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                             SEPARATE STATEMENT OF

                       COMMISSIONER JONATHAN S. ADELSTEIN

                                   CONCURRING

   Re: Premio, Inc, File No. EB-06-IH-0853

   Since its inception, the universal service support mechanism for schools
   and libraries (commonly referred to as the E-rate program) has opened up a
   new world of learning and opportunity for millions of school children and
   library patrons. To ensure the continued success of the E-Rate program, we
   must remain committed to monitoring, auditing, reviewing and reinforcing
   the program. A critical part of our Commission oversight is the use of
   debarment, which prohibits bad actors from participating in the program.
   Accordingly, I support our decision in this Order to debar Premio from all
   involvement in the E-Rate program.

   I concur in, rather than approve, this Order because I would have
   supported a longer debarment period. The Commission's rules provide for a
   debarment period of three years, which may be extended to protect the
   public interest or reduced upon a finding of extraordinary circumstances.
   I note that the Department of Justice has encouraged the Commission to
   exercise our debarment policy in a way that encourages early and complete
   cooperation from defendants, and I recognize that the Commission may take
   into account payment of fines and restitution, the length of time that a
   provider has not participated, and most importantly a high degree of
   cooperation with law enforcement. Even weighing these factors, the
   one-year debarment period adopted in this Order falls short, given the
   scope and seriousness of the fraud-related activities in this case.
   Schools do not have unlimited resources, and I am concerned about the
   effect that fraudulent activity like that perpetrated by Premio can have
   for the affected school systems and their students. In this case, a longer
   debarment period would have sent a stronger and clearer message that fraud
   will not be tolerated.

   (...continued from previous page)

                                                               (continued...)

   Federal Communications Commission FCC 06-177

   10

   Federal Communications Commission FCC 06-177