On-line "fraudsters" have added another weapon to their arsenal. At first, when the "Reshipper Scam" debuted, unsuspecting e-commerce businesses were receiving fraudulent orders via email. As e-commerce began to recognize the "fraudsters'" on-line signature, the respective e-businesses implemented changes to thwart the on-line criminal element.

The "fraudsters" have responded in-kind by taking advantage of the Telecommunications Relay Services (TRS). Under Title IV of the Americans with Disabilities Act (ADA), all telephone companies must provide free relay services. At first, the TRS was utilized by the traditional text telephones. However, with the advent of the personal computer and the Internet, TRS users are now able to utilize the Internet to complete an Internet Protocol (IP) Relay. By using the IP-Relay, anyone throughout the world who has a computer and Internet access can connect to a relay operator (a communication assistant CA) and place a free telephone call, to include the international market.

Recently the Internet Crime Complaint Center (IC3) has seen a dramatic increase in the number of complaints from on-line businesses, who have been victimized by the perpetrators' inappropriate use of the IP-Relay to facilitate their criminal activity.