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 Federal Communications Commission FCC 18-54 
 
Before the 
Federal Communications Commission 
Washington, DC 20554 
 
In the Matter of 
 
Tele Circuit Network Corporation 
) 
) 
) 
) 
) 
 
 
File No.:  EB-TCD-17-00023953 
NAL/Acct. No.:  201832170002 
FRN:  0008800690 
 
NOTICE OF APPARENT LIABILITY FOR FORFEITURE 
 
Adopted:  April 27, 2018 Released:  April 27, 2018 
 
By the Commission:  Commissioner O’Rielly approving in part and dissenting in part. 
 
I. INTRODUCTION 
1. The Federal Communications Commission (FCC or Commission) proposes a penalty of 
$5,323,322 against Tele Circuit Network Corporation (Tele Circuit or Company) for apparently willfully 
and repeatedly violating Sections 201(b) and 258 of the Communications Act of 1934, as amended (Act), 
and Sections 1.17 and 64.1120 of the Commission’s rules (Rules).  Specifically, we find that Tele Circuit 
apparently:  (i) engaged in deceptive marketing practices; (ii) changed the preferred telecommunications 
service providers of consumers without proper authorization verified in accordance with the Rules, 
including but not limited to by misleading consumers as to the Company’s identity or the nature of the 
Company’s proposed offerings (commonly known as “slamming”); (iii) provided false and misleading 
material information to the Commission with respect to the foregoing practices; and (iv) placed 
unauthorized charges (commonly known as “cramming”) for its long distance service on consumers’ 
telephone bills.  We also find that Tele Circuit failed to fully respond to an Enforcement Bureau (Bureau) 
letter of inquiry (LOI), in violation of a Commission order.   
2. We take this action after reviewing numerous complaints against Tele Circuit, including 
many filed by or on behalf of elderly or low-income consumers alleging that the Company engaged in 
slamming and cramming.  Slamming and cramming are deceptive practices that cause consumers to spend 
significant time and effort to return to their preferred carriers, to remove unauthorized charges from their 
bills, and to file complaints with law enforcement agencies.  In some instances, the apparent misconduct 
of Tele Circuit left vulnerable consumers without telephone service for extended periods of time—with 
Tele Circuit allegedly refusing to reinstate service until the crammed charges were paid in full.  Further, it 
appears that some of the third-party verification recordings that Tele Circuit provided to the Commission 
as “evidence” of consumer authorization were fabricated.  Fabricating evidence, submitting false and 
misleading information to the Commission in violation of Section 1.17 of the Rules, or failing to fully 
respond to Commission orders requesting information, disrupts the critical law enforcement functions of 
this agency and hinders our investigations and ability to address consumer complaints.  Based on our 
review of the evidence surrounding these apparent violations, including consumer complaints that 
demonstrate that Tele Circuit’s misconduct was widespread and intentional, we propose a monetary 
forfeiture of $5,323,322.  We also note that in light of Tele Circuit’s egregious misconduct and the nature 
of the apparent violations, we will consider initiating proceedings against the Company to revoke its 
Commission authorizations after assessing the Company’s response to this Notice of Apparent Liability 
for Forfeiture (NAL).  
   
 Federal Communications Commission FCC 18-54 
 
 2 
II. BACKGROUND 
3. Tele Circuit1 is a non-facilities based interexchange carrier authorized by the 
Commission to provide domestic and international long distance telecommunications service.2  The 
Bureau reviewed numerous complaints against Tele Circuit that consumers filed with the Commission, 
state regulatory agencies, and the Better Business Bureau (BBB).3  The complainants, identified in the 
Appendix, contended that Tele Circuit switched their (or their elderly relative’s) long distance service 
from their preferred carrier to Tele Circuit without authorization, and/or charged them for service they did 
not request.  Many of the complainants explained that Tele Circuit’s telemarketers mispresented their 
identity4 by stating that they were calling on behalf of the consumer’s current telecommunications service 
provider.  Some complainants stated that Tele Circuit offered a discount on the consumer’s existing 
service or discussed a (fictitious) government program for low-income individuals or senior citizens that, 
Tele Circuit claimed, could lower the cost of service.5  Tele Circuit provided third-party verification 
(TPV) recordings,6 which are supposed to provide evidence that customers assented to changing their 
                                                     
1 Tele Circuit identified its address as 1815 Satellite Blvd., Suite 504, Duluth, GA 30097.  Tele Circuit’s President is 
Ashar Syed; its CEO is Syed’s wife, Pobish Khan.  See E-mail and Response Document from Yara Paredes, 
Manager, Tele Circuit Network Corporation, to Mika Savir, Attorney Advisor, Telecommunications Consumers 
Division, FCC Enforcement Bureau (May 3, 2017, 15:47 EDT, 15:50 EDT, 15:53 EDT) (LOI Response).  Syed 
previously worked for another toll reseller, America’s Tele-Network Corp.  See Letter from Lance J.M. Steinhart, 
Attorney for Tele Circuit Network Corp., to Marlene H. Dortch, Secretary, FCC (Aug. 25, 2016).  America’s Tele-
Network Corp. terminated its operations as part of a settlement with the Florida Public Service Commission.  See 
State of Florida, Public Service Commission, Memorandum (Apr. 21, 2004) (on file in EB-TCD-17-00023953).  
2 See ITC-214-20030417-00193 (granted May 16, 2003). 
3 Twenty-seven of these complaints involve apparent slamming and cramming violations that took place within the 
12-month period prior to the release of the NAL.  These complaints are identified in the Appendix.  Other 
complaints discussed in the NAL, but not listed in the Appendix and described as “not in Appendix,” arose from 
slams or crams before the 12-month period prior to the release date of the NAL.  Such complaints are not used to 
calculate the proposed forfeiture but are included in the NAL to illustrate Tele Circuit’s past conduct and to support 
the upward adjustment to the forfeiture amount. 
4 In response to the Bureau’s instruction to identify the companies with which Tele Circuit contracts for marketing 
services, Tele Circuit stated that it conducts its own telemarketing.  See LOI Response at 2. 
5 See, e.g., Complaint from P. Ballentine (filed May 17, 2017); Complaint from J. Nichols (filed Jan. 2, 2017) (not in 
Appendix); Complaint from T. Hickman (filed Feb. 22, 2017) (not in Appendix); Complaint from P. Irving (filed 
May 20, 2016) (not in Appendix) (“[m]y elderly mother received a phone call from Tele Circuit.  They told her that 
they were affiliated with AT&T and could give her a senior citizen discount on her phone.”); Complaint from C. 
Carroll on behalf of F. Byrd (filed June 26, 2017) (“my dad received a call from Tele Circuit Network Corp[;] they 
asked . . . his name and they told him they were AT&T and were offering him a Sr. Citizen Discount . . . Can you 
help him and can you stop this company from preying on Senior Citizens?”); Complaint from D. Gourley (filed Apr. 
27, 2016) (not in Appendix) (“[Tele Circuit] is calling seniors saying that they are affiliated with the Government 
and can lower people’s phone bills.”); Complaint from  (filed Apr. 27, 2016) (not in Appendix) (“contacted 
by someone claiming that the FCC passed a regulation where senior citizens could switch their phone service to Tele 
Circuit for a lower rate”); Complaint from K. Dale (filed Apr. 4, 2016) (not in Appendix) (“received a call from a 
company called Tele Circuit claiming to be with AT&T stating that they would be able to lower her lifeline credit”); 
Complaint from M. Arellano (filed Feb. 5, 2016) (not in Appendix) (“my 90 year old mother . . . was called by a Mr. 
Murphy from Tele Circuit and told there was a new govt program for seniors that would give her a 38 [dollar] credit 
on her phone bill . . . they proceeded to change her over from ATT without her knowledge or consent and sent her a 
bill”); Complaint from  (filed June 21, 2016) (not in Appendix) (“receiv[ed] a call from Tele Circuit 
Network regarding a Government Assistance program for senior citizens that included caller ID, call waiting, 
unlimited local calls and 250 minutes of long distance calls, all for $38 a month”).   
6 Third party verification (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.  47 CFR § 64.1120(c)(3).  TPV must comply with Section 
64.1120(c)(3) of the Commission’s rules.  Id. 
   
 Federal Communications Commission FCC 18-54 
 
 3 
long distance service from their existing carriers to Tele Circuit.7  Complainants who listened to the 
recordings stated that the TPVs were fabricated.8    
4. Tele Circuit utilized a billing aggregator, Billing Concepts, Inc. (dba USBI), to place 
charges on consumers’ local exchange carrier (LEC) bills.9  One such LEC was AT&T.  In August 2016, 
AT&T agreed to cease billing for most third-party service providers as part of a settlement with the 
Commission.10  AT&T stopped accepting charges for third parties billing through USBI as of November 
30, 2016, and stopped placing third-party charges on its customers’ bills as of January 5, 2017.11  
Subsequently, Tele Circuit started billing consumers directly for its service.  Many consumers who 
received direct bills from Tele Circuit stated that they had never heard of the Company and did not 
understand why Tele Circuit was billing them given that they were AT&T customers and never intended 
to change their service.12  Some consumers complained that Tele Circuit billed them for unauthorized 
charges multiple times over the course of many months, despite being informed by the consumer that the 
charges were improper.13    
5. After reviewing the complaints received by the Commission about Tele Circuit’s 
practices, the Bureau initiated an investigation of Tele Circuit and issued an LOI to the Company on 
March 28, 2017.14  The LOI instructed the Company to produce various documents and records, including 
evidence that it had complied with the Commission’s verification procedures prior to switching 
consumers’ long distance service providers.  Tele Circuit responded to the LOI on May 3, 2017, but failed 
to fully answer the Bureau’s inquiries and provide all requested documents.  In particular, Tele Circuit 
failed to provide proof that the complainants listed in the LOI had provided Tele Circuit authorization to 
switch their long distance carrier.15   
                                                     
7 See E-mails from Yara Paredes, Manager, Tele Circuit Network Corporation, to Erica McMahon and Mika Savir, 
Attorney Advisors, Telecommunications Consumers Division, FCC Enforcement Bureau (June 9, 2017, 15:15 EDT, 
15:17 EDT, 15:18 EDT; 15:19 EDT, 15:21 EDT, 15:22 EDT, 15:23 EDT; June 19, 2017, 15:48 EDT, 15:52 EDT, 
15:53 EDT; July 11, 2017, 10:05 EDT; Nov. 22, 2017, 11:17 EDT; Dec. 29, 2017, 10:11 EDT, 13:26 EDT; Jan. 26, 
2018, 12:40 EDT; Feb. 19, 2018, 13:04 EDT). 
8 See, e.g., Complaint from J. Castaneda (filed Mar. 8, 2017); Complaint from P. Morales (filed Apr. 5, 2017); 
Complaint from O. Valtierra (filed Oct. 6, 2016); Complaint from M. Casales (filed Feb. 1, 2017); Complaint from 
M. Hernandez (filed Mar. 13, 2017); Complaint from L. Arellano (filed Oct. 22, 2017). 
9 See LOI Response at 2.   
10 AT&T Services, Inc., Order and Consent Decree, 31 FCC Rcd 8540, 8547, para. 16(a) (EB 2016). 
11 See AT&T Service, Inc. Consent Decree 150-Day Compliance Report at 2 (Jan. 5, 2017) (on file in EB-TCD-15-
00019021). 
12 See, e.g., Complaint from L. Cordero (filed Mar. 9, 2017) (not in Appendix); Complaint from D. Perez-Benitoa 
(filed Apr. 6, 2017) (not in Appendix); Complaint from F. Salinas (filed Sept. 6, 2016) (not in Appendix); Complaint 
from D. Cowan (filed June 12, 2017). 
13  See, e.g., Complaint from C. De La Cruz (filed Mar. 10, 2017) (not in Appendix) (“[I] have been having 
problems for 4 months now with a telecommunications services on my home phone, i am 76 yrs old and i call them 
and they say the charges will no longer be on my phone bill but for months now it's still on there[.]”); Complaint 
from A. Viera (filed May 10, 2017) (“Tele Circuit LD has changed my long distance carrier without my 
authorization and has been charging me a fee since Dec. 2016 till today 5/10/17[.]”). 
14 See Letter from Richard A. Hindman, Chief, Telecommunications Consumers Division, FCC Enforcement 
Bureau, to Tele Circuit Network Corporation (Mar. 28, 2017) (on file in EB-TCD-17-00023953) (LOI). 
15 After submitting an incomplete response to the LOI on May 3, 2017, Tele Circuit requested an extension of time 
to fully respond, and the Bureau granted a one-week extension.  See E-mail from Mika Savir, Attorney Advisor, 
Telecommunications Consumers Division, FCC Enforcement Bureau, to Yara Paredes, Manager, Tele Circuit 
Network Corporation (May 3, 2017, 8:29 EDT).  After Tele Circuit failed to provide any evidence of consumer 
authorizations by the extended due date, the Bureau asked whether the Company intended to submit any TPV 
(continued….) 

   
 Federal Communications Commission FCC 18-54 
 
 5 
• “Elderly Abuse Scam.  Tele Circuit called my 87-year old father and switched his phone 
service from AT&T to Tele Circuit,” wrote Complainant  daughter.  “[T]hey 
scammed him on the day of his last sibling’s funeral.  He has had the same phone number 
with AT&T for about 70 years and now he has NO phone service. . . .  Please help us.  
Plus [his] phone number is on the Do Not Call list.  How can this happen?”21 
• Complainant  brother filed a complaint against Tele Circuit, stating “[m]y sister 
who is 90% blind, extremely mentally handicapped, being treated for cancer, on medicare 
and medicaid, was contacted by this company called Tele Circuit concerning her phone 
service.  They flim-flammed her into canceling her service with AT&T which she’s had 
for 20 years or more.”  He went on to explain, “[Tele Circuit] arranged to get AT&T 
canceled and never provided one second of phone service to her.  And then sent her a bill 
for $34.00.  She’s been without her phone for almost a week.  I called Tele Circuit to 
explain the situation and . . . they told me to pay the $34.00 and if I didn’t they would 
continue billing her.”22 
III. DISCUSSION 
7. The Commission finds that Tele Circuit apparently willfully and repeatedly violated 
Sections 201(b) and 258 of the Act,23 and Sections 1.17 and 64.1120 of the Rules.24  Specifically, as 
discussed more fully below, we find that Tele Circuit apparently violated:  (i) Section 201(b), for 
engaging in deceptive marketing practices and relying on fabricated TPV recordings; (ii) Section 258 of 
the Act and Section 64.1120 of the Rules, for submitting requests to switch consumers’ preferred long 
distance carriers without authorization verified in compliance with the Commission’s verification 
procedures; (iii) Section 1.17 of the Rules for providing false and misleading material information to the 
Commission; (iv) Section 201(b) of the Act for placing unauthorized charges on consumers’ telephone 
bills;25 and (v) a Commission order to produce certain information and documents related to Tele 
Circuit’s business practices.  As discussed below, we base these findings on the numerous consumer 
complaints alleging consistent patterns of deceptive behavior by Tele Circuit, and on the Company’s 
misconduct during the course of the investigation, which apparently violate the Act and the Rules.  For 
the reasons discussed below, we find these complaints to be credible.  Accordingly, we propose a 
forfeiture of $5,323,322 for the apparent violations that occurred within the 12 months prior to the release 
date of this NAL.26   
A. Tele Circuit Deceptively Marketed its Services in Apparent Violation of Section 
201(b) of the Act 
8. Section 201(b) of the Act states, in pertinent part, that “[a]ll charges, practices, 
classifications, and regulations for and in connection with [interstate or foreign] communication service 
[by wire or radio], shall be just and reasonable, and any such charge, practice, classification, or regulation 
                                                     
21 Complaint from  (filed Sept. 29, 2016) (not in Appendix). 
22 Complaint from  (filed May 2, 2016) (not in Appendix).  
23 47 U.S.C. §§ 201(b), 258. 
24 47 CFR §§ 1.17, 64.1120. 
25 See Protecting Consumers from Unauthorized Carrier Changes and Related Unauthorized Charges, Notice of 
Proposed Rulemaking, 32 FCC Rcd 6022, 6028-29, n.48 (observing that notwithstanding the Notice of Proposed 
Rulemaking seeking comment on additional rules to protect consumers from slamming and cramming, the 
Commission continues to have authority under Section 201(b) of the Act to take enforcement action against 
cramming violations). 
26 The Appendix identifies the 33 complaints, evidencing 55 apparent violations of the Act and Rules that underlie 
the proposed forfeiture.  
   
 Federal Communications Commission FCC 18-54 
 
 6 
that is unjust or unreasonable is declared to be unlawful.”27  The Commission has held that unfair and 
deceptive marketing practices by interstate common carriers generally, and misrepresentations about a 
carrier’s identity or the nature of its service to obtain a consumer’s authorization to change his or her 
preferred long distance carrier specifically, constitute unjust and unreasonable practices under Section 
201(b) of the Act.28    
9. The evidence shows that Tele Circuit repeatedly made misrepresentations to 
complainants (or the elderly or infirm relatives on whose behalf complainants were filing). Tele Circuit 
deceived them into believing that the Company was calling on behalf of the customer’s existing 
telecommunications provider and that the purpose of the call was to seek authorization to change the 
consumer to a new service with their existing provider (e.g., by offering a discounted rate).  For example:  
• Complainant Cortez stated, “Tele Circuit claimed to be a billing extension for AT&T and 
has been charging me from an account I never opened. . . .  When confronted with the 
situation, Tele Circuit . . . continues to send bills to my current address stating that I must 
pay the pending charges prior to closing the account.  When I asked for proof of 
authorization . . . Tele circuit played a recording from a woman with an entirely different 
name from my own.”29  When Ms. Cortez informed Tele Circuit that the recording was 
not her authorization, they still insisted she pay the bill.   
• Complainant Beal explained, “Tele Circuit will not release the block on my line.  I am 
trying to get back to Global Connection.  Tele Circuit lied about being Global 
Connection.  I really want to stay with Global.”30   
• Complainant Jones said she received a call from Tele Circuit pretending to be her 
Lifeline provider even though she receives her Lifeline service through Global 
Connection.  The Tele Circuit representative claimed to be recertifying her Lifeline 
service but, instead, switched her carrier to Tele Circuit.31   
• Complainant Nichols also received a call from a Tele Circuit representative about a so-
called “Government program to cut in half the cost of [his] landline home phone.”32  “I 
am a 75 year old man who had had AT&T phone service for many years.  I . . . did not 
realize I was authorizing him to switch my service from AT&T until I received a bill 
from a company called Tele Circuit. . . .  It concerns me that Tele Circuit has the ability 
to change my service provider based on an unsolicited phone conversation in which it 
                                                     
27 47 U.S.C. § 201(b).  
28 See Business Discount Plan, Inc., Order of Forfeiture, 15 FCC Rcd 14461, 14469, para. 17 (2000), aff’d in 
relevant part on reconsideration, 15 FCC Rcd 24396 (2000); Advantage Telecommunications Corp., Notice of 
Apparent Liability for Forfeiture, 28 FCC Rcd 6843, 6849, para. 16 (2013) (Advantage NAL), Forfeiture Order, 32 
FCC Rcd 3723, 3725, para. 7 (2017) (Advantage Forfeiture Order); Preferred Long Distance, Inc., Notice of 
Apparent Liability for Forfeiture, 27 FCC Rcd 16489, 16491, para. 7 (2012) (Preferred NAL), Forfeiture Order, 30 
FCC Rcd 13711, 13718, para. 16 (2015) (Preferred Forfeiture Order); Central Telecom Long Distance, Inc., Notice 
of Apparent Liability for Forfeiture, 29 FCC Rcd 5517, 5520, para. 7 (2014) (Central NAL), Forfeiture Order, 31 
FCC Rcd 10392, 10403, para. 25 (2016) (Central Forfeiture Order); U.S. Telecom Long Distance, Inc., Notice of 
Apparent Liability for Forfeiture, 29 FCC Rcd 823, 825–26, para. 7 (2014) (USTLD NAL), Forfeiture Order, 31 FCC 
Rcd 10413, 10424, para. 25 (2016) (USTLD Forfeiture Order); Consumer Telcom, Inc., Notice of Apparent Liability 
for Forfeiture, 28 FCC Rcd 17196, 17198-99, para. 7 (2013) (CTI NAL), Forfeiture Order, 31 FCC Rcd 10435, 
10446, para. 25 (2016) (CTI Forfeiture Order). 
29 Complaint from K. Cortez (filed Mar. 15, 2017) (not in Appendix).  
30 Complaint from P. Beal (filed Apr. 11, 2017) (not in Appendix). 
31 Complaint from K. Jones (filed Apr. 26, 2017) (not in Appendix). 
32 Complaint from J. Nichols (filed Jan. 2, 2017) (not in Appendix). 
   
 Federal Communications Commission FCC 18-54 
 
 7 
was not clear to me what they were going to do.  They should be required to clearly 
identify themselves as not being a representative of my current service provider.”33   
• Complainant Irving also stated that Tele Circuit deceptively marketed its service.  “[M]y 
elderly mother received a phone call from Tele Circuit.  They told her that they were 
affiliated with AT&T and could give her a senior citizen discount on her phone.  When 
she tried to go back to AT&T, she found they had frozen the phone number and refused 
to release it to AT&T.”34 
10. Numerous other complainants reported receiving calls from Tele Circuit telemarketers 
who misrepresented their identity.35  The complaints regarding Tele Circuit’s deceptive marketing span 
the course of over a year.36  Given the volume of complaints and the duration of Tele Circuit’s improper 
practices, it appears that Tele Circuit was aware of and benefited financially from its deceptive marketing 
scheme.  Accordingly, we find Tele Circuit in apparent violation of Section 201(b) of the Act for 
engaging in deceptive practices by representing to complainants that it was calling on behalf of their 
existing long distance carriers and/or failing to disclose the true purpose of its marketing call. 
B. Tele Circuit Relied on Fabricated Audio Recordings as Evidence of Consumer 
Authorization in Apparent Violation of Section 201(b) of the Act and Provided False 
and Misleading Material Information to the Commission in Apparent Violation of 
Section 1.17 of the Rules 
11. Section 201(b) of the Act prohibits carriers from engaging in unjust and unreasonable 
practices, and the Commission has found that deceptive, fraudulent practices, including providing false or 
fabricated TPV recordings to consumers or the Commission, are such unlawful practices.37 
12. Many complainants stated in their complaints or to Bureau staff that the voice on the 
TPV recording was not theirs, or that they did not otherwise have any conversation with Tele Circuit or 
its third-party verifier.  For example:  
                                                     
33 Id. 
34 Complaint from P. Irving (filed May 20, 2016) (not in Appendix). 
35 See, e.g., Complaint from D. Hand (filed Feb. 18, 2016) (not in Appendix) (“I was tricked into changing my 
phone service to this company.  They misrepresented themselves, making me believe that they were AT&T.  I now 
have no phone!”); Complaint from M. Deason (filed Mar. 7, 2016) (not in Appendix) (“I received a call I thought 
was AT&T, my present landline provider offering [a] good deal on phone service.”); Complaint from R. Kelley 
(filed Mar. 17, 2016) (not in Appendix) (“This company scammed me by having someone call on the phone that I 
could not understand and talked so fast I could not hear what he was asking me.  He said he was affiliated with 
AT&T and he was offering me a cheaper monthly phone bill.”); Complaint from R. Daniel (filed Mar. 30, 2016) 
(not in Appendix) (“[M]y 90 year old mother was the victim of a ‘slam.’  She was contacted on her home phone by a 
[Tele Circuit] agent representing himself as being with AT&T.  He scammed my mother into changing phone 
service without her knowledge.”); Complaint from  (filed Jan. 20, 2017) (not in Appendix) (“. . . 
received a call from Tele Circuit stating to be from AT&T offering [her] a lower price with AT&T . . . then found 
out that it was not AT&T that called her.”).     
36 See, e.g., Complaint from D. Hand (filed Feb. 18, 2016) (not in Appendix); Complaint from R. McLeod (filed Jan. 
2, 2018).    
37 See Optic Internet Protocol, Inc., Notice of Apparent Liability for Forfeiture, 29 FCC Rcd 9056, 9061, para. 14 
(2014) (Optic NAL), Forfeiture Order, 30 FCC Rcd 2539 (2015) (Optic Forfeiture Order); see also OneLink 
Communications, Inc., TeleDias Communications, Inc., TeleUno, Inc., Cytel, Inc., Notice of Apparent Liability for 
Forfeiture, 31 FCC Rcd 1403, 1420, para. 16 (2016) (OneLink NAL); United Telecom, Inc., 27 FCC Rcd 16499, 
16503, para. 11 (2012) (United NAL) (each finding a carrier in apparent violation of Section 201(b) for relying on 
fabricated TPV recordings).  
   
 Federal Communications Commission FCC 18-54 
 
 8 
• Upon learning that her carrier was switched from AT&T to Tele Circuit and listening to 
the TPV recording purportedly showing she had authorized the switch, Complainant 
Castaneda stated, “[t]his recording is actually rather horrifying.  It is my voice (I do speak 
Spanish) but I NEVER agreed to change my local toll/long distance service.  I believe I 
was confirming my identity for another purpose . . . I repeat; in the actual phone call I 
was NOT being asked to switch my long distance carrier.  This is a ‘doctored’ recording. 
I hope these scoundrels are shut down.”38 
• Complainant Morales similarly alleged the TPV recording was a fake.  “I found charges 
from Qwest Long Distance [on behalf of Tele Circuit] in my home phone and I never 
requested that service . . . [T]hey play to me a recording where I say YES answering 
questions where they ask if I want the service.  The YES sounds like my voice, but then 
they ask for my maiden name and a different voice answered my married name, no[t] my 
maiden name.  They do not know my maiden name because I never answered those 
questions accepting the service.”39   
• Complainant Valtierra was also adamant that she did not authorize Tele Circuit as her 
long distance provider.  Ms. Valtierra contacted Tele Circuit and was played an audio 
recording of the person who allegedly requested the service.  “I explained the answers to 
‘maiden’ name or ‘birthday’ were incorrect.  I told him to cancel and that I wanted a 
refund of the $6.53 charge to USBI on behalf of Tele Circuit.”40   
• Tele Circuit switched Complainant Casales’ carrier without his authorization.  After 
returning to his preferred provider, Mr. Casales received a bill from Tele Circuit and 
immediately contacted the Company.  “It is sort of a scam because they played a 
recording in which a female with a different name than mine was authorizing them to be 
my long distance carrier.”  Tele Circuit informed Mr. Casales that any adult over 18 years 
old can make any changes to the account.  “This is a scam and it is extremely abusive and 
unprofessional as now they want me to pay that fee.”41 
• Complainant Hernandez stated that after receiving a bill from Tele Circuit, she contacted 
the Company to explain that she did not know Tele Circuit existed and that she does not 
make long distance calls from her house.  “The representative asked me if I wanted to 
hear a recording proving that I requested the service and I said yes.  As I was hearing the 
recording it seemed to me that the whole thing was made up because of the way the 
questions were answered.  One of the questions asked in the recording was my mother’s 
maiden name and the answer was not correct. . . .  I believe legal action needs to be taken 
against this company.”42 
• Complainant Arellano stated that she never spoke to Tele Circuit or authorized the 
switching of her long distance company.  Ms. Arellano’s son listened to the TPV 
recording with his mother and said that the maiden name provided on the recording was 
wrong.  “In addition, the recording is suspicious because the man is speaking Spanish so 
fast that my mom and I can barely understand what he is saying.  My mom would never 
                                                     
38 Complaint from J. Castaneda (filed Mar. 8, 2017). 
39 Complaint from P. Morales (filed Apr. 5, 2017). 
40 Complaint from O. Valtierra (filed Oct. 6, 2016). 
41 Complaint from M. Casales (filed Feb. 1, 2017). 
42 Complaint from M. Hernandez (filed Mar. 13, 2017).  
   
 Federal Communications Commission FCC 18-54 
 
 9 
speak to someone on the phone who was talking that fast.  I believe the recording is a 
fraud.”43     
13. Although Tele Circuit issued general denials of wrongdoing in response to some 
consumer complaints, the Company has not, to date, attempted to refute specific allegations made by 
consumers about evidence suggesting that certain TPVs were fabricated.  For instance, in its response to 
Complainant Valtierra’s assertion that the voice portraying her on Tele Circuit’s TPV did not accurately 
state her maiden name and birthday, Tele Circuit simply stated that it “did not commit fraud” against the 
complainant.44  Tele Circuit did not otherwise address the specific issues that Complainant Valtierra 
raised about the TPV nor did it specifically refute the allegation that the TPV was fabricated.45  Tele 
Circuit issued an identical denial in response to specific allegations made by other complainants.46  Tele 
Circuit’s bald assertions that it “did not commit fraud” are simply not enough to overcome its failure to 
refute any of the specific allegations raised by consumers of what actually occurred.  We, therefore, 
conclude that Tele Circuit presented six fabricated audio recordings47 to the Commission as evidence of 
consumer authorization in apparent violation of Section 201(b) of the Act.48   
14. Based on the evidence discussed above, we find that Tele Circuit also apparently violated 
Section 1.17 of the Rules by submitting fabricated TPVs to the Commission.  Section 1.17(a)(2) of the 
Rules provides that no person may provide to the Commission, in any written statement of fact, “material 
factual information that is incorrect or omit material information . . . without a reasonable basis for 
believing that any such material factual statement is correct and not misleading.”49  This requirement is 
intended in part to enhance the effectiveness of the Commission’s enforcement efforts.50  Thus, even 
absent an intent to deceive, a false statement may constitute a violation of Section 1.17 if provided 
without a reasonable basis for believing that the information is truthful and not misleading.51   
15. In response to the Bureau’s request for evidence of consumer authorization, Tele Circuit 
submitted apparently fabricated TPV recordings to the Commission, despite receiving complaints over the 
                                                     
43 Complaint from L. Arellano (filed Oct. 22, 2017). 
44 Response from Tele Circuit to Complaint from O. Valtierra (on file in EB-TCD-17-00023953). 
45 See id. 
46 See, e.g., Response from Tele Circuit to Complaint from M. Casales (on file in EB-TCD-17-00023953). 
47 Tele Circuit relied on apparently fabricated TPV recordings for Complainants J. Castaneda; O. Valtierra; M. 
Casales; P. Morales; M. Hernandez; and L. Arellano.  We do not propose a forfeiture for each of the Section 201(b) 
violations; rather, we propose a forfeiture for Tele Circuit’s violations of Section 1.17, which were perfected when it 
submitted each apparently fabricated TPV to the Commission.  See infra para. 29; see also Appendix (including the 
dates on which the TPVs were provided to the Commission).   
48 See 47 U.S.C. § 217.  Section 217 imposes liability on a carrier for the acts and omissions of its agents simply if 
those agents act within the scope of their employment; a carrier’s knowledge of its agents’ misdeeds is not required.  
See, e.g., Advantage Forfeiture Order, 32 FCC Rcd at 3726, para. 9; Preferred Forfeiture Order, 30 FCC Rcd at 
13724, para. 26 (each finding a carrier liable for deceptive marketing practices of the third-party telemarketers).  In 
any event, Tele Circuit has not claimed or produced any evidence that it was unaware of its third-party verifier’s 
actions or that the Company should not be held responsible for those actions.  
49 47 CFR § 1.17(a)(2). 
50 See Amendment of Section 1.17 of the Commission’s Rules Concerning Truthful Statements to the Commission, 
Report and Order, 18 FCC Rcd 4016, 4016-17, 4021, paras. 1–2, 12 (2003), recon. denied, Memorandum Opinion 
and Order, 19 FCC Rcd 5790, further recon. denied, Memorandum Opinion and Order, 20 FCC Rcd 1250 (2004) 
(Amendment of Section 1.17).   
51 See id. at 4017, para. 4 (stating that the revision to Section 1.17 is intended to “prohibit incorrect statements or 
omissions that are the result of negligence, as well as an intent to deceive”). 
   
 Federal Communications Commission FCC 18-54 
 
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course of a year from consumers who said they did not authorize a switch to Tele Circuit’s service.52  As 
we have previously stated, parties must “use due diligence in providing information that is correct and not 
misleading to the Commission.”53  This includes taking appropriate steps to determine the truthfulness of 
what is being submitted.  Nothing in the record suggests that Tele Circuit implemented even the most 
basic steps to do so, as evidenced by the six complaints discussed above that form the basis for this rule 
violation.54  Accordingly, we find that Tele Circuit apparently violated Section 1.17(a)(2) of the Rules by 
providing false and misleading material information to the Commission in the form of six fabricated 
TPVs while lacking a reasonable basis for believing that those TPVs were authentic. 
C. Tele Circuit Submitted Requests to Switch Consumers’ Preferred Carriers without 
Authorization in Apparent Violation of Section 258 of the Act and Section 64.1120 
of the Rules  
16. 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.”55 
Section 64.1120 of the Rules prohibits carriers from submitting a preferred carrier change order before 
obtaining verified authorization from the consumer.  The Rules provide that the verified authorization can 
be obtained three ways, including written or electronic authorization or through use of an independent 
third-party verifier.56  “Slamming” refers to the unlawful practice of switching a consumer’s telephone 
service without first obtaining such verified authorization.  Slamming not only harms the consumers who 
are victims of the unlawful act, it also distorts the telecommunications market by enabling carriers that 
engage in fraudulent activity to increase their revenues at the expense of consumers and law-abiding 
carriers.57 
17. First, we find Tele Circuit in apparent violation of Section 258 of the Act and Section 
64.1120 of the Rules for failing to obtain verified authorization before switching the telephone service 
providers of 11 consumers.  After receiving complaints from consumers claiming they were slammed, the 
Bureau directed Tele Circuit to provide the verified authorization the Company relied upon in requesting 
to switch the carriers of those consumers.58  CGB served additional slamming complaints on Tele Circuit 
that consumers filed through the Commission’s Consumer Complaint Center.  Tele Circuit failed to 
provide any kind of verified authorization for 11 of the consumers.  The Rules require carriers to 
“maintain and preserve records of verification of subscriber authorization for a minimum for two years 
                                                     
52 We consider the TPV recordings to be “written statements” as they were submitted as part of written responses to 
the Consumer & Governmental Affairs Bureau’s (CGB’s) Notices of Informal Complaints.  
53 Amendment of Section 1.17, 18 FCC Rcd at 4021, para. 12.  See GPSPS, Inc., Notice of Apparent Liability for 
Forfeiture, 30 FCC Rcd 2522, 2524-27, paras. 6-12 (2015) (GPSPS NAL), Forfeiture Order, 30 FCC Rcd 7814 
(2015) (GPSPS Forfeiture Order); OneLink NAL, 31 FCC Rcd at 1420-21, paras. 17-18 (each finding that the 
carriers apparently violated Section 1.17 of the Rules for submitting fabricated TPV recordings to the Commission). 
54 See supra para. 12; see also Appendix (identifying complaints filed by S. Casteneda, O. Valtierra, M. Casales, P. 
Morales, M. Hernandez, and L. Arellano, each of whom alleged Tele Circuit’s TPV recording was false or had been 
fabricated, along with the dates the TPVs were submitted to the Commission). 
55 47 U.S.C. § 258(a).  See also AT&T Corporation v. FCC, 323 F.3d 1081, 1086 (DC Cir. 2003) (stating that 
carriers must comply with Commission verification procedures and that “a ‘procedure’ is ‘a particular course of 
action,’ or ‘a particular step adopted for doing or accomplishing something.’”) (citing Webster’s Third New 
International Dictionary 1807 (1993)).    
56 47 CFR § 64.1120(c).  
57 See Implementation of the Subscriber Carrier Selection Changes Provisions of the Telecommunications Act of 
1996, Fourth Report and Order, 23 FCC Rcd 493, 493-494, para. 2 (2008). 
58 See LOI at 4.  
   
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 11 
after obtaining such verification.”59  Once the Commission notifies a carrier of an unauthorized carrier 
change complaint, “[f]ailure by the carrier to respond or provide proof of verification will be presumed to 
be clear and convincing evidence of a violation.”60  In 11 cases, Tele Circuit simply did not respond to the 
complaints served on the Company.61  We conclude that Tele Circuit apparently violated Section 258 of 
the Act and Section 64.1120 of the Rules with respect to 11 complainants because the Company failed to 
provide proof of verification in response to those consumers’ unauthorized carrier change complaints.  
18. Second, we find Tele Circuit in apparent violation of Section 258 of the Act and Section 
64.1120 of the Rules for failing to meet the requirements prescribed when a carrier chooses to rely on 
third-party verification to prove consumer authorization for a carrier switch.  Section 64.1120(c)(3)(iii) 
lays out the content and format that must be used when a carrier relies on third party verification of 
consumer authorization.  Specifically, the Rules state that the verifier “must not be misleading,” and must 
elicit, at a minimum, certain information, including “confirmation that the person on the call wants to 
make the carrier change; [and] confirmation that the person on the call understands that a carrier change, 
not an upgrade to existing service, bill consolidation, or any other misleading description of the 
transaction, is being authorized.”62   
19.  We find that for 13 additional consumers, the third-party verification recordings 
purportedly demonstrating their authorization all failed to comply with the requirements of Section 
64.1120(c)(3)(iii).  In all 13 recordings, the verifier fails to confirm that the consumer understands they 
are making a carrier change and that they wish to make such a change.  In fact, the verifier does not 
mention a carrier change at all during the call.  At the end of the call, after concluding a series of rapid-
fire questions, the verifier says, “Welcome to Tele Circuit Network Corporation” and provides a 
telephone number the consumer can call with questions.  At best, consumers may be able to glean from 
this statement that the named company is in some way involved with the actions described during the 
TPV recording and preceding sales call.  However, at no point does the verifier directly ask the consumer 
if they want to make a carrier change or if they understand that they are authorizing a carrier change 
rather than making a change to existing service or a billing change.63  The actions taken by Tele Circuit 
and its verifier do not elicit “confirmation that the person on the call wants to make the carrier change” or 
“confirmation that the person on the call understands that a carrier change is being authorized” as required 
by the Rules.   
20. Taken together, for 11 complainants Tele Circuit could not provide the Commission with 
any evidence of a verified consumer authorization to switch carriers and in 13 cases where Tele Circuit 
                                                     
59 47 CFR § 64.1120(a)(1)(ii).   
60 47 CFR § 64.1150(d). 
61 The complainants are M. Washington; M. Wood; P. McCandless; R. Butler; R. Moore; G. Ferguson; A. Scivally; 
B. Hendrix; V. Bell; W. White; D. Cowan.  See TeleCircuit, Complaints Regarding Unauthorized Change of 
Subscriber’s Telecommunications Carrier, Order, DA 17-1132, 32 FCC Rcd 9532, 9534, para. 4 (CGB 2017); 
TeleCircuit, Complaint Regarding Unauthorized Change of Subscriber’s Telecommunications Carrier, Order, DA 
17-1044, 32 FCC Rcd 7672, 7673-74, para. 4 (CGB 2017); TeleCircuit, Complaints Regarding Unauthorized 
Change of Subscriber’s Telecommunications Carrier, Order, DA 18-87, 2018 WL 654860, at *2, para. 4 (CGB Jan. 
30, 2018) (each granting complaints because Tele Circuit did not respond to the complaints and did not provide 
proof of verification). 
62 47 CFR § 64.1120(c)(3)(iii).  The other kinds of information the Rule requires is “[t]he date of the verification; 
the identity of the subscriber; confirmation that the person on the call is authorized to make the carrier change; . . . 
the names of the carriers affected by the change (not including the name of the displaced carrier); the telephone 
numbers to be switched; and the types of service involved (including a brief description of a service about which the 
subscriber demonstrates confusion regarding the nature of that service.).  Id.    
63 See TPVs associated with Complainants P. Ballentine, J. Lowry, C. Webb, F. Byrd, S. Jones, F. Stevenson, J. 
Locklear, D. Trent, L. Mayes, R. McLeod, J. Hayes, I. Coleman, E. Coronado.   
   
 Federal Communications Commission FCC 18-54 
 
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relied on third-party verification, the verifications were flawed and did not comply with our Rules.  As 
such, Tele Circuit apparently switched the telephone service of 24 consumers without verified 
authorization to do so, in violation of Section 258 of the Act and Section 64.1120 of the Rules.64   
D. Tele Circuit Placed Unauthorized Charges on Consumers’ Telephone Bills in 
Apparent Violation of Section 201(b) of the Act 
21. Section 201(b) of the Act makes it unlawful for a carrier, such as Tele Circuit, to engage 
in any practice in connection with its provision of a telecommunications service that is unjust and 
unreasonable.65  The Commission has found that the inclusion of unauthorized charges and fees on 
consumers’ telephone bills (i.e., cramming) is an “unjust and unreasonable” practice under Section 
201(b).66  Cramming can occur either when third parties place or cause to be placed unauthorized charges 
on consumers’ local telephone bills or when billing carriers place unauthorized charges on the telephone 
bills of their customers for their services or those of a third party.67  In either case, any assessment of an 
unauthorized charge or fee on a telephone bill is an “unjust and unreasonable” practice under Section 
201(b) of the Act.68  
22. We have reviewed the evidence in the record, including consumers’ complaints and their 
telephone bills, and find that Tele Circuit caused to be placed on complainants’ telephone bills 
unauthorized charges in apparent violation of Section 201(b) of the Act.  The complainants identified in 
the Appendix maintain that they neither requested nor agreed to receive service from Tele Circuit and 
were billed for service that they never authorized.  In some of the cases, Tele Circuit switched the 
consumer’s long distance carrier to Tele Circuit and began charging them for its service.  In other cases, 
Tele Circuit did not complete a carrier switch, but nevertheless charged the complainants a monthly fee 
for its long distance service, even though they were not providing service to the consumers.  The charges 
were placed on the complainants’ LEC bills or on a bill from Tele Circuit.69 
23. As we have said previously, a carrier that engages in an initial slam that leads to a 
subsequent cram violates both Sections 258 and 201(b) of the Act for slamming and cramming.70  In such 
                                                     
64 The attached Appendix provides a list of complainants who alleged slamming violations that occurred within the 
12-month period prior to the release of this NAL and the dates on which the apparent violations took place.  
65 47 U.S.C. § 201(b).  
66 See, e.g., Advantage Forfeiture Order, 32 FCC Rcd at 3728, para. 14; CTI Forfeiture Order, 31 FCC Rcd at 
10441-42, para. 15; Central Forfeiture Order, 31 FCC Rcd at 10392, para. 15; USTLD Forfeiture Order, 31 FCC 
Rcd at 10419-10420, para. 15; see also Long Distance Direct, Inc., 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).   
67 See Advantage Forfeiture Order, 32 FCC Rcd at 3728, para. 14; see also 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, 4439, paras. 1, 6 (2012). 
68 See, e.g., LDDI MO&O, 15 FCC Rcd at 3302, para. 14; see also Advantage Forfeiture Order, 32 FCC Rcd at 
3728, para. 14; CTI Forfeiture Order, 31 FCC Rcd at 10441-42, para. 15; Central Forfeiture Order, 31 FCC Rcd at 
10392, para. 15; USTLD Forfeiture Order, 31 FCC Rcd at 10419-10420, para. 15; Telseven, LLC, Notice of 
Apparent Liability for Forfeiture, 27 FCC Rcd 15558, 15564, 15567, paras. 12, 16 (2012), Forfeiture Order, 31 FCC 
Rcd 1639 (2016). 
69 As discussed above, once AT&T terminated billing for most third-party providers in January 2017, Tele Circuit 
began sending consumers direct bills for service.  See supra para. 4.  Only then did some consumers become aware 
that Tele Circuit had switched their local and/or long distance service to Tele Circuit and in some cases, had been 
billing them a monthly service fee for many months without their knowledge or authorization.    
70 See Advantage NAL, 28 FCC Rcd at 6850, para. 18 & n.48, Advantage Forfeiture Order, 32 FCC Rcd at 3728, 
para. 15; Optic NAL, 29 FCC Rcd at 9063, para. 19, Optic Forfeiture Order, 30 FCC Rcd at 2539, para. 1.        
   
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cases, we may exercise our authority to assess forfeitures for both violations,71 and based on the fact that 
Tele Circuit has been on notice that we could propose forfeitures for each such violations, we do so 
here.72   Accordingly, we find that Tele Circuit apparently violated Section 201(b) in 21 instances for 
placing unauthorized charges on consumers’ telephone bills.73 
E. Tele Circuit Violated a Commission Order by Failing to Respond Fully to a Bureau 
LOI 
24. Sections 4(i), 218, and 403 of the Act give the Commission broad power to compel 
carriers, such as Tele Circuit, to provide information and documents sought by the Bureau through 
LOIs.74  It is well established that failure to respond to an LOI from the Bureau constitutes a violation of a 
Commission order.75     
25. The Bureau’s LOI directed Tele Circuit to provide specific information related to its 
compliance with Sections 201(b) and 258 of the Act and the Commission’s anti-slamming rules.  This 
information is necessary to enable the Bureau to perform its investigatory function.  Tele Circuit 
responded to the LOI, but provided only some of the required information.  Specifically, Tele Circuit 
failed to provide the Bureau with consumer complaints or inquiries it received from consumers directly or 
through its billing aggregator, state regulatory authorities, or the BBB.  In addition, Tele Circuit failed to 
provide the Bureau with TPV recordings associated with those complaints.  Further, the Company did not 
provide the scripts used by its telemarketers and third-party verifiers, its contracts with any billing 
aggregator or local exchange carrier, or its state registrations.  Tele Circuit did not explain the reason for 
its failure to provide the required documents or request an extension of time within which to submit all of 
them.  Accordingly, in light of well-established Commission precedent,76 we find that Tele Circuit’s 
failure to provide all of the information and documents responsive to the Bureau’s LOI constitutes an 
apparent willful violation of a Commission order.  
F. Proposed Forfeiture  
26. Section 503(b) of the Act authorizes the Commission to impose a forfeiture against any 
entity that “willfully or repeatedly fail[s] to comply with any of the provisions of [the Act] or of any rule, 
                                                     
71 See Neon Phone Service, Inc., Notice of Apparent Liability for Forfeiture, 32 FCC Rcd 7964, 7971-72, para. 19 & 
Appendix (2017) (Neon NAL); Long Distance Consolidated Billing Co., Notice of Apparent Liability for Forfeiture, 
30 FCC Rcd 8664, 8671, para. 21 & Appendix (2015) (each proposing forfeitures for both the slam and cram 
violation where each occurred within the statute of limitations period). 
72 See Central NAL, 29 FCC Rcd at 5529, para. 25 & n.83; USTLD NAL, 29 FCC Rcd at 835–836, para. 24 & n.93; 
CTI NAL, 28 FCC Rcd at 17208, para. 26 & n.78.   
73 For those consumers whose slams took place outside the statute of limitations, we are proposing a forfeiture based 
only on the unlawful cramming that took place within the last 12 months.  Similarly, in instances where the evidence 
shows that Tele Circuit did not successfully change the complainant’s long distance service provider, but 
nevertheless began charging the complainant for unauthorized monthly long distance service, we propose a 
forfeiture only for the unlawful cramming.  See Complainant LEC Information (on file in EB-TCD-17-00023953).       
74 47 U.S.C. §§ 154(i), 218, 155(c)(3).  “Any order . . . or action made or taken pursuant to any [ ] delegation . . .  
shall have the same force and effect . . . and [be] enforced in the same manner, as orders . . . of the Commission.”  
47 U.S.C. § 155(c)(3). 
75 47 U.S.C. § 503(b)(1)(B).  See GPSPS NAL, 30 FCC Rcd at 2522, para. 1; GPSPS Forfeiture Order, 30 FCC Rcd 
at 7814, para. 2; Net One Int’l, Net One, LLC, Farrahtel Int’l, LLC, Order of Forfeiture, 29 FCC Rcd 264 (EB 2014) 
(Net One Forfeiture Order); SBC Communications, Inc., Forfeiture Order, 17 FCC Rcd 7589 (2002) (SBC 
Forfeiture Order). 
76 See GPSPS NAL, 30 FCC Rcd at 2522, para. 1; GPSPS Forfeiture Order, 30 FCC Rcd at 7814, para. 2; Net One 
Forfeiture Order, 29 FCC Rcd at 264, para. 1; SBC Forfeiture Order, 17 FCC Rcd at 7589, para. 1.  
   
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regulation, or order issued by the Commission.”77  Here, Section 503(b)(2)(B) of the Act authorizes us to 
assess a forfeiture against Tele Circuit of up to a statutory maximum of $196,387 for a single act or 
failure to act.78  In exercising our forfeiture authority, we must consider “the nature, circumstances, 
extent, and gravity of the violation and, with respect to the violator, the degree of culpability, any history 
of prior offenses, ability to pay, and such other matters as justice may require.”79  In addition, the 
Commission has established forfeiture guidelines that establish base penalties for certain violations and 
identify criteria that we consider when determining the appropriate penalty in any given case.80  Under the 
guidelines, we may adjust a forfeiture upward for violations that are egregious, intentional, or repeated, or 
that cause substantial harm or generate substantial economic gain for the violator.81  
27. Section 1.80(b) of the Rules sets a base forfeiture amount of $40,000 for violations of our 
slamming rules.82  Although the guidelines provide no base forfeiture for cramming, the Commission has 
established through case law a base forfeiture of $40,000 for cramming violations.83  As discussed above, 
the Commission can assess separate forfeitures for an unlawful carrier change request and for any 
unauthorized charges that result from that unlawful carrier change request.84  However, where Tele 
Circuit submitted the unlawful carrier change request more than a year prior to the date of this NAL, we 
assess a forfeiture not for the slam, but for the unauthorized charges Tele Circuit placed on the 
consumers’ telephone bills within the last 12 months.  Similarly, in those cases where Tele Circuit 
apparently did not submit a request to change the consumer’s preferred carrier85 but nevertheless charged 
the consumer for service without authorization, we assess a forfeiture for the unauthorized charge only.86  
                                                     
77 See 47 U.S.C. § 503(b).   
78 See 47 U.S.C. § 503(b)(2)(B); see also 47 CFR § 1.80(b)(2).  This amount reflects inflation adjustments to the 
forfeitures specified in Section 503(b)(2)(B) of the Act ($100,000 per violation or per day of a continuing violation 
and $1,000,000 per any single act or failure to act).  The Federal Civil Penalties Inflation Adjustment Act of 1990, 
Pub. L. No. 101-410, 104 Stat. 890, as amended by the Debt Collection Improvement Act of 1996, Pub. L. No. 104-
134, Sec. 31001, 110 Stat. 1321 (DCIA), as further amended by the Federal Reports Elimination Act of 1998, Pub. 
L. No. 105-362, Sec. 1301, 112 Stat. 3280, and as further amended by the Federal Civil Penalties Inflation 
Adjustment Act Improvements Act of 2015, Sec. 701, Pub. L. No. 114-74, 129 Stat. 599 (codified as amended 28 
U.S.C. § 2461) (the 2015 Inflation Adjustment Act), requires the Commission to adjust annually its forfeiture 
penalties for inflation.  See 28 U.S.C. § 2461.  The Commission most recently amended its relevant rules on January 
5, 2018, effective February 1, 2018.  See Amendment of Section 1.80(b) of the Commission’s Rules, Adjustment of 
Civil Monetary Penalties to Reflect Inflation, Order, DA 18-12, 33 FCC Rcd 46 (EB 2018); see also Adjustment of 
Civil Monetary Penalties to Reflect Inflation, 83 Fed. Reg. 4600-01 (Feb. 1, 2018).   
79 See 47 U.S.C. § 503(b)(2)(E). 
80 47 CFR § 1.80(b)(8), Note to paragraph (b)(8).  
81 Id. 
82 See 47 CFR § 1.80, Appendix A, Section I.  
83 See LDDI MO&O, 15 FCC Rcd at 3304, para. 19 (affirming the $40,000 penalty for each cramming violation 
imposed by the Commission in the forfeiture order). 
84 See supra para. 23. 
85 See supra note 73. 
86 The Commission has made clear that each unauthorized charge a carrier places on a consumer’s bill constitutes a 
separate and distinct violation of Section 201(b).  See CTI NAL, 28 FCC Rcd at 17208, para. 26 & n.79 (citing NOS 
Communications, Inc., Notice of Apparent Liability for Forfeiture, 16 FCC Rcd 1833 (2001)).  Although Tele 
Circuit placed multiple unauthorized charges on many complainants’ telephone bills, in this case we do not treat 
each charge as a separate violation and instead propose a forfeiture for one cramming violation per complainant.  
However, we caution other carriers that the Commission is committed to aggressive enforcement of its rules, 
especially in giving effect to the protections afforded consumers, and in other cases may impose a forfeiture for each 
unauthorized charge. 
   
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Applying the $40,000 base forfeiture to each of the 45 slamming and cramming violations87 that occurred 
within the last 12 months results in a proposed forfeiture of $1,800,000. 
28. The Commission’s forfeiture guidelines provide that the base forfeiture amount for 
misrepresentation or lack of candor is the statutory maximum,88 or, in this case, $196,387.89  Considering 
the circumstances of this case, we find that the base forfeiture is warranted for Tele Circuit’s willful 
violations of Section 1.17 of the Rules.  The Commission relies heavily on the truthfulness and accuracy 
of the information provided to it.  “If information submitted to us is incorrect, we cannot properly carry 
out our statutory responsibilities.”90  Here, Tele Circuit submitted apparently fabricated TPVs, as 
evidence that the consumers had agreed to the carrier change.  Such fake TPVs hamper our ability to 
properly enforce the carrier change rules.  Therefore, applying the base forfeiture of $196,387 to the six 
instances when Tele Circuit provided false material information to the Commission within the last 12 
months results in a proposed forfeiture of $1,178,322.91 
29. Pursuant to Section 1.80 of the Commission’s rules and the Commission’s Forfeiture 
Policy Statement, the base forfeiture amount for failure to respond to Commission communications is 
$4,000.92  Using our discretion to adjust the base forfeiture as circumstances warrant, however, we have 
imposed penalties that are many times higher for failing to respond properly to LOIs.93  As the 
Commission has stated in cases where carriers have not provided complete responses to Commission 
orders, “misconduct of this type exhibits contempt for the Commission’s authority, and threatens to 
compromise the Commission’s ability to adequately investigate violations of its rules.”94  The proposed 
forfeiture is appropriate given the extent and willfulness of the violation, and the insufficiency of the LOI 
Response.95  Consistent with prior cases involving carriers that failed to comply with Bureau LOIs, we 
find that Tele Circuit’s failure to respond fully to the Bureau’s LOI in this case warrants a forfeiture of 
$25,000.96   
                                                     
87 A slamming violation occurs whenever a carrier submits an unlawful request to change service providers 
regardless of whether the change actually takes place.  See 47 U.S.C. § 258(a) (“[n]o telecommunications carrier 
shall 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 [the Commission’s] verification procedures. . . .”).   
88 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, 17113 (1997) recons. denied, 15 FCC Rcd 303 (1999) 
(Forfeiture Policy Statement); 47 CFR § 1.80(b)(4), Note to Paragraph (b)(4); Section I. Base Amounts for Section 
503 Forfeitures. 
89 See supra para. 26 and note 78. 
90 Amendment of Section 1.17 of the Commission’s Rules Concerning Truthful Statements to the Commission, Notice 
of Proposed Rulemaking, 17 FCC Rcd 3296, 3297, para. 3 (2002). 
91 The six instances of apparent violations of Section 1.17 that occurred within the 12-month period prior to the 
release of this NAL are identified in the Appendix. 
92 47 CFR § 1.80; Forfeiture Policy Statement, 12 FCC Rcd at 17114, Appendix A, Section I. 
93 See, e.g., GPSPS NAL, 30 FCC Rcd at 2533, para. 28 (upwardly adjusting the base forfeiture to $25,000 for the 
failure to respond fully to an LOI). 
94 Technical Communication Network, LLC, Notice of Apparent Liability for Forfeiture, 28 FCC Rcd 1018, 1020, 
para. 7 (EB 2013) (alteration omitted) (proposing a $25,000 forfeiture for failure to provide a complete response to 
an LOI). 
95 See 47 U.S.C. § 503(b)(2)(E); 47 CFR § 1.80(b)(8), Note to paragraph (b)(8). 
96 Net One Forfeiture Order, 29 FCC Rcd at 264-66, paras. 1-4 (imposing $25,000 penalty for failure to respond 
fully to an LOI), petition for reconsideration denied, Memorandum Opinion and Order, 30 FCC Rcd 1021 (EB 
2015). 
   
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30. Under Section 503 of the Act and our forfeiture guidelines, we must take into account the 
repeated and egregious nature of Tele Circuit’s actions and the harm Tele Circuit caused consumers.97  
Given the facts presented here, and consistent with similar cramming and slamming enforcement actions, 
we conclude that a significant upward adjustment to the base forfeiture penalty for the slamming and 
cramming violations is warranted for the repeated and egregious nature of Tele Circuit’s misconduct and 
the substantial harm that Tele Circuit’s actions caused the public.  In the Preferred Forfeiture Order, the 
Commission affirmed a forfeiture against a carrier that repeatedly engaged in misrepresentation and 
changed consumers’ preferred long distance providers without properly verifying their authorization.98  In 
doing so, the Commission stated that “[c]arriers have long been on notice that such misrepresentations to 
consumers [associated with slamming] may result in substantial forfeiture amounts.”99  Likewise, as noted 
in the CTI NAL, the Commission has repeatedly warned carriers engaged in cramming that “we may 
propose more significant forfeitures in the future as high as is necessary, within the range of our statutory 
authority, to ensure that such companies do not charge consumers for unauthorized services.”100 
31. As explained in the Discussion section above, Tele Circuit apparently engaged in 
slamming and cramming repeatedly over an extended period of time.  Although we base the proposed 
forfeiture on those apparent violations that occurred within the 12 months of the release date of this NAL, 
the Bureau reviewed and investigated numerous other complaints about conduct that took place prior to 
that 12-month period alleging that Tele Circuit had switched consumers’ carriers without their 
authorization101 and placed unauthorized charges on consumers’ telephone bills multiple times.102  For 
instance, one 76-year-old complainant expressed frustration with having to contact Tele Circuit multiple 
times over the course of four months to attempt to remove an improper charge, to no avail.103   
32. The record also shows that Tele Circuit’s apparent violations were egregious.104  Roughly 
half of the complaints the Bureau reviewed in this investigation are from senior citizens or relatives of 
elderly or infirm consumers—those who are especially vulnerable to the deceptive tactics employed by 
Tele Circuit.105  Indeed, the record suggests that, at least in some instances, Tele Circuit and its third-party 
                                                     
97 47 CFR § 1.80(b)(8), Note to paragraph (b)(8).  
98 Preferred Forfeiture Order, 30 FCC Rcd at 13724-26, paras. 27-31. 
99 Preferred Forfeiture Order, 30 FCC Rcd at 13725, para. 29 (citing Central NAL, 29 FCC Rcd at 5531, para. 28; 
USTLD NAL, 29 FCC Rcd at 837, para. 27; Advantage NAL, 28 FCC Rcd at 6855–56, para. 30; Silv Communication 
Inc., Notice of Apparent Liability for Forfeiture, 25 FCC Rcd 5178, 5186, para. 16 (2010) (Silv NAL) (“The 
Commission has warned carriers that it would take swift and decisive enforcement action, including the imposition 
of substantial monetary forfeitures, against any carrier found to have engaged in slamming.”)).  
100 CTI NAL, 28 FCC Rcd at 17209, para. 29 (citing Main Street NAL, 26 FCC Rcd at 8861, para. 24).  
101 See, e.g., Complaints from R. MacDowell (filed Aug. 5, 2016); J. Fernandez (filed Oct. 6, 2016); H. Burris (filed 
Jan. 11, 2017); F. Salinas (filed Sept. 6, 2016); E. Jones (filed Oct. 25, 2016); H. Mount (filed Sept. 29, 2016); J. 
Torres (filed Aug. 29, 2016) (each not identified in the Appendix), along with other complaints described throughout 
the NAL and identified as “not in Appendix.” See supra note 3.   
102 Tele Circuit placed unauthorized charges on more than one telephone bill for the following complainants:  M. 
Casales; O. Valtierra; R. Moore; M. Washington; M. Wood; A. Scivally; and A. Viera. 
103 See supra para. 4, note 13. 
104 47 CFR § 1.80(b)(8), Note to paragraph (b)(8). 
105 See supra para. 6; see also, e.g., Complaint from C. Almonte (filed Feb. 2, 2017) (not in Appendix); Complaint 
from H. Burris (filed Jan. 11, 2017) (not in Appendix); Complaint from J. Nichols (filed Jan. 2, 2107) (not in 
Appendix); Complaint from C. Jones (filed Jan. 31, 2017) (not in Appendix); Complaint from E. Bauer (filed Feb. 1, 
2017) (not in Appendix); Complaint from M. Cook (filed July 1, 2016) (not in Appendix); Complaint from C. De La 
Cruz (filed Mar. 10, 2017) (not in Appendix); Complaint from A. Urgelles (filed Mar. 10, 2017) (not in Appendix); 
Complaint from M. Gutierrez (filed Apr. 2, 2017) (not in Appendix); Complaint from J. Chambless (filed Mar. 29, 
2017) (not in Appendix); Complaint from P. Pestana (filed Apr. 10, 2017) (not in Appendix); Complaint from C. 
(continued….) 
   
 Federal Communications Commission FCC 18-54 
 
 17 
verifiers deliberately exploited these consumers’ obvious confusion and inability to understand the sales 
pitch they heard and understand the questions they were asked.106  Moreover, Tele Circuit’s actions left 
these vulnerable consumers without telephone service for extended periods of time, often because Tele 
Circuit demanded payment of unauthorized charges and other fees prior to reinstating service, creating 
dangerous and, potentially, life-threatening situations for the impacted consumers.107   
33. Given the egregious and repeated nature of Tele Circuit’s improper conduct,108 all in the 
face of multiple warnings from the Commission that these practices would be met with significant and 
substantial penalties, we determine that an upward adjustment of $2,000,000 to the overall base forfeiture 
for the slamming and cramming violations is appropriate.  This significant upward adjustment for the 
alleged conduct here is consistent with Commission precedent in cases dealing with similar egregious and 
repeated misconduct.109  In addition, in light of the Company’s egregious misconduct and the nature of the 
apparent violations, we will consider initiating proceedings against the Company to revoke its 
(Continued from previous page)                                                            
Peterson (filed May 3, 2017) (not in Appendix); Complaint from K. Jones (filed Apr. 26, 2017) (not in Appendix); 
Complaint from D. Cowan (filed June 12, 2017). 
106 See supra para. 6. 
107 See, e.g., Complaint from J. Castaneda (filed Mar. 8, 2017) (“I have NEVER authorized a change to my long 
distance service plan or a change of carrier.  Now, I find that I have a block on my telephone so I can’t place 
calls!”); Complaint from M. Cook (filed July 1, 2016) (not in Appendix) (“phone was turned off before we knew our 
number was changed to telecircuit and I want to change back to att but [Tele Circuit] will not release my phone back 
to prior phone service carrier . . . a 87 year old should not have to go [through] this.”); Complaint from  
(filed Mar. 12, 2017) (not in Appendix) (“Aside from the financial aspects of slamming . . . there is the safety issue 
of . . . cutting off [my mother’s] phone service before her conservator knew the service had been switched from 
AT&T.  This is the only way she or her caregivers can contact me or anyone in case of an emergency.”); Complaint 
from  (filed Jan. 31, 2017) (not in Appendix) (“As of right now my mother is without a phone and if 
anything happens to her, she can’t even dial 911 because she has no service at all.  I was told that she had to pay 
$44.00 to Tele Circuit . . . for her service to be restored.  It’s sad that these companies prey on the elderly.”); 
Complaint from  (filed Sept. 29, 2016) (not in Appendix) (“Tele Circuit called my 87-year old father and 
switched his phone service from AT&T to Tele Circuit. . . . [T]hey scammed him on the day of his last sibling’s 
funeral.  He has had the same phone number with AT&T for about 70 years and now he has NO phone service. . . . 
Please help us.”); Complaint from  (filed May 2, 2016) (not in Appendix) (“[Tele Circuit] arranged to get 
AT&T canceled and never provided one second of phone service to her.  And then sent her a bill for $34.00.  She’s 
been without her phone for almost a week.”). 
108 47 CFR § 1.80(b)(8), Note to paragraph (b)(8).  See Complaint from O. Valtierra (filed Oct. 6, 2016); Complaint 
from J. Castaneda (filed Mar. 8, 2017); Complaint from P. Morales (filed Apr. 5, 2017); Complaint from M. Casales 
(filed Feb. 1, 2017); Complaint from M. Hernandez (filed Mar. 13, 2017); Complaint from L. Arellano (filed Oct. 
22, 2017) (each alleging that Tele Circuit’s TPV recording was fabricated); see also Complaint from J. Nichols 
(filed Jan. 2, 2017) (not in Appendix); Complaint from K. Cortez (filed Mar. 15, 2017) (not in Appendix); 
Complaint from K. Jones (filed Apr. 26, 2017) (not in Appendix); Complaint from T. Hickman (filed Feb. 22, 2017) 
(not in Appendix); Complaint from P. Beal (filed Apr. 11, 2017) (not in Appendix); Complaint from P. Ballentine 
(filed May 17, 2017); (each alleging that Tele Circuit’s telemarketer misrepresented their identity).  
109 See Central NAL, 29 FCC Rcd at 5531, para. 28, Central Forfeiture Order, 31 FCC Rcd at 10408-09, paras. 39-
41 (assessing an upward adjustment of $1,500,000 for egregious misconduct related to 31 slamming and cramming 
violations); CTI NAL, 28 FCC Rcd at 17209, para. 29, CTI Forfeiture Order, 31 FCC Rcd at 10451-53, paras. 38-40 
(assessing an upward adjustment of $1,500,000 for egregious misconduct related to 25 slamming and cramming 
violations); USTLD NAL, 29 FCC Rcd at 837, para. 27, USTLD Forfeiture Order, 31 FCC Rcd at 10430-31, paras. 
39-40 (assessing an upward adjustment of $2,000,000 for egregious misconduct related to 36 slamming and 
cramming violations). 
   
 Federal Communications Commission FCC 18-54 
 
 18 
Commission authorizations after assessing the Company’s response to this Notice of Apparent Liability 
for Forfeiture.110   
34. Under the circumstances here we do not propose a separate forfeiture for Tele Circuit’s 
deceptive marketing.  Rather, consistent with the Forfeiture Policy Statement111 and with prior slamming 
and cramming orders that involved evidence of deceptive marketing,112 we upwardly adjust the proposed 
base forfeiture for the underlying slam and cram violations that are coupled with direct evidence of such 
misconduct.113  In past cases we have upwardly adjusted the base penalty for slamming and cramming 
violations by $80,000, and we have repeatedly warned carriers that we may propose significant forfeitures 
“to ensure that such companies do not use deception to charge consumers for unauthorized services.”114  
Accordingly, consistent with Commission precedent, we propose an upward adjustment of $80,000 for 
each of the four slamming and cramming violations that occurred in the past 12 months and for which 
Tele Circuit apparently misrepresented its identity to the consumers as purported proof of their 
authorization, resulting in a further upward adjustment of $320,000.   
35. Therefore, after applying the Forfeiture Policy Statement, Section 1.80 of the Rules, and 
the statutory factors, we propose a total forfeiture of $5,323,322, for which Tele Circuit is apparently 
liable.   
IV. CONCLUSION 
36. We have determined that Tele Circuit apparently willfully and repeatedly violated 
Sections 201(b) and 258 of the Act, Sections 1.17 and 64.1120 of the Rules, and a Commission order.  As 
such, Tele Circuit is apparently liable for a forfeiture of $5,323,322. 
V. ORDERING CLAUSES 
37. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Act115 and 
Section 1.80 of the Rules,116 Tele Circuit Network Corporation is hereby NOTIFIED of this 
APPARENT LIABILITY FOR FORFEITURE in the amount of five million, three hundred twenty-
three thousand, three hundred twenty-two dollars ($5,323,322) for willful and repeated violations of 
Sections 201(b) and 258 of the Act,117 Sections 1.17 and 64.1120 of the Rules,118 and a Commission 
order. 
38. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the Rules,119 within 
thirty (30) calendar days of the release date of this Notice of Apparent Liability for Forfeiture, Tele 
Circuit Network Corporation SHALL PAY the full amount of the proposed forfeiture or SHALL FILE a 
                                                     
110 See OneLink NAL, 31 FCC Rcd at 1429-30, para. 36 (noting that the Commission will consider initiating 
proceedings against carriers to revoke their Commission authorizations in cases involving egregious misconduct). 
111 Forfeiture Policy Statement, 12 FCC Rcd at 17100–01, para. 27. 
112 USTLD Forfeiture Order, 31 FCC Rcd at 10429, paras. 37-38; Central Forfeiture Order, 31 FCC Rcd at 10408, 
paras. 39-40.  
113 See supra para. 9. 
114 See, e.g., USTLD NAL, 29 FCC Rcd at 837, para. 27 (citing cases), USTLD Forfeiture Order, 31 FCC Rcd at 
10429, para. 37; Central NAL, 29 FCC Rcd at 5531, para. 28, Central Forfeiture Order, 31 FCC Rcd at 10408-09, 
paras. 39-41; Silv NAL, 25 FCC Rcd at 5186, para. 16. 
115 47 U.S.C. § 503(b). 
116 47 CFR § 1.80. 
117 47 U.S.C. §§ 201(b), 258. 
118 47 CFR §§ 1.17, 64.1120. 
119 47 CFR § 1.80. 
   
 Federal Communications Commission FCC 18-54 
 
 19 
written statement seeking reduction or cancellation of the proposed forfeiture consistent with paragraphs 
42 and 43 below. 
39. 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.  Tele Circuit Phone 
Service, Inc. shall send electronic notification of payment to Lisa Williford at lisa.williford@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.120  When completing the FCC Form 159, enter the Account 
Number in block number 23A (call sign/other ID) and enter the letters “FORF” in block number 24A 
(payment type code).  Below are additional instructions that should be followed based on the form of 
payment selected:  
• Payment by check or money order must be made payable to the order of the Federal 
Communications Commission.  Such payments (along with the completed Form 159) must be 
mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-
9000, or sent via overnight mail to U.S. Bank–Government Lockbox #979088, SL-MO-C2-
GL, 1005 Convention Plaza, St. Louis, MO 63101. 
• Payment by wire transfer must be made to ABA Number 021030004, receiving bank 
TREAS/NYC, and Account Number 27000001.  To complete the wire transfer and ensure 
appropriate crediting of the wired funds, a completed Form 159 must be faxed to U.S. Bank 
at (314) 418-4232 on the same business day the wire transfer is initiated. 
• Payment by credit card must be made by providing the required credit card information on 
FCC Form 159 and signing and dating the Form 159 to authorize the credit card payment.  
The completed Form 159 must then be mailed to Federal Communications Commission, P.O. 
Box 979088, St. Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank – 
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
63101. 
40. 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 20554.121  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. 
41. The written statement seeking reduction or cancellation of the proposed forfeiture, if any, 
must include a detailed factual statement supported by appropriate documentation and affidavits pursuant 
to Sections 1.16 and 1.80(f)(3) of the Rules.122  The written statement must be mailed to the Office of the 
Secretary, Federal Communications Commission, 445 12th Street, SW, Washington, DC 20554, Attn:  
Enforcement Bureau, Telecommunications Consumers Division, and to Kristi Thompson, Chief, 
Telecommunications Consumers Division, Enforcement Bureau, Federal Communications Commission, 
445 12th Street, SW, Washington, DC 20554, and must include the NAL/Account Number referenced in 
the caption.  The statement must also be e-mailed to Mika Savir and Erica McMahon at 
mika.savir@fcc.gov and erica.mcmahon@fcc.gov.   
42. The Commission will not consider reducing or canceling a forfeiture in response to a 
claim of inability to pay unless the petitioner submits:  (1) federal tax returns for the most recent three-
year period; (2) financial statements prepared according to generally accepted accounting practices; and 
                                                     
120 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf. 
121 See 47 CFR § 1.1914. 
122 47 CFR §§ 1.16, 1.80(f)(3). 
   
 Federal Communications Commission FCC 18-54 
 
 20 
(3) any other reliable and objective documentation that accurately reflects the petitioner’s current 
financial status.  Any claim of inability to pay must specifically identify the basis for the claim by 
reference to the financial documentation. 
43. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability for 
Forfeiture shall be sent by first class mail and certified mail, return receipt requested, to Ashar Syed, 
President, Tele Circuit Network Corporation, 1815 Satellite Blvd., Suite 504, Duluth GA 30097. 
  
      FEDERAL COMMUNICATIONS COMMISSION 
 
 
 
 
      Marlene H. Dortch 
      Secretary 
 Federal Communications Commission FCC 18-54  
 
 21 
APPENDIX 
 
Apparent violations of Sections 258 and 201(b) of the Act 
 Complainant 
 
Date of carrier 
change and/or date 
charge placed on 
consumer’s bill 
Apparent violation 
1. Ballentine, P. 
BBB 
4/28/17 
5/1/17 
Section 201(b) cram 
Section 258 slam 
Section 201(b) misrepresentation 
2. Washington, M. 
#1824556 
4/28/17 
5/28/17 
Section 258 slam 
Section 201(b) cram 
3. Viera, A. 
#1638031 
5/22/17 Section 201(b) cram 
4. Cowan, D. 
#1697833 
5/26/17 
5/30/17 
Section 201(b) cram 
Section 258 slam 
5. Byrd, F. 
#1729110 
6/5/17 Section 258 slam 
 
6. Dorn, R. 
#2058169 
6/10/17 Section 201(b) cram 
7. Tiller, C. 
#1761647 
6/16/17 Section 201(b) cram 
8. Wood, M. 
#1964453 
8/12/17 
9/22/17 
Section 258 slam 
Section 201(b) cram 
9. Lowry, J. 
BBB 
8/22/17 
9/2/17 
Section 258 slam 
Section 201(b) cram 
10. McCandless, P. 
#1976500 
8/23/17 
10/3/17 
Section 258 slam 
Section 201(b) cram 
11. Jones, S. 
BBB 
8/25/17 Section 258 slam 
12. Butler, R. 
#1936262 
8/28/17 
9/8/17 
Section 258 slam 
Section 201(b) cram 
Section 201(b) misrepresentation 
13. Moore, R. 
#1985411 
9/15/17 
9/28/17  
Section 258 slam 
Section 201(b) cram 
14. Hendrix, B. 
#1935875 
9/17/17 
9/18/17 
Section 258 slam 
Section 201(b) cram 
15. Mayes, L. 
#2051254 
9/19/17 
10/3/17 
Section 258 slam 
Section 201(b) cram 
16. Webb, C. 
BBB, #2002243 
9/22/17 
10/7/17 
Section 258 slam 
Section 201(b) cram 
17. McLeod, R. 
#2140282 
9/23/17 
10/7/17 
Section 258 slam 
Section 201(b) cram 
Section 201(b) misrepresentation 
18. Stevenson, F. 
BBB 
9/25/17 Section 258 slam 
19. Ferguson, G. 
#1984246 
9/28/17 
10/2/17 
Section 201(b) cram 
Section 258 slam 
20. Scivally, A. 
#1967778 
10/2/17 
11/12/17  
Section 258 slam 
Section 201(b) cram 
Section 201(b) misrepresentation 
 Federal Communications Commission FCC 18-54  
 
 22 
21. Coronado, E. 
#2234007 
10/9/17 
1/9/18 
Section 258 slam 
Section 201(b) cram 
22. Trent, D. 
#2115257 
10/19/17 Section 258 slam 
23. White, W. 
#2045774 
10/29/17 
11/8/17 
Section 258 slam 
Section 201(b) cram 
24. Bell, V. 
#2033552 
10/30/17 
10/31/17 
Section 201(b) cram 
Section 258 slam 
25. Locklear, J. 
#2071906 
11/1/17 
11/11/17 
Section 258 slam 
Section 201(b) cram 
26. Coleman, I. 
#2183677 
11/22/17 Section 258 slam 
27. Hayes, J. 
#2129292 
12/6/17 Section 258 slam 
Apparent Violations of Section 1.17 of the Rules 
 Complainant Date Tele Circuit 
provided TPV to the 
Commission 
Violation 
1.   Castaneda, J. 
#1495083 
5/31/17 Section 1.17 
2. Valtierra, O. 
#1238489 
5/31/17 Section 1.17 
3. Casales, M. 
#1429595 
5/31/17 Section 1.17 
4. Morales, P. 
#1549092 
6/9/17 Section 1.17 
5. Hernandez, M. 
BBB 
6/19/17 Section 1.17 
6. Arellano, L. 
#1999351 
1/26/18 Section 1.17