Ahead of the New Hampshire presidential primary, Steve Kramer and three corporations orchestrated and distributed a recorded message via robocalls to thousands of New Hampshire voters. The message used artificial intelligence to mimic President Biden’s voice, telling voters not to vote in the primary election. Further, the robocalls displayed a false caller ID number associated with a prominent figure in the state’s Democratic party.

On March 14, 2024, the League of Women Voters of the United States (LWV-US), the League of Women Voters of New Hampshire (LWV-NH), and several individual New Hampshire voters filed a lawsuit in the U.S. District Court of New Hampshire against Steve Kramer, Lingo Telecom, and Life Corporation, who, together, delivered the robocalls. On May 28, 2024, the plaintiffs filed an amended complaint which added Voice Broadcasting Corporation as a defendant. LWV-NH, LWV-US, and the individual voters seek to stop the defendants from using robocalls and AI technology to intimidate, threaten, coerce, or deceive voters.

Free Speech For People and Akin Gump Strauss Hauer & Feld LLP represent the plaintiffs, along with local counsel Preti, Flaherty, Beliveau, & Pachios, Chartered, LLP.

Key Facts

Caption League of Women Voters of New Hampshire v. Kramer
Court US District Court of New Hampshire
Docket No.
24 1:24-cv-00073
Status Default Judgment entered against Steve Kramer; case settled against remaining defendants.
Plaintiffs League of Women Voters of New Hampshire, League of Women Voters of the United States, and NH Voters
Defendants Steve Kramer, Lingo Telecom, LLC, Life Corporation, and Voice Broadcasting Corporation.

 

Background

Three days before the New Hampshire presidential primary, Steve Kramer paid to create a recorded message using artificial intelligence to mimic President Biden’s voice. Posing as President Biden, the messages falsely implied that voters could not vote in both the primary and general elections and urged voters to “save” their vote for November. Lingo Telecom and Life Corporation then distributed the message via robocalls to thousands of New Hampshire voters without disclosing the source of the calls. The calls “spoofed” a phone number associated with a former chair of the New Hampshire Democratic Party and included her personal cell number in the message itself. 

On March 14, 2024, the League of Women Voters of the United States (LWV-US), the League of Women Voters of New Hampshire (LWV-NH), and several individual New Hampshire voters filed a lawsuit in the U.S. District Court of New Hampshire against Steve Kramer, Lingo Telecom and Life Corporation. Plaintiffs later amended the complaint to include a third corporate defendant, Voice Broadcasting Corporation.  

The lawsuit argues that the robocalls violated federal and state laws that protect voters from intimidation, threats, coercion, and deception: 

  • the Voting Rights Act, which bans intimidating, threatening, or coercing, or attempting to intimidate, threaten or coerce, any person from voting; 
  • the Telephone Consumer Protection Act, which prohibits the distribution of unwanted and deceptive robocalls; 
  • and provisions of New Hampshire state law, which prohibit the distribution of political messages via robocalls without disclosing the source of the calls or that deceive call recipients 

LWV-NH, LWV-US, and the individual voters seek to stop the defendants from using robocalls and AI technology to intimidate, threaten, coerce, or deceive voters. Plaintiffs have asked for a preliminary injunction, which would block the defendants from orchestrating or disseminating illegal political robocalls prior to the 2024 general election. 

Two of the corporate defendants filed a motion to dismiss, which the court denied in March 2025. Plaintiffs resolved their claims against all three corporate defendants via two settlement agreements.   

After Mr. Kramer refused to respond to the complaint or otherwise participate in the lawsuit, the court entered Mr. Kramer’s default. On November 20, the court issued Default Judgment against Mr. Kramer, finding in the plaintiffs favor on all four counts of the amended complaint, awarding financial damages to the individual voter plaintiffs, and permanently enjoining Mr. Kramer from carrying out similar schemes in the future. The injunction specifically blocks Mr. Kramer from “orchestrating a deceptive and coercive robocall campaign or scheme that attempts to or does intimidate, threaten, or coerce lawfully registered voters to cause them to be fearful or reluctant to exercise their right to vote in any election in the United States.” 

Free Speech For People are co-counsel on this lawsuit with Akin Gump Strauss Hauer & Feld LLP and local counsel Preti, Flaherty, Beliveau, & Pachios, Chartered, LLP. 

Read the press release

Read the complaint

Major Developments and Documents

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