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Before the
Federal Communications Commission
Washington, D.C. 20554
)
)
In the Matter of
) File No.: EB-09-TC-382 File No.:
AT&T Inc. EB-09-TC-385
)
Compliance with the File No.: EB-10-TC-384
Commission's )
Acct. No.: 201132170003
Rules and Regulations Governing )
Customer FRN: 0005193701
)
Proprietary Network Information
)
)
ADOPTING ORDER
Adopted: November 29, 2010 Released: November 29, 2010
By the Chief, Enforcement Bureau:
1. In this Order, we adopt the attached Consent Decree entered into
between the Enforcement Bureau ("Bureau") of the Federal
Communications Commission ("Commission") and AT&T Inc. on behalf of
all AT&T Inc. subsidiaries that are subject to the CPNI rules
(collectively "AT&T" or "Company"). The Consent Decree terminates
investigations initiated by the Bureau regarding AT&T's compliance
with section 222(c)(1) of the Communications Act of 1934, as amended,
47 U.S.C. S: 222(c)(1), and sections 64.2007, 64.2008(d) and
64.2008(d)(3)(v) of the Commission's rules, 47 C.F.R. S:S: 64.2007,
64.2008(d) and 64.2008(d)(3)(v).
2. The Bureau and AT&T have negotiated the terms of a Consent Decree that
resolves these matters. 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 referenced
investigations.
4. In the absence of material new evidence relating to this matter, we
conclude that our investigations raise no substantial or material
questions of fact as to whether AT&T possesses the basic
qualifications, including those related to character, to hold or
obtain any Commission license or authorization.
5. Accordingly, IT IS ORDERED, pursuant to Section 4(i) of the
Communications Act of 1934, as amended, 47 U.S.C. S: 154(i), and the
authority delegated by Section 0.111 and 0.311 of the Commission's
rules, 47 CFR S:S: 0.111 and 0.311, that the attached Consent Decree
IS ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned matter IS 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, to AT&T Services, Inc., 1120 20th Street, NW, Suite 1000,
Washington, DC 20036.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
Before the
Federal Communications Commission
Washington, D.C. 20554
)
)
In the Matter of
) File No.: EB-09-TC-382 File No.:
AT&T Inc. EB-09-TC-385
)
Compliance with the File No.: EB-10-TC-384
Commission's )
Acct. No.: 201132170003
Rules and Regulations Governing )
Customer FRN: 0005193701
)
Proprietary Network Information
)
)
CONSENT DECREE
I. INTRODUCTION
1. The Enforcement Bureau of the Federal Communications Commission and
AT&T Inc., on behalf of all AT&T Inc. subsidiaries that are subject to
the CPNI rules (collectively "AT&T" or "Company"), by their authorized
representatives, hereby enter into this Consent Decree for the purpose
of terminating the Bureau's investigations regarding AT&T's compliance
with section 222(c)(1) of the Communications Act of 1934, as amended
("Communications Act" or "Act"), and sections 64.2007, 64.2008(d), and
64.2008(d)(3)(v) of the Commission's rules.
II. DEFINITIONS
2. For 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. "AT&T" or "Company" means all AT&T Inc. subsidiaries that are subject
to the CPNI rules, including any such companies that may be created
or acquired by AT&T during the term of this Consent Decree. AT&T
represents that Attachment A contains a complete list of such
companies currently in operation.
c. "Bureau" means the Enforcement Bureau of the Federal Communications
Commission.
d. "Commission" or "FCC" means the Federal Communications Commission and
all of its bureaus and offices.
e. "Compliance Plan" means the program described in this Consent Decree
at paragraph 10.
f. "Effective Date" means the date on which the Bureau releases the
Adopting Order.
g. "Investigation EB-09-TC-382" means the investigation commenced by the
Bureau's August 5, 2009 Letter of Inquiry to AT&T described in
paragraph 2 below.
h. "Investigation EB-08-TC-385" means the investigation commenced by the
Bureau's August 5, 2009 Letter of Inquiry to AT&T described in
paragraph 4 below.
i. "Investigation EB-10-TC-384" means the investigation commenced by the
Bureau's March 16, 2010 Letter of Inquiry to AT&T described in
paragraph 5 below.
j. "Investigations" means each and all of Investigation EB-09-TC-382,
Investigation EB-08-TC-385, and Investigation EB-10-TC-384.
k. "Order" or "Adopting Order" means an Order of the Bureau adopting the
terms and conditions of this Consent Decree without change, addition,
or modification, and formally terminating the above-captioned
Investigations.
l. "Parties" means AT&T and the Bureau, each of which is a "Party."
m. "Rules" means those rules and regulations codified in Title 47 of the
Code of Federal Regulations.
III. BACKGROUND
Investigation EB-09-TC-382
3. On June 1, 2009, pursuant to section 64.2009(f) of the Commission's
rules, AT&T filed a notice with the Commission reporting failures in its
customer proprietary network information ("CPNI") opt-out mechanism.
According to AT&T, the CPNI toll-free number used by small business
customers to opt-out was mistakenly disconnected. AT&T reported that when
small business customers called the toll-free number during business
hours, they were automatically routed to a call center to speak to a live
representative, but after hours, they were unable to leave an opt-out
request in the voicemail box. According to AT&T, this resulted in the
improper use of the CPNI of 55 customers in 86 marketing campaigns. The
Bureau issued a letter of inquiry ("LOI") to AT&T on August 5, 2009. AT&T
submitted its response to the LOI on September 4, 2009.
Investigation EB-09-TC-385
4. On June 11, 2009, AT&T reported an additional failure in its CPNI
opt-out mechanism. AT&T reported that, in April 2008, it decided to send
terms and conditions for its inside wire plan in the Welcome Package of
any new small business that purchased inside wire protection. According to
AT&T, however, the company was unaware of a previous but erroneous
instruction by pre-merger Bellsouth to the distribution vendor to remove
CPNI notices in Welcome Packages sent to accounts with inside wire
protection. AT&T reports that this resulted in 71,823 customers who did
not receive CPNI notices, but whose CPNI nonetheless, was used by AT&T in
620 small business marketing campaigns. The Bureau sent an LOI to AT&T on
August 5, 2009, and AT&T submitted its response on September 4, 2009.
Investigation EB-10-TC-384
5. On October 30, 2009, AT&T reported a third failure in its CPNI opt-out
mechanism involving its interactive voice response system or "IVR." Small
business customers calling a toll-free number to opt-out were directed to
leave their requests through the IVR. AT&T reported that on October 14,
2008, a security cleanup of the system inadvertently deleted the coding
that instructed the IVR to send the requests to the CPNI opt-out database.
AT&T states that, despite monitoring of the system, AT&T did not discover
the error until a year later on October 7, 2009. AT&T states further that
it does not make outbound telemarketing calls, and cannot determine with
certainty whether it marketed to the 158 customers who called in during
the relevant period. The Bureau sent an LOI to AT&T on March 16, 2010, and
AT&T submitted its response on April 6, 2010.
IV. TERMS OF AGREEMENT
6. 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. AT&T's decision to enter into this
Consent Decree is expressly contingent upon the Bureau's issuance of an
Adopting Order.
7. Jurisdiction. AT&T agrees that the Bureau has jurisdiction over it and
the matters contained in this Consent Decree and has the authority to
enter into and adopt this Consent Decree.
8. Effective Date; Violations. The Parties agree that this Consent Decree
shall become effective on the Effective Date. Upon the Effective Date, 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 Commission to exercise any
rights and remedies attendant to the enforcement of a Commission order.
9. Termination of Investigation. In express reliance on the covenants and
representations contained herein, and to avoid expenditure of additional
public resources, the Bureau agrees to terminate the Investigations. In
consideration for the termination of these matters and in accordance with
the terms of this Consent Decree, AT&T agrees to the terms, conditions,
and procedures contained herein. The Bureau agrees that, in the absence of
new material evidence related to these matters, it will not use the facts
developed in the Investigations through the Effective Date, 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 AT&T, concerning the matters that were the subject of the
Investigations, or with respect to AT&T's basic qualifications, including
its character qualifications, to be a Commission licensee or authorized
common carrier, provided that AT&T satisfies all of its obligations under
this Consent Decree.
10. Compliance Plan. To resolve and terminate the Investigations, and to
ensure compliance with the Commission's CPNI opt-out rules, AT&T agrees to
implement a Compliance Plan that shall include, but is not limited to, the
terms set forth below. The Compliance Plan shall be applicable to the AT&T
companies that are subject to the CPNI rules as described above in
paragraph 2(b). During the term of this Consent Decree, the Compliance
Plan shall also be applicable to any such entities acquired by AT&T
beginning ninety (90) days after consummation of the acquisition.
A. Opt-out Mechanism Review. AT&T shall perform a monthly review of its
CPNI opt-out mechanisms designed to ensure: (1) that its opt-out
mechanisms are working accurately, (2) that AT&T employees or
AT&T-affiliated company employees responsible for managing and overseeing
AT&T's opt-out mechanisms are communicating effectively regarding any
changes to AT&T's opt-out mechanisms and that the communication methods
have relayed effectively all changes to AT&T's opt-out mechanisms to all
necessary personnel, and (3) that validation testing is completed
successfully, as described below. Specifically, AT&T shall do the
following:
i. Review its CPNI notices to ensure that the opt-out instructions
included in such notices are complete and accurate and that customers can
respond as required by the Rules. This review shall include all notices
regardless of the method (e.g., Welcome Package, web page, email, etc.)
used to deliver the notice to customers.
ii. Review all instructions, including dissemination instructions,
provided to vendors and/or internal organizations related to the
delivery of CPNI notices. This review shall compare the proposed
instructions against any existing instructions to ensure against
unintended results. This review shall be designed to ensure that CPNI
notices are included in applicable Welcome Packages, customer bills,
emails, web pages, etc.
iii. Review sample CPNI notices generated by any new instructions prior to
approving dissemination.
iv. Make a test call to each telephone number included in a CPNI notice
(including, but not limited to, any Interactive Voice Response Systems)
both during and after business hours to ensure that the number is working
properly. Verify that a customer can make an opt-out request, including
electronic ones, and verify that applicable CPNI databases are updated to
reflect the opt-out request.
B. Training. AT&T shall ensure that, within sixty (60) days of the
Effective Date, its employees and any employees of its affiliated
companies responsible for managing the preparation and distribution of
CPNI opt-out notices and/or responsible for the proper operation of AT&T's
opt-out mechanisms have received training regarding the CPNI rules. Such
training shall be repeated annually during the term of this Consent
Decree. AT&T shall ensure that any new (or reassigned) employee of AT&T or
an affiliated company assigned the responsibilities noted in the previous
sentence receives CPNI training within forty-five (45) days of starting
employment (or the new assignment). This training shall focus on federal
CPNI opt-out requirements and the terms of this Plan.
C. Reporting Non-Compliance. AT&T shall report any non-compliance with
this Consent Decree to the Enforcement Bureau within thirty (30) days
after the discovery of non-compliance.
D. Compliance Report. AT&T shall provide a Compliance Report from an
officer, as an agent of the Company, one (1) year after the Effective
Date, and at the end of the two (2) year term, stating that the officer
has personal knowledge that the Company (i) has established operating
procedures intended to ensure compliance with this Consent Decree together
with an accompanying statement explaining the basis for the officer's
certification; (ii) has been utilizing those procedures for the entire
term of the Consent Decree; and (iii) the officer is not aware of any
instances of non-compliance with this Consent Decree that have not
otherwise been disclosed pursuant to subsection (C) above. The
certification must comply with Section 1.16 of the Rules and be subscribed
to as true under penalty of perjury in substantially the form set forth
therein. Such certification must be mailed within fifteen (15) days of the
one (1) and the two (2) year anniversary, and AT&T must mail its
certification to the Chief, Telecommunications Consumers Division,
Enforcement Bureau, Federal Communications Commission, 445 12th Street,
S.W., Washington, D.C. 20554, and must include the file numbers listed
above. AT&T shall also send an electronic copy of its certification to
other Telecommunications Consumers Division staff as directed by the
Division Chief.
E. Term of the Compliance Plan. AT&T shall implement the Compliance Plan
within sixty (60) days of the Effective Date. The term of the Compliance
Plan shall expire two (2) years after the Effective Date.
11. Voluntary Contribution. In consideration for the termination of the
Investigations in accordance with the terms of this Consent Decree, AT&T
agrees to make a voluntary contribution to the United States Treasury,
without further protest or recourse to a trial de novo, in the amount of
two hundred thousand dollars ($200,000) within thirty (30) days after the
Effective Date. This voluntary payment does not constitute a forfeiture
under the Act or FCC rules. The payment 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. AT&T will also send electronic notification to
johnny.drake@fcc.gov on the date said payment is made.
12. Waivers. Provided the Bureau issues an Adopting Order, AT&T 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. 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 AT&T
nor the Bureau shall contest the validity of the Consent Decree or the
Adopting Order, and AT&T and the Bureau shall waive any statutory right to
a trial de novo with respect to the issuance of the Adopting Order and
shall consent to a judgment incorporating the terms of this Consent
Decree. AT&T hereby agrees to waive any claims it 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 contained in this Consent Decree.
13. Invalidity. In the event that this Consent Decree is rendered invalid
by a court of competent jurisdiction, it shall become null and void and
may not be used in any manner in any legal proceeding.
14. Privileged and Confidential Documents. By this Consent Decree, AT&T
neither waives nor alters its right to assert and seek protection from
disclosure of any privileged or otherwise confidential and protected
documents and information, or to seek appropriate safeguards of
confidentiality for any competitively sensitive or proprietary
information.
15. Subsequent Rule or Order. The Parties agree that if any provision of
this Consent Decree is inconsistent with any subsequent rule or order
adopted by the Commission, that provision will be superseded by such
Commission rule or order. In the event that 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) are repealed, this Consent Decree shall be terminated when
the action repealing the rules becomes final.
16. Successors and Assigns. AT&T agrees that the provisions of this
Consent Decree shall be binding on its successors, assigns, and
transferees.
17. Final Settlement. The Parties agree and acknowledge that this Consent
Decree shall constitute a final settlement of the above-described
Investigations. The Parties agree that this Consent Decree does not
constitute either an adjudication on the merits or a factual or legal
finding or determination regarding any compliance or noncompliance by AT&T
with the requirements of the Act or the Commission's rules or orders. The
Parties agree that this Consent Decree is for settlement purposes only,
and that by agreeing to this Consent Decree, AT&T does not admit or deny
any noncompliance, violation, or liability associated with or arising from
its actions or omissions involving the Act or the Commission's rules that
are the subject of this Consent Decree.
18. Modifications. This Consent Decree cannot be modified without the
advance written consent of both parties.
19. 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.
20. Section 208 Complaints; Subsequent Investigations. Nothing in this
Consent Decree shall prevent the Bureau from instituting or recommending
any new Investigation or enforcement proceeding against AT&T in the event
of any alleged future misconduct involving violation of this Consent
Decree, or violation of the Act or the Commission's Rules. Nothing in this
Consent Decree shall prevent the Commission or Bureau from adjudicating
complaints filed pursuant to section 208 of the Act, 47 U.S.C. S: 208,
against AT&T for alleged violations of the Act, or for any other type of
alleged misconduct, regardless of when such misconduct took place. The
Bureau's adjudication of any such complaint will be based solely on the
record developed in that proceeding.
21. Counterparts. This Consent Decree may be signed in 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.
22. Authorized Representative. Each Party represents and warrants to the
other that it has full power and authority to enter into this Consent
Decree.
For: AT&T Inc.
__________ ________________________________
Date Gary L. Phillips
General Attorney and Associate General Counsel
AT&T Inc., on behalf of the AT&T subsidiaries subject to the CPNI rules
For: Federal Communications Commission
__________ ________________________________
Date P. Michele Ellison
Chief, Enforcement Bureau
ATTACHMENT A
AT&T Entity FCC Registration Number
Acadiana Cellular General Partnership 0001837814
ACC Corp. 0014553119
ACC National Telecom Corp 0013443718
Alascom, Inc. 0001572676
Alton CellTel Co. Partnership 0003767290
American Cellular, LLC 0017334806
Ameritech Payphone Services, Inc. 0007586175
AT&T Communications of California, Inc. 0003301702
AT&T Communications of Delaware, LLC. 0012838504
AT&T Communications of Hawaii, Inc. 0014532501
AT&T Communications of Illinois, Inc. 0003301793
AT&T Communications of Indiana, GP 0012838421
AT&T Communications of Maryland, LLC 0012838512
AT&T Communications of Michigan, Inc. 0003301876
AT&T Communications of Nevada, Inc. 0003301959
AT&T Communications of New York, Inc. 0012838462
AT&T Communications of NJ, LP 0012838520
AT&T Communications of Ohio, Inc. 0003301736
AT&T Communications of Pennsylvania, LLC 0012838538
AT&T Communications of Texas, Inc. 0016657918
AT&T Communications of the Midwest, Inc. 0003301751
AT&T Communications of the Mountain States, 0003301892
Inc.
AT&T Communications of the Pacific 0003301710
Northwest, Inc.
AT&T Communications of the South Central 0012838561
States, LLC
AT&T Communications of the Southern States, 0012838553
LLC
AT&T Communications of the Southwest, Inc. 0003301918
AT&T Communications of Virginia, LLC 0012838546
AT&T Communications of Washington, D.C., LLC 0012838488
AT&T Communications of West Virginia, Inc. 0003301785
AT&T Communications of Wisconsin, LP 0012838454
AT&T Corp 0005937974
AT&T Mobility LLC 0004979233
AT&T Mobility of Galveston LLC 0016658122
AT&T Mobility Spectrum LLC 0014980726
AT&T Mobility Texas LLC 0016658148
AT&T of Puerto Rico, Inc. 0001731462
AT&T of the Virgin Islands, Inc. 0003464344
AWACS, Inc. 0010852523
Bauce Communications of Beaumont, Inc. 0001562040
Bellingham Cellular Partnership 0004312559
BellSouth Entertainment, LLC 0005095963
BellSouth International, LLC 0005858907
BellSouth Long Distance d/b/a AT&T Long 0003733318
Distance
BellSouth Mobile Data, Inc. 0013935085
BellSouth Telecommunications, Inc. 0005795679
BizTel, Inc. 0003998978
Bloomington Cellular Telephone Company 0001573328
Bradenton Cellular Partnership 0004312591
Bremerton Cellular Telephone Company 0004312609
Cagal Cellular Communications Corporation 0001803246
CCPR of the Virgin Islands, Inc. 0004499034
CCPR Services, Inc. 0003473709
Centennial Beauregard Cellular LLC 0012921946
Centennial Caldwell Cellular LLC 0008816779
Centennial Cellular Tri-State Operating 0012926176
Partnership
Centennial Claiborne Cellular Corp 0012926184
Centennial Communications Corp. 0009631136
Centennial Hammond Cellular LLC 0012926341
Centennial Lafayette Communications LLC 0012926424
Centennial Michiana License Company LLC 0003296480
Centennial Michigan RSA 6 Cellular Corp. 0010310688
Centennial Michigan RSA 7 Cellular Corp. 0008816944
Centennial Morehouse Celllular LLC 0003574142
Centennial Puerto Rico License Corp. 0003572864
Centennial Puerto Rico Operations Corp. 0003572849
Centennial Randolph Cellular LLC 0008816795
Centennial Southeast License Company LLC 0003296472
Centennial USVI Operations Copr. 0007467384
Champaign CellTelco 0001460537
Chattanooga MSA Limited Partnership 0001842723
Cincinnati SMSA Limited Partnership 0004160842
Cingular Wireless of Texas RSA #11 Limited 0003294048
Partnership
Cingular Wireless of Texas RSA #16 Limited 0003294006
Partnership
DC Newco Parent, LLC 0017235060
Decatur RSA Limited Partnership 0004588455
Dobson Cellular Systems of Alaska, LLC 0015568579
Dobson Cellular Systems, LLC 0017334780
Dobson Communications LLC 0017334889
Edge Wireless, LLC 0003800679
Elkhart Cellular Telephone Company 0012927109
Elkhart Metronet, Inc. 0003594991
Florida RSA No. 2B (Indian River) Limited 0001837566
Partnership
Georgia RSA No. 3 Limited Partnership 0001836998
Highland Cellular, LLC 0008951170
Hood River Cellular Telephone Company, Inc. 0001572924
Houma-Thibodaux Cellular Partnership 0004547931
Illinois Bell Telephone Company 0002860856
Indiana Bell Telephone Company, Inc. 0002904654
Lafayette Cellular Telephone Company 0001545771
Lafayette MSA Limited Partnership 0001682509
Louisiana RSA No. 7 Cellular General 0001837798
Partnership
Louisiana RSA No. 8 Limited Partnership 0001837830
Lubbock SMSA Limited Partnership 0001650787
Madison SMSA Limited Partnership 0002842060
McAllen-Edinburg-Mission SMSA Limited 0001658467
Partnership
Medford Cellular Telephone Company, Inc. 0004312772
Mega Comm LLC 0012927208
Melbourne Cellular Telephone Company 0004312799
Michiana Metronet, Inc. 0003595147
Michigan Bell Telephone Company 0002776771
Milwaukee SMSA Limited Partnership 0002846293
Missouri RSA 11/12 Limited Partnership 0001658418
Missouri RSA 8 Limited Partnership 0001658442
Missouri RSA 9B1 Limited Partnership 0001658426
Nevada Bell Telephone Company 0001552173
New Cingular Wireless PCS, LLC 0003291192
Northeastern Georgia RSA Limited Partnership 0001837152
Ocala Cellular Telephone Co., Inc. 0001573492
Oklahoma City SMSA Limited Partnership 0001658392
Oklahoma Independent RSA 7 Partnership 0010698884
Oklahoma RSA 3 Limited Partnership 0001658376
Oklahoma RSA 9 Limited Partnership 0001658368
Olympia Cellular Telephone Company, Inc. 0004312807
Orlando SMSA Limited Partnership 0001843036
Pacific Bell Telephone Company 0001551530
Pine Bluff Cellular, Inc. 0001722271
Provo Cellular Telephone Company 0004312815
Reno Cellular Telephone Company 0004312864
Rural Newco LLC 0017233826
Salem Cellular Telephone Company 0004312880
Santa Barbara Cellular Systems Ltd. 0004312898
Sarasota Cellular Telephone Company 0004312906
SBC Internet Services, Inc. d/b/a AT&T 0012536033
Internet Services
SBC Long Distance, LLC 0003763497
SNET America, Inc. 0003737707
SNET Diversified Group, Inc. 0007586423
South Bend Metronet Inc. 0008816910
Southwestern Bell Telephone Company 0016627473
St. Cloud Cellular Telephone Company, Inc. 0001572742
TC Systems, Inc. 0012833513
TCG America, Inc. 0003476611
TCG Chicago 0014531990
TCG Colorado 0014532022
TCG Connecticut 0014532048
TCG Dallas 0014532089
TCG Detroit 0014532113
TCG Illinois 0014532162
TCG Indianapolis 0014532204
TCG Joint Venture Holdings Inc. dba TCG 0014532238
Oregon
TCG Kansas City, Inc. 0014532261
TCG Los Angeles, Inc. 0014532287
TCG Maryland 0014532303
TCG Midsouth, Inc. 0014532345
TCG Milwaukee, Inc. 0014532386
TCG Minnesota, Inc. 0014532410
TCG New Jersey, Inc. 0017516725
TCG of the Carolinas, Inc. 0014532428
TCG Ohio 0014532451
TCG Omaha 0014532469
TCG Oregon 0014535009
TCG Phoenix 0014532550
TCG Pittsburgh 0014532576
TCG Rhode Island 0014532592
TCG San Diego 0014532642
TCG San Francisco 0014533004
TCG Seattle 0014533053
TCG South Florida 0014533079
TCG St. Louis 0014533087
TCG Utah 0014533111
TCG Virginia, Inc. 0014533145
TeleCorp Communications, LLC 0011499910
Teleport Communications - Washington DC, 0014533368
Inc.
Teleport Communications Atlanta, Inc. 0014533178
Teleport Communications Houston, Inc. 0014533277
Teleport Communications New York 0014533301
Texas RSA 18 Limited Partnership 0001666072
Texas RSA 19 Limited Partnership 0001666056
Texas RSA 20B1 Limited Partnership 0001665058
Texas RSA 6 Limited Partnership 0001665991
Texas RSA 7B1 Limited Partnership 0001666007
Texas RSA 9B1 Limited Partnership 0001666023
Texas RSA No. 2 Limited Partnership 0004550547
The Ohio Bell Telephone Company 0002946986
The Southern New England Telephone Company 0005049150
Topeka SMSA Limited Partnership 0001658632
Visalia Cellular Telephone Company 0004312971
Wisconsin Bell, Inc. 0002716561
47 U.S.C. S: 222(c)(1).
47 C.F.R. S:S: 64.2007, 64.2008(d), 64.2008(d)(3)(v).
47 C.F.R. S: 64.2009(f).
See Notification Under Section 64.2009(f), CC Docket No. 96-115, Letter
from Davida Grant, General Attorney, AT&T Inc., to William Dever, Acting
Chief, Competition Policy Division, Wireline Competition Bureau, and Erica
McMahon, Chief, Consumer Policy Division, Consumer & Governmental Affairs
Bureau, Federal Communications Commission (June 1, 2009) ("June 1, 2009
Opt-Out Failure Notice").
See Letter of Inquiry from Marcy Greene, Deputy Division Chief,
Telecommunications Consumers Division, Enforcement Bureau, to Davida
Grant, General Attorney, AT&T Inc. (August 5, 2009).
See Letter from Davida Grant, General Attorney, AT&T Inc., to Marcy
Greene, Deputy Division Chief, Telecommunications Consumers Division,
Enforcement Bureau (September 4, 2009).
See Notification Under Section 64.2009(f), CC Docket No. 96-115, Letter
from Davida Grant, General Attorney, AT&T Inc., to William Dever, Acting
Chief, Competition Policy Division, Wireline Competition Bureau, and Erica
McMahon, Chief, Consumer Policy Division, Consumer & Governmental Affairs
Bureau, Federal Communications Commission (June 11, 2009) ("June 11, 2009
Opt-Out Failure Notice").
See supra, fn. 2.
See supra, fn. 3.
See Notification Under Section 64.2009(f), CC Docket No. 96-115, Letter
from Davida Grant, General Attorney, AT&T Inc., to William Dever, Acting
Chief, Competition Policy Division, Wireline Competition Bureau, and Erica
McMahon, Chief, Consumer Policy Division, Consumer & Governmental Affairs
Bureau, Federal Communications Commission (October 30, 2009) ("October
30,2009 Opt-Out Failure Notice").
See Letter of Inquiry from Colleen K. Heitkamp, Division Chief,
Telecommunications Consumers Division, Enforcement Bureau, to Davida
Grant, General Attorney, AT&T Inc. (March 16, 2010).
See Letter from Davida Grant, General Attorney, AT&T Inc., to Colleen
Heitkamp, Division Chief, Telecommunications Consumers Division,
Enforcement Bureau (August 6, 2010).
Federal Communications Commission DA 10-2224
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Federal Communications Commission DA 10-2224