, the technology must connect an outbound telephone call to a live agent within two seconds of the call recipient’s completed greeting. 16 C.F.R. § 310.4(b)(1)(iv). The agents making calls using this technology must disclose the purpose of the call, the identity of the seller, make other required disclosures, and comply with other TSR provisions preventing deceptive and abusive conduct. Id. §§ 310.3 and 310.4.

Please be advised that this opinion is based exclusively on all the information furnished in your request. This opinion applies only to the extent that actual company practices conform to the material submitted for review. Please be advised further that the views expressed in this letter are those of the FTC staff. They have not been reviewed, approved, or adopted by the Commission, and they are not binding upon the Commission. However, they do reflect the opinions of the staff members charged with enforcement of the TSR.

Lois Greisman
Associate Director
Division of Marketing Practices

 In short - the system Virtual Voice Technology is only legal if:

  • a live agent hears the called party from the greeting until the hang-up or transfer.
  • an agent is active in the line within 2 seconds the called party has finished his greeting.
  • the live agent is free in his choice to speak with the called party or playing prerecorded messages.
  • if the live agent is playing prerecorded messages he needs to have a possibility to stop the playback.
  • the Telemarketing Sales Rules (TSR) does not get changed.

 

Filter by APML

Follow me

AboutMe

I'm since more then 35 years in the computer business (programming and technical support) and using the Internet since it has started. Since 2002 I'm programming solutions for Asterisk and since 2004 I'm in the call center industry.

Disclaimer

All data and information provided on this site is for informational purposes only. I make no representations as to accuracy, completeness, currentness, suitability, or validity of any information on this site and will not be liable for any errors, omissions, or delays in this information or any losses, injuries, or damages arising from its display or use. All information is provided on an as-is basis and is only representing my own opinion. By browsing or using content from this site you accept the full legal disclaimer of this website.