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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                         )                               
                                                                         
                                         )                               
                                                                         
                                         )                               
     In the Matter of                        File No. EB-09-IH-1219      
                                         )                               
     NTS Communications, Inc.                NAL/Acct. No. 201032080024  
                                         )                               
     Apparent Liability for Forfeiture       FRN No. 0004266938          
                                         )                               
                                                                         
                                         )                               
                                                                         
                                         )                               


                  NOTICE OF APPARENT LIABILITY FOR FORFEITURE

   Adopted: May 4, 2010 Released: May 6, 2010

   By the Commission:

   I. INTRODUCTION

    1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find
       that NTS Communications, Inc. ("NTS"), apparently violated section
       254(d) of the Communications Act of 1934, as amended (the "Act"), and
       section 54.706(a) of the Commission's rules, by willfully or
       repeatedly failing to contribute fully and timely to the Universal
       Service Fund ("USF"). Based on our review of the facts and
       circumstances surrounding this matter, and for the reasons discussed
       below, we find that NTS is apparently liable for a total forfeiture of
       $284,250. We find this significant forfeiture is warranted based on
       NTS's repeated failures to satisfy its obligations to the USF,
       spanning well over a year and amounting to a delinquency of more than
       $248,000 to the Fund.

    2. We order NTS to submit within thirty days a report, supported by a
       sworn statement or declaration under penalty of perjury of a corporate
       officer, setting forth in detail its plan to come into compliance with
       the payment obligations discussed herein.

   II. BACKGROUND

    3. The Act codifies Congress's historic commitment to promote universal
       service to ensure that consumers in all regions of the nation have
       access to affordable, quality telecommunications services. In
       particular, section 254(d) of the Act requires, among other things,
       that "[e]very telecommunications carrier [providing] interstate
       telecommunications services . . . contribute, on an equitable and
       nondiscriminatory basis, to the specific, predictable, and sufficient
       mechanisms established by the Commission to preserve and advance
       universal service." In implementing this Congressional mandate, the
       Commission directed all telecommunications carriers providing
       interstate telecommunications services and certain other providers of
       interstate telecommunications to register with the Commission, comply
       with annual and quarterly filing requirements, and contribute to the
       universal service fund based upon their interstate and international
       end-user telecommunications revenues. The Universal Service
       Administrative Company ("USAC") currently administers the USF. USAC
       uses the revenue projections submitted on the quarterly filings to
       determine each carrier's monthly universal service contribution
       amount, and bills them accordingly each month. Consistent with the
       Debt Collection Improvement Act of 1996 ("DCIA"), USF contributions
       that have become over 90 days delinquent are transferred to the
       Commission for further action to collect the outstanding debt. Failure
       by some providers to pay their share into the USF skews the playing
       field by giving them an economic advantage over their competitors, who
       must then shoulder more than their fair share of the costs of
       universal service.

    4. The Commission has established specific procedures for the
       administration of the USF and other associated federal regulatory
       programs. Pursuant to section 54.711(a) of the Commission's rules, a
       carrier is required to file FCC Form 499-A, also known as the annual
       Telecommunications Reporting Worksheet ("annual Worksheet" or "Form
       499-A"), for the purpose of determining its USF, Telecommunications
       Relay Services Fund ("TRS Fund"), Local Number Portability ("LNP"),
       and North American Numbering Plan ("NANP") administration and
       regulatory fee payments, and, with certain exceptions, to file
       Quarterly Telecommunications Reporting Worksheets ("quarterly
       Worksheet" or "Form 499-Q") to determine its monthly universal service
       contribution amounts. These periodic filings trigger a determination
       of liability, if any, and subsequent billing and collection by the
       entities that

   administer the regulatory programs. Carriers must timely pay their
   contribution invoices, and the Commission's rules explicitly warn
   contributors that failure to file forms or submit payments potentially
   subjects them to enforcement action.

    5. NTS is a Texas-based company that has provided telecommunications
       services since 1981. Through subsidiaries, NTS provides
       facilities-based and resold long distance, private line, frame relay,
       ATM, and toll-free telecommunications services. NTS is owned by Xfone,
       Inc.

    6. In July 2009, USAC referred NTS to the Enforcement Bureau (the
       "Bureau") for potential enforcement action, alleging that NTS had
       failed to comply with the Commission's USF contribution rules. The
       Bureau initiated an investigation against NTS on July 31, 2009,
       issuing a letter of inquiry ("LOI") to NTS seeking information about
       its compliance with USF and other related regulatory obligations.
       NTS's LOI Response indicates that it failed to pay certain USAC
       invoices in full and on time. Specifically, NTS failed on two
       occasions to pay any contribution toward its outstanding USF
       obligations, and it made only partial payments toward its USF
       obligations on twelve additional occasions.

   III. DISCUSSION

    7. Under section 503(b)(1) of the Act, any person who is determined by
       the Commission to have willfully or repeatedly failed to comply with
       any provision of the Act or any rule, regulation, or order issued by
       the Commission shall be liable to the United States for a forfeiture
       penalty. Section 312(f)(1) of the Act defines willful as "the
       conscious and deliberate commission or omission of [any] act,
       irrespective of any intent to violate" the law. The legislative
       history to section 312(f)(1) of the Act clarifies that this definition
       of willful applies to both sections 312 and 503(b) of the Act, and the
       Commission has so interpreted the term in the section 503(b) context.
       The Commission may also assess a forfeiture for violations that are
       merely repeated, and not willful.  "Repeated" means that the act was
       committed or omitted more than once, or lasts more than one day. To
       impose such a forfeiture penalty, the Commission must issue a notice
       of apparent liability, and the person against whom the notice has been
       issued must have an opportunity to show, in writing, why no such
       forfeiture penalty should be imposed. The Commission will then issue a
       forfeiture if it finds, based on the evidence, that the person has
       violated the Act or a Commission rule. As set forth below, we conclude
       that NTS is apparently liable for forfeiture for its apparent willful
       and repeated violations of section 254(d) of the Act and section
       54.706(a) of the Commission's rules.

    8. The fundamental issue in this case is whether NTS apparently violated
       the Act and the Commission's rules by willfully or repeatedly failing
       to make required contributions to the USF. We answer this question in
       the affirmative. Based on the facts and circumstances before us, we
       therefore conclude that NTS is apparently liable for a forfeiture of
       $284,250.

    A. NTS Apparently Failed To Make Full and Timely Universal Service Fund
       Contributions

    9. We conclude that NTS has apparently violated section 254(d) of the Act
       and section 54.706 of the Commission's rules by willfully and
       repeatedly failing to contribute fully and timely to the universal
       service support mechanisms. Section 54.706(a) of the Commission's
       rules unambiguously directs that "entities [providing] interstate
       telecommunications to the public . . . for a fee . . . contribute to
       the universal service support mechanisms." "Interstate
       telecommunications" include, among other things, "private line
       service," "toll-free service," and "resale of interstate services"
       such as those provided by NTS. NTS acknowledges that it was required
       to make USF contributions at all relevant times.

   10. NTS failed to make any payment on its USF invoice for the payment due
       in February 2009, made only partial payments toward its outstanding
       balance from March to November 2009, then failed to make any payment
       toward its balance in December 2009. NTS resumed making partial
       payments toward its outstanding balance in January 2010. NTS claims it
       was not able to make full payments to the USF because of financial
       difficulties. We do not credit this argument. During the same period
       of time, the company continued to collect USF surcharges from its
       customers and it continued to receive disbursement credits from the
       USF. As a result of its failures to pay, NTS has maintained large
       outstanding USF balances with USAC since early 2009, and as of March
       22, 2010, had a past due balance of more than $248,000. NTS does not
       dispute that it is obligated to pay the invoiced amounts or that it
       has failed to pay the full balance due to the USF. Based on the record
       developed in our investigation, we find that NTS has apparently
       violated section 254(d) of the Act and section 54.706 of the
       Commission's rules by willfully and repeatedly failing to contribute
       fully and timely to the USF since February 2009.

    B. Proposed Forfeiture Amount

   11. Section 503(b)(1) of the Act provides that any person who willfully or
       repeatedly fails to comply with any provision of the Act or any rule,
       regulation, or order issued by the Commission shall be liable to the
       United States for a forfeiture penalty. Section 503(b)(2)(B) of the
       Act authorizes the Commission to assess a forfeiture of up to $150,000
       for each violation or each day of a continuing violation, up to a
       statutory maximum of $1,500,000 for a single act or failure to act. In
       determining the appropriate forfeiture amount, we consider the factors
       enumerated in section 503(b)(2)(E) of the Act, including "the nature,
       circumstances, extent and gravity of the violation, and, with respect
       to the violator, the degree of culpability, any history of prior
       offenses, ability to pay, and such other matters as justice may
       require," as well as our forfeiture guidelines.

   12. We find that NTS failed to make payments to the USF in February and
       December 2009, and it made only partial payments on a total of twelve
       occasions - between March and November 2009 and between January and
       March 2010. Nonpayment of universal service contributions is an
       egregious offense. It not only deprives the USF of resources necessary
       to preserve and advance universal service, but it also bestows on
       delinquent entities an unfair competitive advantage by shifting to
       compliant contributors the economic costs and burdens associated with
       universal service. An entity's failure to make required universal
       service contributions frustrates Congress's policy objective in
       section 254(d) of the Act to ensure the equitable and
       non-discriminatory distribution of universal service costs among all
       telecommunications providers. The Commission has established a base
       forfeiture amount of $10,000 for each month in which a contributor has
       failed to fully pay required universal service contributions and
       $20,000 for each month in which a contributor has failed to make any
       required universal service contribution, plus an upward adjustment
       based on one-half of the company's approximate unpaid contributions.
       In addition, the Commission has treated failures to pay universal
       service and other obligations as continuing violations. Our forfeiture
       calculation therefore reflects not only violations that began within
       the last twelve months, but all violations, unless they were cured
       more than one year ago.

   13. As a result, we find that NTS is apparently liable for willfully and
       repeatedly failing to contribute fully and timely to the USF on a
       total of fourteen occasions between February 2009 and March 2010.
       Accordingly, we assess a $20,000 forfeiture for each of the two months
       in which NTS failed to remit any contribution toward its outstanding
       USF obligation. We also assess $10,000 for each of the twelve months
       in which NTS contributed less than the amount of its monthly
       obligation, as provided on the corresponding invoices. Thus, we find
       NTS apparently liable for a base forfeiture of $160,000 for its
       willful and repeated failures to contribute fully and timely to the
       USF on fourteen occasions between February 2009 and the date of this
       NAL. Moreover, consistent with our approach for assessing liability
       for apparent USF violations, and taking into account all the factors
       enumerated in section 503(b)(2)(E) of the Act, we also add an upward
       adjustment of $124,250, approximately one-half of the largest amount
       of NTS's unpaid USF contributions due to USAC and the FCC during the
       period at issue, to the base forfeiture. We therefore find NTS
       apparently liable for a forfeiture of $284,250 for its apparent
       willful or repeated failures to contribute fully and timely to the
       USF.

   IV. CONCLUSION

   14. In light of the seriousness, duration and scope of the apparent
       violations, we propose a forfeiture in the amount of $284,250 for
       NTS's failure to pay its USF obligations. We caution that additional
       violations of the Act or the Commission's rules could subject NTS to
       further enforcement action. Such action could take the form of higher
       monetary forfeitures and/or possible revocation of NTS's operating
       authority, including disqualification of NTS's principals from the
       provision of any interstate common carrier services without the prior
       consent of the Commission.

   V. ORDERING CLAUSES

   15. ACCORDINGLY, IT IS ORDERED THAT, pursuant to section 503(b) of the
       Communications Act of 1934, as amended, 47 U.S.C. S: 503(b), and
       section 1.80 of the Commission's rules, 47 C.F.R. S: 1.80, that NTS
       Communications, Inc. is hereby NOTIFIED of its APPARENT LIABILITY FOR
       A FORFEITURE in the amount of $284,250 for willfully and repeatedly
       violating the Act and the Commission's rules.

   16. IT IS FURTHER ORDERED THAT, pursuant to section 1.80 of the
       Commission's Rules, within thirty days of the release date of this
       NOTICE OF APPARENT LIABILITY, NTS SHALL PAY the full amount of the
       proposed forfeiture or SHALL FILE a written statement seeking
       reduction or cancellation of the proposed forfeiture.

   17. IT IS FURTHER ORDERED THAT NTS shall submit within thirty days of the
       release date of this NOTICE OF APPARENT LIABILITY, a report supported
       by a sworn statement or declaration under penalty of perjury of a
       corporate officer setting forth in detail its plan to come into
       compliance with the reporting and payment obligations discussed
       herein. The report must be mailed to Hillary S. DeNigro, Chief,
       Investigations and Hearings Division, Enforcement Bureau, Federal
       Communications Commission, 445 12th Street, S.W., Suite 4-C330,
       Washington, D.C. 20554. NTS shall also transmit a copy of the report
       via email to hillary.denigro@fcc.gov.

   18. Payment of the forfeiture must be made by check or similar instrument,
       payable to the order of the Federal Communications Commission.  The
       payment must include the NAL/Acct. No. and FRN No. referenced above. 
       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. For payment by credit card, an FCC Form 159 (Remittance
       Advice) must be submitted.  When completing the FCC Form 159, enter
       the NAL/Account number in block number 23A (call sign/other ID), and
       enter the letters "FORF" in block number 24A (payment type code). NTS
       will also send electronic notification within forty-eight (48) hours
       of the date said payment is made to chin.yoo@fcc.gov.

   19. The response, if any, to this NOTICE OF APPARENT LIABILITY must be
       mailed to Hillary S. DeNigro, Chief, Investigations and Hearings
       Division, Enforcement Bureau, Federal Communications Commission, 445
       12th Street, S.W., Room 4-C330, Washington, D.C. 20554 and must
       include the NAL/Acct. No. referenced above.

   20. The Commission will not consider reducing or canceling a forfeiture in
       response to a claim of inability to pay unless the petitioner submits:
       (1) federal tax returns for the most recent three-year period; (2)
       financial statements prepared according to generally accepted
       accounting practices (GAAP); or (3) some other reliable and objective
       documentation that accurately reflects the petitioner's current
       financial status. Any claim of inability to pay must specifically
       identify the basis for the claim by reference to the financial
       documentation submitted.

   21. Requests for payment of the full amount of this Notice of Apparent
       Liability under an installment plan should be sent to: Chief Financial
       Officer -- Financial Operations, Federal Communications Commission,
       445 12th Street, S.W., Room 1-A625, Washington, D.C. 20554. For
       answers to questions, please contact the Financial Operations Group
       Help Desk at 1-877-480-3201 or Email: ARINQUIRIES@fcc.gov.

   22. IT IS FURTHER ORDERED that a copy of this NOTICE OF APPARENT LIABILITY
       FOR FORFEITURE shall be sent by certified mail, return receipt
       requested, to NTS Communications, Inc., Barbara Baldwin, Chief
       Executive Officer, 5307 W. Loop 289, Lubbock, TX 79414.

   FEDERAL COMMUNICATIONS COMMISSION

   Marlene H. Dortch

   Secretary

   47 U.S.C. S: 254(d).

   47 C.F.R. S:S: 54.706(a).

   47 U.S.C. S: 254(d).

   47 C.F.R. S:S: 54.706(b), 54.711, 64.1195. See also 47 U.S.C. S: 254(d)
   ("Any other provider of interstate telecommunications may be required to
   contribute to the preservation and advancement of universal service if the
   public interest so requires."). Contributions are based on a contributor's
   projected revenues, and individual universal service contribution amounts
   that are based upon quarterly filings are subject to an annual true-up.
   Id.; 47 C.F.R. S: 54.709(b).

   47 C.F.R. S: 54.701(a).

   See 47 C.F.R. S: 54.709.

   See Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110
   Stat. 1321, 1358 (1996). Pursuant to the "red light rule," the Commission
   withholds action on applications or other requests for benefits by
   delinquent debtors and ultimately dismisses such applications or other
   requests if the delinquency is not resolved. See 47 C.F.R. S: 1.1910.

   Invoices for USF contributions that become over 90 days delinquent are
   transferred to the Commission for further collection. See
   http://www.universalservice.org/fund-administration/contributors/understanding-your-invoice/important-invoicing-deadlines.aspx.
   Debt collection procedures may include further administrative efforts both
   by the Commission and the United States Treasury or, as appropriate, the
   Commission may refer the delinquent debt to the Department of Justice for
   enforced collection action. 47 C.F.R. S: 1.1917. Collection efforts may
   result in additional charges, to include interest and penalties, as
   provided under 31 U.S.C. S: 3717, and administrative charges pursuant to
   47 C.F.R. S:S: 1.1940 and 54.713, 31 C.F.R. S: 285.12(j).

   See FCC Form 499-A Telecommunications Reporting Worksheet  - Annual
   Filing, http://www.fcc.gov/Forms/Form499-A/499a-2009.pdf  (February 2009)
   ("Annual Worksheet").

   See Federal-State Joint Board on Universal Service, Petition for
   Reconsideration filed by AT&T, Report and Order and Order on
   Reconsideration, 16 FCC Rcd 5748 (2001) ("Quarterly Reporting Order"). 
   Carriers report their revenues for the prior quarter by the beginning of
   the second month in each quarter (i.e., February 1, May 1, August 1, and
   November 1). See Quarterly Reporting Order, 16 FCC Rcd at 5755, P: 19 &
   n.32. See also FCC Form 499-Q Telecommunications Reporting Worksheet  -
   Quarterly Filing for Universal Service Contributors,
   http://www.fcc.gov/Forms/Form499-Q/499q.pdf (April 2009) ("Quarterly
   Worksheet").

   See 47 C.F.R. S: 54.709.

   See 47 C.F.R. S: 54.711(a) ("The Commission shall announce by Public
   Notice published in the Federal Register and on its website the manner of
   payment and the dates by which payments must be made."); "Proposed Second
   Quarter 2006 Contribution Factor," Public Notice, 21 FCC Rcd 2379
   (Wireline Comp. Bur. 2006) ("Contribution payments are due on the date
   shown on the invoice."). See also 47 C.F.R. S: 54.713(b) (noting that if a
   USF "contributor fails to make full payment on or before the date due of .
   . . the monthly invoice provided by the Administrator, the payment is
   delinquent."). Id. The Act and our rules, however, do not condition
   payment on receipt of an invoice or other notice from USAC or other fund
   administrator. See 47 U.S.C. S: 254(d); 47 C.F.R. S:S: 54.706(b) and
   64.604(c)(5)(iii)(A). A carrier that does not file may not receive an
   invoice from USAC, but is nonetheless required to contribute to the USF,
   unless its revenues are considered de minimis. See Globcom, Inc., Notice
   of Apparent Liability, 18 FCC Rcd 19890, 19896, P: 5, n.22 (2003)
   ("Globcom NAL") (subsequent history omitted). The instructions for the
   Worksheet include tables for carriers to determine their annual
   contributions. Providers whose annual contribution is less than $10,000
   are considered de minimis and exempted from contributing to the USF. 47
   C.F.R. S: 54.708.

   See 47 C.F.R. S: 54.713.

   See Response of NTS Communications, Inc. to the Enforcement Bureau's July
   31, 2009 Letter of Inquiry, dated August 31, 2009, at response to
   Questions 1 and 2 ("LOI Response").

   Id. at response to Question 4(b).

   Id. at response to Question 4(c).

   Letter from Trent B. Harkrader, Deputy Chief, Investigations & Hearings
   Division, Enforcement Bureau, FCC, to Barbara Baldwin, Chief Executive
   Officer, NTS Communications, Inc., dated July 31, 2009 ("LOI").

   See LOI Response at response to Question 9.

   47 U.S.C. S: 503(b)(1)(B); 47 C.F.R. S: 1.80(a)(1); see also 47 U.S.C. S:
   503(b)(1)(D) (forfeitures for violation of 14 U.S.C. S: 1464).

   47 U.S.C. S: 312(f)(1).

   H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 51 (1982).

   See, e.g., Application for Review of Southern California Broadcasting Co.,
   Memorandum Opinion and Order, 6 FCC Rcd 4387, 4388 (1991) ("Southern
   California Broadcasting Co.").

   See, e.g., Callais Cablevision, Inc., Grand Isle, Louisiana, Notice of
   Apparent Liability for Monetary Forfeiture, 16 FCC Rcd 1359, 1362, P: 10
   (2001) ("Callais Cablevision") (issuing a Notice of Apparent Liability
   for, inter alia, a cable television operator's repeated signal leakage).

   Southern California Broadcasting Co.,  6 FCC Rcd at 4388, P: 5; Callais
   Cablevision, Inc.,  16 FCC Rcd at 1362, P: 9.

   47 U.S.C. S: 503(b); 47 C.F.R. S: 1.80(f).

   See, e.g., SBC Communications, Inc., Apparent Liability for Forfeiture,
   Forfeiture Order, 17 FCC Rcd 7589, 7591, P: 4 (2002) (forfeiture paid).

   47 U.S.C. S: 254(d).

   47 C.F.R. S:S: 54.706(a).

   47 U.S.C. S: 254(d); 47 C.F.R. S: 54.706(a).

   47 C.F.R. S: 54.706(a).

   Id.

   See LOI Response at response to Question 9 and pp. 8-9.

   LOI Response at Exhibit E, Response to Item No. 9.

   The violations continued with each subsequent day on which NTS failed to
   make full payment. See Globcom, Inc., Order of Forfeiture, 21 FCC Rcd
   4710, 4723, P: 35 n.105 (2006) ("Globcom Forfeiture Order") ("Each failure
   to pay the amount due each month constituted a violation that continued
   for more than 10 days."). USAC's practice is to apply partial payments to
   the oldest debt carried on USAC's books first, and not the current billed
   amount. See North American Telephone Network, LLC, Forfeiture Order, 16
   FCC Rcd 4836, 4838, P: 8 n.12 (2001); Intellicall Operator Services,
   Forfeiture Order, 15 FCC Rcd 21771, 21772, P: 6 n.8. This practice was
   codified by the Commission in 2007. See Comprehensive Review of the
   Universal Service Fund Management, Administration, and Oversight;
   Federal-State Joint Board on Universal Service; Schools and Libraries
   Universal Service Support Mechanism; Lifeline and Link Up; Changes to the
   Board of Directors for the National Exchange Carrier Association, Inc.,
   Report and Order, 22 FCC Rcd 16372, 16380-81, P: 16 (2007);  47 C.F.R. S:
   54.713(e). Each violation is considered continuing until cured by full
   payment of each monthly obligation, as provided on the corresponding
   invoices. See Telrite Corp., Notice of Apparent Liability for Forfeiture
   and Order, 23 FCC Rcd 7231, 7238-39, P: 15 (2008) ("Telrite NAL"); Compass
   Global, Inc., Notice of Apparent Liability for Forfeiture, 23 FCC Rcd
   6125, 6140, P: 33 (2008) ("Compass Global NAL"); Global Crossing North
   America, Inc., Notice of Apparent Liability for Forfeiture, 23 FCC Rcd
   6110, 6122, P:P: 25-27 (2008) ("Global Crossing NAL"); VCI Company, Notice
   of Apparent Liability for Forfeiture and Order, 22 FCC Rcd 15933, 15940,
   P: 24 & n.69 (2007) ("VCI NAL"); Matrix Telecom, Inc., Notice of Apparent
   Liability, 15 FCC Rcd 13544 (2000);  Conquest Operator Services Corp., 
   Order of Forfeiture, 14 FCC Rcd 12518, 12525, P: 16 (1999).

   See LOI Response at response to Question 9.

   47 U.S.C. S: 503(b)(1)(B); 47 C.F.R. S: 1.80(a)(2).

   47 U.S.C. S: 503(b)(2)(B); see also 47 C.F.R. S: 1.80(b)(2); Amendment of
   Section 1.80(b) of the Commission's Rules, Adjustment of Forfeiture Maxima
   to Reflect Inflation, Order, 15 FCC Rcd 18221 (2000).

   47 C.F.R. S: 1.80(b)(4), Note, Guidelines for Assessing Forfeitures.

   See supra para. 10.

   See 47 U.S.C. S: 254(d).

   See OCMC, Inc., Order of Forfeiture, 21 FCC Rcd 10479, 10482, P: 10 (2006)
   ("OCMC Forfeiture Order"); Globcom NAL, 18 FCC Rcd at 19903-04, P:P:
   25-27; Globcom Forfeiture Order, 21 FCC Rcd at 4721-24, P:P: 31-38.

   See, e.g., Globcom Forfeiture Order, 21 FCC Rcd at 4722, P: 33; OCMC
   Forfeiture Order, 21 FCC Rcd at 10482, P: 10.

   See, e.g. Global Crossing NAL, 23 FCC Rcd at 6120-21, P:P: 21-24
   (proposing $10,518,013 forfeiture for, inter alia, the apparent failure to
   make required universal service contributions); Telrite NAL, 23 FCC Rcd at
   7245-46, P: 36 (proposing $924,212 forfeiture for, inter alia, the
   apparent  failure to make required universal service contributions);
   Compass Global NAL, 23 FCC Rcd at 6140-42, P:P: 34-38 (proposing
   $828,613.44 forfeiture for, inter alia, the apparent failure to make
   required universal service contributions).

   These months consist of February 2009 and December 2009. See supra para.
   10.

   These months consist of March to November 2009 and January to March 2010.
   See supra para. 10.

   See supra para. 10.

   NTS continues to have an unpaid outstanding balance due to USAC. We note
   that payment of the forfeiture proposed in this NAL does not absolve NTS
   of its obligation to pay its delinquent balance due to the USF. As
   discussed supra at note 8, debt collection procedures may include further
   administrative efforts both by the Commission and by the United States
   Treasury or, as appropriate, the Commission may refer the delinquent debt
   to the Department of Justice for enforced collection action. 47 C.F.R. S:
   1.1917.

   See Business Options, Inc., Consent Decree, 19 FCC Rcd 2916 (2003); NOS
   Communications, Inc., Affinity Network Incorporated and NOSVA Limited
   Partnership, Consent Decree, 2003 WL 22439710 (2003).

   See 47 C.F.R. S: 1.1914.

   See id.

   Federal Communications Commission FCC 10-78

   5

   1

                                  Federal Communications Commission FCC 99-xx