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REDACTED
Federal Communications Commission DA 13-265
                                                                                                                                                                                                                
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Dialing Services, LLC 
)
)
)
)
)
File No.: EB-TCD-12-00001812
CITATION AND ORDER
PRERECORDED MESSAGE VIOLATIONS
Adopted:  March 15, 2013 Released:  March 15, 2013
By the Chief, Telecommunications Consumers Division, Enforcement Bureau:
I. INTRODUCTION
1. This is an official CITATION AND ORDER (Citation), issued by the Federal 
Communications Commission (Commission or FCC) pursuant to Section 503(b)(5) of the Communications 
Act of 1934, as amended (Communications Act or Act), 47 U.S.C. § 503(b)(5), for violations of the Act and 
the Commission’s rules that govern telephone solicitations, prerecorded, and autodialed telephone calls.
1
  
Specifically, Dialing Services, LLC (“Dialing Services” or “Company”) is being cited for violations of the 
provisions of the Act and Commission’s rules that (1) prohibit making any calls to cell phones using 
autodialers or artificial or prerecorded messages absent an emergency purpose or prior express consent
2
and 
(2) for calls that are otherwise permissible, require certain identification information to be present in 
prerecorded messages.
3
2. Notice of Duty to Comply With Law: Dialing Services is hereby on notice that if it 
subsequently engages in any conduct of the type described in this Citation, including any violation of Section 
227 of the Act or Sections 64.1200 or 64.1601(e) of the Commission’s rules, it may be subject to further legal 
action, including monetary fines (forfeitures).
4
  Such forfeitures may be based on both the conduct that led to 
this Citation and the conduct following it.
5
                                                
1
See 47 U.S.C. § 227; 47 C.F.R. §§ 64.1200, 64.1601(e).  Section 227 was added to the Communications Act by the 
Telephone Consumer Protection Act of 1991, Pub. L. No. 102-243, 105 Stat. 2394 (codified at 47 U.S.C. § 227), and is 
most commonly known as the TCPA.  The TCPA and the Commission’s rules restrict a variety of practices that are 
associated with telephone solicitation and the use of the telephone network to deliver unsolicited advertisements or 
prerecorded and autodialed telephone calls.
2
See 47 U.S.C. § 227(b)(1)(A)(iii); 47 C.F.R. § 64.1200(a)(1)(iii). 
3
See 47 U.S.C. § 227(d)(3)(A); 47 C.F.R. § 64.1200(b).
4
This Citation is being issued to the company named above and includes all other entity names through which it does 
business, as well as its owners, principals, and officers.  Accordingly, all references in this Citation to Dialing Services, 
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Federal Communications Commission DA 13-265
                                                                                                    
2
3. Response Required:  Pursuant to Sections 4(i), (j), and 403 of the Communications Act,
6
we 
also direct the Company to confirm within fifteen (15) calendar days after the release date of this Citation 
that it has (1) ceased making calls to cell phones using autodialers or artificial or prerecorded messages and 
(2) ceased making any prerecorded message calls (to cell phones or otherwise) without the identification 
information required in the Act and Commission’s rules.
II. BACKGROUND
4. The Company offers a service—commonly referred to as “robocalling”—whereby clients 
use the Company to make artificial or prerecorded voice calls to telephone numbers of the clients’ choosing.
7
  
The Company markets its services under various brand names on the Internet.  Clients may use the 
Company’s website to upload sound recordings (i.e., prerecorded messages) to the Company’s servers.
8
  
Alternatively, clients may create prerecorded messages by dialing one of the Company’s phone numbers and 
recording a message over the phone.
9
  For a fee, the Company will then make calls using the prerecorded 
messages to a list of telephone numbers that its clients provide the Company, via the Company’s autodialing 
equipment.
10
  The Company notes that it is able to make millions of autodialed calls for its clients.
11
  The 
Company’s clients include commercial entities (such as multi-level marketers, carpet cleaners and mortgage 
brokers, among others), non-profit organizations (such as churches, schools, and political action committees), 
and political campaigns supporting candidates for public office.
12
                                                                                                                                                                
Company, or you also include all names through which the company does business, and its owners, principals, and 
officers. 
5
See 47 U.S.C § 503(b)(5).  See also S. Rep. No. 95-580, 95th Cong., 1st Sess. at 9 (1977) (if a person or entity that has 
been issued a citation by the Commission thereafter engages in the conduct for which the citation of violation was sent, 
the subsequent notice of apparent liability “would attach not only for the conduct occurring subsequently but also for 
the conduct for which the citation was originally sent.” (emphasis added)).
6
47 U.S.C. §§ 154(i), (j), 403.
7
See Dialing Services Order Form, http://www.politicaller.com/ORDER%20FORM.pdf (last visited Feb. 13, 2013) 
(“Dialing Services, LLC will dial the phone numbers provided by Customer and play the recorded message provided by 
Customer to live answered calls and/or answer machines as indicated by Customer on this order form”).
8
See Dialing Services Website, Uploading Message, https://www.dialingservices.com/MessagesUpload.aspx (last 
visited Feb. 13, 2013); see also Letter from Mitchell Roth, Roth Doner Jackson, PLC, to Richard Hindman, Chief, 
Telecommunications Consumers Division, FCC Enforcement Bureau (Jun. 13, 2012) at 5–8 (on file in 
EB-TCD-12-00001812) (Dialing Services June 13 Response).
9
See Dialing Services Website, Upload Message, https://www.dialingservices.com/MessagesRecord.aspx (last visited 
Feb. 13, 2013); see also Dialing Services June 13 Response at 7.
10
See generally Premier Calling Website, Premiere Dialing Services LLC, http://www.premiercalling.com (last visited 
Feb. 13, 2013); In Touch Systems Website, Products – In Touch, http://www.gointouch.com/products.html (last visited 
Feb. 13, 2013); GOTV Calls Website, Pricing, http://gotvcalls.com/pricing.aspx (last visited Feb. 13, 2013).
11
See In Touch Systems Website, Products – In Touch, http://www.gointouch.com/products.html (last visited Feb. 13, 
2013) (“Reach thousands, hundreds of thousands or even millions of customers with your personal message”).
12
See id. (“Find prospective customers for any kind of product or service. Whether it's Mortgage Refinance, [Multi-
Level Marketing], Carpet Cleaning or Political ‘Get-Out-The-Vote’, [Company] is your answer”); see also Premier 
Calling Website, Premiere Dialing Services LLC, http://www.premiercalling.com/ (last visited Feb. 13, 2013) 
(“[Company] is the industry leader in providing automated calling, voice broadcasting, and robo calling solutions for all 
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Federal Communications Commission DA 13-265
                                                                                                    
3
5. On May 4, 2012, the Telecommunications Consumers Division (TCD) of the FCC’s 
Enforcement Bureau sent the Company a letter of inquiry (LOI), directing the Company to, among other 
things, provide (1) a list of the telephone numbers that the Company called in November 2011, January 2012 
and April 2012 using prerecorded messages; (2) a list of the dates and times when the Company made the 
calls using the prerecorded messages; and (3) sound files of the delivered prerecorded messages.
13
  On June 
13, 2012, the Company filed a response to the LOI.
14
  The Company’s response included the requested 
information for the months of November 2011, January 2012, and April 2012, as well as spreadsheets 
indicating the dates and times that the Company made calls and the phone numbers that Dialing Services 
called during those months.
15
III. APPLICABLE LAW AND VIOLATIONS
A. Prohibitions Against Prerecorded Voice Messages and Autodialed Calls To Cell Phones
6. Under Section 227(b)(1)(A)(iii) of the Communications Act and Section 64.1200(a)(1)(iii) of 
the Commission’s rules, prerecorded voice messages and autodialed calls (including autodialed live calls, 
prerecorded or artificial voice messages, and autodialed text messages) to cell phones and other mobile 
services, such as paging systems, are generally prohibited.  Specifically, Section 227(b)(1)(A)(iii) of the Act 
states that it is unlawful “for any person . . . to make any call . . . using any automatic telephone dialing 
system or an artificial or prerecorded voice . . . to any telephone number assigned to a paging service, cellular 
telephone service, specialized mobile radio service, or other radio common carrier service, or any service for 
which the called party is charged for the call.”
16
  Section 64.1200(a)(1)(iii) of the Commission’s rules states 
that it is unlawful “to initiate any call . . . using any automatic telephone dialing system or an artificial or 
prerecorded voice . . . to any telephone number assigned to a paging service, cellular telephone service, 
specialized mobile radio service, or other radio common carrier service, or any service for which the called 
party is charged for the call.”
17
  
7. The prohibitions in the Act and the FCC rules are subject to only two exceptions: (1) calls 
made for emergency purposes; and (2) calls made with the prior express consent of the called party.
18
  These 
broad prohibitions cover all prerecorded voice and autodialed calls, including political calls and calls made 
by or on behalf of nonprofit organizations.  Callers contending that they have the prior express consent to 
                                                                                                                                                                
types of business and organizations. [. . .] Thousands of business [sic] and organizations have used voice broadcasting 
services from [Company] to send automated calls and pre-recorded messages. Some include AAA, He[r]balife, Planet 
Hollywood Resort and Casino, The Robert O. Anderson School of Management, marketing research firms, political 
candidates and elected officials, and numerous mortgage brokers”).
13
See Letter from Richard Hindman, Chief, Telecommunications Consumers Division, FCC Enforcement Bureau, to 
Anthony C. Kolker, President, Dialing Services, LLC (May 4, 2012) (on file in EB-TCD-12-00001812).
14
See Dialing Services June 13 Response.  
15
See id.
16
47 U.S.C. § 227(b)(1)(A)(iii).
17
47 C.F.R. § 64.1200(a)(1)(iii).
18
See 47 U.S.C. § 227(b)(1)(A)(iii); 47 C.F.R. § 64.1200(a)(1)(iii). 
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Federal Communications Commission DA 13-265
                                                                                                    
4
make prerecorded voice or autodialed calls to cell phones or other mobile service numbers have the burden 
of proof to show that they obtained such consent.
19
8. In addition, Section 227(d)(3)(A) of the Communications Act and Section 64.1200(b) of the 
Commission’s rules require that all otherwise permissible prerecorded messages must include certain 
information to identify the party responsible for the message.  In particular, all permissible prerecorded 
messages must state clearly at the beginning of the message the identity of the business, individual, or other 
entity that is responsible for the call.
20
  If a business or other corporate entity is responsible for the call, the 
prerecorded voice message must contain that entity’s official business name (the name registered with a state 
corporation commission or other regulatory authority).
21
  In addition, the telephone number
22
of such 
business, individual, or other entity must be provided either during or after the prerecorded voice message.
23
  
B. Dialing Services’ Automatic Telephone Dialing System Made Numerous Prerecorded 
Message Calls to Cell Phones In Violation of Federal Law
9. Prerecorded Voice Messages and Autodialed Calls to Cell Phones.  TCD staff compared lists 
of the thousands of phone numbers to which the Company made autodialed or prerecorded message calls
24
to
an industry-standard, commercially available database of known assigned and ported wireless numbers to 
determine whether the Company made such calls to wireless telephones.
25
  From that analysis, TCD staff 
determined that the Company made more than 4.7 million autodialed or prerecorded message calls to cell 
phones, in violation of Section 227(b)(1)(A)(iii) of the Act and Section 64.1200(a)(1)(iii) of the
Commission’s rules.
26
                                                
19
See, e.g., Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, Declaratory Ruling, 
23 FCC Rcd 559, 565, para. 10 (2008) (concluding that “[s]hould a question arise as to whether express consent was 
provided, the burden will be on [the caller] to show it obtained the necessary prior express consent”).
20
47 U.S.C. § 227(d)(3)(A)(i); 47 C.F.R. § 64.1200(b)(1).
21
47 C.F.R. § 64.1200(b)(1).
22
Any telephone number so provided may not be for (1) the autodialer or prerecorded message player that placed the 
call, (2) a 900 number, or (3) any other number for which charges exceed local or long distance transmission charges. 47 
C.F.R. § 64.1200(b)(2).
23
47 U.S.C. § 227(d)(3)(A)(ii); 47 C.F.R. § 64.1200(b)(2).
24
It appears that Dialing Services makes calls using automatic telephone dialing systems or an artificial or prerecorded 
voice.  See Dialing Services Order Form, http://www.politicaller.com/ORDER%20FORM.pdf (last visited Feb. 13, 
2013) (“Dialing Services, LLC will dial the phone numbers provided by Customer and play the recorded message 
provided by Customer to live answered calls and/or answer machines as indicated by Customer on this order form”); In 
Touch Systems Website, Services, http://gointouch.com/services.html (last visited Feb. 13, 2013) (“Let us make your 
calls for you”).
25
See Interactive Marketing Solutions, Inc. Website, http://www.ims-dm.com/index.shtml (last visited Feb. 13, 2013).  
Interactive Marketing Solutions, Inc. is a member of the Direct Marketing Association and bills itself as “the country’s 
largest single-source supplier” of data identifying telephone numbers that have been assigned or ported to wireless 
devices, “to help businesses comply with state and federal legislation.”  Id.
26
By making calls, Dialing Services necessarily “initiates” calls for the purposes of Section 64.1200(a)(1)(iii) of the 
Commission’s rules.
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Federal Communications Commission DA 13-265
                                                                                                    
5
10. As explained above, it is unlawful to make any call using any automatic telephone dialing 
system or prerecorded voice to a cell phone with only two exceptions:  (1) calls made for emergency 
purposes; or (2) calls made with the express prior consent of the called party.
27
  TCD staff reviewed over 100 
sound files provided by Dialing Services.
28
The majority of the prerecorded message calls made by the 
Company were for the purpose of either seeking a vote for a political candidate or endorsing a political 
candidate for office.  None of the recordings provided by the Company in response to the LOI indicated that 
such calls were made for an emergency purpose.
29
  Therefore, we conclude that the calls made to cell phones 
by Dialing Services were not made for an emergency purpose.  Similarly, the Company did not provide 
evidence of prior express consent for these messages.  Therefore, we conclude that the calls the Company 
made to cell phones were not made with the prior express consent of the recipients.
30
11. Independently, TCD staff randomly chose 10 cell phone numbers that Dialing Services 
called with a prerecorded message in April of 2012 and spoke with the call recipient.  A chart of the 
identified cell phone numbers and the dates and times that Dialing Services made autodialed calls and 
delivered prerecorded messages to the recipients is attached at Attachment A.  Without exception, each and 
every recipient denied giving anyone permission to make autodialed calls or prerecorded messages to their 
respective cell phones at any time.
31
  In fact, several of the callers expressed significant frustration and anger 
at receiving autodialed and/or prerecorded message calls on their cell phones.  One recipient, when asked 
whether he had given permission to receive such calls, remarked that the answer was “[n]ot only ‘no’, but 
HELL no.”
32
  This further shows that Dialing Services did not have the prior express consent of these called 
parties to make an autodialed, prerecorded call to their mobile phones.
12. Failure to Include Identifications.  Based on staff review of the prerecorded messages 
provided by the Company in response to the LOI, TCD determined that 100 of the messages either did not 
identify the caller at the beginning of the message, or failed to include a contact telephone number, as 
required by the Act and the Commission’s rules.
33
13. Finding of Violation.  Based on the record developed in this case, the Enforcement Bureau, 
acting through its delegated authority, finds that Dialing Services, LLC, made one or more calls with 
                                                
27
See Section III.A., above.
28
The number of sound files produced by the Company in response to the LOI was a small percentage of the thousands 
of prerecorded messages that the Company indicated it delivered to the recipients of the autodialed calls that it made.  
The Company stated that its clients generally recorded their own sound files, and that those files may be deleted by 
either the Company or its clients. See Letter from Mitchell Roth, Roth Doner Jackson, PLC, to Richard Hindman, Chief, 
Telecommunications Consumers Division, FCC Enforcement Bureau (Jun. 13, 2012) (on file in EB-TCD-12-00001812) 
at 7.
29
See 47 C.F.R. § 64.1200(f)(4) (“emergency purposes means calls made necessary in any situation affecting the health 
and safety of consumers”).
30
See note 17, above.
31
SeeAffidavit of Kristi Thompson, Deputy Chief, Telecommunications Consumers Division, FCC Enforcement 
Bureau (Oct. 12, 2012) (on file in EB-TCD-12-00001812).
32
See id. at 2 (emphasis in original).
33
47 U.S.C. § 227(d)(3)(A); 47 C.F.R. § 64.1200(b).
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Federal Communications Commission DA 13-265
                                                                                                    
6
prerecorded messages in violation of Section 227 of the Communications Act, and Section 64.1200 of the 
Commission’s related rules.
IV. RESPONDING TO THIS CITATION
14. Dialing Services may respond to this Citation within thirty (30) days from the release date of 
this Citation either through (1) a written statement, (2) a teleconference interview with the Commission’s 
Telecommunications Consumers Division in Washington, DC, or (3) a personal interview at the Commission 
Field Office nearest to its place of business.  Dialing Service's response should specify the actions that the 
company is taking to ensure that it does not violate the Communications Act or the Commission’s rules 
governing TCPA violations, as described herein.  
15. If you would like to arrange a teleconference or personal interview, please contact Lloyd 
Collier at (202) 418-2712.  Such teleconference or interview must take place within thirty (30) days of the 
date of this Citation.  If you would like to submit a written response, including any supporting 
documentation, you must send the response within thirty (30) days of the date of this Citation to the 
address below.
Richard A. Hindman, Chief
Telecommunications Consumers Division
Enforcement Bureau
Federal Communications Commission
445 12th Street, SW, Rm. 4-C224
Washington, DC 20554
Reference EB-TCD-12-00001812 when corresponding with the Commission.
16. Reasonable accommodations for people with disabilities are available upon request.  Include 
a description of the accommodation you will need including as much detail as you can.  Also include a way 
we can contact you if we need more information.  Please allow at least five (5) business days advance notice; 
last minute requests will be accepted, but may be impossible to fill.  Send an e-mail to fcc504@fcc.gov or 
call the Consumer & Governmental Affairs Bureau:
      For sign language interpreters, CART, and other reasonable accommodations: 202-418-0530 
(voice), 202-418-0432 (tty);
      For accessible format materials (braille, large print, electronic files, and audio format): 202-
418-0531 (voice), 202-418-7365 (tty).  
V. FUTURE VIOLATIONS
17. If, after receipt of this Citation, Dialing Services again violates Section 227 of the Act, 
Sections 64.1200, or 64.1601(e) of the Commission’s rules in any manner, or violates Section 1.17 of our 
rules (discussed below) when responding to this Citation, the Commission may impose monetary forfeitures 
not to exceed $16,000 for each such violation.
34
  As discussed above, such forfeitures may be based on both 
                                                
34
47 U.S.C. § 503(b)(2)(D).  Section 503(b)(2)(D) provides for forfeitures of up to $10,000 for each violation in cases, 
as in the instant case, where the violation does not involve a Commission licensee or common carriers, among others.  
See 47 U.S.C. § 503(b)(2)(D).  In accordance with the inflation adjustment requirements contained in the Debt 
Collection Improvement Act of 1996, Pub. L. No. 104-134, Sec. 31001, 110 Stat. 1321, the Commission implemented 
an increase of the maximum statutory forfeiture under section 503(b)(2)(D) to $16,000.  See 47 C.F.R. §1.80(b).  See 
REDACTED
Federal Communications Commission DA 13-265
                                                                                                    
7
the conduct that led to the Citation and the conduct following it.
35
In this case, there were approximately 4.7 
million violations that occurred in the three month period of call records reviewed by TCD staff.  A 
subsequent forfeiture action based on just the first three hundred (300) of those violations, calculated at the 
statutory maximum of $16,000 per violation, would result in a potential forfeiture of four million, eight 
hundred thousand dollars ($4,800,000) against the Company.
18. If the Company chooses to respond to this Citation, be advised that it is a violation of 
Section 1.17 of the Commission’s rules (47 C.F.R. § 1.17) for any person or a staff member of that person to 
make any false or misleading written or oral statement of fact.  Specifically, no person shall:
In any written or oral statement of fact, intentionally provide material factual information 
that is incorrect or intentionally omit material information that is necessary to prevent any 
material factual statement that is made from being incorrect or misleading; and
In any written statement of fact, provide material factual information that is incorrect or 
omit material information that is necessary to prevent any material factual statement that 
is made from being incorrect or misleading without a reasonable basis for believing that 
any such material factual statement is correct and not misleading.
36
19. Further, the knowing and willful making of any false statement, or the concealment of any 
material fact, in reply to this Citation is punishable by fine or imprisonment under 18 U.S.C. § 1001.
20. If Dialing Services violates Section 1.17 of the Commission’s rules or the criminal statute 
referenced above, Dialing Services may be subject to further legal action, including monetary fines pursuant 
to Section 503 of the Communications Act.
21. Under the Privacy Act of 1974, 5 U.S.C. § 552a(e)(3), we are informing you that the 
Commission’s staff will use all relevant material information before it, including information that you 
disclose in your interview or written statement, to determine what, if any, enforcement action is required to 
ensure your compliance with the Communications Act and the Commission’s rules.
VI. REQUEST FOR INFORMATION
22. Pursuant to Sections 4(i), 4(j), and 403 of the Communications Act,
37
Dialing Services is
directed to confirm within fifteen (15) calendar days after the release date of this Citation that the Company
has (1) ceased making any calls to cell phones using autodialers or artificial or prerecorded messages (except 
as permitted by section 227(b)(1)(A)(iii) of the Act and section 64.1200(a)(1)(iii).of the Commission’s rules), 
and (2) ceased making any prerecorded message calls without the identification information required in the 
                                                                                                                                                                
also Amendment of Section 1.80(b) of the Commission’s Rules, Adjustment of Forfeiture Maxima to Reflect Inflation, 23 
FCC Rcd 9845 (2008) (amendment of section 1.80(b) to reflect inflation increased the forfeiture maximum for this type 
of violator to $16,000).
35
See note 5, above.
36
47 C.F.R. § 1.17.
37
47 U.S.C. §§ 154(i), (j), 403.
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Federal Communications Commission DA 13-265
                                                                                                    
8
Act and Commission’s rules.  Failure to respond to the request for information, or an inadequate, incomplete, 
or misleading response, may subject the Company to additional sanctions.
38
VII. ORDERING CLAUSES
23. IT IS ORDERED that pursuant to Sections 4(i), 4(j), and 403 of the Communications Act, 
Dialing Services, LLC must provide the information requested in paragraphs 3 and 22.  The response to the 
request for information must be provided in the manner indicated herein and must be received by the FCC 
within fifteen (15) calendar days after the release date of this Citation and Order.
24. IT IS FURTHER ORDERED that a copy of this Citation and Order shall be sent by First 
Class U.S. Mail and Certified Mail, return receipt requested, to: Dialing Services, LLC, Attn: Anthony C. 
Kolker, President, 5149 Cotton RD, Roswell, NM 88201; and to Mitchell N. Roth, Esquire, Roth Doner 
Jackson, PLC, 8200 Greensboro Drive, Suite 820, McLean, Virginia 22102.
FEDERAL COMMUNICATIONS COMMISSION
Richard A. Hindman, Chief
Telecommunications Consumers Division
Enforcement Bureau
                                                
38
See, e.g., SBC Communications, Inc., Apparent Liability for Forfeiture, Forfeiture Order, 17 FCC Rcd 7589 (2002) 
($100,000 forfeiture for refusing to attest to truthfulness and accuracy of responses to a Bureau letter of inquiry); 
Connect Paging, Inc. d/b/a Get A Phone, Forfeiture Order, 22 FCC Rcd 15146 (Enf. Bur. 2007) ($4,000 forfeiture for 
failure to respond to a Bureau letter of inquiry); BigZoo.Com Corporation, Order of Forfeiture, 20 FCC Rcd 3954 (Enf. 
Bur. 2005) ($20,000 forfeiture for failure to respond to an LOI); Donald W. Kaminski, Jr., Forfeiture Order, 18 FCC Rcd 
26065 (Enf. Bur. 2003) ($4,000 forfeiture for failure to respond to a Bureau letter of inquiry). 
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Federal Communications Commission DA 13-265
                                                                                                    
9
Attachment A
Dialing Services
Prerecorded message calls made to wireless telephones without subscriber consent
1
Date and Time of Call
2
Wireless Phone Number Dialed Prerecorded Message
4/4/2012   8:29 [REDACTED] [REDACTED]
4/4/2012   7:29 [REDACTED] [REDACTED]
4/4/2012   9:53 [REDACTED] [REDACTED]
4/4/2012   9:34 [REDACTED] [REDACTED]
4/4/2012   9:57 [REDACTED] [REDACTED]
4/4/2012   9:37 [REDACTED] [REDACTED]
4/4/2012   9:56 [REDACTED] [REDACTED]
4/4/2012   9:48 [REDACTED] [REDACTED]
4/4/2012   9:31 [REDACTED] [REDACTED]
4/4/2012   9:42 [REDACTED] [REDACTED]
                                                
1
See Affidavit of Kristi Thompson, Deputy Chief, Telecommunications Consumers Division, FCC Enforcement 
Bureau (Oct. 12, 2012) (on file in EB-TCD-12-00001812).
2
See Dialing Services June 13 Response, Excel spreadsheet attachment, [REDACTED].  The entry information 
listed in this Attachment A appear on the call detail records produced by Dialing Services in response to the 
Bureau’s May 4, 2012, LOI.