On TV, they’re called crossover episodes – where fictional characters from different shows appear on the same program. A case just filed by the FTC against KFJ Marketing and related parties brings together two aspects of FTC law enforcement – illegal robocalls and questionable lead generation practices – “co-starring” in the same production.

It started with prerecorded calls to consumers telling them that “This is an urgent call about your energy bill” and “Stop the 14% increase coming soon.” Consumers were told to “push 1” to lower their electric bill. If they responded, they were connected to a telemarketer, who asked about their interest in solar panels. If the consumer said yes, the telemarketer scheduled an appointment with a private solar installation company and sold the consumer’s information to that company as a customer lead.

How does the FTC allege the defendants’ course of conduct violates the Telemarketing Sales Rule? Let us count the ways.

First, the complaint charges that the defendants placed calls – 1.3 million of them – to numbers on the Do Not Call Registry.

Second, the FTC says the defendants violated the entity-specific provisions of Do Not Call. In other words, they continued to call consumers who had said “Enough already!” and had already told them they didn’t want to get further calls from (or on behalf of) that company.

Third, the defendants are charged with spoofing their caller ID information – transmitting phony information so consumers couldn’t tell the true source of the call.

Fourth, the FTC alleges the defendants made (or caused others to make) illegal robocalls. As the TSR establishes, it’s illegal to place prerecorded sales call to people unless you have their express agreement in writing authorizing you to robocall them.

The complaint names KFJ Marketing, Sunlight Solar Leads, LLC, Go Green Education, and Francisco Salvat. The case is pending in federal court in California.

Wondering to do when you get annoying (and illegal) robocalls? Here’s a new FTC video with some tips.