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Federal Communications Commission DA 16-242
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Cellco Partnership, d/b/a Verizon Wireless
)
)
)
)
)
File No.:  EB-TCD-14-00017601
Acct. No.:  201632170005
FRN:  0003735230
ORDER
Adopted:  March 7, 2016 Released:  March 7, 2016
By the Chief, Enforcement Bureau:
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission has 
entered into a Consent Decree to resolve its investigation into whether Cellco Partnership, d/b/a Verizon 
Wireless (Verizon Wireless or Company) failed to disclose to consumers that it was inserting Unique 
Identifier Headers (UIDH) into consumers’ Internet traffic over its wireless network.  Verizon Wireless’s 
targeted advertising programs (Verizon Selects and Relevant Mobile Advertising (RMA)) associate 
UIDH with Verizon Wireless customer proprietary information as well as other customer demographic 
and interest information to create profiles in order to serve targeted advertisements.    
2. In December 2014, the Bureau began an investigation into Verizon Wireless after news 
stories raised privacy concerns with its use of UIDH and the Commission received related consumer 
complaints.  The investigation sought to determine Verizon Wireless’s compliance with Section 222 of 
the Communications Act of 1934, as amended (Act)
1
, and Section 8.3 of the Commission’s rules (Open 
Internet Transparency Rule).
2
3. Section 222 of the Act imposes a duty on carriers to protect their customers’ proprietary 
information and use such information only for authorized purposes.
3
  It also expressly prohibits carriers 
that obtain proprietary information from other carriers for the provision of telecommunications services to 
use such information for any other purpose.
4
  The Commission’s Open Internet Transparency Rule 
requires every fixed and mobile broadband Internet access service provider to “publicly disclose accurate 
information regarding the network management practices, performance, and commercial terms of its 
broadband Internet access services sufficient for consumers to make informed choices regarding use of 
such services and for content, application, service, and device providers to develop, market, and maintain 
Internet offerings.”
5
  
4. The Bureau’s investigation found that although Verizon Wireless began inserting UIDH 
into consumers’ Internet traffic as early as December 2012, the Company did not disclose this practice 
until October 2014.  It was not until March 2015—over two years later—that Verizon Wireless updated 
                                                          
1
47 U.S.C. § 222.
2
47 CFR § 8.3.
3
See 47 U.S.C. § 222.
4
Id. at § 222(b).
5
47 CFR § 8.3; FCC Enforcement Advisory; Open Internet Transparency Rule; Broadband Providers Must 
Disclose Accurate Information to Protect Consumers, Public Notice, 29 FCC Rcd 8606 (EB 2014).
Federal Communications Commission DA 16-242
2
its privacy policy to include information about UIDH.  The Bureau’s investigation also found that at least 
one of Verizon Wireless’s advertising partners used UIDH for unauthorized purposes to circumvent 
consumers’ privacy choices by restoring deleted cookies.  In addition, the Bureau’s investigation found 
that Verizon Wireless inserted UIDH into the Internet traffic made from mobile device lines, including 
enterprise, government, and Mobile Virtual Network Operator (MVNO) lines, which were ineligible to 
participate in Verizon Wireless’s targeted advertising programs. 
5. To settle this matter, Verizon Wireless will pay a fine of $1,350,000 and implement a 
compliance plan that requires it to obtain customer opt-in consent prior to sharing a customer’s UIDH 
with a third party to deliver targeted advertising.  With respect to sharing UIDH internally within Verizon 
Communications Inc. and its subsidiaries,
6
it must obtain either opt-in or opt-out consent from its 
customers.  Verizon Wireless will also generate customer UIDH using methods that comply with 
reasonable and accepted security standards.  
6. Verizon Wireless cooperated with the Bureau’s investigation.  During the pendency of 
the Bureau’s investigation, Verizon Wireless updated its customer-facing documents, including its 
privacy policy, to disclose UIDH to consumers and also provided consumers—for the first time—with a 
choice to opt out of UIDH in March 2015.  Given Verizon Wireless’s updates concerning UIDH, the 
compliance plan also requires Verizon Wireless to maintain its current practices of: (1) removing UIDH 
from enterprise, government, and MVNO lines within a reasonable period after activation and in those 
cases not use such UIDH for any purpose; (2) allowing customers who opt in to sharing UIDH to 
subsequently opt out at any time, and (3) disclosing Verizon Wireless practices and use of UIDH in its 
privacy policies and FAQs and update them as appropriate.  
7. In addition, Verizon Wireless will appoint a Compliance Officer that will be responsible 
for ensuring that Verizon Wireless complies with the terms of the Consent Decree.  The Compliance 
Officer or the managers reporting to the Compliance Officer must be privacy certified.  Verizon Wireless 
must report any noncompliance with the terms of the Consent Decree and file regular compliance reports 
during the three-year term of the compliance plan.  If during the pendency of the Compliance Plan, the 
Commission adopts a rule regarding customer opt-in and opt-out consent in connection with the subject 
matter of the Consent Decree, such rule will supersede the related terms of the Consent Decree.
8. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree and terminating the 
referenced investigation regarding Verizon Wireless’s compliance with Section 222 of the Act and 
Section 8.3 of the Commission’s rules.
7
9. In the absence of material new evidence relating to this matter, we do not set for hearing 
the question of Verizon Wireless’s basic qualifications to hold or obtain any Commission license or 
authorization.
8
10. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Act
9
and the 
authority delegated by Sections 0.111 and 0.311 of the Commission’s rules,
10
the attached Consent 
Decree IS ADOPTED and its terms incorporated by reference.
11. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED.
                                                          
6
As defined in paragraph 2(q) of the Consent Decree.
7
47 U.S.C. § 222; 47 CFR 8.3.
8
See 47 CFR § 1.93(b).
9
47 U.S.C. § 154(i).
10
47 CFR §§ 0.111, 0.311.
Federal Communications Commission DA 16-242
3
12. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first class mail and certified mail, return receipt requested, to Tamara Preiss, Vice President, 
Federal Regulatory Affairs, Cellco Partnership, d/b/a Verizon Wireless, 1300 I Street, NW, Washington, 
DC 20005, and to Christopher M. Miller, Vice President and Assistant General Counsel, Federal 
Regulatory Affairs, Cellco Partnership, d/b/a Verizon Wireless, 1300 I Street, NW, Washington, DC 
20005.
FEDERAL COMMUNICATIONS COMMISSION
Travis LeBlanc
Chief
Enforcement Bureau
Federal Communications Commission DA 16-242
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Cellco Partnership, d/b/a Verizon Wireless 
)
)
)
)
)
File No.:  EB-TCD-14-00017601
Acct. No.:  201632170005
FRN:  0003735230
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and Cellco 
Partnership, d/b/a Verizon Wireless (Verizon Wireless), by their authorized representatives, hereby enter 
into this Consent Decree for the purpose of terminating the Enforcement Bureau’s investigation into 
whether Verizon Wireless violated Section 222 of the Communications Act of 1934, as amended,
1
and 
Section 8.3 of the Commission’s rules
2
in connection with its insertion of Unique Identifier Headers 
(UIDH) into consumers’ Hypertext Transfer Protocol (HTTP) requests made over its wireless network.
I. DEFINITIONS
2. For the purposes of this Consent Decree, the following definitions
3
shall apply:
(a) “Act” means the Communications Act of 1934, as amended.
4
(b) “Adopting Order” means an order of the Bureau adopting the terms of this Consent 
Decree, without change, addition, deletion, or modification.
(c) “Commission” and “FCC” mean the Federal Communications Commission and all of 
its bureaus and offices.
(d) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which Verizon Wireless 
is subject by virtue of its business activities.
(e) “Compliance Plan” means the compliance obligations, program, and procedures 
described in this Consent Decree at paragraph 18.
(f) “Effective Date” means the date by which both the Bureau and Verizon Wireless 
have signed the Consent Decree.
(g) “HTTP” means Hypertext Transfer Protocol, an application protocol for distributed, 
collaborative, hypermedia systems.  HTTP is a method of conveying textual or 
multimedia data through the Internet. It defines how messages are formatted and 
transmitted, and what actions Web servers and browsers should take in response to 
various commands.
(h) “Investigation” means the investigation commenced by the Bureau under File No. 
EB-TCD-14-00017601 regarding Verizon Wireless’s compliance with the 
Transparency Rule and Section 222 of the Act.
                                                          
1
47 U.S.C. § 222.
2
47 CFR § 8.3.
3
The Definitions in this Consent Decree do not affect any other Commission order or proceeding.
4
47 U.S.C. § 151 et seq.
Federal Communications Commission DA 16-242
2
(i) “LOI” means the Letter of Inquiry issued by the Bureau to Verizon Wireless on 
December 4, 2014 in connection with the Investigation.
(j) “Operating Procedures” means the standard internal operating procedures and 
compliance policies established by Verizon Wireless to implement the Compliance 
Plan.
(k) “Parties” means Verizon Wireless and the Bureau, each of which is a “Party.”
(l) “Person” shall have the meaning set out in 47 U.S.C. § 153(39).
(m) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
(n) “Third Party” means any Person that is not Verizon.
(o) “Transparency Rule” means Section 8.3 of the Rules, requiring disclosures by 
broadband Internet access service providers of accurate information with respect to 
the network management practices, performance, and commercial terms of their 
broadband Internet access services sufficient for consumers to make informed 
choices regarding such services.
(p) “UIDH” means Unique Identifier Header, a unique character string of letters, 
symbols, and numbers that Verizon Wireless inserts to deliver targeted advertising 
into address header information that accompanies customers’ HTTP requests 
transmitted over the Verizon Wireless network.  For purposes of this Consent Decree, 
UIDH also means similar device-specific identifiers that Verizon Wireless may 
develop to insert into header information transmitted over the Verizon Wireless 
network and used for similar targeted advertising purposes in the future.
(q) “Verizon” means Verizon Communications Inc.; a direct or indirect wholly-owned 
subsidiary of Verizon Communications Inc.; or an entity that is (i) majority-owned 
directly or indirectly by Verizon Communications Inc. and (ii) controlled by Verizon 
Communications Inc., a direct or indirect wholly-owned subsidiary of Verizon 
Communications Inc., or an entity that is majority-owned directly or indirectly by 
Verizon Communications Inc.
(r) “Verizon Wireless,” means Cellco Partnership, d/b/a Verizon Wireless.
II. BACKGROUND
3. Verizon Communications Inc. is a holding company that owns operating subsidiaries that 
provide a range of communications services in the United States and select foreign countries.
5
  Its wholly-
owned subsidiary, Verizon Wireless, provides retail and wholesale wireless voice and data services to 
customers.    
4. Verizon Wireless began testing a targeted advertising service in October 2012 and began 
offering the service to its subscribers in December 2012.
6
  Verizon Wireless operates two advertising 
programs that use the UIDH:  Relevant Mobile Advertising (RMA) and Verizon Selects.
7
  Verizon 
                                                          
5
Verizon Communications, Inc., Form 10Q (filed Jan. 30, 2014), available at
http://eol.edgarexplorer.com/EFX_dll/EdgarPro.dll?FetchFilingHTML1?SessionID=PS9F6Dh7j89S2HD&ID=1026
5052.
6
Letter from Avery Gardiner, Assistant General Counsel, Verizon Legal, to David Valdez, Deputy Chief, 
Telecommunications Consumers Division, FCC Enforcement Bureau, at 15 (Apr. 23, 2015) (on file in EB-TCD-14-
00017601).
7
Id.
Federal Communications Commission DA 16-242
3
Wireless began offering the RMA program in 2012 and Verizon Selects in 2014.  According to Verizon 
Wireless, the difference between the two programs relates to the type of information Verizon Wireless 
uses about its customers to target advertisements.
8
5. Verizon Selects uses a variety of customer information to develop profiles of 
participating customers in order to deliver targeted advertising to those customers.  Verizon Wireless 
asserts that its program Verizon Selects uses the following customer information:  (a) addresses of 
websites visited; (b) device location; (c) apps and device features used; (d) postal and e-mail addresses; 
(e) information about Verizon Wireless products and services usage, including customer proprietary 
network information (CPNI);
9
and (f) demographic and interest information provided by third parties, 
such as gender, age range, and interests (e.g. sports fan, frequent diner, or pet owner).
10
  Since the launch 
of Verizon Selects in 2014, in order for Verizon Wireless subscribers to participate in Verizon Selects, 
subscribers must affirmatively opt into the program through, among other means, their online accounts or 
by following links provided in the Verizon Wireless privacy policy.
11
  
6. According to Verizon Wireless, the RMA program also uses various customer 
information to deliver targeted advertising to customers who participate in RMA.  Verizon Wireless 
asserts that RMA uses the following customer information:  (a) postal and e-mail addresses; (b) certain 
information about Verizon Wireless products and services, such as device type; and (c) demographic and 
interest categories that Verizon Wireless obtains from other companies, such as gender, age range, and 
interests.
12
Customers receive notice of RMA upon activation of service and are given the opportunity to 
opt out, but eligible Verizon Wireless subscribers are otherwise automatically enrolled in the RMA 
program.
13
  Since the launch of RMA in 2012, subscribers may opt-out of RMA through, among other 
means, their online accounts or by following links provided in Verizon Wireless’s privacy policy.
14
                                                          
8
See id. at 1-2.  Verizon Wireless uses certain customer information to identify and deliver ads, along with their ad 
partners, to Verizon Wireless subscribers on their mobile devices. For example, in 2014, 1-800-FLOWERS worked 
with Verizon Wireless to serve Valentine’s Day ads to male Android users, aged 25-44, with household incomes 
higher than $75,000.  See Precision Market Insights Case Study on 1-800-FLOWERS, Precision Market Insights, 
available at http://industryindex.com/uploads/case_studies/a129cc1a168e4fe7d6996ce7c71c818ed27e59f9.pdf (last 
visited Feb. 8, 2016).
9
See 47 U.S.C. § 222(h)(1) (the term ‘‘customer proprietary network information’’ means (a) information that 
relates to the quantity, technical configuration, type, destination, location, and amount of use of a 
telecommunications service subscribed to by any customer of a telecommunications carrier, and that is made 
available to the carrier by the customer solely by virtue of the carrier-customer relationship; and (b) information 
contained in the bills pertaining to telephone exchange service or telephone toll service received by a customer of a 
carrier).  
10
See Verizon Selects FAQs, Verizon Wireless, available at http://www.verizonwireless.com/support/verizon-
selects-faqs/ (last visited Feb. 3, 2016).
11
See Verizon Wireless Privacy Policy, Verizon Wireless webpage, available at 
http://www.verizon.com/about/privacy/policy/ (last visited Mar. 31, 2015); see also Verizon Selects FAQs, Verizon 
Wireless, available at http://www.verizonwireless.com/support/mobile-ads-faqs/ (last visited Feb. 2, 2016).
12
See Relevant Mobile Advertising FAQs, Verizon Wireless, available at
http://www.verizonwireless.com/support/mobile-ads-faqs/ (last visited Feb. 3, 2016).
13
Id.
14
See Verizon Privacy Policy, Verizon Wireless webpage, available at 
http://www.verizon.com/about/privacy/policy/ (last visited Mar. 31, 2015); see also Relevant Mobile Advertising 
FAQs, Verizon Wireless Webpage, available at http://www.verizonwireless.com/support/mobile-ads-faqs/ (last 
visited Feb. 2, 2016).
Federal Communications Commission DA 16-242
4
7. In connection with both the Verizon Selects and RMA programs, Verizon Wireless 
inserts UIDH into the HTTP requests made by eligible mobile wireless subscribers and transmitted over 
the Verizon Wireless network.
15
As early as December 2012, Verizon Wireless began inserting UIDH 
into HTTP Internet traffic transmitted over Verizon Wireless’s network.  
8. In November 2014, several news stories raised privacy concerns with Verizon Wireless’s 
use of UIDH and the Commission received related complaints.
16
  On December 4, 2014, the Bureau 
issued the LOI to Verizon Wireless directing it to provide information regarding the insertion of UIDH 
into consumers’ HTTP requests made over Verizon Wireless’s network.
17
  Specifically, the Investigation 
sought to determine Verizon Wireless’s compliance with the Open Internet Transparency Rule and 
Section 222 of the Act.  The Transparency Rule requires BIAS providers, including wireless mobile 
broadband providers, to disclose accurate information regarding their mobile broadband Internet access 
services sufficient for consumers to make informed choices regarding such services.
18
  Under Section 222 
of the Act, a telecommunications carrier has a duty to protect its customers’ proprietary information and 
any “telecommunications carrier that receives or obtains proprietary information from another carrier for 
purposes of providing any telecommunications service shall use such information only for such purpose, 
and shall not use such information for its own marketing efforts.”
19
  Verizon Wireless submitted an initial 
response to the LOI on January 13, 2015,
20
provided supplemental responses and other submissions, and 
engaged in several discussions with the Bureau related to the Investigation.   
9. Although Verizon Wireless began inserting UIDH into subscribers’ HTTP Internet traffic 
as early as December 2012, and described its advertising programs in its privacy policy and elsewhere, 
Verizon Wireless did not specifically disclose the presence of UIDH and its uses until October 2014.
21
  At 
                                                          
15
See Letter from Avery Gardiner, Assistant General Counsel, Verizon Legal, to Richard A. Hindman, Chief, 
Telecommunications Consumers Division, FCC Enforcement Bureau at 4, 6-7 (Jan. 13, 2015) (Verizon Jan. 13
th
Initial LOI Response) (on file in EB-TCD-14-00017601).  Most Verizon Wireless consumer and small business 
accounts are eligible to be included in the RMA program.  Government, enterprise, Mobile Virtual Network 
Operator subscribers’ lines are not eligible.  A Mobile Virtual Network Operator is a wireless communications 
provider that does not own the wireless network infrastructure over which it provides services to its subscribers.
16
See Craig Timberg, Verizon, AT&T Track Their Users with ‘Supercookies,’Washington Post, November 3, 2014, 
available at http://www.washingtonpost.com/business/technology/verizon-atandt-tracking-their-users-with-super-
cookies/2014/11/03/7bbbf382-6395-11e4-bb14-4cfea1e742d5_story.html; see also Jacob Hoffman-Andrews, 
Verizon Injecting Perma-Cookies to Track Mobile Customers, By-Passing Privacy Controls, Electronic Frontier 
Foundation, November 3, 2014, available at https://www.eff.org/deeplinks/2014/11/verizon-x-uidh.
17
Letter from Richard A. Hindman, Chief, Telecommunications Consumers Division, FCC Enforcement Bureau, to 
Tamara Preiss, Vice President, Federal Regulatory Affairs, Verizon, and Christopher M. Miller, Vice President & 
Associate General Counsel, Verizon (Dec. 4, 2014) (on file in EB-TCD-14-00017601).
18
See 47 CFR § 8.3; see also FCC Enforcement Advisory; Open Internet Transparency Rule; Broadband Providers 
Must Disclose Accurate Information to Protect Consumers, Public Notice, 29 FCC Rcd 8606 (EB 2014) (BIAS 
providers, such as mobile wireless providers that offer data plans for Internet access for smartphones, are subject to 
Section 8.3 of the Rules).  The events covered by the Investigation occurred prior to the effective date of the
enhancements to the Transparency Rule adopted in the Commission’s 2015 Open Internet Order. See Protecting 
and Promoting the Open Internet, Report and Order on Remand, Declaratory Ruling, and Order, 30 FCC Rcd 5601 
(2015) (2015 Open Internet Order).  
19
See 47 U.S.C. § 222(b).
20
See supra note 15.
21
See Verizon Jan. 13
th
Initial LOI Response at 8, Letter from Avery Gardiner, Assistant General Counsel, Verizon 
Legal, to Richard A. Hindman, Chief, Telecommunications Consumers Division, FCC Enforcement Bureau (May 
18, 2015) (on file in EB-TCD-14-00017601) (Verizon May 18
th
Supplemental LOI Response); see also UIDH 
(continued….)
Federal Communications Commission DA 16-242
5
that time, Verizon Wireless made the disclosure in its UIDH “Frequently Asked Questions” (FAQs) 
section of its website.
22
  In late March 2015, Verizon Wireless updated its privacy policy to include a 
disclosure regarding UIDH.
23
  
10. As part of its original FAQs addressing the UIDH, Verizon Wireless said that “[i]t is 
unlikely that sites and ad entities will attempt to build customer profiles for online advertising or any 
other purpose using the UIDH.”
24
  News reports in January 2015, identified a Verizon Wireless 
advertising partner that, according to those news reports, used UIDH for unauthorized purposes.
25
  
Specifically, according to the news reports, this advertising partner restored its cookie IDs that users 
cleared from their browsers by associating them with Verizon Wireless UIDHs.
26
  In February 2015, 
Verizon Wireless acknowledged those news articles raising concerns about the advertising partner’s use 
of UIDH for purposes outside of Verizon Wireless’s advertising programs in its UIDH FAQs.
27
  It also 
stated that it “will work with other partners to ensure that their use of UIDH is consistent with the 
purposes intended.”
28
11. During the course of the Investigation, Verizon Wireless updated its customer-facing 
documents.  On March 31, 2015, Verizon Wireless updated its privacy policy to specifically disclose the 
presence of UIDH and provided a related opt-out capability for its subscribers.
29
  Further, Verizon 
Wireless updated its UIDH FAQ disclosures to describe, among other things, what UIDH is and how it is 
used, and the UIDH opt-out choices available to subscribers.
30
  Verizon Wireless also updated its RMA 
and Verizon Selects FAQs to describe what customer information is used and for what purposes, choices 
(Continued from previous page)                                                            
FAQs, Verizon Wireless, available at http://www.verizonwireless.com/support/unique-identifier-header-faqs/ (last 
visited Jan. 16, 2015).
22
See Verizon May 18
th
Supplemental LOI Response; see also UIDH FAQs, Verizon Wireless, available at 
http://www.verizonwireless.com/support/unique-identifier-header-faqs/ (last visited Jan. 16, 2015).  Verizon 
Wireless subscribers can access links to the related FAQs located in Verizon Wireless’s Privacy Policy.
23
See Verizon Privacy Policy, Verizon Wireless, available at http://www.verizon.com/about/privacy/policy/ (last 
visited Mar. 31, 2015).
24
See UIDH FAQs, Verizon Wireless, available at http://www.verizonwireless.com/support/unique-identifier-
header-faqs/ (last visited Jan. 16, 2015). 
25
See Julia Angwin and Mike Tigas, Zombie Cookie: The Tracking Cookie That You Can’t Kill, Propublica, January 
14, 2015, available at https://www.propublica.org/article/zombie-cookie-the-tracking-cookie-that-you-cant-kill; see
also UIDH FAQs, Verizon Wireless, available at http;//www.verizonwireless.com/support/unique-identifier-header-
faqs/ (last visited Feb. 1, 2015); Letter from Avery Gardiner, Assistant General Counsel, Verizon Legal, to Richard 
A. Hindman, Chief, Telecommunications Consumers Division, FCC Enforcement Bureau, at 4 (Feb. 12, 2015) (on 
file in EB-TCD-14-00017601).
26
See Zombie Cookie ID to be Suspended Pending Re-evaluation, Turn, Inc., available at
http://www.turn.com/blog/zombie-cookie-id-to-be-suspended-pending-re-evaluation (last visited on Feb. 1, 2015).
27
See UIDH FAQs, Verizon Wireless, available at http;//www.verizonwireless.com/support/unique-identifier-
header-faqs/ (last visited Feb. 1, 2015).
28
See id.
29
See Verizon Wireless Privacy Policy, Verizon Wireless, available at
http://www.verizon.com/about/privacy/policy/ (last visited Mar. 31, 2015); see also UIDH FAQs, Verizon Wireless, 
available at http://www.verizonwireless.com/support/unique-identifier-header-faqs/ (last visited Apr. 6, 2015).  
30
See UIDH FAQs, Verizon Wireless, available at http://www.verizonwireless.com/support/unique-identifier-
header-faqs/ (last visited Feb. 2, 2016). 
Federal Communications Commission DA 16-242
6
customers can make about the use of their data, and who has access to customer data.
31
  On March 31, 
2015, Verizon Wireless modified its systems to stop inserting the UIDH after a customer opts out of the 
RMA program unless that customer has chosen to participate in Verizon Selects.  In addition, following 
Verizon’s acquisition of AOL,
32
Verizon announced a combination of the Verizon Wireless and AOL 
advertising programs and committed to transmit UIDH only to entities that are on a pre-approved “white 
list.”
33
12. The Parties negotiated the following terms and conditions of settlement and hereby enter 
into this Consent Decree as provided below. 
III. TERMS OF AGREEMENT
13. Adopting Order.  The provisions of this Consent Decree shall be incorporated by the 
Bureau in an Adopting Order.  This Consent Decree specifically addresses UIDH as it relates to Verizon 
Wireless’s advertising programs.  This Consent Decree does not impose obligations on Verizon Selects or 
other Verizon Wireless advertising programs that require prior customer opt-in approval.
34
14. Jurisdiction.  For the purposes of this Consent Decree, including any subsequent 
enforcement of its terms, Verizon Wireless agrees that the Bureau has jurisdiction over it and the matters 
contained in this Consent Decree and has the authority to enter into and adopt this Consent Decree.
15. Effective Date; Violations.  The Parties agree that this Consent Decree shall become 
effective on the Effective Date.  As of the Effective Date, the Parties agree that this Consent Decree shall 
have the same force and effect as any other order of the Commission.  
16. Termination of Investigation.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
terminate the Investigation. In consideration for the termination of the Investigation, Verizon Wireless 
agrees to the terms, conditions, and procedures contained herein.  The Bureau further agrees that, in the 
absence of new material evidence, it will not use the facts developed in the Investigation through the 
Effective Date, or the existence of this Consent Decree, to institute any new proceeding, formal or 
informal, or take any action against Verizon Wireless concerning the matters that were the subject of the 
Investigation.  The Bureau also agrees that, in the absence of new material evidence, it will not use the 
facts developed in the Investigation through the Effective Date, or the existence of this Consent Decree, to 
institute any proceeding, formal or informal, or to set for hearing the question of Verizon Wireless’s basic 
qualifications to be a Commission licensee or hold Commission licenses or authorizations.
35
                                                          
31
See Relevant Mobile Advertising FAQs, Verizon Wireless, available at 
http://www.verizonwireless.com/support/mobile-ads-faqs/ (last visited Feb. 2, 2016); see also Verizon Selects 
FAQs, Verizon Wireless, available at http://www.verizonwireless.com/support/mobile-ads-faqs/ (last visited Feb. 2, 
2016).
32
On June 23, 2015, Verizon announced it had closed its acquisition of AOL.  See Tom DiChristopher, Verizon 
Closes AOL Acquisition, CNBC, June 23, 2015, available at http://www.cnbc.com/2015/06/23/verizon-closes-aol-
acquisition.html. AOL is an American multinational mass media corporation that develops, grows, and invests in 
brands and websites such as The Huffington Post, TechCrunch, and Engadget. The company's business 
spans digital distribution of content, products, and services, which it offers to consumers, publishers, and advertisers.  
See AOL, Inc., Wikipedia, available at https://en.wikipedia.org/wiki/AOL (last visited Feb. 8, 2016).
33
See Karen Zacharia, What Verizon Privacy Updates Really Mean, Verizon Wireless, Oct. 7, 2015, available at
http://www.verizon.com/about/news/what-verizons-privacy-updates-really-mean.  A white list is a list of people or 
organizations that have been approved to receive special consideration or privileges.  SeeWhite List, The Free 
Dictionary, available at http://www.thefreedictionary.com/whitelist (last visited Feb. 11, 2016).
34
See 47 U.S.C. 222(c)(1).
35
See 47 CFR 1.93(b).
Federal Communications Commission DA 16-242
7
17. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, Verizon 
Wireless shall designate a senior corporate manager with the requisite corporate and organizational 
authority to serve as a Compliance Officer and to discharge the duties set forth below.  The person 
designated as the Compliance Officer shall be responsible for developing, implementing, and 
administering the Compliance Plan and ensuring that Verizon Wireless complies with the terms and 
conditions of the Compliance Plan and this Consent Decree.  In addition to the general knowledge of the 
Communications Laws necessary to discharge his or her duties under this Consent Decree, the 
Compliance Officer shall have specific knowledge or rely on other individuals with specific knowledge of 
the information security principles and practices necessary to implement the information security 
requirements of this Consent Decree, Section 222 of the Act, and the Transparency Rule, before assuming 
his/her duties.  The Compliance Officer or managers reporting to the Compliance Officer with 
responsibilities related to this Consent Decree shall be privacy certified by an industry certifying 
organization and keep current through appropriate continuing privacy education courses.
18. Compliance Plan.  For purposes of settling the matters set forth herein, Verizon Wireless 
agrees that it shall implement the following procedures:
(a) Opt-In.  Verizon Wireless will not share the UIDH of a customer with a Third Party 
to deliver targeted advertising unless Verizon Wireless obtains prior opt-in consent 
from that customer.  Opt-in consent to participate in the Verizon Selects program 
satisfies this requirement.
(b) Security.  Verizon Wireless shall generate the UIDH of a customer using methods 
that comply with reasonable and accepted security standards.  
(c) Other Restrictions.  Verizon Wireless shall maintain its current practice of (1) 
removing the UIDH from an ineligible line within a reasonable period after activation 
and not use these UIDHs for any purpose;
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(2) allowing customers eligible to 
participate in the RMA program to opt out of having UIDH inserted in their HTTP 
traffic; (3) allowing customers who opt in pursuant to subsection 18(a) to 
subsequently opt out at any time, and (4) disclosing Verizon Wireless practices and 
use of the UIDH in its privacy policies and FAQs and update such disclosures as 
appropriate.
(d) Operating Procedures.  Within sixty (60) calendar days of the Effective Date 
Verizon Wireless shall establish Operating Procedures designed to ensure its 
compliance with subparagraphs (a) and (c) of this section.  In the Operating 
Procedures, Verizon Wireless shall ensure that if another Verizon entity receives the 
UIDH from Verizon, that Verizon entity will not share it in a way that Verizon 
Wireless would be prohibited from doing directly under the terms of this Consent 
Decree.  The Operating Procedures also will reflect that Verizon is permitted to share 
the UIDH among Verizon entities with either opt-out or opt-in customer consent.  
19. Reporting Noncompliance.  Verizon Wireless shall report any noncompliance with 
Section 222(b) of the Act, the Transparency Rule, and with the terms and conditions of this Consent 
Decree that is more than an anomaly within fifteen (15) calendar days after discovery of such 
noncompliance.  Such reports shall include a detailed explanation of: (i) each instance of noncompliance 
that is more than an anomaly; (ii) the steps that Verizon Wireless has taken or will take to remedy such 
                                                          
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Ineligible lines are comprised of government, enterprise, and Mobile Virtual Network Operator lines.  If there are 
any temporary uses of the UIDH following activation of these lines, Verizon Wireless shall eliminate them within 
60 days from the Effective Date. If in the future Verizon Wireless desires to include these lines in its programs that 
use the UIDH, it shall ensure these customers have the same options provided for in this Consent Decree, including 
the ability to opt in and to opt out.
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noncompliance; (iii) the schedule on which such remedial actions will be taken; and (iv) the steps that 
Verizon Wireless has taken or will take to prevent the recurrence of any such noncompliance.  All reports 
of noncompliance that is more than an anomaly shall be submitted to the Chief, Telecommunications 
Consumers Division, Enforcement Bureau, Federal Communications Commission, 445 12th Street, SW, 
Rm. 4C-224, Washington, DC 20554, with a copy submitted electronically to David.Valdez@fcc.gov, 
Kimbarly.Taylor@fcc.gov, and Melanie.Tiano@fcc.gov.
20. Compliance Reports. Verizon Wireless shall submit Compliance Reports with the 
Commission ninety (90) calendar days, twelve (12) months, twenty-four (24) months, and thirty-six (36) 
months after the Effective Date.
(a) Each Compliance Report shall include a detailed description of Verizon Wireless’s 
efforts during the relevant period to comply with Section 222 (b) of the Act, the 
Transparency Rule, and the terms and conditions of this Consent Decree.
(b) Each Compliance Report shall include a certification by the Compliance Officer, as 
an agent of and on behalf of Verizon Wireless, stating that the Compliance Officer 
has personal knowledge that Verizon Wireless: (i) has established and implemented 
the Compliance Plan; (ii) has utilized the Operating Procedures since the 
implementation of the Compliance Plan; and (iii) is not aware of any instances of 
noncompliance that is more than an anomaly with the terms and conditions of this 
Consent Decree, including the reporting obligations set forth in paragraph 19 of this 
Consent Decree.
(c) The Compliance Officer’s certification shall be accompanied by a statement 
explaining the basis for such certification and must comply with Section 1.16 of the 
Rules and be subscribed to as true under penalty of perjury in substantially the form 
set forth therein.
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(d) If the Compliance Officer cannot provide the requisite certification, the Compliance 
Officer, as an agent of and on behalf of Verizon Wireless, shall provide the 
Commission with a detailed explanation of the reason(s) why and describe fully: (i) 
each instance of noncompliance that is more than an anomaly; (ii) the steps that 
Verizon Wireless has taken or will take to remedy such noncompliance, including the 
schedule on which the proposed remedial actions will be taken; and (iii) the steps that 
Verizon Wireless has taken or will take to prevent the recurrence of any such 
noncompliance, including the schedule on which such preventive action will be 
taken.
(e) All Compliance Reports shall be submitted to the Chief, Telecommunications 
Consumers Division, Enforcement Bureau, Federal Communications Commission, 
445 12th Street, SW, Rm. 4C-224, Washington, DC 20554, with a copy submitted 
electronically to David.Valdez@fcc.gov, Kimbarly.Taylor@fcc.gov, and 
Melanie.Tiano@fcc.gov.
21. Termination Date. Unless stated otherwise, the requirements set forth in paragraphs 17 
through 20 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.  
22. Section 208 Complaints; Subsequent Investigations.  Nothing in this Consent Decree 
shall prevent the Commission or its delegated authority from adjudicating complaints filed pursuant to 
Section 208 of the Act
38
against Verizon Wireless or its affiliates for alleged violations of the Act, or for 
                                                          
37
47 CFR § 1.16.
38
47 U.S.C. § 208.
Federal Communications Commission DA 16-242
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any other type of alleged misconduct, regardless of when such misconduct took place.  The Commission’s 
adjudication of any such complaint will be based solely on the record developed in that proceeding.  
Except as expressly provided in this Consent Decree, this Consent Decree shall not prevent the 
Commission from investigating new evidence of noncompliance by Verizon Wireless with the 
Communications Laws.
23. Settlement Amount.  Verizon Wireless will pay a fine to the United States Treasury in 
the amount of one million, three hundred fifty thousand dollars ($1,350,000) within thirty (30) calendar 
days of the Effective Date.  Verizon Wireless shall send electronic notification of payment to 
Johnny.Drake@fcc.gov on the date said payment is made.  The payment must be made by check or 
similar instrument, wire transfer, or credit card, and must include the Account Number and FRN 
referenced above.  Regardless of the form of payment, a completed FCC Form 159 (Remittance Advice) 
must be submitted.
39
  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-
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.
Questions regarding payment procedures should be addressed to the Financial Operations Group Help 
Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.
24. Waivers.  As of the Effective Date, Verizon Wireless waives any and all rights it may 
have to seek administrative or judicial reconsideration, review, appeal or stay, or to otherwise challenge 
or contest the validity of this Consent Decree and the Adopting Order.  Verizon Wireless shall retain the 
right to challenge Commission interpretation of the Consent Decree or any terms contained herein.  If 
either Party (or the United States on behalf of the Commission) brings a judicial action to enforce the 
terms of the Consent Decree or the Adopting Order, neither Verizon Wireless nor the Commission shall 
contest the validity of the Consent Decree or the Adopting Order, and Verizon Wireless shall waive any 
statutory right to a trial de novo.  Verizon Wireless hereby agrees to waive any claims it may otherwise 
have under the Equal Access to Justice Act
40
relating to the matters addressed in this Consent Decree.
25. Severability.  The Parties agree that if any of the provisions of the Consent Decree shall 
be held unenforceable by any court of competent jurisdiction, such unenforceability shall not render 
                                                          
39
An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/forms#159.pdf.
40
See 5 U.S.C. § 504; 47 CFR §§ 1.1501–1.1530.
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unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not 
containing the particular unenforceable provision or provisions, and the rights and obligations of the 
Parties shall be construed and enforced accordingly.
26. Invalidity.  In the event that this Consent Decree in its entirety is rendered invalid by any 
court of competent jurisdiction, it shall become null and void and may not be used in any manner in any 
legal proceeding.
27. Subsequent Rule or Order.  The Parties agree that if any provision of the Consent 
Decree is more or less restrictive than any subsequent Rule or order adopted by the Commission (except 
an order specifically intended to revise the terms of this Consent Decree to which Verizon Wireless does 
not expressly consent) regarding the same subject matter, including any subsequent Rule or order with 
respect to opt-in or opt-out, that provision will be superseded by such Rule or order.  
28. Successors and Assigns.  Verizon Wireless agrees that the provisions of this Consent 
Decree shall be binding on its successors, assigns, and transferees.
29. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.  The Parties further 
agree that this Consent Decree does not constitute either an adjudication on the merits or a factual or legal 
finding regarding any compliance or noncompliance with the requirements of the Communications 
Laws.  
30. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
31. Paragraph Headings.  The headings of the paragraphs in this Consent Decree are 
inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent 
Decree.
32. Authorized Representative.  Each Party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.  Each person signing this Consent Decree on 
behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this Consent 
Decree and to bind the Party to its terms and conditions.
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33. Counterparts.  This Consent Decree may be signed in counterpart (including 
electronically or by facsimile).  Each counterpart, when executed and delivered, shall be an original, and 
all of the counterparts together shall constitute one and the same fully executed instrument.
________________________________
Travis LeBlanc
Chief
Enforcement Bureau
________________________________
Date
________________________________
Chris Miller
Vice President & Associate General Counsel
Cellco Partnership d/b/a Verizon Wireless 
________________________________
Date