3. Positions of the Parties
The Division of Ratepayer Advocates (DRA)
DRA encouraged the Commission to protect consumers by fulfilling its promise to step up its enforcement efforts and adopt the proposed rules, with several recommended enhancements. DRA challenged the carriers' claims that they can "self-police" with "best management practices" because each entity in the "third-party billing food chain gets a slice of the revenues."2
DRA presented evidence that instances of unauthorized charges on local exchange and wireless bills are increasing, and reflect sophisticated international schemes to defraud customers.3 DRA included summaries of victims' complaints showing the financial and clerical burden imposed on victims who must hunt down unauthorized charges in increasingly complicated billing statements and obtain refunds only after repeated telephone calls.4 DRA also included in its Opening Comments an injunction issued by the Honorable William Alsup of the U.S. District Court for the Northern District of California against crammer Inc21.com Corporation. Among other things, Judge Alsup's injunction chastised the local exchange carriers for failing to protect their customers from these fraudulent charges.5 DRA recommended that all Billing Telephone Corporations be required to provide subscribers with a cost-free option to block all third-party billing, and actively inform their customers of the option.6 DRA explained that the Commission has received complaints of carriers telling subscribers who request such a block that state and federal law mandates that the carrier provide billing to third parties.7
DRA supported aggressive billing termination processes and suggested clarifications to the standards. DRA also recommended that the Commission publish each carrier's termination and complaint data on the Commission's web site for prospective subscribers.8
The Utility Consumers Action Network (UCAN)
UCAN described the proposed rules as an "overdue step forward" to address a key failure in protecting communications consumers - the systemic practice of Billing Telephone Corporations to refuse to investigate and resolve customer complaints of unauthorized charges.9 UCAN explained that the practices of Billing Telephone Corporations enables unauthorized billing to continue because these Corporations have no incentive or requirement to aggressively prevent and, failing that, to identify and remedy unauthorized billing.
UCAN recommended that the key to adopting rules that will prevent unauthorized billings is that the revised rules clearly state that Billing Telephone Corporations are responsible for all items in bills presented to subscribers.10 UCAN found the proposed rule "unsettlingly vague" in light of the importance of this provision. UCAN proposed significant revisions to the rule to articulate standards for ensuring that only authorized charges for legitimate service providers are included on subscribers' bills. UCAN's revisions focused on the need for mandating investigations by Billing Telephone Corporations of all disputed charges, and requiring that the Billing Telephone Corporation "take responsibility for its billings" and not force subscribers to pursue unresponsive third parties.11
UCAN supported the disclosure requirements for service providers but suggested that Billing Telephone Corporations and Billing Agents be required to retain records of their pre-contract inquiry into a prospective billing service customer.12
UCAN recommended that the requirements for the billing termination process be clarified to specify exactly when a Billing Telephone Corporation or Billing Agent must investigate and report bad actors to the Consumer Protection and Safety Division (CPSD).13 UCAN pointed out that alleged service provider errors could be used to explain unacceptable levels of unauthorized billings which would allow bad actors to continue to avoid detection.
UCAN supported the proposed complaint reporting requirements but recommended that the obtained information, redacted to remove customer-specific data, be published on the Commission's web site.14 UCAN stated that having this information available for consumers and other Billing Telephone Corporations will assist in preventing future unauthorized billings.
The Utility Reform Network (TURN)
TURN commended the assigned Commissioner for proposing "real protections for consumers" and intensifying the Commission's focus on prevention of unauthorized charges by providing strong disincentives to "all players in the billing value chain."
TURN took issue with the proposed rule requiring subscriber authorization and contended that "specific, written authorization" should be required as was recently adopted in Illinois. TURN recommended deleting the rule that proposed for direct-dialed telephone service, that evidence that the call was dialed be prima facie evidence of authorization.
TURN opposed the "watered-down" standard of "commercially reasonable" actions to ensure that only authorized charges are presented on a bill. TURN explained that this loophole was confusing for all the parties, and that at least one Billing Telephone Corporation interpreted it as a reduction in the level of consumer protection required. TURN provided quotations from Verizon Communications, Inc., in a federal court pleading describing the proposed rules as reflecting "a more modest obligation" to prevent unauthorized billings. TURN pointed out that telecommunications providers have no financial incentive to monitor the actions of their billing partners because these providers achieve "significant profitability" from the sale of billing services. TURN identified another, similar loophole in the proposed rule for disclosure requirements, and sought clarification on the "10%" standard of billing service termination.
TURN opposed the flexible compliance option for unauthorized billing record retention and stated that this option gives the Billing Agents and Billing Telephone Corporations "way too much discretion."
TURN supported the monthly report preparation and proposed that the report be submitted monthly, rather than quarterly. Finally, terming the proposed amount "literally a pittance," TURN recommended that the fine for not filing a report be increased to correlate with revenues earned by the billing entity.
AT&T California (AT&T)15
AT&T explained that it requires all service providers, including those billing through a Billing Agent, to complete an application process before billing begins. AT&T reviews the applications and checks the applicants against an internal data base to "identify possible problems."16 AT&T collects cramming complaint data monthly for both Billing Agents and individual service providers. If the monthly reports exceed unspecified "threshold" levels, then AT&T may impose remedial action including terminating billing services. For every customer complaint of unauthorized charges, the responsible service provider must pay AT&T $150 and additional fees apply for "excessive adjustments to end-user bills above a threshold."17
AT&T stated that in response to continuing customer complaints, it has recently adopted "even more stringent anti-cramming measures" for its billing services customers and that it has had to completely discontinue billing for voice mail, e-mail, web hosting, and internet-based directory assistance because "cramming complaint rates were notably high."18 AT&T also recently provided all its customers service representatives with enhanced training to identify and respond to cramming complaints. As a result of this training, AT&T has been able to obtain better cramming complaint reports and has used this data to terminate billing services to service providers.
AT&T concluded that it is "in the process of considering several possible, new anti-cramming measures, and it is open to considering all reasonable options." AT&T cautioned, however, that any such measures "must be carefully considered in light of its effectiveness, cost, complexity, and burdens imposed both on industry and on customers seeking to pay for purchases through their telephone bills."19
AT&T's primary objection to the proposed rules were several areas of "vague and overbroad language" that "fail to set clear and specific standards." AT&T focused this criticism on Rules 4 and 5, which require Billing Telephone Corporations to "monitor" billings and take "all commercially reasonable steps" to ensure that only authorized charges are billed.20
For wireless carriers, AT&T recommended limiting their reporting requirements to service providers that have been terminated from billing services.21
AT&T also contended that the Commission has sufficient authority over wireline Billing Telephone Corporations that requiring these corporations to tally and report complaints of their own unauthorized charges is unnecessary and inefficient.22 AT&T opposed including false, misleading, or deceptive charges within the meaning of cramming.
In reply to the comments filed by other parties, AT&T emphasized that: "there is no evidence that stricter monitoring requirements or reporting obligations will offer any additional protections to consumers."23 AT&T supported workshops to discover whether "any modifications should be made to current rules to encourage more robust consumer-driven measures against incidences of cramming."24 AT&T supported focusing on the "customer acquisition end" of third-party sales transactions rather than on the "billing end." AT&T conceptually supported DRA's call for "the cost-free option to block third-party billing at any time," and recommended workshops to sort out the details.25
Verizon California Inc. (Verizon)
Verizon stated that the proposed rule revisions upset the balance created in earlier decisions in this docket between allowing third-party billing for the benefit of consumers and imposing safeguards that protect consumers.26 In light of the significant changes proposed, Verizon recommended that the Commission hold further hearings or workshops to allow for further comments on concerns expressed by the parties.
Verizon opposed expanding existing reporting requirements to include charges imposed by Billing Telephone Corporations.27 Verizon explained that the volume of customer billing issues regarding its own services would overwhelm Commission's staff with useless information and obscure the relevant information about Verizon's customer complaints that the Commission's staff already receives in the Consumer Affairs Branch. Moreover, the ultimate sanction of prohibiting further billing services would be unavailable with carriers of last resort, such as Verizon.
Verizon spelled out the additional protections its customers have from unauthorized charges:28
1. Verizon only allows "authorized users" to add or change services, and offers an optional security code to further limit account access.
2. Verizon mails a written confirmation letter setting out the terms and conditions of any change to an account.
3. Customers are offered a free block of all pay-per-use service charges as required by California and federal law, and have a one time bill adjustment for such services that were inadvertently ordered.
4. California law also requires Verizon to offer its customers a free block of all charges for 900 and 976 services.
Ultimately, Verizon concludes, the proper remedy for unauthorized billings by a Billing Telephone Corporation such as itself is an Order Instituting Investigation triggered by complaints directly to the Consumer Affairs Branch.29 As such, there is no need for Verizon to compile the voluminous details of its customer disputes and separately report them to the Commission a second time.
SureWest Telephone (SureWest)
SureWest argued that the proposed rules exceeded the scope of this phase of the consumer protection proceeding and were procedurally improper and substantially unjustified. SureWest stated that the proposed rules go far beyond the directive in D.06-03-013 to craft rules for reporting requirements and the record includes no evidentiary basis for the proposed rules.30
SureWest claimed that the proposed rules "improperly shift the burden of third-party oversight and enforcement onto carriers rather than the CPUC." Decrying the onerous, unnecessary burden to "police their own bills," SureWest argued that this was an improper abdication of the Commission's responsibility for consumer protection.31
SureWest argued that the proposed definition of "customer complaint" was overly broad: "Disputes regarding the terms and conditions of service, including associated allegations from consumers that they have been mislead, should not fall under the term `cramming.'32 Including these matters in a cramming reporting regime will only distort `cramming' issues and thwart efforts to pinpoint the real problems that the Commission should be identifying."33
SureWest concluded its comments with a list of rules that required additional clarification.
Small Local Exchange Carriers
The small local exchange carriers echoed SureWest's comments, and added that they do not generally bill for unaffiliated third parties, will often have no unauthorized billing complaints and, consequently, should not be required to submit quarterly reports.34
California Association of Competitive
Telecommunications Companies (CALTEL)
CALTEL opposed extending the rules beyond third-party billing by Billing Telephone Corporations. CALTEL explained that its members provide service, often by individual case basis contracts, to small and medium sized businesses and do not provide billing and collection services for third parties. As such, CALTEL's members have few if any complaints of unauthorized charges, and customers with billing disputes have the business sophistication to address the dispute directly with their provider. CALTEL argued that including wholesale and business customers, as well as a carrier's own billings, in the cramming reporting rules was "overkill" that will impose unnecessary expense on the providers with no public benefit.35
Cox California Telcom LLC, dba Cox Communications,
Cox TMI Wireless, LLC and Astound Broadband (Cox)
These carriers opposed the proposed rule that Billing Telephone Corporations report their own customer complaints about direct billings.36 These carriers also recommended that customers served pursuant to a contract should be excluded from any complaint tally because these contractual disputes are not necessarily unauthorized billing, and the wholesale and business customers that obtain service via contract do not require Commission protection from unauthorized charges.37
Cox contended that the proposed prohibition of Billing Telephone Corporations directing customers to contact service providers directly would increase the Billing Telephone Corporation's cost of doing business and would conflict with existing law. Cox also opposed as vague and unnecessary the proposed rules requiring Billing Telephone Corporations to monitor third-party billings and suspend billing services where unauthorized charges occur.38 Cox supported the Commission adopting reporting rules for third-party billing complaints that are limited to service providers for which the Billing Telephone Corporation has terminated providing services.
BSG Clearing Solutions (BSG)
BSG stated that it is the largest third-party billing aggregator in the United States and that it has been operating for over two decades.39 Before BSG will accept billings from a service provider, BSG conducts a comprehensive due diligence process that includes, but is not limited to, background checks of all officers, directors, and individuals with decision-making authority, site visits, inquiries to local exchange carriers for past termination history, internet search for regulatory issues, and purchasing the product as if a customer.40 The due diligence process takes three to six months and costs up to $1,000.41 Once BSG accepts the service provider, BSG conducts monthly reviews of its customer service inquiries and has a pre-set threshold for terminating billing services.42 BSG also explained that it has developed a validation and authentication tool --named "URU" - for service providers that solicit over the internet. The URU tool uses thirteen different vendors to scrutinize each transaction, including Lexis/Nexis to confirm name, address, and last four of the social security number all match.43
Cbeyond Communications, LLC. (Cbeyond)
Cbeyond stated that it provides telecommunications services to business customers only and that it does not allow charges for third-party services or products to be placed on its customers' bills. Cbeyond contended that the proposed rules were overly broad in including business customers because these customers are sophisticated and possess sufficient bargaining power to resolve any billing issues with a carrier.44 Cbeyond recommended that the Commission focus its resources on carriers with a history of applying or allowing unauthorized charges on residential and small business customer bills, rather than on carriers that serve larger businesses.45
Miller Isar, Inc.
This regulatory consulting firm represents four non-facilities-based interexchange carriers that bill through incumbent local exchange carriers in California. These carriers read the proposed rules as applying to customer transfer requests, which are already subject to stringent customer authorization requirements. Based on this reading, these carriers concluded that the proposed rules would allow incumbent local exchange carriers to attempt to "win back" customers that have validly requested transfer to another carrier because the Billing Telephone Corporation is the final arbiter of billing disputes.46
ILD Teleservices, Inc. (ILD)
ILD recommended that the Commission focus on adopting the most effective and efficient ways to identify cramming and deal with subscribers and removing offending service providers from the marketplace. ILD suggested that the definition of customer complaint should exclude those instances where a proper authorization was on file.47 ILD strongly supported allowing Billing Telephone Corporations to deflect a subscriber inquiry to the Billing Agent as the most efficient means to resolve the inquiry.48 ILD opposed the proposed percentage standard for discontinuing billing services and supported using a longer term average, perhaps a three-month rolling average. Finally, the record keeping requirements for Billing Agents should not include the subscriber name because Billing Agents do not typically have that information.49
tw telecom of California, lp (tw telecom)
This facilities-based carrier provides business telecommunications services only and does not bill for third parties. This carrier argues that applying the proposed record keeping and reporting rules to carriers that provide only business and wholesale telecommunications services is unwarranted, and that the Commission should exempt these carriers from the proposed rules as the Commission did with in-language rules in D.07-07-043.50
Unitedtel, LLC
Unitedtel stated that the proposed rules overly focus on individual complaints and unfairly penalize service providers that have refund rates greater than 10%. Unitedtel recommended adopting industry-wide standards for order validation as a better means to identify "bad actors" without discouraging refunds.51
Preferred Long Distance Inc. (Preferred Long Distance)
Preferred Long Distance opposed requiring the Billing Telephone Corporation to address complaints of unauthorized charges because these Corporations are often incumbent local exchange carriers that are in direct competition with resellers and the Billing Telephone Corporation will be overly eager to issue a refund to the customer and a charge back to the service provider, and also try to win the customer back.52 Preferred Long Distance recommended that the service provider be part of the dispute resolution process and have a right to appeal the outcome.
CTIA - The Wireless Association (CTIA)
CTIA stated that the proposed rules were not necessary because existing rules prohibit unauthorized charges on bills and carriers have adopted measures to prevent such practices. The "major participants in the mobile media value chain including wireless operators, aggregators, median networks, third-party content providers, agencies, brands, advertisers, hand-held device manufacturers, service providers, and market research firms" have formed the Mobile Marketing Association (MMA) to develop the acceptable method by which charges for mobile content can be placed on a customer's bill.53 CTIA stated that: "rather than interfacing directly with each of the numerous [mobile content] providers, wireless carriers contract with a smaller group of companies known as aggregators, who in turn contract with the providers."54 The MMA's methodology provides a standard for valid customer authorization to purchase third-party content, such a ringtones or wallpaper.
CTIA opposed obtaining the identity and regulatory compliance history of each Service Provider and instead proposed a "targeted exchange of information between carriers and CPSD" to share information on "bad actors" to preclude them from presenting further billings in California.55 CTIA also explained that collecting and retaining all the information listed in the proposed rules would require "significant and costly operational and system changes" in each wireless carrier's customer service center, and the data obtained will "not be reliable" due to the complex and subjective assessments each customer service representative would be required to make.56
Verizon Wireless
Verizon Wireless opposed the proposed rules as "unjustified" and creating an impediment to offering innovative services demanded by wireless customers.57 Verizon explained that it allows "hundreds" of third-party content providers access to its customers' bills, and that learning the identity and regulatory compliance history of these providers would "slow down the approval process."58 Verizon Wireless argued that the cost of the approval process could discourage carriers from offering content that did not have wide-spread appeal, resulting in fewer offerings. Verizon Wireless contended that because a carrier is a "purveyor" of information, the First Amendment to the United States Constitution prevented this Commission from imposing "pre-approval investigation requirements" on the carrier prior to accepting a billing services customer.59
Verizon Wireless stated that its nationwide call centers receive over 10 million calls a month and that due to the sheer volume of calls the cost of any additional information tracking requirement will be "very large."60 Verizon Wireless focused on the expense of tracking customer complaints of unauthorized charges and explained that a California-specific rule would be expensive to implement because the customer service representative would need to determine where the customer resided and then whether the call related to an unauthorized charge. The resulting data, Verizon Wireless concluded, would also be unreliable because each of its thousands of representatives would necessarily be making subjective assessments of the purpose of the call.
Verizon Wireless opposed suspending billing service for any Service Provider with a specified customer complaint or refund rate, and instead advocated that suspension decision be made as Verizon Wireless does now "based on the totality of the circumstances specific to the situation at hand."61 Verizon Wireless also opposed revealing the identity of Service Providers with high levels of unauthorized billings to the Commission's CPSD because such Service Providers might not cooperate further with Verizon Wireless. Finally, Verizon Wireless opposed rules for lost or stolen handsets, contending that absent a "good reason" it was the subscriber's responsibility to notify the carrier of the loss or theft.62
Verizon Wireless recommended that the Commission retain its existing rules and add three additional rules. First, Verizon Wireless supported allowing CPSD to request and obtain a copy of a carrier's policies for approving and monitoring third-party billing customers. Second, Verizon Wireless reiterated its earlier proposal that the Commission adopt a rule requiring each carrier to notify CPSD upon terminating billing services for a Service Provider. Finally, Verizon Wireless agreed that carriers could make information or data on circumstances surrounding the billing services contract termination available to Commission enforcement staff.63
Cricket Communications and MetroPCS (Cricket and MetroPCS)
Cricket and MetroPCS stated that they each offer wireless telecommunications services on a pay-in-advance basis. Customers do not receive a post-delivery bill for services but rather pay in full for a billing period prior to the period commencing. Service is offered on an unlimited basis at a constant amount for each billing period; customers who wish to purchase extra services must first establish a separate, completely optional, account to pay for the extra services.64
Cricket and MetroPCS described their processes for authorizing service providers of the extra services:
Cricket and MetroPCS allow a very limited number of reputable third-party content and service providers to access their billing systems, e.g., to bill customers directly for additional content and services. Cricket and MetroPCS individually screen these third-party content and services providers and require such providers to abide by the [MMA] Guidelines, including the "double opt-in" requirement [of two affirmative acts by the customer].
Cricket and MetroPCS individually evaluate and verify the legitimacy of any third-party provider through established protocols specifically designed to complement the pay-in-advance service model. Specifically, any third-party provider wishing to provide content or service via Cricket's or MetroPCS' billing system is required to submit a program summary for approval before access is granted. Cricket and MetroPCS can also audit third-party campaigns to ensure that they are functioning according to accepted standards and billing procedures.65
Ad Hoc Coalition for Enhanced Billing Services
This Coalition is a group of companies that provide "information and related services to consumers" and collects fees from those customers "by means of their local telephone company invoice."66 The Coalition contends that the Commission has exceeded its jurisdiction over "non-regulated entities that rely on LEC billing" and that some of the proposed rules are pre-empted by federal rules which allow customers to be directed to billing clearinghouses to resolve complaints.67
AGI Publishing, Inc., d/b/a Valley Yellow Pages (Valley Yellow Pages)
Valley Yellow Pages supported preventing unauthorized charges and providing subscribers refunds for unauthorized charges.68 Valley Yellow Pages encouraged the Commission to adopt stronger protections for valid billings from service providers. For example, it recommends that the rules be revised to state that a service provider's account shall not be subject to chargeback or debit for any refunds issued if the service provider has timely submitted proof of authorization. Further, it proposes that a service provider be given the opportunity to contact a subscriber to resolve a complaint, in lieu of the Billing Telephone Corporation.69
PaymentOne Corporation
In reply comments, PaymentOne stated that is a billing aggregator providing access to local exchange carriers for "companies selling digital products or services" and that its billing platforms include credit card, cell phone, direct and account debit billing.70 PaymentOne explained that it has "recently initiated an authentication protocol pursuant to which PaymentOne validates and authenticates the transaction and identity of the customer on the front" and that this new procedure has "resulted in a substantial decrease in instances of unauthorized billings."71
Small Resellers72
These firms compete with incumbent local exchange carriers, primarily for long distance services, and address the special needs of particular long distance consumers in California. Small Resellers note that they are unaware of any evidence in the record of this case that there is any increase, since GO 168 was promulgated in March of 2006, in the incidence of cramming, or unauthorized charges appearing on telephone bills. Consequently, they oppose new rules making substantially more stringent the conditions under which they can obtain billing services in this state. The Small Resellers argue that the proposed rules would allow Billing Telephone Corporations to apply looser standards for waiving third-party charges than to waiving their own charges, leading to anticompetitive strategic behavior to eliminate competition from small carriers that are dependent on Billing Telephone Corporations for billing services.
2 Opening Comments of the Division of Ratepayer Advocates on Cramming Complaint Reporting Rules Pursuant to February 12, 2010, Assigned Commissioner Ruling at 6.
3 Id. at 3 - 7.
4 Id. at 7 - 8.
5 Memorandum Opinion and Findings In Support of Preliminary Injunction, Feb. 19, 2010, F.T.C. v. Inc21.com Corp., No. C 10-00022 (N.D. Cal. March 16, 2010).
6 Id. at 10.
7 Id.
8 Id. at 13 - 14.
9 Comments of the Utility Consumers' Action Network on Assigned Commissioner's Ruling Requesting Comment on Proposed California Telephone Corporation Billing Rules at 2.
10 Id. at 11.
11 Id. at 12 - 14.
12 Id. at 14.
13 Id. at 14 - 17.
14 Id. at 17.
15 AT&T California submitted joint comments with AT&T Communications, Inc. and New Cingular Wireless, PCS, LLC.
16 Opening Comments of AT&T California, AT&T Communications of California, Inc, and New Cingular Wireless PCS, LLC. at 5.
17 Id.
18 Id. at 5 - 6.
19 Id. at 6.
20 Id. at 8 - 11.
21 Id. at 6 - 7.
22 Id. at 17.
23 Reply Comments of AT&T California, AT&T Communications of California, Inc., and New Cingular Wireless PCS, LLC. at 2.
24 Id.
25 Id. at 10.
26 Opening Comments of Verizon California, Inc. on the Assigned Commissioner Ruling Requesting Comments on New Cramming Rules at 3.
27 Id. at 7 - 12.
28 Id. at 8.
29 Id. at 12.
30 Opening Comments of SureWest Telephone on the Assigned Commissioner Ruling Requesting Comments on Proposed California Telephone Corporation Billing Rules at 1 -5.
31 Id. at 5 - 8.
32 Id. at 7.
33 Id.
34 Opening Comments of Calaveras Telephone Company, Cal-Ore Telephone Co., Ducor Telephone Company, Foresthill Telephone Company, Happy Valley Telephone Company, Hornitos Telephone Company, Kerman Telephone Co., Pinnacles Telephone Company, The Ponderosa Telephone Co., Sierra Telephone Company, Inc., The Siskiyou Telephone Company, Volcano Telephone Company, and Winterhaven Telephone Company on the Assigned Commissioner's Ruling Requesting Comment on Proposed California Telephone Corporation Billing Rules.
35 Comments of the California Association of Competitive Telecommunications Companies on on Assigned Commissioner's Ruling Requesting Comment on Proposed California Telephone Corporation Billing Rules at 3 - 5.
36 Comments of Cox California Telcom LLC, dba Cox Communications,
Cox TMI Wireless, LLC and Astound Broadband on Assigned Commissioner's Ruling Requesting Comment on Proposed California Telephone Corporation Billing Rules at pages 3 - 5.
37 Id. at 5 - 7.
38 Id. at 10.
39 Comments of BSG Clearing Solutions at 1.
40 Id. at 2.
41 Id.
42 Id. at 3.
43 Id. at 4.
44 Opening Comments of Cbeyond Communications, LLC, on on the Assigned Commissioner Ruling Requesting Comments on Proposed California Telephone Corporation Billing Rules at 1 - 2.
45 Id. at 3 - 5.
46 Comments at 7 - 9.
47 Opening Comments of ILD Teleservices, Inc., on the Assigned Commissioner Ruling Requesting Comments on Proposed California Telephone Corporation Billing Rules at 1.
48 Id.
49 Id. at 2.
50 Opening Comments of tw telecom of California, lp at 2.
51 Opening Comments of Unitedtel LLC on Assigned Commissioner's Ruling Requesting Comment and Briefing on Cramming Reporting Requirements at 3.
52 Comments of Preferred Long Distance, Inc. at 1 - 4.
53 Opening Comments of CTIA - The Wireless Association on the Assigned Commissioner Ruling Requesting Comments on Proposed California Telephone Corporation Billing Rules at 6 - 9.
54 Id. at 7.
55 Id. at 9 - 13.
56 Id. at 15 - 19.
57 Comments of Verizon Wireless on Assigned Commissioner's Ruling Requesting Comment on Proposed California Telephone Corporation Billing Rules, at 1.
58 Id. at 5.
59 Id. at 12 -14.
60 Id. at 15.
61 Id. at 23.
62 Id. at 27.
63 Id. at 31 - 32.
64 Comments of Cricket Communications, Inc., and MetroPCS California, LLC. at 3 - 6.
65 Cricket and MetroPCS Opening Comments at 6 - 7.
66 Comments of the Ad Hoc Coalition for Enhanced Billing Services at 1.
67 Id. at 2 - 3.
68 Opening Comments of AGI Publishing, Inc. d/b/a Valley Yellow at 1.
69 Id. at 3-4.
70 Reply Comments of PaymentOne Corporation at 1.
71 Id. at 6.
72 Legent Communications Corp., d/b/a Long Distance America (U6624C); Online Savings, LLC (U6981C); LD Access, LLC (U7048C); Inmark Inc., d/b/a Preferred Billing; Twin City Capital, LLC, d/b/a Small Business America and American Select; Affordable Long Distance, LLC; and ProTel Advantage, Inc., d/b/a Long Distance Savings.
