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Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of )
)
CenturyTel, Inc. )
) File No. EB-03-TC-121
) NAL Acct. No. 200632170001
Compliance with the ) FRN: 0003740651
Commission's )
Rules and Regulations Governing )
Advertising the Availability of )
Lifeline and
Link-Up
ORDER
Adopted: November 17, 2005
Released: November 22, 2005
By the Chief, Enforcement Bureau:
1. In this Order, we adopt the attached Consent Decree
entered into between the Enforcement Bureau and CenturyTel, Inc.
(``CenturyTel''). The Consent Decree terminates an investigation
initiated by the Enforcement Bureau regarding CenturyTel's
compliance with section 214(e)(1)(B) of the Communications Act of
1934, as amended (the ``Act''), and sections 54.405(b) and
54.411(d) of the Commission's rules,1 as it relates to the duty
to publicize Lifeline and Link-Up programs to low-income
residents on tribal lands.
2. The Enforcement Bureau and CenturyTel have negotiated
the terms of a Consent Decree that would resolve this matter and
terminate the investigation. A copy of the Consent Decree is
attached hereto and incorporated by reference.
3. After reviewing the terms of the Consent Decree, we
find that the public interest would be served by adopting the
Consent Decree and terminating the investigation. We also
conclude that, in the absence of material new information not
previously disclosed to the Bureau, the matters raised in the
investigation do not raise any substantial and material questions
of fact regarding CenturyTel's qualifications to be a Commission
licensee.
4. Accordingly, IT IS ORDERED, pursuant to Section 4(i) of
the Communications Act of 1934, as amended,2 and the authority
delegated by sections 0.111 and 0.311 of the Commission's rules,3
that the attached Consent Decree IS ADOPTED.
5. IT IS FURTHER ORDERED that the above-captioned
investigation IS TERMINATED.
FEDERAL COMMUNICATIONS COMMISSION
Kris Anne Monteith
Chief, Enforcement Bureau
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of )
)
CenturyTel, Inc. ) File No. EB-03-TC-
121
) NAL Acct. No.
200632170001
Compliance with the Commission's ) FRN: 0003740651
Rules and Regulations Governing )
Advertising the Availability of Lifeline and )
Link-Up )
CONSENT DECREE
I. INTRODUCTION
6. The Enforcement Bureau (``Bureau'') of the Federal
Communications Commission (the ``FCC'' or ``Commission'')
and CenturyTel, Inc. (``CenturyTel''), by their authorized
representatives, hereby enter into this Consent Decree for
the purpose of terminating the Bureau's investigation (the
``Investigation'') regarding CenturyTel's compliance with
section 214(e)(1)(B) of the Communications Act of 1934, as
amended (the ``Act''), and sections 54.405(b) and 54.411(d)
of the Commission's rules,4 as it relates to the duty to
publicize Lifeline and Link-Up programs to low-income
residents on tribal lands.
II. BACKGROUND
2. CenturyTel is an eligible telecommunications
carrier (``ETC''), i.e., a telephone company eligible to
receive universal service support under section 214 of the
Act.5 CenturyTel serves numerous tribal lands in the 22-
state area in which it operates as an incumbent Local
Exchange Carrier.
3. The Bureau sent a Letter of Inquiry (``LOI'') to
CenturyTel on October 7, 2003,6 stating that it was
investigating whether CenturyTel was satisfying its
obligations under sections 54.405(b) and 54.411(d) of the
Commission's rules to publicize the availability of Lifeline
and Link-Up services to low-income residents on tribal lands
``in a manner reasonably designed to reach those likely to
qualify'' for those services. The Bureau sent a
supplemental LOI on April 6, 2004.7 The LOIs directed
CenturyTel to describe actions it had taken to satisfy
sections 54.405(b) and 54.411(d) of the Commission's rules
and to support its responses with pertinent documentation
and affidavits.
4. During the course of the Investigation, CenturyTel
provided written responses to the LOIs on November 17,
2003,8 and April 26, 2004.9 After meeting with
representatives of CenturyTel on October 28, 2004, the
Bureau sent a follow-up letter on November 9, 2004.10
CenturyTel provided supplemental responses on November 19,
2004,11 January 14, 2005,12 and January 26, 2005.13 In
recent meetings with the Bureau, CenturyTel stated that it
provides Lifeline and Link-Up services to low-income
residents on tribal lands in 12 states within its 22-state
incumbent region. CenturyTel asserted that it conducted
outreach to low-income residents on tribal lands within its
region and provided some evidence to support its
contention.14
III. DEFINITIONS
5. For purposes of this Consent Decree, the following
definitions shall apply:
1.a. ``Act'' means the Communications Act of
1934, as amended.
1.b. ``Bureau'' means the Enforcement Bureau
of the Federal Communications Commission.
1.c. ``CenturyTel'' means CenturyTel, Inc.
and any affiliate, d/b/a, predecessor-in-
interest, parent companies and any direct or
indirect subsidiaries of such parent companies,
or other affiliated companies or businesses and
their successors and assigns.
1.d. ``CenturyTel Tribal Land'' means that
portion of the tribal land described in the
Commission's report, ``Telephone Subscribership
on American Indian Reservations and Off-
Reservation Trust Lands,'' released May 2003,
and any subsequent such report, for which
CenturyTel is an ETC.
1.e. ``Commission'' means the Federal
Communications Commission.
1.f. ``Effective Date'' means fourteen (14)
days from the date on which the Bureau releases
the Adopting Order.
1.g. ``Investigation'' means the
investigation commenced by the Bureau's Letter
of Inquiry, dated October 7, 2003, to
CenturyTel regarding CenturyTel's possible
noncompliance with section 214(e)(1)(B) of the
Act and sections 54.405(b) and 54.411(d) of the
Commission's rules and possible noncompliance
with the Bureau's directives in the October 7,
2003 and April 6, 2004 LOIs.
1.h. ``Order'' or ``Adopting Order'' means an
Order of the Bureau adopting the terms and
conditions of this Consent Decree without
change, addition, or modification, and formally
terminating the above-captioned Investigation.
1.i. ``Parties'' means CenturyTel and the
Bureau.
1.j. ``CenturyTel's Field Team'' means Area
Supervisors, Public Relations Managers and Area
Operations Managers responsible for Lifeline
and Link-Up outreach to their respective
CenturyTel Tribal Land. Each CenturyTel Field
Team member will report directly to
CenturyTel's External Communications Manager
regarding all Lifeline and Link-Up outreach
efforts.
IV. AGREEMENT
6. CenturyTel agrees that the Commission and its
delegated authority, the Bureau, have jurisdiction
over it and the subject matter contained in this
Consent Decree and the authority to enter into and
adopt this Consent Decree.
7. The Parties agree and acknowledge that this
Consent Decree shall constitute a final settlement of the
Investigation. In express reliance on the covenants and
representations contained herein, and to avoid the potential
expenditure of additional public resources, the Bureau
agrees to terminate the Investigation. In consideration for
the termination of this Investigation and in accordance with
the terms of this Consent Decree, CenturyTel agrees to the
terms, conditions, and procedures contained herein.
8. The Parties agree that this Consent Decree does
not constitute either an adjudication on the merits or a
factual or legal finding or determination regarding any
compliance or noncompliance by CenturyTel with the
requirements of the Act or the Commission's rules or orders.
The Parties agree that this Consent Decree is for settlement
purposes only.
9. In consideration for the termination of the
Investigation in accordance with the terms of this Consent
Decree, CenturyTel agrees to make a voluntary contribution
to the United States Treasury, without further protest or
recourse to a trial de novo, in the amount of seventy-five
thousand dollars ($75,000) within thirty (30) days after the
Effective Date. The payment must be made by check or
similar instrument, payable to the order of the Federal
Communications Commission. The payment must include the
Acct. No. and FRN No. referenced above. Payment by check or
money order may be mailed to Forfeiture Collection Section,
Finance Branch, Federal Communications Commission, P.O. Box
73482, Chicago, IL, 60673-7482. Payment by overnight mail
may be sent to Bank One/LB 73482, 525 West Monroe, 8th Floor
Mailroom, Chicago, IL 60661. Payment by wire transfer may
be made to ABA Number 071000013, receiving bank Bank One,
and account number 1165259.
10. To resolve and terminate the Investigation, and to
ensure compliance with the Commission's Lifeline and Link-Up
outreach rules, CenturyTel agrees to implement a Lifeline
and Link-Up Outreach Plan to low-income residents on
CenturyTel Tribal Lands, that CenturyTel has identified in
submissions to the Bureau, consisting of the components
delineated below in paragraphs 10 through 13. In the event
that, after the Effective Date, CenturyTel becomes an ETC on
at least a portion of a tribal land appearing in the
Commission's report, ``Telephone Subscribership on American
Indian Reservations and Off-Reservation Trust Lands,''
released May 2003, and any subsequent such report, it shall
extend the outreach programs described herein to those
portions of the newly served tribal lands and such areas
shall become CenturyTel Tribal Lands for the remainder of
the duration of this Consent Decree. In the event that,
after the Effective Date, CenturyTel ceases to be an ETC in
any portion of the CenturyTel Tribal Lands, such areas shall
cease to be CenturyTel Tribal Lands as of the date on which
CenturyTel's ETC designation ceased to be effective. In
either case, CenturyTel will notify the Bureau of the
addition to or deletion from the CenturyTel Tribal Lands,
and provide a map or other description of such area and the
affected American Indian Reservations or Off-Reservation
Trust Lands affected.
A. Individual Tribal Outreach
i) Individualized Tribal Plans. CenturyTel
will develop and submit to the Bureau an
individualized Lifeline and Link-Up outreach
plan for each CenturyTel Tribal Land not
later than three months after the Effective
Date. These individualized outreach plans
will incorporate various types of outreach
efforts designed to reach that specific tribe
in the most effective manner and will consist
of at least some of the specific outreach
efforts, in CenturyTel's judgment most likely
to be effective, described in paragraphs
10(A)(iii) through 10(A)(vii) below. The
outreach efforts to be incorporated into the
individualized tribal plans will be
determined by CenturyTel personnel within the
state who have experience with the specific
tribes. CenturyTel will also make good faith
efforts to work in conjunction with tribal
liaisons, described in paragraph 10(A)(ii)
below, to develop the outreach plan for their
particular tribe.
ii) Tribal Liaisons. CenturyTel will make
good faith efforts to identify and contact
tribal liaisons for all CenturyTel Tribal
Lands not later than thirty days after the
Effective Date. Efforts to contact the
various tribal liaisons may include in-person
visits, direct mail, and/or telephone
contact. CenturyTel's Field Team will confer
with the tribal liaisons in order to
determine the most effective outreach efforts
to publicize Lifeline and Link-Up to their
particular tribe. CenturyTel will also
provide tribal liaisons with Lifeline and
Link-Up posters, flyers, and applications
that they can distribute to members of their
tribe. CenturyTel will notify the FCC's
Enforcement Bureau and the Consumer and
Governmental Affairs Bureau of any CenturyTel
Tribal Land that CenturyTel is unsuccessful
in contacting.
iii) Distribution of Individualized
Materials. CenturyTel will conduct personal
outreach to inform residents living on
CenturyTel Tribal Lands about the
availability of Lifeline and Link-Up.
CenturyTel will work with tribal liaisons to
obtain the names and/or location information
for tribal residents for tribes that provide
a list of residents. CenturyTel will
distribute individualized materials directly
to the identified residents on CenturyTel
Tribal Lands once a year. These materials
will clearly explain the application
procedures and eligibility criteria to
receive Lifeline and Link-Up services. Where
tribal liaisons do not provide specific names
of tribal members and how they can be
reached, CenturyTel will not be responsible
for making personal contact. The personal
outreach will be conducted within thirty days
of receiving a list from the tribal liaisons.
iv) Public Service Announcements.
CenturyTel will distribute public service
announcements (``PSAs'') to radio stations
that reach CenturyTel Tribal Lands. The PSAs
will include a CenturyTel customer service
telephone number staffed by trained customer
service representatives who can help
interested customers apply for the Lifeline
and Link-Up programs. These PSAs will be
disseminated four times a year and will
clearly describe both the Enhanced and the
non-Enhanced Lifeline and Link-Up programs
and the availability of such programs to
those living on tribal lands.
v) Newspaper Advertisements. CenturyTel
will identify tribal newspapers serving
CenturyTel Tribal Lands. CenturyTel will
place paid advertisements in these tribal
newspapers twice yearly. All advertisements
will specifically mention both the Enhanced
and the non-Enhanced Lifeline and Link-Up
programs and provide further information on
eligibility criteria and application
instructions.
vi) Press Releases. CenturyTel will send
newspapers in-depth press releases that
contain information about both the Enhanced
and the non-Enhanced Lifeline and Link-Up
services offered by CenturyTel, eligibility
criteria and application instructions. These
press releases will be sent to the tribal
newspapers identified in 10 (A)(v) above two
times a year.
vii) Social Service Agencies. CenturyTel
will make good faith efforts to identify
social service agencies that provide outreach
to tribal residents on CenturyTel Tribal
Lands not later than two months after the
Effective Date. Not later than three months
after the Effective Date, CenturyTel will
provide printed posters, flyers, and
applications to these social service agencies
for dissemination to those interested in
learning more about both the Enhanced and the
non-Enhanced Lifeline and Link-Up programs.
Twice yearly, the social service agencies
will receive either a personal visit,
telephone call or an explanatory letter that
describes the programs in detail, including
eligibility criteria and applications
instructions.
B. Service-Area Wide Outreach
In addition to the outreach efforts described in
paragraph 10(A) above, CenturyTel will take each of the
following steps to publicize the Lifeline and Link-Up
programs to all CenturyTel Tribal Lands.
i)Training. CenturyTel will provide training
materials to all appropriate employees, as
determined by the CenturyTel Field Team, in
CenturyTel Tribal Lands at least once yearly.
The training materials will clearly explain
the importance of the programs, eligibility
criteria and application instructions. These
training materials will also be integrated
into present Lifeline and Link-Up information
in all customer service representatives'
handbooks.
ii) Bill Messages. CenturyTel will continue
to publish Lifeline and Link-Up bill messages
on a twice yearly basis. The bill messages
will alert existing customers about the
opportunity to receive help with their phone
bills if they meet the eligibility
requirements. The bill messages will also
promote ``word of mouth'' advertising aimed
at reaching those residents without telephone
service. This ``word of mouth'' advertising
should encourage existing customers to tell a
friend, neighbor or family member without
telephone service about Lifeline and Link-Up.
CenturyTel will also publish similar ``word
of mouth'' ads or messages in all of the
telephone directories it distributes within
CenturyTel Tribal Lands.
iii) Website. Within 60 days of the
Effective Date, CenturyTel will include an
informative page on its website,
www.centurytel.com, which explains the
Lifeline and Link-Up programs. The page will
include information on the eligibility
requirements, the sign-up procedures, and a
phone number by which interested customers
can receive further information. Existing
customers will be able to request an
application be mailed to them using the
MyAccount function on the site. Those who
are not customers will be offered a toll-free
(8YY) number through which they will be able
to request an application. This page will
provide a link to the appropriate state
website, where state law requires.
CenturyTel will also offer to work with the
tribal liaisons for those tribes with
websites to include a link to CenturyTel's
Lifeline and Link-Up information page on the
tribal websites, providing such tribal
liaisons are willing to participate.
CenturyTel will include the URL address for
the Lifeline and Link-Up information page in
its outreach advertising.
iv) State and Local Officials. CenturyTel
will provide outreach information about
Lifeline and Link-Up service to state and
local officials and a contact person to whom
such officials can refer individuals with
questions about Lifeline and Link-Up. This
effort will be undertaken twice yearly.
v)Other. CenturyTel will make good faith
efforts to promote Lifeline and Link-Up to
all tribes within its service areas. When
CenturyTel encounters a tribe that is
particularly hard to reach or receives a
request for service from a customer on
CenturyTel Tribal Land to which CenturyTel
cannot get access, CenturyTel will notify the
FCC's Enforcement Bureau and Consumer and
Governmental Affairs Bureau.
11. CenturyTel will assess its outreach efforts
periodically to determine whether they are effective, as
follows:
(a) CenturyTel will conduct a survey of
tribal liaisons once a year to determine
whether the outreach efforts for the past
year have been effective in reaching the
residents of CenturyTel Tribal Lands and
informing them of the Lifeline and Link-Up
programs.
(b) CenturyTel will assess whether any
CenturyTel Tribal Land is within the
coverage area of any newspaper, radio, or
other media outlet (that CenturyTel is not
already using pursuant to paragraph 10
above) that CenturyTel can use to promote
Lifeline and Link-Up.
(c) CenturyTel will track Lifeline and Link-
Up applications and chart increases in
Lifeline and Link-Up customers over time,
by CenturyTel Tribal Land. This assessment
will be done relative to October 1, 2005.
This assessment will occur twice during the
period covered by this Plan, the first
assessment to be completed not later than
twelve months after October 1, 2005 and the
second not later than eighteen months from
October 1, 2005.
(d) If CenturyTel learns that certain
outreach efforts are ineffective to reach a
particular tribe, CenturyTel will adjust
the outreach effort in response to the
assessment. In such cases, CenturyTel will
also provide the Bureau with a revised
individualized tribal outreach plan to
reflect the adjustment in the outreach
effort for the particular tribe.
12. CenturyTel will implement the following record-
keeping mechanisms to document each outreach effort
undertaken to promote Lifeline and Link-Up.
1.j)a. CenturyTel will maintain a record
of all individuals trained.
1.j)b. CenturyTel will maintain logs of
all radio PSAs and press releases that it
distributes to radio stations and
newspapers for a period of two years.
CenturyTel will also request confirmation
from both broadcasters and newspapers of
when PSAs and press releases were aired or
printed.
1.j)c. Each of CenturyTel's Field Team
members will keep a log of all of the
efforts undertaken within their service
areas to promote Lifeline and Link-Up to
those living on CenturyTel Tribal Lands.
CenturyTel will submit the logs for each
state to the Bureau with its written report
of compliance (described in paragraph 13
below) as supporting documentation. The
logs will show the contact date, contact
person, the outreach method used, the
targeted tribe, and the targeted tribal
land.
1.j)d. CenturyTel will retain copies of
all written material used in newspaper
advertisements, press releases, posters,
flyers, and other outreach efforts for two
years. The field logs will contain
documentation of when and where these
materials were distributed. For newspaper
advertisements, CenturyTel will require
confirmation from the media sources of when
they were published. Dated copies of the
published newspaper advertisements may
serve as such confirmation.
1.j)e. CenturyTel will maintain records of
all invoices for advertisements as well as
any other expenditure that CenturyTel
incurs for the promotion of Lifeline and
Link-Up to those living on CenturyTel
Tribal Lands for two years.
1.j)f. CenturyTel will retain copies of
all bill messages sent out to customers on
CenturyTel Tribal Lands for two years.
CenturyTel will also maintain copies of
directory pages that contain printed
information about the Lifeline and Link-Up
programs for two years.
13. CenturyTel will submit written reports to the
Bureau describing its compliance with this Consent Decree
twelve and eighteen months after the Effective Date. The
reports shall address in detail CenturyTel's compliance with
each separate term and provision of this Consent Decree.
CenturyTel must mail its reports to Colleen Heitkamp, Chief,
Telecommunications Consumers Division, Enforcement Bureau,
Federal Communications Commission, 445 12th Street, S.W.
Room 4-C244, Washington, D.C. 20554, and must include the
file number listed above. CenturyTel will also send an
electronic copy of its reports to Mark Stone, Deputy Chief,
Telecommunications Consumers Division, at Mark.Stone@fcc.gov
and Donna Cyrus, Senior Attorney Advisor, Telecommunications
Consumers Division, at Donna.Cyrus@fcc.gov.
14. The Bureau agrees that, in the absence of new
material evidence related to this matter, it will not use
the facts developed in this Investigation through the
Effective Date or the existence of this Consent Decree to
initiate, on its own motion, any new proceeding, formal or
informal, or take any action on its own motion against
CenturyTel, including any other enforcement action, nor will
the Bureau seek on its own motion any administrative or
other penalties from CenturyTel, concerning the matters that
were the subject of the Investigation. The Bureau also
agrees that it will not use the facts developed in the
Investigation through the Effective Date or the existence of
this Consent Decree to initiate, on its own motion, any
proceeding, formal or informal, or take any action on its
own motion against CenturyTel with respect to CenturyTel's
basic qualifications, including its character
qualifications, to be a Commission licensee or authorized
common carrier. Consistent with the foregoing, nothing in
this Consent Decree limits the Commission's authority to
consider and adjudicate any complaint that may be filed
pursuant to section 208 of the Act, 47 U.S.C. § 208, and to
take any action in response to such complaint. The
Commission's adjudication of any such complaint will be
based solely on the record developed in that proceeding.
The Bureau agrees that, to the extent consistent with
paragraph 21, CenturyTel's compliance with all the terms of
this Consent Decree constitutes compliance with the
Commission's Lifeline and Link-Up outreach rules during the
period in which the Consent Decree is effective.
15. CenturyTel's decision to enter into this Consent
Decree is expressly contingent upon the Bureau's issuance of
an Adopting Order.
16. Provided the Bureau issues an Adopting Order,
CenturyTel 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.
17. If either Party (or the United States on behalf of
the Commission) brings a judicial action to enforce the
terms of the Adopting Order, neither CenturyTel nor the
Commission shall contest the validity of the Consent Decree
or the Adopting Order, and CenturyTel and the Commission
will 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.
18. In the event that this Consent Decree is rendered
invalid by a court of competent jurisdiction, it shall
become null and void and may not be used in any manner in
any legal proceeding.
19. By this Consent Decree, CenturyTel 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 information.
20. CenturyTel agrees that any violation of the Order
or 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.
21. The Parties agree that if any provision of this
Consent Decree conflicts with any subsequent rule or order
adopted by the Commission (except an order specifically
intended to revise the terms of this Consent Decree to which
CenturyTel does not consent), that provision will be
superseded by such Commission rule or order.
22. The Parties agree that the requirements of this
Consent Decree shall expire eighteen (18) months from the
Effective Date.
23. This Consent Decree may be signed in counterparts.
For: CenturyTel, Inc. For:
Enforcement Bureau
Federal Communications Commission
__________ _______________________ __________
______________________
Date (CenturyTel Signature) Date Kris
Anne Monteith
Chief,
Enforcement Bureau
_________________________
147 U.S.C. § 214(e)(1)(B); 47 C.F.R. §§ 54.405(b), 54.411(d).
247 U.S.C. § 154(i).
347 C.F.R. §§ 0.111, 0.311.
447 U.S.C. § 214(e)(1)(B); 47 C.F.R. §§ 54.405(b),
54.411(d).
547 U.S.C. § 214.
6See Letter of Inquiry from Colleen Heitkamp, Chief,
Telecommunications Consumers Division, Enforcement Bureau,
to John F. Jones, Vice President, Federal Government
Relations, CenturyTel, Inc. (October 7, 2003).
7See Letter of Inquiry from Colleen Heitkamp, Chief,
Telecommunications Consumers Division, Enforcement Bureau,
to John F. Jones, Vice President, Federal Government
Relations, CenturyTel, Inc. (April 6, 2004).
8See Letter from Terrance Hinkston, Compliance Specialist,
CenturyTel, Inc., to Lynn Vermillera, Attorney,
Telecommunications Consumers Division, Enforcement Bureau
(November 17, 2003) (``November 17, 2003 Response'').
9See Letter from Robert D. Shannon, Federal Government
Relations, CenturyTel, Inc. to Cynthia Bryant, Attorney,
Telecommunications Consumers Division, Enforcement Bureau
(April 26, 2004) (``April 26, 2004 Response'').
10See Letter from Mark Stone, Deputy Chief,
Telecommunications Consumers Division, Enforcement Bureau,
to Karen Brinkmann, Latham and Watkins, LLP, and John F.
Jones, Vice President, Federal Government Relations,
CenturyTel, Inc. (November 9, 2004).
11See Letter from Karen Brinkmann and Manu Gayatrinath,
Latham & Watkins, LLP, and John F. Jones, Director, Federal
Government Relations, CenturyTel, Inc., to Mark Stone and
Donna Cyrus, Telecommunications Consumers Division,
Enforcement Bureau (November 19, 2004) (``November 19, 2004
Response'').
12See Letter from Karen Brinkmann and Manu Gayatrinath,
Latham & Watkins, LLP, and John F. Jones, Director, Federal
Government Relations, CenturyTel, Inc. to Mark Stone and
Donna Cyrus, Telecommunications Consumers Division,
Enforcement Bureau (January 14, 2005) (``January 14, 2005
Response'').
13See Letter from Karen Brinkmann and Manu Gayatrinath,
Latham & Watkins, LLP, and John F. Jones, Director, Federal
Government Relations, CenturyTel, Inc. to Mark Stone and
Donna Cyrus, Telecommunications Consumers Division,
Enforcement Bureau (January 26, 2005) (``January 26, 2005
Response'').
14See the November 17, 2003 Response, April 26, 2004
Response, November 19, 2004 Response, January 14, 2005
Response, and the January 26, 2005 Response.