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                                 April 1, 2009



   Turn Key Solutions

   Attn: Efran Leyza, President and CEO

   Nate Villerial

   4920 W Thunderbird Road

   Phoenix, AZ 85306

   Re: File No. EB-09-TC-271

   Dear Mr. Leyza and Mr. Villerial:

   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 violations of the Act and the Federal Communications Commission's
   rules that govern telephone solicitations and unsolicited advertisements.
   As explained below, you may appeal this citation. In addition, future
   violations of the Act or 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 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."

   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
   occurring before September 2, 2008, and $16,000 for each such violation or
   each day of a continuing violation occurring on or after September 2,

   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 are exempt from the telephone solicitation rules, that you
   downloaded and used the National Do-Not-Call Registry in compliance with
   our rules but the person's telephone number was not on that version of the
   Registry, or that the calls were made in error and should be covered by
   the Commission's safe harbor provisions, 47 C.F.R. S: 64.1200(c)(2)(i). 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., Rm. 4-C222

   Washington, D.C. 20554

   Reference File No. EB-09-TC-271 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 or call the Consumer & Governmental Affairs

   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.


   Kurt A. Schroeder

   Deputy Chief, Telecommunications Consumers Division

   Enforcement Bureau

   Federal Communications Commission


   47 U.S.C. S: 227; 47 C.F.R. S: 64.1200. A copy of these provisions is
   enclosed for your convenience. Section 227 was added to the Communications
   Act by the Telephone Consumer Protection Act of 1991 and is most commonly
   known as the TCPA. The TCPA and the Commission's parallel rules restrict a
   variety of practices that are associated with telephone solicitation and
   use of the telephone network to deliver unsolicited advertisements,
   including prerecorded messages to residential telephone lines.

   We have attached one complaint at issue in this citation. Within the
   complaint is the telephone number 312-380-5416, which your business
   utilized during the time period at issue.

   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 C.F.R. S: 64.1200(f)(10).

   See 47 C.F.R. S:1.80(b)(3); Amendment of Section 1.80 of the Commission's
   Rules and Adjustment of Forfeiture Maxima to Reflect Inflation, 15 FCC Rcd
   18221 (2000) (forfeiture maximum set at $11,000 for violators who are not
   common carriers or other entities specifically designated in section 503
   of the Act); Amendment of Section 1.80(b) of the Commission's Rules and
   Adjustment of Forfeiture Maxima to Reflect Inflation, 19 FCC Rcd 10945
   (2004) (amendment of section 1.80(b) to reflect inflation left the
   forfeiture maximum for this type of violator at $11,000); Amendment of
   Section 1.80(b) of the Commission's Rules, Adjustment of Forfeiture Maxima
   to Reflect Inflation, FCC 08-154, rel. June 13, 2008 (amendment of section
   1.80(b) to reflect inflation increased the forfeiture maximum for this
   type of violator to $16,000, effective September 2, 2008).

   See 2003 Order, 18 FCC Rcd at 14042-49; 47 C.F.R. S:
   64.1200(f)(12)(i)-(iii) (exceptions to definition of "telephone

                       Federal Communications Commission



                       Federal Communications Commission


                            WASHINGTON, D.C.  20554