Federal Communications Commission DA 08-1322
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
CapRock Communications, Inc.
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File No. EB-07-IH-5119
NAL/Acct. No. 200832080087
FRN No. 0001-6437-66
ORDER
Adopted: June 10, 2008 Released: June 10, 2008
By the Enforcement Bureau: 
1. In this Order, we adopt the attached Consent Decree entered into between the 
Enforcement Bureau (“Bureau”) and CapRock Communications, Inc. (“CapRock”).  The Consent Decree 
terminates an investigation by the Bureau against CapRock for possible violation of, among other things, 
section 254 of the Communications Act of 1934, as amended (the “Act”),1 and sections 54.706, 54.711, 
and 64.1195 of the Commission’s rules relating to registration, regulatory filings and the universal service 
fund.2
2. The Bureau and CapRock have negotiated the terms of the Consent Decree that resolve 
this matter.  A copy of the Consent Decree is attached hereto and incorporated by reference.  
3. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree and terminating the 
investigation.
4. In the absence of material new evidence relating to this matter, we conclude that our 
investigation raises no substantial or material questions of fact as to whether CapRock possesses the basic 
qualifications, including those related to character, to hold or obtain any Commission license or 
authorization.    
5. Accordingly, IT IS ORDERED that, pursuant to section 4(i) of the Communications Act 
of 1934, as amended,3 and sections 0.111 and 0.311 of the Commission’s Rules,4 the Consent Decree 
attached to this Order IS ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigation IS 
TERMINATED.
7. IT IS FURTHER ORDERED that CapRock shall make its voluntary contribution to the 
United States Treasury, as specified in the Consent Decree, by mailing a check or similar instrument 
  
1 47 U.S.C. § 254.
2 47 C.F.R. §§ 54.706, 54.711, and 64.1195.
3 47 U.S.C. § 154(i).
4 47 C.F.R. §§ 0.111, 0.311.
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payable to the Order of the Federal Communications Commission, to Federal Communications 
Commission, P.O. Box 979088, St. Louis, MO 63197-9000.  Payment by overnight mail may be sent to 
U.S. Bank – Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
63101.  Payment[s] by wire transfer may be made to ABA Number 021030004, receiving bank Federal 
Reserve Bank of New York, and account number 27000001.  For payment by credit card, an FCC Form 
159 (Remittance Advice) must be submitted. When completing the FCC Form 159, enter the 
NAL/Account number in block number 23A (call sign/other ID), and enter the letters “FORF” in block 
number 24A (payment type code). CapRock shall also send electronic notification of payment of the 
voluntary contribution on the date said payment is made to michele.berlove@fcc.gov.
8. IT IS FURTHER ORDERED that CapRock will file reports with the Commission 
ninety days after the effective date of the Consent Decree, as defined therein (“Effective Date”) and 
twelve months after the Effective Date.  Each report shall include a compliance certificate from an officer, 
as an agent of CapRock, stating that the officer has personal knowledge that CapRock has established 
operating procedures intended to ensure compliance with this Consent Decree, together with an 
accompanying statement explaining the basis for the officer’s compliance certification.  All reports shall 
be submitted to Hillary S. DeNigro, Chief, Investigations and Hearings Division, Enforcement Bureau, 
Federal Communications Commission, 445 12th Street, S.W., Washington, D.C. 20554.  The Company 
shall also transmit a copy of the reports via email to hillary.denigro@fcc.gov.
9. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first class mail and certified mail, return receipt requested, to C. Douglas Jarrett, Keller & 
Heckman LLP, 1001 G Street, N.W., Suite 500 West, Washington, D.C. 20001.
FEDERAL COMMUNICATIONS COMMISSION
Kris Anne Monteith
Chief, Enforcement Bureau
Federal Communications Commission DA 08-1322
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Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
CapRock Communications, Inc.
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)
)
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File No. EB-07-IH-5119
NAL/Acct. No. 200832080087
FRN No. 0001-6437-66
CONSENT DECREE
1. The Enforcement Bureau (“Bureau”) and CapRock Communications, Inc. (“CapRock”), 
by their authorized representatives, hereby enter into this Consent Decree for the purpose of terminating 
the Enforcement Bureau’s investigation into whether CapRock violated, among other things, section 254 
of the Communications Act of 1934, as amended (the “Act”)5 and sections 54.706, 54.711, and 64.1195 
of the Commission’s rules6 relating to registration, regulatory filings and the universal service fund 
(“USF”). 
I.         DEFINITIONS
2. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended, 47 U.S.C. § 151 et seq.
(b) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(c) “CapRock” means CapRock Communications, Inc. and its predecessors-in-interest 
and successors-in-interest.
(d) “Commission” and “FCC” mean the Federal Communications Commission and all of 
its bureaus and offices.  
(e) “Compliance Plan” means the program described in this Consent Decree at paragraph 
10.
(f) “Effective Date” means the date on which the Commission releases the Adopting 
Order.
(g) “Investigation” means the investigation commenced by the Bureau’s May 24, 2007 
Letter of Inquiry7 regarding whether CapRock violated, among other things, section 
254(d) of the Communications Act of 1934, as amended (the “Act”) and sections 
  
5 47 U.S.C. § 254.
6 47 C.F.R. §§ 54.706, 54.711, and 64.1195.
7See Letter from Trent B. Harkrader, Deputy Chief, Investigations and Hearings Division, Enforcement Bureau, 
FCC, dated May 24, 2007 (“May 24, 2007 LOI”).
Federal Communications Commission DA 08-1322
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54.706, 54.711, and 64.1195 of the Commission’s rules relating to registration, 
regulatory filings and the universal service fund.8  
(h) “Order” or “Adopting Order” means an Order of the Commission adopting the terms 
of this Consent Decree without change, addition, deletion, or modification.
(i) “Parties” means CapRock and the Bureau.
(j) “Rules” means the Commission’s regulations found in Title 47 of the Federal 
Regulations.
II. BACKGROUND
3. Pursuant to section 64.1195(a) of the Commission’s rules and pursuant to Commission 
orders, all carriers that provide interstate telecommunications service and certain other providers of 
interstate telecommunications must register with the Commission through submission of FCC Form 499-
A.9 In addition, section 254(d) of the Act and sections 54.706 and 54.711 of the rules require 
telecommunications carriers that provide interstate telecommunications services to file annual and 
quarterly Telecommunications Reporting Worksheets (FCC Form 499-A and FCC Form 499-Q) and 
contribute to the USF on the basis of their interstate and international end-user telecommunications 
revenues.
4. CapRock, a Texas-based company, is a niche provider of telecommunications, offering 
primarily international satellite services worldwide to the energy, maritime, construction and mining 
industries, as well as for disaster relief and government applications, but also providing interstate 
telecommunications in the United States.  CapRock thus is subject to the requirements discussed in 
paragraph 3 above.
5. On March 23, 2007, through counsel, CapRock self-disclosed to the Bureau that it had 
discovered that it had failed to comply with certain regulations pertaining to universal service and other 
associated reporting and contribution obligations. CapRock also indicated that it would be submitting its 
registration, annual and quarterly Telecommunications Reporting Worksheets for prior reporting periods, 
all of which were submitted on April 2, 2007.  On May 24, 2007, the Bureau issued a letter of inquiry 
(“LOI”) to CapRock directing it to provide certain documents and information.10 CapRock submitted its 
  
8 47 U.S.C. § 254(d); 47 C.F.R. §§ 54.706, 54.711, and 64.1195.
9 47 U.S.C. § 254(d), 47 C.F.R. § 64.1195(a); Universal Service Contribution Methodology, Federal-State Joint 
Board on Universal Service, 1998 Biennial Regulatory Review – Streamlined Contributor Reporting Requirements 
Associated with Administration of Telecommunications Relay Service, North American Numbering Plan, Local 
Number Portability, and Universal Service Support Mechanisms, Telecommunications Services for Individuals with 
Hearing and Speech Disabilities, and the Americans with Disabilities Act of 1990, Administration of the North 
American Numbering Plan and North American Numbering Plan Cost Recovery Contribution Factor and Fund 
Size, Number Resource Optimization, Telephone Number Portability, Truth-In-Billing and Billing Format, IP-
Enabled Services, Report and Order and Notice of Proposed Rulemaking, WC Docket Nos. 06-122 and 04-36, CC 
Docket Nos. 96-45, 98-171, 90-571, 92-237, 99-200, 95-116, and 98-170, 21 FCC Rcd 7518, 7548-49, para. 61 
(2006).
10 See LOI.  
Federal Communications Commission DA 08-1322
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response on June 13, 2007.11 On August 6, 2007, the Bureau sent a follow-up letter of inquiry to 
CapRock,12 to which CapRock responded on August 27, 2007 and September 12, 2007.13  
III. TERMS OF AGREEMENT
6. Adopting Order.  The Parties agree that the provisions of this Consent Decree shall be 
subject to final approval by the Bureau by incorporation of such provisions by reference in the Adopting 
Order without change, addition, modification, or deletion.
7. Jurisdiction. CapRock agrees that the Bureau has jurisdiction over it and the matters 
contained in this Consent Decree and has the authority to enter into and adopt this Consent Decree.
8. Effective Date:  Violations.  The Parties agree that this Consent Decree shall become 
effective on the date on which the FCC releases the Adopting Order.  Upon release, the Adopting Order 
and this Consent Decree shall have the same force and effect as any other Order of the Bureau.  Any 
violation of the Adopting Order or of the terms of this Consent Decree shall constitute a separate violation 
of a Bureau Order, entitling the Bureau to exercise any rights and remedies attendant to the enforcement 
of a Commission Order.
9. Termination of Investigation.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
terminate its investigation.  In consideration for the termination of said investigation, CapRock agrees to 
the terms, conditions, and procedures contained herein.  The Bureau further agrees that in the absence of 
new material evidence, the Bureau will not use the facts developed in this investigation through the 
Effective Date of the Consent Decree, or the existence of this Consent Decree, to institute, on its own 
motion, any new proceeding, formal or informal, or take any action on its own motion against CapRock 
concerning the matters that were the subject of the investigation, nor will the Bureau recommend any 
such action to the Commission.  The Bureau also agrees that it will not use the facts developed in this 
investigation through the Effective Date of this Consent Decree, or the existence of this Consent Decree, 
to institute on its own motion any proceeding, formal or informal, or take any action on its own motion 
against CapRock with respect to CapRock’s basic qualifications, including its character qualifications, to 
be a Commission licensee or authorized common carrier or hold Commission authorizations, nor will the 
Bureau recommend any such action to the Commission.
10. Compliance Plan. CapRock agrees that it will develop, within sixty (60) calendar days 
from the Effective Date, an internal Compliance Plan to ensure CapRock’s future compliance with the 
Act, the Commission’s rules, and the Commission’s orders governing reporting and USF contribution 
requirements for providers of telecommunications.  The Compliance Plan includes the following 
components: 
  
11 See LOI Response, dated June 12, 2007 but forwarded to the Commission under cover letter from C. Douglas 
Jarrett, Keller and Heckman LLP, to Vickie S. Robinson, Assistant Chief, Investigations and Hearings Division, 
Enforcement Bureau, FCC, dated June 13, 2007.
12 Letter from Trent B. Harkrader, Deputy Chief, Investigations and Hearings Division, Enforcement Bureau, FCC, 
to C. Douglas Jarrett, Keller and Heckman LLP, dated August 6, 2007 (“Supplemental LOI”).
13 Letters from C. Douglas Jarrett, Keller and Heckman LLP, to Michele Levy Berlove, Attorney Advisor, 
Investigations and Hearings Division, Enforcement Bureau, FCC, dated August 27 and September 12, 2007 
(“Supplemental LOI Responses”).
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(a) Compliance Manual.  CapRock shall create, maintain and update a USF Compliance 
Manual.  CapRock personnel who engage in activities related to USF compliance and 
reporting obligations of CapRock will have ready access to the Compliance Manual 
and are to follow the procedures contained therein.  The Compliance Manual will, 
among other things, describe the rules and requirements as they apply to CapRock 
regarding USF compliance and reporting obligations.  The Compliance Manual will 
set forth a schedule of filing and payment dates associated with the USF, and 
CapRock will create compliance notifications that alert CapRock to upcoming filing 
and payment dates.  The Compliance Manual will encourage personnel to contact 
CapRock’s Designated Contact and Regulatory Legal Counsel with any questions or 
concerns that arise with respect to CapRock’s USF compliance and reporting 
obligations.  
(b) Compliance Training Program. CapRock will establish an USF compliance training 
program for any employee who engages in activities related to  CapRock’s USF 
compliance and reporting obligations.  Training sessions will be conducted for such 
employees to ensure such employees are informed regarding all applicable USF 
obligations, and, for new employees who are engaged in such activities, within the 
first sixty (60) days of employment.
(c) Designated Contact.  CapRock will designate one employee as the point of contact 
for all USF compliance obligations.
(d) Review and Monitoring.  CapRock will review the USF Compliance Manual and 
USF Compliance Training Program to ensure that they are maintained in a proper 
manner and continue to address the objectives set forth therein.
(e) Audits.  CapRock will ensure that any internal reviews of this Compliance Plan, if 
conducted, specifically consider compliance with the pertinent USF requirements.
(f) Compliance Reports.  CapRock will file compliance reports with the Commission 
ninety days after the Effective Date and twelve (12) months after the Effective Date.  
Each compliance report shall include a compliance certificate from an officer or 
responsible official, as an agent of CapRock, stating that the individual has personal 
knowledge that CapRock has established operating procedures intended to ensure 
compliance with this Consent Decree, together with an accompanying statement 
explaining the basis for the officer’s or responsible official’s compliance 
certification.  All compliance reports shall be submitted to Hillary S. DeNigro, Chief, 
Investigations and Hearings Division, Enforcement Bureau, Federal Communications 
Commission, 445 12th Street, S.W., Washington, D.C. 20554.  The Company shall 
also transmit a copy of the reports via email to hillary.denigro@fcc.gov.  
(g) Termination Date: Unless stated otherwise, the compliance requirements under this 
Consent Decree will expire twelve (12) months after the Effective Date.
11. Voluntary Contribution.  CapRock agrees that it will make a voluntary contribution to 
the United States Treasury in the amount of one-hundred nine thousand and four hundred dollars 
($109,400), to be paid in three equal installments on July 1, 2008, October 1, 2008 and January 2, 2009.  
Each payment must be made by check or similar instrument, payable to the order of the Federal 
Communications Commission.  The payment must include the Account Number and FRN Number 
referenced in the caption to the Adopting Order.  Payment by check or money order may be mailed to 
Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000. Payment by 
Federal Communications Commission DA 08-1322
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overnight mail may be sent to U.S. Bank – Government Lockbox #979088, SL-MO-C2-GL, 1005 
Convention Plaza, St. Louis, MO 63101.  Payments by wire transfer may be made to ABA Number 
021030004, receiving bank Federal Reserve Bank of New York, and account number 27000001.  
CapRock will also send electronic notification within forty-eight (48) hours of the date said payment is 
made to michele.berlove@fcc.gov.
12. Waivers.  CapRock waives any and all rights it may have to seek administrative or 
judicial reconsideration, review, appeal or stay, or to otherwise challenge or contest the validity of this 
Consent Decree and the Order adopting this Consent Decree, provided the Commission issues an Order 
adopting the Consent Decree without change, addition, modification, or deletion.  CapRock shall retain 
the right to challenge Commission interpretation of the Consent Decree or any terms contained herein.  If 
either Party (or the United States on behalf of the Commission) brings a judicial action to enforce the 
terms of the Adopting Order, neither CapRock nor the Commission shall contest the validity of the 
Consent Decree or the Adopting Order, and CapRock shall waive any statutory right to a trial de novo.  
CapRock hereby agrees to waive any claims it may otherwise have under the Equal Access to Justice Act, 
5 U.S.C. § 504 and 47 C.F.R. § 1.1501 et seq., relating to the matters addressed in this Consent Decree.
13. Severability. The Parties agree that if any of the provisions of the Adopting Order or the 
Consent Decree shall be invalid or unenforceable, such invalidity or unenforceability shall not invalidate 
or render unenforceable the entire Adopting Order or Consent Decree, but rather the entire Adopting 
Order or Consent Decree shall be construed as if not containing the particular invalid or unenforceable 
provision or provisions, and the rights and obligations of the Parties shall be construed and enforced 
accordingly.  In the event that this Consent Decree in its entirety is rendered invalid by any court of 
competent jurisdiction, it shall become null and void and may not be used in any manner in any legal 
proceeding.
14. Subsequent Rule or Order. The Parties agree that if any provision of the Consent 
Decree conflicts with any subsequent rule or Order adopted by the Commission (except an Order 
specifically intended to revise the terms of this Consent Decree to which CapRock does not expressly 
consent) that provision will be superseded by such Commission rule or Order.
15. Successors and Assigns. CapRock agrees that the provisions of this Consent Decree 
shall be binding on its successors, assigns, and transferees.  
16. Final Settlement. The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties.  The Parties further agree that this Consent Decree does 
not constitute either an adjudication on the merits or a factual or legal finding or determination regarding 
any compliance or noncompliance with the requirements of the Act or the Commission’s Rules and 
Orders.  The Parties further agree that this Consent Decree is for settlement purposes only and that by 
agreeing to the Consent Decree, CapRock does not admit any liability for violating the Act or the 
Commission rules or orders in connection with the matters that are the subject of this Consent Decree.
17. Modifications. This Consent Decree cannot be modified without the advance written 
consent of both Parties.
18. Paragraph Headings. The headings of the Paragraphs in this Consent Decree are 
inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent 
Decree.
19. Authorized Representative.  Each party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.
Federal Communications Commission DA 08-1322
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20. Counterparts. This Consent Decree may be signed in any number of counterparts 
(including by facsimile), each of which, when executed and delivered, shall be an original, and all of 
which counterparts together shall constitute one and the same fully executed instrument.
________________________________
Kris Anne Monteith
Chief
Enforcement Bureau 
________________________________
Date
________________________________
Alan B. Aronowitz
General Counsel
CapRock Communications, Inc.  
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Date