******************************************************** 
                      NOTICE
********************************************************

This document was converted from Microsoft Word.

Content from the original version of the document such as
headers, footers, footnotes, endnotes, graphics, and page numbers
will not show up in this text version.

All text attributes such as bold, italic, underlining, etc. from the
original document will not show up in this text version.

Features of the original document layout such as
columns, tables, line and letter spacing, pagination, and margins
will not be preserved in the text version.

If you need the complete document, download the
Microsoft Word or Adobe Acrobat version.

*****************************************************************



Federal Communications Commission FCC 17-66 
Before the 
Federal Communications Commission 
Washington, DC 20554 
In the Matter of 
Advanced Tel, Inc. 
)
)
)
)
)
File No.:  EB-IHD-14-000148601 
NAL/Acct. No.:  201532080005 
FRN:  0006815898 
FORFEITURE ORDER 
Adopted:  May 30, 2017 Released:  June 8, 2017 
By the Commission: 
I. INTRODUCTION 
1. We impose a penalty of $975,000 against Advanced Tel, Inc. (ATI or Company) for
violating its federal regulatory obligations as a telecommunications service provider for several years by 
failing to file required data and make required contributions to important federal programs.  In ATI’s 
response to our Notice of Apparent Liability for Forfeiture (NAL), in which we proposed a forfeiture 
penalty of $1,588,988, ATI asserted an inability to pay the proposed forfeiture, and argued that its penalty 
should be reduced or cancelled because of the statute of limitations.  ATI, however, did not dispute the 
facts underlying the violations identified in the NAL.  For the reasons discussed below, we reduce the 
proposed forfeiture penalty and assess a forfeiture of $975,000 against the Company. 
II. BACKGROUND
2. ATI is a California-based non-dominant interexchange carrier that provides interstate,
international, and intrastate long distance telecommunications services as a switchless reseller in 25 
states.2  According to ATI, it has provided service since at least 2006.3  In May 2008, the Enforcement 
Bureau (Bureau) of the Federal Communications Commission (Commission) received information 
indicating that ATI failed to comply with certain obligations of telecommunications service providers 
under the Communications Act of 1934, as amended (Act), and the Commission’s rules (Rules).4   
3. Following the Bureau’s investigation, the Commission released the ATI NAL on January
26, 2015, proposing a forfeiture penalty of $1,588,988 for ATI’s apparent violations, including its failure 
to file required data and make required contributions to important federal programs.5    
1 The investigation began under File No. EB-08-IH-5311 and was subsequently assigned the above-captioned file 
number.     
2 See Domestic Section 214 Application Filed for the Transfer of Control of Advanced Tel, Inc. to InterMetro 
Communications, Inc., Public Notice, 22 FCC Rcd 5534 (Wireline Comp. Bur. 2007). 
3 ATI has provided contradictory information on the date it began providing service.  See Advanced Tel, Inc. April 
2015 FCC Form 499-A (on file in EB-IHD-14-00014860) (stating ATI began providing service prior to 1999); 
Letter from Kenneth Fish, Chief Financial Officer, Advanced Tel, Inc., to Rebekah Bina, Attorney Advisor, 
Investigations and Hearings Division, FCC Enforcement Bureau (Mar. 16, 2009) (on file in EB-IHD-15-00018603) 
(stating ATI began providing service in 2006); Advanced Tel, Inc. April 2002 FCC Form 499-A (on file in EB-IHD-
14-00014860) (stating ATI was a new registrant in 2002).   
4 The NAL includes a more complete discussion of the facts and history of this case and is incorporated herein by 
reference.  See Advanced Tel, Inc., Notice of Apparent Liability for Forfeiture, 30 FCC Rcd 833 (2015) (ATI NAL). 
5 Id. at 834-39, paras. 5-18. 
 Federal Communications Commission FCC 17-66 
 2 
4. On February 25, 2015, ATI filed a response to the ATI NAL, and on February 26, 2015, 
ATI filed a supplemental response.6  ATI did not dispute the facts underlying the violations identified in 
the ATI NAL.7  Rather, ATI sought to reduce the forfeiture based on its inability to pay the proposed 
forfeiture in the ATI NAL, or to mitigate the forfeiture amount based on arguments regarding the statute of 
limitations.8    
III. DISCUSSION 
5. The Commission proposed a forfeiture in the ATI NAL in accordance with Section 503(b) 
of the Act, Section 1.80 of the Rules, and the Commission’s Forfeiture Guidelines.9  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.”10  As discussed below, we have 
fully considered ATI’s response and supplemental response to the ATI NAL.  The Company has requested 
a downward adjustment under Section 1.80 of the Rules,11 and provided financial documentation 
sufficient to demonstrate that a downward adjustment is warranted based on the Company’s inability to 
pay the forfeiture proposed in the ATI NAL.  We therefore reduce the $1,588,988 forfeiture proposed in 
the ATI NAL to $975,000.  ATI has also raised a variety of legal arguments relating to the statute of 
limitations and the continuing violation doctrine, but as discussed below, the reduction in the proposed 
forfeiture renders ATI’s arguments moot.   
6. ATI does not dispute our conclusions in the ATI NAL that it willfully and repeatedly 
failed to:  (i) timely and fully contribute to the Universal Service Fund (USF);12 (ii) timely and fully 
contribute to the Telecommunications Relay Service (TRS) Fund;13 (iii) timely and fully pay Local 
Number Portability (LNP) cost recovery mechanism contributions;14 (iv) timely and fully pay required 
regulatory fees;15 and (v) timely file a Quarterly Telecommunications Reporting Worksheet (FCC Form 
499-Q or Quarterly Worksheet).16  We therefore affirm our conclusions in the ATI NAL with respect to 
those violations for the reasons set forth in the ATI NAL.17  ATI challenges our proposed forfeiture 
amount in the ATI NAL based on ATI’s inability to pay the proposed forfeiture amount, as well as our 
application of the statute of limitations under the Act. 
                                                     
6 See Allison D. Rule, Esq., Marashlian & Donahue, LLC, Counsel to Advanced Tel, Inc., Response to Notice of 
Apparent Liability for Forfeiture (Feb. 25, 2015) (on file in EB-IHD-14-00014860) (ATI NAL Response); Allison 
D. Rule, Esq., Marashlian & Donahue, LLC, Counsel to Advanced Tel, Inc., Supplement to Response to Notice of 
Apparent Liability for Forfeiture (Feb. 26, 2015) (on file in EB-IHD-14-00014860) (ATI Supplemental Response). 
7 See ATI NAL Response; ATI Supplemental Response. 
8 See id.  
9 See 47 U.S.C. § 503(b); 47 CFR § 1.80; 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 
Guidelines), recons. denied, Memorandum Opinion and Order, 15 FCC Rcd 303 (1999).  
10 47 U.S.C. § 503(b)(2)(E). 
11 See 47 CFR § 1.80(b)(8), Note to paragraph (b)(8); ATI NAL Response at 31-32; ATI Supplemental Response at  
1-2. 
12 See 47 U.S.C. § 254(d); 47 CFR § 54.706(a). 
13 See 47 U.S.C. § 225; 47 CFR § 64.604(c)(5)(iii). 
14 See 47 U.S.C. § 251(e)(2); 47 CFR § 52.32. 
15 See 47 CFR § 1.1154, 1.1157(b)(1). 
16 See 47 CFR § 54.711. 
17 See ATI NAL, 30 FCC Rcd at 834, 842, paras. 5, 29. 

 Federal Communications Commission FCC 17-66 
 4 
revenues of a company’s affiliated operations and its parent company.29  ATI provided 2010 through 2014 
joint tax returns of ATI and its parent company, InterMetro Communications, Inc. (InterMetro).30  As 
opposed to the unaudited financial statements of ATI, we find that the more reliable and objective 
financial information to assess ATI’s inability to pay the proposed forfeiture are the three joint tax 
returns.31  The Companies deemed that the businesses of ATI and InterMetro were sufficiently 
interconnected to justify a joint tax return.32  The Companies found it appropriate to report its joint 
revenue for purposes of determining its income tax obligation.  We likewise find it appropriate to rely on 
their jointly reported revenue for purposes of determining a forfeiture.33  We reject ATI’s proposed 
forfeiture reduction, and adjust the forfeiture downward based on the 2012 through 2014 joint tax returns 
provided by ATI. 
10. The 2012, 2013 and 2014 joint tax returns indicate that average gross revenue for the 
Companies over the three-year period was  
 to the nearest dollar.34  Based on the joint tax returns that ATI submitted to the 
Commission, we find that the $1,588,988 forfeiture proposed in the ATI NAL should be reduced.  The 
inability to pay adjustment is not designed to reflect the severity of the violation, but is instead intended to 
produce a forfeiture that the violator should be able to afford, and is considered against the totality of the 
circumstances underlying this case.  Based on those considerations, we find that a forfeiture of $975,000, 
which is a rounded figure that is  percent of  
the Companies’ joint average gross revenue from 2012 through 2014 is reasonable and consistent with 
Commission precedent addressing an enforcement subject’s ability to pay a forfeiture.35  
                                                     
29 SM Radio, Inc., 23 FCC Rcd at 2432, para. 10 (citations omitted); Forfeiture Guidelines, 12 FCC Rcd at 17158, 
para. 113 (1997) (stating the Commission will consider the totality of the circumstances, and “[t]he parent 
company's ability to pay, therefore, is relevant in evaluating the subsidiary company’s ability to pay the forfeiture”). 
30 ATI and InterMetro are referred to collectively herein as the Companies. 
31 See, e.g., Coleman Enters., 15 FCC Rcd at 24389, para. 11 (“we consider the most reliable and recent financial 
information that [the company] provided us to be its 1998 federal tax return showing gross revenues”), recons. 
denied, 16 FCC Rcd at 10025, para. 6 (“the Commission has discretion to determine what documentation it 
considers as reliable and objective evidence of ability to pay”); Hoosier Broadcasting Corp., Memorandum Opinion 
and Order, 15 FCC Rcd 8640, 8641, para. 7 (Enforcement Bureau 2000) (claims of inability to pay “should be 
supported by tax returns or other financial statements prepared under generally accepted accounting procedures for 
the most recent three year period.” (citations omitted)). 
32 See ATI 6/18/15 Email, supra, note 24; ATI 11/25/15 Email, supra, note 24.   
33 InterMetro and ATI share corporate headquarters and certain officers and board members.  InterMetro 
Communications, Inc., FCC Form 499 Filer Database Detailed Information for 499 Filer ID Number 826003, 
http://apps.fcc.gov/cgb/form499/499detail.cfm?FilerNum=826003 (last visited June 6, 2017); Advanced Tel, Inc., 
FCC Form 499 Filer Database Detailed Information for 499 Filer ID Number 822008, 
http://apps.fcc.gov/cgb/form499/499detail.cfm?FilerNum=822008 (last visited June 6, 2017).   
34 See ATI 6/18/15 Email, supra, note 24; ATI 11/25/15 Email, supra, note 24.  The tax returns show that gross 
revenues for 2012, 2013 and 2014 were  
, respectively.  See ibid.  
35 See Coleman Enters., 16 FCC Rcd at 10025 (forfeiture not deemed excessive where it represented approximately 
7.96 percent of the violator’s gross revenues); Kenneth Paul Harris, Sr., Forfeiture Order, 15 FCC Rcd 23991, 
23993, para. 7 (Enforcement Bureau 2000) (forfeiture not deemed excessive where it represented approximately 
4.52 percent of the violator’s gross revenues); Hoosier Broadcasting Corporation, 15 FCC Rcd at 8641 (Enf. Bur. 
2002) (forfeiture not deemed excessive where it represented approximately 7.6 percent of the violator’s gross 
revenues); PJB Communications, 7 FCC Rcd at 2089 (forfeiture not deemed excessive where it represented 
approximately 2.02 percent of the violator’s gross revenues). 
 Federal Communications Commission FCC 17-66 
 5 
B. ATI’s Arguments Concerning the Statute of Limitations are Moot 
11. Section 503(b)(6)(B) of that Act provides that no forfeiture penalty shall be imposed if 
“the violation charged occurred more than 1 year prior to the date of issuance of the required notice or 
notice of apparent liability.”36  ATI makes several arguments concerning the statute of limitations.  ATI 
argues:  (a) the Commission attempts to disregard the statute of limitations through the ATI NAL;37 (b) the 
Commission misapplies and confuses the continuing violation doctrine;38 (c) the Commission disregards 
its own precedent, which according to ATI, precludes the application of the continuing violation 
doctrine;39 and (d) by applying the continuing violation doctrine, the Commission violates ATI’s due 
process rights, unlawfully discriminates against ATI, and violates the Administrative Procedures Act.40  
ATI also argues that a tolling agreement between ATI and the Bureau expired on November 19, 2014.  
Thus, ATI argues, the Commission was limited to proposing forfeitures only for violations that began on 
or after January 26, 2014 – one year prior to the issuance of the ATI NAL.41 
12. We need not address those arguments here since they are mooted by the Commission’s 
downward adjustment for ATI’s inability to pay.42   If the Commission were to agree with ATI’s proposal 
for calculating the forfeiture we would assess a total forfeiture of $978,98843 – which is more than the 
forfeiture amount we impose in this Order.  Put another way, we need not address ATI’s arguments 
regarding the statute of limitations and continuing violation doctrine because ATI is already benefitting 
from a lower forfeiture due to the Commission’s acceptance of ATI’s inability to pay the proposed 
forfeiture or even a lower $978,988 forfeiture.  
13. Section 54.713(e) of the Rules requires the application of the American Rule of 
accounting, which applies any payments to oldest debts first.44  The result of applying the American Rule 
of accounting to ATI’s USF assessments and payment failures is that ATI failed to pay any portion of all 
12 USF invoices issued by USAC within the 12 months preceding the ATI NAL.45  Under the theory 
advocated by ATI, we would therefore assess a $20,000 base forfeiture for each USF payment violation,46 
                                                     
36 47 U.S.C. § 503(b)(6)(B).  
37 See ATI NAL Response at 6-17. 
38 See id. at 6-17, 27-28. 
39 See id. at 26-27.  We note that when Congress passed the Act, it explicitly gave the Commission authority to issue 
forfeitures for continuing violations.  See 47 U.S.C. § 503(b)(2).  
40 See ATI NAL Response at 28-31.   
41 See id. at 2-5.   
42 See supra, paras. 7-10. 
43 See infra, paras. 13-16. 
44 See 47 CFR § 54.713(e) (“If a universal service fund contributor pays the Administrator a sum that is less than the 
amount due for the contributor’s universal service contribution, the Administrator shall adhere to the “American 
Rule” . . . . In applying the payment to outstanding principal, the Administrator shall apply such payment to the 
contributor’s oldest past due amounts first.”).   
45 As of December 15, 2014, ATI’s total debt owed for USF assessments was $643,642.66, and between January and 
December 2014, USAC issued 12 monthly invoices assessing ATI a total of $13,412.31 for USF contributions.  See 
E-mail from Michelle Garber, Senior Director of Financial Operations, Universal Service Administrative Company, 
to David Janas, Special Counsel, Investigations and Hearings Division, FCC Enforcement Bureau (January 16, 
2015) (on file in EB-IHD-14-00014860).  Thus, payments made by ATI for 2014 invoices were applied to older 
debts under the American Rule of accounting.  ATI’s claim that all USF obligations incurred after August 2014 had 
been paid in full, see ATI NAL Response at 5-6, is not correct.    
46 See, e.g., OCMC, Inc., Order of Forfeiture, 21 FCC Rcd 10479, 10482, para. 10 (2006) (OCMC Forfeiture 
Order); Globcom, Inc., Notice of Apparent Liability for Forfeiture and Order, 18 FCC Rcd 19893 (2003) (Globcom 
NAL), forfeiture issued, Order of Forfeiture, 21 FCC Rcd 4710, 4722, para. 33 (2006) (Globcom Forfeiture Order). 
 Federal Communications Commission FCC 17-66 
 6 
which multiplied by 12 violations totals $240,000.  Further, consistent with Commission precedent 
concerning forfeitures for USF payment failures,47 we would add an upward adjustment of 50 percent of 
ATI’s highest debt for unpaid USF assessments, $703,655 (one-half of $1,407,310.76 to the nearest 
dollar),48 which would subject ATI to a total forfeiture of $943,655 for USF payment violations.   
14. ATI argues however that when assessing a forfeiture, the Commission cannot take into 
account debt for USF payment failures if USAC transfers the debt to the United States Department of the 
Treasury (Treasury) for collection.49  We find no merit in this argument.  ATI’s USF payment violations 
were not satisfied merely because ATI’s USF debt was transferred to Treasury for collection.  Treasury is 
the collection agent for ATI’s debt to the USF.  Whether USF debt resides with USAC or Treasury is 
irrelevant to the amount of debt that ATI owes to the USF.50  ATI’s debt to the USF is a relevant measure 
of the gravity of ATI’s payment failures for the Commission to consider when determining an appropriate 
forfeiture penalty under the Act, the Rules, and the Forfeiture Guidelines.51 
15. As to ATI’s other federal program payment violations, consistent with Commission 
precedent concerning forfeitures for TRS payment failures, as applied to ATI, a $10,000 base forfeiture 
for ATI’s TRS payment violation within the year preceding the ATI NAL,52 plus an upward adjustment of 
50 percent of ATI’s highest debt for unpaid TRS assessments,53 $5,333 (one-half of $10,665.80 to the 
nearest dollar),54 would subject ATI to a forfeiture of $15,333 for the TRS payment violation.  ATI would 
also be subject to a $10,000 base forfeiture for its LNP payment violation,55 and a $10,000 base forfeiture 
                                                     
47 See, e.g., OCMC Forfeiture Order, 21 FCC Rcd at 10482, para 10; Globcom Forfeiture Order, 21 FCC Rcd at 
4722, para. 33.   
48 See ATI NAL, 30 FCC at 841, para. 22.  Under Section 503(b)(2)(E) of the Act, the Commission must consider a 
violator’s history of prior offenses.  Thus, when assessing an upward adjustment to a forfeiture, see 47 CFR § 
1.80(b)(8), Note to paragraph (b)(8), it is appropriate to consider ATI’s highest debt for unpaid USF assessments, 
which ATI reached in October 2009.      
49 Id. at iv-v, 15-17.   
50 While ATI has challenged the Commission’s enforcement action for ATI’s payment violations, ATI has not 
disputed that it owes the amounts assessed by the USF, TRS, and LNP administrators.  The USF, TRS and LNP debt 
is not subject to any pending administrative review process, and is legally enforceable debt under 31 CFR § 
285.12(c)(3)(i).  ATI’s suggestion that the debt is not legally enforceable is thus without merit.  See ATI NAL 
Response at 15-16 & n. 70.  Moreover, the payment violations identified in the ATI NAL are not violations for 
ATI’s failures to make collection action payments to the Department of the Treasury, see id. at 15, but violations of 
the Commission’s payment rules, as ATI acknowledges, see id. at n.66. 
51 See 47 U.S.C. § 503(b)(2)(E); 47 CFR § 1.80; 12 FCC Rcd 17087. 
52 See, e.g., RB Commc’ns, Inc., d/b/a Starfone, Notice of Apparent Liability for Forfeiture and Order, 27 FCC Rcd 
4393, 4402, para. 26 (2012) (Starfone NAL), forfeiture issued, Forfeiture Order, 29 FCC Rcd 5668 (2014) (Starfone 
Forfeiture Order), recons. denied, Memorandum Opinion and Order, 30 FCC Rcd 4720 (Deputy Chief, 
Enforcement Bureau 2015); ADMA Telecom, Inc., Notice of Apparent Liability for Forfeiture, 24 FCC Rcd. 838, 
853 para. 35 (2009) (ADMA NAL), forfeiture issued, Forfeiture Order, 26 FCC Rcd 4152 (2011) (ADMA Forfeiture 
Order); Globcom NAL, 18 FCC Rcd at 19904, para. 29. 
53 See, e.g., PTT Phone Cards, Inc., Notice of Apparent Liability for Forfeiture, 29 FCC Rcd 11531, 11544, para. 32 
(2014), forfeiture issued, 30 FCC Rcd 14701 (2015); Starfone NAL, 27 FCC Rcd at 4402, para. 26; ADMA NAL, 24 
FCC Rcd at 853, para. 35; Globcom NAL, 18 FCC Rcd at 19904, para. 29. 
54 See ATI NAL, 30 FCC at 841, para. 24.   
55 See, e.g., PTT Phone Cards, 29 FCC Rcd at 11544, para. 34; Kajeet, Inc., Notice of Apparent Liability for 
Forfeiture and Order, 26 FCC Rcd 16684, 16695, para. 24 (2011), consent decree adopted, Order, 30 FCC Rcd 
10608 (Enforcement Bureau 2015); Telrite Corp., Notice of Apparent Liability for Forfeiture and Order, 23 FCC 
Rcd 7231, 7245, para. 34 (2008) consent decree adopted, Order, 27 FCC Rcd 4110 (2012).  
 Federal Communications Commission FCC 17-66 
 7 
for its regulatory fee payment violation.56   
16. Thus, if the Commission were to agree with ATI’s proposed forfeiture methodology,57 
the total forfeiture assessment for USF and other federal program payment violations as discussed above 
would be $978,988, which is greater than the forfeiture amount we assess in this Order.  Accordingly, 
ATI’s arguments concerning the statute of limitations and the continuing violation doctrine are dismissed 
as moot.   
IV. CONCLUSION 
17. After considering the relevant statutory factors, the Commission’s Rules, and the 
Commission’s Forfeiture Guidelines, we find that ATI is liable for a total forfeiture of $975,000.  Based 
upon the evidence before us, a forfeiture of $975,000 properly reflects the nature, extent, and gravity of 
the violations and, with respect to the Company, its degree of culpability, history of prior offenses, and 
ability to pay. 
V. ORDERING CLAUSES 
18. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Act,58 and 
Section 1.80 of the Rules,59 Advanced Tel, Inc. IS LIABLE FOR A MONETARY FORFEITURE in 
the amount of nine hundred seventy five thousand dollars ($975,000) for willfully and/or repeatedly 
violating Sections 251(e)(2) and 254(d) of the Communications Act and Sections 1.1154, 1.1157, 52.32, 
54.706, 54.711, and 64.604(c)(5)(iii) of the Commission’s Rules.   
19. 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 of this Forfeiture Order.60  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.61   
20. 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.  Advanced Tel, Inc. 
shall send electronic notification of payment to Jeffrey Gee at Jeffrey.Gee@fcc.gov, Kalun Lee at 
Kalun.Lee@fcc.gov, and David Janas at David.Janas@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.62  When completing the 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 completed Form 159) must be 
mailed to the Federal Communications Commission, P.O. Box 979088, St. Louis, MO 
                                                     
56 See, e.g., PTT Phone Cards, 29 FCC Rcd at 11544, para. 33; Starfone NAL, 27 FCC Rcd at 4402, para. 27.  If the 
Commission were to limit the scope of violations only to violations that began within one year of the ATI NAL, as 
ATI argues, ATI would not be subject to a $50,000 forfeiture for their failure to timely file its Quarterly Worksheet 
due November 1, 2013, which it did not file until January 27, 2014, nearly three months late.  Cf. ATI NAL, 30 FCC 
at 839, 842, paras. 18, 27. 
57 See ATI NAL Response at 2. 
58 47 U.S.C. § 503(b). 
59 47 CFR § 1.80. 
60 Id. 
61 47 U.S.C. § 504(a). 
62 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf. 
 Federal Communications Commission FCC 17-66 
 8 
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 From 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. 
21. Any request for making full payment over time under an installment plan should be sent 
to:  Chief Financial Officer – Financial Operations, Federal Communications Commission, 445 12th 
Street, SW, Room 1-A625, Washington, DC 20554.63  Advanced Tel, Inc. shall send electronic 
notification of a request to Jeffrey Gee at Jeffrey.Gee@fcc.gov, Kalun Lee at Kalun.Lee@fcc.gov, and 
David Janas at David.Janas@fcc.gov on the date said request is made.  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. 
22. IT IS FURTHER ORDERED that, pursuant to Sections 4(i), 225, 251(e)(2) and 254(d) 
of the Act, and sections 1.1154, 1.1157(b)(1), 52.32, 54.706(a), 64.604(c)(5)(iii) of the Rules,64 within 90 
days Advanced Tel, Inc. SHALL PAY all overdue assessments for the Universal Service Fund, the 
Telecommunications Relay Service Fund, the Local Number Portability cost recovery mechanism, and 
federal regulatory fees. 
23. IT IS FURTHER ORDERED that a copy of this Forfeiture Order shall be sent by first 
class mail and certified mail, return receipt requested, to counsel for Advanced Tel, Inc., Allison D. Rule, 
Esq., Marashlian & Donahue, LLC, 1420 Spring Hill Road, Suite 401, McLean, Virginia 22102. 
 
 
FEDERAL COMMUNICATIONS COMMISSION 
 
 
 
 
Marlene H. Dortch 
Secretary 
                                                     
63 See 47 CFR § 1.1914. 
64 47 U.S.C. §§ 154(i), 225, 251(e)(2), 254(d); 47 CFR §§ 1.1154, 1.1157(b)(1), 52.32, 54.706(a), 64.604(c)(5)(iii).