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See discussion supra 25.M  X3' B.Reasonableness of MCI's Practices  X 48.` ` As explained below, our order reaches two conclusions: (1) that the Tariff is not clear and explicit as required by section 61.2 of the Commission's rules, which renders the Tariff unreasonable in violation of section 201(b) of the Act; and (2) that the Tariff MCI's practice of assessing "NonSubscriber" perminute rates and percall surcharges on interexchange calls originating on lines presubscribed to MCI's interexchange service is unreasonable in violation of section 201(b) of the Act. We note, however, that these two conclusions are interrelated, because they stem from two sections of the Act, 201(b) and 203, that are directed at reaching the same goal, requiring that the tariffing practices of carriers be reasonable. That is, it is an unreasonable practice for a carrier to file a tariff that contains terms that consumers will not understand. In the first instance, we find that consumers cannot understand the Tariff because it contains insufficient explanatory information. In the second instance, we find that consumers would not understand the Tariff, even if MCI were to provide further explanatory information, because the Tariff's distinctions between Subscriber and NonSubscriber rates are inherently confusing. " %\+''qq "Ԍ X4 1.` ` MCI's Tariff Terms are Not "Clear and Explicit. "  X49.` ` Section 201(b) of the Act requires that all of MCI's charges, practices, classifications, and regulations for the provision of communications services be just and  X4reasonable.&U {O'ԍ47 U.S.C.  201(b); See Halprin Complaint at 7; Freedom Complaint at 7; MCI Halprin Answer at 10; MCI Freedom Answer at 10.. To further this statutory obligation, Part 61.2 of the Commission's rules requires that all tariff publications must contain clear and explicit explanatory statements regarding  Xv4rates and regulations.E'v"U yOI 'ԍ47 C.F.R.  61.2.E In addition, we must construe any ambiguities in tariffs against the  X_4filing carrier.Y(\_U {O 'ԍThe Associated Press Request for Declaratory Ruling, Memorandum, Opinion and Order, 72 F.C.C. 2d  {O '760, 76465 (1979) (quoting Commodity News Services, Inc. v. Western Union, 29 FCC 1208, 1213, aff'd 29  yOV'FCC 1205 (1960)). Y  X14 10.` ` Complainants contend that the Tariff is vague and ambiguous regarding the circumstances that trigger the application of MCI's NonSubscriber rates to directdialed  X 4interexchange calls.N) U yO'ԍComplainants' Brief at 1617.N Complainants focus on the portion of the Tariff providing when MCI will charge its NonSubscriber perminute rates and percall surcharges for directdialed calls. Xcalls which are placed by a person, firm corporation or other entity that: . . .  X 4remains presubscribed to MCI service after its account(s) are removed from MCI's billing system, subsequently continues to use MCI's network, and is  X{4billed for such use by a local exchange carrier, the Company or its agents.*{f U yO'ԍMCI Tariff F.C.C. No. 1, 4th revised page No. 18.3.1; MCI Tariff F.C.C. No. 1, 134th revised page No. 19.1 (emphasis added).  Complainants argue that the Tariff is unclear because it does not identify the circumstances  X64under which MCI removes a customer's account from its billing system.T+6 U yO'ԍ Complainants' Brief at 1617.T  X4 11.` ` MCI claims that the challenged Tariff terms are unambiguous.,N U yO#'ԍMCI Brief at 9, 14; Reply Brief of MCI at 6 (filed August 3, 1998) (MCI Reply Brief). In addition,  X4MCI submitted supplemental explanations concerning the meaning of the terms at issue.F-U yO%'ԍMCI Reply Brief at 6.F According to MCI, those terms mean that directdialed calls are subject to NonSubscriber"n-\+''qq" perminute rates and percall surcharges only when "the account was terminated for customer  X4violation of the terms and conditions of its contract with MCI or because the customer chose  X4not to set up a customer account."R.U {OM'ԍId. (emphasis in original).R  X4 12.` ` We reject MCI's claim that the Tariff is unambiguous for several reasons. First, the supplemental explanation offered by MCI is not consistent with the facts here. Neither complainant had entered into a contract with MCI for the provision of service to the  Xa4Numbers. Nor had either complainant "[chosen] not to set up a customer account." Indeed, Complainants never even knew that the Numbers had been presubscribed to MCI. Second, MCI's explanation does not square with the actual text of the Tariff, which describes "removal" of the account from MCI's billing system as the triggering event for the imposition of NonSubscriber rates. Removal presupposes an existing account not that a customer refrained from setting up a customer account in the first place.  X 4 13.` ` In any event, in evaluating whether the Tariff is clear and explicit, we must  X 4look solely to the terms used in the Tariff, not to MCI's postfiling explanations./ ZU {O'ԍAssociated Press, 72 F.C.C. 2d 760, 76465 ("Tariffs are to be interpreted according to the reasonable construction of their language; neither the intent of the framers nor the practice of the carrier controls, for the user cannot be charged with knowledge of such intent or with the carrier's canon of construction . . . However, if there is an ambiguity in tariffs they should be construed against the framer and favorably to users . . ..")  {O'(quoting Commodity News Services, Inc. v. Western Union, 29 FCC 1208, 1213, aff'd 29 FCC 1205 (1960)).  Those terms do not clearly and explicitly describe when MCI will apply NonSubscriber rates to lines that are presubscribed to MCI. In particular, the Tariff does not explain what circumstances cause MCI to remove a customer's account from its billing system, which removal triggers the imposition of NonSubscriber rates. Without such an explanation, a customer cannot determine whether, or even when, MCI will remove its account from MCI's billing system. Thus, we find that the Tariff does not clearly describe when MCI will charge NonSubscriber rates to a line presubscribed to MCI. Accordingly, we conclude that the Tariff is neither clear nor explicit. On this basis, we find that the Tariff violates part 61.2 of the Commission's rules and section 201(b) of the Act.  X' 2.` ` MCI's Charging of NonSubscriber Rates to Customers That Have  X'Telephone Lines Presubscribed to MCI is Unreasonable. (#`  Xi4 14.` ` Complainants allege that, even if the pertinent portions of MCI's Tariff were sufficiently clear and explicit, MCI's charging of NonSubscriber rates to customers making  X;4directdialed calls is unreasonable in violation of section 201(b) of the Act.L0;U yO$'ԍComplainants' Brief at 78.L According to Complainants, the legal presumption that MCI's NonSubscriber rates and practices are reasonable is rebutted under these circumstances, because MCI insulates its NonSubscriber"  0\+''qq"  X4rates from competitive forces by charging them to unsuspecting customers.1U yOy'ԍHalprin Complaint at 1, 45; Freedom Complaint at 1, 45; Complainants' Brief at 18. Complainants assert that customers cannot know in advance of billing they will be charged NonSubscriber rates, which negates the competitive market forces underlying the presumption of  X4reasonableness.2DXU yO'ԍHalprin Complaint at 1, 45, 910; Freedom Complaint at 1, 45, 910; Complainants' Brief at 4, 7, 15. Complainants contend further that rates tend towards cost when competitive forces are working and, therefore, the fact that MCI's rates are being raised disproportionately to increases in costs evidences that competitive forces are not working. Complainants' Brief at 45. Complainants rely on the fact that the cost for a 1 minute directdialed call under MCI's NonSubscriber rates has increased 850% since December 1996. Complainants argue that this fact combined with MCI's failure to establish a proportionately high increase in costs evidences  {Ot 'that competitive forces are not working. Id. Complainants also argue that the fact that MCI does not advertise  {O> 'these rates is evidence that competitive forces are not at work in this market segment. Id. at 4.  X415.` ` MCI argues that Complainants had sufficient information as of December, 1996, to know that the lines associated with the Numbers were presubscribed to MCI and that no customer account had been established with MCI for the provision of interexchange service  XH4to the Numbers.H3Hd U yO]'ԍMCI Reply Brief at 5. H It appears that Nextwave paid for MCI's provision of service to the  X14Numbers from September 1998 through February 1998.941 U yO'ԍJoint Statement at 2. It appears that, when the Numbers were presubscribed to MCI, the Halprin Number was used primarily as an outgoing fax transmission line and the Freedom Number was used primarily as Freedom's main incoming line. Affidavit of Laura Magner in Support of Halprin, Temple, Goodman & Sugrue's and Freedom Technologies, Inc.'s Responses to MCI's First Set of Interrogatories at 12 (filed July 20, 1998). As a result, the Numbers were likely low usage lines with regard to outgoing interexchange calls.9 MCI apparently reasons that Nextwave's payment for such services evidences that Complainants were not paying for presubscribed service during that period. Consequently, Complainants' nonpayment gave Complainants' reason to suspect that a change in the presubscription of service for the Numbers had occurred. Thus, MCI reasons, Complainants knew or should have known that they would be charged MCI's NonSubscriber rates.  X416.` ` We conclude that MCI's charging of NonSubscriber rates for directdialed calls is unreasonable. As explained below, Complainants have provided sufficient evidence to rebut the presumption of reasonableness given to tariffs of nondominant IXCs. For competition effectively to police the rates, terms and conditions of tariff offerings, consumers must have access to clear information from which to make choices and compare offerings. Indeed, fundamental to the Commission's reliance on market forces to ensure that charges are competitive, and thus reasonable, is the tenet that consumers know what prices they are being" 4\+''qq"  X4charged and what choices they are being given.5NU {Oy'ԍImplementation of the Subscriber Carrier Selection Changes Provisions of the Telecommunications Act  {OC'of 1996, Further Notice of Proposed Rulemaking and Memorandum Opinion and Order, 12 FCC Rcd 10674,  {O '10682 (1997); Billed Party Preference for InterLATA 0+ Calls, Second Further Notice of Proposed Rulemaking,  {O'11 FCC Rcd 7274 (1996); Policies and Rules Concerning Unauthorized Changes of Consumers' Long Distance  {O'Carriers, 10 FCC Rcd 9560, 9564 (1995); Policies and Rules Concerning Operator Service Providers, Notice of  {Ok'Proposed Rulemaking, 5 FCC Rcd 4630, 463132 (1990); Telecommunications Research and Action Center and  {O5'Consumer Action v. Central Corporation International Telecharge, Inc., et al., Memorandum Opinion and Order, 4 FCC rcd 2157, 2158 (1989). The market can serve as a constraint on an unreasonable practice only if consumers are aware of the practice. As the Commission has recently stated, "consumers must have adequate information about the services they are receiving, and the alternatives available to them, if they are to reap the benefits of a  X4competitive market."6U {O3 'ԍTruthinBilling and Billing Format, Notice of Proposed Rulemaking, CC Docket No. 98170, 3 (rel. Sept. 17, 1998).  Xv417.` ` Our evaluation of MCI's use of the term "NonSubscriber" to describe rates that will be charged for calls made over presubscribed lines is based on the relationship between presubscription and directdialing, which informs customers about the nature of the customercarrier relationship. Presubscription is the process by which a customer chooses a  X 4single IXC to carry all of its "1+" interexchange calls.7$ 8 U {O'ԍPICInvestigation of Access and Divestiture Related Tariffs, Memorandum, Opinion and Order, 101 FCC 2d  {O'911, 928 (1985) (Allocation Order). The physical connection that results from presubscription is that the software of the serving LEC's switch is programmed to route "1+" calls originating from that customer's local service line to the point of presence (POP) of the chosen primary interexchange carrier (PIC).  Thus, when a customer dials "1" plus the area code and local telephone number, the customer accesses only the services of the IXC it chose. In contrast, a customer that does not choose to presubscribe its line to an IXC cannot originate interexchange calls from its line by dialing "1" plus the area code and local telephone number. Customers may choose to access IXCs to which their lines are not presubscribed by dialing a sevendigit carrier access code plus the area code and local  X4telephone number./8($U {Oe' Originally, an end user could also access other IXCs by dialing a five-digit access code. Allocation  {O/'Order, 101 FCC 2d at 911. As of September 1, 1998, a seven-digit access code is required. See Administration  {O'of the North American Numbering Plan Carrier Identification Codes (CICs), 13 FCC Rcd 8687, 8700 (Com. Car.  {O 'Bur. 1998); FCC Consumer Alert, DA 98-1736, 1998 WL 549332 (F.C.C.) (Com. Car. Bur. Aug. 31, 1998)./ Dialing a sevendigit carrier access code is the only way a customer that did not choose to presubscribe its line to an IXC may complete an interexchange call.  XK418.` `  DIRECT Because a customer cannot complete a directdialed interexchange call unless a specific IXC has been chosen to carry the traffic on that line, the fact that an interexchange  X4call can be completed using "1+" dialing signifies to the customer that its local line has been presubscribed to an IXC. Making an interexchange call using "1+" dialing is also referred to" 8\+''qq" as "directdialing" because once a customer chooses to presubscribe to a carrier its calls are directly routed to that IXC.  X419.` ` At bottom, the practice at issue is MCI's charging of rates that are identified in the Tariff as applicable to "NonSubscribers" for calls made over lines that are presubscribed to MCI, i.e., lines that permit the caller to engage in directdialing. For the following reasons, we conclude that this practice is inherently confusing to consumers and therefore violative of section 201(b) of the Act.  X1420.` ` When a customer can use a line to directdial a call using 1+ dialing, this  X 4signifies to the customer that the line has been presubscribed to an interexchange service.`9 U {O 'ԍSee discussion supra 1718.` It is unreasonable to expect a customer that has chosen to "presubscribe" to MCI's service to consider itself a "NonSubscriber." Thus, regardless of the Tariff's terms, such a customer would not understand that use of a telephone line that is "presubscribed" to MCI's  X 4interexchange service may be subjected to "NonSubscriber" rates under any circumstances.:  ZU yO'ԍOur conclusion here should not be construed as requiring that MCI place all directdialed calls in a particular subscriber rate plan. Rather, in accordance with the requirements of the Act and the Commission's rules and orders, MCI may establish different rate plans under the Subscriber rubric, so long as it is clear from the terms of the tariff when and how a subscriber is placed in such plans. Moreover, customers making directdialed interexchange calls would be misled by MCI's wholly internal distinction between a customer making directdialed calls who has a billing account with MCI, and a customer making directdialed calls who does not have a billing account with MCI. Because it is reasonable for a consumer to believe that directdialing  XM4capability triggers Subscriber rates, not NonSubscriber rates, we find that a customer would not understand that MCI can or will charge NonSubscriber rates for directdialed calls. Accordingly, we conclude that the challenged practice contained in the Tariff is unreasonable, because it is inherently misleading to consumers.  X421.` ` MCI further argues that its practice is reasonable because MCI allegedly does not remove an account from its billing system without customer authorization and, therefore, it claims that customers do have actual knowledge of the fact that they will be subject to  X4MCI's NonSubscriber rates.F;BU yO 'ԍMCI Reply Brief at 6.F We disagree. A customer "authorizing" its removal from MCI's billing system would not understand that such removal could occur while such customer remains presubscribed to MCI. We conclude that the continuing capability to place a directdialed interexchange call signifies to a customer, notwithstanding such customer's  X;4"authorization" to remove him/her from MCI's billing system, that an ongoing billing relationship between such customer and MCI exists. This is so regardless of the language used to describe the relationship in the Tariff. " ;\+''qq"Ԍ X422.` ` We further find MCI's attempt to make an administrative distinction, especially one that benefits MCI financially, between categories of presubscribed customers based on  X4MCI's choice to remove certain customers from its billing system, is disingenuous. Customers reasonably expect that they are choosing to establish a billing arrangement with MCI by choosing to presubscribe their interexchange service to MCI. Indeed, the purpose of a presubscribed relationship is to permit the continuing provision of directdialed interexchange service to a customer in exchange for the customer's obligation to pay the carrier at the tariffed rate. In addition, the language of the Tariff itself assumes that presubscribed customers have accounts in MCI's billing system in the normal course of events. The choice to presubscribe a line to MCI's interexchange services equates to the choice to establish a billing relationship between the customer for that line and MCI. We conclude that even customers who authorize removal of their accounts from MCI's billing system do not have actual knowledge that MCI will continue to provide them with  X 4presubscribed interexchange service and charge them NonSubscriber rates.  X 423.` ` MCI also contends that Complainants had constructive knowledge that they  X4would be charged MCI's NonSubscriber rates.D<U yO 'ԍMCI Brief at 1316.D In so contending, MCI relies on the Filed Rate Doctrine, which establishes that, as a matter of law, customers are deemed to know the  Xf4charges and practices described in a filed tariff.:=fXU {Oo'ԍId.: MCI's reliance on the Filed Rate Doctrine is misplaced. While the Filed Rate Doctrine imposes constructive knowledge of the terms of  X84tariffs on consumers,l>8U {O'ԍMCI Telecommunications Corp, 512 U.S. 218, 230.l it also provides for a review of the reasonableness of the rates and  X!4practices contained in a tariff pursuant to the statutory provisions for such review.D?!|U {ON'ԍId at 23031.D Where, as we have already held here, it is determined that the terms of a tariff are unreasonable  X4because they are inherently confusing, the Filed Rate Doctrine cannot validate such terms.`@U {O'ԍSee discussion supra 1620.`  X4That is, the constructive notice established as a matter of law by the Filed Rate Doctrine  X4cannot be used to prove that the charges and practices contained in the tariff are themselves lawful. Indeed, it is well established that the rates and practices carriers seek to shelter pursuant to the Filed Rate Doctrine are always subject to an inquiry into their  X4reasonableness.dAU {O#'ԍMCI Telecommunications Corp, 512 U.S. 23031.d  XV424.` ` Finally, we likewise reject MCI's contention that its distinction between "Subscribers" and "NonSubscribers" is reasonable because, when the customer account at"? 2 A\+''qq" issue herein was terminated, MCI was unable to "dePIC" itself as the presubscribed carrier to  X4a telephone line.]B~U yOb'ԍMCI Reply Brief at 67. MCI uses the term "dePIC" to described the process of removing the  {O*'presubscription of a customer's line to an IXC. See discussion supra n. PIC55 . MCI alleges that only a customer can remove the presubscription of an interexchange carrier from such customer's line. MCI Reply Brief at 67 (citing MCI's Supplemental Response to Interrogatories at 9). MCI reasons that, because only a customer can "dePIC" its line, it is a customer's responsibility to "dePIC" its line when such customer chooses to terminate  {OL'its account with MCI. Id. Accordingly, MCI contends it acts reasonably by removing a customer from its  {O'billing system while remaining presubscribed to such customer's line. Id.] MCI's alleged inability to dePIC itself as the presubscribed carrier is irrelevant to our conclusion. Our conclusion in this proceeding is based on the inherent confusion created by the "Subscriber" and "NonSubscriber" labels. We find that, no matter how explicitly MCI explains the circumstances that would cause a customer whose line is  X4"presubscribed" to be charged MCI's "NonSubscriber" rates and surcharges, those labels have such accepted and wellknown meanings that their use in this manner will be confusing and thus unreasonable.  X3' C.XReasonableness of MCI's NonSubscriber Rates (#  X 425.` ` Complainants allege that MCI's NonSubscriber rates charged to customers that are presubscribed to MCI's interexchange service are unreasonable, in violation of section  X 4201(b) of the Act.C U yO'ԍHalprin Complaint at 1, 45, 9; Freedom Complaint at 1, 45, 9; Complainants' Brief at 4; 47 U.S.C.  201(b). Because we conclude that MCI's practice of charging NonSubscriber rates for directdialed interexchange calls is unreasonable, we decline at this time to resolve whether MCI's NonSubscriber rates are unreasonable.  X{4#M IV. DAMAGES ă  XM426.` ` Complainants seeks an award of damages for the difference between the amount Complainants paid to MCI pursuant to MCI's NonSubscriber rates and the amount  X4they would have paid to MCI had MCI's rates been reasonable.Df U yO6'ԍHalprin Complaint at 13; Freedom Complaint at 13; Complainants' Brief at 2122. In response, MCI argues that, to the extent Complainants are entitled to damages, an award of damages should be limited to the difference between MCI's NonSubscriber rates and the applicable  X4interexchange rates of Complainants' chosen long distance carrier.E" U yO"'ԍMCI's Brief at 1719. MCI also argues extensively in opposition to Complainants request that, upon a determination that MCI's NonSubscriber rates are too high, the Commission revise MCI's NonSubscriber rates  {O$'to be no more than 125% of MCI's basic rate schedule. Id. We do not consider this argument because we are not revising MCI's NonSubscriber rate. "E\+''qq>"Ԍ X427.` ` As explained above, we conclude that a customer who is presubscribed to MCI would reasonably consider itself a "subscriber" of MCI's interexchange services. Thus, we further conclude that the only reasonable rate that MCI could have charged Complainants for their interexchange service is a "Subscriber" rate. Accordingly, MCI is directed to rerate Complainants' directdialed interexchange calls at issue in this proceeding at MCI's tariffed  X4basic rates for subscriber calls that were in effect at the time such calls were placed.'FXU yO'ԍWe note that the parties have stipulated that the Numbers' presubscription to MCI was not wrongful. Second Joint Statement at 2. Consequently, there is no basis for us to direct MCI to rerate Complainants' calls at the rates of another carrier.' MCI is further directed to refund to Complainants the amount Complainants paid for MCI's provision of service to the Numbers less the amount Complainants would have been billed for MCI's provision of service to the Numbers had such service been charged at MCI's basic "Subscriber" rates.  X 428.` ` Complainants have additionally requested damages on behalf of all customers who have paid MCI's NonSubscriber rates for the previous two years. Complainants assert that they have standing to request such damages, because "the policy underpinnings of Sections 201 and 208 of the Act permit the Commission to fashion appropriate relief for all  X 4consumers harmed by the unjust and unreasonable rates of nondominant IXCs."KG U yO@'ԍComplainants' Brief at 22.K MCI responds that Complainants do not have standing to seek damages on behalf of all other  Xy4customers.{HyxU yO'ԍMCI Halprin Answer at 6, 19; MCI Freedom Answer at 6, 19; MCI Brief at 19.{  XK429.` ` The Commission has clearly stated that class action lawsuits are neither contemplated by, nor consistent with, the private remedies created under sections 206 through  X4209 of the Act.'I\U {O'ԍMCI Telecommunications Corporation v. Pacific Bell Telephone co., 8 FCC Rcd 1517, 1526) (1993);  {O'Certified Collateral Corp. v. Allnet Communications Services, Inc., 2 FCC Rcd 2171, 2173 (Comm. Car. Bur. 1987).' Therefore, although other customers situated similarly to Complainants might be entitled to damages pursuant to section 208(a) of the Act, the remedy available to these customers is to file their own section 208 complaints with the Commission. Complainants simply cannot seek damages on their behalf.  X430.` ` Complainants also request that we assess forfeitures against MCI, order MCI to pay punitive damages, and condition MCI's operating authority on its compliance with the  X|4Commission's rulings in this proceeding.J|, U yOY%'ԍHalprin Complaint at 14; Freedom Complaint at 14; Complainants' Brief at 2025. MCI responds that Complainants seek relief"| J\+''qq"  X4completely out of proportion to the alleged harm.AKU yOy'ԍMCI Brief at 20.A MCI also contends that the Commission  X4does not have the authority to award punitive damages.DLXU yO'ԍMCI Brief at 2122.D MCI argues further that Complainants' request that the Commission condition MCI's operating authority on compliance with this order is outrageous, because Complainants have not established the  X4requisite abusive behavior for such an extreme remedy.DMU yO= 'ԍMCI brief at 2021.D  Xv4 31.` ` Complainants have presented the Commission with no evidence to support a conclusion that MCI will refuse to comply with the Commission's orders in this proceeding. Accordingly, we deny Complainants' request that the Commission condition MCI's operating  X14authority on its compliance with this order.N|1xU {OZ'ԍIn the Matter of CCN, Inc., Church Discount Group, Inc., Discount Calling Card, Inc., Donation Long Distance, Inc., Long Distance Services, Inc., Monthly Discounts, Inc., Monthly Phone Services, Inc., and Phone  {O'Calls, Inc., Order to Show Cause and Notice of Opportunity for Hearing, CC Docket No. 97144, 2021 (April 21, 1998) (Commission issued an Order to Show Cause why the operating authority bestowed on the Fletcher Companies should not be revoked after the Commission found that the Fletcher Companies had repeatedly engaged in unlawful common carrier activities and had demonstrated a continued refusal to respond to official inquiries and correspondence from the Commission.) We also deny Complainants' claim of punitive damages in this instance. Assuming, without deciding, that we have the authority to award punitive damages, the facts here do not justify any consideration of such damages, because Complainants have failed to show that MCI acted "maliciously, wantonly or with a  X 4recklessness that betokens improper motive or vindictiveness."O U yOB'ԍStrouth v. Western Union Telegraph Co., Initial Decision, 70 FCC 2d 525, 570 (1977), aff'd in relevant part, 70 FCC 2d 506 (Rev.Bd. 1978); Complainants' Brief at 2223. In addition, we deny Complainants' request that the Commission assess forfeitures against MCI in this proceeding. Section 208 provides for private remedies for individuals aggrieved by carriers, while Section  X4503 gives the Commission the discretion to assess forfeitures.iPU yOU'ԍ47 U.S.C.  208, 503((b); 47 C.F.R.  1.80(e).i If the Commission determines that MCI's practice of charging NonSubscriber rates for directdialed calls warrants the issuance of a Notice of Apparent Liability for Forfeiture under section 503 of the Act, it will do so in a separate proceeding.  X4J V. SANCTIONS ă  X432.` ` Complainants filed a Motion for Sanctions alleging that MCI submitted contradictory and misleading discovery responses and engaged in dilatory tactics that"P\+''qq"  X4contravene the intent of the Commission's formal complaint rules.yQU yOy'ԍComplainants' Request for Imposition of Sanctions (filed July 29, 1998).y MCI opposed the Motion, arguing that its responses to the discovery requests at issue were accurate, and that MCI clarified the source of the minor and inadvertent discrepancies that occurred upon  X4discovery.pRXU yO'ԍMCI Opposition to Request For Sanctions (filed August 5, 1998).p MCI argues further that it acted properly in filing its Motion to Stay Additional  X4Discovery, Motion to Dismiss, and Application for Review.S"U {O= 'ԍId. Specifically, MCI filed a Motion to Stay Additional Discovery and a Motion to Dismiss. MCI Motion to Dismiss (filed July 24, 1998); MCI Motion to Stay Additional Discovery (filed July 24, 1998). Because we are deciding the merits of this dispute, MCI's Motion to Stay Additional Discovery and Motion to Dismiss are denied as moot.  Xv4 33.` ` The circumstances that warrant the Commission's issuance of sanctions is  X_4determined on a casebycase basis.hTD_U {O'ԍImplementation of the Telecommunications Act of 1996, Amendment of Rules Governing Procedures to  {O'be Followed When Formal Complaints are Filed Against Common Carriers, Report and Order, 12 FCC Rcd 22497, 22610 (1997) (The Commission "has at [its] disposal a wide range of sanctions to address violations or abuses of our formal complaint rules, including summary grant or dismissal of a complaint (in whole or in part), the drawing of adverse inferences as to material facts, monetary forfeitures, admonishment rulings, and show cause proceedings. Because sanctionable behavior may entail a wide range of conduct by complainants and defendant carriers, the Commission has considerable discretion to tailor sanctions to the individual circumstances of a particular violation.") (citations omitted).h MCI has adequately explained the discrepancies that Complainants identified in MCI's discovery responses, and we do not find them to be an intentional attempt to mislead the Commission. Further, we do not find that MCI's filing of various motions warrant the imposition of sanctions. On these grounds, we deny Complainants' Motion for Sanctions.  X 4  VI. APPLICATION FOR REVIEW ă  X 4!34.` ` MCI filed an Application for Review of certain discovery rulings made by  X4Commission counsel on July 24, 1998.XUXU yO'ԍMCI Application for Review (filed July 24, 1998) (MCI Application). The discovery rulings at issue were made with delegated authority by Enforcement Division Staff Attorney Sumita Mukhoty at a status conference that took place on July 23, 1998 and memorialized by letter. July 24, 1998 Letter.X At a July 23, 1998 status conference, Commission counsel directed MCI to (1) provide complete responses to interrogatory requests that had been previously granted at a telephonic status conference that took place on July 13, 1998, and (2) provide the Commission with information concerning "the various circumstances that trigger its NonSubscriber charges, including an explanation of why, in circumstances like those in the complaint, MCI remains on the line to provide interexchange service at Non"U\+''qq"ԫ X4Subscriber rates when its long distance customers' accounts with MCI are closed."VU {Oy'ԍJuly 24, 1998 Letter; see also Letter of July 14, 1998 from Sumita Mukhoty to Albert Halprin, Esq, and Laura S. Roecklein, Esq. (July 14, 1998 Letter). MCI alleges that the July 23, 1998 status conference order (1) expanded the scope of previously ordered discovery without providing MCI an opportunity to oppose such expansion, and (2)  X4exceeded the scope of issues presented in this proceeding.AW"U yO'ԍMCI Application.A MCI also contends that Commission counsel's discovery rulings are reversible because, on July 22, 1998, Commission  X4counsel and counsel for Complainants allegedly engaged in improper ex parte communications  Xx4concerning the discovery disputes at issue in the July 23, 1998 status conference.XXxU yO 'ԍMCI Application; 47 C.F.R.  1.1208.X  XJ4"35.` ` Under section 1.115 of the Commission's rules, "[a]ny person aggrieved by any action taken pursuant to delegated authority may file an application requesting review of that  X 4action by the Commission."IY BU yO'ԍ47 C.F.R.  1.115(a).I No application for review will be granted if the person or entity exercising the designated authority was given no opportunity to address the question of fact or  X 4law upon which the application relies.IZ U {Oq'ԍId.  1.115(c).I Furthermore, the Commission may deny an  X 4application without specifying any reasons for its action.I[ d U {O'ԍId.  1.115(g).I  X 4#36.` ` We deny MCI's application, and we will address our reasons for doing so. We clarify, however, that in the future, applications for review of interlocutory staff rulings in the context of section 208 complaint proceedings generally will not be considered until the Commission issues a final ruling on the merits of the complaint. In the event, however, that the ruling on the merits of the complaint is made pursuant to delegated authority, the application for review will not be considered until after the delegated authority has issued its final ruling on the merits of the complaint.  X4$37.` ` As an initial matter, we find that MCI has not established its allegation that ex  X4parte violations occurred on July 22, 1998. On that date, counsel for Complainants did contact Commission counsel to inform her that a discovery dispute existed and to inquire about when to file a motion to compel, should one be necessary, in light of the accelerated  X4schedule of these proceedings.z\ U yO@%'ԍSee Affidavit of Richard T. White in Support of Complainants' Opposition.z During that telephone conversation, Commission counsel  X4reminded counsel for Complainants of the Commission's ex parte rules for restricted" \\+''qq="  X4proceedings and limited the conversation accordingly.:]U {Oy'ԍId.: Consequently, the conversation did not address the merits or even the nature of the discovery dispute referenced by Complainants' counsel. Commission counsel scheduled a status conference for the very next day, July 23, 1998, because the impending statutory deadline for resolving the merits of this matter required identification and resolution of any outstanding discovery disputes at the  X4earliest possible date.j^ZU yO'ԍ47 U.S.C.  208(b)(1) (Commission required to issue a final order within 5 months of the date of filing of the Complaint); Letter of July 22, 1998 from Sumita Mukhoty to Albert Halprin, Esq, Richard White, Esq., Laura S. Roecklein, Esq., Len Kennedy, Esq., and R. Dale Dixon, Esq. (July 22, 1998 Letter). We note that  {O 'MCI's Counsel was informed at the July 23, 1998 status conference that no ex parte  communication regarding the nature of the existing discovery dispute occurred between Complainants' counsel and Commission staff counsel.j On these grounds, we reject MCI's allegation that improper ex parte communications occurred with respect to the discovery decisions at issue.  XJ4%38.` ` We further find that MCI has not established that the discovery rulings either were made without providing MCI an opportunity to respond to Complainants' discovery requests, or went beyond the scope of the subject matter before the Commission in this proceeding. The ruling relating to the provision of further information regarding any cost justification and noncost factors that underlie MCI's NonSubscriber rates was not a ruling on a new request for discovery. Rather, it was an explicit direction to MCI to comply with  X 4discovery that had been previously ordered by the July 13, 1998 status conference ruling.^_ U yOE'ԍJuly 24, 1998 Letter; July 14, 1998 Letter. ^ The timing of the ruling on this discovery dispute was responsive to the constraints imposed by the applicable statutory deadline. Moreover, the Commission's rules expressly provide that "[i]n its discretion, the Commission may modify the scope, means and scheduling of discovery in light of the needs of a particular case and the requirements of applicable statutory  XM4deadlines."I`Md U yOb'ԍ47 C.F.R.  1.729(h).I We further find that the ruling requiring MCI to provide the Commission with information relating to MCI's application of its NonSubscriber rates in this case was warranted. This ruling directed MCI to provide the Commission with information that was  X4necessary to the proper resolution of these proceedings.Pa U {O 'ԍSee July 24, 1998 Letter.P The Commission's formal  X4complaint rules explicitly provide for such inquiry,bX U yO(#'ԍ47 C.F.R.  1.732(g) ("The Commission may require the parties to submit any additional information it deems appropriate for a full, fair, and expeditious resolution of the proceeding, including affidavits and exhibits.") and the information requested by Commission counsel was directed at understanding MCI's practices that are at issue in this proceeding. Accordingly, we deny MCI's Application for Review."b\+''qq"Ԍ X'ԙ   ;WVII. CONCLUSION\  X4 &39.` ` For the reasons discussed above, we conclude that MCI Tariff F.C.C. No. 1 is not clear and explicit as required by section 61.2 of the Commission's rules and is unreasonable in violation of section 201(b) of the Act. We further conclude that MCI Tariff F.C.C. No. 1 is unreasonable in violation of section 201(b) of the Act, to the extent that MCI assesses "NonSubscriber" perminute rates and percall surcharges on interexchange calls originating on lines presubscribed to MCI's interexchange service.  X1' VII. ORDERING CLAUSES \  X 4'40.` ` Accordingly, IT IS ORDERED that, pursuant to sections 1, 4(i), 4(j), 201(b), 205, 206, and 208 of the Act, as amended, 47 U.S.C.  151, 154(i), 154(j), 201(b), 205, 206, 208, and section 61.2 of the Commission's rules, 47 C.F.R.  61.2, that the formal complaint filed by Halprin, Temple, Goodman & Sugrue against MCI Telecommunications Corporation and the formal complaint filed by Freedom Technologies, Inc. against MCI Telecommunications Corporation ARE GRANTED to the extent described herein and ARE OTHERWISE DENIED.  XK4(41.` ` IT IS FURTHER ORDERED that the practice of charging NonSubscriber rates for "directdialed" calls by customers who are presubscribed to MCI Telecommunications, Inc., IS UNREASONABLE in violation of Section 201(b) of the Communications Act of 1934, as amended, 47 U.S.C. 201(b).  X4)42.` ` IT IS FURTHER ORDERED that the tariff language at issue in this complaint  X4as specified in paragraph 12, supra, IS UNLAWFUL in violation of Section 61.2 of the Commission's Rules, 47 C.F.R.  61.2.  X~4*43.` ` IT IS FURTHER ORDERED that MCI Telecommunications Corporation SHALL REFUND to Halprin, Temple, Goodman & Sugrue the amount Halprin, Temple, Goodman & Sugrue paid for MCI Telecommunications Corporation's provision of service to the Halprin Number less the amount Halprin, Temple, Goodman & Sugrue would have been billed for MCI Telecommunications Corporation's provision of service to the Halprin Number had such service been charged at MCI Telecommunications Corporation's tariffed basic subscriber rates for calls that were in effect at the time such calls were placed  X 4+44.` ` IT IS FURTHER ORDERED that MCI Telecommunications Corporation SHALL REFUND to Freedom Technologies, Inc., the amount Freedom Technologies, Inc., paid for MCI Telecommunications Corporation's provision of service to the Freedom Number less the amount Freedom Technologies, Inc., would have been billed for MCI Telecommunications Corporation's provision of service to the Freedom Number had such service been charged at MCI Telecommunications Corporation's tariffed basic subscriber rates for calls that were in effect at the time such calls were placed "<&b\+''qqB$"Ԍ X4ԙ,45.` ` IT IS FURTHER ORDERED that MCI Telecommunications Corporation's Motion to Stay Additional Discovery and Motion to Dismiss ARE DENIED.  X4-46.` ` IT IS FURTHER ORDERED that MCI Telecommunications Corporation's Application for Review IS DENIED.  Xv4.47.` ` IT IS FURTHER ORDERED that Halprin, Temple, Goodman & Sugrue's and Freedom Technologies, Inc.'s Joint Motion for Sanctions IS DENIED.  X14 /48.` ` IT IS FURTHER ORDERED that MCI Telecommunications Corporation SHALL IMMEDIATELY upon release of this order stop assessing NonSubscriber charges to customers presubscribed to MCI.  X 4049.` ` IT IS FURTHER ORDERED that MCI Telecommunications Corporation SHALL FILE tariff revisions within ten days of the release of this Order to clarify that NonSubscriber charges will only apply to customers that are not presubscribed to MCI. ` `  hhCqFEDERAL COMMUNICATIONS COMMISSION  X44 ` `  hhCqMagalie Roman Salas ` `  hhCqSecretary