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 Federal Communications Commission FCC 16-122 
 
 
Before the 
Federal Communications Commission 
Washington, DC 20554 
 
In the Matter of 
 
Central Telecom Long Distance, Inc. 
 
 
) 
) 
) 
) 
) 
File No.:  EB-TCD-13-00011651 
 
NAL/Acct. No.:  201432170008 
 
FRN: 0017288341 
 
FORFEITURE ORDER 
 
Adopted:  September 14, 2016 Released:  September 15, 2016 
 
By the Commission:  Commissioner O’Rielly concurring in part and dissenting in part. 
 
I. INTRODUCTION 
1. We impose a penalty of $3,460,000 against Central Telecom Long Distance, Inc. (Central 
or Company) for improperly changing the preferred long distance carriers of consumers, a practice 
commonly known as “slamming,” and charging consumers directly or through their local telephone 
companies for long distance service that they had never authorized, a practice commonly referred to as 
“cramming.”  Central also deceptively marketed its services to consumers as part of its slamming and 
cramming scheme.  In addition, where Central billed consumers directly, it failed to clearly and plainly 
describe the charges, in violation of the Commission’s truth-in-billing rules.  Slamming and cramming are 
deceptive business practices that result in consumers paying for services they never requested and then 
expending great time and personal effort to return to their preferred carriers.  These practices are made 
even more egregious where, as here, they are coupled with deceptive marketing.  After reviewing 
Central’s response to the Notice of Apparent Liability for Forfeiture (NAL), we reduce the penalty 
proposed in the NAL and assess a $3,460,000 forfeiture.   
II. BACKGROUND 
2. The Enforcement Bureau (Bureau) of the Federal Communications Commission (FCC or 
Commission) initiated an investigation of Central1 after reviewing over one hundred consumer complaints 
filed against the Company.  As discussed in more detail in the NAL,2 many of the consumers who filed 
complaints contended that Central misrepresented that the Company was (or was affiliated with) the 
complainant’s existing long distance carrier and that the purpose of the Company’s marketing call was 
merely to obtain the complainant’s authorization to change the current service plan with his or her 
existing carrier—not to switch carriers.3  According to the complainants, after obtaining and recording 
their “authorization,” Central then attempted to switch their long distance carrier to Central.4  In some 
cases, Central successfully effected the carrier change and in other cases Central did not because, for 
                                                     
1 Central, located at 102 S. Tejon Street, Suite 1100, Colorado Springs, CO 80903, is a non-facilities-based 
interexchange carrier. 
2 Central Telecom Long Distance, Inc., Notice of Apparent Liability for Forfeiture, 29 FCC Rcd 5517 (2014) (NAL).  
The NAL contains a more complete discussion of the facts and history of this case and is incorporated herein by 
reference.  See NAL, 29 FCC Rcd at 5517–5527, paras. 2–21.  The Appendix to the NAL contains a list of 
complaints, including the complainant’s name, date of carrier change or billing date, and violation.  Id. at 5535-36. 
3 Id. at 5518, para. 3. 
4 Id.  
 Federal Communications Commission FCC 16-122 
 
 2 
example, a consumer had taken the initiative through a “PIC freeze” to block unauthorized carrier 
changes.5  In both types of cases, Central charged the complainants for long distance services.  The 
charges were billed directly to complainants or were placed on the complainants’ local exchange carrier 
(LEC)6 bill.7  For example, Complainant Bingham explained that after her grandmother (who did not use 
long distance service) died and Ms. Bingham had her telephone disconnected, Central continued to send 
bills for its “service” several months after the telephone was disconnected.8  Complainants alleged that 
they did not authorize Central’s service and that they had no need to pay Central for the same service that 
they had with another carrier.  The NAL ordered Central to, within 30 days, either pay the proposed 
forfeiture amount or submit evidence or arguments in response to the NAL that no forfeiture should be 
imposed or that some lesser amount should be assessed.  Central filed a response to the NAL on June 17, 
2014.9 
3. The slamming and cramming scheme in this case is very similar to that in two other 
recent cases: Consumer Telcom, Inc. (CTI),10 and U.S. Telecom Long Distance, Inc. (USTLD);11 all three 
companies are operated by a fourth company, the “hub” of the operation, Data Integration Systems, Inc. 
(DIS) that handles the day-to-day operations of the three companies.12  All three companies—USTLD, 
CTI, and Central—are managed from DIS’s offices at 17832 Gillette Ave., Irvine, CA 92416.13  DIS, 
whose sole owner, officer, and director is Craig Konrad (Konrad),14 provides billing, training, customer 
service, and other data management and retrieval services for Central15 as well as CTI and USTLD.16  
According to Konrad, DIS would provide services pursuant to the contract with Central, including:   
                                                     
5 Id.  A preferred or presubscribed interexchange carrier (PIC) freeze “prevents a change in a subscriber’s preferred 
carrier selection unless the subscriber gives the carrier from whom the freeze was requested his or her express 
consent.”  See 47 CFR § 64.1190(a).   
6 E.g., AT&T, Verizon, or CenturyLink.  “The term ‘local exchange carrier’ means any person that is engaged in the 
provision of telephone exchange service or exchange access. Such term does not include a person insofar as such 
person is engaged in the provision of a commercial mobile service under section 332 (c) of this title, except to the 
extent that the Commission finds that such service should be included in the definition of such term.”  47 U.S.C. § 
153(32).    
7 NAL, 29 FCC Rcd at 5518, para. 3.    
8 Complaint from S. Bingham. 
9 See Central Telecom Long Distance, Inc.’s Response to Notice of Apparent Liability for Forfeiture (June 17, 2014) 
(NAL Response) (on file in EB-TCD-13-00011651).  Konrad provided the substantive information in the NAL 
Response regarding Central’s operations.  See NAL Response, Exhibit 2, Affidavit of Craig Konrad. 
10 Consumer Telcom, Inc., Notice of Apparent Liability for Forfeiture, 28 FCC Rcd 17196 (2013) (CTI NAL). 
11 U.S. Telecom Long Distance, Inc., Notice of Apparent Liability for Forfeiture, 29 FCC Rcd 823 (2014) (USTLD 
NAL). 
12 NAL, 29 FCC Rcd at 5517-18, para. 2. 
13 Konrad provided a “declaration under penalty of perjury” to the Bureau’s letter of inquiry (LOI), stating that “[a]ll 
of the information requested by the Letter of Inquiry that is locatable and in CTLD’s possession, custody, control or 
knowledge has been produced.” In addition, Konrad provided the substantive responses to the LOI, and stated that 
“CTLD’s responses to the questions directed to CTLD . . . which DIS assisted CTLD in preparing its responses, are 
true and correct to the best of my personal knowledge and belief.”  See “Responses of Central Telecom Long 
Distance, Inc. to Letter of Inquiry, Dated October 17, 2013, Issued by the Enforcement Bureau of the Federal 
Communications Commission” (Dec. 2, 2013) (on file in EB-TCD-13-00011651). 
14 According to the 2015 FCC Form 499-A, filed Mar. 17, 2015, Konrad is also the chief executive officer of the toll 
reseller, Business Discount Plan, Inc.      
15 See NAL Response at Exhibit 2, Affidavit of Craig Konrad.  
16 NAL, 29 FCC Rcd at 5517, para. 2 
 Federal Communications Commission FCC 16-122 
 
 3 
collecting and managing data needed for billing and collect[ion] services; interfacing with billing 
aggregators, interexchange carriers and local exchange carriers; training telemarketers; providing 
software and software services; managing databases; reviewing services and other non-service 
contracts; and overseeing regulatory matters.”17 
4. With respect to marketing, “CTLD, through its agent DIS, trains and instructs its sales 
representatives”18 and “also has a quality assurance monitoring program in which it, through its agent 
DIS, regularly listens in on the sales representative’s calls.”19  According to the Konrad affidavit, DIS 
provides the “telemarketers with CTLD’s training materials.”20  After the third party verifier process, DIS 
“uses [the name and address of new customers] to prepare address labels.”21  DIS provides these address 
labels to its subcontractor, National Customer Service Center (NCSC), “who then affixes these address 
labels to envelopes.  DIS pays for the postage that is loaded into a postage meter, and NCSC will then 
mail the customer various promotional materials.  If the documents are undeliverable, “DIS will then 
double check the customer’s name and address and correct the address label, if necessary, and re-mail the 
envelope.”22  According to Konrad, NCSC prepares all of the responses to the consumer complaints.23   
5. The three companies, USTLD, CTI, and Central, have different owners, although the 
owner of CTI, Joseph Nicotra, was previously an officer of USTLD;24 however, they are all operated by 
DIS.  Konrad, the owner of DIS, is also the president of another toll reseller, Business Discount Plan, 
Inc.25  This system of using multiple companies, all run by one person or company, is used to dilute the 
number of complaints against each specific reseller and to make it more difficult for regulatory and law 
enforcement agencies to know how much cramming (or slamming) is occurring.26 
6. On May 5, 2014, the Commission released the NAL proposing a $3,960,000 forfeiture 
against Central for its apparently willful and repeated violations of Sections 201(b) and 258 of the 
Communications Act of 1934, as amended (Communications Act or Act),27 and Sections 64.1120 and 
64.2401(b) of the Commission’s rules (Rules).28  The NAL found that the Company apparently violated 
Section 258 of the Act and Section 64.1120 of the Rules by changing the preferred carriers of three 
consumers without authorization (slams), and Section 201(b) of the Act by assessing 28 unauthorized 
charges (crams) on bills to consumers.  In addition, Central apparently further violated Section 201(b) by 
                                                     
17 NAL Response at Exhibit 2, Affidavit of Craig Konrad at 1. 
18 Id. at 7. 
19 Id. at 8. 
20 Id. 
21 Id. at 11. 
22 Id. at 12.  
23 Id. at 19-20. 
24 Id. at Exhibit 5, p. 216. 
25 See NAL, 29 FCC Rcd at 5518 & n.5.  Konrad is the President of toll reseller Business Discount Plan, Inc., a 
company the Commission had investigated for slamming and misrepresentation when he was the Vice President of 
that company.  See Bus. Disc. Plan, Inc., Notice of Apparent Liability for Forfeiture, 14 FCC Rcd 340 (1998) (BDP 
NAL), Order of Forfeiture, 15 FCC Rcd 14461 (2000) (BDP Forfeiture Order). 
26 See United States Senate Committee on Commerce, Science, and Transportation, Office of Oversight and 
Investigations, “Unauthorized Charges on Telephone Bills,” Staff Report for Chairman Rockefeller, July 12, 2011 
(Senate Report) at pp. 9-10, available at http://apps.fcc.gov/ecfs/document/view?id=7021859847. 
27 47 U.S.C. §§ 201(b), 258. 
28 47 CFR §§ 64.1120, 64.2401(b). 
 Federal Communications Commission FCC 16-122 
 
 4 
engaging in seven instances of misrepresentation, and apparently violated Section 64.2401(b) of the Rules 
by committing four truth-in-billing violations when sending bills directly to consumers.   
7. Central makes a number of arguments in its NAL Response as to why the NAL should be 
canceled or reduced.  The Company contends that: (i) it did not slam consumers because it complied with 
the Commission’s verification rules for carrier changes; (ii) it did not cram consumers because the 
recurring charges it assessed were for “bundled services” authorized by consumers; (iii) it did not 
deceptively market its services because it has implemented telemarketer training and other safeguards; 
(iv) the Commission’s reliance on unsworn consumer complaints was unreasonable and denied the 
Company due process; (v) it did not violate the Commission’s truth-in-billing rules because the Company 
was billing consumers for a previous unpaid bill; and (vi) the NAL upward adjustments of the proposed 
forfeiture amount were arbitrary and capricious.29  As we discuss below, we reject each of Central’s 
arguments.  However, we reduce the penalty proposed in the NAL and assess a forfeiture amount of 
$3,460,000.     
III. DISCUSSION 
8. The Commission proposed a forfeiture in this case in accordance with Section 503(b) of 
the Act,30 Section 1.80 of the Rules,31 and the Commission’s Forfeiture Policy Statement.32  When we 
assess forfeitures, Section 503(b)(2)(E) requires that we take into account 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.”33  As discussed below, we 
have fully considered Central’s response to the NAL, but we do not find its arguments persuasive.  Based 
on the preponderance of the evidence in the record, we assess a $3,460,000 forfeiture. 
A. Central Slammed Consumers in Violation of Section 258 of the Act and Section 
64.1120 of the Rules 
9. Section 258 of the Act makes it unlawful for any telecommunications carrier to “submit 
or execute a change in a subscriber’s selection of a provider of telephone exchange service or telephone 
toll service except in accordance with such verification procedures as the Commission shall prescribe.”34  
Section 64.1120 of the Commission’s rules prohibits carriers from submitting a request to change a 
consumer’s preferred provider of telecommunications services before verifying authorization from the 
consumer; carriers can verify that authorization in one of three specified ways, including “Third Party 
Verification” (TPV).35  If a carrier relies on a TPV,36 the verifier must be independent of the carrier and, 
among other things, must confirm that the consumer with whom the verifier is speaking: (i) has the 
authority to change the carrier associated with the telephone number in question; (ii) in fact wishes to 
                                                     
29 In addition, the Company submitted three years of federal tax returns to support its claim that it was not able to 
pay the proposed forfeiture.   
30 47 U.S.C. § 503(b). 
31 47 CFR § 1.80. 
32 The Commission’s Forfeiture Policy Statement and Amendment of Section 1.80 of the Rules to Incorporate the 
Forfeiture Guidelines, Report and Order, 12 FCC Rcd 17087 (1997) (Forfeiture Policy Statement), reconsideration 
denied, Memorandum Opinion and Order, 15 FCC Rcd 303 (1999).  
33 47 U.S.C. § 503(b)(2)(E). 
34 Id. § 258(a).      
35 47 CFR § 64.1120(c)(1)–(3). 
36 TPV is one method a carrier may use to verify and record a consumer’s authorization to change his or her 
preferred long distance carrier.  TPV must comply with Section 64.1120(c)(3) of the Commission’s rules.  47 CFR § 
64.1120(c)(3).     
 Federal Communications Commission FCC 16-122 
 
 5 
change carriers; and (iii) understands that he or she is authorizing a carrier change.37  The Rules expressly 
prohibit verifiers from misleading consumers while attempting to obtain the required authorization (i.e., 
the rules require, inter alia, that a verifier’s description of the carrier change not be misleading).38  In its 
NAL Response, Central makes a number of arguments in an attempt to avoid its liability, but we find 
none of them persuasive and, based on the preponderance of the evidence in the record, affirm the NAL’s 
finding of violations of Section 258 of the Act and Section 64.1120 of the Rules. 
10. In the NAL we found that Central apparently violated Section 258 of the Act and Section 
64.1120 of the Rules by switching three consumers’ preferred providers of telecommunications services 
without proper authorization verified in accordance with the Rules.39  Specifically, in all three cases the 
third party verifier’s description of the carrier change was misleading in violation of the Rules, and failed 
to confirm that the consumer wished to change carriers and understood that they were authorizing such a 
change.40  As consumers repeatedly described, Central’s telemarketers initially led the consumers to 
believe that they were speaking to their existing carrier and that the purpose of the call was to discuss the 
consumer’s existing service.41  After those misrepresentations were made by Central’s telemarketers, the 
consumer’s call was passed to the third party verifier, who told consumers that “[t]he reason we are 
speaking to you is to confirm the change in long distance service to Central Telecom Long Distance, Inc. 
as your long distance carrier.”42  As we explained in the NAL, simply tacking on the words “as your long 
distance carrier” does not change the fact that the verifier stated that the purpose of the call was to change 
the consumer’s “service,” rather than the carrier providing that service, and that consumers believed their 
service would continue to be through their existing preferred carrier because of the initial 
misrepresentations made by Central’s telemarketers (discussed in greater detail in the NAL and below).43  
The consumers had not agreed to change their carriers and there were no agreements for a carrier change 
to “confirm” with the third party verifier.  It is well established law that changing service is not equivalent 
to changing carriers,44 and Central’s statements suggesting that it was seeking verification only for a 
                                                     
37 Id. § 64.1120(c)(3)(iii). 
38 Id. 
39 NAL, 29 FCC Rcd at 5519–5523, paras. 6–13. 
40 See id. at 5522, paras. 10–11. 
41 Id. at 5520–21, paras. 8–9. 
42 Id. at 5521–22, para. 9. 
43 Id. at 5520–21, paras. 8–9 (citing Implementation of the Subscriber Carrier Selection Changes Provisions of the 
Telecommunications Act of 1996; Policies and Rules Concerning Unauthorized Changes of Consumers’ Long 
Distance Carriers, Fourth Report and Order, 23 FCC Rcd 493, 501, para. 19 (2008) (footnotes omitted) (Slamming 
Fourth Report and Order)). 
44 See, e.g., Consumer Telcom, Inc., Order on Reconsideration, 27 FCC Rcd 5340, 5345, para. 17 (CGB 2012) 
(finding “the verifier’s question, ‘Do you have authority to make changes to your long distance service?’ did not 
confirm that the person was authorizing a change that would result in receiving service from a different carrier”) 
(emphasis in original); Central Telecom Long Distance, Inc., Complaints Regarding Unauthorized Change of 
Subscriber’s Telecommunications Carrier, Order, 28 FCC Rcd 16653 (CGB 2013) (finding “the verifier’s question, 
‘Do you have the authority to make changes to your long distance service?’” did not confirm that the person was 
authorizing a change that would result in receiving service from a different carrier); Central Telecom Long 
Distance, Inc., Complaints Regarding Unauthorized Change of Subscriber’s Telecommunications Carrier, Order, 28 
FCC Rcd 13353 (CGB 2013) (same, for two complaints); Central Telecom Long Distance, Inc., Complaint 
Regarding Unauthorized Change of Subscriber’s Telecommunications Carrier, Order, 28 FCC Rcd 9276 (CGB 
2013) (same); Central Telecom Long Distance, Inc., Complaints Regarding Unauthorized Change of Subscriber’s 
Telecommunications Carrier, Order, 28 FCC Rcd 6537 (CGB 2013) (same, for two complaints); Central Telecom 
Long Distance, Inc., Complaint Regarding Unauthorized Change of Subscriber’s Telecommunications Carrier, 
Order, 28 FCC Rcd 6241 (CGB 2013) (same); Consumer Telcom, Inc., Complaints Regarding Unauthorized 
Change of Subscribers’ Telecommunications Carrier, Order, 25 FCC Rcd 3202 (CGB 2010) (same, two 
(continued….) 
 Federal Communications Commission FCC 16-122 
 
 6 
change in “service” were misleading and in violation of Section 64.1120(c)(3), notwithstanding the 
addition of the phrase “as your long distance carrier” at the end of the sentence.45   
11. Central argues that the Commission should not focus on a single statement by the 
verifier, which it claims was taken “out of context,” and that its TPVs, when reviewed in their entirety 
“did not lead to consumer confusion concerning the true purpose of the solicitation call.”46  According to 
Central, the verifications “confirmed that the person on the call understood that a carrier change, not an 
upgrade to existing service, bill consolidation, or other misleading description of the underlying 
transaction, was being authorized.”47  The evidence shows otherwise.  Notably, after the three consumers 
discovered that their carrier was changed without their authorization they immediately took steps to 
obtain a refund of the Central charges, and file complaints against Central due to the unauthorized carrier 
change and resulting unauthorized charges.48   
12. Further, Central is mistakenly focusing on one small part of the TPV—i.e., the reference 
to a consumer’s “long distance carrier”—to show that the TPV complied with our verification rules.  The 
(Continued from previous page)                                                            
complaints); U.S. Telecom Long Distance, Inc., Complaint Regarding Unauthorized Change of Subscriber’s 
Telecommunications Carrier, Order, 25 FCC Rcd 3135 (CGB 2010) (same). 
45 Central contends that it is “incomprehensible” and “inconceivable” that we find fault with its TPVs because, 
according to Central, there have been numerous CGB orders that reviewed similar language used by Central which 
CGB found did not constitute a slam.  NAL Response at 31.  Central’s contention, however, is based entirely upon 
old CGB orders dating back to 2008.  NAL Response at 17-19.  Central conveniently ignores the subsequent CGB 
orders that supersede that prior precedent.  In these more recent orders CGB specifically found Central violated the 
slamming rules because its TPVs asked consumers about a change in “service” and not a change in “carrier.”  See, 
e.g., supra note 44.  These orders put Central on notice prior to the slams at issue in the NAL that the old CGB 
precedent no longer applied following the Commission’s 2008 rulemaking and that Central needed to change its 
TPVs to bring them into compliance with the slamming rules.  We find no merit in Central’s argument and affirm 
our findings in the NAL.  CGB has released more recent orders with the same conclusion.  See, e.g., U.S. Telecom 
Long Distance, Inc., Complaints Regarding Unauthorized Change of Subscriber’s Telecommunications Carrier, 
Order, 29 FCC Rcd 5805 (CGB 2014) (finding that the statement that the purpose of the recorded conversation was 
“to confirm the change in long distance service to US Telecom Long Distance as your long distance carrier” was in 
violation of FCC carrier change rules); Consumer Telcom, Inc., Complaints Regarding Unauthorized Change of 
Subscriber’s Telecommunications Carrier, Order, 29 FCC Rcd 5800 (CGB 2014) (same, regarding Consumer 
Telcom, Inc.); Central Telecom Long Distance, Inc., Complaints Regarding Unauthorized Change of Subscriber’s 
Telecommunications Carrier, Order, 29 FCC Rcd 5795 (CGB 2014) (same, regarding Central); Central Telecom 
Long Distance, Inc., Complaints Regarding Unauthorized Change of Subscriber’s Telecommunications Carrier, 
Order, 29 FCC Rcd 5790 (CGB 2014) (same); Central Telecom Long Distance, Inc., Complaint Regarding 
Unauthorized Change of Subscriber’s Telecommunications Carrier, Order, 29 FCC Rcd 4839 (CGB 2014) (same).   
46 NAL Response at 30.  Central argues that the TPVs complied with our rules and were not misleading, combining, 
to some extent, the slamming and misrepresentation issues.  
47 Id. 
48 See, e.g., Complaint from C. Moore (she hung up during the TPV, yet there were charges from Central on her next 
AT&T bill and she immediately called to complain and “he said after I paid the charge on billing statement July 19th 
that there would be no more charges from them.  Was not supposed to even be added to my AT&T account.”  The 
following month she had Central charges on the next AT&T bill and she called again to complain.); Complaint from 
L. DeRoin (“I received a bill in the mail from Central Telecom . . .  for long distance service.  I did not authorize this 
company to be my long distance carrier. . . . I tried to call Central Telecom and there is no answer.  I called them 
today and all I get is a voicemail message that they are not available. . . . When you call the number it states thank 
you for calling customer care, please hold on the line.  No one comes on the line.”); Complaint from K.  (Mrs. 
 “called to complain that her long distance service was switched by USBI without her consent.  Mrs.  
claims that a month and a half ago, an individual representing themselves as a CenturyLink employee called her and 
advised her that they could save her money on her long distance. . . . Mrs.  would like the charges to be 
removed from her bill and to be switched back over to CenturyLink.”). 
 Federal Communications Commission FCC 16-122 
 
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evidence shows that prior to the TPV, the Central telemarketer led consumers to believe that the purpose 
of the call was to discuss the existing service, not to change carriers.  Consequently, the vague language 
of the TPV, “confirm the change in long distance service,” did not significantly contradict what the 
Central telemarketer had just said, i.e., that they were discussing a change in their current service (not a 
carrier change), and was misleading and therefore in violation of our verification rules.  As the 
Commission stated in its Slamming Fourth Report and Order, “some carriers introduce ambiguity into 
what should be a straightforward interaction by describing the carrier change offer as a mere ‘upgrade’ to 
existing service or in other ways that obscure the true purpose.”49  Here, the evidence demonstrates that 
Central “obscured the true purpose” of its interactions with consumers for the purpose of switching their 
carriers without their authorization.   
13. Central also argues that instead of looking at the allegations of each complaint, including 
the statements and representations made to consumers prior to the TPV, if the TPV, standing alone, 
complies with our rules, then it “necessarily means that the customers were authorized to make a carrier 
change, wanted to make a carrier change, and understood that they were making a carrier change.”50  
Essentially, the Company’s position is that as long as there is a “valid” TPV, the associated carrier change 
is justified regardless of what a telemarketer may have told the consumer.51  As discussed above, we have 
reviewed the relevant Central TPVs and determined that they do not comply with our verification rules 
and thus, do not prove authorization.  Even if we were to accept Central’s argument (that a valid TPV 
alone proves authorization), it would be of no avail in the instant case.  Central’s TPV argument also fails 
because the misrepresentations told to consumers by Central’s telemarketers alone invalidate the TPVs, 
making the subsequent carrier changes invalid.52  Moreover, a falsified TPV53 could make it appear that a 
complainant had agreed to a carrier change when no such agreement had occurred.54  Accordingly, we 
reject the contention that we should look no further than the TPV in determining whether a particular 
carrier change comports with the Act and our Rules.     
14. For all these reasons, and based upon a preponderance of evidence in the record, we 
affirm the finding in the NAL that Central, in violation of Section 258 of the Act and Section 64.1120 of 
the Commission’s rules, changed the preferred carriers of three consumers without proper authorization 
verified in accordance with the Commission’s rules.    
                                                     
49 Slamming Fourth Report and Order, 23 FCC Rcd at 501, para. 19 (footnotes omitted).  Moreover, the 
Commission has previously stated that third party verifier scripts “should clearly and conspicuously confirm that the 
subscriber has previously authorized a carrier change.”  Id. (citing Implementation of the Subscriber Carrier 
Selection Changes Provisions of the Telecommunications Act of 1996; Policies and Rules Concerning Unauthorized 
Changes of Consumers’ Long Distance Carriers, Second Report and Order and Further Notice of Proposed 
Rulemaking, 14 FCC Rcd 1508, 1553, para. 72 (1998)).   
50 NAL Response at 39.   
51 Id. 
52 See supra para. 10.  See also NAL, 29 FCC Rcd at 5522, para. 11 (explaining that due to the misrepresentations by 
the telemarketer, the Company cannot demonstrate the complainants wanted to make a carrier change and 
understood that they were authorizing a carrier change.). 
53 See NAL, 29 FCC Rcd at 5530, para. 26 & n.86. 
54 This is consistent with AT&T Corporation v. FCC, 323 F.3d 1081, 1086 (DC Cir. 2003) (AT&T v. FCC).  In 
AT&T v. FCC, the court agreed with AT&T that “carriers seeking new customers via telemarketing have little 
choice but to depend on the veracity of the person answering the phone.”  The matter of a falsified TPV was not at 
issue in the two slamming instances before the court; in fact, the court repeatedly noted that the telemarketer 
following our verification procedures would have to rely on the person who answered the telephone call.  Our 
position here, however, is that a falsified TPV cannot comply with our verification rules because it is not the 
subscriber’s verification but a faked recording created solely to mislead state and/or federal agencies that the 
subscriber agreed to the carrier change. 
 Federal Communications Commission FCC 16-122 
 
 8 
B. Central Placed Unauthorized Charges on Consumers’ Telephone Bills 
(“Cramming”) 
15. Central also violated Section 201(b) of the Act by placing 28 unauthorized charges on 
consumers’ telephone bills.55  The Commission has previously held that the placement of unauthorized 
charges and fees on consumers’ telephone bills—known as “cramming”—is an “unjust and unreasonable” 
practice under Section 201(b).56  Cramming can occur either when third parties place unauthorized 
charges on consumers’ existing carriers’ telephone bills or when carriers place unauthorized charges on 
their own customers’ telephone bills.57  Any assessment of an unauthorized charge on a telephone bill or 
for a telecommunications service is an “unjust and unreasonable” practice under Section 201(b) of the 
Act.58  Central argues in its NAL Response that: (1) it did not cram consumers, but instead charged them 
for a “bundled” service that the consumers had authorized;59 and (2) by failing to comply with Central’s 
complaint procedures, consumers authorized any charges billed by Central.60  For the reasons discussed 
below, we reject these arguments and, based on a preponderance of the evidence in the record, affirm the 
NAL’s finding that Central violated Section 201(b) of the Act by placing 28 unauthorized charges on 
consumers’ telephone bills. 
1. Complainants did not authorize Central’s “bundled” services 
16. In the NAL we found that Central apparently violated Section 201(b) of the Act by 
placing 28 unauthorized charges on consumers’ telephone bills, in some cases multiple charges on the 
same consumer’s bills.61  When Central was able to change a consumer’s long distance carrier to itself, it 
would charge the consumer for itemized long distance calls as well as a monthly recurring charge.  When 
Central was unable to change a consumer’s carrier (such as when the consumer had a PIC freeze in 
place), or when a consumer discovered the unauthorized carrier change to Central and switched back to 
his or her original carrier, Central nonetheless assessed the same monthly recurring charge even though 
Central was not the consumer’s presubscribed long distance carrier.  Central contends that it sells a 
“bundle” of services and thus did not cram these consumers because it was billing them for its “bundled 
long distance service,” not just for the long distance service that the consumer either was never subscribed 
to (i.e., because a PIC freeze was in place) or that was canceled (because the consumer switched back to 
                                                     
55 Central’s process for third party billing generally involves three parties:  Central; its billing aggregator, Billing 
Services Group (known as BSG or USBI); and the LEC that issues the consumer’s bill.  See NAL, 29 FCC Rcd at 
5523, n.41.  As we described in the NAL, the underlying carriers, Level 3 or Global Crossing Telecommunications, 
Inc. and CenturyLink send Central information on the traffic on a customer’s billing telephone number which 
Central rates and sends to its billing aggregator to aggregate its billing and send to the applicable LEC for billing 
Central’s charges to the end user.  Id., 29 FCC Rcd at 5527, n.65.   
56 See, e.g., Long Distance Direct, Inc., Apparent Liability for Forfeiture, Memorandum Opinion and Order, 15 FCC 
Rcd 3297, 3302, para. 14 (2000) (LDDI MO&O) (finding that the company’s practice of cramming membership and 
other unauthorized fees on consumer telephone bills was an unjust and unreasonable practice in connection with 
communication services).   
57 See Empowering Consumers to Prevent and Detect Billing for Unauthorized Charges (“Cramming”), Report and 
Order and Further Notice of Proposed Rulemaking, 27 FCC Rcd 4436, 4437, paras. 1–2 (2012); see also Advantage 
Telecommunications Corp., Notice of Apparent Liability for Forfeiture, 28 FCC Rcd 6843, 6850, para. 17 (2013) 
(Advantage NAL). 
58 See Advantage NAL, 28 FCC Rcd at 6850, para. 17 (regardless of the method used to bill consumers, “any 
assessment of an unauthorized charge billed to consumers is an ‘unjust and unreasonable’ practice under Section 
201(b)”). 
59 NAL Response at 50–69. 
60 Id. at 52–69. 
61 NAL, 29 FCC Rcd at 5523–27, paras. 14–21.   
 Federal Communications Commission FCC 16-122 
 
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their preferred carrier).62  As discussed below, however, the evidence demonstrates that the complainants 
had not authorized Central to charge them for any service, including this “bundled” service. 
17. Central states that its bundled service includes “subscribed casual calling, calling card, 
and directory assistance long-distance service.”63  We understand that the “casual calling”64 service 
Central is referring to is a dial around service, i.e., the caller would dial 10-10 followed by the carrier 
identification code, or CIC, for the underlying carrier.65  Despite Central’s claims that these recurring 
charges are “valid accrued charges for long distance service provided”66 the evidence shows that 
complainants had not authorized or used such “bundled long-distance service.”67  As we discussed in the 
NAL, the bundle is not mentioned in the TPV and is not described or listed on the telephone bills from the 
LEC or from Central.68  Central admits that the TPV transcript does not “refer to a bundled package of 
services that includes casual calling, free directory assistance minutes, and a calling card.”69 
18. The complainants all contended that Central billed them for services they did not 
authorize.70  In most cases, Central initially switched their service away from their carrier to Central.  
Then, once the complainants had returned to their original carriers, Central continued to bill them for 
monthly service and other fees and taxes—either through their LEC bills or on bills sent to them directly 
by Central.  Numerous complainants described discovering unauthorized charges from Central on their 
local telephone bills, or on bills sent to them directly by Central, for long distance service they did not 
authorize and Central did not provide.71  Central has not offered any evidence to dispute the record 
evidence and justify its practice of continuing to bill consumers for several months after the unauthorized 
service was cancelled.  Central explains that after a consumer had cancelled the Central service and the 
underlying carrier (Global Crossing/Level 3 or CenturyLink) has deactivated the account—due to the 
consumer’s request for a PIC change back to the previous carrier—Konrad would “activate the line if it 
had been deactivated.”72  Thus, after the service was cancelled by both the consumer and the underlying 
wholesale carrier, Central would “go back in and click that back to active”73 to continue billing the 
consumer unauthorized charges.  The complainants’ assertions that such charges were unauthorized, 
                                                     
62 NAL Response at 50.   
63 Id. 
64 Casual calling services are those services that do not require the calling party to establish an account with an 
interexchange carrier or otherwise subscribe to a service.  A casual calling service is not a subscribed service and the 
caller using a casual calling service would not have an account with the interexchange carrier.  Therefore, if Central 
offered a casual calling service, it would not charge a recurring fee for such service because a casual calling service, 
by definition, does not have subscribed customers. 
65 Dial around long distance can be an economical service in certain circumstances, in lieu of a 1+ long distance 
service.  For example, some carriers offer discounted international services to certain countries on a dial around 
basis that consumers may prefer to the international service offered by the consumer’s PIC-ed carrier.  There is no 
evidence in the record that Central offers any such discounted services.   
66 NAL Response at 51. 
67 NAL, 29 FCC Rcd at 5526–27, paras. 17–21.   
68 Id. at 5526, para. 18. 
69 NAL Response at Exhibit 5, 478-79. 
70 NAL, 29 FCC Rcd at 5526–27, paras. 17–21. 
71 Id. at 5523–26, paras. 15–16 & n.52.  
72 NAL Response at Exhibit 5, pp. 463-470. Specifically, Konrad said that this would be done by himself “or 
somebody that works for Data Integration Systems, and we have subsequently handed that over to Priscilla’s 
company here just recently.”  Id. at 465. 
73 Id. at 466. 
 Federal Communications Commission FCC 16-122 
 
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described in detail in the NAL, are not credibly refuted.  Therefore, we find, based on the preponderance 
of the evidence in the record, that Central did not have the complainants’ authorization to charge for any 
service and thus crammed consumers by charging complainants for those unauthorized services.74   
19. In its NAL Response, Central first tries to establish that consumers authorized the 
recurring charges by providing two undated rate cards describing Alabama and Missouri calling plans.75  
Central has failed to show that the complainants received an Alabama or Missouri rate card, or any rate 
card, containing information about the bundle of services.76  Central also provided an undated “General 
Service Agreement.”77  Central has not shown that the Agreement was in effect in 2013 or 2014, the time 
period during which the apparent violations relevant to the NAL occurred, or that the complainants 
received this Agreement.  Further, Central has not explained why a consumer, already paying his or her 
presubscribed carrier for 1+ long distance service, would knowingly pay Central a monthly recurring 
charge for its dial around long distance service.  We do not find that Central’s evidence refutes the 
complainants’ assertions that they did not sign up for these services and that the charges were 
unauthorized. 
20. With respect to the casual calling service element of the bundle, Central speculates that 
the casual calling service would be a “convenient service for customers who are away from their 
presubscribed phone.”78  However, this explanation appears to confuse casual calling, pay-per-call dial 
around long distance service, and a subscribed calling card service because it fails to take into account 
that the call would be charged to the person whose telephone is used for the call, not the customer who 
made the call.  Assuming Central was referring to a subscribed calling card service using a toll free 
number and a PIN, also allegedly part of the bundle, Central fails to show that any customer authorized 
the service or, in fact, even used the service.  Central also contends that subscribers could use the casual 
calling service if they “want to use CTLD’s deeply discounted international rates to make international 
calls.”79  However, there is no evidence in the record that Central had “deeply discounted” international 
rates, that any consumers were aware of international rates offered by the Company, or that any 
consumers had used this service.  Central has not given any examples of the complainants, or any other 
person, using the casual calling dial around service.80   
21. Finally, Central contends that the invoice from Level 3 provided in the NAL Response 
shows that consumers had used its directory assistance and calling card services.81  After reviewing this 
invoice we conclude that Central has not provided persuasive evidence that the complainants used these 
two services or authorized them.  The only invoice provided is for May 15, 2014 (the “Effected Invoice 
                                                     
74 In addition to the above described unauthorized charges, Central’s position is that after cancellation of its service 
by a consumer, the Company will still bill a consumer for several months—despite the fact that no charges were 
ever authorized.  Central states that “[i]n order to cancel service correctly with Central Telecom the customer must 
contact Central Telecom customer service directly.  That is why these procedures are clearly outlined in the General 
Service Agreement that was mailed to the customer as well as the Company’s Public Disclosure Document.”  See, 
e.g., Central’s response to Complaint from S. Bingham; Central’s response to Complaint from D. Honnas. 
75 NAL Response at Attachment 2. 
76 The rate cards do not list directory assistance as part of the bundled plan.  See NAL Response at Attachment 2.  
Twenty-six of the complainants are from states other than Alabama or Missouri.  
77 See NAL Response at Attachment 4. 
78 NAL Response at Exhibit 2, para. 14.   
79 NAL Response at 55.   
80 The wholesale invoice provided by Central does not categorize the dial around calls separately; there is no 
evidence in the record that any consumer used Central’s dial around service at any time.  See NAL Response, 
Attachment 5. 
81 NAL Response at 67. 
 Federal Communications Commission FCC 16-122 
 
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Date”); however, the complaints at issue were for slams and crams that occurred long before that date.82  
The invoice shows that no calling card calls were made that month.83  Central contends that it charges its 
customers for directory assistance calls after a certain number of free directory assistance calls;84 
therefore, Central should be able to identify which customers made directory assistance calls, and how 
many calls were made by those customers, yet the Company has failed to provide such information in its 
NAL Response.  Central did not submit any evidence in the record that the complainants made any 
directory assistance calls.  Based on these facts, we are not persuaded that directory assistance calls made 
by unknown persons after the last cram date at issue in the NAL shows that the complainants authorized 
Central’s bundle of services as Central would have us believe.  Further, none of Central’s bills (neither 
those issued by the LEC nor those issued by Central directly) identifies or even reflects any charges for a 
“bundled service” or mentions a bundle of services at all.85  Accordingly, based on the preponderance of 
the evidence in the record, we conclude that Central has failed to show that the complainants authorized 
the bundled services. 
2. Complainants’ failure to follow Central’s “cancellation procedures” is not a 
substitute for authorization to be billed 
22. Central further argues that the recurring charges described above were authorized 
because consumers must contact the Company directly in order to cancel its services and stop Central 
from continuing to charge them.86  Otherwise, according to Central, it bills the consumer monthly fees 
regardless of whether Central is the preferred carrier.87  Thus, a consumer who discovered an 
unauthorized carrier change to Central and charges on his or her telephone bill and complained to the 
LEC to have the carrier changed back and the charges removed would, according to the argument put 
forth by Central, be authorizing further Central charges because the cancellation was not performed in 
accordance with Central’s procedures, of which the consumer was unaware having never sought service 
by Central in the first place.  The LEC bills upon which Central was billing the consumers specifically 
instructed the consumers to contact the LEC with any billing questions.88  A consumer faced with an 
unauthorized charge from Central on his or her telephone bill would therefore reasonably follow the 
instructions on the telephone bill and contact the LEC to have the charge removed.  According to Central, 
after a consumer canceled Central’s service through his or her LEC, and Central received the cancellation 
                                                     
82 There were only three slams or crams in 2014, and the most recent was April 15, 2014.  The remaining slams and 
crams listed in the Appendix occurred in 2013. 
83 NAL Response at Attachment 5.   
84 See Affidavit of Craig Konrad, NAL Response at Exhibit 2, p. 6 (“Depending on the rate plan to which the 
customer has subscribed, the customer is allowed a certain number of free directory assistance calls.”). 
85 See direct bills sent to Complainants J. Hudson, C. , A. Trembley, and A. Stanley.  The direct bills list 
“Central Telecom Long Distance, Inc. Charges” beside a line for “Adjusted Long Distance Charges” or “Long 
Distance Charges.”  On the bottom of the bill Central states: “This letter is being sent to inform you of charges that 
were sent back to Central Telecom Long Distance, Inc., by your local carrier.  These are charges that you contacted 
your local phone company about, that you were not aware of, or did not understand.”  There is no other description 
of the service or the charges or any mention of “bundled services,” such as a travel card, directory assistance, or 
casual calling long distance, on the bill.   
86 NAL Response at 52.  Central contends that this cancellation policy is explained during the “initial sales call.”  Id.   
87 The complainants’ telephone bills do not mention the bundled services or the particular requirements for 
cancelling Central services. 
88 See, e.g., Verizon bill attached to Complaint from J. Hudson; AT&T bill attached to Complaint from F.  
(under “Billing Summary” there are instructions to “Visit att.com/billing” with “Billing Questions” as well as toll 
free numbers to call with billing questions). 
 Federal Communications Commission FCC 16-122 
 
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information from its underlying carrier,89 instead of honoring the consumer’s request for cancellation of 
the unauthorized service, it continued to send the consumer a direct bill for “services.”90  Thus, Central, 
on notice of the cancellations, continued to bill consumers on the pretext that the consumers failed to 
follow Central’s cancellation procedure, which Central contends was explained to consumers during the 
course of its initial sales call.91  Central has not provided a recording of its initial sales call to any of the 
complainants or any other evidence to support this contention. 
23. Notwithstanding Central’s unsubstantiated claim that it notified consumers of its 
cancellation policy, Central cannot deliberately ignore the consumers’ cancellations and expect them to 
follow particular Central procedures to cancel a bundled service they had not previously ordered and of 
which, according to the available evidence, they were unaware.  Indeed, Central has not shown that the 
complainants had any information about the Company’s particular cancellation procedures.  We find it 
unjust and unreasonable to expect a consumer to do anything more to cancel a service on his or her 
telephone bill than what the consumer is instructed to do on the bill containing the charge.  Moreover, as 
discussed in the NAL, the initial sales call misrepresented the services and the purpose of the call and thus, 
the consumer acting reasonably at the time of cancellation would have no reason to refer back to that 
initial call for clarity as to his or her obligation in cancelling a service that was never authorized in the 
first instance.92 
24. We therefore, affirm the finding in the NAL and find that the record here establishes that 
Central placed charges on consumers’ local telephone bills or billed them directly for service without the 
consumers’ authorization.  Any carrier that charges consumers for services without authorization from the 
consumer is in violation of Section 201(b) of the Communications Act and that violation is even more 
egregious when, as in this case, the carrier has actual knowledge that the charge is not authorized through 
a cancellation notice. 
C. Central Deceptively Marketed its Services to Consumers 
25. As stated in the NAL, Central violated Section 201(b) of the Act by misrepresenting its 
identity to consumers.93  The Company makes two arguments in an attempt to refute this finding.  Central 
argues: (i) that its training of telemarketers makes it unlikely that they misrepresented the identity or 
affiliation of the Company to consumers, and (ii) that the TPVs and unsigned responses to complaints 
prove that no misrepresentations took place.  We reject these arguments and find that Central violated 
Section 201(b) of the Act by engaging in misrepresentations of its identity to consumers. 
1. Telemarketer Training Does Not Refute the Findings in the NAL that the 
Company Deceptively Marketed its Services 
26. We found in the NAL that Central’s telemarketers apparently misrepresented that the 
Company was (or was affiliated with) complainants’ existing long distance carriers.  For example, Ms. 
Honnas explained:   
I received a phone call from a woman who said she was with CenturyLink and the reason for her 
call was that CenturyLink did not want to lose any more landline customers . . . [and] they were 
offering a discount for customers that have a record of small use of long distance . . . . [I said that] 
                                                     
89 Central gathers information on the customers’ usage for billing purposes.  See Office of Consumer Advocate v. 
Consumer Telcom, Inc., State of Iowa Department of Commerce Utilities Board, Docket No. FCU-2012-0011c 
(FCU-2012-0001, FCU-2012-0007), Global Crossing Telecommunications, Inc., Direct Testimony of Diane L. 
Peters (Feb. 25, 2013) (explaining the Global Crossing procedure for providing end-user information to resellers). 
90 See NAL, 29 FCC Rcd at 5535 for the list of complainants who received direct bills from Central. 
91 NAL Response at 57–59. 
92 NAL, 29 FCC Rcd at 5520-22, paras. 7-9. 
93 Id. at 5520–21, paras. 7–8. 
 Federal Communications Commission FCC 16-122 
 
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I do not want to change [my] phone company. . . .[T]hen I received a bill from Central Telecom 
Long Distance for $16 . . . . I never use long distance so why would I ever want their service.94  
 
27. Central argues that it is highly improbable that the Company tricked any of its customers 
into believing the telemarketer was calling from their own carriers because Central instructs telemarketers 
that “they must advise prospective customers during the telemarketing call that they are with ‘Central 
Telecom Long Distance, Inc.;’” the telemarketers must sign a marketing practices agreement; Central has 
a quality assurance monitoring program; and the dialing software program has a 17 second delay before 
the telemarketer is shown the customer’s telephone number and address, making it “extremely difficult” 
to misrepresent that the telemarketer is affiliated with or actually is the consumer’s long distance carrier.95 
28. We are not persuaded that the existence of a telemarketing agreement prevented Central’s 
telemarketers from the acts of misrepresentation described above and in the NAL.  The record reflects, for 
example, that Complainant Millard was led to believe that the telemarketer was calling from AT&T.  He 
explains: 
 [Central] called and posed as my AT&T provider [and] made a sales pitch stating my phone bill 
would go down by $10 if I agreed to their new terms and conditions so I did[,] thinking it was 
AT&T. . . . I have two cell phones so I do not even use my home phone for long distance.96   
 
29. Other complainants described similar instances of misrepresentation.97  We also disagree 
that the 17 second delay described by Central98 precludes a telemarketer from misrepresenting his or her 
identity to consumers.  Central has not shown that during the 17 seconds before the telemarketer is shown 
the consumer’s telephone number and address,99 the telemarketer would be prevented from saying that he 
or she was calling from the consumer’s long distance carrier.  With respect to the “quality assurance 
monitoring program,”100 we do not find that the allegation that DIS “regularly listens in on the sales 
representative’s calls”101 refutes the misrepresentations described by the complainants.  Central has not 
provided recordings of the telemarketer for the specific complaints at issue to refute the evidence of 
misrepresentation.  Based on the evidence in the record, we find that the multiple consumers who took the 
time to file complaints against Central describing instances of misrepresentation to be far more persuasive 
than the Central allegation that a telemarketer has signed a marketing practices agreement and that some 
calls are monitored.   
30. We reject the argument that Central’s telemarketing safeguards, anti-slamming policies, 
and telemarketer contracts prevented misrepresentations, cramming, or slamming, or in any way 
alleviated Central of its statutory and rule obligations.   
                                                     
94 Complaint from D. Honnas.   
95 NAL Response at 42–44. 
96 Complaint from B. Millard. 
97 See, e.g., Complaint from K.  (“[A]n individual representing themselves as a CenturyLink employee called 
her and advised her that they could save her money.”); Complaint from K. Josephsen (“Back in September [2013] 
USBI called . . . and claimed that they were with CenturyLink.”); Complaint from M. Thompson (“received a call 
stating that they were Verizon. . . . Then she received a bill showing charges from U.S.B.I. and Central. . . . Verizon 
[told] her that they did not call her and that they would see that this was cancelled.  However, she is still getting 
billed.”).   
98 NAL Response at 43–44.     
99 Although not explained in the NAL Response, presumably the issue is that once the telemarketer has this 
information he or she can do an internet search to determine the consumer’s carrier. 
100 NAL Response at 43. 
101 Id. at 44. 
 Federal Communications Commission FCC 16-122 
 
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2. Central Has Not Refuted Evidence that it Misrepresented Itself to 
Consumers 
31. As discussed above, in the NAL we found that Central apparently misrepresented itself to 
consumers by claiming that it was their existing long distance carrier and that the purpose of its call was 
to modify the consumers’ current service plan.  Central contends that it did not misrepresent itself to 
consumers.102  Central uses the unsigned response it sent to each consumer complaint, with some 
revisions, as support for its arguments.103  Central fails to provide any evidence to refute the specific 
allegations of misrepresentation described in the complaints.   
32. For example, Central quotes a portion of Ms. Josephsen’s complaint where she states that 
the telemarketer “deceived” her by claiming that she would save “close to $10.00 per month by switching 
to them,” but disingenuously omits her statement that the telemarketer “claimed that they were with 
Centurylink (our current provider). . . .”104  Central disputes Complainant Richards’ claim that the TPV 
Central provided as proof of her authorization was “doctored up” because, according to Central, the TPV 
“is virtually identical to all of [Central’s] TPVs . . . .”105  Central also relies on the affidavit of the owner 
of its third party verification company, Molly Cook, who stated that “[o]nce the recordings are made, they 
are preserved intact and cannot be altered in any way.”106  Ms. Cook’s affidavit, however, does not refute 
that Central misrepresented itself to consumers.  Further, whether the TPV was “virtually identical” to the 
other TPVs does not refute Ms. Richards contention that it was “a dubbed tape and . . .  doctored up.”107  
Central argues that the complaint filed by Ms. Millard fails to show misrepresentation because of the 
TPV;108 however, in its response Central has omitted to address Ms. Millard’s claim that the telemarketer 
“posed as my AT&T provider.”109   
33. Central also discusses other complaints alleging misrepresentation and relies on the fact 
that there was a TPV to support its contention that there was no misrepresentation.  We find these 
arguments unconvincing as well, for the same reasons discussed above.  Bureau staff reviewed many 
misrepresentation complaints lodged against Central, although only the complaints that were within our 
12 month statute of limitations were included in the NAL’s proposed forfeiture.  Our review of the record, 
the complaints outlined in the NAL, as well as the other evidence described in this proceeding, all support 
the findings in the NAL, including the finding that the Central telemarketers engaged in 
misrepresentations.  We conclude that Central has not refuted the evidence of misrepresentations as 
described in the NAL and, based on the evidence in the record, we affirm the findings and conclusions in 
the NAL.  
D. The NAL’s Reliance on Consumer Complaints was Reasonable and Central was not 
Denied Due Process 
34. Central contends that the Commission’s reliance on consumer complaints, instead of a 
“sworn statement” is “suspect.”110  We disagree.  There is no requirement in the Act111 or in the 
                                                     
102 Id. at 38–50. 
103 See id., Appendix. 
104 Complaint from K. Josephsen. 
105 NAL Response at 41. 
106 Id., Exhibit 4.  
107 Complaint from J. Richards. 
108 NAL Response at 41. 
109 Complaint from B. Millard. 
110 NAL Response at 44–45.  Central’s responses to the consumer complaints were all unsigned and Central has 
never identified the employee(s) or contractor(s) who provided the information for those letters. 
 Federal Communications Commission FCC 16-122 
 
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Commission’s rules112 that we use sworn statements or even that we base our investigations on consumer 
complaints.  Further, the Commission decides on a case-by-case basis whether to obtain declarations in 
support of complaints.113  The NAL was primarily based on consumer complaints the Bureau reviewed and 
followed a similar process used in other recent slamming and cramming investigations.114  In this 
investigation, the Bureau reviewed over one hundred complaints and interviewed many of the 
complainants.  The complaints, all of which stated that the carrier change and/or charges were 
unauthorized, were filed with the Commission, various state regulatory agencies,115 the Federal Trade 
Commission, or the Better Business Bureau.  In investigating the other two companies that were part of 
this operation, USTLD and CTI, the Bureau found similar complaints from consumers, i.e., that the 
carrier change to USTLD or CTI and/or charges assessed by those companies were not authorized.116  
Central had more than enough information about the complaints upon which the NAL’s proposed 
forfeiture was based to allow it to rebut the NAL’s findings and contest the complainants’ veracity in its 
NAL Response.  Nonetheless, the Company did not submit any evidence disputing the veracity of the 
complainants.  Central has not offered any evidence that the complainants are not truthful. 
35. We also reject Central’s claim that it was denied due process because the complaints 
were “unsworn” and there are “numerous reasons why a customer would mistakenly describe the 
substance of his telephone conversation with a telemarketer” or “intentionally falsely describe” the 
telemarketing call.117  Central was on notice that its actions were in violation of our Rules and the Act118 
and of the allegations in each complaint.  Central had contacted each of the complainants to address their 
complaints, and had also sent some of the complainants direct bills.119  The consumer complaints were all 
initially served on Central; the Company had ample opportunity to investigate any complaint regardless of 
(Continued from previous page)                                                            
111 See Section 403 of the Act, providing, in pertinent part, that “[t]he Commission shall have full authority and 
power at any time to institute an inquiry, on its own motion, in any case and as to any matter or thing ... concerning 
which any question may arise under any of the provisions of this Act, or relating to the enforcement of any of the 
provisions of this Act.” 47 U.S.C. § 403. 
112 Central erroneously cites to 47 CFR § 1.351, for the proposition that using consumer complaints in lieu of sworn 
statements was “afoul” of our rules.  NAL Response at 45.  Section 1.351, however, specifically pertains to formal 
hearings.  The rule section also states that “[s]uch rules may be relaxed if the ends of justice will be better served by 
so doing.”  47 CFR § 1.351. 
113 See Business Discount Plan, Inc., Order on Reconsideration, 15 FCC Rcd 24396, 24401, para. 12 (2000).    
114 See, e.g., USTLD NAL, 29 FCC Rcd at 824, para. 3; CTI NAL, 28 FCC Rcd at 17197, para. 4; Advantage NAL, 28 
FCC Rcd at 6845, para. 6; United Telecom, Inc., Notice of Apparent Liability for Forfeiture, 27 FCC Rcd 16499, 
16500, para. 3 (2012) (United NAL); Preferred Long Distance, Inc., Notice of Apparent Liability for Forfeiture, 27 
FCC Rcd 16489, 16489, para. 2 (2012) (Preferred NAL), Forfeiture Order, 30 FCC Rcd 13711 (2015); Silv 
Communication Inc., Notice of Apparent Liability for Forfeiture, 25 FCC Rcd 5178, 5179, para. 2 (2010) (Silv 
NAL). 
115 Central provided complaints that consumers had filed against Central with the Alabama Public Service 
Commission, the Arizona Corporation Commission, the California Public Utilities Commission, the Michigan 
Public Service Commission, the Attorney General of Missouri, the New York State Public Service Commission, the 
Public Utility Commission of Texas, and the Washington Utilities and Transportation Commission. 
116 See USTLD NAL, 29 FCC Rcd at 824, para. 3 (reviewed over 60 complaints); CTI NAL, 29 FCC Rcd at 17197, 
para. 4 (reviewed over 100 complaints). 
117 NAL Response at 49. 
118 See, e.g., BDP Forfeiture Order, 15 FCC Rcd at 14469, para. 17; USTLD NAL, 29 FCC Rcd at 825–26, para.7; 
CTI NAL, 28 FCC Rcd at 17198–99, para. 7; Advantage NAL, 28 FCC Rcd at 6849, para. 16; United NAL, 27 FCC 
Rcd at 16502, para. 9; Preferred NAL, 27 FCC Rcd at 16491, para. 7; Silv NAL, 25 FCC Rcd at 5180–82, paras. 5–7. 
119 As we discuss in more detail below, on several occasions after consumers complained about Central’s 
unauthorized charges and the LEC removed the charges, Central then billed the consumers directly. 
 Federal Communications Commission FCC 16-122 
 
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whether the complaint contained a sworn declaration.  With respect to the notice aspect of due process, 
Central had advance notice that slamming, cramming, and misrepresentation were in violation of the Act 
and our Rules.  Prior to the time frame of the complaints at issue here, the Commission had released one 
forfeiture order and several notices of apparent liability that address the very same practices and actions 
we find in this case to be in violation of the Act and our Rules.120  Further, the NAL, as a notice of 
proposed forfeiture liability, affords Central the due process right to respond and offer any evidence to 
rebut the apparent findings of the NAL.  Accordingly, we reject this argument and find that the NAL is 
appropriately supported. 
E. Central Violated the Commission’s Truth-in-Billing Rules 
36. We found in the NAL that where Central billed consumers directly, it failed to clearly and 
plainly describe the charges, in violation of the Commission’s truth-in-billing rules.  Under these rules, 
“[c]harges contained on telephone bills must be accompanied by a brief, clear, non-misleading, plain 
language description of the service or services rendered.  The description must be sufficiently clear in 
presentation and specific enough in content so that customers can accurately assess that the services for 
which they are billed correspond to those that they have requested and received . . . .”121  The purpose of 
the truth-in-billing rules is “to reduce slamming and other telecommunications fraud by setting standards 
for bills for telecommunications service.”122  In addition, the rules are “intended to aid customers in 
understanding their telecommunications bills, and to provide them with the tools they need to make 
informed choices in the market for telecommunications service.”123 
37. In the NAL, we concluded that the bills Central issued to customers directly were neither 
sufficiently clear nor specific enough to aid customers in assessing their bills.124  In particular, the 
monthly recurring charge for Central’s “bundled” services was not described as such on either the LEC 
bill or on the Central bill.  The Central bills were not dated, included no payment due date, and lacked a 
brief, clear, and non-misleading description of the service or services rendered.125  They included a line 
item charge for “Long Distance Charges” or “Adjusted Long Distance Charges” but had no information 
about what was included in that amount or what time period was covered by the alleged charge.  The bills 
did not identify any long distance calls made (such as numbers called, dates, or length of such calls), did 
not list any fees or taxes, and failed to identify any specific services that Central claims are part of its 
“bundled package of services.”126  Central contends that the bills complied with our truth-in-billing rules 
because they were merely billing consumers for unpaid bills, analogous to a carrier billing for a previous 
unpaid charge.127  We reject this argument for the reasons discussed below and affirm the NAL’s findings.  
38. Central’s argument fails to recognize that in the instant case, the bill or charge received 
by the consumer was from a carrier other than the consumer’s preferred carrier and was an unauthorized 
charge.  Complainants were initially charged on their LEC bill by Central, an unauthorized carrier, which 
                                                     
120 See, e.g., BDP Forfeiture Order, 15 FCC Rcd at 14469, para. 17 (Business Discount Plan’s telemarketers 
unlawfully deceived consumers about the identity of the carrier and the nature of the service offering); Advantage 
NAL, 28 FCC Rcd at 6849, para. 16 (same); United NAL, 27 FCC Rcd at 16502, para. 9 (same); Preferred NAL, 27 
FCC Rcd at 16491, para. 7 (same); Silv NAL, 25 FCC Rcd at 5180–82, paras. 5–7 (same). 
121 47 CFR § 64.2401(b). 
122 Id. § 64.2400. 
123 Id. 
124 NAL, 29 FCC Rcd at 5527–28, paras. 22–23.  See also USTLD NAL, 29 FCC Rcd at 834–35, paras. 21–22; CTI 
NAL, 28 FCC Rcd at 5527–28, paras. 23–24; Advantage NAL, 28 FCC Rcd at 6854–55, paras. 26–27.  
125 NAL, 29 FCC Rcd at 5527, para. 22. 
126 Id. 
127 NAL Response at 69–72. 
 Federal Communications Commission FCC 16-122 
 
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the consumers then complained about, had the Central service cancelled, and received a credit for the 
unauthorized charges.  The unauthorized charges thus remained rightfully unpaid by consumers.  After 
Central received information about the cancellations and billing credits the Company nonetheless 
continued to pursue payment by directly sending the consumers bills for these disputed charges.  The 
Central bills (mailed long after the initial LEC bill containing the unauthorized charges) had no 
information about the specific charges and in some cases were sent many months after the consumers had 
received a credit from the LEC for the unauthorized charges.  This failure to include a non-misleading 
plain language description of the charges sufficiently clear so as to allow consumers the ability to 
ascertain what the charges were for is in direct violation of Section 64.2401 of the Commission’s “truth-
in-billing” rules.  Accordingly, we find Central’s unpaid bill argument to be unpersuasive and we affirm 
the finding that Central has failed to clearly and plainly describe charges appearing on its telephone bills, 
in violation of Section 64.2401(b) of the Commission’s rules.128     
F. Forfeiture Amount  
39. In the Central NAL, we found that after considering the relevant statutory factors and the 
Commission’s Forfeiture Policy Statement, Central was liable for a proposed total forfeiture amount of 
$3,960,000.  As we explained in the NAL,129 this proposed amount resulted from a $40,000 forfeiture for 
the 31 instances of slamming and cramming130 and the four truth-in-billing violations, as well as an 
upward adjustment of $80,000 for each of the seven instances of misrepresentation, and other upward 
adjustments based on the egregious circumstances presented in the record here.  Central argues that the 
forfeiture amount is not supported by the facts and that it is unable to pay the proposed forfeiture.131   
40. As discussed at length above, Central has failed to refute the evidence in the record in 
support of the slamming, cramming, misrepresentation, and truth-in-billing violations.  In particular, it 
does not address the fact that the Commission reviewed over 100 complaints from consumers who alleged 
improper conduct on the part of Central, and determined that this conduct was extensive and repeated.  
For example, Central’s slamming actions were particularly egregious because the Consumer & 
Governmental Affairs Bureau repeatedly notified Central that its verification practices (the same that are 
at issue here) violated the Commission’s slamming rules.132  Further, Konrad, Central’s agent, testified 
                                                     
128 NAL, 29 FCC Rcd at 5527–28, paras. 22–23; see also Advantage NAL, 28 FCC Rcd at 6854–55, paras. 26–27 
(discussing apparent Section 64.2401 violations in that investigation).  
129 NAL, 29 FCC Rcd at 5529–5533, paras. 25–30. 
130 Although the forfeiture guidelines do not provide a base forfeiture amount for cramming, we have established a 
base forfeiture of $40,000 for cramming violations.  See LDDI MO&O, 15 FCC Rcd at 3304, para. 19 (“The 
imposition of charges on a telephone bill for ‘services’ the consumer has not authorized is sufficiently egregious to 
warrant a forfeiture in an amount equal to that for slamming.”). 
131 NAL Response at 73–80. 
132 See, e.g., Consumer Telcom, Inc., Order on Reconsideration, 27 FCC Rcd 5340, 5345, para. 17 (CGB 2012) 
(finding “the verifier’s question, ‘Do you have authority to make changes to your long distance service?’ did not 
confirm that the person was authorizing a change that would result in receiving service from a different carrier”); 
Central Telecom Long Distance, Inc., Complaints Regarding Unauthorized Change of Subscriber’s 
Telecommunications Carrier, Order, 28 FCC Rcd 16653 (CGB 2013) (same, for two complaints); Central Telecom 
Long Distance, Inc., Complaints Regarding Unauthorized Change of Subscriber’s Telecommunications Carrier, 
Order, 28 FCC Rcd 13353 (CGB 2013) (same, for two complaints); Central Telecom Long Distance, Inc., 
Complaint Regarding Unauthorized Change of Subscriber’s Telecommunications Carrier, Order, 28 FCC Rcd 9276 
(CGB 2013) (same); Central Telecom Long Distance, Inc., Complaints Regarding Unauthorized Change of 
Subscriber’s Telecommunications Carrier, Order, 28 FCC Rcd 6537 (CGB 2013) (same, for two complaints); 
Central Telecom Long Distance, Inc., Complaint Regarding Unauthorized Change of Subscriber’s 
Telecommunications Carrier, Order, 28 FCC Rcd 6241 (CGB 2013) (same); Consumer Telcom, Inc., Complaints 
Regarding Unauthorized Change of Subscribers’ Telecommunications Carrier, Order, 25 FCC Rcd 3202 (CGB 
(continued….) 
 Federal Communications Commission FCC 16-122 
 
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that after a consumer had cancelled the Central service and the underlying carrier deactivated the account, 
Konrad would activate the line if it had been deactivated and “go back in, and click that back to active”133 
to continue billing the unauthorized charges.  Konrad would continue to bill consumers after they had 
already cancelled, conduct that we find particularly egregious.  In addition, Central, as a carrier, is 
responsible for the conduct of third parties acting on its behalf, such as Konrad.134  Konrad, an agent of 
Central, was responsible for the day-to-day running of the Company.135  In addition to owning DIS, 
Konrad is the president of toll reseller BDP.136  The Commission investigated BDP for slamming and 
misrepresentation137 and described, in the BDP Forfeiture Order, that “[b]etween December 1997 and 
October 1998, the Commission processed thousands of written consumer complaints alleging slamming 
by BDP . . . . Each complainant contended that BDP had converted his or her designated PIC without 
authorization, and that BDP used unjust and unreasonable telemarketing practices in effecting these 
unauthorized PIC changes.”138  At the time of the BDP investigation, Konrad was the Vice President of 
BDP, and, as such, was served with a copy of the BDP NAL.139  In operating USTLD, CTI, and Central, as 
the agent of these three companies, Konrad engaged in the same practices as discussed in the BDP 
Forfeiture Order.   
41. In the NAL, the Commission also alleged that Central and its telemarketers and third 
party verifiers “deliberately exploited elderly or disabled consumers’ obvious confusion and inability to 
understand the sales pitch they heard and understand the questions they were asked.”140  Due to the 
egregious nature of Central’s conduct, the Commission proposed an upward adjustment of $1,500,000 
and an additional upward adjustment of $500,000 for substantial consumer harm and Central’s 
exploitation of the elderly and infirm.141  Central argues that the upward adjustments were not supported 
by facts because it “did not engage in any slamming or cramming misconduct,”142 and “it would be 
virtually impossible for CTLD to exploit the elderly.”143  Specifically, Central claims it purchases lists of 
land line telephone numbers from several sources, including Info USA, which contain numbers in the 
states where Central provides long distance service.144  Central has the burden of providing evidence to 
disprove the allegation in the NAL.  We find that the evidence in the record on this point is inconclusive.  
Accordingly, we conclude that the upward adjustment of $1,500,000 is sufficient to deter further 
egregious conduct by Central and do not impose an additional upward adjustment of $500,000.”  
(Continued from previous page)                                                            
2010) (same, two complaints); U.S. Telecom Long Distance, Inc., Complaint Regarding Unauthorized Change of 
Subscriber’s Telecommunications Carrier, Order, 25 FCC Rcd 3135 (CGB 2010) (same). 
133 NAL Response at Exhibit 5, p. 466. 
134 See 47 U.S.C. § 217 (“. . . the act, omission, or failure of any . . . agent [ ] or other person acting for or employed 
by any common carrier . . . , acting within the scope of his employment, shall in every case be also deemed to be the 
act, omission, or failure of such carrier . . . .”); see also LDDI MO&O, 15 FCC Rcd at 3300, para. 9; Silv NAL, 25 
FCC Rcd at 5180, para. 5 & n.18. 
135 NAL, 29 FCC Rcd at 5517, para. 2. 
136 See FCC Form 499-A, filed by Business Discount Plan, Inc. on Apr. 1, 2015.  
137 BDP NAL, 14 FCC Rcd at 353-363, paras. 27-44. 
138 See BDP Forfeiture Order, 15 FCC Rcd at 14461-62, para. 2. 
139 BDP NAL, 14 FCC Rcd at 364, para. 49. 
140 NAL, 29 FCC Rcd at 5531, para. 29. 
141 NAL, 29 FCC Rcd at 5530-33, paras. 27–30.  
142 NAL Response at 76. 
143 Id. at 79. 
144 Id. 
 Federal Communications Commission FCC 16-122 
 
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42. Finally, Central states that it “is not financially able to pay the proposed forfeiture” and in 
support, submits federal income tax returns for the years 2010, 2011, and 2012.145  The NAL stated that  
[t]he 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.146   
Upon review of Central’s financial information, and the totality of the circumstances presented here, we 
decline to reduce the forfeiture amount further.  Section 503(b)(2)(B) of the Act empowers the 
Commission to assess a forfeiture of up to $150,000 for each willful or repeated violation in this case of 
the Act or of any rule, regulation, or order issued by the Commission under the Act.147  In exercising our 
forfeiture authority, we are required to take into account “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.”148   
43. With regard to an individual’s or entity’s inability to pay claim, the Commission has 
determined that, in general, gross income or revenues are the best indicator of an ability to pay a 
forfeiture.149  However, a party’s inability to pay is only one factor in our forfeiture calculation analysis, 
and is not dispositive in setting a forfeiture.150  The other four factors are:  (i) the nature, circumstances, 
extent, and gravity of the violation; (ii) the degree of culpability; (iii) any history of prior offenses; and 
(iv) and such other matters as justice may require.  With respect to the nature, circumstances, extent, and 
gravity of the violation and the degree of culpability, in particular, we have described the large number of 
consumer complaints against the Company for slamming and cramming and misrepresentation.151  The 
NAL also describes the nature of the misrepresentations by Central.152  In addition, Central continued to 
bill consumers for the unauthorized charges after the consumers had canceled the Central “service” that 
they never authorized in the first place and returned to their prior carriers.153  In some cases, Central sent 
                                                     
145 NAL Response at 81 & Exhibit 10. 
146 NAL, 29 FCC Rcd at 5534, para. 37. 
147 47 U.S.C. § 503(b)(2)(B); see also 47 CFR § 1.80(b)(2).  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 in 2013.  See Amendment of Section 1.80(b) of the Commission’s Rules, Adjustment of Civil 
Monetary Penalties to Reflect Inflation, 28 FCC Rcd 10785 (EB 2013); see also Inflation Adjustment of Monetary 
Penalties, 78 Fed. Reg. 49,370-01 (Aug. 14, 2013) (setting Sept. 13, 2013, as the effective date for the increases).  
Because the DCIA specifies that any inflationary adjustment “shall apply only to violations that occur after the date 
the increase takes effect,” however, we apply the forfeiture penalties in effect at the time the apparent violation took 
place.  28 U.S.C. § 2461 note (6).   
148 See 47 U.S.C. § 503(b)(2)(E); see also Forfeiture Policy Statement, 12 FCC Rcd at 17100–01, para. 27.. 
149 See Local Long Distance, Inc., Order of Forfeiture, 15 FCC Rcd 24385 (2000) (forfeiture not deemed excessive 
where it represented approximately 7.9 percent of the violator’s gross revenues). 
150 See 47 U.S.C. § 503(b)(2)(E). 
151 See NAL, 29 FCC Rcd at 5518, para. 3 (“over one hundred complaints filed”). 
152 Id. at 5520-21, para. 8. 
153 Id. at 5523-27, paras. 14-20. 
 Federal Communications Commission FCC 16-122 
 
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consumers a direct bill for the unauthorized service after the consumers’ LEC had credited the 
unauthorized Central charges.154     
44. We have previously rejected inability to pay claims in cases of repeated or otherwise 
egregious violations.155  Given the record evidence here that Central willfully and repeatedly violated the 
Act and the Commission’s rules, and the egregious nature of its misrepresentations and exploitive tactics, 
we find that these factors outweigh any inability to pay claim raised by Central and that therefore, the 
record does not warrant any further mitigation of the proposed forfeiture amount.  Accordingly, after 
consideration of the entire record and the factors listed above, we find that a forfeiture in the amount of 
$3,460,000 is warranted. 
IV. CONCLUSION 
45. We have reviewed Central’s arguments and reduce the proposed forfeiture amount by 
$500,000.  We find that the preponderance of the evidence in the record establishes that Central changed 
the preferred carriers of three consumers without authorization, assessed unauthorized charges on 28 
occasions, and that in seven of those slamming and cramming instances made misrepresentations to those 
consumers.  In addition, we find that the preponderance of the evidence in the record establishes that 
Central violated the truth-in-billing rules when in four instances it sent consumers bills that were not 
accompanied by a brief, clear, non-misleading, plain language description of the service or services 
rendered.  We conclude that the evidence cited in the NAL was not refuted by Central.  Accordingly, the 
Commission finds that Central violated Sections 201(b) and 258 of the Act and Sections 64.1120 and 
64.2401 of the Commission’s rules and we assess a forfeiture of $3,460,000.   
V. ORDERING CLAUSES 
46. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Act156 and Section 
1.80 of the Commission’s rules,157 Central Telecom Long Distance, Inc. IS LIABLE FOR A 
MONETARY FORFEITURE in the amount of three million four hundred sixty thousand dollars 
($3,460,000) for willfully and repeatedly violating Sections 201(b) and 258 of the Act and Sections 
64.1120 and 64.2401(b) of the Commission’s rules.158 
47. Payment of the forfeiture shall be made in the manner provided for in Section 1.80 of the 
rules within thirty (30) calendar days after the release date of this Forfeiture Order.159  If the forfeiture is 
not paid within the period specified, the case may be referred to the U.S. Department of Justice for 
enforcement of the forfeiture pursuant to Section 504(a) of the Act.160   
48. 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.  Central Telecom 
                                                     
154 Id. at 5527-28, paras. 22-23. 
155 See, e.g., TV Max, Inc., et al., Forfeiture Order, 29 FCC Rcd 8648, 8661, para. 25 (2014) (noting that the 
Commission “has previously rejected inability to pay claims in cases of repeated or otherwise egregious 
violations”); Kevin W. Bondy, Forfeiture Order, 26 FCC Rcd 7840 (EB 2011) (holding that violator's repeated acts 
of malicious and intentional interference outweighed evidence concerning his ability to pay), aff'd, Memorandum 
Opinion and Order, 28 FCC Rcd 1170 (EB 2013), aff'd, Memorandum Opinion and Order, 28 FCC Rcd 16815 (EB 
2013); Whisler Fleurinor, Forfeiture Order, 28 FCC Rcd 1087, 1090, para. 9 (EB 2013) (violator’s demonstrated 
inability to pay outweighed by gravity of multiple intentional violations). 
156 47 U.S.C. § 503(b). 
157 47 CFR § 1.80. 
158 Id. §§ 64.1120, 64.2401(b). 
159 Id. § 1.80. 
160 47 U.S.C. § 504(a). 
 Federal Communications Commission FCC 16-122 
 
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Long Distance, Inc. shall send electronic notification of payment to Johnny Drake at 
Johnny.Drake@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.161  When completing the FCC Form 
159, Central Telecom Long Distance, Inc. should enter the Account Number in block number 23A (call 
sign/other ID) and 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.   
 
49. Any request for 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  20554.162  Questions regarding payment procedures should be 
directed to the Financial Operations Group Help Desk by telephone, 1-877-480-3201, or by e-mail, 
ARINQUIRIES@fcc.gov.  
50. IT IS FURTHER ORDERED that a copy of this Order for Forfeiture shall be sent by 
Certified Mail Return Receipt Requested and First Class Mail to Central Telecom Long Distance, Inc.’s 
attorneys, Michael L. Glaser and Michael D. Murphy, 1720 S. Bellaire St., Suite 607, Denver, CO 80222. 
 
     FEDERAL COMMUNICATIONS COMMISSION 
 
 
     
 
     Marlene H. Dortch 
     Secretary    
 
                                                     
161 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf. 
162 See 47 CFR § 1.1914.