ATTACHMENT B CONSUMER PROTECTION AND SAFETY DIVISION California Public Utilities Commission INVESTIGATIVE REPORT ON LEGACY LONG DISTANCE INTERNATIONAL, INC. I.10-06-013

TABLE OF CONTENTS

I. SUMMARY 11

II. BACKGROUND 22

A. Legacy and Its Operations 22

B. CPSD's Protest Of Legacy's Application For Expanded Authority 44

C. Consumer Cramming Complaints Against Legacy 55

1. Consumer Complaints Filed with Billing Aggregator BSG 55

2. Consumer Complaints Filed with the Commission's CAB 66

D. Scope Of CPSD Investigation 88

III. LEGACY VIOLATED P.U. CODE §2890(a) BY PLACING UNAUTHORIZED CHARGES ON CONSUMERS' TELEPHONE BILLS 99

A. LEGACY BILLED FOR COLLECT CALLS THAT DID NOT OCCUR 1010

B. Legacy Billed For Unauthorized Third Party Billing 1313

C. Legacy Billed For Calls That Did Not Connect Well 1414

D. Legacy Billed For Rejected Collect Calls 1414

E. Legacy Billed For Collect Calls Left On Answering Machines 1515

IV. LEGACY VIOLATED P.U. CODE §2896(a), §451, AND THE FEDERAL TELECOMMUNICATIONS ACT SECTION 226 BY FAILING TO DISLCOSE RATE INFORMATION TO ITS CONSUMERS 1616

V. LEGACY VIOLATED P.U. CODE §489(a) BY FAILING TO FILE ITS COMPLETE TARIFF TIMELY 1919

VI. LEGACY VIOLATED P.U. CODE §532 BY CHARGING CONSUMERS RATES IN EXCESS OF ITS FILED TARIFFS 1919

VII. LEGACY VIOLATED THE COMMISSION'S RULE 1.1 BY FAILING TO DISCLOSE NUMEROUS REGULATORY SANCTIONS IT SUSTAINED IN 16 OTHER STATES 2020

VIII. CPSD RECOMMENDS THE COMMISSION OPEN AN ORDER INSTITUTING INVESTIGATION 2323

APPENDICES