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Federal Communications Commission
Washington, DC 20554
In the Matter of
) File No.: EB-TCD-12-00000438
Compliance with the Commission's
) Acct. No.: 201332170006
Rules and Regulations Governing
Customer ) FRN: 0018626853
Proprietary Network Information )
Adopted: December 4, 2012 Released: December 4, 2012
By the Chief, Enforcement Bureau:
1. In this Order, we adopt the attached Consent Decree entered into
between the Enforcement Bureau (Bureau) of the Federal Communications
Commission (Commission) and CenturyLink, Inc. (CenturyLink or
Company). The Consent Decree terminates the investigation initiated by
the Bureau regarding CenturyLink's compliance with Section 222(c)(1)
of the Communications Act of 1934, as amended, 47 U.S.C. S: 222(c)(1),
and Section 64.2007 of the Commission's rules, 47 C.F.R. S: 64.2007.
2. The Bureau and CenturyLink have negotiated the terms of the Consent
Decree that resolves these matters. A copy of the Consent Decree is
attached hereto and incorporated by reference.
3. After reviewing the terms of the Consent Decree and evaluating the
facts before us, we find that the public interest would be served by
adopting the Consent Decree and terminating the referenced
4. In the absence of material new evidence relating to this matter, we
conclude that our investigation raises no substantial or material
questions of fact as to whether CenturyLink possesses the basic
qualifications, including those related to character, to hold or
obtain any Commission license or authorization.
5. Accordingly, IT IS ORDERED, pursuant to Section 4(i) of the
Communications Act of 1934, as amended, 47 U.S.C. S: 154(i), and the
authority delegated by Sections 0.111 and 0.311 of the Commission's
rules, 47 C.F.R S:S: 0.111, 0.311, that the attached Consent Decree IS
6. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED.
7. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree
shall be sent by first class mail and certified mail, return receipt
requested, to John E. Benedict, Vice President - Federal Regulatory
Affairs & Regulatory Counsel, CenturyLink, 1099 New York Avenue, N.W.,
Suite 250, Washington, DC 20001.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
Federal Communications Commission
Washington, DC 20554
In the Matter of )
CenturyLink, Inc. )
File No.: EB-TCD-12-00000438
Compliance with the Commission's )
Acct. No.: 201332170006
Rules and Regulations Governing )
Customer FRN: 0018626853
Proprietary Network Information
1. The Enforcement Bureau of the Federal Communications Commission and
CenturyLink, Inc., by their authorized representatives, hereby enter
into this Consent Decree for the purpose of terminating the
Enforcement Bureau's investigation regarding CenturyLink, Inc.'s
compliance with Section 222(c)(1) of the Communications Act of 1934,
as amended, and Section 64.2007 of the Commission's rules.
2. For purposes of this Consent Decree, the following definitions shall
a. "Act" means the Communications Act of 1934, as amended, 47 U.S.C. S:
151 et seq.
b. "Adopting Order" means an order of the Bureau adopting the terms and
conditions of this Consent Decree without change, addition, or
c. "Affiliate" shall have the same meaning defined in section 153(2) of
the Communications Act. 47 U.S.C. S:153(2).
d. "Bureau" means the Enforcement Bureau of the Federal Communications
e. "CenturyLink" or "Company" means CenturyLink, Inc., its Affiliates,
and its predecessors-in-interest and successors-in-interest, but
excludes Qwest Communications International, Inc. and its affiliates
existing as of March 31, 2011 (Qwest). To the extent that any Qwest
customers are integrated into CenturyLink's legacy systems for CPNI
opt-out, they shall be included as part of CenturyLink for purposes
of this Consent Decree.
f. "Commission" and "FCC" mean the Federal Communications Commission and
all of its bureaus and offices.
g. "Communications Laws" means collectively, the Act, the Rules, and the
published and promulgated orders and decisions of the Commission to
which CenturyLink is subject by virtue of its business activities,
including, but not limited to, the CPNI Rules.
h. "Compliance Plan" means the compliance obligations, program, and
procedures described in this Consent Decree at paragraph 10.
i. "Covered Employees" means all employees and agents of CenturyLink who
perform, supervise, oversee, or manage the performance of, duties
relating to the management of CenturyLink's CPNI opt-out programs.
j. "CPNI Rules" means Section 222 of the Act, 47 U.S.C. S: 222, and the
rules set forth at Section 64.2001 et. seq., 47 C.F.R. S: 64.2001 et
k. "Effective Date" means the date on which the Bureau releases the
l. "Investigation" means the Bureau's investigation regarding
CenturyLink's compliance with Section 222 of the Communications Act,
47 U.S.C. S: 222, and Section 64.2007 of the Commission's Rules, 47
C.F.R. S: 64.2007, commenced by the Bureau's December 3, 2010 Letter
of Inquiry to CenturyLink described in paragraph 4 below.
m. "Operating Procedures" means the standard, internal operating
procedures and compliance policies established by CenturyLink to
implement the Compliance Plan.
n. "Parties" means CenturyLink and the Bureau, each of which is a
o. "Rules" means the Commission's regulations found in Title 47 of the
Code of Federal Regulations.
3. Pursuant to Section 222 of the Act, the Commission has adopted rules to
protect the confidentiality of customer proprietary network information
(CPNI). These rules generally require customer approval before a carrier
may use, disclose, or permit access to CPNI.
4. On September 21, 2010, pursuant to section 64.2009(f) of the
Commission's rules, CenturyLink filed a notice with the Commission
reporting failures in its CPNI opt-out mechanism. According to
CenturyLink, it sent biennial CPNI notices to its customers in September
and early October 2009. The company states, however, that on September 16,
2010, it discovered that one of its interactive voice response systems
(IVR) had not been properly recording opt-out selections for calls made to
that toll-free number. The Bureau issued a letter of inquiry (LOI) to
CenturyLink on December 3, 2010. CenturyLink submitted its response to the
LOI on January 7, 2011. The Parties entered into agreements to toll the
statute of limitations to give the Parties an opportunity to engage in
settlement discussions leading to this Consent Decree.
IV. TERMS OF AGREEMENT
5. Adopting Order. The Parties agree that the provisions of this Consent
Decree shall be subject to final approval by the Bureau by incorporation
of such provisions by reference in the Adopting Order.
6. Jurisdiction. CenturyLink agrees that the Bureau has jurisdiction over
it and the matters contained in this Consent Decree and that the Bureau
has the authority to enter into and adopt this Consent Decree.
7. Effective Date; Violations. The Parties agree that this Consent Decree
shall become effective on the Effective Date. Upon the Effective Date, the
Adopting Order and this Consent Decree shall have the same force and
effect as any other order of the Commission. Any violation of the Adopting
Order or of the terms of this Consent Decree shall constitute a separate
violation of a Commission order, entitling the Commission to exercise any
rights and remedies attendant to the enforcement of a Commission order.
8. Termination of Investigation. In express reliance on the covenants and
representations contained herein, and to avoid expenditure of additional
public resources, the Bureau agrees to terminate the Investigation. In
consideration for the termination of said Investigation and in accordance
with the terms of this Consent Decree, CenturyLink agrees to the terms,
conditions, and procedures contained herein. The Bureau further agrees
that, in the absence of new material evidence related to the
Investigation, it will not use the facts developed in the Investigation
through the Effective Date, or the existence of this Consent Decree to
institute, on its own motion, or refer to the Commission, any new
proceeding, formal or informal, or take, on its own motion, or refer to
the Commission, any action against CenturyLink, concerning the matters
that were the subject of the Investigation, or with respect to
CenturyLink's basic qualifications, including its character
qualifications, to be a Commission licensee or hold other Commission
9. Section 208 Complaints; Subsequent Investigations. Nothing in this
Consent Decree shall prevent the Commission or its delegated authority
from adjudicating complaints filed pursuant to section 208 of the Act
against CenturyLink for alleged violations of the Act, or for any other
type of alleged misconduct, regardless of when such misconduct took place.
The Commission's adjudication of any such complaint will be based solely
on the record developed in that proceeding. Except as expressly provided
in this Consent Decree, this Consent Decree shall not prevent the
Commission from investigating new evidence of noncompliance by CenturyLink
of the Act, the Commission's Rules, or the Adopting Order.
10. Compliance Plan. For purposes of settling the matters set forth
herein, CenturyLink agrees that it shall within thirty (30) calendar days
after the Effective Date, develop and implement a Compliance Plan,
consistent with its responsibility to ensure future compliance with the
Communications Laws, including the CPNI Rules, and with the terms and
conditions of this Consent Decree. The Compliance Plan shall include,
without limitation, the following components:
a. Compliance Officer. Within fifteen (15) calendar days after the
Effective Date, CenturyLink shall designate a senior corporate manager
with the requisite corporate and organizational authority to serve as
Compliance Officer and to discharge the duties set forth below. The person
designated as the Compliance Officer shall be responsible for developing,
implementing, and administering the Compliance Plan and ensuring that
CenturyLink complies with the terms and conditions of the Compliance Plan
and this Consent Decree. In addition to the general knowledge of the
Communications Laws necessary to discharge his/her duties under this
Consent Decree, the Compliance Officer shall have specific knowledge of
the CPNI Rules prior to assuming his/her duties.
b. Compliance Operating Procedures. To help ensure that IVR CPNI requests
are properly recorded, CenturyLink shall maintain the following Operating
Procedures regarding its use of any IVRs to record opt-out requests:
i. A Covered Employee within the Company's marketing organization shall
serve as Manager of Reporting Quality with responsibility of monitoring
the IVR opt-out process end-to-end to ensure the transactions are being
recorded with all necessary data. The Manager of Reporting Quality
reports directly to the Company's Product Operations Manager and
indirectly to the Senior Vice President - Marketing, whose organization
oversees all consumer and small to large business marketing, including
use of CPNI for CenturyLink marketing.
ii. The Company shall maintain an alarm function to make sure the IVR is
working and accepting calls. The alarm function is specialized
software tied to the phone system that dials the telephone numbers for
the CPNI IVR 800 routing numbers continuously. If it detects an
inactive line, it will alert the relevant CenturyLink staff to take
action. Monitoring will be provided 24 hours per day, 7 days per week,
by the Customer Care Team.
iii. CenturyLink shall use an automated dashboard reporting system that
generates data on opt-out elections and the IVR's results, so that any
drops in volumes of opt-out elections will be noticeable. The automated
dashboard reporting system shall track the activity on the IVR for
elections, generating both summary and detail data. The summary data shall
provide an overview of election volumes by day, and therefore, would
reveal any sudden drops in activity. The detail data shall include a test
account number and a telephone number, both of which are changed each
business day. The dashboard reporting system shall allow the company to
ensure the values, including customers' CPNI elections, are properly
captured and written to the system report. This report shall be reviewed
each business day by the Manager of Quality Reporting.
iv. CenturyLink shall monitor the IVR's performance each business day.
Specifically, the Manager of Reporting Quality (or his or her designee)
shall monitor the IVR's performance by telephoning the IVR each business
day to confirm it is answering properly, giving the correct prompts, and
operating correctly. This is in addition to the monitoring of the alarm
functionality by the IVR Customer Care Team.
v. CenturyLink shall confirm each business day that data from CPNI
elections entered via the IVR is properly transferred to CenturyLink's
billing system and marketing database. Specifically, the Manager of
Reporting Quality (or his or her designee) shall enter a sample CPNI
opt-in/opt-out election at the IVR and track that the request registers
properly from the CenturyLink IVR to the billing system and marketing
database. If the sample opt-in/opt-out request does not register properly,
the Manager of Reporting Quality shall analyze why and initiate repair and
resolution. The Manager of Reporting Quality shall also immediately call
an internal "red flag" meeting (or high priority meeting with notice to
top marketing and systems management). During the repair, calls to the IVR
shall be rerouted 24/7 to a live operator to receive opt-in/opt-out
selections. Additionally, marketing use of CPNI shall cease immediately
until the error with the data feed is identified and corrected.
vi. Any changes, additions, or deletions to the IVR system (or any systems
that interact with the IVR system) shall be coordinated through the
Manager of Reporting Quality to ensure there is no negative effect on the
IVR system as a result of such change, addition, or deletion.
c. Compliance Manual. Within sixty (60) calendar days after the Effective
Date, the Compliance Officer shall develop and distribute a Compliance
Manual to all Covered Employees. The Compliance Manual may be made
available and distributed by electronic means. The Compliance Manual shall
explain the CPNI Rules and set forth the Operating Procedures that Covered
Employees shall follow to help ensure CenturyLink's compliance with the
CPNI Rules. CenturyLink shall periodically review and revise the
Compliance Manual, as necessary, to ensure that the information set forth
therein remains current and complete. CenturyLink shall distribute any
revisions to the Compliance Manual promptly to all Covered Employees.
d. Compliance Training Program. CenturyLink shall establish and implement
a Compliance Training Program on compliance with the CPNI Rules and the
Operating Procedures. As part of the Compliance Training Program, Covered
Employees shall be advised of CenturyLink's obligation to report any
noncompliance with the CPNI Rules under paragraph 11 of this Consent
Decree and shall be instructed on how to disclose such noncompliance to
the Compliance Officer. All Covered Employees shall be trained pursuant to
the Compliance Training Program within sixty (60) calendar days after the
Effective Date, except that any person who becomes a Covered Employee at
any time after the Effective Date shall be trained within thirty (30)
calendar days after the date such person becomes a Covered Employee.
CenturyLink shall repeat the compliance training on an annual basis and
shall periodically review and revise the Compliance Training Program, as
necessary, to ensure that it remains current and complete and to enhance
11. Reporting Non-Compliance. CenturyLink shall report to the Bureau any
non-compliance with this Consent Decree within 15 calendar days after the
discovery of non-compliance. CenturyLink shall also: (i) report to the
Bureau any non-compliance with requirements relating to approval for use
of CPNI, as set forth in Section 64.2007 of the Rules, within 15 calendar
days after discovery of such non-compliance; (ii) report to the Bureau any
non-compliance with requirements relating to notice for use of CPNI, as
set forth in Section 64.2008 of the Rules, within 15 days after discovery
of non-compliance; (iii) report to the Bureau any non-compliance with the
requirements relating to safeguards for use of CPNI, as set forth in
Section 64.2009 of the Rules; and (iv) simultaneously provide to the
Bureau a confidential copy of all notifications that CenturyLink submits
to law enforcement, pursuant to Section 64.2011(a) of the Rules. The
reports required by this paragraph shall include a detailed explanation of
(i) each instance of non-compliance; (ii) the steps that CenturyLink has
taken or will take to remedy such non-compliance; (iii) the schedule on
which such remedial actions will be taken; and (iv) the steps that
CenturyLink has taken or will take to prevent the recurrence of any such
non-compliance. All reports of non-compliance and notifications shall be
submitted to the Chief, Telecommunications Consumers Division, Enforcement
Bureau, Federal Communications Commission, 445 12th Street SW, Washington,
DC 20554, with a copy submitted electronically to Donna Cyrus at
12. Compliance Reports. The Compliance Officer, as an agent of and on
behalf of CenturyLink, shall file compliance reports ninety (90) calendar
days after the Effective Date, six (6) months after the Effective Date,
one (1) year after the Effective Date, and at the end of the two (2) year
a. Each compliance report shall include a detailed description of
CenturyLink's efforts during the relevant period to comply with the terms
and conditions of this Consent Decree and the Commission's CPNI Rules
b. Each compliance report shall include a certification by the Compliance
Officer, as an agent of and on behalf of CenturyLink, stating that the
Compliance Officer has personal knowledge that CenturyLink (A) has
established and implemented the Compliance Plan; (B) has been following
all aspects of the Compliance Plan for the entire term of the Consent
Decree; and (C) is not aware of any instances of non-compliance with the
terms and conditions of this Consent Decree-including the reporting
obligations set forth in paragraph 11 above-that have not been disclosed
as required by paragraph 11 above. The certification shall be accompanied
by a statement explaining the basis for the certification and must comply
with Section 1.16 of the Rules, and be subscribed to as true under penalty
c. If the Compliance Officer cannot provide the requisite certification,
the Compliance Officer, as an agent of and on behalf of CenturyLink, shall
provide the Commission with a detailed explanation of the reason(s) why
and describe fully (A) each instance of non-compliance; (B) the steps that
CenturyLink has taken or will take to remedy such non-compliance,
including the schedule on which proposed remedial actions will be taken;
and (C) the steps that CenturyLink has taken or will take to prevent
recurrence of any such non-compliance, including the schedule on which
such preventive action will be taken.
d. All Compliance Reports must be mailed within fifteen (15) calendar days
of the one (1) and the two (2) year anniversary of the Effective Date, and
submitted to the Chief, Telecommunications Consumers Division, Enforcement
Bureau, Federal Communications Commission, 445 12th Street, S.W.,
Washington, D.C. 20554, and must include the file number listed above.
CenturyLink shall also send an electronic copy of its certification to
Donna Cyrus at email@example.com.
13. Termination Date. The obligations set forth in paragraphs 10 through
12 of this Consent Decree shall expire twenty-four (24) months after the
Effective Date, except that the Compliance Report requirement shall expire
twenty-four months and sixteen calendar days after the Effective Date.
Additionally, in the event that the opt-out requirements set forth in
sections 64.2001-2009 of the Commission's Rules (47 C.F.R. S:S:
64.2001-2009) are repealed, this Consent Decree shall be terminated when
the action repealing the rules becomes final.
14. Voluntary Contribution. CenturyLink agrees that it will make a
voluntary contribution to the United States Treasury in the amount of one
hundred, fifty thousand dollars ($150,000) within thirty (30) calendar
days after the Effective Date. CenturyLink shall also send electronic
notification of payment to Johnny Drake at firstname.lastname@example.org on the
date said payment is made. The payment must be made by check or similar
instrument, wire transfer, or credit card, and must include the Account
Number and FRN referenced above. Regardless of the form of payment, a
completed FCC Form 159 (Remittance Advice) must be submitted. When
completing the FCC Form 159, enter the Account Number in block number 23A
(call sign/other ID) and enter the letters "FORF" in block number 24A
(payment type code). Below are additional instructions you should follow
based on the form of payment you select:
* Payment by check or money order must be made payable to the order of
the Federal Communications Commission. Such payments (along with the
completed Form 159) must be mailed to Federal Communications
Commission, P.O. Box 979088, St. Louis, MO 63197-9000, or sent
via overnight mail to U.S. Bank - Government Lockbox #979088,
SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101.
* Payment by wire transfer must be made to ABA Number 021030004,
receiving bank TREAS/NYC, and Account Number 27000001. To complete
the wire transfer and ensure appropriate crediting of the wired funds,
a completed Form 159 must be faxed to U.S. Bank at (314) 418-4232 on
the same business day the wire transfer is initiated.
* Payment by credit card must be made by providing the required credit
card information on FCC Form 159 and signing and dating the Form 159
to authorize the credit card payment. The completed Form 159 must then
be mailed to Federal Communications Commission, P.O. Box 979088, St.
Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank -
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St.
Louis, MO 63101.
If you have questions regarding payment procedures, please contact the
Financial Operations Group Help Desk by phone, 1-877-480-3201, or by
15. Waivers. Provided the Bureau issues an Adopting Order, CenturyLink
waives any and all rights it may have to seek administrative or judicial
reconsideration, review, appeal or stay, or to otherwise challenge or
contest the validity of this Consent Decree and the Adopting Order.
CenturyLink shall retain the right to challenge the Commission's
interpretation of the Consent Decree or any terms contained herein, and of
the Commission's Rules. If either Party (or the United States on behalf of
the Commission) brings a judicial action to enforce the terms of the
Adopting Order or this Consent Decree, neither CenturyLink nor the Bureau
shall contest the validity of the Consent Decree or the Adopting Order,
and CenturyLink shall waive any statutory right to a trial de novo with
respect to the issuance of the Adopting Order and shall consent to a
judgment incorporating the terms of this Consent Decree. CenturyLink
hereby agrees to waive any claims it may otherwise have under the Equal
Access to Justice Act, 5 U.S.C. S: 504 and 47 C.F.R. S: 1.1501 et seq.,
relating to the matters contained in this Consent Decree.
16. Severability. The Parties agree that if any of the provisions of the
Adopting Order or the Consent Decree shall be invalid or unenforceable,
such invalidity or unenforceability shall not invalidate or render
unenforceable the entire Adopting Order or Consent Decree, but rather the
entire Adopting Order or Consent Decree shall be construed as if not
containing the particular invalid or unenforceable provision or
provisions, and the rights and obligations of the Parties shall be
construed and enforced accordingly. In the event that this Consent Decree
in its entirety is rendered invalid by any court of competent
jurisdiction, it shall become null and void and may not be used in any
manner in any legal proceeding.
17. Privileged and Confidential Documents. By this Consent Decree,
CenturyLink neither waives nor alters its right to assert and seek
protection from disclosure of any privileged or otherwise confidential and
protected documents and information, or to seek appropriate safeguards of
confidentiality for any competitively sensitive or proprietary
18. Subsequent Rule or Order. The Parties agree that if any provision of
this Consent Decree is inconsistent with any subsequent rule or order
adopted by the Commission, that provision will be superseded by such
Commission rule or order.
19. Successors and Assigns. CenturyLink agrees that the provisions of this
Consent Decree shall be binding on its successors, assigns, and
20. Final Settlement. The Parties agree and acknowledge that this Consent
Decree shall constitute a final settlement between the Parties with
respect to the Investigation. The Parties further agree that this Consent
Decree does not constitute either adjudication on the merits or a factual
or legal finding or determination regarding any compliance or
noncompliance with the Communications Laws.
21. Modifications. This Consent Decree cannot be modified or amended
without the advance written consent of both Parties.
22. Paragraph Headings. The headings of the paragraphs in this Consent
Decree are inserted for convenience only and are not intended to affect
the meaning or interpretation of this Consent Decree.
23. Counterparts. This Consent Decree may be signed in counterparts
(including by facsimile or electronic mail), each of which, when executed
and delivered, shall be an original, and all of which counterparts
together shall constitute one and the same fully executed instrument.
24. Authorized Representative. The individual signing this Consent Decree
on behalf of CenturyLink represents and warrants that he is authorized by
CenturyLink to execute this Consent Decree and to bind CenturyLink to the
obligations set forth herein. The FCC signatory represents that she is
signing this Consent Decree in her official capacity and that she is
authorized to execute this Consent Decree.
For: Federal Communications Commission
P. Michele Ellison
For: CenturyLink, Inc.
John E. Benedict
Vice President - Federal Regulatory Affairs & Regulatory Counsel
This case was formerly assigned the File No. EB-10-TC-485. In January
2011, the Telecommunications Consumers Division assigned a new case
This case was formerly assigned the file number EB-10-TC-485. In January
2011, the Telecommunications Consumers Division assigned a new case
47 U.S.C. S: 222(c)(1).
47 C.F.R. S: 64.2007.
The FCC approved CenturyLink, Inc.'s merger with Qwest Communications
International, Inc. on March 18, 2011. The transaction closed on April 1,
47 U.S.C. S: 222.
47 C.F.R. S: 64.2007.
47 C.F.R. S: 64.2009(f).
See Notification Pursuant to 47 C.F.R.S: 64.2009(f); CC Docket No. 96-115,
Letter from Susan T. Pate, Manager, Business Product Systems Integration,
CenturyLink, Inc., to William Dever, Chief, Competition Policy Division,
FCC Wireline Competition Bureau, and Colleen Heitkamp, Chief, FCC Consumer
Policy Division, Consumer & Governmental Affairs Bureau (September 21,
2010) (on file in EB-TCD-12-00000438).
See Letter of Inquiry from Kimberly A. Wild, Assistant Division Chief,
Telecommunications Consumers Division, FCC Enforcement Bureau, to Susan T.
Pate, Manager, Business Product Systems Integration, CenturyLink, Inc.
(December 3, 2010) (on file in EB-TCD-12-00000438).
See Letter from Carrick B. Inabnett, Vice President and Assistant General
Counsel, CenturyLink, Inc., to Kristi Thompson, Deputy Division Chief,
Telecommunications Consumers Division, FCC Enforcement Bureau (January 7,
2011) (on file in EB-TCD-12-00000438).
47 C.F.R. S: 1.16.
An FCC Form 159 and detailed instructions for completing the form may be
obtained at http://www.fcc.gov/Forms/Form159/159.pdf.
Federal Communications Commission DA 12-1925
Federal Communications Commission DA 12-1925