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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                         )                               
                                                                         
                                         )                               
     In the Matter of                        File No. EB-08-IH-1386      
                                         )                               
     Telseven, LLC                           NAL/Acct. No. 201232080024  
                                         )                               
     Patrick B. Hines                        FRN 0009834466              
                                         )                               
     Apparent Liability for Forfeiture       FRN 0021816459              
                                         )                               
                                                                         
                                         )                               


                  NOTICE OF APPARENT LIABILITY FOR FORFEITURE

   Adopted: June 14, 2012 Released: June 14, 2012

   By the Commission:

   I. INTRODUCTION

    1. In this Notice of Apparent Liability for Forfeiture (NAL), we find
       that Telseven, LLC (Telseven or Company) apparently violated: (1)
       Section 254(d) of the Communications Act of 1934, as amended (Act),
       and Section 54.706 of the Commission's rules by willfully or
       repeatedly failing to contribute fully to the Universal Service Fund
       (USF); (2) Section 54.711(a) of the Commission's rules by willfully or
       repeatedly filing inaccurate FCC Forms 499-Q; (3) Section 251(e)(2) of
       the Act and Section 52.17 the Commission's rules by willfully or
       repeatedly failing to make full contributions to the administration of
       the North American Numbering Plan (NANP); (4) Section 251(e)(2) of the
       Act and Section 52.32(a) of the Commission's rules by willfully or
       repeatedly failing to make full contributions to the administration of
       local number portability (LNP); and (5) Sections 1.1154 and
       1.1157(b)(1) of the Commission's rules by willfully or repeatedly
       failing to pay regulatory fees when due. Based on our review of the
       facts and circumstances surrounding this matter, and for the reasons
       discussed below, we find that Telseven is apparently liable for
       forfeiture penalties totaling one million, seven hundred fifty-eight
       thousand, four hundred sixty-five dollars ($1,758,465).

   II. BACKGROUND

    2. 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
       USF based on their interstate and international end-user
       telecommunications revenues. The Universal Service Administrative
       Company (USAC) currently administers the USF. USAC uses contributors'
       revenue projections, as reported on Form 499-Q, to determine each
       contributor's monthly universal service contribution obligation and
       bills the carrier accordingly each month. Consistent with the Debt
       Collection Improvement Act of 1996 (DCIA), USAC transfers invoices for
       USF contributions that have become over 90 days delinquent to the
       Commission for further action to collect the outstanding debt. A
       provider's failure to pay its share into the USF skews the playing
       field by giving the provider an economic advantage over its
       competitors, who must then shoulder more than their fair share of the
       costs of universal service.

    3. Section 251(e)(1) of the Act directs the Commission to oversee the
       administration of telecommunications numbering to ensure the
       availability of telephone numbers on an equitable basis. Section
       251(e)(2) of the Act requires that "[t]he cost of establishing
       telecommunications numbering administration arrangements . . . shall
       be borne by all telecommunications carriers on a competitively neutral
       basis as determined by the Commission." In carrying out this statutory
       directive, the Commission adopted Section 52.17 of its rules, which
       requires, among other things, that all telecommunications carriers
       contribute on the basis of their end-user telecommunications revenues
       for the prior calendar year on a competitively neutral basis to meet
       the costs of numbering administration.

    4. Section 251(b)(2) of the Act establishes that every telecommunications
       carrier has a duty to provide local number portability in accordance
       with requirements established by the Commission. Section 251(e)(2) of
       the Act requires, in pertinent part, that "[t]he cost of
       establishing . . . number portability shall be borne by all
       telecommunications carriers on a competitively neutral basis as
       determined by the Commission." In implementing this statutory
       directive, the Commission adopted Section 52.32 of its rules, which
       requires, among other things, that all telecommunications carriers
       contribute to the costs of local number portability on the basis of
       their end-user telecommunications revenues for the prior calendar
       year.

    5. Pursuant to Section 1.1151 of the Commission's rules, providers of
       interstate telecommunications services and other providers must pay
       regulatory fees to the Commission to cover the costs of certain
       regulatory activities. In particular, Sections 1.1154 and 1.1157(b)(1)
       of the Commission's rules require that interstate telecommunications
       carriers pay regulatory fees on the basis of their interstate and
       international end-user revenues. Such fees must be paid on an annual
       basis, and failure to do so subjects a carrier to late payment
       penalties, as well as to possible revocation of its operating
       authority. Further, under its "red light rule," the Commission
       withholds action on applications or requests for benefits from any
       entity that has failed to timely meet its USF, TRS, NANP, and LNP
       contribution obligations or to pay its regulatory fees when due, and
       ultimately dismisses such applications or other requests if the
       delinquencies are not resolved.

    6. The Commission has established specific procedures for the
       administration of the USF, numbering, LNP, regulatory fee, and other
       associated federal regulatory programs. The procedures include the
       requirement that each telecommunications provider file accurate
       company-specific revenue data on FCC Form 499-A annually. With certain
       exceptions, interstate telecommunications providers also must file
       good faith estimates of their projected revenue on Form 499-Q. The
       numbering program and LNP administrators and the Commission use the
       data reported on Form 499-A to determine and bill for the
       telecommunications provider's LNP administration, numbering
       administration, and regulatory fee payment obligations, and USAC uses
       that data as well as the data reported on Form 499-Q to determine and
       bill for the provider's USF contribution obligations. Carriers must
       pay their contribution invoices in a timely manner, and the
       Commission's rules explicitly warn contributors that failure to file
       forms or submit payments potentially subjects them to enforcement
       action.

    7. Telseven is a Florida-based company that held itself out and
       registered with the Commission as a "provider of interstate
       telecommunications services." Telseven described its
       telecommunications service as an "interstate Enhanced Number
       Assistance Directory Service" (ENADA). This service, according to
       Telseven, offered consumers the ability to obtain information about
       recently disconnected or out-of-service toll free numbers. A consumer
       using this service would contact Telseven by dialing one of the
       approximately one million such numbers that Telseven controlled. A
       consumer dialing one of these numbers typically heard a message
       offering Telseven's assistance in finding the current toll-free number
       of the party the consumer was trying to reach. A recorded message
       would then provide the consumer with an "equal access code" (i.e.,
       dial-around number) for contacting Telseven's directory assistance
       platform in Nevada. Consumers dialing this equal access code would
       have their calls transmitted to the Nevada platform by Telseven,
       rather than by the consumer's prescribed long distance carrier. Since
       Telseven did not offer service in Nevada, all calls using this equal
       access number were interstate long distance calls.

    8. Telseven imposed per call charges on many of the consumers who
       contacted its Nevada platform. These charges included, in addition to
       any fees that Telseven imposed for transmission to the Nevada platform
       and the other aspects of Telseven's purported service, a per call
       "Federal Universal Service Fund charge." Telseven also "charge[d] an
       administrative recovery fee of $1.65 in any month" the consumer dialed
       its "directory assistance service . . . to offset the cost Telseven
       incurs in complying with regulatory obligations" including "the cost
       of complying with the Federal Universal Service Charge."

    9. On July 2, 2008, the Enforcement Bureau (Bureau) issued a letter of
       inquiry (LOI) to Telseven seeking information about its compliance
       with the USF contribution rules and other related regulatory
       obligations. On September 22, 2008, Telseven responded to the LOI. In
       response to the Bureau's requests for additional financial information
       and the identity of all Telseven affiliates, Telseven filed
       supplemental information on December 18, 2009, June 15, 2010, and July
       12, 2010. The information developed through the Bureau's investigation
       indicates that Telseven apparently failed to fully and timely
       contribute to the USF and the NANP and LNP cost recovery mechanisms,
       provide good faith estimates of its projected telecommunication
       revenue in its Quarterly Worksheets, and pay its annual regulatory
       fees to the Commission.

   10. On April 20, 2012, Telseven filed for Chapter 7 bankruptcy in the
       United States Bankruptcy Court for the Middle District of Florida,
       Jacksonville Division. Telseven informed the Bureau of this Chapter 7
       bankruptcy filing on April 23, 2012. By April 26, 2012, Telseven's
       Internet website stated that the Company is "no longer providing
       services."

   III. DISCUSSION

   11. 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.

   12. The fundamental issues in this case are whether Telseven apparently
       violated the Act and the Commission's rules by willfully or repeatedly
       failing to make required contributions to the USF and the NANP and LNP
       cost recovery mechanisms, by failing to file accurate Quarterly
       Worksheets, and by failing to pay required regulatory fees to the
       Commission. We answer these questions in the affirmative. As set forth
       below, we conclude that Telseven is apparently liable for forfeiture
       for willful or repeated violations of Section 251(e)(2) and 254(d) of
       the Act and Sections 1.1154, 1.1157(b)(1), 52.17, 52.32(a), 54.706,
       and 54.711 of the Commission's rules. Based on the facts and
       circumstances before us, we therefore conclude that Telseven is
       apparently liable for forfeitures totaling one million, seven hundred
       fifty-eight thousand, four hundred sixty-five dollars ($1,758,465).

    A. Telseven Apparently Failed to Make Full and Timely Universal Service
       Fund Contributions

   13. We conclude that Telseven apparently violated Section 254(d) of 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 support mechanisms. Section 54.706(a) of the Commission's
       rules unambiguously directs that "[e]ntities [providing] interstate
       telecommunications to the public . . . for a fee . . . must contribute
       to the universal service support mechanisms." As set forth above,
       Telseven not only held itself out as-and has registered as-a provider
       of "interstate telecommunications services," but apparently also
       provided and charged for the interstate long distance transmission to
       its Nevada platform. Indeed, Telseven's fees to the public apparently
       included both per-call and monthly charges for the USF. Those fees, in
       combination with Telseven's registration with the Commission as a
       provider of interstate telecommunications services, make clear that
       Telseven was holding itself out to the public as providing an
       interstate telecommunications service.

   14. According to USAC, Telseven's outstanding balance due for delinquent
       USF contributions is $1,056,929.62. Our rules direct USAC to apply the
       "American Rule" of accounting whereby any USF payment of less than the
       total amount due is applied first to the oldest past due debt. On the
       basis of that rule, USAC determined that the last monthly USF invoice
       that Telseven paid in full was the invoice dated October 22, 2007 and
       due November 15, 2007, and that the last monthly USF invoice that
       Telseven partially paid was the invoice dated November 22, 2007 and
       due December 14, 2007.

   15. In its April 2009 and July 2009 Form 499-Q filings, Telseven projected
       such low telecommunications revenues that USAC placed the company in
       de minimis status for 2009, meaning that Telseven would not be
       required to contribute to the USF for that year. Based on the actual
       revenues reported by Telseven on its Form 499-A for 2009, Telseven was
       not de minimis in 2009. This resulted in subsequent true-up billing by
       USAC for each month from July 2010 through September 2010. The last
       invoice USAC issued to Telseven with new USF contribution charges was
       for September 2010. For each month from October 2010 through February
       2011, inclusive, the invoices USAC issued to Telseven added interest
       on unpaid obligations and DCIA penalty charges as our rules require.
       After February 2011, USAC transferred all of Telseven's outstanding
       USF debt to the Commission for collection in accordance with the DCIA.
       USAC therefore has not sent any additional invoices to Telseven since
       February 22, 2011. The absence of a monthly invoice from USAC,
       however, does not relieve Telseven of its outstanding payment
       obligations. The Commission has repeatedly stated that carriers must
       pay their obligations to USAC regardless of whether or not they
       receive a bill from USAC. Telseven's violations for unpaid USF
       contributions continued with each subsequent day on which it failed to
       make full payment. Based on the record, we find that Telseven has
       apparently violated Section 254(d) of the Act and Section 54.706 of
       the Commission's rules by willfully or repeatedly failing to
       contribute fully and timely to the USF from December 2007 to April
       2012, inclusive.

    B. Telseven Apparently Failed to Provide Good Faith Estimates of Its
       Quarterly Telecommunications Revenue

   16. Our rules require carriers to file good faith estimates of their
       quarterly telecommunications revenue on Form 499-Q. A carrier's
       failure to provide such estimates has serious implications for the USF
       program because USAC uses the revenue reported on Form 499-Q to
       calculate each carrier's monthly USF contribution obligation, if any,
       subject to an annual true-up based on the actual revenues, as reported
       on the entity's Form 499-A.

   17. The Forms 499-Q that Telseven filed in April 2009 and July 2009
       apparently failed to provide good faith estimates of Telseven's
       projected telecommunications revenue for the third and fourth quarters
       of 2009. In those Quarterly Worksheets, Telseven projected revenues
       sufficiently low for USAC to place Telseven in de minimis status for
       2009. Telseven's actual revenue for 2009, as reported on its Form
       499-A filing due April 1, 2010, was more than three times greater than
       Telseven had predicted in its Form 499-Q filings and showed that
       Telseven did not qualify for de minimis status in 2009. USAC
       determined that Telseven's actual revenues meant that it had a
       $13,444.62 contribution obligation to the USF for 2009. We deem the
       difference between Telseven projected revenue, as reported on its
       Forms 499-Q and its actual revenue, as reported on its Forms 499-A, to
       be so significant as to show that the Form 499-Q revenue estimates
       were apparently not made in good faith, as Section 54.711(a) of our
       rules requires. Based on the record, we therefore find that Telseven
       apparently violated Section 54.711(a) by willfully or repeatedly
       filing Forms 499-Q that failed to provide good faith estimates of
       Telseven's quarterly telecommunications revenue.

    C. Telseven Apparently Failed To Make Full and Timely Contributions to
       the NANP Cost Recovery Mechanism

   18. We further find that Telseven has apparently violated Section
       251(e)(2) of the Act and Section 52.17(a) of the Commission's rules by
       willfully or repeatedly failing to make timely contributions toward
       the costs of number administration. As a provider of interstate
       telecommunications service, Telseven was obligated to contribute to
       the NANP administration cost recovery mechanisms on the basis of the
       end-user telecommunications revenues it reported on its Annual
       Worksheet (Form 499-A) during the period covered by this NAL.

   19. The record demonstrates that Telseven failed to timely remit its NANP
       payment for 2011. The due date on the invoice was July 12, 2011, but
       the invoice remains unpaid. We therefore conclude based on the record
       that Telseven has apparently violated Section 251(e)(2) of the Act and
       Section 52.17(a) of the Commission's rules by willfully or repeatedly
       failing to make timely NANP administration contributions for 2011.

    D. Telseven Apparently Failed To Make Full and Timely Contributions to
       the LNP Cost Recovery Mechanism

   20. The record demonstrates that Telseven failed to contribute fully and
       timely to the LNP cost recovery mechanism in 2005, 2010, and 2011. As
       of April 23, 2012, Telseven had not made payment on the LNP invoice
       issued by the LNP administrator on December 31, 2005, which was due on
       February 14, 2006. Telseven made only a partial payment for 2010. It
       has not remitted any payment for 2011. Telseven's outstanding LNP
       contribution debt is $5,027.20. Based on the record developed in our
       investigation, we find that Telseven has apparently violated Section
       251(e)(2) of the Act and Section 52.32(a) of the Commission's rules by
       willfully or repeatedly failing to contribute fully and timely to the
       LNP cost recovery mechanism in 2005, 2010, and 2011.

    E. Telseven Apparently Failed to Pay Its Regulatory Fees

   21. As an interstate telecommunications service provider, Telseven was
       required to pay regulatory fees on the basis of its interstate and
       international end-user revenues reported on its Annual Worksheet.
       According to Commission records, Telseven has not paid its annual
       regulatory fees to the Commission for 2009 and 2010. Telseven is
       delinquent in the amount of $22,736.25. We find that Telseven
       apparently violated Sections 1.1154 and 1.1157(b)(1) of the
       Commission's rules by willfully or repeatedly failing to pay
       regulatory fee program payments when due.

    F. Proposed Forfeitures

   22. 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 against a
       telecommunications carrier 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.

   23. We find that under the American Rule of accounting, in which all
       payments are applied first to the oldest outstanding debt, the last
       Telseven USF invoice that was paid in full was the invoice issued on
       October 22, 2007 that was due on November 15, 2007, and that the last
       Telseven USF invoice that received partial payment was the invoice
       issued on November 22, 2007 that was due on December 14, 2007. Since
       that last partial payment, Telseven has not made any payments on its
       outstanding USF obligations. The Commission has long recognized that
       failure to make 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 approximately one-half of the largest amount of Telseven's
       unpaid USF contributions during the period covered by the Commission's
       investigation. In addition, the Commission has treated failures to pay
       universal service and other obligations as continuing violations. As
       noted above, because Telseven has not made any payments on any USF
       invoices since late 2007, our forfeiture calculation reflects not only
       violations that began within the last twelve months, but also
       violations that began prior to the last twelve months and continued
       during the twelve-month period preceding this NAL.

   24. As a result, we find that Telseven is apparently liable for a
       forfeiture for willful or repeated failure to make any contribution to
       the USF for fifty-three months, from January 2008 to May 2012,
       inclusive. Accordingly, we assess a $20,000 forfeiture for each of the
       fifty-three months in which Telseven failed to remit any contribution
       toward its outstanding USF obligation, for a total of $1,060,000. We
       also assess a $10,000 forfeiture for Telseven's failure to fully pay
       the invoice due on December 14, 2007. Thus, we find Telseven
       apparently liable for a base forfeiture of $1,070,000 for its willful
       or repeated failures to contribute fully and timely to the USF on
       fifty-four months from December 2007 to May 2012, inclusive. Moreover,
       consistent with our approach for assessing liability for USF
       violations, and taking into account all of the factors enumerated in
       Section 503(b)(2)(E) of the Act, we also add an upward adjustment of
       $528,465 to the base forfeiture-approximately one-half of the largest
       amount of Telseven's unpaid USF contributions during the period
       covered by the Commission's investigation. We therefore find Telseven
       apparently liable for a forfeiture of one million, five hundred
       ninety-eight thousand, four hundred sixty-five dollars ($1,598,465)
       for willful or repeated failures to contribute fully and timely to the
       USF.

   25. As we noted above, a carrier's obligation to file Annual and Quarterly
       Worksheets providing good faith estimates of its telecommunications
       revenue is directly linked to, and thus has serious implications for,
       administration of the USF, TRS, NANP, LNP and regulatory fee programs.
       Telseven filed two Quarterly Worksheets that apparently failed to meet
       this standard. The Commission has established precedent for a
       forfeiture of $50,000 for failure to file a Worksheet or for filing an
       inaccurate Quarterly or Annual Worksheet. We find a forfeiture of
       $50,000 also appropriate for filing a Quarterly Worksheet that fails
       to provide a good faith estimate of the filer's projected
       telecommunications revenue. Accordingly, we find that Telseven is
       apparently liable for a forfeiture of one hundred thousand dollars
       ($100,000) for its willful or repeated failure to file Quarterly
       Worksheets providing such good faith estimates by the May 1 and August
       1, 2009 filing deadlines.

   26. We also conclude that Telseven apparently failed to contribute to the
       NANP administration cost recovery mechanism in 2011. The failure to
       make required NANP administration contributions hampers the
       Commission's ability to ensure that the cost of establishing
       telecommunications numbering administration arrangements is "borne by
       all telecommunications carriers on a competitively neutral basis" as
       Congress envisioned. The Commission has generally established a base
       forfeiture amount of $10,000 for each instance in which a contributor
       fails to make required contributions to the NANP administration cost
       recovery mechanism. Consequently, and consistent with precedent, we
       find that Telseven is apparently liable for a forfeiture of ten
       thousand dollars ($10,000) for willful or repeated failure to make
       full and timely payment of its required contribution toward the NANP
       administration cost recovery mechanism for 2011.

   27. We also find that Telseven is apparently liable for a forfeiture for
       willfully or repeatedly failing to make full and timely contributions
       toward LNP cost recovery mechanisms in 2005, 2010, and 2011. The
       Commission has prescribed a $10,000 base forfeiture amount for failure
       to pay LNP contributions. We therefore find Telseven apparently liable
       for a forfeiture of thirty thousand dollars ($30,000) for its willful
       and repeated failure to make full and timely payment of its required
       contribution toward the LNP administration cost recovery mechanism for
       2005, 2010, and 2011.

   28. Finally, we conclude that Telseven has apparently failed to fully pay
       its regulatory fees to the Commission. Telseven's violations for
       failing to fully pay its regulatory fees are continuing until the
       amounts owed are fully paid. The Commission has established a base
       forfeiture amount of $10,000 for failure to make required regulatory
       fee payments. We find Telseven apparently liable for a forfeiture of
       twenty thousand dollars ($20,000) for its willful or repeated failures
       to fully pay its regulatory fees to the Commission for 2009 and 2010.

    G. All Obligations under This NAL Extend to Mr. Patrick Hines

   29. The Commission may "pierce the corporate veil" and hold one entity or
       individual liable for the acts or omissions of a different, related
       entity when: (1) there is a common identity of officers, directors or
       shareholders; (2) there is common control between the entities; and
       (3) it is necessary to preserve the integrity of the Communications
       Act and to prevent the entities from defeating the purpose and
       provisions of statutory provisions. In Capital Telephone Co. v. FCC,
       for example, the United States Court of Appeals for the D.C. Circuit
       upheld the Commission's decision to pierce the corporate veil of an
       applicant for a paging frequency license after concluding that (a) the
       applicant was wholly-owned and controlled by another applicant for a
       paging frequency in the same area at a different location and (b)
       "[i]t would do violence to the statutory command to grant both
       desirable frequencies to a single commonly controlled enterprise
       having only one real owner."

   30. Here, Telseven appears to be the corporate vehicle for the activities
       of just one person, Mr. Patrick B. Hines, a/k/a P. Brian Hines. Mr.
       Hines is the sole officer and director of Telseven, and as such has
       exercised complete control over Telseven. Mr. Hines is also a
       beneficiary, and likely the sole beneficiary, of the Patrick Hines
       Revocable Trust, which owns 100 percent of Telseven. Indeed, Mr. Hines
       has been identified in official Commission filings as holding 100
       percent of Telseven's equity, either directly or indirectly. Further,
       in a proceeding before the California Public Utilities Commission,
       Telseven acknowledged that it is wholly-owned by the Patrick Hines
       Revocable Trust and confirmed that it "is not operated by any other
       entity . . . not controlled by any other entity . . . [and] is not
       managed by any other entity." Thus, it appears that Mr. Hines is the
       sole owner of Telseven. Telseven also identified Mr. Hines as its
       president in its company registration information provided to the
       Commission through the Commission Registration System (CORES). On
       January 5, 2004, Mr. Hines, acting in his capacity as the president of
       Telseven, executed the Company's "Articles of Amendment of
       Organization."

   31. As in Capital Telephone Co, it is necessary here to look beyond the
       Telseven corporate name and take "cognizance of the identity of
       ownership and control" between Telseven and Patrick Hines in order to
       implement core statutory directives and our implementing rules.
       Specifically, Section 254(d) of the Act mandates that "[e]very
       telecommunications carrier that provides interstate telecommunications
       services shall contribute, on an equitable and nondiscriminatory
       basis" to the USF. Similarly, Section 251(e)(2) of the Act requires
       that all telecommunications carriers shall bear telecommunications
       numbering and number portability costs on a competitively neutral
       basis. Finally, Section 503(b)(1) of the Act specifies that "[a]ny
       person who is determined by the Commission . . . to have willfully or
       repeatedly failed to comply with any of the provisions of [the] Act or
       [Commission] rule . . . shall be liable . . . for a forfeiture
       penalty." In these circumstances, we are entitled to look through
       Telseven's corporate structure to prevent Mr. Hines from using a
       corporate entity to circumvent these statutory directives and our
       rules implementing them. Because Mr. Hines apparently solely owns,
       controls, and manages Telseven, we find it consistent with our
       precedent to hold Mr. Hines personally liable for the actions of
       Telseven. Accordingly, for purposes of this NAL, the term Telseven
       includes Patrick Hines personally and all obligations under this NAL
       therefore also extend to Mr. Hines.

   IV. CONCLUSION

   32. In light of the seriousness, duration, and scope of the apparent
       violations, we propose forfeitures totaling one million, seven hundred
       fifty-eight thousand, four hundred sixty-five dollars $1,758,465)
       against Telseven, consisting of one million, five hundred ninety-eight
       thousand, four hundred sixty-five dollars ($1,598,465) for failure to
       make full and timely USF contributions; one hundred thousand dollars
       ($100,000) for failure to file accurate Quarterly Telecommunications
       Reporting Worksheets; ten thousand dollars ($10,000) for failure to
       make full and timely NANP contributions; thirty thousand dollars
       ($30,000) for failure to make full and timely LNP contributions; and
       twenty thousand dollars ($20,000) for failure to make full and timely
       regulatory fee payments to the Commission.

   33. We caution that additional violations of the Act or the Commission's
       rules could subject Telseven and its principal to further enforcement
       action. Such action could take the form of higher monetary
       forfeitures, disqualification of Telseven's principals, including Mr.
       Hines, from providing any interstate common carrier service without
       the prior consent of the Commission, and/or revocation of Telseven's
       and Mr. Hines's authority to operate any business that is subject to
       the Commission's regulatory jurisdiction under the Act.

   V. ORDERING CLAUSES

   34. ACCORDINGLY, IT IS ORDERED that, pursuant to Section 503(b) of the
       Act, and Section 1.80 of the Commission's rules, Telseven, LLC is
       hereby NOTIFIED of its APPARENT LIABILITY FOR A FORFEITURE in the
       amount of one million, seven hundred fifty-eight thousand, four
       hundred sixty-five dollars ($1,758,465) for willfully or repeatedly
       violating the Act and the Commission's rules.

   35. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the
       Commission's rules, within thirty (30) calendar days of the release
       date of this Notice of Apparent Liability for Forfeiture, Telseven
       SHALL PAY the full amount of the proposed forfeitures or SHALL FILE a
       written statement seeking reduction or cancellation of the proposed
       forfeitures.

   36. 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/Account Number and FRN referenced above.
       Payments by check or money order may be mailed to Federal
       Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.
       Payments 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 TREAS/NYC, and account number 27000001. An FCC Form 159
       (Remittance Advice) must be submitted with any payments. 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). Telseven will also send electronic
       notification within forty-eight (48) hours of the date said payment is
       made to Terry.Cavanaugh@fcc.gov and Robert.Krinsky@fcc.gov.

   37. The written statement seeking reduction or cancellation of the
       proposed forfeitures, if any, must include a detailed factual
       statement supported by appropriate documentation and affidavits
       pursuant to Sections 1.80(f)(3) and 1.16 of the Commission's rules.
       The written statement must be mailed to Theresa Z. Cavanaugh, 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/Account number
       referenced above. The written statement should also be e-mailed to
       Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov, Pamela S. Kane at
       Pamela.Kane@fcc.gov, and Robert B. Krinsky at Robert.Krinsky@fcc.gov.

   38. 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.

   39. Requests for payment of the full amount of this Notice of Apparent
       Liability for Forfeiture 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 regarding payment procedures, please
       contact the Financial Operations Group Help Desk at 1-877-480-3201 or
       E-mail: ARINQUIRIES@fcc.gov.

   40. 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 each of the following: Telseven, LLC, 200 Executive Way,
       Ponte Vedra Beach, Florida 32082; Doreen Abbott, P.O. Box 56257,
       Jacksonville, Florida 32241-6257; Jacob A. Brown, Esq., Akerman
       Senterfitt, LLP, 50 N. Laura Street, Suite 3100, Jacksonville, Florida
       32202; Jason B. Burnett, Esq., GrayRobinson, P.A., 50 N. Laura Street,
       Suite 1100, Jacksonville, Florida 32202; and Patrick B. Hines, 350
       Ponte Vedra Boulevard, Ponte Vedra Beach, Florida 32082-1812.

   FEDERAL COMMUNICATIONS COMMISSION

   Marlene H. Dortch

   Secretary

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

   47 C.F.R. S: 54.711(a). Form 499-Q is also known as the Quarterly
   Telecommunications Reporting Worksheet or Quarterly Worksheet.

   47 U.S.C. S: 251(e)(2); 47 C.F.R. S: 52.17.

   47 U.S.C. S: 251(e)(2); 47 C.F.R. S: 52.32(a).

   47 C.F.R. S:S: 1.1154, 1.1157(b)(1).

   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.").

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

   See id. S:S: 54.709(a), 54.713(b). The monthly bills are subject to an
   annual true-up based on the actual revenues that contributors report on
   FCC Form 499-A. 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, 5755, para. 19 & n.32 (2001) (Quarterly
   Reporting Order); 47 C.F.R. S: 54.709(a). Form 499-A is also known as the
   Annual Telecommunications Reporting Worksheet or Annual Worksheet.

   See Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110
   Stat. 1321, 1358.

   See USAC, Understanding Invoices, available at
   http://www.universalservice.org/cont/invoices/ (last visited Apr. 28,
   2012). Debt collection procedures may include further administrative
   efforts by both the Commission and the United States Treasury or, as
   appropriate, Commission referral of 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, including 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, 54.713 and 31 C.F.R. S: 285.12(j).

   47 U.S.C. S: 251(e)(1).

   Id. S: 251(e)(2).

   47 C.F.R. S: 52.17.

   47 U.S.C. S: 251(b)(2).

   Id. S: 251(e)(2).

   47 C.F.R. S: 52.32.

   Section 9(a)(1) of the Act directs the Commission to "assess and collect
   regulatory fees to recover the costs of the following regulatory
   activities of the Commission: enforcement activities, policy and
   rulemaking activities, user information services, and international
   activities." 47 U.S.C. S: 159(a)(1); see also 47 C.F.R. S: 1.1151.

   47 C.F.R. S:S: 1.1154, 1.1157(b)(1).

   Id. S: 1.1157(b)(1). Section 1.1154 of the Commission's rules sets forth
   the schedule of annual regulatory charges and filing locations for common
   carrier services. See 47 C.F.R. S: 1.1154.

   See 47 U.S.C. S: 159(c)(1), (c)(3).

   47 C.F.R. S: 1.1910. The "red light rule" took effect on November 1, 2004.
   See FCC Announces Brief Delay in Enforcement of Red Light Rule, Public
   Notice, 19 FCC Rcd 19452 (2004).

   See 47 C.F.R. S: 54.711(a); see also, e.g.,  FCC Form 499-A
   Telecommunications Reporting Worksheet  - Annual Filing, available at
   http://transition.fcc.gov/Forms/Form499-A/499a-2012.pdf (last visited May
   15, 2012).

   See 47 C.F.R. S: 54.711(a); Quarterly Reporting Order, 16 FCC Rcd at 5755,
   para. 19; see also FCC Form 499-Q Telecommunications Reporting Worksheet 
   - Quarterly Filing for Universal Service Contributors, available at
   http://www.fcc.gov/Forms/Form499-Q/499q-2012.pdf (last visited May 15,
   2012).

   See 47 C.F.R. S:S: 1.1154 (regulatory fees), 52.17 (numbering), 52.32
   (LNP), 54.709 (USF).

   See, e.g., 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 Fourth Quarter 2011 Contribution Factor, Public Notice, 26 FCC
   Rcd 12943, 12946 (Off. Managing Dir. 2011) ("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 . . . monthly invoice provided by the Administrator, the
   payment is delinquent"). The Act and our rules, however, do not condition
   payment on receipt of an invoice or other notice from USAC, other program
   administrator, or the Commission. See, e.g., 47 U.S.C. S: 254(d); 47
   C.F.R. S: 54.706(b). For instance, a carrier that does not file Form 499-A
   or Form 499-Q 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 for Forfeiture
   and Order, 18 FCC Rcd 19893, 19896, para. 5 n.22 (2003) (Globcom NAL)
   (subsequent history omitted). In the case of USF contributions, providers
   whose contribution obligation in a given year is less than $10,000 are
   considered de minimis and exempted from contributing to the USF for that
   year. See 47 C.F.R. S: 54.708. Filers do not calculate the amounts that
   they must contribute in the Quarterly and Annual Worksheets. Rather, the
   USF, TRS, NANP, and LNP administrators use the revenue information on
   these Worksheets to calculate a funding base and individual contributions
   for each support mechanism. See, e.g., 2012 Telecommunications Worksheet
   Instructions (FCC Form 499-A) at 31, available at 
   http://www.fcc.gov/document/2012-form-499-instructions (last visited May
   9, 2012).

   47 C.F.R. S: 54.713.

   See Telseven, LLC "Registration Detail," available at
   https://fjallfoss.fcc.gov/coresWeb/searchDetail.do?frn= 0009834466 (last
   visited May 15, 2012). Telseven also obtained authorization, pursuant to
   Section 214 of the Communications Act and Section 63.18 of the
   Commission's rules, to provide international telecommunications services.
   See International Authorizations Granted, Public Notice, 19 FCC Rcd 4036
   (Int'l Bur. 2004).

   Telseven, LLC, d/b/a Calling 101 10 275, Calling 10 1515 800, Calling 10
   10 141, Application for Authority to Provide Service in Accordance with
   Section 63.18(e)(2) of the Rules, Attach. 1 at Response to Question 9
   (filed Feb. 6, 2004) ("Telseven . . . is a competitive provider of
   interstate telecommunications services."), available at
   http://licensing.fcc.gov/cgibin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_
   numberC/File+Number/%3D/ITC2142004020900047&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/File+Number
   (last visited May 14, 2012); FCC Form 499 Filer Database Detailed
   Information, Filer Identification for Telseven, available at
   http://apps.fcc.gov/cgb/form499/499detail.cfm?FilerNum=823700 (last
   visited May 11, 2012) (based on Telseven's Form 499 filings, listing all
   states except Alaska and Nevada as jurisdictions in which Telseven
   provides telecommunications services); see Letter from Wendy M. Creeden,
   Counsel for Telseven, LLC, Sullivan & Worcester, LLP, to Elizabeth Mumaw,
   Attorney Advisor, Investigations & Hearings Division, FCC Enforcement
   Bureau, at Responses to Questions 1-2 (Sept. 22, 2008) (on file in
   EB-08-IH-1386) (Telseven Sept. 22 Letter).

   Telseven Sept. 22 Letter at Response to Question 2.

   See Telseven, LLC, Calling 10, LLC d/b/a California Calling 10, and
   Patrick Hines, Response to the Order Instituting Investigation and Denial
   of All Assertions of Possible Violation of California Law of Telseven,
   LLC, Calling 10, LLC d/b/a California Calling 10, and Patrick Hines, an
   Individual, Case No. I.10-12-010, at 9-10 (Cal. Pub. Util. Comm'n, filed
   Jan. 21, 2011) (Telseven Response to Cal. Pub. Util. Comm'n Investigation
   Order).

   See Cal. Pub. Util. Comm'n, Order Instituting Investigation into the
   Operations of Telseven, LLC, Calling 10, LLC, and Patrick Hines, Case No.
   I.10-12-010, at 7 (issued Dec. 21, 2010) (Cal. Pub. Util. Comm'n
   Investigation Order); Post-Hearing Brief of Consumer Protection & Safety
   Div., Cal. Pub. Util. Comm'n, Case No. I.10-12-010, at 29 (filed Apr. 6,
   2012) (Cal. Pub. Util. Comm'n Post-Hearing Brief); Cal. Pub. Util. Comm'n,
   Telseven Hearing, Testimony of Patrick B. Hines, Case No. I.10-12-010, at
   389 (Nov. 17, 2011).

   See Cal. Pub. Util. Comm'n Post-Hearing Brief at 32.

   See Telseven Response to Cal. Pub. Util. Comm'n Investigation Order at 10.

   See Cal. Pub. Util. Comm'n, Opening Brief of Calling 10, LLC d/b/a
   California Calling 10. Telseven, LLC and Patrick Hines, Case No.
   I.10-12-010, at 41 (Cal. Pub. Util. Comm'n, filed Apr. 6, 2011).

   See "Telseven.com - Welcome to Telseven LLC," available at
   http://telseven.com (Jan. 23, 2012) (on file in EB-08-IH-1386).

   See "Telseven.com - Rates," available at http://telseven.com/rate.html
   (Jan. 23, 2012) (on file in EB-08-IH-1386).

   Letter from Trent B. Harkrader, Deputy Chief, Investigations & Hearings
   Division, FCC Enforcement Bureau, to Patrick Hines, Chief Executive
   Officer, Telseven  (Jul. 2, 2008) (on file in EB-08-IH-1386).

   Telseven Sept. 22 Letter.

   Letter from Wendy M. Creeden, Counsel for Telseven, to Robert B. Krinsky,
   Attorney Advisor, Investigations & Hearings Division, FCC Enforcement
   Bureau (Dec. 18, 2009) (on file in EB-08-IH-1386); Letter from Kathy L.
   Cooper, Counsel for Telseven, to Michele Berlove, Deputy Div. Chief,
   Investigations & Hearings Division, FCC Enforcement Bureau (Jun. 15, 2010)
   (on file in EB-08-IH-1386); Letter from Kathy L. Cooper, Counsel for
   Telseven, to Robert B. Krinsky, Attorney Advisor, Investigations &
   Hearings Division, FCC Enforcement Bureau (Jul. 12, 2010) (on file in
   EB-08-IH-1386).

   See Telseven Sept. 22 Letter at Response to Questions 9, 11-14; see also,
   e.g.,  E-mail from Fred Theobald, USAC, to Robert Krinsky, Attorney
   Advisor, Investigations and Hearings Division, FCC Enforcement Bureau
   (Jan. 31, 2012, 13:28 EDT) (attaching USAC billing history for Telseven);
   E-mail from Fred Theobald, USAC, to Robert Krinsky, Attorney Advisor,
   Investigations and Hearings Division, FCC Enforcement Bureau (Feb. 14,
   2012, 9:20 EDT); E-mail from Fred Theobald, USAC, to Robert Krinsky,
   Attorney Advisor, Investigations and Hearings Division, FCC Enforcement
   Bureau (Apr. 12, 2012, 11:41 EDT); E-mail from Fred Theobald, USAC, to
   Robert Krinsky, Attorney Advisor, Investigations and Hearings Division,
   FCC Enforcement Bureau (Apr. 13, 2012, 14:04 EDT) (Fourth Theobald
   E-mail); E-mail from Fred Theobald, USAC, to Robert Krinsky, Attorney
   Advisor, Investigations and Hearings Division, FCC Enforcement Bureau (May
   1, 2012, 9:04 EDT) (Fifth Theobald E-mail); E-mail from Fred Theobald,
   USAC, to Robert Krinsky, Attorney Advisor, Investigations and Hearings
   Division, FCC Enforcement Bureau (May 2, 2012, 13:17 EDT) (Sixth Theobald
   E-mail); E-mail from Heather Bambrough, Welch, LLP, to Robert Krinsky,
   Attorney Advisor, Investigations and Hearings Division, FCC Enforcement
   Bureau (Jan. 24, 2012, 12:16 EDT) (regarding Telseven's NANP payment
   deficiency); E-mail from Heather Bambrough, Welch, LLP, to Robert Krinsky,
   Attorney Advisor, Investigations and Hearings Division, FCC Enforcement
   Bureau (Jan. 24, 2012, 13:49 EDT) (Second Bambrough E-mail); E-mail from
   Karen Laffey, Neustar, Inc., to Robert Krinsky, Attorney Advisor,
   Investigations and Hearings Division, FCC Enforcement Bureau (Jan. 27,
   2012, 16:54 EDT) (E-mail from Karen Laffey, Neustar, Inc., to Robert
   Krinsky, Attorney Advisor, Investigations and Hearings Division, FCC
   Enforcement Bureau (Apr. 23, 2012, 12:00 EDT) (Second Laffey E-mail)
   (attaching spreadsheet listing delinquent invoice amounts); E-mail from
   Ann Monahan, Financial Management Specialist, FCC Office of the Managing
   Director (Feb. 3, 2012, 9:29 EDT) (First Monahan E-mail); E-mail from Ann
   Monahan, Financial Management Specialist, FCC Office of the Managing
   Director (Feb. 6, 2012, 16:09 EDT).

   Notification from Jason B. Burnett and Paige A. Wagner, GrayRobinson,
   P.A., Counsel for Telseven, Notice of Filing Chapter 7 Bankruptcy, U.S.
   Bankr. Ct., Mid. Dist. Fla., Jacksonville Div., Case No.: 3:11-bk-2682-PMG
   (Apr. 23, 2012) (on file in EB-08-IH-1386) (stating that on April 20, 2012
   Telseven had filed for Chapter 7 bankruptcy).

   Id.

   See Telseven, LLC Homepage, available at http://telseven.com/ (last
   visited Apr. 26, 2012) ("Telseven has filed a Chapter 7 Bankruptcy
   proceeding in Jacksonville, Florida, Case No. 3:12-bk-02683. The company
   is no longer providing services.").

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

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

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

   See, e.g., Southern California Broadcasting Co., Memorandum Opinion and
   Order, 6 FCC Rcd 4387, 4388, para. 5 (1991) (Southern California
   Broadcasting).

   See, e.g., Callais Cablevision, Inc.,  Notice of Apparent Liability for
   Monetary Forfeiture, 16 FCC Rcd 1359, 1362, para. 10 (2001) (Callais
   Cablevision) (issuing an NAL for, inter alia, a cable television
   operator's repeated violation of the cable signal leakage rules).

   Southern California Broadcasting,  6 FCC Rcd at 4388, para. 5; Callais
   Cablevision,  16 FCC Rcd at 1362, para. 9.

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

   See, e.g., SBC Communications, Inc.,  Forfeiture Order, 17 FCC Rcd 7589,
   7591, para. 4 (2002).

   47 U.S.C. S:S: 251(e)(2), 254(d); 47 C.F.R. S:S: 1.1154, 1.1157(b)(1),
   52.17(a), 52.32(a), 54.706, 54.711(a).

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

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

   Supra paras. 7-8.

   See "Telseven.com - Rates," available at http://telseven.com/rate.html
   (Jan. 23, 2012) (on file in EB-08-IH-1386) ("Note that Telseven charges an
   administrative recovery fee of $1.65 in any month you dial our directory
   assistance service. This fee is intended to offset the cost Telseven
   incurs in complying with regulatory obligations and includes the cost of
   complying with the Federal Universal Service Charge.").

   See Fifth Theobald E-mail (updating on May 1, 2012 Telseven USF data
   prepared on January 26, 2012).

   47 C.F.R. S: 54.713(e); see also Comprehensive Review of the Universal
   Service Fund Management, Administration, and Oversight, Report and Order,
   22 FCC Rcd 16372, 16380-81, para. 16 (2007).

   See USAC, "Telseven Invoice History," attached to Fourth Theobald E-mail;
   Fifth Theobald E-mail; USAC Invoices to Telseven, Invoice Nos.
   UBDI0000274287 (statement date Oct. 22, 2007), UBDI0000279222 (statement
   date Nov. 22, 2007).

   See Telseven's Form 499-Q for Projected Third Quarter Revenues 2009
   (received by USAC Apr. 24, 2009); Telseven's Form 499-Q for Projected
   Fourth Quarter Revenues 2009) (received by USAC Jul. 23, 2009); see also
   Fourth Theobald E-mail. Section 54.708 of the Commission's rules provides,
   in pertinent part, that if "a contributor's contribution to universal
   service in any given year is less than $10,000 that contributor will not
   be required to submit a contribution . . . ." 47 C.F.R. S: 54.708.

   See Telseven 2009 Form 499-A Telecommunications Reporting Worksheet
   (reporting actual revenues for calendar year 2009) (received by USAC on
   Mar. 29, 2010) (Telseven 2009 Form 499-A);  Fourth Theobald E-mail.

   See Telseven 2010 Form 499-A (reporting 2009 revenue); USAC Invoices to
   Telseven, Invoice Nos. UBDI0000432028 (statement date Jul. 22, 2010),
   UBDI0000438013 (statement date Aug. 20, 2010), UBDI0000444156 (statement
   date Sept. 22, 2010); see also Fourth Theobald E-mail.

   USAC Invoice to Telseven, Invoice No. UBDI0000450029 (statement date Oct.
   22, 2010); see also Fourth Theobald E-mail.

   See 47 C.F.R. S: 54.713(b); USAC Invoices to Telseven, Invoice Nos.
   UBDI0000432028 (statement date Jul. 22, 2010), UBDI0000456025 (statement
   date Nov. 22, 2010), UBDI0000462005 (statement date Dec. 22, 2010),
   UBDI0000466986 (statement date Jan. 21, 2011), UBDI0000472973 (statement
   date Feb. 22, 2011); see also Fourth Theobald E-mail.

   See supra para. 2 (discussing DCIA).

   See, e.g., Telrite Corp., Notice of Apparent Liability for Forfeiture, 23
   FCC Rcd 7231, 7239 n.53 (2008) (Telrite NAL); Globcom, Inc. d/b/a Globcom
   Global Communications, Order of Forfeiture, 21 FCC Rcd 4710, 4712, para. 5
   (2006) (Globcom Forfeiture Order); BCE Nexxia Corp., Notice of Apparent
   Liability, 20 FCC Rcd 15121, 15124, 15126, paras. 10, 15 (2005).

   See, e.g., Kajeet Inc. and Kajeet/Airlink, LLC, Notice of Apparent
   Liability for Forfeiture and Order, 26 FCC Rcd 16684, 16690, para. 13
   (2011) (Kajeet NAL);  Telrite NAL,  23 FCC Rcd at 7239, para. 16; Globcom
   Forfeiture Order, 21 FCC Rcd at 4723, para. 35 n.105 (2006); Matrix
   Telecom, Inc., Notice of Apparent Liability for Forfeiture, 15 FCC Rcd
   13544, 13546, para. 7 (2000);  Conquest Operator Services Corp.,  Order of
   Forfeiture, 14 FCC Rcd 12518, 12525, para. 16 (1999); see also Compass
   Global, Inc., Notice of Apparent Liability for Forfeiture, 23 FCC Rcd
   6125, 6140, para. 33 (Compass Global NAL); Global Crossing North America,
   Inc., Notice of Apparent Liability for Forfeiture, 23 FCC Rcd 6110, 6121,
   para. 24 (2008) (Global Crossing NAL).

   See 47 C.F.R. S: 54.711(a); Quarterly Reporting Order, 16 FCC Rcd at 5755,
   para. 19.

   See supra note 63 and accompanying text.

   See 47 C.F.R. S: 54.708 (stating that "[i]f a contributor's contribution
   to universal service in any given year is less than $10,000 that
   contributor will not be required to submit a [USF] contribution . . . for
   that year").

   See Fourth Theobald E-mail; USAC Invoices to Telseven, Invoice Nos.
   UBDI0000432028 (statement date Jul. 22, 2010), UBDI0000438013 (statement
   date Aug. 20, 2010), UBDI0000444156 (statement date Sept. 22, 2010);
   Telseven's Form 499-A for calendar year 2009 (received by USAC Mar. 29,
   2010); USAC Invoices to Telseven, Invoice Nos. UBDI0000432028 (statement
   date Jul. 22, 2010), UBDI0000438013 (statement date Aug. 20, 2010),
   UBDI0000444156 (statement date Sept. 22, 2010).

   47 C.F.R. S: 52.17(b). In particular, contributions to support numbering
   administration are based upon a provider's end-user telecommunications
   revenues for the prior calendar year and a contribution factor determined
   annually by the Chief of the Wireline Competition Bureau, but in no event
   will be less than $25. Id. S: 52.17(a). NANP administration contributions
   are due on an annual basis, with certain exceptions not relevant here.

   See Second Bambrough E-mail.

   47 U.S.C. S: 251(e)(2); 47 C.F.R. S: 52.17(a).

   See Second Laffey E-mail.

   See Account Summary-Telseven, LLC, attached to Second Laffey E-mail.

   Id.

   Id.

   Id.

   See 47 U.S.C. S: 251(e)(2); 47 C.F.R. S: 52.32(a).

   See 47 C.F.R. S:S: 1.1154, 1.1157(b)(1).

   See First Monahan E-mail.

   Id.

   See 47 C.F.R. S:S: 1.1154, 1.1157. Standard regulatory fees applicable to
   common carrier services must be paid in full by the due date. 47 C.F.R. S:
   1.1157(b)(1).

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

   See 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, 23 FCC Rcd 9845 (2008).

   47 U.S.C. S: 503(b)(2)(E).

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

   Id. S: 54.713(e).

   See USAC, "Telseven Invoice History," attached to Fourth Theobald E-mail;
   Fourth Theobald E-mail; Fifth Theobald E-mail; Sixth Theobald E-mail; USAC
   Invoices to Telseven, Invoice Nos. UBDI0000274287 (statement date Oct. 22,
   2007), UBDI0000279222 (statement date Nov. 22, 2007).

   See, e.g., Kajeet NAL, 26 FCC Rcd at 16694, para. 21; ADMA Telecom, Inc.,
   Forfeiture Order, 26 FCC Rcd 4152, 4157, para. 15 (2011)(ADMA Forfeiture
   Order); Telrite NAL, 23 FCC Rcd at 7241-42, para. 24.

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

   See, e.g., Kajeet NAL, 26 FCC Rcd at 16694, para. 21;  ADMA Forfeiture
   Order,  26 FCC Rcd at 4158, para. 15; Globalcom NAL,  25 FCC Rcd at 13485,
   para. 16; NTS Communications, Inc.,  Notice of Apparent Liability for
   Forfeiture, 25 FCC Rcd 5137, 5142, paras. 12-13 (2010); Telrite NAL,  23
   FCC Rcd at 7242-44, paras. 25-28; Compass Global, NAL, 23 FCC Rcd at
   6138-40, paras. 31-34; Global Crossing NAL, 23 FCC Rcd at 6120, para. 21;
   OCMC, Inc., Order of Forfeiture, 21 FCC Rcd 10479, 10482, para. 10 (2006);
   Globcom Forfeiture Order,  21 FCC Rcd at 4721-24, paras. 31-38.

   See, e.g.,  Kajeet NAL, 26 FCC Rcd at 16696, para. 26;  ADMA Telecom,
   Inc., Notice of Apparent Liability for Forfeiture, 24 FCC Rcd 838, 852-53,
   para. 34 (2009)(ADMA NAL); Telrite NAL, 23 FCC Rcd at 7243, para. 28.

   See, e.g.,  Kajeet NAL, 26 FCC Rcd at 16694, para. 21; ADMA Forfeiture
   Order,  26 FCC Rcd at 4159 n.56; Telrite NAL, 23 FCC Rcd at 7245-46, para.
   36; Compass Global NAL, 23 FCC Rcd at 6140-42, paras. 34-38; Global
   Crossing NAL, 23 FCC Rcd at 6120-23, paras. 21-27.

   See USAC Invoice to Telseven, Invoice No. UBDI0000274287 (statement dated
   Oct. 22, 2007); see also Fourth Theobald E-mail.

   The American Rule of accounting was applied to determine the largest
   unpaid invoice. See USAC, "Telseven Invoice History," attached to  Fourth
   Theobald E-mail; USAC Invoice Telseven, Invoice No. UBDI0000283967
   (statement dated Dec. 21, 2007).

   See, e.g., ADMA NAL, 24 FCC Rcd at 851-52, para. 31; Telrite NAL, 23 FCC
   Rcd at 7244, para. 31.

   47 U.S.C. S: 251(e)(2).

   See, e.g., ADMA NAL, 24 FCC Rcd at 853, para. 36; Telrite NAL, 23 FCC Rcd
   at 7245, para. 33; Teletronics, Inc., Notice of Apparent Liability of
   Forfeiture and Order, 20 FCC Rcd 13291, 13303, para. 35 (2005).

   See, e.g., Omniat International Telecom, Notice of Apparent Liability for
   Forfeiture and Order, 24 FCC Rcd 4265, para. 28 (2009); ADMA NAL, 24 FCC
   Rcd at 852, para. 37.

   See, e.g.,  Kajeet NAL, 26 FCC Rcd at 16695, para. 24; Telrite NAL, 23 FCC
   Rcd at 7245, para. 34.

   See, e.g., Telrite NAL, 23 FCC Rcd at 7245, para. 35.

   See id.

   See APPC Service, Inc., Data Net Systems, LLC, Davel Communications, Inc.,
   Jaroth, Inc. D/B/A Pacific Telemanagement Services, and Intera
   Communications Corp., (Complainants) v. NetworkIP, LLC, and Network
   Enhanced Telecom, LLP, (Defendants), Memorandum Opinion and Order, 22 FCC
   Rcd 4286, 4307, para. 47 (2007) (citations omitted).

   Capital Telephone Co. v. FCC, 498 F.2d 734 at 737 (D.C. Cir. 1974)
   (Capital Telephone); see Mansfield Journal Co. (FM) v. FCC, 180 F.2d 28,
   37 (D.C. Cir. 1950) (piercing corporate veil where one family owned all of
   the stock in both entities and the owners took active part in the control
   and formulations of both entities).

   See Cal. Pub. Util. Comm'n, Hearing Transcript-Testimony of Patrick B.
   Hines, Case No. I.10-21-010 at 226-27, (Nov. 16, 2011) (When asked by the
   administrative law judge to state his name for the record, Mr. Hines
   responded "Patrick Hines, Patrick Brian Hines, H-i-n-e-s"); see also Cal.
   Pub. Util. Comm'n, Consumer Protection & Safety Div., Response of Consumer
   Protection & Safety Division to Respondent Patrick Hines' Motion to Stay
   or Dismiss for Lack of Jurisdiction at 11 (May 4, 2012) (noting that
   Patrick B. Hines and P. Brian Hines are the same person, and that Mr.
   Hines is using the "P. Brian Hines" presentation of his name for purposes
   of the Bankruptcy Court litigation).

   See Telseven Sept. 22 Letter at Response to Question 3.

   See Calif. Pub. Utilities Comm'n, Case. No. I.10-12-010, Evidentiary
   Hearing Transcript at 302; Statement of Financial Affairs, In re:
   Telseven, LLC, U.S. Bankr. Ct., Mid. Dist. Fla., Jacksonville Div., Case
   No. 3:12-bk-02682-PMG, Item 20 "Current Partners, Officers, Directors, and
   Shareholders" (filed May 4, 2012); see also Corporate Ownership Statement
   (Rule 7008.1),  In re: Telseven, LLC, U.S. Bankr. Ct., Middle Dist. Fla.
   (Jacksonville Div.), Case No. 3:12-bk-02682-PMG at Item 20 "Current
   Partners, Officers, Directors, and Shareholders" (filed May 4, 2012).

   See International Section 214 Application of Telseven, LLC, FCC File
   Number ITC2142004020900047, Attachment 2, granted Dec. 1, 2005, DA
   05-3129, Report No. TEL-00970.

   See Telseven, LLC and California Calling 10, LLC, Response to Inquiry 19
   of the Feb. 19, 2009 Data Request from Calif. Pub. Util. Comm'n, (Mar. 20,
   2009), incorporated as part of documents assembled in re: Calf. Pub. Util.
   Comm'n, Order Instituting Investigation on the Commission's own motion
   into the operations, practices, and conduct of Telseven, LLC, Calling 10,
   LLC dba California Calling 10, (U-7015-C), and Patrick Hines, an
   individual, to determine whether Telseven, Calling 10, and Patrick Hines
   have violated the laws, rules and regulations of this State in the
   provision of directory assistance services to California consumers, Case
   No. I.10-12-010, Document No. PUC0226 at para. 3 (filed Dec. 16, 2010).

   See FCC Registration system -Telseven Profile, available at
   https://fjallfoss.fcc.gov/coresWeb/serch Detail.do?frn=0009834466 (last
   visited May 15, 2012).

   See Telseven Sept. 22 Letter at Response to Question 1, Exhibit A:
   "Telseven Articles of Organization."

   Capital Telephone, 498 F.2d at 738.

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

   Id. S: 251(e)(2); see also id. S: 159(a) (requiring that the Commission
   collect regulatory fees to recover the costs of its regulatory
   activities).

   47 U.S.C. S: 503(b)(1).

   Telseven continues to have unpaid outstanding balances due to USAC, the
   LNP and NANP Administrators, and the Commission. We note that payment of
   the forfeitures proposed in this NAL will not absolve Telseven of its
   obligations to pay its delinquent balances. As discussed above in
   paragraph 2, debt collection procedures may include further administrative
   efforts both by the Commission and by the United States Treasury or, as
   appropriate, referral of the delinquent debt to the Department of Justice
   for enforced collection action. 47 C.F.R. S: 1.1917.

   47 U.S.C. S: 503(b).

   47 C.F.R. S: 1.80.

   See 47 C.F.R.  S:S: 1.80(f)(3), 1.16.

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

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   Federal Communications Commission FCC 12-62

   Federal Communications Commission FCC 12-62