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                                 June 27, 2007

   VIA CERTIFIED MAIL

   RETURN RECEIPT REQUESTED

   Tele-Ten Marketing

   ATTN: David Alexander

   3550 West 6th Street, Suite 301

   Los Angeles, CA 90020

   3250 Wilshire Blvd., Suite 1600

   Los Angeles, CA 90010

   Re: File No. EB-07-TC-3498

   Dear Mr. Alexander:

   This is an official CITATION, issued pursuant to section 503(b)(5) of the
   Communications Act of 1934, as amended (the Act), for violations of the
   Federal Communications Commission's rules that govern telemarketing calls.
   As explained below, you may appeal this citation. In addition, future
   violations of the Commission's rules in this regard may subject you and
   your company to monetary forfeitures.

   Attached are consumer complaints regarding telemarketing calls that your
   company or an entity acting on behalf of your company, acting under your
   direction, made to residential telephone lines despite previous
   do-not-call requests by members of the households. These complaints
   indicate that you and your company have violated the Commission's
   requirements regarding telemarketing calls in 47 C.F.R. S: 64.1200(d).

   Section 64.1200(d) of the Commission's rules requires entities that make
   telemarketing calls to residential telephone subscribers to follow certain
   procedures to ensure that the subscribers are able to stop such calls.
   Specifically, entities that make telemarketing calls must (1) develop
   written policies for maintaining a do-not-call list and make such written
   policies available upon demand; (2) inform and train their personnel
   engaged in any aspect of telemarketing about the existence and use of the
   do-not-call list; (3) place consumers who request not to receive
   telemarketing calls on the do-not-call list; and (4) honor each
   do-not-call request within a reasonable time from the date of the request,
   which may not exceed thirty (30) days, for five years from the time the
   request is made. In addition, the Commission has found that it is unlawful
   to call a residential telephone line to deliver a telemarketing call if
   any member of the household has made a do-not-call request.

   Under the Act and the Commission's rules, a "telemarketing" call is "the
   initiation of a telephone call or message for the purpose of encouraging
   the purchase or rental of, or investment in, property, goods, or services,
   which is transmitted to any person."

   In addition, attached are consumer complaints regarding telemarketing
   calls that your company, or an entity acting on behalf of your company,
   made to telephone lines that are contained in the National Do-Not-Call
   Registry. These complaints indicate that your company, acting under your
   direction, has violated the Commission's rules regarding telephone
   solicitations. See 47 C.F.R. S: 64.1200(c)(2).

   Section 64.1200(c)(2) of the Commission's rules generally prohibits the
   delivery of telephone solicitations to residential telephone numbers that
   are contained in the National Do-Not-Call Registry except in certain
   limited situations. Under the Communications Act and the Commission's
   rules, a "telephone solicitation" is "the initiation of a telephone call
   or message for the purpose of encouraging the purchase or rental of, or
   investment in, property, goods, or services, which is transmitted to any
   person." Calls made by or on behalf of tax-exempt nonprofit groups are not
   considered to be telephone solicitations. Similarly, calls that are made
   to a person who either has provided prior express invitation or permission
   to call or has an established business relationship with the caller are
   not considered to be telephone solicitations. Finally, the rules permit
   telephone solicitations to a consumer whose number is listed on the
   National Do-Not-Call Registry if that consumer has a personal relationship
   with the individual making the calls.

   Accordingly, under the Commission's rules, it is unlawful to deliver a
   telephone solicitation to a residential telephone line on the National
   Do-Not-Call Registry unless: (1) the call is made by or on behalf of a
   tax-exempt nonprofit group; (2) the call is made by a person who has a
   personal relationship with the called party; (3) the called party has
   provided signed, written consent for the call to be made; or (4) the
   called party has made a purchase from, or had a transaction with, the
   caller within the 18 months immediately preceding the call or has made an
   inquiry or application regarding the caller's products or services within
   the three months immediately preceding the call, and the called party has
   not specifically asked the caller to stop all telemarketing calls.

   Entities making telephone solicitations must honor do-not-call
   registrations no later than 31 days after a number is placed on the
   National Do-Not-Call Registry, and for a period of no less than five
   years. To accomplish this, section 64.1200(c)(2)(i)(D) requires entities
   making telephone solicitations to use a version of the National
   Do-Not-Call Registry obtained no more than 31 days before any telephone
   solicitation is made, and to document this process. An entity that does
   not claim one of the exemptions set forth above is not liable for calling
   a telephone number on the National Do-Not-Call Registry only if it is able
   to demonstrate that it has fully complied with the Commission's standards
   governing use of the National Do-Not-Call Registry as set out in section
   64.1200(c)(2)(i)(A)-(E) of the rules, and that the particular telephone
   solicitation call was the result of error.

   If, after receipt of this citation, you or your company violate the
   Communications Act or the Commission's rules in any manner described
   herein, the Commission may impose monetary forfeitures not to exceed
   $11,000 for each such violation or each day of a continuing violation.

   You may respond to this citation within 30 days from the date of this
   letter either through (1) a personal interview at the Commission's Field
   Office nearest to your place of business, or (2) a written statement. You
   may use this response to appeal this citation. For example, you may claim
   that you honored the person's do-not-call request within a reasonable time
   that did not exceed 30 days, or that you can document that the person gave
   permission for the call after making an earlier do-not-call request. In
   addition, your response should specify the actions that you are taking to
   ensure that you do not violate the Commission's rules governing telephone
   solicitation and unsolicited advertisements, as described above.

   You may schedule a personal interview at the nearest Commission field
   office. These offices are located in: Atlanta, GA; Boston, MA; Chicago,
   IL; Columbia, MD; Dallas, TX; Denver, CO; Detroit, MI; Kansas City, MO;
   Los Angeles, CA; New Orleans, LA; New York, NY; Philadelphia, PA; San
   Diego, CA; San Francisco, CA; Seattle, WA; and Tampa, FL. Please call Al
   McCloud at 202-418-2499 if you wish to schedule a personal interview. You
   should schedule any interview to take place within 30 days of the date of
   this letter. You should send any written statement within 30 days of the
   date of this letter to:

   Kurt A. Schroeder

   Deputy Chief

   Telecommunications Consumers Division

   Enforcement Bureau

   Federal Communications Commission

   445 - 12th Street, S.W.

   Washington, D.C. 20554

   You should reference EB-07-TC-3498 when corresponding with the Commission.

   If you request a meeting, reasonable accommodations for people with
   disabilities are available upon request. Include a description of the
   accommodation you will need including as much detail as you can. Also
   include a way we can contact you if we need more information. Please allow
   at least 5 days advance notice; last minute requests will be accepted, but
   may be impossible to fill. Send an e-mail to fcc504@fcc.gov or call the
   Consumer & Governmental Affairs Bureau:

   For sign language interpreters, CART, and other reasonable accommodations:

   202-418-0530 (voice), 202-418-0432 (tty)

   For accessible format materials (braille, large print, electronic files,
   and audio

   format): 202-418-0531 (voice), 202-418-7365 (tty)

   As required by the Privacy Act of 1974, 5 U.S.C. S: 552(a)(e)(3), you are
   hereby notified that the Commission's staff will use all relevant material
   information to determine what, if any, enforcement action is required to
   ensure your compliance with the Commission's rules. This will include any
   information that you disclose in your interview or written statement.

   Finally, you should be aware that the knowing and willful making of any
   false statement or the concealment of any material fact in reply to this
   citation is punishable by fine or imprisonment under 18 U.S.C. S: 1001.

   Thank you in advance for your anticipated cooperation.

   Sincerely,

   Kurt A. Schroeder

   Deputy Chief

   Telecommunications Consumers Division

   Enforcement Bureau

   Federal Communications Commission

   Enclosures

   47 U.S.C. S: 227; 47 C.F.R. S: 64.1200.

   See attached complaint(s).

   47 C.F.R. S: 64.1200(d).

   Consumer.Net v. AT&T, Order, 15 FCC Rcd 281, 298 (1999).

   47 U.S.C. S: 227(a)(3); 47 C.F.R. S: 64.1200(f)(7).

   47 U.S.C. S: 227(a)(3); 47 C.F.R. S: 64.1200(f)(9).

   Prior express invitation or permission to call a number contained on the
   National Do-Not-Call Registry must be evidenced by a signed, written
   agreement between a consumer and seller. The agreement must include both
   the consumer's consent to be called by the particular seller and the
   telephone number to which such calls may be placed. 47 C.F.R. S:
   64.1200(c)(2)(ii).

   An "established business relationship" means "a prior or existing
   relationship formed by a voluntary two-way communication between a person
   or entity and a residential subscriber with or without an exchange of
   consideration, on the basis of the subscriber's purchase or transaction
   with the entity within the eighteen (18) months immediately preceding the
   date of the telephone call or on the basis of the subscriber's inquiry or
   application regarding products or services offered by the entity within
   the three months immediately preceding the date of the call, which
   relationship has not been previously terminated by either party." 47
   C.F.R. S: 64.1200(f)(3). The established business relationship exception
   does not apply when a telephone subscriber has made a company-specific
   do-not-call request. A company-specific do-not-call request terminates an
   established business relationship for telemarketing purposes even if the
   requester continues to do business with the company. 47 C.F.R.

   S: 64.1200(f)(3)(i); see also Rules and Regulations Implementing the
   Telephone Consumer Protection Act of 1991, Report and Order, 7 FCC Rcd
   8752, 8766 n.47, 8770 n.63 (1992); see also H.R. Rep. 102-317, 1st Sess.,
   102nd Cong. at 15 (1991); Charvat v. Dispatch Consumer Services, Inc., 95
   Ohio St. 3d 505, 769 N.E.2d 829 (2002).

   47 C.F.R. S: 64.1200(c)(2)(iii). A "personal relationship" exists if the
   recipient of the call is a "family member, friend, or acquaintance of the
   telemarketer making the call." 47 C.F.R. S: 64.1200(f)(11).

   The 31-day requirement applies to telephone solicitations made on or after
   January 1, 2005. Rules and Regulations Implementing the Telephone Consumer
   Protection Act of 1991, Order, 19 FCC Rcd 19215 (2004). Previously, the
   Commission's rules provided that do-not-call registrations had to be
   honored within 3 months. Rules and Regulations Implementing the Telephone
   Consumer Protection Act of 1991, Report and Order, 18 FCC Rcd 14014,
   14040, para. 38 (2003). The 3-month provision applied to telephone
   solicitations made before January 1, 2005.

   See 47 C.F.R. S: 1.80(b)(3).

   Federal Communications Commission

   2

   2

   Federal Communications Commission

                       FEDERAL COMMUNICATIONS COMMISSION

                            WASHINGTON, D.C.  20554