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Before the
Federal Communications Commission
Washington, D.C. 20554
)
)
In the Matter of
)
Global Information Technologies
) File No. EB-08-TC-4005
Compliance with the Commission's File No. EB-08-IH-0615
)
Rules and Regulations Governing NAL/Acct. No. 201132080011
Customer )
FRN: 0007350226
Proprietary Network Information and )
Universal Service Fund Line-Item
Charges )
)
)
ORDER
Adopted: October 4, 2010 Released: October 5, 2010
By the Chief, Enforcement Bureau:
1. In this Order, we adopt the attached Consent Decree entered into
between the Enforcement Bureau (the "Bureau") and Global Information
Technologies ("GIT"). The Consent Decree terminates the enforcement
proceedings initiated by the Bureau against GIT for possible violation
of section 222 of the Communications Act of 1934, as amended ("Act"),
section 64.2009(e) of the Federal Communications Commission's
("Commission") rules, and the Commission's EPIC CPNI Order relating to
the confidentiality of customer proprietary network information, and,
among other things, section 254 of the Act and section 54.712(a) of
the Commission's rules relating to the recovery of universal service
fund contributions from end-user customers.
2. The Bureau and GIT have negotiated the terms of the Consent Decree
that resolve this matter. A copy of the Consent Decree is attached
hereto and incorporated by reference.
3. After reviewing the terms of the Consent Decree and evaluating the
facts before us, we find that the public interest would be served by
adopting the Consent Decree and terminating the investigations.
4. In the absence of material new evidence relating to this matter, we
conclude that the Bureau's investigations raise no substantial or
material questions of fact as to whether GIT possesses the basic
qualifications, including those related to character, to hold or
obtain any Commission license or authorization.
5. Accordingly, IT IS ORDERED that, pursuant to section 4(i) of the Act,
and sections 0.111 and 0.311 of the Commission's Rules, the Consent
Decree attached to this Order IS ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigations ARE
TERMINATED.
7. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree
shall be sent by first class mail and certified mail, return receipt
requested, Ginger Washburn, President, Global Information
Technologies, GIT Satellite LLC, 13740 Research Blvd, Suite Q-2,
Austin, TX 78750.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
Before the
Federal Communications Commission
Washington, D.C. 20554
)
)
In the Matter of
)
Global Information Technologies
) File No. EB-08-TC-4005
Compliance with the Commission's File No. EB-08-IH-0615
)
Rules and Regulations Governing NAL/Acct. No. 201132080011
Customer )
FRN: 0007350226
Proprietary Network Information and )
Universal Service Fund Line-Item
Charges )
)
)
CONSENT DECREE
I. INTRODUCTION
1. The Enforcement Bureau ("the Bureau") of the Federal Communications
Commission (the "Commission" or "FCC") and Global Information Technologies
("GIT") hereby enter into this Consent Decree for the purpose of
terminating the Bureau investigations against GIT for possible violation
of section 222 of the Communications Act of 1934, as amended ("Act"),
section 64.2009(e) of the Commission's rules, and the Commission's EPIC
CPNI Order relating to the confidentiality of customer proprietary network
information, and, among other things, section 254 of the Act and section
54.712(a) of the Commission's rules relating to the recovery of universal
service fund contributions from end-user customers.
II. DEFINITIONS
2. For the purposes of this Consent Decree, the following definitions
shall apply:
a. "Act" means the Communications Act of 1934, as amended, 47 U.S.C.
S: 151 et seq.
b. "Adopting Order" means an Order of the Commission adopting the terms
of this Consent Decree without change, addition, deletion, or
modification.
c. "GIT" means Global Information Technologies and its
predecessors-in-interest and successors-in-interest.
d. "GIT Investigation (EB-08-TC-4005)" means the investigation commenced
by the Bureau's Letter of Inquiry and Omnibus Notice of Apparent
Liability For Forfeiture.
e. "GIT Investigation (EB-08-IH-0615)" means the investigation commenced
by the Bureau's March 17, 2008 Letter of Inquiry and the Bureau's June
10, 2008 Supplemental Letter of Inquiry to GIT.
f. "Bureau" means the Enforcement Bureau of the Federal Communications
Commission.
g. "Commission" and "FCC" mean the Federal Communications Commission and
all of its bureaus and offices.
h. "Compliance Plan" means the program described in this Consent Decree
at paragraph 11
i. "Effective Date" means the date on which the Commission releases the
Adopting Order.
j. "Parties" means GIT and the Bureau.
k. "Rules" means the Commission's regulations found in Title 47 of the
Code of Federal Regulations.
III. BACKGROUND
CPNI Investigation
3. Section 222 imposes the general duty on all telecommunications carriers
to protect the confidentiality of their subscribers' proprietary
information. The Commission has issued rules implementing section 222 of
the Act. The Commission required carriers to establish and maintain a
system designed to ensure that carriers adequately protected their
subscribers' CPNI. Section 64.2009(e) is one such requirement. In 2006,
some companies, known as "data brokers," advertised the availability of
records of wireless subscribers' incoming and outgoing telephone calls for
a fee. Data brokers also advertised the availability of certain landline
toll calls. On April 2, 2007, the Commission strengthened its privacy
rules with the release of the EPIC CPNI Order, which adopted additional
safeguards to protect CPNI against unauthorized access and disclosure. The
EPIC CPNI Order was directly responsive to the actions of databrokers, or
pretexters, to obtain unauthorized access to CPNI. The EPIC CPNI Order
requires that all companies subject to the CPNI rules file annually, on or
before March 1, a certification with the Commission pursuant to amended
rule 47 C.F.R. S: 64.2009(e). Additionally, companies must now provide,
with their certification, "an explanation of any actions taken against
data brokers and a summary of all customer complaints received in the past
year concerning the unauthorized release of CPNI."
4. GIT Investigation (EB-08-TC-4005): A number of companies failed to
comply with the annual certification filing requirement and did not file
compliance certifications on or before March 1, 2008, for the 2007
calendar year. GIT was one of those companies. As a result, the Bureau
sent a Letter of Inquiry to GIT and the other companies, asking them to
provide copies and evidence of its annual CPNI certification filings. GIT
failed to submit satisfactory evidence of its timely filing of its annual
CPNI certifications. GIT ultimately filed its 2007 CPNI certification on
September 10, 2008. In its Omnibus Notice of Apparent Liability for
Forfeiture, the Bureau determined that as a result of GIT's failure to
file annual CPNI certifications, GIT (and the other companies) was in
apparent violation of section 222 of the Act, section 64.2009(e) of the
Commission's rules, and the Commission's EPIC CPNI Order. On March 10,
2009, GIT filed its response to the Omnibus NAL.
Universal Service Investigation
5. The Commission's rules require that entities providing interstate
telecommunications services and certain other providers of interstate
telecommunications contribute to the federal universal service fund
("USF") based upon their interstate and international end-user
telecommunications revenues. The Commission does not require contributors
to recover their universal service contributions from their customers.
Instead, the Commission allows contributors to recover their universal
service contributions from their customers, subject to certain
requirements. Specifically, section 54.712 of the Commission's rules
provides that contribution costs passed through to end-user customers as
federal universal service line-item charges may not exceed the interstate
telecommunications portion of the customers' bills multiplied by the
relevant contribution factor. In addition, section 201(b) requires that
all carrier charges, practices, classifications, and regulations "for and
in connection with" interstate communications services be just and
reasonable, and gives the Commission jurisdiction to enact rules to
implement that requirement.
6. GIT Investigation (EB-08-IH-0615): GIT offers interstate
telecommunications services, primarily satellite services, and is subject
to the requirements discussed above. On March 17, 2008, the Bureau sent a
Letter of Inquiry ("LOI") to GIT inquiring about its compliance with the
Commission's universal service filing and contribution rules, as well as
its rules relating to the recovery from end-user customers of a common
carrier's contributions to the universal service fund, the
telecommunications relay service fund, the North American Numbering Plan
administration, and local number portability administration. GIT submitted
a series of responses between March 25 and April 15, 2008. On June 10,
2008, the Bureau sent a follow-up letter to GIT seeking additional
information. GIT submitted a response to the follow-up letter on June 20,
2008.
IV. TERMS OF AGREEMENT
7. Adopting Order. The Parties agree that the provisions of this Consent
Decree shall be subject to final approval by the Bureau by incorporation
of such provisions by reference in the Adopting Order without change,
addition, modification, or deletion.
8. Jurisdiction. GIT agrees that the Commission has jurisdiction over it
and the matters contained in this Consent Decree and has the authority to
enter into and adopt this Consent Decree.
9. Effective Date; Violations. The Parties agree that this Consent Decree
shall become effective on the date on which the Bureau releases the
Adopting Order. Upon release, the Adopting Order and this Consent Decree
shall have the same force and effect as any other Order of the Commission.
Any violation of the Adopting Order or of the terms of this Consent Decree
shall constitute a separate violation of a Commission Order, entitling
the Bureau to exercise any rights and remedies attendant to the
enforcement of a Commission Order.
10. Termination of Investigations. In express reliance on the covenants
and representations in this Consent Decree and to avoid further
expenditure of public resources, the Bureau agrees to terminate
investigations GIT Investigation (EB-08-TC-4005) and GIT Investigation
(EB-08-IH-0615). In consideration for the termination of said
investigations, GIT agrees to the terms, conditions, and procedures
contained herein. The Bureau further agrees that, in the absence of new
material evidence, the Bureau will not use the facts developed in the
investigations through the Effective Date of the Consent Decree, or the
existence of this Consent Decree, to institute, on its own motion, any new
proceeding, formal or informal, or take any action on its own motion
against GIT concerning the matters that were the subject of the
investigations. The Bureau also agrees that it will not use the facts
developed in these investigations through the Effective Date of this
Consent Decree, or the existence of this Consent Decree, to institute on
its own motion any proceeding, formal or informal, or take any action on
its own motion against GIT with respect to GIT's basic qualifications,
including its character qualifications, to be a Commission licensee or
authorized common carrier.
11. Compliance Plans. For purposes of settling the matters set forth
herein, GIT agrees to create, within sixty (60) calendar days from the
Effective Date, internal Compliance Plans related to GIT's future
compliance with the Act, the Commission's rules, and the Commission's
orders governing the confidentiality of customer proprietary network
information and telecommunications service providers' recovery of
universal service contributions from end-user customers. The Plans will
include, at a minimum, the following components:
a. GIT Investigation (EB-08-TC-4005) Compliance Plan:
a. GIT agrees to take all measures necessary to achieve full compliance
with section 64.2009(e) of the Commission's rules.
b. GIT agrees that, within thirty (30) days from the Effective Date, its
personnel will be trained as to when they are and are not authorized
to use CPNI.
c. GIT further agrees to have an express disciplinary process in place
for the unauthorized use of CPNI within thirty (30) days from the
Effective Date.
d. Additionally, GIT agrees to submit a copy of its annual section
64.2009(e) compliance certificate, which it is required to file
annually in EB Docket 06-36, for each of two (2) years following the
Effective Date of this Consent Decree to the 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. GIT will also send an electronic copy of its certification to
other Telecommunications Consumers Division staff as directed by the
Division Chief.
e. GIT shall report any non-compliance with this Compliance Plan to the
Enforcement Bureau within 30 days after the discovery of
non-compliance.
f. This Consent Decree will expire two (2) years after the Effective
Date or upon the termination of the certification requirement set
forth in section 64.2009(e) of the Commission's rules, 47 C.F.R. S:
64.2009(e), whichever is earlier.
g. GIT will certify at the end of the two (2) year term that it is in
compliance with the terms of the Plan. Such certification must be
mailed within fifteen (15) days after the two-year anniversary of the
Effective Date of this Consent Decree.
b. GIT Investigation (EB-08-IH-0615) Compliance Plan:
a. Compliance Manual. GIT shall create, maintain, and update an FCC
Compliance Manual. GIT personnel who engage in activities related
to FCC regulation of GIT will have ready access to the Compliance
Manual and are to follow the procedures contained therein. The
Compliance Manual will, among other things, describe the rules
and requirements as they apply to GIT regarding the Universal
Service Fund (USF) compliance and reporting requirements. The
Compliance Manual will set forth a schedule of filing and payment
dates associated with the USF. The Compliance Manual will
encourage personnel to contact GIT's Designated Contact or
internal regulatory legal counsel, with any questions or concerns
that arise with respect to GIT's FCC compliance. GIT shall submit
to the Bureau a final version of its Compliance Manual sixty (60)
days after the Effective Date.
b. Compliance Training Program. GIT will establish an FCC compliance
training program for any employee who engages in activities related
to FCC regulation of GIT. Training sessions will be conducted at
least annually for such employees to ensure compliance with the Act
and the FCC's regulations and policies and, for new employees who are
engaged in such activities, within the first sixty (60) days of
employment.
c. Designated Contact. GIT will designate one employee as the point of
contact for all FCC compliance matters.
d. Review and Monitoring. GIT will review the FCC Compliance Manual and
FCC Compliance Training Program annually to ensure that they are
maintained in a proper manner and continue to address the objectives
set forth therein.
e. Compliance Reports. GIT will file Compliance Reports with the
Commission ninety (90) days after the Effective Date, twelve (12)
months after the Effective Date, and twenty-four (24) months after
the Effective Date. Each Compliance Report shall include a compliance
certificate from an officer, as an agent of GIT, stating that the
officer has personal knowledge that GIT has established operating
procedures intended to ensure compliance with this Consent Decree,
together with an accompanying statement explaining the basis for the
officer's compliance certification. All Compliance Reports shall be
submitted to Chief, Investigations & Hearings Division, Enforcement
Bureau, Federal Communications Commission, 445 12th Street, S.W.,
Room 4-C320, Washington, D.C. 20554.
12. Compliance Reporting. All compliance reports and certifications shall
be submitted to the Chief, Telecommunications Consumers Division,
Enforcement Bureau, Federal Communications Commission, 445 12th Street,
S.W., Washington, D.C. 20554 and the Chief, Investigations and Hearings
Division, Enforcement Bureau, Federal Communications Commission, 445 12th
Street, S.W., Washington, D.C. 20554.
13. Termination Date. Unless stated otherwise, the requirements of this
Consent Decree will expire twenty-four (24) months after the Effective
Date or, with respect to those requirements pertaining to the resolution
of the CPNI investigation (EB-08-TC-4005), upon the termination of the
opt-out requirements set forth in sections 64.2001-2009 of the
Commission's rules, 47 C.F.R. S:S: 64.2001-2009, whichever is earlier.
14. Section 208 Complaints; Subsequent Investigations. Nothing in this
Consent Decree shall prevent the Commission or its delegated authority
from adjudicating complaints filed pursuant to section 208 of the Act
against GIT for alleged violations of the Act, or for any other type of
alleged misconduct, regardless of when such misconduct took place. The
Commission's adjudication of any such complaint will be based solely on
the record developed in that proceeding. Except as expressly provided in
this Consent Decree, this Consent Decree shall not prevent the Commission
from investigating new evidence of noncompliance by GIT of the Act, the
rules, or the Adopting Order.
15. Voluntary Contribution. GIT agrees that it will make a voluntary
contribution to the United States Treasury in the amount of twenty-three
thousand five hundred dollars ($23,500) paid out in monthly installments
to be completed within two years of the Effective Date of this Consent
Decree. The payments must be made by check or similar instrument, payable
to the Order of the Federal Communications Commission. The payment must
include the Account Number and FRN Number referenced in the caption to the
Adopting Order. Payment by check or money Order may be mailed to Federal
Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.
Payment by overnight mail may be sent to U.S. Bank - Government Lockbox
#979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101.
Payments by wire transfer may be made to ABA Number 021030004, receiving
bank Federal Reserve Bank of New York, and account number 27000001. GIT
will also send electronic notification on the date said payment is made to
Mika Savir at Mika.Savir@fcc.gov and to Pam Slipakoff at
Pam.Slipakoff@fcc.gov.
16. Notification. GIT also agrees to post a notice on its website, until
termination of this Consent Decree pursuant to the terms of paragraph 13
above, stating: "If you were a customer between January 2005 and June
2008, it is possible we may have collected Universal Service funds from
you that were higher than we were required to pay. If you would like us to
check your account, please contact us at Service@gitsat.com." GIT will
place a link to this notice, entitled "GIT Notices" on the homepage of its
website at www.gitsat.com. To the extent that GIT issues refunds to
customers or former customers as a result of this notice and provides to
the Bureau sufficient documentation of such refunds, the amount of the
voluntary contribution set forth in paragraph 15 remaining due during
months 13 through 24 of the payment period shall be reduced by the amount
refunded.
17. Waivers. GIT 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, provided the Commission issues an Order adopting the
Consent Decree without change, addition, modification, or deletion. GIT
shall retain the right to challenge Commission interpretation of the
Consent Decree or any terms contained herein. 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 GIT nor the Commission
shall contest the validity of the Consent Decree or the Adopting Order,
and GIT shall waive any statutory right to a trial de novo. GIT hereby
agrees to waive any claims they may otherwise have under the Equal Access
to Justice Act, 5 U.S.C. S: 504 and 47 C.F.R. S: 1.1501 et seq., relating
to the matters addressed in this Consent Decree.
18. Subsequent Rule or Order. The Parties agree that if any provision of
the 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 GIT does not expressly consent) that
provision will be superseded by such Commission rule or order.
19. Successors and Assigns. GIT agrees that the provisions of this Consent
Decree shall be binding on their successors, assigns, and transferees.
20. Final Settlement. The Parties agree and acknowledge that this Consent
Decree shall constitute a final settlement between the Parties. The
Parties further agree that this Consent Decree does not constitute either
an admission of liability, an admission of noncompliance, an adjudication
on the merits, or a factual or legal finding or determination regarding
any compliance or noncompliance with the requirements of the Act or the
Commission's Rules and Orders.
21. Modifications. This Consent Decree cannot be modified without the
advance written consent of both Parties.
22. Paragraph Headings. The headings of the Paragraphs in this Consent
Decree are inserted for convenience only and are not intended to affect
the meaning or interpretation of this Consent Decree.
23. Authorized Representative. Each party represents and warrants to the
other that it has full power and authority to enter into this Consent
Decree.
24. Counterparts. This Consent Decree may be signed in any number of
counterparts (including by facsimile), each of which, when executed and
delivered, shall be an original, and all of which counterparts together
shall constitute one and the same fully executed instrument.
________________________________
P. Michele Ellison
Chief, Enforcement Bureau
Federal Communications Commission
________________________________
Date
________________________________
Ginger Washburn
President
Global Information Technologies
________________________________
Date
47 U.S.C. S: 222.
47 C.F.R. S: 64.2009(e).
47 U.S.C. S: 254.
47 C.F.R. S: 54.712(a).
47 U.S.C. S: 154(i).
47 C.F.R. S:S: 0.111, 0.311.
47 U.S.C. S: 222.
47 C.F.R. S: 64.2009(e).
47 U.S.C. S: 254.
47 C.F.R. S: 54.712(a).
See Annual CPNI Certification, Omnibus Notice of Apparent Liability for
Forfeiture, 24 FCC Rcd 2299, 2301 para. 4 (Enforcement Bureau 2009)
("Omnibus NAL").
See Letter from Trent B. Harkrader, Deputy Chief, Investigations and
Hearings Division, Enforcement Bureau, FCC, to Ginger Washburn, Chief
Executive Officer, Global Information Technologies, dated March 17, 2008
("LOI").
See Letter from Trent B. Harkrader, Deputy Chief, Investigations and
Hearings Division, Enforcement Bureau, FCC, to Ginger Washburn, Chief
Executive Officer, Global Information Technologies, dated June 10, 2008
("Supplemental LOI").
Section 222 of the Communications Act, 47 U.S.C S: 222, provides that:
"Every telecommunications carrier has a duty to protect the
confidentiality of proprietary information of, and relating to, other
telecommunications carriers, equipment manufacturers, and customers,
including telecommunication carriers reselling telecommunications services
provided by a telecommunications carrier." Prior to the 1996 Act, the
Commission had established CPNI requirements applicable to the enhanced
services operations of AT&T, the Bell Operating Companies ("BOCs"), and
GTE, and the customer premises equipment ("CPE") operations of AT&T and
the BOCs, in the Computer II, Computer III, GTE Open Network Architecture
("ONA"), and BOC CPE Relief proceedings. See Implementation of the
Telecommunications Act of 1996: Telecommunications Carriers' Use of
Customer Proprietary Network Information and Other Customer Information
and Implementation of Non-Accounting Safeguards of Sections 271 and 272 of
the Communications Act of 1934, as amended, CC Docket Nos. 96-115 and
96-149, Second Report and Order and Further Notice of Proposed Rulemaking,
13 FCC Rcd 8061, 8068-70, para. 7 (1998) ("CPNI Order") (describing the
Commission's privacy protections for confidential customer information in
place prior to the 1996 Act.
See CPNI Order. See also Implementation of the Telecommunications Act of
1996: Telecommunications Carriers' Use of Customer Proprietary Network
Information and Other Customer Information and Implementation of the
Non-Accounting Safeguards of Sections 271 and 272 of the Communications
Act of 1934, as amended, CC Docket Nos. 96-115 and 96-149, Order on
Reconsideration and Petitions for Forbearance, 14 FCC Rcd 14409 (1999);
Implementation of the Telecommunications Act of 1996: Telecommunications
Carriers' Use of Customer Proprietary Network Information and Other
Customer Information and Implementation of the Non-Accounting Safeguards
of Sections 271 and 272 of the Communications Act of 1934, as amended, CC
Docket Nos. 96-115 and 96-149; 2000 Biennial Regulatory Review -- Review
of Policies and Rules Concerning Unauthorized Changes of Consumers' Long
Distance Carriers, CC Docket No. 00-257, Third Report and Order and Third
Further Notice of Proposed Rulemaking, 17 FCC Rcd 14860 (2002); EPIC CPNI
Order.
See, e.g., http://www.epic.org/privacy/iei/.
See id.
EPIC CPNI Order, 22 FCC Rcd 6927. Specifically, pursuant to section
64.2009(e): A telecommunications carrier must have an officer, as an agent
of the carrier, sign and file with the Commission a compliance certificate
on an annual basis. The officer must state in the certification that he or
she has personal knowledge that the company has established operating
procedures that are adequate to ensure compliance with the rules in this
subpart. The carrier must provide a statement accompanying the
certification explaining how its operating procedures ensure that it is or
is not in compliance with the rules in this subpart. In addition, the
carrier must include an explanation of any actions taken against data
brokers and a summary of all customer complaints received in the past year
concerning the unauthorized release of CPNI. This filing must be made
annually with the Enforcement Bureau on or before March 1 in EB Docket No.
06-36, for data pertaining to the previous calendar year. 47 C.F.R. S:
64.2009(e).
Id. at 6928.
Id. at 6953; 47 C.F.R. S: 64.2009(e).
EPIC CPNI Order, 22 FCC Rcd at 6953.
See Omnibus NAL, 24 FCC Rcd at 2308, Appendix.
See Annual CPNI Certification, Omnibus Notice of Apparent Liability for
Forfeiture, 24 FCC Rcd 2299, 2301 para. 4 (Enforcement Bureau 2009)
("Omnibus NAL").
Id.
See Letter from Thomas Lynch, Counsel for Global Information Technologies,
to Marlene H. Dortch, Secretary, FCC, dated Sept. 10, 2008.
See Letter from Thomas Lynch, Counsel for Global Information Technologies,
to Marlene H. Dortch, Secretary, FCC and Marcy Green, Deputy Chief,
Telecommunications Consumers Division, Enforcement Bureau, FCC, dated Mar.
10, 2009 ("GIT Omnibus NAL Response")
See generally 47 C.F.R. S:S: 54.706 - 54.713 (outlining requirements for
contributions to the federal universal service support mechanisms). See
also Federal-State Joint Board on Universal Service, 1998 Biennial
Regulatory Review - Streamlined Contributor Reporting Requirements
Associated with Administration of Telecommunications Relay Services, North
American Numbering Plan, Local Number Portability, and Universal Service
Support Mechanisms, Telecommunications Services for Individuals with
Hearing and Speech Disabilities, and the Americans with Disabilities Act
of 1990, Administration of the North American Numbering Plan and North
American Numbering Plan Cost Recovery Contribution Factor and Fund Size,
Number Resource Optimization, Telephone Number Portability,
Truth-in-Billing and Billing Format, Report and Order and Second Further
Notice of Proposed Rulemaking, 17 FCC Rcd 24952 (2002) ("Interim
Contribution Order").
See Federal-State Board on Universal Service, Report and Order, 12 FCC Rcd
8776, 9210-11, para. 853 (1997) (subsequent history omitted) ("Universal
Service Order").
Id.
47 C.F.R. S: 54.712.
47 U.S.C. S: 201(b).
See LOI.
See Supplemental LOI.
See Letter from Thomas Lynch, Counsel for Global Information Technologies,
to Michele Levy Berlove, Attorney Advisor, Investigations and hearings
Division, Enforcement Bureau, FCC, dated June 20, 2008.
Federal Communications Commission DA 10-1250
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Federal Communications Commission DA 10-1250
Federal Communications Commission DA 10-1250
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Federal Communications Commission DA 10-1250
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