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

In the Matter of                 )    File No. EB-04-IH-0656
                                )
                                )
Telecom House, Inc.              )    NAL/Acct. No. 200532080144
                                )
                                )
Apparent Liability for           )    FRN No. 0011-3826-03
Forfeiture                       )

                  NOTICE OF APPARENT LIABILITY 
                    FOR FORFEITURE AND ORDER


Adopted:  September 13, 2005                           Released:  
September 13, 2005

By the Commission:

I.   INTRODUCTION 
                                      
     1.   In this Notice of Apparent Liability for Forfeiture 
(``NAL''), we find that a telecommunications provider, operating 
since 2000 and at least indirectly benefiting from the federal 
programs supporting the telecommunications industry since that 
time, apparently failed to meet its statutory and regulatory 
obligations relating to those programs.  Based upon the facts and 
circumstances surrounding this matter, we conclude that this 
company is apparently liable for a total forfeiture of $529,300.  

     2.   We specifically find that Telecom House, Inc. 
(``Telecom House'') has apparently violated section 64.1195 of 
the Commission's rules by willfully and repeatedly failing to 
register with the Commission until September 2004.1  We also find 
that Telecom House has apparently violated sections 54.711(a) and 
64.604(c)(5)(iii)(B) of the Commission's rules by failing to 
submit certain Telecommunications Reporting Worksheets 
(``Worksheets'') from 2001 to 2005.2  Finally, we find that 
Telecom House has apparently violated section 254(d) of the 
Communications Act of 1934, as amended (the ``Act''),3 and 
sections 54.706(a) and 64.604(c)(5)(iii)(A) of the Commission's 
rules by willfully and repeatedly failing to contribute to the 
Universal Service Fund (``USF'') and Telecommunications Relay 
Service (``TRS'') Fund on a timely basis.4    

     3.   We are resolved to ensure a level playing field for all 
companies that are required to contribute to the maintenance of 
our various Congressionally mandated programs, including the 
federal universal service program.  The failure of a carrier to 
fulfill its obligation to contribute to these programs has a 
direct and significant detrimental impact on the programs and on 
other industry participants because that failure removes from the 
base of contributions telecommunications revenues that otherwise 
should be included, thereby forcing other telecommunications 
carriers to shoulder additional costs associated with the 
programs.  Thus, this NAL and others like it represent one 
element in a comprehensive approach to improving the efficacy and 
fairness of the universal service program as well as reducing 
waste, fraud and abuse in the program.

     4.   We order Telecom House to submit within thirty days, 
either as part of its response to this NAL or separately, a 
report, supported by a sworn statement or declaration under 
penalty of perjury of a corporate officer, setting forth in 
detail its plan to come into compliance with the relevant payment 
and reporting rules discussed herein.  We further order Telecom 
House to file with the Universal Service Administrative Company 
(``USAC'') within thirty days all annual Telecommunications 
Reporting Worksheets and amended Worksheets required under the 
Commission's rules from the date that Telecom House commenced 
providing telecommunications services in the United States to the 
date of this NAL.5
 
II.  BACKGROUND

     5.   The Commission is charged by Congress with regulating 
interstate and international telecommunications and ensuring that 
providers of such telecommunications comply with the requirements 
imposed on them by the Act and our rules.6  The Commission also 
has been charged by Congress to establish, administer and 
maintain various telecommunications regulatory programs, and to 
fund these programs through assessments on the telecommunications 
providers that benefit from them.  In order to accomplish these 
goals, the Commission established ``a central repository of key 
facts about carriers'' through which it could monitor the entry 
and operation of interstate telecommunications providers to 
ensure, among other things, that they are qualified, do not 
engage in fraud, and do not evade oversight.7  Commission rules 
require that, upon entry or anticipated entry into interstate 
telecommunications markets, telecommunications carriers register 
by submitting information on FCC Form 499-A, also known as the 
annual Telecommunications Reporting Worksheet.8  The Commission 
also requires telecommunications providers to submit financial 
information on annual and, with some exceptions not applicable to 
Telecom House since 2003,9 quarterly short-form Worksheets to 
enable the Commission to determine and collect the statutorily 
mandated program assessments.10

     6.   The Telecommunications Act of 1996 codified Congress' 
historical commitment to promote universal service to ensure that 
consumers in all regions of the nation have access to affordable, 
quality telecommunications services.11  In particular, section 
254(d) of the Act requires, among other things, that ``[e]very 
telecommunications carrier [providing] interstate 
telecommunications services . . . contribute, on an equitable and 
nondiscriminatory basis, to the specific, predictable, and 
sufficient mechanisms established by the Commission to preserve 
and advance universal service.''12  In implementing this 
Congressional mandate, the Commission directed all 
telecommunications carriers providing interstate 
telecommunications services and certain other providers of 
interstate telecommunications to contribute to the Universal 
Service Fund based upon their interstate and international end-
user telecommunications revenues.13  Failure by some providers to 
pay their share into the Fund skews the playing field by giving 
non-paying providers an economic advantage over their competitors 
who must shoulder more than their fair share of the costs of the 
Fund.

     7.   Section 225(b)(1) of the Act, which codifies Title IV 
of the Americans with Disabilities Act of 1990, directs the 
Commission to ``ensure that interstate and intrastate 
telecommunications relay services are available, to the extent 
possible and in the most efficient manner, to hearing-impaired 
and speech-impaired individuals in the United States.''14  To 
that end, the Commission established the TRS Fund to reimburse 
TRS providers for the costs of providing interstate 
telecommunications relay services.15  Pursuant to section 
64.604(c)(5)(iii)(A) of the Commission's rules, every carrier 
that provides interstate telecommunications services must 
contribute to the TRS Fund based upon its interstate end-user 
revenues.16

     8.   The Commission has established specific procedures to 
administer the programs for the universal service and other 
regulatory programs.  A carrier must file Worksheets for the 
purpose of determining its USF and other regulatory fee program 
payments.17  These periodic filings trigger a determination of 
liability, if any, and subsequent billing and collection by the 
entities that administer the regulatory programs.  USAC uses the 
revenue projections submitted on the quarterly filings to 
determine each carrier's universal service contribution amount.18  
Carriers are required to pay their monthly USF contribution by 
the date shown on their invoice.19  The Commission's rules 
explicitly warn contributors that failure to file their forms or 
submit their payments potentially subjects them to enforcement 
action.20  Further, under the Commission's ``red light rule,'' 
action will be withheld on any application to the Commission or 
request for authorization made by any entity that has failed to 
pay when due its regulatory program payments, such as USF 
contributions, and if payment or payment arrangements are not 
made within 30 days from notice to the applicant, such 
applications or requests will be dismissed.21

     9.   Telecom House began providing telecommunications 
service in the United States in 2000.22  Telecom House provides 
``1-800 Access for International Calling[,] Prepaid Phone Cards 
[and] Long Distance Telephone Service.''23  

     10.  In 2004, the Enforcement Bureau (``Bureau'') audit 
staff sought to identify resellers of telecommunications service 
that failed to register as telecommunications service providers 
with the Commission, and, thus, may also have failed to satisfy 
various Commission program requirements.24  In order to identify 
such resellers, the Bureau audit staff compared lists of 
resellers provided by wholesale service providers against the 
Commission's central repository of registered telecommunications 
service providers with filer identification numbers.  If a 
reseller did not appear to have an identification number, the 
audit staff sent an inquiry to that reseller.  On August 9, 2004, 
the Bureau's audit staff sent a letter to Telecom House 
requesting information pertaining to Telecom House's compliance 
with section 64.1195 of the Commission's rules.25  Thereafter, on 
September 14, 2004, Telecom House registered pursuant to section 
64.1195 of the Commission's rules,26 several years after it began 
providing service.    

     11.  On January 26, 2005, the Bureau issued a letter of 
inquiry to Telecom House.27  The January 26, 2005 LOI directed 
Telecom House, among other things, to submit a sworn written 
response to a series of questions relating to Telecom House's 
apparent failure to register and file Telecommunications 
Reporting Worksheets and to make mandated federal 
telecommunications regulatory program payments.  Telecom House 
responded to the January 26, 2005 LOI on March 17, 2005.28 

     12.  On March 10, 2005, approximately six months after it 
registered, and approximately seven months after the Bureau's 
August 9, 2004 Audit Letter, Telecom House untimely attempted to 
file its annual Worksheets for 2002, 2003 and 2004, which 
(improperly) reported 2002, 2003, and 2004 revenue, 
respectively.29  Because Telecom House had used the wrong forms 
with its March 10, 2005 filing, however, on March 31, 2005, 
Telecom House reported its 2002, 2003 and 2004 revenue, using the 
annual Worksheets for 2003, 2004 and 2005, respectively.30  
Telecom House filed its quarterly Worksheet for May 2005 on April 
28, 2005.31  Although Telecom House has been providing 
telecommunication services since 2000, it still has apparently 
not filed annual Worksheets for 2001 or 2002, which would report 
2000 and 2001 revenue, respectively.

     13.  On July 13, 2005, the Bureau issued a follow-up letter 
of inquiry to Telecom House.32  Telecom House responded on August 
5, 2005, and provided to the Bureau corrected annual Worksheets 
for 2003, 2004 and 2005, which it previously filed on March 31, 
2005, and its quarterly Worksheet for May 2005, which it 
previously filed on April 28, 2005.33  As a result of these 
filings, USAC calculated that Telecom House owed $23,777.44 to 
the USF for 2003 and 2004, and would owe $1,810.14 for each month 
in the third quarter of 2005 (corresponding to the quarterly 
Worksheet the company filed on April 28, 2005).  Telecom House 
did not provide with its August 5, 2005 LOI Response a quarterly 
Worksheet that was due August 1, 2005, and USAC records do not 
indicate that an August 2005 quarterly Worksheet has been filed 
by Telecom House.  Within the past year, Telecom House also 
failed to file its quarterly Worksheets due in November 2004 and 
February 2005.  As a result, USAC has not calculated exactly how 
much the company owes for first and second quarters of 2005.  On 
August 24, 2005, USAC received the first payment of Telecom 
House. 

III.      DISCUSSION

     14.  Under section 503(b)(1)(B) of the Act, any person who 
is determined by the Commission to have willfully or repeatedly 
failed to comply with any provision of the Act or any rule, 
regulation, or order issued by the Commission shall be liable to 
the United States for a forfeiture penalty.34  Section 312(f)(1) 
of the Act defines willful as ``the conscious and deliberate 
commission or omission of [any] act, irrespective of any intent 
to violate'' the law.35  The legislative history to section 
312(f)(1) of the Act clarifies that this definition of willful 
applies to both sections 312 and 503(b) of the Act,36 and the 
Commission has so interpreted the term in the section 503(b) 
context.37  The Commission may also assess a forfeiture for 
violations that are merely repeated, and not willful.38  
``Repeated'' means that the act was committed or omitted more 
than once, or lasts more than one day.39  To impose such a 
forfeiture penalty, the Commission must issue a notice of 
apparent liability and the person against whom the notice has 
been issued must have an opportunity to show, in writing, why no 
such forfeiture penalty should be imposed.40  The Commission will 
then issue a forfeiture if it finds by a preponderance of the 
evidence that the person has violated the Act or a Commission 
rule.41  As set forth below, we conclude under this standard that 
Telecom House is apparently liable for a forfeiture for its 
apparent willful and repeated violations of section 254(d) of the 
Act42 and sections 54.706(a), 54.711(a), and 64.604(c)(5)(iii), 
and 64.1195 of the Commission's rules.43

     15.  The fundamental issues in this case are whether Telecom 
House apparently violated the Act and the Commission's rules by:  
(1) willfully or repeatedly failing to register pursuant to 
section 64.1195 of the Commission's rules;44 (2) willfully or 
repeatedly failing to file Telecommunications Reporting 
Worksheets; and (3) willfully or repeatedly failing to make 
requisite contributions toward the Universal Service and TRS 
Funds when due.  We answer these questions affirmatively.  Based 
on a preponderance of the evidence, we conclude that Telecom 
House is apparently liable for a forfeiture of $529,300 for 
apparently willfully and repeatedly violating section 254(d) of 
the Act,45 and sections 54.706(a), 54.711(a), 64.604(c)(5)(iii), 
and 64.1195 of the Commission's rules.46

     16.  Specifically, we propose the following forfeitures for 
apparent violations within the last year: (1) $100,000 for 
failure to register pursuant to section 64.1195 of the 
Commission's rules;47 (2) $150,000 for failure to file three 
Telecommunications Reporting Worksheets; (3) $258,224 for failure 
to make twelve monthly USF contributions on a timely basis; and 
(4) $21,076 for failure to make its 2005 TRS Fund contribution on 
a timely basis.  Although we propose forfeitures only for 
apparent violations within the last year, we discuss below the 
history of Telecom House's noncompliance in prior years as useful 
background and to demonstrate the scope of Telecom House's 
misconduct and the context of the misconduct that is within the 
statute of limitations period and thus covered by this NAL.

     III.A.    Registration with the Commission

     17.  We conclude that Telecom House has apparently violated 
section 64.1195(a) of the Commission's rules by failing to 
register with the Commission from 2001 until September 14, 
2004.48  Telecom House's failure to register constitutes a clear 
violation of a vital Commission rule.  Section 64.1195(a) of the 
Commission's rules unambiguously requires that all carriers that 
provide, or plan to provide, interstate telecommunications 
services register with the Commission by submitting specified 
information.49  Although Telecom House has been providing 
interstate telecommunications services since 2000, it failed to 
register in accordance with section 64.1195(a) until September 
14, 2004, approximately one month after it received the Bureau's 
August 9, 2004 Audit Letter.  As a result of its misconduct, 
Telecom House operated for over four years without participation 
in any of the programs tied to registration.  As an interstate 
telecommunications carrier, Telecom House had a clear and 
affirmative duty to apprise itself of, and satisfy, its federal 
obligations.50    

     18.  We view Telecom House's apparent failure to register 
for over four years as a serious dereliction of its 
responsibilities under the Act and our rules.  A carrier's 
compliance with the Commission's registration requirement is 
critical to the administration of the USF and TRS programs, and 
to fulfilling Congress' objectives in sections 254(d) and 
225(b)(1) of the Act.  As we noted above, a carrier's duty to 
register upon entry, or anticipated entry, into interstate 
telecommunications markets is essential to the fulfillment of the 
USF, TRS, and other regulatory program missions because it 
identifies the company to the various program administrators and 
brings the company within the purview and oversight of those 
administrators.  If a carrier never identifies itself as a 
telecommunications provider by properly registering under the 
Commission's rules, then neither the Commission nor the various 
program administrators can ascertain whether that carrier has 
fulfilled other regulatory obligations, including the requirement 
that carriers file Worksheets and contribute to USF, TRS, and 
other regulatory programs.  Moreover, the program administrators 
have no basis upon which to invoice the carrier for 
contributions.  A telecommunications carrier that fails to 
register thus can operate outside of the Commission's oversight 
and evade its federal obligations to contribute toward the vital 
programs linked to registration.

     19.  The impact of a carrier's failure to register is no 
less severe where, as here, that carrier ultimately registers 
with the Commission.  Although Telecom House registered on 
September 14, 2004, and has apparently filed some of the required 
Worksheets in the last few months, Telecom House delayed its 
registration for an extended period of time and took no action 
until after receiving a letter from the Bureau.51  The Commission 
has repeatedly stated that subsequent corrective measures to 
address a violation do not eliminate a licensee's responsibility 
for the period during which the violation occurred.52  Telecom 
House's substantial delay in registering after receiving the 
Bureau's letter raises serious questions about its intention to 
do so absent threat of Commission action.  Based on a 
preponderance of the evidence, therefore, we find that Telecom 
House apparently has violated section 64.1195(a) of the 
Commission's rules by willfully and repeatedly failing to 
register from 2001 until September 14, 2004.53  

     III.B.    Submission of Telecommunications Reporting 
          Worksheets 

     20.  We conclude that Telecom House apparently has violated 
sections 54.711(a) and 64.604(c)(5)(iii)(B) of the Commission's 
rules by willfully and repeatedly failing to file certain 
Telecommunications Reporting Worksheets, on a timely basis, from 
2001 through March 2005.54  On March 31, 2005, Telecom House 
reported its 2002, 2003 and 2004 revenue.  While Telecom House 
reported its 2004 revenue on time, i.e., before April 1, 2005, it 
untimely reported its 2002 and 2003 revenue, which was due April 
1, 2003 and April 1, 2004, respectively.  Telecom House filed its 
quarterly Worksheet for May 2005 on April 28, 2005.  Although 
Telecom House has been providing telecommunication services since 
2000, it has not filed Annual Worksheets for 2001 or 2002, which 
is used to report 2000 and 2001 revenue, respectively.  Within 
the past year, while Telecom House did file its quarterly 
Worksheet due May 1, 2005, it failed to file the quarterly 
Worksheets due November 1, 2004 and February 1 and August 1, 
2005.

     21.  Section 54.711(a) and 64.605(c)(5)(iii)(B) of the 
Commission's rules clearly establish a carrier's obligation to 
file periodic Telecommunications Reporting Worksheets.55  A 
carrier's failure to file these Worksheets as required has 
serious implications for the USF and TRS programs.  As discussed 
above, the filing of a Telecommunications Reporting Worksheet 
prompts a determination of liability for, and subsequent billing 
and collection of, payments by the administrators of the 
Universal Service and TRS Funds.  With regard to the federal 
universal service program in particular, the failure of a carrier 
such as Telecom House to abide by its federal filing obligation 
has a direct and profound detrimental impact by removing from the 
base of USF contributions telecommunications revenues that 
otherwise should be included, thereby shifting to compliant 
carriers additional economic burdens associated with the federal 
universal service program.56  Consequently, a carrier's failure 
to file required Worksheets thwarts the very purpose for which 
Congress enacted section 254(d) - to ensure that every interstate 
carrier ``contribute, on an equitable and nondiscriminatory 
basis, to the specific, predictable, and sufficient mechanisms 
established by the Commission to preserve and advance universal 
service.''57  Viewed in this context, the Telecommunications 
Reporting Worksheet is not only an administrative tool, but a 
fundamental and critical component of the Commission's Universal 
Service program.
  
     22.  Based on a preponderance of the evidence, we find that 
Telecom House apparently has violated section 254 of the Act58 
and section 54.711 and 64.604 of the Commission's rules59 by 
willfully and repeatedly failing to timely file required 
information with the Commission on multiple occasions since 2001, 
including failure to make three filings within the last year, the 
time period covered by this NAL.  The NAL proposes a forfeiture 
for Telecom House's failure to file the quarterly Worksheets due 
November 1, 2004, and February 1 and August 1, 2005.

     III.C.    Universal Service Contributions

     23.  We further conclude that Telecom House apparently 
violated section 254(d) of the Act and section 54.706 of the 
Commission's rules by willfully and repeatedly failing to 
contribute to universal service support mechanisms on a timely 
basis.60  Section 54.706(c) of the Commission's rules 
unambiguously directs that ``entities [providing] interstate 
telecommunications to the public . . . for a fee . . . contribute 
to the universal service support programs.''61  Since 2003, 
Telecom House was required, pursuant to section 54.706(b) of the 
Commission's rules, to contribute to universal service mechanisms 
based upon either its historical or projected revenues.62  As we 
previously have stated,

          [c]arrier nonpayment of universal service 
          contributions undermines the efficiency and 
          effectiveness of the universal service 
          support mechanisms.  Moreover, delinquent 
          carriers may obtain a competitive advantage 
          over carriers complying with the Act and our 
          rules.  We consider universal service 
          nonpayment to be a serious threat to a key 
          goal of Congress and one of the Commission's 
          primary responsibilities.63 

Based on a preponderance of the evidence, we find that Telecom 
House apparently has violated sections 254(d) of the Act and 
54.706 of the Commission's rules by willfully and repeatedly 
failing to timely make its monthly universal service contribution 
payments for a period of years, including twelve such failures 
within the past year.  

     III.D.    Telecommunications Relay Service Contributions

     24.  We also find that Telecom House apparently has violated 
section 64.604(c)(5)(iii)(A) of the Commission's rules by failing 
to make required contributions to the interstate TRS Fund when 
due.64  As an interstate telecommunications carrier, Telecom 
House has been obligated to contribute to the TRS Fund on the 
basis of its interstate and international end-user 
telecommunications revenues.65  A carrier's contribution to the 
TRS Fund is based upon its subject revenues for the prior 
calendar year and a contribution factor determined annually by 
the Commission.66  Subject carriers must make TRS contributions 
on an annual basis, with certain exceptions that are not 
applicable to Telecom House.67  

     25.  Telecom House has not made any TRS Fund payments on a 
timely basis.  In its March 17, 2005 LOI response, Telecom House 
expressly stated that ``[t]he Company has not previously 
contributed directly to the TRS.''68  In its August 5, 2005 LOI 
response, Telecom House stated that ``[t]he Company has received 
one invoice for TRS contribution, for which payment is not yet 
due.''69  To the contrary, the invoice Telecom House produced in 
response to the LOI states on its face that ``[p]ayment must be 
received by 7/26/2005.''70  Based on a preponderance of the 
evidence, we therefore find that Telecom House apparently has 
violated section 64.604 of the Commission's rules by willfully 
and repeatedly failing to pay its TRS contributions when due, 
including its failure to make on a timely basis the payment due 
on July 26, 2005.

     III.E.    Proposed Forfeiture

     26.  Section 503(b)(1)(B) of the Act provides that any 
person that willfully or repeatedly fails to comply with any 
provision of the Act or any rule, regulation, or order issued by 
the Commission, shall be liable to the United States for a 
forfeiture penalty.71  For the apparent violations in this case, 
section 503(b)(2)(B) of the Act authorizes the Commission to 
assess a forfeiture of up to $130,000 for each violation or each 
day of a continuing violation, up to a statutory maximum of 
$1.325 million for a single act or failure to act.72  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.''73

     27.  Under section 503(b)(6) of the Act, we may only propose 
forfeitures for apparent violations that occurred within one year 
of the date of this NAL.74  Nevertheless, section 503(b) does not 
bar us from assessing whether Telecom House's conduct prior to 
that time period apparently violated the Act or our rules in 
determining the appropriate forfeiture amount for those 
violations within the statute of limitations.75  Therefore, 
although we find that Telecom House apparently violated the Act 
and our rules for over four years, we propose forfeitures here 
only for violations that occurred within the last year.

     28.  This case involves a carrier's failure both to register 
and submit any Telecommunications Reporting Worksheets from the 
time it commenced providing telecommunications services until 
after it received a letter from the Bureau76 - in this case, a 
period of over four years.  We find Telecom House's failure to 
discharge its federal reporting obligations to be particularly 
egregious.  As we stated above, the registration and filing of 
Telecommunications Reporting Worksheets are fundamental to the 
implementation of our central repository of carriers and to the 
administration of multiple statutorily derived programs - 
including the USF Fund.  Where, as here, a carrier ignores its 
obligations by wholly failing to register - thereby affecting the 
time and manner in which these important federal programs are 
funded - it undermines the programs and thwarts the purposes for 
which Congress and the Commission established them.  

     29.  Recently, we have held that a substantial forfeiture of 
$100,000 is warranted for a carrier's failure to register with 
the Commission.77  We explained that ``[t]his egregious behavior 
strikes at the core of our ability to implement and enforce the 
Act and our rules effectively, thus warranting a substantial 
forfeiture.''78  This is because a carrier that fails to register 
hampers ``efficient and effective Commission enforcement by 
delaying detection of, and action against, its behavior . . . and 
imposes a substantial burden on the Commission, which can only 
identify such carriers through compliance review programs that 
require significant amounts of staff time and resources.''79  
Taking into account all of the factors enumerated in section 
503(b)(2)(D) of the Act, we conclude that a proposed forfeiture 
of $100,000 is warranted. 

     30.  In the past, we have held that a substantial forfeiture 
of $50,000 is warranted for a carrier's failure to file a 
Telecommunications Reporting Worksheet for revenue reporting 
purposes.80  We find that Telecom House's willful and repeated 
failure to file periodic Telecommunications Reporting Worksheets 
is egregious.  As we noted above, a carrier's obligation to file 
these Worksheets is directly linked to, and thus has serious 
implications for, administration of the USF and other regulatory 
programs.  By ignoring its reporting obligations, Telecom House 
has unilaterally shifted to compliant carriers and their 
customers the economic costs associated with the universal 
service and other regulatory programs.  Therefore, we find that 
Telecom House is apparently liable for a $150,000 forfeiture for 
its failure to file three Worksheets within the last year; i.e., 
those due November 1, 2004, and February 1 and August 1, 2005.

     31.  Based on the facts above, it also appears that Telecom 
House has failed to timely make the requisite contributions into 
the Universal Service Fund for a period of over two years.  
Again, nonpayment of universal service contributions is an 
egregious offense that bestows on delinquent carriers an unfair 
competitive advantage by shifting to compliant carriers the 
economic costs and burdens associated with universal service.  A 
carrier's failure to make required universal service 
contributions frustrates Congress' policy objective in section 
254(d) of the Act to ensure the equitable and non-discriminatory 
distribution of universal service costs among all 
telecommunications providers.81  The Commission has established a 
base forfeiture amount of $20,000 for each month in which a 
carrier has failed to make required universal service 
contributions.82  Consequently, we find Telecom House apparently 
liable for a base forfeiture of $240,000 for its willful and 
repeated failure to make twelve universal service contributions 
when due within the past year. 

     32.  In the past, we have calculated upward adjustments to 
forfeitures for failure to make USF payments based on half of the 
company's unpaid contributions.83  As explained above, USAC 
records show that on August 15, 2005, Telecom House owed 
$25,587.58 for USF contributions.  In addition, although USAC has 
not calculated how much Telecom House owes for the first two 
quarters of 2005 because the company failed to file the quarterly 
forms that correspond to these periods, we estimate that the 
company owes $10,860 for this period.84  Therefore, taking into 
account all of the factors enumerated in section 503(b)(2)(D) of 
the Act, we propose an upward adjustment of $18,224 ($12,794 + 
$5,430)85 - half the amount we estimate that Telecom House owed 
for outstanding USF contributions on August 15, 2005 - for 
Telecom House's apparent failure to make universal service 
contributions.  We thus find Telecom House liable for a total 
proposed forfeiture of $258,224 for its apparent willful and 
repeated failure to make timely contributions into the Universal 
Service Fund.

     33.  We also find that Telecom House apparently has failed 
to make any TRS contributions on a timely basis.  Telecom House's 
2005 TRS obligation was due on July 26, 2005, and it has not made 
this payment.  Where a carrier fails to satisfy its TRS 
obligations for an extended period of time, it thwarts the 
purpose for which Congress established section 225(b)(1) of the 
Act and its implementing regulations - to ensure that 
telecommunications relay services ``are available to the extent 
possible and in the most efficient manner, to hearing-impaired 
and speech-impaired individuals in the United States.''86  The 
Commission has established a base forfeiture amount of $10,000 
for each instance in which a carrier fails to make required TRS 
contributions.87  In light of the failure of Telecom House to pay 
its 2005 TRS obligation on a timely basis, we find it apparently 
liable for a base forfeiture in the amount of $10,000.  For the 
reasons discussed above regarding Telecom House's failure to make 
universal service contributions and consistent with Commission 
precedent,88 we find that an upward adjustment, in an amount 
approximately one-half of the carrier's unpaid 2005 TRS 
contributions ($22,152),89 is appropriate for Telecom House's 
apparent failure to make timely TRS contributions.  Taking into 
account the factors enumerated in section 503(b)(2)(D) of the 
Act, we conclude that an upward adjustment of $11,076 is 
reasonable.  Consequently, we find Telecom House liable for a 
total proposed forfeiture of $21,076 for its willful and repeated 
failure to satisfy its 2005 TRS obligations.

IV.  CONCLUSION
     34.  In light of the seriousness, duration and scope of the 
apparent violations, and to ensure that a company with 
substantial revenues such as Telecom House does not consider the 
proposed forfeiture merely ``an affordable cost of doing 
business,''90 we find that a proposed forfeiture in the amount of 
$529,300 is warranted.  As discussed above, this proposed 
forfeiture amount includes:  (1) a total proposed penalty of 
$100,000 for failing to register pursuant to section 64.1195 of 
the Commission's rules;91 (2) a total proposed penalty of 
$150,000 for failing to file three Telecommunications Reporting 
Worksheets within the past year; (3) a total proposed penalty of 
$258,224 for failing to make twelve monthly universal service 
contributions when due within the past year; and (4) a total 
proposed penalty of $21,076 for failing to make its 2005 TRS 
program contribution when due.

     35.  We caution that additional violations of the Act or the 
Commission's rules could subject Telecom House to further 
enforcement action.  Such action could take the form of higher 
monetary forfeitures and/or possible revocation of Telecom 
House's operating authority, including disqualification of 
Telecom House's principals from the provision of any interstate 
common carrier services without the prior consent of the 
Commission.92  In addition, we note that, to the extent Telecom 
House is ever found to be delinquent on any debt owed to the 
Commission (e.g., has failed to pay all of its USF 
contributions), the Commission will not act on, and may dismiss, 
any application or request for authorization filed by Telecom 
House, in accordance with the agency's ``red light'' rules.93  We 
order Telecom House to submit within thirty days, either as part 
of its response to this NAL or separately, a report, supported by 
a sworn statement or declaration under penalty of perjury of a 
corporate officer, stating its plan to come into compliance with 
the relevant payment and reporting rules discussed herein.  We 
further order Telecom House to file with USAC within thirty days 
all Annual Telecommunications Reporting Worksheets and amended 
Worksheets required under the Commission's rules from the date 
that Telecom House commenced providing telecommunications 
services in the United States to the date of this NAL.  

V.   ORDERING CLAUSES

     36.  ACCORDINGLY, IT IS ORDERED THAT, pursuant to section 
503(b) of the Communications Act of 1934, as amended,94 and 
section 1.80 of the Commission's rules,95 that Telecom House is 
hereby NOTIFIED of its APPARENT LIABILITY FOR A FORFEITURE in the 
amount of $529,300 for willfully and repeatedly violating the Act 
and the Commission's rules.

     37.  IT IS FURTHER ORDERED THAT, pursuant to section 1.80 of 
the Commission's Rules,96 within thirty days of the release date 
of this NOTICE OF APPARENT LIABILITY, Telecom House SHALL PAY the 
full amount of the proposed forfeiture or SHALL FILE a written 
statement seeking reduction or cancellation of the proposed 
forfeiture.

     38.  IT IS FURTHER ORDERED THAT, pursuant to sections 4(i), 
219(b), and 254(d) of the Act,97 and sections 54.706(a) and 
54.711(a) of the Commission's rules,98 within thirty days of the 
release of this NOTICE OF APPARENT LIABILITY AND ORDER, Telecom 
House SHALL SUBMIT a report, supported by a sworn statement or 
declaration under penalty of perjury by a corporate officer, 
stating its plan promptly to come into compliance with the 
payment and reporting rules discussed herein.  Telecom House also 
SHALL SUBMIT to USAC within thirty days all Annual 
Telecommunications Reporting Worksheets and amended Worksheets 
required under the Commission's rules from the date that Telecom 
House commenced providing telecommunications services to the date 
of this NAL.

     39.  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/Acct. No. and FRN No. referenced above. Payment bycheck or 
money order may be mailed to Federal Communications Commission, 
P.O. Box358340,Pittsburgh, PA 15251-8340. Payment by overnight 
mail may be sent toMellon Bank/LB358340,500 Ross Street, Room 
1540670, Pittsburgh, PA 15251. Payment by wire transfer may be 
made to ABA Number043000261, receiving bankMellon Bank, and 
account number911-6106.

     40.  The response, if any, to this NOTICE OF APPARENT 
LIABILITY must be mailed to William H. Davenport, Chief, 
Investigations and Hearings Division, Enforcement Bureau, Federal 
Communications Commission, Room 4-A237, 445 12th Street, S.W., 
Washington, D.C.  20554 and must include the NAL/Acct. No. 
referenced above.

     41.  The Commission will not consider reducing or canceling 
a forfeiture in response to a claim of inability to pay unless 
the petitioner submits:  (1) federal tax returns for the most 
recent three-year period; (2) financial statements prepared 
according to generally accepted accounting practices (GAAP); or 
(3) some other reliable and objective documentation that 
accurately reflects the petitioner's current financial status.  
Any claim of inability to pay must specifically identify the 
basis for the claim by reference to the financial documentation 
submitted.

     42.  Requests for payment of the full amount of this NAL 
under an installment plan should be sent to Chief, Credit and 
Management Center, 445 12th Street, S.W., Washington, D.C.  
20554.99
     43.  IT IS FURTHER ORDERED that a copy of this NOTICE OF 
APPARENT LIABILITY AND ORDER shall be sent by certified mail, 
return receipt requested, to Douglas D. Orvis II, Esq., Swidler 
Berlin LLP, 3000 K Street, Suite 300, Washington, D.C. 20007-
5116; and Mr. Aaron Amid, Telecom House, Inc., 8421 Wilshire 
Boulevard, Suite 300, Beverly Hills, CA 90211.

                              FEDERAL COMMUNICATIONS COMMISSION




                              Marlene H. Dortch
                              Secretary 
_________________________

1 47 C.F.R.  64.1195.
2 47 C.F.R.  54.711(a), 64.604(c)(5)(iii)(B).
3 47 U.S.C.  254(d).  
4 47 C.F.R.  54.706(a), 64.604(c)(5)(iii)(A).
5 The Commission has appointed USAC as the administrator of 
federal universal service support mechanisms and has made it 
responsible for billing and collection of USF contributions.  47 
C.F.R.  54.701(a), 54.702(b).
6 See, e.g., 47 U.S.C.  151.
7 See Implementation of the Subscriber Carrier Selection 
Provisions of the Telecommunications Act of 1996, Third Report 
and Order and Second Order on Reconsideration, 15 FCC Rcd 15996, 
16024 (2000) (``Carrier Selection Order'').    
8 47 C.F.R.  64.1195.
9 Based on Telecom House's reported revenue for 2002, which it 
reported through its 2003 Form 499-A, it was a de minimis carrier 
in 2002, see 47 C.F.R.  54.708, and therefore was not required 
to file quarterly Worksheets in 2002.
10 See 47 U.S.C.  225(d)(3); 254(d).  In 1999, to streamline 
the administration of the programs and to ease the burden on 
regulatees, the Commission consolidated the information filing 
requirements for multiple telecommunications regulatory programs 
into the annual Telecommunications Reporting Worksheet.  See 1998 
Biennial Regulatory Review, Report and Order, 14 FCC Rcd 16602 
(1999).  The next year the Commission revised the 
Telecommunications Reporting Worksheet slightly to collect the 
additional information necessary to achieve its goal of 
establishing a central repository for interstate 
telecommunications providers by the least provider-burdensome 
method.  Carrier Selection Order, 15 FCC Rcd at 16026.  
11 The Telecommunications Act of 1996 amended the Communications 
Act of 1934.  See Telecommunications Act of 1996, Pub. L. No. 
104-104, 110 Stat. 56 (1996).
12 47 U.S.C.  254(d).  
13 47 C.F.R.  54.706(b).  Beginning April 1, 2003, carrier 
contributions were based on a carrier's projected, rather than 
historical, revenues.  Id.  
14 47 U.S.C.  225(b)(1).
15 See Telecommunications Relay Services and the Americans with 
Disabilities Act of 1990, Third Report and Order, 8 FCC Rcd 5300, 
5301,  7 (1993).  Telecommunications relay services enable 
persons with hearing and speech disabilities to communicate by 
telephone with persons who may or may not have such disabilities.  
Such services provide telephone access to a significant number of 
Americans who, without it, might not be able to make calls to or 
receive calls from others.  See Telecommunications Relay Services 
and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities, Report and Order, 15 FCC Rcd 5140, 5143,  5 
(2000).  The National Exchange Carriers Association (``NECA'') 
currently is responsible for administering the TRS Fund.
16 47 C.F.R.  64.604(c)(5)(iii)(A).  
17 Upon submission of a Form 499-A registration, the carrier is 
issued a filer identification number by USAC.  The filer 
identification number is then to be included on all further 
filings by the company and is used by the Commission and its 
administrators to track the carrier's contributions and invoices.  
With certain exceptions that have not applied to Telecom House 
since 2002, interstate telecommunications carriers must file FCC 
Form 499-Q quarterly, reporting revenue information by February 
1, May 1, August 1 and November 1 of each year, and FCC Form 499-
A annually, by April 1 of each year.  See Instructions for 
Completing the Worksheet for Filing Contributions to 
Telecommunications Relay Service, Universal Service, Number 
Administration and Local Number Portability Support Mechanisms, 
FCC Form 499, April 2004, at 9.
18 Individual universal service contribution amounts that are 
based upon quarterly filings are subject to an annual true-up.  
See Federal-State Joint Board on Universal Service, Petition for 
Reconsideration filed by AT&T, Report and Order and Order on 
Reconsideration, 16 FCC Rcd 5748 (2001); 47 C.F.R.  54.709(a).  
19 See Globcom, Inc., Notice of Apparent Liability for Forfeiture 
and Order, 18 FCC Rcd 19893, 19896,  5 (2003); 47 C.F.R.  
54.711(a) (``The Commission shall announce by Public Notice 
published in the Federal Register and on its website the manner 
of payment and the dates by which payments must be made.'').  
See, e.g., ``Proposed Third Quarter 2003 Contribution Factor,'' 
Public Notice, 18 FCC Rcd 11442 (WCB 2003) (``Contribution 
payments are due on the date shown on the [USAC] invoice.'').  
The Act and our rules, however, do not condition payment on 
receipt of an invoice or other notice from USAC.  See 47 U.S.C.  
254(d); 47 C.F.R.  54.706(b).  A carrier that does not file may 
not receive an invoice from USAC, but is nonetheless required to 
contribute to the universal service fund, unless its revenues are 
considered de minimis.  Globcom, Inc., 18 FCC Rcd at 19896,  5 & 
n.22.  The instructions for the Telecommunications Reporting 
Worksheet include tables for carriers to determine their annual 
contributions.  Telecom House has not qualified for the de 
minimis exception since 2002.
20 47 C.F.R.  54.713.
21 47 C.F.R.  1.1910.  The rule went into effect on November 1, 
2004.  See ``FCC Announces Brief Delay in Enforcement of Red 
Light Rule,'' Public Notice, 19 FCC Rcd 19452 (2004).
22 Response to Data Requests/Request for Documents, EB-04-IH-
0656, at 4, dated March 17, 2005 (``March 17, 2005 LOI 
Response'').  
23 See http://www.thouse.com/about.html.
24 See 47 C.F.R.  64.1195(a).
25 See Letter from Hugh Boyle, Chief Auditor, Investigations and 
Hearings Division, Enforcement Bureau, to Telecom House dated 
August 9, 2004 (``August 9, 2004 Audit Letter'').  
26 47 C.F.R.  64.1195.  Telecom House did not, however, 
apparently file any outstanding Worksheets on September 14, 2004.    
27 Letter from Hillary S. DeNigro, Deputy Chief, Investigations 
and Hearings Division, Enforcement Bureau, Federal Communications 
Commission, to Aaron Amid, Chief Executive Officer, Telecom 
House, Inc., dated January 26, 2005 (``January 26, 2005 LOI'').  
28 See supra note 22.
29 March 17, 2005 LOI Response, Exhibits 6-3, 6-6, & 8.  
Companies are required to report their previous year's revenue on 
Form 499-A.  Thus, Telecom House should have used the Form 499-A 
for 2003, 2004, and 2005 to report revenue for 2002, 2003, and 
2004, respectively.
30 Response to Supplemental Request, EB-04-IH-0656, Attachment 1, 
dated August 5, 2005 (``August 5, 2005 LOI Response'').  
31 Id.
32 Letter from Hillary S. DeNigro, Deputy Chief, Investigations 
and Hearings Division, Enforcement Bureau, Federal Communications 
Commission, to Douglas D. Orvis II, Swidler Berlin LLP, Counsel 
to Telecom House Incorporated, dated July 13, 2005 (``July 13, 
2005 LOI'').  
33 See supra note 30.
34 47 U.S.C.  503(b)(1)(B); 47 C.F.R.  1.80(a)(1).
35 47 U.S.C.  312(f)(1).
36 H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 51 (1982).
37 See, e.g., Application for Review of Southern California 
Broadcasting Co., Memorandum Opinion and Order, 6 FCC Rcd 4387, 
4388 (1991) (``Southern California Broadcasting Co.'').
38 See, e.g., Callais Cablevision, Inc., Grand Isle, Louisiana, 
Notice of Apparent Liability for Monetary Forfeiture, 16 FCC Rcd 
1359 (2001) (issuing a Notice of Apparent Liability for, inter 
alia, a cable television operator's repeated signal leakage).
39 Callais Cablevision, Inc., 16 FCC Rcd at 1362,  9; Southern 
California Broadcasting Co., 6 FCC Rcd at 4388,  5.
40 47 U.S.C.  503(b); 47 C.F.R.  1.80(f).
41 See, e.g., SBC Communications, Inc., Forfeiture Order, 17 FCC 
Rcd 7589, 7591,  4 (2002) (``SBC Forfeiture Order'') (forfeiture 
paid).
42 47 U.S.C.  254(d).
43 47 C.F.R.  54.706(a), 54.711(a), 64.604(c)(5)(iii)(B), 
64.1195.
44 47 C.F.R.  64.1195.
45 47 U.S.C.  254(d).
46 47 C.F.R.  54.706(a), 54.711(a), 64.604(c)(5)(iii)(B), 
64.1195.
47 47 C.F.R.  64.1195.
48 47 C.F.R.  64.1195(a); Carrier Selection Order, 15 FCC Rcd 
15996, 16025 (requiring existing carriers like Telecom House to 
register on the date the new registration requirement becomes 
effective by means of certain information in FCC Form 499-A); 66 
FR 17083 (2001) (announcing that OMB-approved information 
collection requirement in section 64.1195 would take effect on 
April 2, 2001).
49 Id.  The Commission adopted the registration requirement in 
section 64.1195(a) after finding that such a requirement would 
enable it to better monitor the entry of carriers into the 
interstate telecommunications market and any associated increases 
in slamming activity, and, among other things, would enhance the 
Commission's ability to take appropriate enforcement action 
against carriers that have demonstrated a pattern or practice of 
slamming.  See Carrier Selection Order, 15 FCC Rcd at 16024  62. 
50 See The Commission's Forfeiture Policy Statement and Amendment 
of Section 1.80 of the Commission's Rules, Report and Order, 12 
FCC Rcd 17087, 17099,  22 (1997) (``Forfeiture Policy 
Statement''), recon. denied, 15 FCC Rcd 303 (1999) (``The 
Commission expects, and it is each licensee's obligation, to know 
and comply with all of the Commission's rules.'').
51 See August 9, 2004 Audit Letter.  Further, Telecom House made 
no apparent efforts to pay its long overdue USF obligations, or 
to file its long overdue Worksheets, until after receiving a 
second letter from the Bureau in January 2005.
52 AT&T Wireless Services, Inc., Forfeiture Order, 17 FCC Rcd 
21866, 21870-71, (2002); America's Tele-Network Corp., Order of 
Forfeiture, 16 FCC Rcd 22350, 22355,  15 (2001); Coleman 
Enters., Inc. d/b/a/ Local Long Distance, Inc., Order of 
Forfeiture, 15 FCC Rcd 24385, 24388,  8 (2000).  
53 The proposed forfeitures in this NAL relate only to the 
portion of that period within a year of release of this NAL.
54 47 C.F.R.  54.711(a), 64.604(c)(5)(iii)(B).  
55 47 C.F.R.  54.711(a), 64.604(c)(5)(iii)(B).
56 Sixty days prior to the start of each quarter, USAC is 
required to provide the Commission with a projection of the high 
cost, low income, schools and libraries, and rural health care 
funding requirements for the following quarter.  See 
www.universalservice.org/overview/filings.  Based on USAC's 
projection of the needs of the USF, and revenue projections from 
the registered carriers subject to universal service 
requirements, the Commission establishes a specific percentage of 
interstate and international end-user revenues that each subject 
telecommunications provider must contribute toward the USF.  This 
percentage is called the contribution factor.  The contribution 
factor, and, consequently, the amount owed to the USF by each 
affected telecommunications company, changes each quarter, 
depending on the needs of the USF and carrier-provided revenue 
projections.  See www.fcc.gov/wcb/universal_service/quarter.  
Thus, in cases where a carrier, such as Telecom House, fails to 
file required Worksheets reporting its revenue projections in a 
timely fashion, its revenues are excluded from the contribution 
base from which universal assessments are derived, and the 
economic burden of contributing falls disproportionately on 
carriers that have satisfied their reporting obligations.   
57 47 U.S.C.  254(d).
58 47 U.S.C.  254.  
59 47 C.F.R.  54.711, 64.604.
60 47 U.S.C.  254(d); 47 C.F.R.  54.706.
61 47 C.F.R.  54.706(c).  
62 See 47 C.F.R.  54.706(c).      
63 Globcom, Inc., Notice of Apparent Liability for Forfeiture and 
Order, 18 FCC Rcd 19893, 19903,  26 (2003).
64 47 C.F.R.  64.604(c)(5)(iii)(A).
65 Id.  Each subject carrier must contribute at least $25 per 
year.  Carriers whose annual contributions are less than $1,200 
must pay the entire amount at the beginning of the contribution 
period.  47 C.F.R.  64.604(c)(5)(iii)(B).  Otherwise, carriers 
may divide their contributions into equal monthly payments.  Id.
66 47 C.F.R.  64.604(c)(5)(iii)(B).  
67 See id.
68 March 17, 2005 LOI Response (question #10).  
69 August 5, 2005 LOI Response (question #4).
70 Id. at Attachment 4.
71 47 U.S.C.  503(b)(1)(B); see also 47 C.F.R.  1.80(a)(2).
72 47 U.S.C.  503(b)(2)(B); see also 47 C.F.R.  1.80(b)(2).  
Effective September 7, 2004, the Commission amended its rules to 
increase the maximum penalties to account for inflation since the 
last adjustment of the penalty rates.  See Amendment of Section 
1.90 of the Commission's Rules, Order, 19 FCC Rcd 10945, 10946  
6 (2004).
73 47 U.S.C.  503(b)(2)(D); see also Forfeiture Policy 
Statement, 12 FCC Rcd at 17100,  27; 47 C.F.R.  1.80(b).
74 47 U.S.C.  503(b)(6)(B); see also 47 C.F.R.  1.80(c)(3).
75 See, e.g., Carrera Communications, LP, Notice of Apparent 
Liability for Forfeiture and Order, FCC 05-147, 2005 WL 1750417 
(F.C.C.) at  24 (released July 25, 2005); InPhonic, Inc., Notice 
of Apparent Liability for Forfeiture and Order, FCC 05-145, 2005 
WL 1750418 (F.C.C.) at  24 (released July 25, 2005); 
Teletronics, Inc., Notice of Apparent Liability for Forfeiture 
and Order, FCC 05-146, 2005 WL 1750420 (F.C.C.) at  28 (released 
July 25, 2005); Globcom, Inc., 18 FCC Rcd at 19903; Roadrunner 
Transp., Inc., Forfeiture Order, 15 FCC Rcd 9669, 9671 (2000); 
Liab. of E. Broad. Corp., Memorandum Opinion and Order, 10 F.C.C. 
2d 37 (1967).

76 See InPhonic, Inc., 2005 WL at 1750418 (F.C.C.) at  25; 
Teletronics, Inc., 2005 WL 1750420 (F.C.C.) at  29.
77 See InPhonic, Inc., 2005 WL at 1750418 (F.C.C.) at  26; 
Teletronics, Inc., 2005 WL 1750420 (F.C.C.) at   30.
78 InPhonic, Inc., 2005 WL at 1750418 (F.C.C.) at  26; 
Teletronics, Inc., 2005 WL 1750420 (F.C.C.) at  30.
79 InPhonic, Inc., 2005 WL at 1750418 (F.C.C.) at  26; 
Teletronics, Inc., 2005 WL 1750420 (F.C.C.) at  30.
80 Globcom, Inc., 18 FCC Rcd at 19905.  See also Carrera 
Communications, Inc., 2005 WL 1750417 (F.C.C.) at  25; InPhonic, 
Inc., 2005 WL 1750418 (F.C.C.) at  27; Teletronics, Inc., 2005 
WL 1750420 (F.C.C.) at  31.
81 See 47 U.S.C.  254(d).
82 See Globcom, Inc., 18 FCC Rcd at 19903-19904,  25-27.  See 
also Carrera Communications, Inc., 2005 WL 1750417 (F.C.C.) at  
26; InPhonic, Inc., 2005 WL 1750418 (F.C.C.) at  28; Telecom 
Mgmt., Inc., Notice of Apparent liability for Forfeiture, FCC 05-
156 2005 WL 1949643 (F.C.C.) at   17 (released Aug. 12, 2005); 
Teletronics, Inc., 2005 WL 1750420 (F.C.C.) at  32.
83 See, e.g., Globcom, Inc., 18 FCC Rcd at 19903-19904,  25-27.  
See also Carrera Communications, Inc., 2005 WL 1750417 (F.C.C.) 
at   27; InPhonic, Inc., 2005 WL 1750418 (F.C.C.) at   29; 
OCMC, Inc., Notice of Apparent Liability for Forfeiture, FCC 05-
157, 2005 WL 1949644 (F.C.C.) at  19; Telecom Mgmt., Inc., 2005 
WL 1949643 (F.C.C.) at   18; Teletronics, Inc., 2005 WL 1750420 
(F.C.C.) at  32.
84 See supra 13.  Telecom House made its first USF payment of 
$9,802.62 on August 24, 2005, but payment was due nearly ten days 
before, and in any event, as explained above, the vast majority 
of that amount corresponds to a partial payment for its overdue 
balance due for 2003 and 2004.
85 The first figure ($12,794) is one half of the amount USAC 
calculated that Telecom House owes to the USF for 2003, 2004, and 
the late-paid sum for one month of the third quarter of 2005; the 
second figure ($5,430) is one half of the amount that we estimate 
Telecom House owes to the USF for the first and second quarters 
of 2005.
86 47 U.S.C.  225(b)(1).
87 See Globcom, Inc., 18 FCC Rcd at 19904,  29.  See also 
Carrera Communications, Inc., 2005 WL 1750417 (F.C.C.) at   29; 
InPhonic, Inc., 2005 WL 1750418 (F.C.C.) at   31; Teletronics, 
Inc., 2005 WL 1750420 (F.C.C.) at   34.
88 See Globcom, Inc., 18 FCC Rcd at 19904,  29.  See also 
Carrera Communications, Inc., 2005 WL 1750417 (F.C.C.) at   29; 
InPhonic, Inc., 2005 WL 1750418 (F.C.C.) at  31; Teletronics, 
Inc., 2005 WL 1750420 (F.C.C.) at   34.
89 See August 5, 2005 LOI Response at Attachment 4.
90 Forfeiture Policy Statement, 12 FCC Rcd at 17099; see also 47 
C.F.R.  1.80(b)(4).
91 47 C.F.R.  64.1195.
92 See Business Options, Inc., Consent Decree, 19 FCC Rcd 2916 
(2003); NOS Communications, Inc., Affinity Network Incorporated 
and NOSVA Limited Partnership, Consent Decree, 2003 WL 22439710 
(2003).
93 47 C.F.R.  1.1910.
94 47 U.S.C.  503(b).
95 47 C.F.R.  1.80.
96 See 47 C.F.R.  1.80(f)(3).
97 47 U.S.C.  4(i), 219(b), and 254(d).
98 47 C.F.R.  54.706(a) and 54.711(a).
99 See 47 C.F.R.  1.1914.