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                                August 17, 2011

                                                                   DA 11-1424

   SENT  VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED

   AND FACSIMILE

   Mr. Tyrone D. Pipkin

   c/o Mr. Walter Francis Becker, Jr.

   Chaffe McCall LLP

   Energy Centre

   1100 Poydras St., Suite 2300

   New Orleans, LA 70163-2300

   Re: Notice of Suspension and Initiation of Debarment Proceedings,

   File No. EB-11-IH-1071

   Dear Mr. Pipkin:

   The Federal Communications Commission ("Commission") has received notice
   of your conviction of conspiracy to defraud the United States in violation
   of 18 U.S.C S: 371 in connection with your participation in the federal
   schools and libraries universal service support mechanism ("E-Rate
   program"). Consequently, pursuant to 47 C.F.R. S: 54.8, this letter
   constitutes official notice of your suspension from the E-Rate program. In
   addition, the Enforcement Bureau ("Bureau") hereby notifies you that the
   Bureau will commence debarment proceedings against you.

   I. Notice of Suspension

   The Commission has established procedures to prevent persons who have
   "defrauded the government or engaged in similar acts through activities
   associated with or related to the schools and libraries support mechanism"
   from receiving the benefits associated with that program. Schools may
   receive E-Rate program funding for eligible goods and services by filing
   application forms, seeking competitive bids, and selecting the most
   cost-effective vendor. To ensure the integrity of the program, the E-rate
   program rules prohibit an E-Rate vendor or anyone associated with an
   E-Rate vendor from participating in the application process or vendor
   selection.

   On March 28, 2011, you entered a plea agreement and pleaded guilty to
   conspiring with others to defraud and obtain money from the E-Rate Program
   by controlling the application, bidding, and implementation process of the
   E-Rate program for schools located in four states. Specifically, you and a
   co-conspirator violated E-Rate program rules by completing E-Rate
   applications on behalf of Innovation Schools and other schools from
   December 2001 through September 2005. Second, you and a co-conspirator
   obstructed the open competitive bidding process by concealing your
   relationship with a school official who devised a scheme to ensure
   Innovation Schools and other schools would hire GNT and Computer Training
   and Associates ("CTA") as their E-Rate service providers. In exchange, you
   and a co-conspirator paid the school official $79,382 in bribes and
   kickbacks for steering E-Rate contracts to your companies. As a result of
   your assistance, Innovation Schools received more than $10,000 in federal
   E-Rate funding in 2003, 2004 and 2005. Your company and CTA directly
   benefited from this scheme by receiving over $1.4 million in E-Rate work
   from Innovation Schools and other schools located in Florida and
   elsewhere. These actions constitute the conduct or transactions upon which
   this suspension notice and proposed debarment proceeding is based.

   On June 21, 2011, the United States District Court for the Eastern
   District of Louisiana sentenced you to serve one year and a day in prison
   followed by a two year period of supervised release for conspiring to
   defraud the federal E-Rate program in multiple states. The court also
   ordered you to pay a $6,000 criminal fine for your role in the conspiracy
   scheme.

   Pursuant to section 54.8(b) of the Commission's rules, upon your
   conviction the Bureau is required to suspend you from participating in any
   activities associated with or related to the schools and libraries support
   mechanism, including the receipt of funds or discounted services through
   the schools and libraries support mechanism, or consulting with,
   assisting, or advising applicants or service providers regarding the
   schools and libraries support mechanism. Your suspension becomes effective
   upon receipt of this letter or publication of the notice in the Federal
   Register, whichever comes first.

   In accordance with the Commission's debarment rules, you may contest this
   suspension or the scope of this suspension by filing arguments, with any
   relevant documents, within 30 calendar days after receipt of this letter
   or after a notice is published in the Federal Register, whichever comes
   first. Such requests, however, will not ordinarily be granted. The Bureau
   may reverse or limit the scope of suspension only upon a finding of
   extraordinary circumstances. Absent extraordinary circumstances, the
   Bureau will decide any request to reverse or modify a suspension within 90
   calendar days of its receipt of such request.

   II. Initiation of Debarment Proceedings

   As discussed above, your guilty plea and conviction of criminal conduct in
   connection with the E-Rate program serves as a basis for immediate
   suspension from the program, as well as a basis to commence debarment
   proceedings against you. Conviction of criminal fraud is cause for
   debarment as defined in section 54.8(c) of the Commission's rules.
   Therefore, pursuant to section 54.8(b) of the rules, your conviction
   requires the Bureau to commence debarment proceedings against you.

   As with the suspension process, you may contest debarment or the scope of
   the proposed debarment by filing arguments and any relevant documentation
   within 30 calendar days of receipt of this letter or publication in the
   Federal Register, whichever comes first. The Bureau, in the absence of
   extraordinary circumstances, will notify you of its decision to debar
   within 90 calendar days of receiving any information you may have filed.
   If the Bureau decides to debar you, its decision will become effective
   upon either your receipt of a debarment notice or publication of the
   decision in the Federal Register, whichever comes first.

   If and when your debarment becomes effective, you will be prohibited from
   participating in activities associated with or related to the schools and
   libraries support mechanism for three years from the date of debarment.
   The Bureau may set a longer debarment period or extend an existing
   debarment period if necessary to protect the public interest.

   Please direct any response, if sent by messenger or hand delivery, to
   Marlene H. Dortch, Secretary, Federal Communications Commission, 445 12th
   Street, S.W., Room TW-A325, Washington, D.C. 20554, to the attention of
   Joy M. Ragsdale, Attorney Advisor, Investigations and Hearings Division,
   Enforcement Bureau, Room 4-A236, with a copy to Theresa Z. Cavanaugh,
   Acting Division Chief, Investigations and Hearings Division, Enforcement
   Bureau, Room 4-C322, Federal Communications Commission. All messenger or
   hand delivery filings must be submitted without envelopes. If sent by
   commercial overnight mail (other than U.S. Postal Service ("USPS") Express
   Mail and Priority Mail), the response must be sent to the Federal
   Communications Commission, 9300 East Hampton Drive, Capitol Heights,
   Maryland 20743. If sent by USPS First Class, Express Mail, or Priority
   Mail, the response should be addressed to Joy Ragsdale, Attorney Advisor,
   Investigations and Hearings Division, Enforcement Bureau, Federal
   Communications Commission, 445 12th Street, S.W., Room 4-A236, Washington,
   D.C. 20554, with a copy to Theresa Z. Cavanaugh, Acting Division Chief,
   Investigations and Hearings Division, Enforcement Bureau, Federal
   Communications Commission, 445 12th Street, S.W., Room 4-C322, Washington,
   D.C. 20554. You shall also transmit a copy of your response via e-mail to
   Joy M. Ragsdale, joy.ragsdale@fcc.gov  and to Theresa Z. Cavanaugh,
   Terry.Cavanaugh@fcc.gov.

   If you have any questions, please contact Ms. Ragsdale via U.S. postal
   mail, e-mail, or by telephone at (202) 418-7931. You may contact me at
   (202) 418-1420 or at the email address noted above if Ms. Ragsdale is
   unavailable.

   Sincerely yours,

   Theresa Z. Cavanaugh

   Acting Chief

   Investigations and Hearings Division

   Enforcement Bureau

   cc: Johnnay Schrieber, Universal Service Administrative Company (via
   e-mail)

   Rashann Duvall, Universal Service Administrative Company (via email)

   Juan Rodriguez, Antitrust Division, United States Department of Justice
   (via email)

   Marvin Opotowsky, Antitrust Division, United States Department of Justice
   (via email)

   Any further reference in this letter to "your conviction" refers to your
   conviction in United States v. Tyrone D. Pipkin, Criminal Docket Nos.
   10-325 and 11-15 "A", Judgment (E.D.LA. filed June 21, 2011) ("Tyrone
   Pipkin Judgment").

   See 47 C.F.R. S: 54.8; 47 C.F.R. S: 0.111 (delegating to the Enforcement
   Bureau authority to resolve universal service suspension and debarment
   proceedings). The Commission adopted debarment rules for the schools and
   libraries universal service support mechanism in 2003. See Schools and
   Libraries Universal Service Support Mechanism, Second Report and Order and
   Further Notice of Proposed Rulemaking, 18 FCC Rcd 9202 (2003) ("Second
   Report and Order")  (adopting section 54.521 to suspend and debar parties
   from the E-rate program). In 2007 the Commission extended the debarment
   rules to apply to all Federal universal service support mechanisms.
   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; Rural
   Health Care 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 app. C at 16410-12 (2007) (Program Management
   Order) (section 54.521 of the universal service debarment rules was
   renumbered as section 54.8 and subsections (a)(1), (5), (c), (d),
   (e)(2)(i), (3), (e)(4), and (g) were amended.)

   Second Report and Order, 18 FCC Rcd at 9225, P: 66; Program Management
   Order, 22 FCC Rcd at 16387, P: 32. The Commission's debarment rules define
   a "person" as "[a]ny individual, group of individuals, corporation,
   partnership, association, unit of government or legal entity, however
   organized." 47 C.F.R. S: 54.8(a)(6).

   47 C.F.R. S:S: 54.504, 54.511(c).

   See Request for Review by Mastermind Internet Services, Inc.,
   Federal-State Joint Board on Universal Service, Changes to the Board of
   Directors of the National Exchange Carrier Association, Inc., CC Docket
   No. 96-45, Order, 16 FCC Rcd 4028, 4032-33 P:P: 10-12 (2000) (Mastermind
   Order) (finding that when an applicant surrenders control of the bidding
   process to an employee of an entity that will also participate in the
   bidding process as a prospective service provider, the applicant
   irreparably impairs its ability to hold a fair and open competitive
   bidding process); see also Universal Service Administrative Company's
   ("USAC") description of an Open and Fair Competitive Bidding Process at
   http://www.universalservice.org/sl/applicants/step03/run-open-fair-competition.aspx.

   United States v. Tyrone D. Pipkin, Criminal Docket No. 11-15 "A", Plea
   Agreement (E.D. La. 2011) ("Plea Agreement"). The conspiracy scheme
   involved schools in Arkansas, Florida, Illinois and Louisiana.

   Tyrone Pipkin is co-owner of Global Networking Technologies, Inc. ("GNT"),
   an E-Rate service provider hired by Innovation Schools and other schools
   located in four states.

   The Bureau will serve notice of suspension and initiation of debarment
   proceedings to Gloria F. Harper, co-owner of GNT and owner of CTA, who
   pleaded guilty to conspiracy on June 2, 2011, and awaits sentencing
   scheduled for the fall of 2011. See Justice News, Dep't of Justice, Former
   Co-Owner of Illinois Technology Company Sentenced to Serve One Year and a
   Day in Prison for Role in Conspiracy to Defraud the Federal E-Rate
   Program, June 21, 2011, at
   http://www.justice.gov/opa/pr/2011/June/11-at-807.html ("Press Release").

   United States v. Tyrone D. Pipkin, Criminal Docket No. 11-15 "A", Factual
   Basis at 2 (E.D. La. 2011) ("Factual Basis").

   Factual Basis at 3, 4. See also United States v. Tyrone D. Pipkin, Docket
   No. 4:10cr67, Indictment at 2 (N.D. Fla. 2010).

   Factual Basis at 4. See also Press Release P: 4.

   Factual Basis at 4.

   Id.

   Second Report and Order, 18 FCC Rcd at 9226, P: 70; 47 C.F.R. S:
   54.8(e)(2)(i).

   Judgment at 2 (The prison term is one year and a day for both Count one of
   Case No. 10-325 and Count one of Case No. 11-15 "A". Both terms will run
   concurrently for a total prison term of one year and one day.).

   Judgment at 5. You were also ordered to immediately pay a $200 Special
   Assessment. Id.

   47 C.F.R. S: 54.8(b). See Second Report and Order, 18 FCC Rcd at
   9225-9227, P:P: 67-74.

   47 C.F.R. S:S: 54.8(a)(1), (d).

   Second Report and Order, 18 FCC Rcd at 9226, P: 69; 47 C.F.R. S:
   54.8(e)(1).

   47 C.F.R. S: 54.8(e)(4).

   Id.

   47 C.F.R. S: 54.8(f).

   Second Report and Order, 18 FCC Rcd at 9226, P: 70; 47 C.F.R. S:S:
   54.8(e)(5), (f).

   "Causes for suspension and debarment are conviction of or civil judgment
   for attempt or commission of criminal fraud, theft, embezzlement, forgery,
   bribery, falsification or destruction of records, making false statements,
   receiving stolen property, making false claims, obstruction of justice and
   other fraud or criminal offense arising out of activities associated with
   or related to the schools and libraries support mechanism, the high-cost
   support mechanism, the rural healthcare support mechanism, and the
   low-income support mechanism." 47 C.F.R. S: 54.8(c). Associated activities
   "include the receipt of funds or discounted services through [the Federal
   universal service] support mechanisms, or consulting with, assisting, or
   advising applicants or service providers regarding [the Federal universal
   service] support mechanisms." 47 C.F.R. S: 54.8(a)(1).

   47 C.F.R. S: 54.8(b).

   Second Report and Order, 18 FCC Rcd at 9226, P: 70; 47 C.F.R. S:
   54.8(e)(3).

   Id., 18 FCC Rcd at 9226, P: 70; 47 C.F.R. S: 54.8(e)(5).

   Id. The Commission may reverse a debarment, or may limit the scope or
   period of debarment upon a finding of extraordinary circumstances,
   following the filing of a petition by you or an interested party or upon
   motion by the Commission. 47 C.F.R. S: 54.8(f).

   Second Report and Order, 18 FCC Rcd at 9225, P: 67; 47 C.F.R. S:S:
   54.8(d), (g).

   Id.

   See FCC Public Notice, DA 09-2529 for further filing instructions (rel.
   Dec. 3, 2009).

   Tyrone D. Pipkin

   August 17, 2011

   Page 3 of 5

                       Federal Communications Commission

                               Enforcement Bureau

                      Investigations and Hearings Division

                       445 12th Street, SW, Suite 4-C330

                             Washington, D.C. 20554