Global Billing Solutions (Case reference: 28902)
| Case Number | 28902 |
| Year | 2013 |
| Published date | 21 August 2013 |
| Adjudicated Party | Global Billing Solutions |
| Procedure Type | Emergency Procedure (Phone-Paid Services Authority) |
Code Compliance Panel
Tribunal Decision
47
Tribunal Sitting Number 131 / Case 3
Case Reference: 28902
Level 2 provider
Global Billing Solutions
Type of Service
Competition - non-scratchcard
Level 1 provider
mBlox Limited
Network operator
All Mobile Network operators
THIS CASE WAS BROUGHT AGAINST THE LEVEL 2 PROVIDER UNDER PARAGRAPH 4.5
OF THE CODE
BACKGROUND
The Level 2 provider, Global Billing Solutions operated an online subscription mobile content and
competition quiz service using the brand name “Ringaling” (the “Service
”).The Service operated
on the premium rate shortcode 80160 at a cost of £4.50 per week and was promoted via affiliate
marketeing. The Level 1 provider for the Service was mBlox Limited.
The Service offered consumers the opportunity to access the Services’ mobile website and view
daily feeds on celebrity gossip, jokes, horoscopes and amusing
videos. Consumers were also
offered
the opportunity to participate in a competition to win a prize, such as Apple products. The
competition period was from 1 July 2012 to 31 October 2013.
The Service operated from September 2012 to 9 July 2013.
Serious concerns regarding the promotion of the Service were uncovered as a result of in-
house
monitoring of the Service conducted by the PhonepayPlus Research and Market Intelligence
Team (the “RMIT
”). The monitoring revealed that affiliate marketing, which generated consumer
traffic to the Service
, appeared to utilise a form of malware (ransomware) that stopped
consumers’ internet browsers working, resulting in users being unable to access a large number
of popular websites, including Facebook, Ebay, Google. Users were told that they were required
to sign up to the Service (and/or other premium rate services) in order to unblock their browsers.
Monitoring
On 28 June 2013, the RMIT visited the website “wifihackpassword.com” (Appendix A
), which
offered users software that purported to enable them to hack into locked Wi-
Fi networks. The
RMIT clicked on a button marked “Download Now!” which resulted in the software being
downloaded. The RMIT opened the file. Instantly a dialogue box appeared and offered a
seemingly essential update which the RMIT decli
ned. A further dialogue box appeared that
stated:
“Error! Too old version! Update please!”. The only option was to click “OK”.
The RMIT noted
from previous monitoring experiences that accepting the upgrade led to a
premium rate service and upon opting-in to the subscription a password,
which had no function
and which did not allow an upgrade to take place, was provided.
The RMIT’s internet browser was
blocked by the malware and was not unblocked following entry into the service.
The RMIT conducted an additional monitoring session on 2 July 2013. The RMIT opened the
Code Compliance Panel
Tribunal Decision
48
Internet Explorer browser and found it could not access the Google homepage as it was still
blocked from the previous monitoring session (Appendix B
). The browser displayed a webpage
that contained a warning that stated:
“This website has been blocked for you! Steps to access this website again. 1. Click the unlock
button below. 2. Pick survey to verify that you are human. 3. Complete Survey. 4. Continue
using this website.
“This website
has been blocked because of your recent activity. Your actions have been
marked as a spam bot like. To visit this website again follow the instructions on the left [see
numbered point above]. This is made for security reasons.
“Information about you:
Country name: UK
City:
IP: [IP address redacted]
“Click here to unblock.”
In exactly the same manner as in
the previous monitoring sessions, the RMIT clicked on the
“Click here to unlock” button, a further pop-up appeared which stated (Appendix C):
“WARNIN
G! The content you are browsing is blocked! You must complete at least one offer to
have access to this page.”
The RMIT selected an option that stated, “Chance to win the All New iPhone 5”.
The RMIT was
directed to one of the Level 2 provider’s promotional landing pages
which opened in a new
browser window.
The RMIT followed the instructions contained on the landing page and answered one
multiple
choice question. The RMIT were directed to enter its MSISDN and click “Submit” (Appendix D)
.
The next screen prompted the RMIT to send the keyword “WEB” to the shortcode 80160
to opt in
to the Service (Appendix E)
. The RMIT monitoring phone received a free text message, again
prompting the RMIT to send the trigger keyword to the premium rate shortcode. Upon doing
this,
the RMIT received subscription confirmation text
messages that confirmed the RMIT had
succ
essfully opted into the Service and this was also confirmed on the monitoring computer
screen.
A notification tab at the bottom of the page indicated a file d
ownload was complete but upon
clicking on it, the RMIT found the file was password protected and there was no information on
where the password could be found. The RMIT noted that the download appeared to have
no
purpose or function.
The RMIT eventually c
losed all the browser windows that had been opened during the monitoring
session and opened a new Internet Explorer window. The browser displayed the same webpage
notifying the browser was blocked (Appendix B).
The RMIT selected the “unblock” button and was led back to the “WARNING!” pop-
up page that
directed the user to complete an “offer” to unblock the browser (Appendix C
). The RMIT selected
the “offer” titled “Your Chance to Win the New iPad Mini” and was directed to one of the
Level 2
provider’s landing pages. The RMIT completed one multiple choice question
and was then
prompted to enter its MSISDN and click “Submit” (Appendix F). The RMIT followed the instructed
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