2. Company Background

88 Telecom Corporation (88 Telecom), a California Corporation, with offices in San Francisco, is a vendor of prepaid telephone debit cards. 88 Telecom has been in business since January 2004. In May 2008, 88 Telecom filed this application to obtain a certificate of public convenience and necessity (CPCN), to provide inter - and intra - local access and transport area services in California as a non-dominant interexchange carrier, after learning from Qwest Communications (Qwest) that it must have operating authority in California. 88 Telecom had been operating under the assumption that it already had operating authority through a company called True America Communications, Inc. (True America), which was the previous company owned and operated by Eddie Wong, who was the secretary and co-owner of 88 Telecom at the time of incorporation in 2004. However, because of the inquiry by Qwest, 88 Telecom realized that True America's CPCN had been revoked by Commission Resolution T-16892.