TABLE OF CONTENTS
I. SUMMARY 4
II. COMPANY BACKGROUND 5
A. Services Provided by Americatel 7
B. Americatel's marketing strategy 8
III. CRAMMING COMPLAINTS AGAINST AMERICATEL 9
A. High Levels of Cramming Complaints 9
B. Complaints Resulted From Fraudulent Behavior of Americatel's Marketing Vendor 10
1. Americatel Admitted That Cramming Occurred 12
2. 61,097 California Consumers Were Crammed as a Result of Americatel's Marketing Vendor's Forging the Letters of Authorization 12
3. Americatel Refunded a Total of $1.5 Million to the California Customers Affected by Fraudulent Sales Conducted by Its Marketing Vendor 13
IV. STAFF'S ANALYSIS OF CRAMMING COMPLAINTS AGAINST AMERICATEL 14
A. Cramming Complaint Data From Americatel 14
B. Cramming Complaints Data From CAB 16
C. Complaints with CAB Show that Most Consumers Alleged Cramming, Continuous Billing Even After Cancellation Was Requested and Inadequate Service Provision 18
D. Declarations From Complainants Show Americatel Crammed Them 20
V. STAFF DISCOVERED AMERICATEL OVERCHARGED CUSTOMERS $2 MILLION IN RATES AND FEES 20
VI. AMERICATEL FAILED TO PERFORM DUE DILIGENCE IN ESTABLISHING BUSINESS RELATIONSHIP WITH ITS MARKETING VENDOR 22
VII. AMERICATEL FAILED TO ADEQUATELY MONITOR THE ACTIVITIES OF ITS MARKETING VENDOR 23
VIII. AMERICATEL VIOLATED P.U. CODE SECTION §2890 (A) BY PLACING UNAUTHORIZED CHARGES ON CONSUMERS' TELEPHONE BILLS AND BY OVERCHARGING THEM 25
IX. AMERICATEL VIOLATED P.U. CODE §451 25
X. RECOMMENDATIONS 25
