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 Federal Communications Commission DA 16-1289 
 
Before the 
Federal Communications Commission 
Washington, DC 20554  
 
In the Matter of 
 
WDT World Discount Telecommunications Co., 
Inc. 
 
  ) 
  ) 
  ) 
  ) 
  ) 
  
 
                 
 
File No.:  EB-IHD-15-00020150 
NAL/Acct. No.:  201732080002 
FRN:  0009514803 
              
NOTICE OF APPARENT LIABILITY FOR FORFEITURE 
AND ADMONISHMENT 
 
Adopted:  November 18, 2016 Released:  November 18, 2016 
 
By the Chief, Enforcement Bureau: 
 
I. INTRODUCTION 
1. We propose a penalty of $100,000 against WDT World Discount Telecommunications 
Co., Inc. (WDT or Company), for an apparent violation of the Commission’s universal service reporting 
obligations, and for transferring, without prior Commission approval, certain assets, including its 
customer base.  Specifically, we find that WDT apparently violated the Communications Act of 1934 
(Act), as amended, and the Commission’s rules by failing to timely file one annual revenue report with 
the Universal Service Administrative Company (USAC), and by failing to obtain prior Commission 
approval for transferring its assets, including its customer base.  By failing to meet its regulatory filing 
obligations, WDT interfered with the orderly administration of the universal service funding mechanisms.  
In addition, WDT’s unauthorized transfer prevented the Commission from evaluating possible risks to 
competition and consumers, and any other adverse consequences that might have resulted from the asset 
transfer.  In proposing penalties for WDT’s failures to comply with its regulatory reporting and 
authorization obligations, we also consider the company’s past conduct in charging excessive universal 
service fees to its international long distance customers.  Relatedly, we admonish WDT for its violations 
of our rule prohibiting excessive universal service surcharges that occurred outside the one-year statute of 
limitations.  Taken as a whole, we view the Company’s apparent noncompliance as a serious dereliction 
of its responsibilities as a telecommunications service provider, and one that warrants the proposal of a 
substantial monetary penalty. 
II. BACKGROUND 
2. Until early 2016, WDT World Discount Telecommunications Co., Inc., was an Illinois-
based toll reseller providing international and domestic long distance service nationwide, and some local 
phone service in Illinois.1  Registered as a privately held corporation in Texas,2 WDT held Commission 
authorizations to provide domestic and international telecommunications service pursuant to Section 214 
of the Act.3 
                                                     
1 See WDT World Discount Telecommunications Co., April 2016 FCC Form 499-A (on file in EB-IHD-15-
00020150) (2016 Form 499-A).  As further discussed below, WDT transferred its assets in 2016. 
2 Texas Secretary of State, Corporations Section, WDT World Discount Telecommunications Co., File No. 
155560600 (formed Oct. 25, 1999). 
3 See International Bureau Filing System (IBFS) File No.:  ITC-214-19970605-00310 (granted July 23, 1997) 
available at http://licensing fcc.gov/cgi-
bin/ws.exe/prod/ib/forms/reports/swr031b hts?q set=V SITE ANTENNA FREQ.file numberC/File+Number/%3
 Federal Communications Commission DA 16-1289 
 2
3. Because of its high percentage of international revenues from 2011 to 2015, WDT 
qualified for and availed itself of the Limited International Revenue Exemption (LIRE) provided in the 
Commission’s rules (Rules), which exempted the Company from contributing to the Universal Service 
Fund (USF) based on its international revenues pursuant to Section 54.706(c).4  After auditing the 
accuracy of WDT’s 2012 FCC Form 499A, which reported WDT’s annual revenues for 2011, USAC 
concluded that WDT collected USF surcharges based on international service despite the fact that WDT 
was not paying into the USF at the time based on its LIRE status as a primarily international service 
provider.5  On June 9, 2014, USAC referred the Company to the Commission for potential enforcement 
action.6 
4. On December 21, 2015, the Enforcement Bureau (Bureau) issued a Letter of Inquiry 
(LOI) to WDT to investigate whether the Company or its subsidiaries had violated provisions of the Act 
and Rules, including improperly recovering excessive federal USF contributions costs through line items 
on customers’ bills, and failing to timely file required regulatory data, including revenue information 
reported on FCC Form 499A (Annual Worksheets).7  After the Bureau granted the Company’s extension 
request, WDT responded to the LOI in several parts on February 3, 2016, February 12, 2016, March 15, 
2016, and March 25, 2016.8  On January 1, 2016, WDT transferred certain of its assets, including its 
customer base, to Master Call Connections, LLC, an interexchange service provider.9  WDT never sought 
FCC approval of the acquisition of assets before closing on the transaction, as required by the Commission’s 
Rules. 
III. DISCUSSION 
5. Based on the facts and circumstances before us, and as described more fully below, we 
find that WDT apparently willfully or repeatedly failed to timely file one Annual Worksheet in 
accordance with Section 54.711(a) of the Rules,10 and failed to obtain prior Commission approval for 
transferring certain assets, including its customer base, as required by Section 214 of the Act and Sections 
                                                     
D/ITC2141997060500310&prepare=&column=V SITE ANTENNA FREQ.file numberC/File+Number (last 
visited Nov. 1, 2016). 
4 See 47 CFR § 54.706(c) (when an entity subject to the USF reporting requirements has quarterly interstate revenue 
of less than 12 percent of its combined quarterly interstate and international revenue, the carrier is eligible for the 
LIRE and its international revenue will not be used in determining the entity’s quarterly USF contribution base 
obligation). 
5 See Letter from Michelle Garber, Director, Financial Operations, USAC, to Terry Cavanaugh, Chief, 
Investigations and Hearings Division, FCC Enforcement Bureau (June 9, 2014) (on file in EB-IHD-15-00020150) 
(USAC Referral). 
6 See id. 
7 See Letter from Jeffrey J. Gee, Chief, Investigations and Hearings Division, FCC Enforcement Bureau, to Roman 
Talis, President and CEO, WDT World Discount Telecommunications Co., Inc., WDT Wireless 
Telecommunications, Inc., and AllVoi, Inc. (Dec. 21, 2015) (addressing Company’s compliance with 47 U.S.C. 
§§ 159(a), 201(b), 254(d); and 47 CFR §§ 1.1154, 1.1157, 54.702(n), 54.706, 54.707, 54.711, 54.712, 54.713, 
64.1195, 64.2401, and 64.5001) (on file in EB-IHD-15-00020150) (LOI). 
8 See Letters from John J. Heitmann, Kelley Drye & Warren LLP, Counsel to WDT World Discount 
Telecommunications Co., Inc., WDT Wireless Telecommunications, Inc., and AllVoi, Inc., to Jeffrey J. Gee, Chief, 
Investigations and Hearings Division, FCC Enforcement Bureau (dated February 3, 2016, February 12, 2016, March 
15, 2016, and March 25, 2016) (on file in EB-IHD-15-00020150) (collectively, LOI Response).   
9 LOI Response to Inquiry 6; Asset Purchase Agreement executed by WDT and Master Call Connections, LLC 
(dated Jan. 1, 2016) (on file in EB-IHD-15-00020150, subject to confidentiality request).  See also 
https://www.wdteasy.com (referencing “IMPORTANT information for WDT Easy customers!  Due to the recent 
merger of WDT, Inc. and MasterCall Connections, some changes have been made to the service you currently use”). 
10 See 47 CFR § 54.711(a). 
 Federal Communications Commission DA 16-1289 
 3
63.01, 63.03, 63.04, and 63.18 of the Rules.11  We also consider WDT’s imposition of excessive customer 
surcharges in violation of Section 54.712 of the Rules in assessing proposed penalties for its 
noncompliance, and we admonish WDT for its violations of this rule that occurred beyond the one-year 
statute of limitations. 
A. WDT Apparently Violated Section 54.711 of the Commission’s Rules by Failing to 
Timely File an Annual Revenue Reporting Worksheet 
6. The Act directs the Commission to establish, administer, and maintain programs to 
promote universal service, Telecommunications Relay Service (TRS), and numbering administration 
programs, among other mandates.12  To help accomplish these goals, the Commission has established the 
USF and related funding mechanisms.  As Congress has directed,13 the Commission funds USF programs 
through assessments on telecommunications service providers.  To gather the data necessary to calculate 
assessments, the Commission requires interstate telecommunications service providers, among others, to 
periodically file projected revenue information and, using the FCC Form 499A, also known as the Annual 
Worksheet, to report providers’ actual revenues from the various types of services provided during the 
previous calendar year.14  USAC utilizes this data to calculate, and later true-up, a company’s USF 
contributions.15  The Annual Worksheet filing obligations allow the Commission and the administrator of 
the USF to determine the extent of a company’s payment obligations for these federal programs.16   
7. WDT failed to timely submit an Annual Worksheet reporting revenue for 2012, which 
was due April 1, 2013.17  WDT submitted its 2013 Annual Worksheet on November 27, 2015, more than 
31 months late.18  We therefore find it is apparent that WDT willfully or repeatedly violated Section 
54.711(a) of the Rules by failing to timely file the Annual Worksheet that was due April 1, 2013. 
8. Pursuant to Section 54.711(a) of the Rules, telecommunications providers such as WDT 
are required to timely file Telecommunications Reporting Worksheets to provide the information 
necessary to calculate amounts that a service provider must contribute to federal regulatory programs.  A 
carrier's failure to file these required worksheets has a direct and detrimental impact by interfering with 
the calculation of USF contributions telecommunications revenues, and shifts additional economic 
burdens to compliant carriers in the USF program.  Consequently, a carrier's failure to file required 
Worksheets frustrates the very purpose for which Congress enacted Section 254(d) of the Act—to ensure 
that every interstate carrier “contribute, on an equitable and nondiscriminatory basis, to the specific, 
predictable, and sufficient mechanisms established by the Commission to preserve and advance universal 
service.”19  By failing to timely file the required revenue data on different types of services during the 
                                                     
11 See 47 U.S.C. § 214; 47 CFR §§ 63.01, 63.03, 63.04, 63.18. 
12 See 47 U.S.C. §§ 225(b)(1)–(2), 251(b)(2), (e), 254(a)(2). 
13 See 47 U.S.C. §§ 225(d)(3), 251(e)(2), 254(d). 
14 See 47 CFR §§ 52.17(b), 52.32(b), 54.711(a), 64.604(c)(5)(iii)(B). 
15 See Wireline Competition Bureau Releases 2016 Telecomms. Reporting Worksheets & Accompanying 
Instructions, Public Notice, 31 FCC Rcd 973, 2016 WL 520248, **44 (Wireline Comp. Bur. 2016). 
16 See InPhonic, Inc., Notice of Apparent Liability for Forfeiture and Order, 20 FCC Rcd 13277, 13283-84, para. 18 
(2005), forfeiture issued, Order of Forfeiture and Further Notice of Apparent Liability for Forfeiture, 22 FCC Rcd 
8689, 8691, para. 5 (2007). 
17 Wireline Competition Bureau Releases 2013 Telecomms. Reporting Worksheets & Accompanying Instructions, 
Public Notice, 28 FCC Rcd 1933 (2013). 
18 See https://efile.universalservice.org/form499/source/search.asp?optFilerID=823370&allFilings=1 (WDT’s USAC 
filing history) (last visited Nov. 1, 2016) (search results on file in EB-IHD-15-00020150).   
19 47 U.S.C. §254(d). 
 Federal Communications Commission DA 16-1289 
 4
calendar year, WDT interfered with the orderly administration of the universal service funding 
mechanism.  
B. WDT Apparently Violated Section 214 of the Act and Sections 63.01, 63.03, 63.04 
and 63.18 of the Rules by Failing to Obtain Prior Commission Approval for a 
Transfer Of Assets  
9. Section 214 of the Act requires telecommunications carriers to obtain a certificate of 
public convenience and necessity from the Commission before constructing, acquiring, operating, or 
engaging in the transmission of common carrier communications services over communications lines, and 
before discontinuing, reducing, or impairing service to a community.20  In addition, the Commission’s 
Rules also state that sales of assets that include a company’s customer base should be treated as transfers 
of control requiring Commission approval.21  From July 23, 1997 until January 1, 2016, WDT held 
Commission authorizations to provide domestic and international telecommunications service pursuant to 
Section 214 of the Act for itself and its subsidiaries.22  On January 1, 2016, WDT consummated a transfer 
of its assets, including a transfer of its customer base, to Master Call Connections LLC,23 another 
telecommunications provider, without obtaining prior Commission approval.   
10. Although ten months have passed since the Company finally disclosed the transfer of 
assets in response to the LOI, it still has not submitted applications with the Wireline Competition and 
International Bureaus for the requisite approvals necessary to consummate the transaction.  Nor has WDT 
explained why it has not filed applications for approval.  Pursuant to Section 214 of the Act and the rules 
cited above, WDT was required to obtain two approvals from the Commission—one from the Wireline 
Competition Bureau and another from the International Bureau—before consummating the transfer of 
assets including customer accounts.24  Based on a preponderance of the evidence, we therefore find that 
WDT’s unauthorized transfer of its assets and customer base resulted in two violations—one for the 
domestic authorization and one for the international authorization—of  Section 214 of the Act and 
Sections 63.01, 63.03, 63.04 and 63.18 of the Rules.25  WDT’s violations of the statute and Rules continue 
                                                     
20 See 47 U.S.C. § 214(a).  In 1999, the Commission granted all telecommunications carriers blanket authority under 
Section 214 to provide domestic interstate services and to construct or operate any domestic transmission line.  See   
47 CFR § 63.01(a) (“Any party that would be a domestic interstate communications common carrier is authorized to 
provide domestic, interstate services to any domestic point and to construct or operate any domestic transmission 
line as long as it obtains all necessary authorizations from the Commission for use of radio frequencies.”). 
21 See 47 CFR §§ 63.01, 63.03, 63.04, and 63.18; see also Implementation of Further Streamlining Measures for 
Domestic Section 214 Authorizations, Report and Order, 17 FCC Rcd 5517, 5547-49, paras. 59-64 (2002) 
(modifying 47 CFR § 63.01 to reflect that asset purchases will no longer be subject to blanket authority, but rather 
will be treated as transfers of control). 
22 See LOI Response to Inquiries No. 6 and 7; International Bureau Filing System (IBFS) File No.:  ITC-214-
19970605-00310 (granted July 23, 1997) available at http://licensing fcc.gov/cgi-
bin/ws.exe/prod/ib/forms/reports/swr031b hts?q set=V SITE ANTENNA FREQ.file numberC/File+Number/%3
D/ITC2141997060500310&prepare=&column=V SITE ANTENNA FREQ.file numberC/File+Number (last 
visited Nov. 1, 2016). 
23 See Asset Purchase Agreement (dated Jan. 1, 2016) (on file in EB-IHD-15-00020150, subject to confidentiality 
request). 
24 See 47 U.S.C. § 214(a); 47 CFR §§ 63.01 (requiring prior approval for transfer of domestic transmission lines), 
63.03 (streamlining procedures for domestic transfer of control applications), 63.04 (filing procedures for domestic 
transfer of control applications), and 63.18 (procedures for transfer of control applications for international common 
carriers). 
25 See 47 U.S.C. § 214(a); 47 CFR §§ 63.01, 63.03, 63.04, and 63.18. 
 Federal Communications Commission DA 16-1289 
 5
under the applicable statutory limitations period until Commission approvals of the transfers are 
granted.26 
C. WDT Apparently Violated Section 54.712(a) of the Commission’s Rules by 
Imposing Excessive USF Surcharges on Service for Which it Had No Contribution 
Obligation 
11. Section 54.712(a) of the Commission’s Rules prohibits USF contributors from charging 
more to the end-user for USF surcharges than what they pay into the fund on interstate revenues from that 
customer.27  As the Commission noted when it adopted Section 54.712, such pass-throughs of USF costs 
are not mandatory customer surcharges, since it wanted carriers to retain the flexibility to structure their 
recovery of the costs of universal service.28  However, it emphasized that contributors choosing to pass 
through USF contributions to customers must “include complete and truthful information regarding the 
contribution amount.  We do not assume that contributors will provide false or misleading statements, but 
we are concerned that consumers receive complete information regarding the nature of the universal 
service contribution.”29 
12. Pursuant to Section 54.706(c),30 WDT qualified for LIRE from 2011-2015 because its 
interstate revenue equaled less than 12 percent of its combined interstate and international revenue.  As a 
result, WDT was exempt from contributing to the USF based on its international revenues.31  However, 
upon investigation, WDT apparently billed customers for excessive and unlawful USF surcharges for 
international service this entire period, despite having no USF contribution obligation on those revenues.  
Specifically, according to its Annual Worksheets filed with USAC, WDT reported more than $ 32 
of international surcharge revenue during the period in which it qualified for LIRE, between 2011 and 
2015, and did not pay USF charges on international revenues at the time.  Accordingly, the surcharges on 
international service collected by WDT between 2011 and 2015 appear to have exceeded the recovery 
from end-users permitted under Section 54.712(a) of the Commission’s Rules.33 
                                                     
26 See, e.g., PTT Phone Cards, Inc., Notice of Apparent Liability for Forfeiture, 29 FCC Rcd 11531, 11534, para. 9 
(2014) (PTT Phone Cards NAL); Unipoint Technologies, Inc., Notice of Apparent Liability for Forfeiture, 27 FCC 
Rcd 12751, 12757, para. 13 (2012) (Unipoint NAL). 
27 47 CFR § 54.712(a).  Specifically, the rule provides: “If a contributor chooses to recover its federal universal 
service contribution costs through a line item on a customer’s bill the amount of the federal universal service line-
item charge may not exceed the interstate telecommunications portion of that customer’s bill times the relevant 
contribution factor.”  Id. 
28 See In the Matter of Fed.-State Joint Bd. on Universal Serv., Report and Order, 12 FCC Rcd 8776, 9211-12, para. 
855 (1997) (Universal Service First Report and Order). 
29 Id. 
30 See 47 CFR § 54.706(c) (when an entity subject to the USF reporting requirements has quarterly interstate 
revenue of less than 12 percent of its combined quarterly interstate and international revenue, the carrier is eligible 
for the LIRE and its international revenue will not be used in determining the entity’s quarterly USF contribution 
base obligation). 
31 See 47 CFR § 54.706(c).  The rule extends the exemption to the entity that is subject to the USF reporting 
requirements as well as the entity’s affiliated providers of interstate and international telecommunications and 
telecommunications services.  Id. 
32 The Bureau has redacted information in this NAL relating to WDT’s revenues.  On each FCC Form 499A, WDT’s 
President requested nondisclosure and certified that the reported revenue data was privileged and confidential and 
that public disclosure of such information would likely cause substantial harm to the competitive position of the 
company.  See 47 CFR § 0.459; FCC Form 499A, Line 605.  
33 47 CFR § 54.712(a). 
 Federal Communications Commission DA 16-1289 
 6
13. Following the issuance of the final USAC audit report in 2014,34 WDT stopped reporting 
international surcharge revenue on its Annual Worksheets in 2015,35 and WDT stated that it ceased 
imposing the charges on customer bills in early fall of 2015.36  However, as we discuss below, in light of 
WDT’s violation of Commission Rules by improperly collecting such a significant amount of customer 
overcharges over such a long period, we find the existence of the prior violations warrants consideration 
in our calculation of the proposed forfeitures for the rule violation relating to WDT’s failure to timely file 
an Annual Worksheet as well as for its failure to obtain prior Commission approval for its transfer of 
assets.37  We also find these violations by WDT merit admonishment to emphasize the seriously anti-
consumer nature of its collection of excessive USF surcharges on service for which the Company had no 
USF contribution obligation. 
D. Proposed Action 
1. Proposed Forfeiture Amount  
14. Section 503(b) of the Act authorizes the Commission to impose a forfeiture against any 
entity that “willfully or repeatedly fail[s] to comply with any of the provisions of [the Act] or of any rule, 
regulation, or order issued by the Commission.”38  Section 503(b)(2)(B) of the Act authorizes the 
Commission to assess a forfeiture against WDT up to $189,361 for each violation or each day of a 
continuing violation, up to a statutory maximum of $1,893,610 for a single act or failure to act.39  In 
exercising our forfeiture authority, we must consider 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.”40  In addition, the Commission has established 
forfeiture guidelines that establish base penalties for certain violations and identify criteria that we 
consider when determining the appropriate penalty in any given case.41  Under these guidelines, we may 
adjust a forfeiture upward for violations that are egregious, intentional, or repeated, or that cause 
substantial harm or generate substantial economic gain for the violator.42  We may adjust a forfeiture 
downward under the guidelines for minor violations, good faith or voluntary disclosure, a history of 
                                                     
34 See USAC Referral, Attachment A. 
35 See WDT 2016 FCC Form 499A, Line 403(e) (on file in EB-IHD-15-00020150). 
36 See LOI Response to Inquiry 22. 
37 See Section III.D.1, infra. 
38 47 U.S.C. § 503(b). 
39 See 47 U.S.C. § 503(b)(2)(B); 47 CFR § 1.80(b)(9).  These amounts reflect inflation adjustments to the forfeitures 
specified in Section 503(b)(2)(B) ($100,000 for each violation or each day of a continuing violation, except that the 
amount assessed for any continuing violation shall not exceed a total of $1,000,000 for any single act or failure to 
act).  The Federal Civil Penalties Inflation Adjustment Act of 1990, Pub. L. No. 101-410, 104 Stat. 890, as amended 
by the Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, Sec. 31001, 110 Stat. 1321 (DCIA), requires 
the Commission to adjust its forfeiture penalties periodically for inflation.  See 28 U.S.C. § 2461 note (4).  The 
Commission most recently adjusted its penalties to account for inflation on June 9, 2016.  See Amendment of Section 
1.80(b) of the Commission’s Rules, Adjustment of Civil Monetary Penalties to Reflect Inflation, Order,  31 FCC Rcd 
6793 (EB 2016); see also Inflation Adjustment of Monetary Penalties, 81 Fed. Reg. 42,554 (Jun. 30, 2016) (setting 
August 1, 2016 as the effective date for the increases). 
40 47 U.S.C. § 503(b)(2)(E). 
41 47 CFR § 1.80(b)(8), Note to paragraph (b)(8).  
42 Id.  See also The Comm’n’s Forfeiture Policy Statement & Amendment of Section 1.80 of the Rules to Incorporate 
the Forfeiture Guidelines, Report and Order, 12 FCC Rcd 17087, 17098-99, para. 22 (1997) (noting that “[a]lthough 
we have adopted the base forfeiture amounts as guidelines to provide a measure of predictability to the forfeiture 
process, we retain our discretion to depart from the guidelines and issue forfeitures on a case-by-case basis, under 
our general forfeiture authority contained in Section 503 of the Act”) (Forfeiture Guidelines), recon. denied, 
Memorandum Opinion and Order, 15 FCC Rcd 303 (1999).     
 Federal Communications Commission DA 16-1289 
 7
overall compliance, or an inability to pay.43  The Commission’s forfeiture guidelines specifically “are 
intended as a guide for frequently recurring violations” and not “a complete or exhaustive list of 
violations.”44 
15. Under Section 503(b)(6) of the Act, we may only propose forfeitures for apparent 
violations that accrued within one year of the date of this NAL.45  Nevertheless, Section 503 does not 
prohibit us from assessing whether WDT’s conduct prior to that date apparently violated the Act or our 
Rules and we may consider WDT's other violations in determining the appropriate forfeiture amount for 
those violations within the statute of limitations.46  Therefore, although we find that WDT apparently 
violated the Act and our Rules in multiple years, we discuss forfeitures here for only the last year of 
violations.  We admonish WDT for the violations of the rule prohibiting excessive USF surcharges that 
occurred beyond the statute of limitations.47 
16. Pursuant to Commission precedent, we impose a forfeiture of $50,000 for WDT’s failure 
to timely file an Annual Worksheet that it was legally obligated to file on April 1, 2013.48  The forfeiture 
amount of $50,000 for its failure to timely file, as applied to WDT, is consistent with the statutory factors 
in the Act.  We thus find that WDT is apparently liable for a forfeiture of fifty thousand dollars ($50,000) 
for its apparently willful or repeated failure to timely file its Annual Worksheet.49 
17. Regarding WDT’s unauthorized transfer of assets, which included its customer base, 
Section 1.80 of the Rules establishes a base forfeiture amount of $8,000 for an “unauthorized substantial 
transfer of control.”50  WDT was required by Section 214 of the Act and Sections 63.01, 63.03, 63.04, and 
63.18 of the Rules to obtain two approvals from the Commission – one from the Wireline Competition 
Bureau and another from the International Bureau – before consummating the transfer of assets including 
customer accounts.51  Consequently, for the two failures to obtain authorization to transfer WDT’s assets 
and customer base, we find that a proposed base forfeiture in the amount of $16,000 is appropriate.  The 
Commission has upwardly adjusted the base forfeiture to $20,000 for two unauthorized transfer of control 
violations in other cases because of the duration of the violation and other factors contained in Section 
503(b)(2)(E) of the Act.52  In this case, WDT consummated the transaction over 11 months ago.  
                                                     
43 47 CFR § 1.80(b)(8), Note to paragraph (b)(8). 
44 Forfeiture Guidelines, 12 FCC Rcd at 17109-10, para. 53. 
45 47 U.S.C. § 503(b)(6)(B). See also 47 C.F.R. § 1.80(c)(4). 
46 47 C.F.R. § 1.80(b)(8). 
47 47 CFR § 54.712(a). 
48 See, e.g., UnityComm, LLC, DA 16-1020, Notice of Apparent Liability for Forfeiture, ___ FCC Rcd ___ (EB 
2016); Advanced Tel, Inc., Notice of Apparent Liability for Forfeiture, 30 FCC Rcd 833, 8441-42, paras. 27-28 
(2015); ADMA Telecom, Inc., Notice of Apparent Liability for Forfeiture, 24 FCC Rcd. 838 (2009), forfeiture 
issued, Forfeiture Order, 26 FCC Rcd 4152, 4155, 4162, paras. 9, 28 (2011); Globcom, Inc., Notice of Apparent 
Liability for Forfeiture and Order, 18 FCC Rcd 19893 (2003), forfeiture issued, Order of Forfeiture, 21 FCC Rcd 
4710, 4720–21, 4727, paras. 26–28, 31, 45 (2006).   
49 We note that other violations of the Commission’s reporting requirements applicable to WDT and its subsidiaries 
may be subject to separate sanctions in a future enforcement action.  See, e.g., 47 CFR § 54.711(a). 
50 See 47 CFR § 1.80(b)(8), Note to paragraph (b)(8). 
51 See 47 U.S.C. § 214(a); 47 CFR §§ 63.01 (requiring prior approval for transfer of domestic transmission lines), 
63.03 (streamlining procedures for domestic transfer of control applications), 63.04 (filing procedures for domestic 
transfer of control applications), and 63.18 (procedures for transfer of control applications for international common 
carriers). 
52 See Roman LD, Inc., Notice of Apparent Liability for Forfeiture, 30 FCC Rcd 3433, 3438-39, paras. 16-17 (2015); 
Stanacard LLC, Notice of Apparent Liability for Forfeiture, 28 FCC Rcd 82, 87, para. 14 (2013). 
 Federal Communications Commission DA 16-1289 
 8
Consequently, an upward adjustment is appropriate and consistent with precedent.53  Based on the facts 
and circumstances presented, we conclude that the appropriate forfeiture amount for the two instances of 
unauthorized transfer of control is twenty thousand dollars ($20,000). 
18. In light of WDT’s improper collection of over $  of international USF surcharges 
for more than four years when it had no associated USF payment obligation, we find it is appropriate to 
upwardly adjust the proposed base forfeiture for the failures to timely file revenue worksheets and for 
unauthorized transfers, in order to deter other contributors from imposing excessive surcharges in 
violation of Section 54.712(a) of the Rules.  As noted above, following the issuance of the final USAC 
audit report in 2014, WDT stopped reporting international surcharge revenue on its Annual Worksheets in 
2015, and WDT stated that it ceased imposing the charges on customer bills in early fall of 2015.54  
Because WDT stopped the practice more than 12 months before the issuance of this NAL, the excessive 
surcharge violations have lapsed under the applicable one-year statute of limitations.55  However, because 
WDT improperly collected such a significant amount of customer overcharges over such a long period, 
we find this history of prior violations of Section 54.712(a)—and particularly the egregiousness of the 
amount improperly collected in the guise of USF recovery—justifies an upward adjustment of the 
proposed forfeiture for the worksheet violations, based on the factors set forth in Section 503(b)(2)(E) of 
the Act,56 as well as Commission precedent.57  Telecommunications providers that contribute to USF are 
responsible for providing customers with complete and truthful information regarding any charges that 
relate to universal service.58  In no event should contributors impose USF costs on customers when they 
have no USF contribution obligation associated with the service being provided.  Taking the seriousness, 
extensive period, and scope of WDT’s past improper collection of excessive USF surcharges into account, 
we find that the base forfeiture for the worksheet and unauthorized transfer of asset violations should be 
upwardly adjusted by an additional thirty thousand dollars ($30,000).  
19. Therefore, after applying the Forfeiture Guidelines, Section 1.80 of the Rules, and the 
statutory factors, we propose a total forfeiture of $100,000, for which WDT is apparently liable. 
2. Admonishment 
20. As noted above, we also admonish WDT for its violations of our Rules that occurred 
outside the one-year statute of limitations. Although we propose forfeitures for the apparent violations 
within the last year, admonishment for violations beyond the statute of limitations is appropriate here to 
note the full scope and scale of WDT's departure from our Rules. 
                                                     
53 See Stanacard LLC, 28 FCC Rcd at 87 (adjusting proposed forfeiture for two unauthorized Section 214 
transactions persisting for more than six months before corrective action taken). 
54 See para. 13, supra; LOI Response to Inquiry 22. 
55 Under federal law, the statute of limitations for issuance of a Notice of Apparent Liability (NAL) for violations of 
the Act, Commission Rules, or both, by a non-broadcast licensee, is one year from the date on which the alleged 
violations occurred.  47 U.S.C. § 503(b)(6). 
56 See 47 U.S.C. § 503(b)(2)(E). 
57 See 47 U.S.C. § 503(b)(2)(E); Optic Internet Protocol, Inc., 29 FCC Rcd 9056, 9065 (2014) (upwardly adjusting 
the $40,000 base forfeiture for cramming where carrier’s conduct was egregious, and caused substantial and 
continuing harm to consumers); U.S. Telecom Long Distance, Inc., Forfeiture Order, 31 FCC Rcd 10413 (2016) 
(same).  See also Telecom Mgmt., Inc., Forfeiture Order, 21 FCC Rcd 10470, 10477 (2006) (upwardly adjusting 
proposed forfeiture of $167,992 by 100 percent to $335,983 for failures to pay USF contributions). 
58 See In the Matter of Fed.-State Joint Bd. on Universal Serv., Report and Order, 12 FCC Rcd 8776, 9211-12, para. 
855 (1997). 
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21. We therefore admonish WDT for violating Section 54.712(a) of our Rules59 through its 
imposition of excessive USF surcharges on customers of international service for which WDT had no 
USF contribution obligation.  
IV. CONCLUSION 
22. We have determined it is apparent that WDT willfully or repeatedly violated Section 214 
of the Act, and Sections 54.711(a), 63.01, 63.03, 63.04, and 63.18 of the Rules.  We further find that 
WDT violated 54.712(a) of the Rules.  In light of the seriousness, duration and scope of the apparent 
violations, we find that a proposed forfeiture of $100,000 is warranted. As discussed, this proposed 
forfeiture amount includes (1) a proposed penalty of $50,000 for WDT's apparent failure to timely file a 
revenue reporting worksheet; and (2) a total proposed penalty of $20,000 for WDT's apparent failure to 
obtain prior Commission approval for the transfer of its assets, including its customer base; and (3) an 
upward adjustment of $30,000 for WDT’s charging excessive USF fees to its international long distance 
customers.  As such, WDT is apparently liable for a forfeiture of $100,000.    
V. ORDERING CLAUSES 
23. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Act60 and 
Sections 1.80 of the Rules,61 WDT World Discount Telecommunications Co. Inc. is hereby NOTIFIED 
of this APPARENT LIABILITY FOR A FORFEITURE in the amount of One Hundred Thousand 
Dollars ($100,000) for willful or repeated violations of Section 214 of the Act,62 and Sections 54.711(a), 
63.01, 63.03, 63.04, and 63.18 of the Rules.63 
24. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the Rules,64 within thirty 
(30) calendar days of the release date of this Notice of Apparent Liability for Forfeiture, WDT World 
Discount Telecommunications Co. Inc. SHALL PAY the full amount of the proposed forfeiture or 
SHALL FILE a written statement seeking reduction or cancellation of the proposed forfeiture consistent 
with paragraph 28 below. 
25. IT IS FURTHER ORDERED that WDT World Discount Telecommunications Co. Inc. 
IS ADMONISHED for its violations of Section 54.712(a) of the Rules. 
26. Payment of the forfeiture must be made by check or similar instrument, wire transfer, or 
credit card, and must include the NAL/Account Number and FRN referenced above.  WDT World 
Discount Telecommunications Co. Inc. shall send electronic notification of payment to Jeffrey J. Gee at 
Jeffrey.Gee@fcc.gov, and Mindy Littell at Mindy.Littell@fcc.gov on the date said payment is made.  
Regardless of the form of payment, a completed FCC Form 159 (Remittance Advice) must be 
submitted.65  When completing the FCC Form 159, enter the Account Number in block number 23A (call 
sign/other ID) and enter the letters “FORF” in block number 24A (payment type code).  Below are 
additional instructions that should be followed based on the form of payment selected:  
• Payment by check or money order must be made payable to the order of the Federal 
Communications Commission.  Such payments (along with the completed Form 159) must be 
mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-
                                                     
59 47 CFR § 54.712(a). 
60 47 U.S.C. § 503(b). 
61 47 CFR § 1.80. 
62 47 U.S.C. § 214. 
63 See 47 U.S.C. § 214; 47 CFR §§ 54.711(a), 63.01, 63.03, 63.04, 63.18. 
64 47 CFR § 1.80. 
65 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www fcc.gov/Forms/Form159/159.pdf. 
 Federal Communications Commission DA 16-1289 
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9000, or sent via overnight mail to U.S. Bank – Government Lockbox #979088, SL-MO-C2-
GL, 1005 Convention Plaza, St. Louis, MO 63101. 
• Payment by wire transfer must be made to ABA Number 021030004, receiving bank 
TREAS/NYC, and Account Number 27000001.  To complete the wire transfer and ensure 
appropriate crediting of the wired funds, a completed Form 159 must be faxed to U.S. Bank 
at (314) 418-4232 on the same business day the wire transfer is initiated. 
• Payment by credit card must be made by providing the required credit card information on 
FCC Form 159 and signing and dating the Form 159 to authorize the credit card payment.  
The completed Form 159 must then be mailed to Federal Communications Commission, P.O. 
Box 979088, St. Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank – 
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
63101. 
27. Any request for making full payment over time under an installment plan should be sent 
to:  Chief Financial Officer—Financial Operations, Federal Communications Commission, 445 12th 
Street, SW, Room 1-A625, Washington, DC 20554.66  Questions regarding payment procedures should be 
directed to the Financial Operations Group Help Desk by phone, 1-877-480-3201, or by e-mail, 
ARINQUIRIES@fcc.gov. 
28. The written statement seeking reduction or cancellation of the proposed forfeiture, if any, 
must include a detailed factual statement supported by appropriate documentation and affidavits pursuant 
to Sections 1.16 and 1.80(f)(3) of the Rules.67  The written statement must be mailed to the Office of the 
Secretary, Federal Communications Commission, 445 12th Street, SW, Washington, DC 20554, ATTN:  
Enforcement Bureau – Investigations & Hearings Division, and must include the NAL/Account Number 
referenced in the caption.  The statement must also be e-mailed to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, 
and Mindy Littell at Mindy.Littell@fcc.gov. 
29. 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; 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. 
30. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability for 
Forfeiture and Admonishment shall be sent by first class mail and certified mail, return receipt requested, 
to Steve Augustino, Esq., Counsel to WDT World Discount Telecommunications, Inc., Kelley Drye & 
Warren LLP, Washington Harbour, Suite 400, 3050 K Street, NW, Washington, D.C. 20007. 
 
      FEDERAL COMMUNICATIONS COMMISSION 
 
 
 
 
Travis LeBlanc  
Chief 
Enforcement Bureau 
 
                                                     
66 See 47 CFR § 1.1914. 
67 47 CFR §§ 1.16, 1.80(f)(3).