July 1, 2021 Administrative Guidance to YUNO Co., Ltd. on Improper Solicitations without Specifying the Purpose of Soliciting MVNO Services

Improper solicitations were confirmed in the business activities of YUNO Co., Ltd. (headed by HAMADA Naoto, CEO), a telecommunications carrier that provides a mobile virtual network operator (MVNO) service named No Mobile with a stationary router used. The company solicited the MVNO service that uses a stationary router without specifying the purpose of the solicitations, calling up consumers and telling them fictitious reasons, e.g., the calls are for fixed-line telephone services provided by a major telecommunications carrier or for the confirmation of usage status.
From the above, YUNO Co., Ltd. was found in violation of Article 27-2, Paragraph 2 of the Telecommunications Business Act (Act No. 86 of 1984), which prohibits solicitations without notifying the purpose of the solicitations, and in other violation of the provisions of the Telecommunications Business Act. Accordingly, the Ministry of Internal Affairs and Communications (MIC) has instructed YUNO Co., Ltd. to comply with the Telecommunications Business Act thoroughly.

1. Outline of the case and content of administrative guidance

1. MIC and other ministerial agencies concerned received many complaints about No Mobile, a mobile virtual network operator (MVNO) service (hereafter referred to as the “Service”) provided by YUNO Co., Ltd. (hereafter referred to as “YUNO”) for consumers with a stationary router used. Among them, many improper cases were pointed out. For example, YUNO introduced itself as a major telecommunications carrier or the carrier’s sales agent without specifying the purpose of the solicitations and made people misunderstand that they were being solicited by the major telecommunications carrier or its agent.

2. In response to the above complaint consultations, MIC requested the submission of a recording of the telephone solicitations made by YUNO, where inappropriate solicitations were found as shown in the attached PDF.

3. From the recording, MIC confirmed YUNO’s violations of Article 26, Paragraph 1 (the obligation to explain the terms and conditions for the provision of services) of the Telecommunications Business Act (hereafter referred to as the “Act”), Article 27-2, Paragraph 1 (the prohibition of misrepresentation) and Paragraph 1 (the prohibition of solicitation without notifying the fact of solicitation) of the Act.

4. From the above circumstances, MIC has instructed YUNO to ensure thorough compliance with the Act.

2．About the solicitations made by YUNO

MIC grasped YUNO’s specific solicitation method; YUNO called users of optical lines provided by a major telecommunications carrier and had them cancel their optical line contracts and revert to the previous analog line contracts. Then YUNO had the users conclude contracts for YUNO’s MVNO service named No Mobile with a stationary router used as an alternative to the optical line contracts. This solicitation method was remarkably like a method confirmed when MIC announced the administrative guidance of December 28, 2020.

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  MIC’s press release of December 28, 2020