VIII. OSP DOES NOT HAVE OPERATING AUTHORITY IN CALIFORNIA BUT MAY BE PROVIDING A SERVICE THAT REQUIRES REGISTRATION WITH THE COMMISSION

According to Mr. Vogel, OSP provided only interstate calls¹⁰⁴ for its collect call operator service. If such were the case then OSP did not need Commission operating authority. However, in addition to operator services, OSP appears to be a provider of prepaid calling card services according to its billing aggregator, (see discussion in Section II.A.1.), thus, Staff believes OSP is in violation of P.U. Code §885(a), which states:

Any entity offering the services of telephone prepaid debit cards is subject to the registration requirements of Section 1013...unless the entity is certificated by the [C]ommission to provide telephone service.

¹⁰⁴ Attachment 2 (OSP Response received on March 8, 2011 by CPSD).