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Before the
Federal Communications Commission
Washington, DC 20554
)
In the Matter of ) File Nos.:
EB-TCD-12-00000304,
Verizon )
EB-TCD-12-00000440
Compliance with the Commission's Rules )
and Regulations Governing Customer Account No.: 201232170009
Proprietary Network Information and )
Toll Free Numbering FRN: 0016304214
)
)
ADOPTING ORDER
Adopted: July 26, 2012 Released: July 26, 2012
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 and Verizon. The Consent Decree terminates the
investigations initiated by the Bureau regarding Verizon's compliance
with Sections 201(b) and 222(c)(1) of the Communications Act of 1934,
as amended, 47 U.S.C. S:S: 201(b), 222(c)(1) and Sections 52.105 and
64.2010(f) of the Commission's rules, 47 C.F.R. S:S: 52.105,
64.2010(f).
2. The Bureau and Verizon have negotiated the terms of the 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 Verizon 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 Sections 0.111 and 0.311 of the Commission's
rules, 47 C.F.R. S:S: 0.111 and 0.311, that the attached Consent
Decree 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, to Tamara Preiss, Vice President, Federal Regulatory
Affairs, 1300 I Street, NW, Suite 400 West, Washington, DC 20005.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
Before the
Federal Communications Commission
Washington, DC 20554
)
In the Matter of ) File Nos.:
EB-TCD-12-00000304,
Verizon )
EB-TCD-12-00000440
Compliance with the Commission's Rules )
and Regulations Governing Customer Account No.: 201232170009
Proprietary Network Information and )
Toll Free Numbering FRN: 0016304214
)
)
CONSENT DECREE
The Enforcement Bureau of the Federal Communications Commission and
Verizon, by their authorized representatives, hereby enter into this
Consent Decree for the purpose of terminating the Enforcement Bureau's
investigations into potential violations by Verizon of Sections 201(b) and
222(c)(1) of the Communications Act of 1934, as amended, and Sections
52.105 and 64.2010(f) of the Commission's rules.
I. DEFINITIONS
1. For the purposes of this Consent Decree, the following definitions
shall apply:
a. "Act" or "Communications 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 Bureau adopting the terms of
this Consent Decree without change, addition, deletion, or
modification.
c. "Affiliate" shall have the same meaning defined in Section 153(1) of
the Communications Act, 47 U.S.C. S: 153(1).
d. "Bureau" means the Enforcement Bureau of the Federal Communications
Commission.
e. "Commission" and "FCC" mean the Federal Communications Commission and
all of its bureaus and offices.
f. "Communications Laws" means collectively, the Act, the Rules, and the
published and promulgated orders and decisions of the Commission to
which Verizon is subject by virtue of its business activities,
including but not limited to Sections 201(b) and 222(c)(1) of the Act
and Sections 52.105 and 64.2010(f) of the Rules.
g. "Compliance Plan" means the compliance obligations and compliance
program described in this Consent Decree at paragraph 10.
h. "CPNI" shall have the meaning set forth at 47 C.F.R. S: 222(h)(1).
i. "CPNI Investigation" means the investigation commenced by the Bureau's
LOI, dated May 3, 2011, regarding Verizon's possible noncompliance
with Section 222(c)(1) of the Act, 47 U.S.C. S: 222(c)(1), and Section
64.2010(f) of the Commission's rules, 47 C.F.R. S: 64.2010(f).
j. "CPNI Rules" means the rules set forth at 47 C.F.R. S: 64.2001 et seq.
and any amendments or additions to those rules subsequent to the
Effective Date.
k. "Effective Date" means the date on which the Bureau releases the
Adopting Order.
l. "Investigations" means both the CPNI Investigation and the Toll Free
Investigation.
m. "June 2010 Settlement" means the Consent Decree executed by and
between the Bureau and Verizon, released on June 28, 2010, and set
forth at 25 FCC Rcd 8019 (Enf. Bur. 2010).
n. "LOI" means letter of inquiry.
o. "Parties" means Verizon and the Bureau, each of which is a "Party."
p. "RespOrg" or "Responsible Organization" shall have the meaning set
forth at 47 C.F.R. S: 52.101(b).
q. "Rules" means the Commission's regulations found in Title 47 of the
Code of Federal Regulations.
r. "Toll Free Number" shall have the meaning set forth at 47 C.F.R. S:
52.101(f).
s. "Toll Free Number Investigation" means the investigation commenced by
the Bureau's LOI dated August 16, 2010, regarding Verizon's possible
noncompliance with Section 52.105 of the Rules.
t. "Toll Free Number Rules" means the rules set forth at 47 C.F.R.
S:S: 52.105-52.111 and any amendments or additions to those rules
subsequent to the Effective Date.
u. "Verizon" or "Company" means the regulated, wholly owned subsidiaries
of Verizon Communications Inc. and their successors and assigns.
II. BACKGROUND
2. Pursuant to Section 222 of the Act, the Commission has adopted rules
to protect the confidentiality of customer proprietary network
information (CPNI). Among other things, these rules generally require
customer notification when a significant account change (SAC), such as
a password change, occurs on a customer's account.
3. On June 28, 2010, Verizon entered into a consent decree with the
Bureau that terminated another CPNI investigation. The compliance plan
contained in the consent decree required Verizon to perform weekly
checks for SAC transaction errors. Verizon was also required under the
consent decree to report any noncompliance with the consent decree
provisions to the Bureau. On March 9, 2011, Verizon informed the
Bureau that its review had identified certain systems requiring
modification to ensure that required SAC notices were timely sent to
customers as required by the CPNI Rules.
4. The Bureau issued an LOI to Verizon on May 3, 2011. The Bureau met
with Verizon on June 1, 2011, at which time Verizon detailed
additional instances in which Verizon's systems and processes required
modification to ensure that SAC notices were sent to consumers. On
June 10, 2011, Verizon submitted a letter detailing those additional
issues. Verizon submitted its response to the LOI on June 30, 2011.
5. Section 52.105 of the Rules prohibits the warehousing of Toll Free
Numbers. Warehousing, generally, is when a Responsible Organization
reserves a Toll Free Number from the Toll Free Number database without
having an actual subscriber for that Toll Free Number.
To investigate potential violations by Verizon of the Toll Free Number
Rules, on August 16, 2010, the Bureau issued an LOI to Verizon Select
Services, Inc. (VSSI), and on September 29, 2010, a subpoena to VSSI .
Verizon provided information in response to the LOI and the subpoena on
various dates. On March 18, 2011, the Bureau issued a second LOI, and on
April 6, 2011, a second subpoena to Verizon. Verizon provided information
in response to the second LOI and subpoena on various dates. According to
Verizon's May 16, 2011, subpoena response, Verizon had reserved toll free
numbers in advance of a subscriber request from 2005 to 2011.
III. 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.
7. Jurisdiction. Verizon 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 as defined herein. 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 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 the
CPNI Investigation and the Toll Free Number Investigation. In
consideration for the termination of the Investigations, Verizon
agrees to the terms, conditions, and procedures contained herein. The
Bureau agrees that absent new material evidence, it will not use the
facts developed in the CPNI Investigation through the Effective Date,
or the existence of this Consent Decree, to institute, on its own
motion, or refer to the Commission, any new proceeding, formal or
informal, or to take, on its own motion, or refer to the Commission,
any action against Verizon concerning the matters that were the
subject of the investigation or with respect to Verizon's basic
qualifications, including its character qualifications, to be a
Commission licensee or hold Commission authorizations. The Bureau also
agrees that absent new material evidence, it will not use the facts
developed in the Toll Free Number Investigation through the Effective
Date, or the existence of this Consent Decree, to institute, on its
own motion, or refer to the Commission, any new proceeding, formal or
informal, or to take, on its own motion, or refer to the Commission,
any action against Verizon concerning the matters that were the
subject of the investigation or with respect to Verizon's basic
qualifications, including its character qualifications, to be a
Commission licensee or hold Commission authorizations.
10. Compliance Plan. For purposes of settling the matters set forth
herein, Verizon shall within thirty (30) calendar days after the
Effective Date, develop and implement a Compliance Plan relating to
Verizon's future compliance with those portions of the Communications
Laws relating to the CPNI Rules and Toll Free Number Rules, and with
the terms and conditions of this Consent Decree. Verizon represents
that it has one or more management employees in each of its business
units who has responsibility for compliance with each of the
Communications Laws that are relevant to its operations; that there
are at least twenty (20) such management employees; and that,
collectively, these management employees exercise responsibility for
Verizon's compliance with all of the Communications Laws that are
relevant to its operations. Verizon agrees that it will either
maintain this compliance structure, or, if it makes changes, shall
ensure that it maintains equivalent management oversight over
compliance with all Communication Laws that are applicable to its
operations. The Compliance Plan shall include, at a minimum, the
following components:
a. Compliance Officer. Within thirty (30) days of the Effective Date,
Verizon shall designate two senior corporate managers to serve as the
Compliance Officers for the CPNI Rules and Toll Free Number Rules
issues, respectively. The Compliance Officers will be responsible for
implementing and administering Verizon's Compliance Plan.
b. Notice of Consent Decree. Within thirty (30) days after the Effective
Date, Verizon shall notify all directors, officers (including the
Compliance Officers), managers, and employees responsible for managing
and overseeing Verizon's SAC notice procedures and toll free number
reservation and assignment of the terms and conditions set forth
herein.
CPNI
c. June 2010 Settlement Obligations. Paragraph 9(B)-(E) of the June 2010
Settlement is hereby incorporated by reference and made a part of this
Consent Decree, except for those portions of paragraph 9(B)-(E) that
are unrelated to SAC notification.
d. SAC Compliance Review Prior to Material Changes. Beginning sixty (60)
days after the Effective Date, Verizon shall perform a monthly review
of each of its mechanisms to disseminate SAC notices to its customers
to ensure (1) that such mechanisms in fact are disseminating SAC
notices as required by the CPNI Rules, and (2) that Verizon employees
(including employees of Verizon Affiliates) responsible for managing
and overseeing Verizon's SAC notice dissemination mechanisms are
communicating effectively to all necessary personnel any changes to
such mechanisms.
e. CPNI Training. Within sixty (60) days after the Effective Date,
Verizon shall reinforce its existing annual CPNI training and
implement an SAC Notice Training Program for the Verizon employees
(including employees of Verizon Affiliates) responsible for managing
the process by which Verizon SAC notices are distributed to customers,
as well as for any managers overseeing such employees. At a minimum,
Verizon shall do the following:
i. Modify its training materials to place additional focus on the
requirements of Section 64.2010(f).
ii. Conduct training that
1. Describes the requirements and prohibitions set forth in the
CPNI Rules, in particular those set forth in Section
64.2010(f) and Section 64.2010(g); and
2. Addresses the potential internal and regulatory consequences
of failing to comply with the Commission's CPNI Rules and
Verizon's methods and procedures concerning CPNI.
iii. Provide the above-described training to new and reassigned
employees responsible for developing or disseminating SAC
notices within forty-five (45) days of when the employees assume
such responsibilities, provided such date is no less than
fifteen (15) days following the Effective Date.
Toll Free Numbers
f. Remedial Measures. Within ten (10) days of the Effective Date, Verizon
shall certify by letter to the Commission, directed to the Chief,
Telecommunications Consumers Division, that as of April 18, 2011,
Verizon has implemented changes to the process and procedures of
Verizon's RespOrgs to ensure that none of Verizon's RespOrgs reserves
or places in working status any Toll Free Number unless the Verizon
RespOrg has a subscriber for whom it is reserving or placing the
number in working status.
g. Toll Free Number Training. Within sixty (60) days of the Effective
Date, Verizon shall provide training to each Verizon employee
(including employees of Verizon Affiliates) who is responsible for
reserving any Toll Free Numbers or assigning any Toll Free Number to
working status for Verizon RespOrgs. At a minimum, the training shall
accomplish the following:
i. Describe the requirements and prohibitions set forth in the Toll
Free Number Rules, in particular Section 52.105 and what it means
for a RespOrg to have an "actual toll free subscriber" when
reserving a toll free number or assigning it to working status.
ii. Address the potential internal and regulatory consequences of
failing to comply with the Commission's Toll Free Rules and
Verizon's methods and procedures concerning toll free numbers.
iii. Be provided to new and reassigned employees who are responsible
for reserving any Toll Free Number or assigning any Toll Free
Number to working status for Verizon RespOrg within forty-five
(45) days of when the employees assume their Toll Free Numbering
responsibilities, provided such date is no less than fifteen
(15) days following the Effective Date.
Other Terms
h. Compliance Reports. Verizon shall submit compliance reports to the
Bureau six (6), twelve (12), eighteen (18), and twenty-four (24)
months after the Effective Date (Compliance Reports).
i. Each Compliance Report shall include a certification by each
Compliance Officer, as an agent of and on behalf of Verizon,
stating that the Compliance Officer has personal knowledge that
Verizon has established and implemented the Compliance Plan, and
after due inquiry is not aware of any instances of noncompliance
with the terms and conditions of this Consent Decree, including
the reporting obligations set forth in paragraph 11.
ii. The Compliance Officer's certification shall be accompanied by a
statement explaining the basis for such certification and 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.
iii. If the Compliance Officer is not able to so certify, the Compliance
Officer, as an agent of and on behalf of Verizon, shall provide the
Commission with a detailed explanation of the reason(s) why and
describe fully each instance of noncompliance; the steps Verizon has
taken or will take to remedy such noncompliance, including the
schedule on which Verizon will take the proposed remedial actions;
and the steps Verizon has taken or will take to prevent the
recurrence of any such noncompliance, including the schedule on
which Verizon will take such preventive action.
iv. All Compliance Reports shall be in writing and directed to the Chief,
Telecommunications Consumers Division, Enforcement Bureau, Federal
Communications Commission, 445 12th Street, SW, Washington, DC 20554.
Verizon shall also send an electronic copy of each Compliance Report
to Donna.Cyrus@fcc.gov and Andra.Cunningham@fcc.gov.
i. Termination. The requirements relating to the Compliance Plan shall
expire twenty-four (24) months after the Effective Date, except where
this Consent Decree specifies a different time period.
11. Reporting Noncompliance. Verizon shall report any noncompliance with
the terms and conditions of this Consent Decree (including paragraph
9(B)-(E) in the June 2010 Settlement that is incorporated by reference
in this Consent Decree as set forth in paragraph 10(c) above), any
noncompliance with Section 64.2010(f) of the Rules to the extent that
such noncompliance is more than an anomaly, or any noncompliance with
the Toll Free Number Rules, within fifteen (15) business days after
discovery of such noncompliance. Such reports shall include a detailed
explanation of (i) each instance of noncompliance, (ii) the steps that
Verizon has taken or will take to remedy such noncompliance, (iii) the
schedule on which Verizon will take the proposed remedial actions, and
(iv) the steps that Verizon has taken or will take to prevent the
recurrence of any such noncompliance. All reports of noncompliance
shall be submitted to the Chief, Telecommunications Consumers
Division, Enforcement Bureau, Federal Communications Commission, 445
12th Street, SW, Rm. 4-C224, Washington, DC 20554, with a copy
submitted electronically to Donna.Cyrus@fcc.gov and
Andra.Cunningham@fcc.gov. The reporting obligations set forth in this
paragraph shall expire twenty-four (24) months after the Effective
Date. In addition, beginning on the Effective Date, Verizon shall, at
the request of the Bureau, meet with the Bureau once each 60-day
period during the term of the Compliance Plan to discuss Verizon's
adherence to the Compliance Plan and its performance under the CPNI
Rules. Verizon agrees to provide the Bureau with information the
Bureau requests concerning these topics.
12. Voluntary Contribution. Verizon agrees that it will make a voluntary
contribution to the United States Treasury in the amount of nine
hundred seventy thousand dollars ($970,000) within thirty (30)
calendar days after the Effective Date. Verizon shall also send
electronic notification of payment to Johnny Drake at
johnny.drake@fcc.gov on the date said payment is made. The payment
must be made by check or similar instrument, wire transfer, or credit
card, and must include the NAL/Account number and FRN referenced
above. Regardless of the form of payment, a completed FCC Form 159
(Remittance Advice) must be submitted. When completing the FCC Form
159, enter the Account Number in block number 23A (call sign/other ID)
and enter the letters "FORF" in block number 24A (payment type
code).
Below are additional instructions you should follow based on the form of
payment you select:
* Payment by check or money order must be made payable to the order of
the Federal Communications Commission. Such payments (along with the
completed Form 159) must be mailed to Federal Communications
Commission, P.O. Box 979088, St. Louis, MO 63197-9000, or sent
via overnight mail to U.S. Bank - Government Lockbox #979088,
SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101.
* Payment by wire transfer must be made to ABA Number 021030004,
receiving bank TREAS/NYC, and Account Number 27000001. To complete
the wire transfer and ensure appropriate crediting of the wired funds,
a completed Form 159 must be faxed to U.S. Bank at (314) 418-4232 on
the same business day the wire transfer is initiated.
* Payment by credit card must be made by providing the required credit
card information on FCC Form 159 and signing and dating the Form 159
to authorize the credit card payment. The completed Form 159 must then
be mailed to Federal Communications Commission, P.O. Box 979088, St.
Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank -
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St.
Louis, MO 63101.
If you have questions regarding payment procedures, please contact the
Financial Operations Group Help Desk by phone, 1-877-480-3201, or by
e-mail, ARINQUIRIES@fcc.gov.
13. Waivers. Verizon 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 Bureau issues an Adopting
Order as defined 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 or Consent Decree, neither Verizon nor the
Commission shall contest the validity of the Consent Decree or the
Adopting Order, and Verizon shall waive any statutory right to a trial
de novo. Verizon 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 addressed in this
Consent Decree.
14. Subsequent Rule or Order. The Parties agree that if any provision of
this 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 Verizon does not
expressly consent), such provision will be superseded by such Rule or
order.
15. Successors and Assigns. Verizon agrees that the provisions of this
Consent Decree shall be binding on its successors, assigns, and
transferees.
16. Final Settlement. The Parties agree and acknowledge that this Consent
Decree shall constitute a final settlement between the Parties to the
CPNI Investigation and the Toll Free Investigation.
17. Modifications. This Consent Decree cannot be modified or amended
without the advance written consent of both Parties.
18. 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.
19. 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, 47 U.S.C. S: 208, against Verizon or its affiliates 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 evidence of noncompliance by Verizon of the Act or
the Rules.
20. Invalidity. In the event that this Consent Decree in its entirety is
rendered invalid by any court of competent jurisdiction, it shall
become null and void and may not be used in any manner in any legal
proceeding.
21. Authorized Representative. The individual signing this Consent Decree
on behalf of Verizon represents and warrants that he or she is
authorized by Verizon to execute this Consent Decree and to bind
Verizon to the obligations set forth herein. The FCC signatory
represents that she is signing this Consent Decree in her official
capacity and that she is authorized to execute this Consent Decree.
22. Counterparts. This Consent Decree may be signed in any number of
counterparts (including by facsimile or scanned form), 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.
For: Federal Communications Commission
__________________________________________
P. Michele Ellison
Chief
Enforcement Bureau
__________________________________________
Date
For: Verizon
__________________________________________
Kathleen G. Ramsey
Associate General Counsel
__________________________________________
Date
In January 2011, the Telecommunications Consumers Division transitioned
pending cases to a new electronic case management system. As part of that
transition, cases received new, electronically assigned file numbers. The
investigation now numbered EB-TCD-12-00000304 was formerly numbered
EB-10-TC-445. The investigation now numbered EB-TCD-12-00000440 was
previously numbered EB-11-TC-011.
In January 2011, the Telecommunications Consumers Division transitioned
pending cases to a new electronic case management system. As part of that
transition, cases received new, electronically assigned file numbers. The
investigation now numbered EB-TCD-12-00000304 was formerly numbered
EB-10-TC-445. The investigation now numbered EB-TCD-12-00000440 was
previously numbered EB-11-TC-011.
47 U.S.C. S:S: 201(b), 222(c)(1).
47 C.F.R. S:S: 52.105, 64.2010(f).
Letter from Richard A. Hindman, Chief, Telecommunications Consumers
Division, FCC Enforcement Bureau, to Tamara Preiss, Vice President,
Federal Regulatory Affairs, Verizon (May 3, 2011) (on file in
EB-11-TC-011).
Letter from Kurt Schroeder, Deputy Chief, Telecommunications Consumers
Division, FCC Enforcement Bureau, to Verizon Select Services aka Verizon
Business (Aug. 16, 2010) (on file in EB-10-TC-445).
47 U.S.C. S: 222.
See 47 C.F.R. S: 64.2010(f).
Verizon, Adopting Order and Consent Decree, 25 FCC Rcd 8019 (Enf. Bur.
2010).
See supra note 4.
See Letter from Tamara Preiss, Vice President, Federal Regulatory Affairs,
Verizon, to Richard A. Hindman, Chief, Telecommunications Consumers
Division, FCC Enforcement Bureau (June 10, 2011) (on file in
EB-11-TC-011).
Letter from Edward Shakin and Mark Montano, Verizon, to Kimberly A. Wild,
Assistant Chief, Telecommunications Consumers Division, FCC Enforcement
Bureau (June 30, 2011) (on file in EB-11-TC-011). On August 3, 2011, and
August 5, 2011, Verizon provided supplemental responses regarding data on
SACs prior to January 1, 2010, for the portals or call centers that were
included in their June 30, 2011, response.
See 47 C.F.R. S: 52.105(a).
Letter from Kurt Schroeder, Deputy Chief, Telecommunications Consumers
Division, FCC Enforcement Bureau, to Verizon Select Services aka Verizon
Business (Aug. 16, 2010) (on file in EB-10-TC-445).
Letter from Kurt Schroeder, Deputy Chief, Telecommunications Consumers
Division, FCC Enforcement Bureau, to Verizon Select Services aka Verizon
Business (Sept. 29, 2010) (on file in EB-10-TC-445).
See Letter from Verizon to Kurt Schroeder, Deputy Chief,
Telecommunications Consumers Division, FCC Enforcement Bureau (Oct. 13,
2010) (on file in EB-10-TC-445); Letter from Verizon to Acting Chief,
Telecommunications Consumers Division, FCC Enforcement Bureau (Oct. 6,
2010) (on file in EB-10-TC-445); Letter from Verizon to Kurt Schroeder,
Deputy Chief, Telecommunications Consumers Division, FCC Enforcement
Bureau (Sept. 22, 2010) (on file in EB-10-TC-445).
Letter from Richard A. Hindman, Chief, Telecommunications Consumers
Division, FCC Enforcement Bureau, to Verizon (Mar. 18, 2011) (on file in
EB-10-TC-445).
Letter from Suzanne M. Tetreault, Deputy Chief, FCC Enforcement Bureau, to
Verizon (Apr. 6, 2011) (on file in EB-10-TC-445).
See Letter from Verizon to Richard A. Hindman, Chief, Telecommunications
Consumers Division, FCC Enforcement Bureau (May 16, 2011) (on file in
EB-10-TC-445) (Supplemental Response); Letter from Verizon to Richard A.
Hindman, Chief, Telecommunications Consumers Division, FCC Enforcement
Bureau (Apr. 18, 2011) (on file in EB-10-TC-445).
See Supplemental Response at 3.
An FCC Form 159 and detailed instructions for completing the form may be
obtained at http://www.fcc.gov/Forms/Form159/159.pdf.
(Continued from previous page)
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Federal Communications Commission DA 12-1146
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Federal Communications Commission DA 12-1146
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