VIII. DISCUSSION
A. Jurisdiction
OSP, a third party service provider, and Integretel and TBR, both billing agents, are subject to the Commission's jurisdiction because they place charges on California telephone bills. Pursuant to section 2890(a), "[a] telephone bill may only contain charges for products or services, the purchase of which the subscriber has authorized." Section 2889.9(b) provides the Commission with the authority to enforce section 2890 against "a person or corporation or its billing agent that is a nonpublic utility" and to impose penalties against those entities as if they were a public utility if they have violated section 2890. In Decision (D.) 06-03-013, we addressed the expansive scope of our jurisdiction to combat violators of section 2890, even if suspected violators are not normally subject to our jurisdiction:
In enacting the laws, the Legislature stipulated that P.U. Code sections 2889.9 and 2890 apply not only to utilities, but also to non-utility billing agents and other persons or corporations responsible for generating a charge on a subscriber's phone bill. Thus the commission may impose penalties on persons or corporations that violate the cramming statutes, even if the violators typically are not subject to our jurisdiction.98
Here, the Commission is called upon to determine whether OSP violated section 2890 by placing unauthorized charges for collect calls on California telephone bills. Thus, the Commission has jurisdiction over OSP. The Commission also has jurisdiction over Integretel and TBR as billing agents who facilitated the placement of OSP charges on California telephone bills.
B. Violation of Section 2890
As stated above, section 2890 prohibits the placement of unauthorized charges for products or services on a telephone bill. Based on the evidence presented in the Staff Report, it appears that OSP violated section 2890 by systematically placing unauthorized charges on consumers' telephone bills.
The evidence appears to show that OSP charged customers for collect calls that did not occur. We seriously question the validity of any of OSP's EMI "records" it submitted to billing agents to bill customers, as neither AT&T nor Verizon could validate one single EMI "record" from the random sample Staff selected. Moreover, there were no matching AMA call records for any of the thirteen complainants that provided declarations attesting that OSP billed them for unauthorized collect calls. Furthermore, OSP's own billing agent, TBR, concluded that OSP's "call detail records and their associated billing transactions were fraudulent" based on its inability to validate its own sample of OSP's billings with any AMA records from Verizon.
Based on this overwhelming evidence, Staff infers that OSP provided fabricated EMI "records" to its billing agents for all of its billings and consequently caused California consumers to be billed for fictitious collect calls in apparent violation of section 2890. We agree. The large number of complaints lodged against OSP and OSP's extraordinarily high refund rate, on average 35% and as high as 53% for 2009, further substantiates this allegation. Staff has thoroughly investigated and corroborated its allegation against OSP for violating section 2890. Therefore, by this Order we will provide an opportunity for OSP to appear before us and show cause why it should not be fined or have any other sanctions imposed as a result of the alleged cramming.
C. Violation of Section 451
Section 451 makes every unjust or unreasonable charge demanded or received by a public utility unlawful. In D.01-04-035, the Commission found that "placing charges on a person's local telephone bill based on an invalid `authorization' is unreasonable."99 As demonstrated above, because it appears that none of OSP's supposed customers authorized the collect calls for which OSP charged them, all of OSP's charges were, therefore, unreasonable and unlawful. As with the apparent section 2890 violation, we will provide an opportunity for OSP to appear before us and show cause why it should not be fined or have any other sanctions imposed as a result of its apparent violation of section 451.
D. Violation of Section 885
Pursuant to section 885, "[a]ny entity offering the services of telephone prepaid debit cards is subject to the registration requirements of Section 1013, commencing January 1, 1999, unless that entity is certificated by the commission to provide telephone service."100 OSP may have violated this section because it did not register with the Commission to provide prepaid calling card service. Staff alleges that OSP offered prepaid calling card services in conjunction with its collect call service. While OSP appears to claim that it merely used the prepaid debit cards to market its collect call service,101 its billing agent stated otherwise. In a data response to Staff, TBR stated that OSP "is an operator service provider for collect calls and also offers calling card services."102 Therefore, whether OSP provided prepaid calling card services is a question of fact in this case the Commission will consider.
E. John Vogel Liability
Staff alleges that John Vogel was an alter ego of OSP, and should therefore be held jointly and severally liable with it for violations of pertinent statutes and regulations. Alternatively, personal liability may be predicated on a showing that
Mr. Vogel "participated directly in the practices discussed above, and had the authority to control them."103 John Vogel was the sole officer and managing member of OSP. Therefore, Staff alleges that he participated directly in the cramming practices demonstrated above and had the authority to control them.
The alter ego doctrine is grounded in equity, and said to apply only where two general requirements are met: first, there must be such a unity of interest and ownership that the separate personalities of the corporation and the controlling individuals or companies no longer exist; and, second, a failure to disregard the corporate entity must sanction a fraud or promote injustice.104 The officer, director or shareholder may also be personally liable where he "specifically directed or authorized the wrongful acts."105
Whether the corporate entity should be disregarded, and personal liability attached, depends on the facts of a particular case.106 Courts have considered an array of factors in analyzing alter ego problems, including but not limited to: commingling of funds and other assets; the unauthorized diversion of corporate funds or assets to other than corporate uses; the treatment by an individual of the assets of the corporation as his own; sole ownership of all of the stock in a corporation by one individual or the members of a family; the employment of the same attorney; common addresses and business models; and the diversion of assets from a corporation by or to a stockholder or other person or entity, to the detriment of creditors.107 Common ownership and a common business plan may also be predicates of individual liability for corporate misfeasance.108
The Commission believes there is good reason for further investigation of this issue, and will allow staff to complete discovery on the alter ego issue in this proceeding.
Staff further recommends that the Commission consider imposing restrictions on John Vogel, including permanently enjoining him from billing customers, either directly or through an intermediary, by placing any charges on any telephone bill. These restrictions would run against any business or operation John Vogel currently owns or operates as well as any future endeavors. Based on the history of cramming allegations against another Vogel-run entity (Link Systems), the egregious nature of the cramming allegations in this case against OSP, and the Commission's revocation of a license for Global Access, another Vogel entity, the Commission will also consider this recommendation.
F. Relief Respondents TBR and Integretel
We expect that billing agent/aggregators, as well as the billing telephone companies, will fully cooperate in this Investigation, as they are required to do.109 In D.99-08-017, the Commission ordered OAN and several other billing agents to
file with the Commission's Docket Office and serve on all parties, a full accounting of their respective transactions with, or on behalf of, Coral Communications, Inc. . . . Such accountings shall include, without limitation, a statement of all amounts billed for Coral/Easy Access, amounts actually collected, amounts refunded to customers, amounts disbursed to Coral/Easy Access, and amounts retained by the billing agent.110
Pursuant to our authority under P.U. Code § 2889.8(g), we order the billing agents and billing telephone companies involved in this case to provide a similar accounting, including total billings, collections, and refunds associated with Respondent OSP's charges. We ask staff to inform us of whether that has occurred.
In order to preserve the Commission's authority pursuant to section 734 to order refunds to aggrieved customers should the Commission ultimately find OSP violated section 2890, the Commission directs OSP's past and present billing agents, specifically Integretel and TBR, within 30 days of this Order to place all monies in its possession related to any OSP charges in an interest-bearing escrow or trust account pending resolution of this Investigation. Integretel and TBR shall provide CPSD with the escrow or trust account information upon CPSD's request.
G. Remedies
Upon proof of a cramming or related violation, the Commission has the authority to order restitution to any consumer who has been victimized by Respondents or their billing agents, to make that consumer whole pursuant to section 734. Staff may recommend, and the Commission may consider, penalties pursuant to &_butType=4&_butStat=0&_butNum=4&_butInline=1&_butinfo=CA PUB UTIL 2107&_fmtstr=FULL&docnum=4&_startdoc=1&wchp=dGLbVzW-zSkAA&_md5=c89469495ecf918d59ee5541683c9bf8" target="_top">P. U. Code §§ 2107 and &_butType=4&_butStat=0&_butNum=5&_butInline=1&_butinfo=CA PUB UTIL 2108&_fmtstr=FULL&docnum=4&_startdoc=1&wchp=dGLbVzW-zSkAA&_md5=9bf6595c2be92222e1aaff5530dd8f81" target="_top">2108 in the amount of $500 to $20,000 per offense per day. In addition, we may consider whether John Vogel, including any current or future entities he runs, should be permanently enjoined from placing charges on the telephone bills of California customers.
For purposes of enforcement, the Public Utilities Code extends the Commission's jurisdiction over nonpublic utilities that generate a charge on a subscriber's telephone bill. Where the Commission finds that "a person or corporation" has violated §§ 2890 and/or 2889.9, the Commission is authorized to treat that person or corporation as if it were a public utility for purposes of fines, contempt citations, and other penalties.111 The Commission also has explicit authority to order any billing telephone company to "terminate the billing and collection services" for any person or corporation failing to comply with these statutory sections.112 Finally, the Commission may "adopt rules, regulations and issue decisions and orders, as necessary, to safeguard the rights of consumers and to enforce the provisions" of Article 2, including sections 2889.9 and 2890.113
Based on the Commission's broad remedial authority pursuant to section 2889.9, the Commission may order the billing agents TBR and Integretel to return funds retained from any of OSP's unauthorized billings, as well as to order these billing agents to disgorge all proceeds retained from OSP's unauthorized billings.114
H. Categorization
This proceeding is categorized as adjudicatory. Pursuant to Rule 8.2(b) of the Commission's Rules of Practice and Procedure, ex parte communications are prohibited. The determination as to category is appealable under Rule 7.6.
Therefore, IT IS ORDERED that:
1. Pursuant to Rule 5.1 of the Commission's Rules of Practice and Procedure, an Investigation on the Commission's own motion is instituted into the operations of OSP and its owner John Vogel (collectively, Respondents), and specifically whether:
a. Respondents violated P.U. Code § 2890 by causing charges to be placed on consumers' bills for products or services which the consumers did not request or authorize;
b. OSP violated P.U. Code § 451 by placing unjust or unreasonable charges on consumers' telephone bills;
c. OSP violated P.U. Code § 885 by offering prepaid calling cards in California without Commission authorization;
d. OSP violated P.U. Code §§ 270, 431-435, 702, 739, 879 and 2881 for its failure to remit regulatory fees and surcharges on intrastate revenue for the prepaid calling cards; and
e. John Vogel is an alter ego of Respondent OSP, or so directed and authorized the acts alleged by Staff, such that his personal liability is equitable and appropriate.
2. The Commission will consider whether, pursuant to §§ 701, 734, and 1702 of the Public Utilities Code, any of the following remedies are warranted:
a. Respondents, including Relief Respondents, be ordered to disgorge all profits obtained illegally, and pay reparations, restitution, and/or refunds, pursuant to P.U. Code § 734, to California consumers in the total amount collected from them for OSP's collect call services and related charges, where consumers had not knowingly authorized the services or the amounts charged;
b. Respondents be fined pursuant to P.U. Code §§ 2107 and 2108 for the above-described violations of the Public Utilities Code and related Orders, Decisions, Rules, directions, demands and requirements of this Commission; and/or
c. Respondent John Vogel be permanently enjoined from billing customers, either directly or through an intermediary, by placing any charges on any telephone bill. This injunction would also run against any business or operation Respondent John Vogel currently owns or operates as well as any future endeavors.
3. To facilitate the completion of this investigation, and consistent with the provisions of P.U. Code §§ 311, 314, 581-82 and 584, Respondents are ordered to provide the information requested in Attachment 1 hereto within forty-five (45) days of service of this OII.
4. We direct the Process Office to add the following as "interested parties" to the service list of this proceeding: Pacific Bell Telephone (AT&T), Verizon, mCapital, LLC, and CardinalPointe Capital Group.
5. Respondents and interested parties are ordered to preserve for the pendency of this action all documents which might relate to this action, including but not limited to EMI records, reports based on EMI records, switch records, reports based on switch records, contracts (including contracts with billing agents/aggregators and third parties relative to Respondents' services and billing), invoices, correspondence, intra- and inter-office memoranda, intra- and inter-office email, electronic archives, all websites and electronic archives of information from past company websites, and consumer complaints and other expressions of dissatisfaction from California consumers. Respondents and interested parties are ordered to cooperate with staff in its investigation.
6. Billing agents Integretel and TBR and billing telephone companies AT&T and Verizon are ordered to file with the Commission's Docket Office and serve on all parties, within forty-five (45) days of service of this OII, a full accounting of their respective transactions with, or on behalf of, Respondents. Such accountings should include, without limitation, a statement on an annual basis of all amounts billed on behalf of Respondent OSP, amounts collected on behalf of Respondent OSP, amounts refunded or credited back to customer accounts, amounts retained by the billing agents and billing telephone companies for their services, amounts paid to public purpose funds (universal service and the like), and any other amounts paid out of Respondent OSP's revenue stream, i.e., out of amounts collected on behalf of Respondent OSP for the collect call services described herein. We request, to the extent possible, that the billing agents and telephone companies specify the amounts in each of these categories attributable to collect call service, administrative fee, and universal service fees or the like.
7. Staff shall continue to monitor consumer complaints against Respondents. We expect staff to bring additional evidence of any related and potentially harmful business practices to our attention. We grant staff leave to propose the addition of other parties, factual allegations, and potential violations that may arise from this additional evidence. Such proposals shall be presented to the Assigned Commissioner and Assigned Administrative Law Judge in the form of a motion to amend the OII, and shall be accompanied by a staff declaration supporting the proposed amendments. The cutoff date for advancing evidence of additional violations, for responses if appropriate, for the exchange of testimony, and other procedures as necessary shall be determined by the Assigned Commissioner or Assigned Administrative Law Judge.
8. Many of the attachments to the Staff Report were submitted as confidential
material pursuant to P.U. Code § 583. The Commission authorizes the publication of information from those attachments, to the limited extent that information is found in this OII. As to the attachments themselves, staff shall prepare and serve on Respondents and interested parties by June 17 proposed public and (to the extent appropriate) proposed confidential versions of its Staff Report, and may prepare those in several iterations to the extent that multi-party confidentiality claims must be accommodated. If Respondents or interested parties assert that any portion of the proposed public report should remain unavailable for public review, or that confidential materials should not be provided to other parties, they shall file a written motion for protection of specifically identified portions of the report and attachments, and provide legal support for these assertions, no later than July 15, 2011. CPSD shall reply by July 29, 2011.
9. The attached Consumer Protection and Safety Division Staff Report is hereby entered into the record for this proceeding.
10. Staff shall be subject only to that discovery relating to the specific violations alleged in this Order, described in the Staff Report, or added to the scope of this proceeding by subsequent motion.
11. These ordering paragraphs suffice for the "preliminary scoping memo" required by Rule 6 (c) of the Commission's Rules of Practice and Procedure.
12. This proceeding is categorized as an adjudicatory proceeding and is expected to require an evidentiary hearing. Pursuant to Rule 8.2(b) of the Commission's Rules of Practice and Procedure, ex parte communications are prohibited. The determination as to the category is appealable under Rule 7.6.
13. A prehearing conference shall be scheduled for the purpose of setting a schedule for this proceeding, including dates for discovery, amendment to the OII as necessary, exchange of written testimony, disclosure of witnesses, hearings, and briefing as appropriate in this matter.
14. The Executive Director shall cause a copy of this Order to be personally served on the Respondents' designated agent for service in California:
OSP Communications LLC
Business Filings Incorporated
311 S. Division St.
Carson City, Nevada 89703
John Vogel
1100 South 10th Street
Las Vegas, Nevada 89104
Robert N. Hocker, Esq.
Hocker & Nalu
Counsel for OSP and John Vogel
1230 Columbia Street, Suite 650
San Diego, CA 92101
The Billing Resource LLC
National Registered Agents, Inc. (C1941323)
2875 Michelle Drive, Suite 100
Irvine, CA 92606
The Billing Resource LLC d/b/a Integretel
Attn: Ken Dawson
5883 Rue Ferrari
San Jose, CA 95138
The Billing Resource LLC d/b/a Integretel
c/o Gail S. Greenwood, Esq.
Pachulski Stang Ziehl and Jones
150 California St. 15th Floor
San Francisco, CA 94111
and by delivering by Federal Express, Certified, and/or Priority Mail (such that confirmation of delivery may be verified) copies of the Order to Respondents' principal place of business, at the following addresses:
John Vogel
OSP Communications LLC
1100 S. 10th Street
Las Vegas, Nevada 89104
The Billing Resource LLC
302 Enzo Drive, Suite 162
San Jose, CA 95138
The Billing Resource LLC d/b/a Integretel
Attn: Ken Dawson
5883 Rue Ferrari
San Jose, CA 95138
In addition, a copy of this Order shall be served on local counsel for Respondents:
Robert N. Hocker, Esq.
Hocker & Nalu
Counsel for OSP and John Vogel
1230 Columbia Street, Suite 650
San Diego, CA 92101
Joseph G. Dicks, Esq.
Dicks & Workman, APC
Counsel for The Billing Resource LLC
750 B Street, Ste 2720
San Diego, CA 92101-8122
Michael H. Ahrens, Esq.
Counsel for The Billing Resource d/b/a Integretel
Sheppard, Mullin, Richter & Hampton LLP
4 Embarcadero Center, 17th Floor
San Francisco, CA 94111-4106
In addition, copies of this Order shall be served on the following interested parties, by Federal Express, Certified, and/or Priority Mail (such that confirmation of delivery may be verified):
Pacific Bell Telephone Company d/b/a AT&T California
Eric Batongbacal, Executive Director
525 Market Street, Room 1944
San Francisco, CA 94105
Verizon California, Inc.
Margo Ormiston
Specialist-State Gov't Relations
711 Van Ness Avenue, Suite 300
San Francisco, CA 94102
mCapital, LLC and CardinalPointe Capital Group
c/o Dana M. Perlman, Esq.
Perlman and Associates, A Law Corporation
9454 Wilshire Boulevard, Ste. 500
Beverly Hills, CA 90212
15. Respondents OSP and John Vogel are ordered to answer or otherwise respond to this Order within thirty (30) days of service. Respondents and any other person filing a response to this Order shall state in the response any objections to the order regarding the need for hearings, issues to be considered, or proposed schedule.
This order is effective today.
Dated: May 26, 2011, in San Francisco, California.
MICHAEL R. PEEVEY
President
TIMOTHY ALAN SIMON
MICHEL PETER FLORIO
CATHERINE J.K. SANDOVAL
MARK J. FERRON
Commissioners
ATTACHMENT 1
OII DATA REQUESTS TO RESPONDENTS OSP AND JOHN VOGEL
Unless stated otherwise, the following requests seek information and documents for years 2007-2009 inclusive, including any documents created or in effect during that time.
1. Please identify all factual statements in the above OII with which you disagree, and provide documents and evidence supporting your disagreement.
2. Please provide every script used by OSP with respect to the recording(s) played on OSP's collect call service access numbers, and identify as clearly as possible during what period of time the script was used.
3. Please state the total monies or revenues collected from California consumers in each of these five categories: operator charge; surcharge; minute usage charge; USF fee; and administrative fees. If OSP collected a charge not listed in the aforementioned categories, please also include that charge in this response. From these totals, please state all amounts paid to billing telephone companies, billing agents, universal service funds, or any other third parties.
4. Please provide California tax returns and any explanation of a discrepancy between the numbers provided in response to OII DR 3.
5. Please provide all routing instructions provided by OSP or any of its affiliates in conjunction with the access numbers it controls and/or uses in marketing its collect call services.
6. With regard to all OSP billings that Integretel billed and collected on behalf of OSP, please provide the EMI records and the associated complete AMA or switch records (containing all data fields).
7. Please provide all invoices sent by EKC, relating in whole or in part to the provision of OSP's collect call service.
8. Please provide any contract, letter agreement, email, memoranda or other documents setting forth the terms of any OSP and EKC agreement.
9. Please provide any memoranda or other documents setting forth OSP's policy regarding refunds or credits back to California (and other) consumers, which policy or policies were in effect at any time during OSP's years of operations.
10. Please provide any contracts, manuals, memoranda, product descriptions, or other documents relating to the servers and other equipment that constitute the switching platform OSP used to provide its collect call service, including contracts with EKC.
11. Please provide any memoranda, correspondence (email or otherwise), or other documents relating to OSP's use of EMI records as a defense to customer complaints, including but not limited to correspondence between or among billing agent/aggregators Integretel or TBR, OSP, EKC, AT&T, Verizon, or any of them.
12. Please provide any correspondence between or among billing agent/aggregators Integretel or TBR, OSP, EKC, AT&T, Verizon, or any of them and government agencies, regulators or prosecutors, or any of them, relating to allegations of unauthorized charges on telephone bills.
13. Please provide the transcripts of any depositions given by John Vogel relating to allegations of unauthorized charges on telephone bills.
14. Please provide any correspondence between or among billing agent/aggregators Integretel or TBR, OSP, EKC, any billing telephone company, or any of them, relating to the handling of customer complaints.
15. Please provide any regulatory complaints, inquiries, or civil complaints received by OSP over the last 5 years related to more than one allegation of unauthorized charges for collect call service, or an allegation of a pattern of conduct that was alleged to be misleading or fraudulent.
16. With regard to the debit and prepaid calling cards OSP used to market its collect call service, please provide the following:
a. A clear copy of the every calling card(s) used to advertise OSP's collect call operator service. Provide both sides of each card;
b. Legal company name(s) of the underlying calling card service providers(s);
c. Name(s) of the owners and officers of the calling card companies;
d. Name(s) of the persons in the company most knowledgeable about the calling card service;
e. Date each the company listed in response to (b) initiated its calling card service;
f. Places or locations, including addresses, where customers could purchase these debit/prepaid calling cards;
g. The amounts or denominations (i.e., $10, $20, etc.) of the calling cards;
h. State and fully discuss the business relationship between OSP Communications, LLC and the companies offering these debit/prepaid calling cards;
i. Provide the contract between OSP and the companies offering these of debit/prepaid calling cards;
j. The contract amount that OSP paid the calling card companies for advertising it's collect call services;
k. Duration period (provide month, day and year) OSP advertised its collect call service on the debit/prepaid calling cards;
l. If the OSP advertisement still appears on the debit/prepaid calling cards, explain in detail why the advertisement continues to appear on the cards if OSP ceased operating in 2009;
m. State whether the companies offering the debit/prepaid calling cards are currently registered with the California Public Utilities Commission.
17. With regard to the entities identified in Table 1 of the OII, provide the following information:
a. Business address for principle place of business;
b. Indicate whether they are still in operation;
c. Duration of service (month, date and year);
d. List services provided;
e. Update John Vogel's official role(s);
f. List John Vogel's duties and responsibilities;
g. List other telecommunications-related entities not already listed in Table 1.
98 D.06-03-013, Decision Issuing Revised General Order 168, Market Rules to Empower Telecommunications Consumers and to Prevent Fraud, Slip. Op. at 76.
99 D.01-04-035 (Coral Investigation),Slip. Op. at 27.
100 P.U. Code § 885(a).
101 Staff Report at 4-5.
102 Ibid. at 4.
103 FTC v. Inc21, supra, 688 F.Supp.2d 929, 939-940 (N.D. Cal. 2010), citing FTC v. Publishing Clearing House, Inc, 104 F.3d 1168, 1170 (9th Cir. 1997).
104 &_butType=3&_butStat=2&_butNum=4&_butInline=1&_butinfo=&_fmtstr=FULL&docnum=5&_startdoc=1&wchp=dGLbVzz-zSkAA&_md5=9b10caf05b3422cbaec1d4a6211eb479" target="_top">Watson v. Commonwealth Ins. Co, (1936) 8 C2d 61, 68.
105 Wyatt v Union Mortgage Co., 24 C3d 773, 785 (2007) ("Directors and officers of a corporation are not rendered personally liable for its torts merely because of their official positions, but may become liable if they directly ordered authorized or participated in the tortuous conduct").
106 D.03-01-079 (Titan Investigation), Slip Op. at 16, citing Alexander v. Abbey of the Chimes, 104 CA3d 39, 46 (1980). In Titan, the alter ego theory was rejected on due process grounds, because the individual alleged to be the alter ego of the corporation had not been named in the original order instituting investigation. Id,.Slip Op. at 16-17.
107 Id., citing Associated Vendors, Inc. v. Oakland Meat Co., Inc., 210 CA2d 825, 838-840 (1962) (citations omitted); other factors include: failure to maintain an arm's-length relationship among related entities. the concealment and misrepresentation of the identity of the ownership, management, and financial interest of the business, and use of same address. Id. at 839-40.
108 Wyatt v. Union Mortgage, supra, 24 C3d at 785-86 ("tightly knit, family-oriented business operation" where one individual "owned all or a controlling interest in each of the affiliated corporations").
109 P.U. Code § 2889.8(g) ("... blling agents, and telephone corporations billing for these products or services shall cooperate with the commission in the commission's efforts to enforce the provisions of this article ..."); D.99-08-917 (In re Coral Communications), 1999 Cal. PUC LEXIS 519, *4 ("We put on notice all entities which provide billing and collection services, including LECs and billing agents, that the Commission may direct them to provide information on billing services provided to respondents in future proceedings").
110 D.99-08-017 (Coral Investigation), Interim Opinion, Ordering Paragraph 1.
111 P.U. Code § 2889.9(b).
112 P.U. Code § 2889.9(c).
113 See P.U. Code § 2889.9(i).
114 See e.g., D.01-04-035 (Coral Investigation), supra, Slip. Op. at 29-34.
