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   April 10, 2008

   VIA CERTIFIED MAIL

   RETURN RECEIPT REQUESTED

   Corporate Image Marketing, Inc.

   Corporate Image Marketing d/b/a Abco Communications

   Corporate Image Marketing d/b/a Brand800.com

   c/o Mr. Anthony B. Kinnear and Mr. Robert Zoglin

   418 Aviation Blvd.

   Suite E

   Santa Rosa, CA 95403

   RE: EB-07-TC-13275

   Dear Mssrs. Kinnear and Zoglin:

   This is an official CITATION, issued pursuant to section 503(b)(5) of the
   Communications Act of 1934, as amended (the "Act"), 47 U.S.C. S:
   503(b)(5), for failure to respond completely and timely to a Commission
   inquiry and for violations of the Federal Communications Commission's
   rules that govern toll free number administration. As explained below,
   future violations of the Act or Commission's rules in this regard may
   subject you and your company to monetary forfeitures.

   Sections 4(i), 4(j), and 403 of the Act afford the Commission broad
   authority to investigate the entities it regulates. Section 4(i)
   authorizes the Commission to "issue such orders, not inconsistent with
   this Act, as may be necessary in the execution of its functions," and
   Section 4(j) states that "the Commission may conduct its proceedings in
   such manner as will best conduce to the proper dispatch of business and to
   the ends of justice." Section 403 likewise grants the Commission "full
   authority and power to institute an inquiry, on its own motion ...
   relating to the enforcement of any of the provisions of this Act."

   Section 251(e)(1) of the Act requires the Commission to ensure that
   numbers are made available on an equitable basis. To meet this obligation,
   the Commission implemented rules to ensure "the efficient, fair, and
   orderly allocation of toll free numbers" and, specifically prohibit the
   warehousing and hoarding of toll free numbers. Warehousing is defined as a
   practice whereby Responsible Organizations ("RespOrgs") reserve toll free
   numbers from the Service Management System database without having a
   customer for whom the numbers are being reserved. Hoarding is defined as a
   practice whereby a toll free subscriber acquires more numbers than the
   subscriber plans to use. Hoarding also includes number brokering, which is
   the selling of a toll free number for a fee. The Commission has found that
   warehousing and hoarding are contrary to the public interest.

   It has come to our attention that your company, acting under your
   direction, reserved toll free numbers, either directly or indirectly
   through an affiliate, from the Service Management System database without
   having an actual toll free subscriber for whom those numbers were being
   reserved. In addition, your company, acting under your direction, engaged
   in the selling of toll free numbers for a fee.

   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, (2) a written statement, or (3)
   a teleconference interview with the Commission's Telecommunications
   Consumers Division in Washington, DC. Your response should specify the
   actions that you are taking to ensure that you do not violate the
   Commission's rules governing the warehousing and hoarding of toll free
   numbers, as described above.

   Please contact Sharon Lee at (202) 418-7534 to arrange for an interview at
   the closest field office, 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:

   Sharon D. Lee

   Associate Chief

   Telecommunications Consumers Division

   Enforcement Bureau

   Federal Communications Commission

   445-12th Street, S.W., Rm. 4-A222

   Washington, D.C. 20554

   Reference EB-07-TC-13275 when corresponding with the Commission.

   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).

   Under the Privacy Act of 1974, 5 U.S.C. S: 552(a)(e)(3), we are informing
   you that the Commission's staff will use all relevant material information
   before it, including information that you disclose in your interview or
   written statement, to determine what, if any, enforcement action is
   required to ensure your compliance with the Communications Act and the
   Commission's rules.

   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,

   Colleen K. Heitkamp

   Chief, Telecommunications Consumers Division

   Enforcement Bureau

   Federal Communications Commission

   Enclosures

   cc: Todd Daubert

   Isaac Himowitz

   See 47 C.F.R. S:S: 52.105 and 52.107. A copy of these provisions is
   enclosed for your convenience.

   47 U.S.C. S: 154(i).

   47 U.S.C. S 154(j).

   47 U.S.C. S: 403.

   47 U.S.C. S: 251(e)(1). See also Toll Free Service Access Codes, Second
   Report and Order and Further Notice of Proposed Rulemaking, CC Docket No.
   95-155, 12 FCC Rcd 11162 (1997) (Second Report and Order).

   See Second Report and Order, 12 FCC Rcd 11162 (1997). See also Toll Free
   Service Access Codes, Fourth Report and Order, CC Docket No. 95-155, 13
   FCC Rcd 9058 (1998); see also Toll Free Service Access Codes, Fifth Report
   and Order, CC Docket No. 95-155, 15 FCC Rcd 11939 (2000).

   47 C.F.R. S: 52.105.

   47 C.F.R. S: 52.107.

   Id.

   See Second Report and Order, 12 FCC Rcd 11162  at paras. 25 and 30
   (requiring language be added to the SMS tariff and the LECs' toll free
   database access tariffs to make RespOrgs aware of the Commission's
   conclusions on the subject of warehousing and hoarding). See also sections
   52.105 and 52.107 of the Commission's rules, 47 C.F.R. S:S: 52.105 and
   52.107.

   Federal Communications Commission DA 08-825

   2

   2

   Federal Communications Commission DA 08-825

                       FEDERAL COMMUNICATIONS COMMISSION

                            WASHINGTON, D.C.  20554