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                           Before the
                Federal Communications Commission
                     Washington, D.C.  20554

In the Matter of                 )
                                ) Corporation           )    File No. EB-04-IH-0504
                                )    NAL/Acct. No. 200532080020
                                )    FRN 0009726001

                       ORDER OF FORFEITURE 

Adopted:  February 18, 2005                            Released:  
February 23, 2005

By the Chief, Enforcement Bureau:


     1.   In this Order of Forfeiture, we assess a monetary 
forfeiture of $20,000 against Corporation 
(``BigZoo'').  The noted violation involves BigZoo's failure to 
respond to a directive of the Enforcement Bureau (``Bureau'') to 
provide certain information and documents pursuant to a 
Commission Letter of Inquiry (``LOI'').1


     2.   The facts and circumstances surrounding this case are 
set forth in the Notice of Apparent Liability for Forfeiture 
issued by the Bureau in December 2004, and need not be 
reiterated at length here.2  BigZoo sells prepaid long distance 
phone service, and is therefore a telecommunications carrier 
providing interstate service that is required to contribute to 
the Universal Service Fund (``USF'') under section 54.706 of the 
Commission's rules.3  In October 2004, the Universal Service 
Administrative Company (``USAC'') referred BigZoo to the Bureau 
for action concerning its failure to fully and timely contribute 
to the USF.  Thereafter, by letter dated October 15, 2004, the 
Bureau initiated an investigation into whether the company 
violated, among other things, section 54.706 of the Commission's 
rules, and directed BigZoo to provide certain specified 
documents and information within twenty calendar days of the 
date of the letter, i.e., by November 4, 2004.4  Through 
counsel, BigZoo subsequently asked for two extensions of time 
for response, and the Bureau granted them, ultimately postponing 
the date for response to November 23, 2004.5  To date, the 
Bureau has not received any response to the LOI.6

     3.   On December 21, 2004, the Bureau issued the NAL for 
forfeiture in the amount of $20,000.  The NAL ordered BigZoo to 
pay the forfeiture or respond to the notice, as well as to 
respond to the LOI, within 30 days.7  This notice was sent to 
BigZoo's last known address via certified mail and email.  As of 
the date of the release of this order, BigZoo has still not 
filed a response to LOI, and has not paid the forfeiture amount 
or submitted a response to the NAL.


     4.   As discussed in the NAL, section 503(b)(2)(B) of the 
Act authorizes the Commission to assess a forfeiture against 
telecommunications carriers of up to $130,000 for each violation 
or each day of a continuing violation, up to a statutory maximum 
of $1,325,000 for a single act or failure to act.8  In 
determining the appropriate forfeiture amount, we consider the 
factors enumerated in section 503(b)(2)(D) of the Act, including 
``the nature, circumstances, extent, and gravity of the 
violation and, with respect to the violator, the degree of 
culpability, any history of prior offenses, ability to pay, and 
such other matters as justice may require.''9  The Commission 
will then issue a forfeiture if it finds by a preponderance of 
the evidence that the person has willfully or repeatedly 
violated the Act or a Commission rule.10  In exercising such 
authority, we have the discretion to adjust the forfeiture 
amount based on the particular facts and circumstances of the 

     5.   In the NAL, we proposed a forfeiture of $20,000 for 
BigZoo's apparent violation of a Commission order by willfully 
and repeatedly failing to respond to a Bureau directive to 
provide certain information and documents.11  We noted the base 
forfeiture of $3,000 for failure to file required forms of 
information, and the base forfeiture of $4,000 for failure to 
respond to a Commission communication, but concluded that the 
circumstances here warranted a substantial increase from these 
amounts. 12  We explained that BigZoo's misconduct ``exhibits a 
disregard for the Commission's authority that cannot be 
tolerated, and, more importantly, threatens to compromise the 
Commission's ability to adequately investigate violations of its 

     6.   By failing to respond to the NAL, BigZoo has failed to 
identify facts or circumstances to persuade us that there is a 
basis for modifying the proposed forfeiture, and we are not 
aware of any further mitigating circumstances sufficient to 
warrant a reduction of the forfeiture penalty.  For these 
reasons, we hereby impose a forfeiture of $20,000 for BigZoo's 
failure to respond to a Commission communication as set forth in 
the NAL.

     7.   Accordingly, IT IS ORDERED THAT, pursuant to section 
503(b) of the Communications Act of 1934, as amended, 47 U.S.C. 
 503(b), and section 1.80 of the Commission's rules, 47 C.F.R. 
 1.80, that Corporation SHALL FORFEIT to the United 
States government the sum of $20,000 for willfully and 
repeatedly violating the Commission's rules.

     8.   Payment of the forfeiture shall be made in the manner 
provided for in section 1.80 of the Commission's rules within 30 
days of the release of this Order.  If the forfeiture is not 
paid within the period specified, the case may be referred to 
the Department of Justice for collection pursuant to Section 
504(a) of the Act.14  Payment of the forfeiture must be made by 
check or similar instrument, payable to the order of the Federal 
Communications Commission.  The payment must include the 
NAL/Account No. and the FRN referenced above.  Payment by check 
or money order may be mailed to Forfeiture Collection Section, 
Finance Branch, Federal Communications Commission, and P.O. Box 
73482, Chicago, Illinois 60673-7482.  Payment by wire transfer 
may be made to ABA Number 071000013, receiving bank Bank One, 
and account number 1165259.  Requests for full payment under an 
installment plan should be sent to: Chief, Revenue and 
Receivables Operations Group, 445 12th Street, S.W., Washington, 
D.C., 20554.15

     9.   IT IS FURTHER ORDERED that a copy of this Order shall 
be sent by first class mail and certified mail return receipt to Corporation, 55 S. Lake Avenue, Suite 700, Pasadena, 
CA 91101

                              FEDERAL COMMUNICATIONS COMMISSION

                              David H. Solomon
                              Chief, Enforcement Bureau

1 Letter from Eric J. Bash, Assistant Chief, Investigations & 
Hearings Division, Enforcement Bureau, FCC, to Pantipa Sarai, Corp. (Oct. 15, 2004) (``LOI'').
2  See BigZoo.Com Corporation, Notice of Apparent Liability for 
Forfeiture and Order, DA 04-3983 (Enf. Bur., released Dec. 21, 
2004) (``NAL'').
3 47 C.F.R.  54.706(a).
4 See LOI.
5 BigZoo NAL, supra note 2, at 2.
6 Id.
7 Id. at 5.
8 47 U.S.C.  503(b)(2)(B).  See also 47 C.F.R.  1.80(b)(2); 
Amendment of Section 1.80(b) of the Commission's Rules, 
Adjustment of Forfeiture Maxima to Reflect Inflation, Order, 19 
FCC Rcd 10945 (2004). 
9 47 U.S.C.  503(b)(2)(D).
10 See, e.g., SBC Communications, Inc., Forfeiture Order, 17 FCC 
Rcd 7589, 7591,  4 (2002).
11 BigZoo NAL, supra note 2, at 5.
12 Id. at 4.
13 Id.
14 47 U.S.C  504(a).
15 See 47 U.S.C  1.1914.