Cox's Offer to Customers Whose Listings Were Erroneously Published

At about the same time the Commission was hearing testimony on the joint plan for the reclamation and reprinting of directories, Cox filed its Advice Letter No. 50, which (1) described the special measures Cox was prepared to offer customers whose numbers had been inadvertently published, and (2) sought permission for Cox to deviate from its tariffs for the purpose of making these offers.

The advice letter proposed two basic options for customers whose numbers had been erroneously published. For those customers who wanted to change to a new unlisted telephone number, Cox proposed to undertake this change without charge, and to give such customers 120 prepaid minutes to contact people who needed to know about the change. For customers who wanted to retain their old number, Cox proposed to offer a special package of free services until April 30, 2001, approximately one year after the first tainted directories had been distributed. These services-all of which were offered for the purpose of helping the customer screen out unwanted calls-included Caller ID, Call Waiting ID and Selective Call Acceptance and Rejection.

In addition to these two basic options, Cox proposed to offer "escalation procedures" for customers-such as judges and correctional officers-who had reasonable concerns about their safety as a result of the distribution of tainted directories. Cox divided these customers into four levels and sought the advice of a panel of law enforcement, domestic violence and privacy experts as to the measures appropriate for each level; it then offered to pay the customers an amount designed to cover (or help defray) the cost of the measures. The highest level included customers "who have received particular, directed threats from a specific person in the past," while the lowest level included persons "who may have security concerns, but not as a result of occupational choice." The amount Cox was prepared to offer each level of customer was filed under seal with the Telecommunications Division.