VI. OSP VIOLATED P.U. CODE SECTION §2890 (a) BY PLACING UNAUTHORIZED CHARGES ON CONSUMERS' TELEPHONE BILLS

Based on Staff's analysis of consumer complaints, interviews with and declarations from complainants, the absence of matching AMA call records, and TBR's declaration, Staff believes OSP crammed more than 250,000 California consumers by placing unauthorized collect call charges on their telephone bills. Therefore, OSP violated P.U. Code §2890(a), which states: "A telephone bill may only contain charges for products or services, the purchase of which the subscriber has authorized."