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8547, 8547 n.2 (1997) ("Show Cause Order") (provided as Attachment A). We note that there are  yOv-  Nseveral companies currently incorporated under the name "Long Distance Services, Inc." This order,   however, in addition to the companies named in the above caption, concerns only that "Long Distance   jServices, Inc." that was incorporated in the Commonwealth of Virginia on January 10, 1994, under the name  yO!-  "Long Distance Services, Inc.," and whose executive officer and/or registered agent is Daniel Fletcher. We   also note that there appear to be a number of names under which Long Distance Services, Inc. marketed   its services, such as "Long Distance Services of Virginia," "Charity Long Distance," and "Church Long  {O&$-Distance." See id. at 8547 n.1. (# because they have repeatedly "slammed"   b yO-  .ԍXxSlamming occurs when a company changes a consumer's primary interexchange carrier ("PIC") from his/her presubscribed carrier to another company without the consumer's knowledge and authorization. (# " P 0*''JJ"  xlong distance telephone subscribers and committed numerous other violations of the Communications Act  S- xof 1934, as amended ("the Act") and our rules.LE yO`-ԍxSee infra paras. 27.L Commission staff has determined that each of the  S- xMcompanies, all apparently owned and operated by Daniel Fletcher,AxE yO-  ԍXxDaniel Fletcher appears to be the principal owner and operator of each of the Fletcher Companies. Other   individuals who appear to be connected with the Fletcher Companies in some capacity as either principals  yOX -  or officers are Robert Motter and Sandra Platt. See Show Cause Order, 12 FCC Rcd at 8548 n.3 & 8555,   ?para. 11 (stating that Daniel Fletcher appears to be the "common thread" among all of the entities described herein).(#A ceased providing common carrier  xservices in 1997 while the Commission staff was engaged in a massive investigation into their slamming  S`- xpractices.X`( E yO(-  kԍXxSeveral states also instituted enforcement actions against the Fletcher Companies contemporaneous with  yO-  Lthe Commission's investigation. See Show Cause Order, 12 FCC Rcd at 8548 nn.45 (discussing enforcement actions in Alabama, New York, Louisiana, South Carolina and Virginia). (#ƃ We take this revocation action today to ensure that none of the companies can resume common  xcarrier operations and once again engage in slamming or other conduct that is harmful to consumers. As  xan additional measure, because the principals of these companies have ignored or evaded numerous  xrequests by the Commission that they appear before the Commission and provide some explanation for  xtheir actions, we enjoin Daniel Fletcher and all other principals associated with the Fletcher Companies  xfrom providing any telephone services in the future without the prior consent and authorization of the  Sp- xCommission..xpH E yOX-  ԍXxWe emphasize that the Fletcher Companies includes any successors or assigns of the entities identified  yO -  kabove. See supra note 1. Therefore, we not only order the Fletcher Companies to cease and desist from   Many future provision of interstate common carrier services without the prior consent of the Commission,   but also order any successor or assign of the Fletcher Companies and any other company that the   kprincipal and or principals of the Fletcher Companies have established or seek to establish to cease and   desist from any future provision of interstate common carrier services without the prior consent of the Commission.(#. In this order, we also assess forfeitures against the Fletcher Companies and their principals  xthat total $5,681,500. We also deny the petition to intervene and motion to enlarge the issues of Atlas Communications, Ltd. and Billing Concepts, Inc.  S -T  S -II. BACKGROUND ĐTP  S - ` x2. ` ` The Fletcher Companies are interexchange carriers ("IXCs") that currently provide, or have  xprovided, resale interstate long distance telecommunications services to consumers in various states  S0- xthroughout the country as well as limited international service.0E yOX$-ԍXxThe Fletcher Companies operate as common carriers subject to Title II of the Act.(#Ɗ On June 13, 1997, the Commission"00*%%JJ"  S- xMreleased its Order to Show Cause and Notice of Opportunity for Hearing, FCC 97210 ("Show Cause  S- xOrder")pE yOB-ԍXxShow Cause Order, 12 FCC Rcd at 8547.(#p in this proceeding. The Show Cause OrderĠordered the Fletcher Companies to show cause why  xthe operating authority of the Fletcher Companies should not be revoked and whether the principal or  xprincipals of the Fletcher Companies and the Fletcher Companies should not be ordered to cease and desist  xfrom any future provision   of interstate common carrier services without the prior consent of the  S<- xCommission. The facts and circumstances leading to the issuance of the Show Cause Order are recited  S- xtherein and need not be reiterated at length.F XE yO -ԍXxSee id.(#F The Commission adopted the Show Cause Order in response  x=to over 1400 complaints, beginning in 1993, with the majority of the complaints from mid1996 through  S- x!1997, alleging, inter alia, that certain of the Fletcher Companies had changed consumers' primary  xinterexchange carriers ("PICs") from their presubscribed carriers to one of the Fletcher Companies without  Sz- xthe consumers' knowledge and authorization.q XzE yO-  ԍXxGenerally, when a consumer elects to subscribe to an IXC, that IXC notifies the consumer's local exchange   carrier ("LEC") of the consumer's decision. Thereafter, the LEC routes the consumer's long distance calls to the chosen IXC and takes other steps to effect the PIC change. (#q The Commission has long prohibited slamming and has  SR - xpromulgated rules and issued orders to protect consumers from this practice. R E yO-  kԍXxSee 47 C.F.R.  64.1100, 64.1150; Implementation of the Subscriber Carrier Selection Changes Provisions   of the Telecommunications Act of 1996 and Policies and Rules Concerning Unauthorized Changes of  yO-  Consumers' Long Distance Carriers, CC Docket No. 94-129, Further Notice of Proposed Rule Making and  yOR-  >Memorandum Opinion and Order on Reconsideration, 12 FCC Rcd 10,674 (1997) (1997 FNPRM & Order on  yO-  Recon.); Policies and Rules Concerning Unauthorized Changes of Consumers' Long Distance Carriers, 10 FCC  yO-  MRcd 9560 (1995) (LOA Order), stayed in part, 11 FCC Rcd 856 (1995) (In-bound Stay Order); Policies and  yO-  {Rules Concerning Changing Long Distance Carriers, 7 FCC Rcd 1038 (1992) (PIC Change Order), recon.  yOr-  denied, 8 FCC Rcd 3215 (1993); Investigation of Access and Divestiture Related Tariffs, 101 FCC 2d 911  yO:-  (1985) (Allocation Order), Investigation of Access and Divestiture Related Tariffs, 101 FCC 2d 935 (Com. Car.  yO-  =Bur. 1985) (Waiver Order), recon. (of both Allocation Order and Waiver Order) denied, 102 FCC 2d 503 (1985)  yO-(Reconsideration Order). See infra para. 6. (# The Commission's PIC xchange rules and orders require, among other things, that IXCs obtain signed letters of agency ("LOAs")  xor, in the case of telemarketing solicitations, complete one of four telemarketing verification procedures  S -before submitting PICchange requests to LECs on behalf of consumers.t hE yO-ԍxSee PIC Change Order, 7 FCC Rcd at 103839.t   S - ` x3.` ` Most of the complaints detail the Fletcher Companies' use of misleading, and in some  xcases fraudulent, marketing practices to effect the unauthorized PIC changes, including submitting,  xdirectly or through marketing agents, forged or falsified letters of agency ("LOAs") to the local exchange  xcarriers responsible for effecting the PIC changes. Some complaints further alleged that some of the  S- xFletcher Companies billed them for long distance calls that they did not place, or assessed monthly fees" 0*%%JJ"  S-for services without their knowledge or authorization.o i yOh-ԍx See Show Cause Order, 12 FCC Rcd at 8552, para. 7.o  S- ` @x4. ` ` Under the Commission's rules for resolving consumer complaints,bXi yO-ԍXxSee 47 C.F.R.  1.7161.718.(#b the Common Carrier  xBureau's Enforcement Division ("Enforcement Division") forwarded each consumer complaint filed against@  xthe Fletcher Companies to the appropriate company with the requisite Official Notice of Informal  S8- xComplaint ("Official Notice").8i yO -  zԍXxUpon receipt of a consumer complaint, the Enforcement Division routinely issues an Official Notice to all   carriers identified in the complaint or that may, in the staff's view, assist in the resolution of the   .complaint. The Official Notice requires the common carrier to satisfy or answer the complaint and respond   to the Commission's Official Notice with a written report, a copy of which must be sent directly to the   >complainant. The Official Notice also outlines specific consequences of failing to respond to an informal  yO -  kcomplaint. SeeĠSections 1.7161.718 of the Commission's rules, 47 C.F.R.  1.7161.718. Because none   of the Fletcher Companies had filed with the Secretary of the Commission the name of a designated agent   for service of Official Notices as required by Section 413 of the Act, the Commission served the Official   !Notices on business addresses gleaned from, among other things, inquiries made to LECs and to the Fletcher Companies' billing agents.(# The Fletcher Companies failed to respond to the vast majority of the  xOfficial Notices issued by the staff. In the few instances when the Fletcher Companies filed responses  xzto the Commission's Official Notices, the responses were poorly prepared, failed either to satisfy the  S- xcomplaints within the meaning of Section 208 of the Act  i yO-  ԍXxThe Commission has established rules and procedures that enable consumers to bring to the Commission's   kattention allegations of misconduct by carriers and to obtain relief from rates and practices found to be  yOp-  unlawful or otherwise contrary to the public interest. See 47 U.S.C.  208; see also 47 C.F.R.  1.7161.718. (# and Section 1.717 of our rules or to explain  S- x/the Fletcher Companies' refusal or inability to do so,hi yO-ԍx47 C.F.R.  1.717. Section 1.717 provides in pertinent part:  ` XxX` ` [T]he Commission will forward informal complaints to the appropriate carrier  ` 7for investigation. The carrier will, within such time as may be prescribed,  ` advise the Commission in writing, with a copy to the complainant, of its satisfaction of the complaint or its refusal or inability to do so ....x`  and otherwise fell far short of the information  xkrequired by the staff to further investigate the complaints and make determinations about the carriers'  SH - xcompliance with the Act and our rules and orders.qH i yO -ԍXxSee Show Cause Order, 12 FCC Rcd at 8553, para. 9.(#q The responses merely contained what amount to  xvague denials of the complainants' allegations and conveyed virtually no specific information about the  S -carriers' practices or any facts and circumstances pertaining to the complainants allegations.> pi yO$-ԍxSee id.> " 0*%%JJ "Ԍ S- ` x5. ` ` Furthermore, beginning in June 1996, a number of Official Notices issued by the staff to  xthe Fletcher Companies concerning consumer complaints were returned to the Commission by the U.S.  S- xPostal Service marked "unclaimed," "moved," or "refused."fi yO-ԍXxSee id. at 8554, para. 10 & n.24.(#f Thereafter, the staff attempted repeatedly  S- xMand unsuccessfully to contact representatives of the Fletcher Companies by telephone and by mail. Xi yO-  ԍXxOn August 20, 1996, an individual identifying himself as "Dan Fletcher," apparently aware of the staff's   repeated efforts to contact him and his companies regarding the unresolved consumer complaints, left   /a voice mail message on the telephone line of an Enforcement Division staff member. In that message,   the caller represented that all Official Notices concerning complaints filed against the Fletcher Companies   should be mailed to the following address: Long Distance Services, 2117 L Street, N.W., No. 293, Washington,   D.C., 20037, which was subsequently identified as a mail drop location, "Mailboxes, Etc." To date, neither   the Fletcher Companies nor Mr. Fletcher himself have responded to any of these Official Notices either in  yO -  kwriting or by telephone. Representatives of Mailboxes, Etc. reported that the individuals who leased the   {mail drop on behalf of Long Distance Services failed to pay the requisite fees, and that consequently,   kMailboxes, Etc. is no longer accepting mail on behalf of Long Distance Services. The Commission further   enlisted the assistance of Dun & Bradstreet, a corporation that provides businesstobusiness information   Nand services for marketing and commercial credit and collection and maintains a business database   covering 41 million companies worldwide. Based on information obtained from staff investigations and the   Dun & Bradstreet reports, the Commission learned that all of the addresses listed in the Dun & Bradstreet   reports for the Fletcher Companies were mail drop locations rather than business locations maintained  yO8-or operated by the Fletcher Companies. See id. at 855456, paras. 1012.(#  xBased on staff investigations, the staff subsequently obtained a new address for service of Official Notices  xfiled against Phone Calls, Inc. and Monthly Phone Services, Inc. The staff mailed Official Notices relating  xto approximately 500 informal complaints to this address. The majority of these Official Notices were  xMreturned to the Commission marked either "moved, left no address" or "return to sender not at this address."  Sp- ` x6. ` ` Based on the information described above, and set forth in greater specificity in the Show  SJ - xCause Order, the Commission found that the Fletcher Companies apparently were either unwilling or  xunable to conduct lawful common carrier operations even within the broad parameters established by  S - xthe Act and rules and orders governing nondominant carriers.Y i yO<-ԍXxSee id. at 8558, para. 17.(#Y As the Commission pointed out in the  S - xShow Cause Order, many of the consumer complaints involved allegations that one or more of the  xFletcher Companies changed consumers' PICs without their authorization, in violation of the Commission's  xyslamming rules and orders. We have previously found the practice of slamming through the use of forged  xor falsified LOAs to be a particularly egregious violation of our rules because such practices undermine  xthe competitive nature of the interexchange marketplace and deprive consumers of their right to select the  S-services of particular interexchange carriers to satisfy their long distance service needs.0i yO"-  >ԍXxSee, e.g., LDS, Inc., Notice of Apparent Liability for Forfeiture, 12 FCC Rcd 14,105 (1996) (this "LDS, Inc." is not affiliated with Daniel Fletcher).(# x"0*%%JJ"Ԍ S- ` x7.` ` In the Show Cause Order, we expressed concern that the Fletcher Companies compounded  xjthe egregious nature of their slamming practices by failing to respond to or accept Official Notices issued  x by the staff in response to consumer complaints, and by failing to designate agents for the receipt of  xznotices, orders, or other correspondence issued by the Commission, as required by Section 413 of the  Sb- xAct.xbi yO-ԍXx47 U.S.C.  413. In pertinent part, Section 413 states:(#  ` pXxX` ` It shall be the duty of every common carrier subject to this Act to designate in writing  ` pan agent in the District of Columbia, upon whom service of all notices and process and  ` pall orders, decisions, and requirements of the Commission may be made for and on  ` pbehalf of said carrier in any proceeding or suit pending before the Commission, and to file such designation in the office of the secretary of the Commission . . . . ` ƈ Moreover, we stated that Daniel Fletcher and the Fletcher Companies apparently deliberately acted  xto frustrate the staff's efforts to investigate consumer complaints and to inquire into the Companies'  S-practices by failing to provide legitimate business addresses or telephone numbers. ri yO -ԍXxSee Show Cause Order, 12 FCC Rcd at 8559, para. 18.(#r  S-T  S-FIII. HEARING AND DISCUSSION ĐTP  Sr- ` x8. ` ` Based on the actions of the Fletcher Companies described above and further set forth in  SJ - xthe Show Cause Order, the Commission convened an evidentiary hearing to determine whether the  xoperating authority of the Fletcher Companies should be revoked and whether the Fletcher Companies  xand/or their principals should be ordered to cease and desist from any future provision of interstate  x\common carrier services without the prior consent of the Commission. Specifically, the Commission  xconvened a hearing to provide the Fletcher Companies and their principals an opportunity to demonstrate  xfacts and circumstances that might refute the Commission's findings that the Fletcher Companies and their  xMprincipals had committed numerous violations of the Act and the Commission's rules and that would  xjpersuade the Commission that the operating authority of the Fletcher Companies should not be revoked.  x\For example, the Commission sought to develop record evidence concerning the PIC changes made or  x{requested to be made by the Fletcher Companies. The Commission also sought to develop record  xevidence regarding Long Distance Services, Inc.'s, Phone Calls, Inc.'s., and Discount Calling Card, Inc.'s  xfailure to accept and/or respond to Official Notices, and the companies' inadequate responses to certain  x{Official Notices, as well as their failure to file with the Secretary of the Commission the name of a  SD- x\designated agent for service of all notices and process, orders, and requirements of the Commission.\Di yO|-ԍXxSee id. at 856061, para. 23.(#\  xFurthermore, the Commission sought to develop record evidence pertaining to Long Distance Services,  xInc.'s failure to file tariffs covering its interstate telecommunications service offerings during the period  S-from May 1, 1996 to present.F( i yO"-ԍXxSee id.(#F x  S|- ` x9. ` ` The Commission also sought to develop record evidence concerning the Fletcher  xCompanies' violations of one or more of the following provisions of the Communications Act of 1934,"T 0*%%JJ"  xas amended, and the Commission's rules: 47 U.S.C.  203(a), 208(a), 413, and 416(c) and 47 C.F.R.   S- x 1.717, 64.1100, and 64.1150.Fi yO@-ԍXxSee id.(#F The Commission further sought to determine whether the continued  x0operation of the Fletcher Companies as common carriers would serve the public convenience and  xnecessity, and whether the issuance of an order restraining the Fletcher Companies and their principals  S`-from future provision of interstate common carrier services would be in the public interest.D`Xi yOX-ԍxSee id.D x  S- ` x 10. ` ` Notwithstanding the Fletcher Companies' failure to designate an agent for the receipt of  x[notices, orders, or other correspondence issued by the Commission, and to file such designation with the  S- xCommission, in violation of Section 413 of the Act,i yOH -ԍXxSee 47 U.S.C.  413; see also supra para. 7 & note 24 (citing Section 413 of the Act).(#Ƥ the Commission made significant efforts to locate  x.the Fletcher Companies and their principals, including, but not limited to enlisting the assistance of Dun  x& Bradstreet and repeatedly attempting to contact representatives of the Fletcher Companies by telephone  SH - xand by mail.yH xi yO`-ԍXxSee Show Cause Order, 12 FCC Rcd at 855456, paras. 1012.(#y The Commission also mailed a copy of the Show Cause Order to the Fletcher Companies'  xylast known address. Despite these efforts, neither Daniel Fletcher nor any other representative of any of  xthe Fletcher Companies filed a written appearance stating that the Fletcher Companies' principals or other  S - xlegal representative would appear at the hearing and present evidence on the matters specified in the Show  S - xCause Order.  i yOT-  ԍXxThe failure of a principal, principals, or other legal representative to file a notice of appearance or to  yO-  appear at the hearing waives their right to a hearing. See 47 C.F.R.  1.92 (stating in pertinent part,   /"[a]fter issuance of an order to show cause . . . calling upon a person to appear at a hearing before the   Commission, the (1) fail[ure] to file a timely written appearance as prescribed in  1.91(c) indicating that   he will appear at a hearing and present evidence on the matters specified in the order" constitutes a waiver of such hearing).(# Moreover, neither Fletcher nor any of his representatives appeared at the prehearing held  xon July 15, 1997. Accordingly, by Order released July 17, 1997, Administrative Law Judge Joseph  S^- xChachkin terminated the proceeding and certified the case to the Commission,w!^ i yO~-ԍXxOrder, CC Docket No. 97144, FCC 97M125 (rel. July 17, 1997).(#w for the Commission to  xdetermine whether, on the basis of all available information, a revocation order and/or a cease and desist  S-order should issue.Z"i yO-ԍXxSee 47 C.F.R.  1.92(c).(#Z  S- ` x 11. ` ` Because neither Daniel Fletcher nor any other representative of the Fletcher Companies  S- x/filed a notice of appearance or appeared at the hearing, we deem each allegation set forth in the Show  Sp- x\Cause Order to be admitted.[#pi yO$-ԍXxSee 47 C.F.R.  1.724(d).(#[ Therefore, we find that the Fletcher Companies committed numerous"p0#0*%%JJ"  xviolations of both our rules and the Act, including, but not limited to submitting unauthorized PIC  xchanges; charging consumers for calls that they did not make; failing to file and maintain with the  xzCommission tariffs containing schedules of the charges, terms, and conditions of their common carrier  S- x[offerings in the manner prescribed by Section 203(a) of the Act and the Commission's rules and orders;$i yO-  ԍXxSection 10 of the 1996 Act provides the Commission with authority to forbear from applying the provisions   Mof Title II, including the tariffing provisions, subject to certain, limited exceptions. On October 31, 1996,  yO-  the Commission released the Tariff Forbearance Order, which adopted a complete detariffing policy for the   =domestic interstate, interexchange services of nondominant, interexchange carriers, pending a ninemonth  yO-  transition period. Policy and Rules Concerning the Interstate, Interexchange Marketplace, Implementation  yO-  zof Section 254(g) of the Communications Act of 1934, as amended, Second Report and Order, 11 FCC Rcd  yO -  120,730 (1996) (Tariff Forbearance Order), stayed sub nom. MCI Telecommunications Corp. v. FCC,  yOh -  Consolidated Cases 961459, 961477, 971009, Feb. 13, 1997; Order on Reconsideration, 12 FCC Rcd 15,014  yO0 -  (1997), further recon. pending. Because the alleged violations at issue in this proceeding predate the   Commission's adoption of a complete detariffing policy, the Fletcher Companies were responsible for filing tariffs for all their domestic interstate, interexchange services.(#  xfailing to file with the Secretary of the Commission the name of a designated agent for service of all  xnotices and process, orders, and requirements of the Commission pursuant to Section 413 of the Act; and  S- xMfailing to observe and comply with all Commission orders as required by Section 416(c) of the Act.P%X( i yO-  ԍXx47 U.S.C.  413; 416(c). Section 416(c) states that "[i]t shall be the duty of every person, its agents and   employees, and any receiver or trustee thereof, to observe and comply with such orders so long as the same shall remain in effect."(#P  xFurther, because the Fletcher companies have failed to follow corporate formalities, we find it appropriate to assess liability for the violations committed by the Fletcher companies against the company principals.  Sp- ` x 12. ` ` Because the Fletcher Companies are classified as nondominant interexchange carriers,z&pH i yOX-ԍXxSee Show Cause Order, 12 FCC Rcd at 854849, para. 2 & n.6.(#z  xtheir authority to provide domestic, interstate services was obtained automatically pursuant to Section  S - x63.07 of our rules.Q'X i yO-  ԍXxSee 47 C.F.R.  63.07(a), which states in pertinent part that "[a]ny party that would be a nondominant   domestic interstate communications common carrier is authorized to provide domestic, interstate services to any domestic point . . . ."(#Q As such, the Fletcher Companies are considered to have "blanket" authority to  S - x=operate domestic common carrier facilities within the meaning of Section 214 of the Act.)(  i yO-  MԍXxSee 47 U.S.C.  214; 47 C.F.R.  63.07;  see also Show Cause Order, 12 FCC Rcd 8549, para. 2 & n.7. This   "blanket" operating authority extends to the provision of both domestic and international common carrier   kservice. Therefore, we note that one of the Fletcher Companies, Phone Calls Inc., provided international service pursuant to its "blanket" operating authority under Section 214 of the Act. (#) Accordingly,  x0the Fletcher Companies could "construct, acquire, or operate" any transmission line for domestic  S - x\telecommunications service without obtaining prior written authorization from the Commission.G) i yO($-ԍXxSee id. (#G In  xaddition, Phone Calls, Inc., one of the Fletcher Companies, maintained an international Section 214" p)0*%%JJj"  S- xauthorization.h*i yOh-ԍxSee File No. ITC 96312, effective, Aug. 2, 1996.h Pursuant to our authority under Section 4(i) of the Act,Q+Xi yO-ԍXx47 U.S.C.  154(i). (#Q we hereby revoke the operating  xauthority of the Fletcher Companies because of the egregious actions and blatant violation of our rules and  S-the Act committed by the Fletcher Companies and the principal and/or their principals.A,Xi yO8-  ԍXxRevocation of the operating authority extends to the Fletcher Companies' provision of domestic   =interexchange service and Phone Calls, Inc.'s provision of international service pursuant to its international Section 214 authorization.(#A  S`- ` px 13. ` ` We hereby delegate to the Chief, Common Carrier Bureau, authority to issue orders  xrevoking a common carrier's operating authority pursuant to Section 214 of the Act, and to issue orders  xyto cease and desist such operations, in cases where the Chief Administrative Law Judge, or the Presiding  x.Officer designated, has issued a certification order to the Commission pursuant to Section 1.92(c) of our  S-rules that the carrier has waived its opportunity for hearing under that section.-xi yOh-  /ԍXxSee 47 U.S.C.  5(c); 47 C.F.R.  1.91(a). Section 1.92(a) provides that after the issuance of an order to   Mshow cause, pursuant to  1.91, that calls upon a person to appear at a hearing before the Commission,   the occurrence of any one of the following events or circumstances, constitutes waiver of such hearing:   (1) respondent fails to file a timely written appearance indicating that he will appear at the hearing; (2)   !respondent fails to appear at the hearing after providing notification that he will appear; or (3) the  yOP-  /respondent files a written statement with the Commission that he waives his right to a hearing. See 47  yO-C.F.R.  1.92(a); see also supra para. 9 & note 23.(#Ƒ x  Sp- ` `x 14. ` ` We also order the Fletcher Companies and each principal of the Fletcher Companies to  xcease and desist from any future provision of interstate common carrier service without the prior consent  xof the Commission. In addition, we find that the egregious actions of the Fletcher Companies and their  xLprincipals, who have committed numerous violations of our rules and the Act, warrant the imposition of  S - xforfeitures against them. In the Show Cause Order, we included a Notice of Apparent Liability for willful  S - x<or repeated violations of the Commission rules,p. H i yO-ԍxSee Show Cause Order, 12 FCC Rcd at 8562, para. 26.p under the authority of Section 503(b) of the Act.n/ i yO"-#]\  PCqP#эx47 U.S.C.  503(b).n Under  S - xthe proposals set forth in the Show Cause Order, the amount of forfeiture would be calculated as follows:  x/a) $15,000 for each unauthorized conversion of complainants' long distance service in violation of 47  xC.F.R.  64.1100 and/or 64.1150; b) $5,000 for each failure to respond to an Official Notice of Informal  xComplaint or inadequate response to an Official Notice of Informal Complaint in violation of 47 U.S.C.  xz 208(a) and 416(c) and 47 C.F.R.  1.717; c) $1,000 for violation of 47 U.S.C.  413; and d) $6,000  xyfor each failure to comply with the requirements of 47 U.S.C.  203(a),X01Í ÍX01ÍÍ plus $300 for each and every day of the continuance of each such violation. "l h/0*%%JJs"Ԍ S- ` X` hp x (#%'0*,.8135@8:to the violator, the degree of culpability, and history of prior offenses, ability to pay, and such other  S- xmatters as justice may require."Y0} yO-X` hp x (#%'0*,.8135@8:"deliberate failure to ensure that letters of authorization are valid and properly authorized" leads to an  yO-unauthorized conversion. Id. (# Calculating upon this basis,  x=we assess a forfeiture of $3,600,000 for slamming violations against Long Distance Services, Inc. (LDSI)  xand its principals, and a forfeiture of $1,650,000 for slamming violations against Phone Calls, Inc. (PCI)  xand its principals. We also find that certain of the Fletcher Companies failed to respond to at least 61  S^- xNotices of Informal Complaint, in violation of 47 U.S.C.  208(a) and 416(c) and 47 C.F.R.  1.717.3^} yO-  X` hp x (#%'0*,.8135@8:violation of Section 203(a) of the Act. In the Show Cause Order, we stated that it appeared that the  xjmajority of the Fletcher Companies provided telecommunications services without maintaining tariffs on  S- xkfile with the Commission.4} yO-  kX` hp x (#%'0*,.8135@8: x} yO-X` hp x (#%'0*,.8135@8:0*%%JJ"Ԍ S- ` $ԙd24. ` ` IT IS FURTHER ORDERED that pursuant to Sections 4(i) and 503 of the Act, 47   x\154(i), 503, that Long Distance Services, Inc. (LDSI) and its principals shall FORFEIT to the United  xStates Government $3,600,000, and Phone Calls, Inc. (PCI) and its principals SHALL FORFEIT to the  S- xUnited States Government $1,650,000 , for violating the Commission's rules governing primary  S`- xinterexchange carrier conversions.U?`} yO-X` hp x (#%'0*,.8135@8:the case will be referred to the Department of Justice for collection pursuant to Section 504(a) of the  SH -Communications Act.  ]GH } yO-X` hp x (#%'0*,.8135@8: