III. CRAMMING COMPLAINTS AGAINST OSP

A. cab and tbr records show substantial numbers of complaints from california consumers against osp

Staff reviewed OSP's complaint data from the Commission's CAB database⁴⁹ and found a total of 107 cramming complaints against OSP for the period 2007 through 2009. Additionally Staff reviewed the quarterly cramming complaint reports that Integretel and TBR submitted to CPSD in compliance with P.U. Code §2889.9(d).⁵⁰ Table 2 below illustrates an 823% increase in complaints TBR reported in 2009 compared to 2008 (from 1,158 to 10,691), which resulted in millions of dollars in refunds to consumers (see Table 4).

Table 2

OSP Communications Complaints

CAB and TBR Data: 2007-2009

Sources: CAB Database and TBR Quarterly Reports

(In reading Table 2, please note that from August 2007 - October 8, 2008 Integretel acted as OSP's billing aggregator; from October 9 - December 2009, TBR acted as

OSP's billing aggregator.)

After reviewing the details of the complaints made by consumers to CAB, Staff noted consumers consistently complained of receiving a charge for a collect call that the consumer neither received nor authorized. Below are excerpts of California consumers' complaints (transcribed here as found in the CAB database), which indicate collect call charges that ranged from $7.38 to $20.20.

⁴⁹ Attachment 21 (Complaints Data from CAB database).

⁵⁰ P.U. Code §2889.9(d) states: "The Commission shall establish rules that require each billing telephone company, billing agent, and ... to provide the commission with reports of complaints made by subscribers regarding the products or services that are charged on their telephone bills as a result of billing and collection services that the billing telephone company provides to third parties, including affiliates of the billing telephone company."