Federal Communications Commission DA 10-1250
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Global Information Technologies
Compliance with the Commission’s
Rules and Regulations Governing Customer
Proprietary Network Information and Universal 
Service Fund Line-Item Charges
)
)
)
)
)
)
)
)
)
)
File No. EB-08-TC-4005
File No. EB-08-IH-0615
NAL/Acct. No. 201132080011
FRN: 0007350226
ORDER
Adopted:  October 4, 2010 Released:  October 5, 2010
By the Chief, Enforcement Bureau: 
1. In this Order, we adopt the attached Consent Decree entered into between the 
Enforcement Bureau (the “Bureau”) and Global Information Technologies (“GIT”).  The Consent Decree 
terminates the enforcement proceedings initiated by the Bureau against GIT for possible violation of 
section 222 of the Communications Act of 1934, as amended (“Act”),1 section 64.2009(e) of the Federal 
Communications Commission’s (“Commission”) rules,2 and the Commission’s EPIC CPNI Order 
relating to the confidentiality of customer proprietary network information, and, among other things, 
section 254 of the Act3 and section 54.712(a) of the Commission’s rules4 relating to the recovery of 
universal service fund contributions from end-user customers.
2. The Bureau and GIT 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 
investigations.
4. In the absence of material new evidence relating to this matter, we conclude that the 
Bureau’s investigations raise no substantial or material questions of fact as to whether GIT possesses the 
basic qualifications, including those related to character, to hold or obtain any Commission license or 
authorization. 
  
1 47 U.S.C. § 222.
2 47 C.F.R. § 64.2009(e).
3 47 U.S.C. § 254.
4 47 C.F.R. § 54.712(a).
Federal Communications Commission DA 10-1250
2
5. Accordingly, IT IS ORDERED that, pursuant to section 4(i) of the Act,5 and sections 
0.111 and 0.311 of the Commission’s Rules,6 the Consent Decree attached to this Order IS ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigations ARE 
TERMINATED.
7. 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, Ginger Washburn, President, Global 
Information Technologies, GIT Satellite LLC, 13740 Research Blvd, Suite Q-2, Austin, TX 78750.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
  
5 47 U.S.C. § 154(i).
6 47 C.F.R. §§ 0.111, 0.311.
Federal Communications Commission DA 10-1250
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Global Information Technologies
Compliance with the Commission’s
Rules and Regulations Governing Customer
Proprietary Network Information and Universal 
Service Fund Line-Item Charges
)
)
)
)
)
)
)
)
)
)
File No. EB-08-TC-4005
File No. EB-08-IH-0615
NAL/Acct. No.  201132080011
FRN:  0007350226
CONSENT DECREE
I. INTRODUCTION
1. The Enforcement Bureau (“the Bureau”) of the Federal Communications Commission 
(the “Commission” or “FCC”) and Global Information Technologies (“GIT”) hereby enter into this 
Consent Decree for the purpose of terminating the Bureau investigations against GIT for possible 
violation of section 222 of the Communications Act of 1934, as amended (“Act”),1 section 64.2009(e) of 
the Commission’s rules,2 and the Commission’s EPIC CPNI Order relating to the confidentiality of 
customer proprietary network information, and, among other things, section 254 of the Act3 and section 
54.712(a) of the Commission’s rules4 relating to the recovery of universal service fund contributions from 
end-user customers.
II. 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) “Adopting Order” means an Order of the Commission adopting the terms of this Consent 
Decree without change, addition, deletion, or modification.
(c) “GIT” means Global Information Technologies and its predecessors-in-interest and 
successors-in-interest.
(d) “GIT Investigation (EB-08-TC-4005)” means the investigation commenced by the 
Bureau’s Letter of Inquiry and Omnibus Notice of Apparent Liability For Forfeiture.5
  
1 47 U.S.C. § 222.
2 47 C.F.R. § 64.2009(e).
3 47 U.S.C. § 254.
4 47 C.F.R. § 54.712(a).
5 See Annual CPNI Certification, Omnibus Notice of Apparent Liability for Forfeiture, 24 FCC Rcd 2299, 2301 
para. 4  (Enforcement  Bureau 2009) (“Omnibus NAL”).
Federal Communications Commission DA 10-1250
2
(e) “GIT Investigation (EB-08-IH-0615)” means the investigation commenced by the 
Bureau’s March 17, 2008 Letter of Inquiry6 and the Bureau’s June 10, 2008 
Supplemental Letter of Inquiry to GIT.7
(f) “Bureau” means the Enforcement Bureau of the Federal Communications Commission.
(g) “Commission” and “FCC” mean the Federal Communications Commission and all of its 
bureaus and offices.  
(h) “Compliance Plan” means the program described in this Consent Decree at paragraph 11
(i) “Effective Date” means the date on which the Commission releases the Adopting Order.
(j) “Parties” means GIT and the Bureau.
(k) “Rules” means the Commission’s regulations found in Title 47 of the Code of Federal 
Regulations.
III. BACKGROUND
CPNI Investigation
3.  Section 222 imposes the general duty on all telecommunications carriers to protect the 
confidentiality of their subscribers’ proprietary information.8 The Commission has issued rules 
implementing section 222 of the Act.9 The Commission required carriers to establish and maintain a 
  
6See Letter from Trent B. Harkrader, Deputy Chief, Investigations and Hearings Division, Enforcement Bureau, 
FCC, to Ginger Washburn, Chief Executive Officer, Global Information Technologies, dated March 17, 2008 
(“LOI”). 
7 See Letter from Trent B. Harkrader, Deputy Chief, Investigations and Hearings Division, Enforcement Bureau, 
FCC, to Ginger Washburn, Chief Executive Officer, Global Information Technologies, dated June 10, 2008 
(“Supplemental LOI”).
8 Section 222 of the Communications Act, 47 U.S.C § 222, provides that:  “Every telecommunications carrier has a 
duty to protect the confidentiality of proprietary information of, and relating to, other telecommunications carriers, 
equipment manufacturers, and customers, including telecommunication carriers reselling telecommunications 
services provided by a telecommunications carrier.”  Prior to the 1996 Act, the Commission had established CPNI 
requirements applicable to the enhanced services operations of AT&T, the Bell Operating Companies (“BOCs”), 
and GTE, and the customer premises equipment (“CPE”) operations of AT&T and the BOCs, in the Computer II, 
Computer III, GTE Open Network Architecture (“ONA”), and BOC CPE Relief proceedings.  See Implementation 
of the Telecommunications Act of 1996: Telecommunications Carriers’ Use of Customer Proprietary Network 
Information and Other Customer Information and Implementation of Non-Accounting Safeguards of Sections 271 
and 272 of the Communications Act of 1934, as amended, CC Docket Nos. 96-115 and 96-149, Second Report and 
Order and Further Notice of Proposed Rulemaking, 13 FCC Rcd 8061, 8068-70, para. 7 (1998) (“CPNI Order”) 
(describing the Commission’s privacy protections for confidential customer information in place prior to the 1996 
Act.
9 See CPNI Order.  See also Implementation of the Telecommunications Act of 1996: Telecommunications Carriers' 
Use of Customer Proprietary Network Information and Other Customer Information and Implementation of the 
Non-Accounting Safeguards of Sections 271 and 272 of the Communications Act of 1934, as amended, CC Docket 
Nos. 96-115 and 96-149, Order on Reconsideration and Petitions for Forbearance, 14 FCC Rcd 14409 (1999);
Implementation of the Telecommunications Act of 1996: Telecommunications Carriers’ Use of Customer 
Federal Communications Commission DA 10-1250
3
system designed to ensure that carriers adequately protected their subscribers’ CPNI.  Section 64.2009(e) 
is one such requirement.  In 2006, some companies, known as “data brokers,” advertised the availability 
of records of wireless subscribers’ incoming and outgoing telephone calls for a fee.10 Data brokers also 
advertised the availability of certain landline toll calls.11  On April 2, 2007, the Commission strengthened 
its privacy rules with the release of the EPIC CPNI Order,12 which adopted additional safeguards to 
protect CPNI against unauthorized access and disclosure. The EPIC CPNI Order was directly responsive 
to the actions of databrokers, or pretexters, to obtain unauthorized access to CPNI.13  The EPIC CPNI 
Order requires that all companies subject to the CPNI rules file annually, on or before March 1, a 
certification with the Commission pursuant to amended rule 47 C.F.R. § 64.2009(e).14 Additionally, 
companies must now provide, with their certification, “an explanation of any actions taken against data 
brokers and a summary of all customer complaints received in the past year concerning the unauthorized 
release of CPNI.”15
4. GIT Investigation (EB-08-TC-4005): A number of companies failed to comply with 
the annual certification filing requirement and did not file compliance certifications on or before March 1, 
2008, for the 2007 calendar year. GIT was one of those companies.16 As a result, the Bureau sent a Letter 
of Inquiry to GIT and the other companies, asking them to provide copies and evidence of its annual 
CPNI certification filings.17 GIT failed to submit satisfactory evidence of its timely filing of its annual 
CPNI certifications.18 GIT ultimately filed its 2007 CPNI certification on September 10, 2008.19 In its 
Omnibus Notice of Apparent Liability for Forfeiture, the Bureau determined that as a result of GIT’s 
    
Proprietary Network Information and Other Customer Information and Implementation of the Non-Accounting 
Safeguards of Sections 271 and 272 of the Communications Act of 1934, as amended, CC Docket Nos. 96-115 and 
96-149; 2000 Biennial Regulatory Review -- Review of Policies and Rules Concerning Unauthorized Changes of 
Consumers’ Long Distance Carriers, CC Docket No. 00-257, Third Report and Order and Third Further Notice of 
Proposed Rulemaking, 17 FCC Rcd 14860 (2002); EPIC CPNI Order.
10 See, e.g., http://www.epic.org/privacy/iei/.
11 See id.
12 EPIC CPNI Order, 22 FCC Rcd 6927.  Specifically, pursuant to section 64.2009(e):  A telecommunications 
carrier must have an officer, as an agent of the carrier, sign and file with the Commission a compliance certificate on 
an annual basis.  The officer must state in the certification that he or she has personal knowledge that the company 
has established operating procedures that are adequate to ensure compliance with the rules in this subpart.  The 
carrier must provide a statement accompanying the certification explaining how its operating procedures ensure that 
it is or is not in compliance with the rules in this subpart.  In addition, the carrier must include an explanation of any 
actions taken against data brokers and a summary of all customer complaints received in the past year concerning 
the unauthorized release of CPNI.  This filing must be made annually with the Enforcement Bureau on or before 
March 1 in EB Docket No. 06-36, for data pertaining to the previous calendar year.  47 C.F.R. § 64.2009(e).
13 Id. at 6928.
14 Id. at 6953; 47 C.F.R. § 64.2009(e).
15 EPIC CPNI Order, 22 FCC Rcd at 6953.
16 See Omnibus NAL, 24 FCC Rcd at 2308, Appendix.
17 See Annual CPNI Certification, Omnibus Notice of Apparent Liability for Forfeiture, 24 FCC Rcd 2299, 2301 
para. 4  (Enforcement Bureau 2009) (“Omnibus NAL”).
18 Id.
19 See Letter from Thomas Lynch, Counsel for Global Information Technologies, to Marlene H. Dortch, Secretary, 
FCC, dated Sept. 10, 2008.
Federal Communications Commission DA 10-1250
4
failure to file annual CPNI certifications, GIT (and the other companies) was in apparent violation of 
section 222 of the Act, section 64.2009(e) of the Commission’s rules, and the Commission’s EPIC CPNI
Order.   On March 10, 2009, GIT filed its response to the Omnibus NAL.20
Universal Service Investigation
5. The Commission’s rules require that entities providing interstate telecommunications 
services and certain other providers of interstate telecommunications contribute to the federal universal 
service fund (“USF”) based upon their interstate and international end-user telecommunications 
revenues.21 The Commission does not require contributors to recover their universal service contributions 
from their customers.22 Instead, the Commission allows contributors to recover their universal service 
contributions from their customers, subject to certain requirements.23  Specifically, section 54.712 of the 
Commission’s rules provides that contribution costs passed through to end-user customers as federal 
universal service line-item charges may not exceed the interstate telecommunications portion of the 
customers’ bills multiplied by the relevant contribution factor.24 In addition, section 201(b) requires that 
all carrier charges, practices, classifications, and regulations “for and in connection with” interstate 
communications services be just and reasonable, and gives the Commission jurisdiction to enact rules to 
implement that requirement.25
6. GIT Investigation (EB-08-IH-0615): GIT offers interstate telecommunications 
services, primarily satellite services, and is subject to the requirements discussed above.  On March 17, 
2008, the Bureau sent a Letter of Inquiry (“LOI”) to GIT inquiring about its compliance with the 
Commission’s universal service filing and contribution rules, as well as its rules relating to the recovery 
from end-user customers of a common carrier’s contributions to the universal service fund, the 
telecommunications relay service fund, the North American Numbering Plan administration, and local 
number portability administration.26 GIT submitted a series of responses between March 25 and April 15, 
  
20 See Letter from Thomas Lynch, Counsel for Global Information Technologies, to Marlene H. Dortch, Secretary, 
FCC and Marcy Green, Deputy Chief, Telecommunications Consumers Division, Enforcement Bureau, FCC, dated 
Mar. 10, 2009 (“GIT Omnibus NAL Response”) 
21 See generally 47 C.F.R. §§ 54.706 – 54.713 (outlining requirements for contributions to the federal universal 
service support mechanisms).  See also Federal-State Joint Board on Universal Service, 1998 Biennial Regulatory 
Review ? Streamlined Contributor Reporting Requirements Associated with Administration of Telecommunications 
Relay Services, 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, Report and Order and Second Further Notice of Proposed 
Rulemaking, 17 FCC Rcd 24952 (2002) (“Interim Contribution Order”).
22 See Federal-State Board on Universal Service, Report and Order, 12 FCC Rcd 8776, 9210-11, para. 853 (1997) 
(subsequent history omitted) (“Universal Service Order”).
23 Id.
24 47 C.F.R. § 54.712.  
25 47 U.S.C. § 201(b).
26 See LOI.
Federal Communications Commission DA 10-1250
5
2008.  On June 10, 2008, the Bureau sent a follow-up letter to GIT seeking additional information.27 GIT 
submitted a response to the follow-up letter on June 20, 2008.28
IV. TERMS OF AGREEMENT
7. 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.
8. Jurisdiction. GIT agrees that the Commission has jurisdiction over it and the matters 
contained in this Consent Decree and has the authority to enter into and adopt this Consent Decree.
9. Effective Date; Violations.  The Parties agree that this Consent Decree shall become 
effective on the date on which the Bureau 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 Commission.  Any 
violation of the Adopting Order or of the terms of this Consent Decree shall constitute a separate violation 
of a Commission Order, entitling the Bureau to exercise any rights and remedies attendant to the 
enforcement of a Commission Order.
10. Termination of Investigations.  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 investigations GIT Investigation (EB-08-TC-4005) and GIT Investigation (EB-08-IH-0615).  In 
consideration for the termination of said investigations, GIT 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 the investigations 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 GIT concerning the matters that were the 
subject of the investigations.  The Bureau also agrees that it will not use the facts developed in these 
investigations 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 GIT with respect to GIT’s basic qualifications, including its character qualifications, to be a 
Commission licensee or authorized common carrier.
11. Compliance Plans. For purposes of settling the matters set forth herein, GIT agrees to 
create, within sixty (60) calendar days from the Effective Date, internal Compliance Plans related to 
GIT’s future compliance with the Act, the Commission’s rules, and the Commission’s orders governing 
the confidentiality of customer proprietary network information and telecommunications service 
providers’ recovery of universal service contributions from end-user customers.  The Plans will include, 
at a minimum, the following components:
(a) GIT Investigation (EB-08-TC-4005) Compliance Plan:
a. GIT agrees to take all measures necessary to achieve full compliance with section 
64.2009(e) of the Commission’s rules.  
  
27 See Supplemental LOI.
28 See Letter from Thomas Lynch, Counsel for Global Information Technologies, to Michele Levy Berlove, 
Attorney Advisor, Investigations and hearings Division, Enforcement Bureau, FCC, dated June 20, 2008. 
Federal Communications Commission DA 10-1250
6
b. GIT agrees that, within thirty (30) days from the Effective Date, its personnel 
will be trained as to when they are and are not authorized to use CPNI.  
c. GIT further agrees to have an express disciplinary process in place for the 
unauthorized use of CPNI within thirty (30) days from the Effective Date.  
d. Additionally, GIT agrees to submit a copy of its annual section 64.2009(e) 
compliance certificate, which it is required to file annually in EB Docket 06-36, 
for each of two (2) years following the Effective Date of this Consent Decree to 
the Chief, Telecommunications Consumers Division, Enforcement Bureau, 
Federal Communications Commission, 445 12th Street, S.W., Room 4-C244, 
Washington, D.C. 20554, and must include the file number listed above.  GIT
will also send an electronic copy of its certification to other Telecommunications 
Consumers Division staff as directed by the Division Chief.  
e. GIT shall report any non-compliance with this Compliance Plan to the 
Enforcement Bureau within 30 days after the discovery of non-compliance. 
f. This Consent Decree will expire two (2) years after the Effective Date or upon 
the termination of the certification requirement set forth in section 64.2009(e) of 
the Commission’s rules, 47 C.F.R. § 64.2009(e), whichever is earlier.
g. GIT will certify at the end of the two (2) year term that it is in compliance with 
the terms of the Plan.  Such certification must be mailed within fifteen (15) days 
after the two-year anniversary of the Effective Date of this Consent Decree.  
(b) GIT Investigation (EB-08-IH-0615) Compliance Plan: 
a. Compliance Manual. GIT shall create, maintain, and update an FCC 
Compliance Manual. GIT personnel who engage in activities related to FCC 
regulation of GIT 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 GIT regarding 
the Universal Service Fund (USF) compliance and reporting requirements. The 
Compliance Manual will set forth a schedule of filing and payment dates 
associated with the USF. The Compliance Manual will encourage personnel to 
contact GIT’s Designated Contact or internal regulatory legal counsel, with any 
questions or concerns that arise with respect to GIT’s FCC compliance. GIT shall 
submit to the Bureau a final version of its Compliance Manual sixty (60) days 
after the Effective Date.
b. Compliance Training Program.  GIT will establish an FCC compliance 
training program for any employee who engages in activities related to FCC 
regulation of GIT. Training sessions will be conducted at least annually for such 
employees to ensure compliance with the Act and the FCC’s regulations and 
policies and, for new employees who are engaged in such activities, within the 
first sixty (60) days of employment.
c. Designated Contact.  GIT will designate one employee as the point of contact 
for all FCC compliance matters.
Federal Communications Commission DA 10-1250
7
d. Review and Monitoring.  GIT will review the FCC Compliance Manual and 
FCC Compliance Training Program annually to ensure that they are maintained 
in a proper manner and continue to address the objectives set forth therein.  
e. Compliance Reports.  GIT will file Compliance Reports with the Commission 
ninety (90) days after the Effective Date, twelve (12) months after the Effective 
Date, and twenty-four (24) months after the Effective Date. Each Compliance 
Report shall include a compliance certificate from an officer, as an agent of GIT, 
stating that the officer has personal knowledge that GIT 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 Compliance Reports shall be submitted to Chief, Investigations 
& Hearings Division, Enforcement Bureau, Federal Communications 
Commission, 445 12th Street, S.W., Room 4-C320, Washington, D.C. 20554.  
12. Compliance Reporting.  All compliance reports and certifications shall be submitted to 
the Chief, Telecommunications Consumers Division, Enforcement Bureau, Federal Communications 
Commission, 445 12th Street, S.W., Washington, D.C. 20554 and the Chief, Investigations and Hearings 
Division, Enforcement Bureau, Federal Communications Commission, 445 12th Street, S.W., 
Washington, D.C. 20554.
13. Termination Date.  Unless stated otherwise, the requirements of this Consent Decree 
will expire twenty-four (24) months after the Effective Date or, with respect to those requirements 
pertaining to the resolution of the CPNI investigation (EB-08-TC-4005), upon the termination of the opt-
out requirements set forth in sections 64.2001-2009 of the Commission’s rules, 47 C.F.R. §§ 64.2001-
2009, whichever is earlier.  
14. Section 208 Complaints; Subsequent Investigations.  Nothing in this Consent Decree 
shall prevent the Commission or its delegated authority from adjudicating complaints filed pursuant to 
section 208 of the Act against GIT for alleged violations of the Act, or for any other type of alleged 
misconduct, regardless of when such misconduct took place.  The Commission’s adjudication of any such 
complaint will be based solely on the record developed in that proceeding.  Except as expressly provided 
in this Consent Decree, this Consent Decree shall not prevent the Commission from investigating new 
evidence of noncompliance by GIT of the Act, the rules, or the Adopting Order.
15. Voluntary Contribution.  GIT agrees that it will make a voluntary contribution to the 
United States Treasury in the amount of twenty-three thousand five hundred dollars ($23,500) paid out in 
monthly installments to be completed within two years of the Effective Date of this Consent Decree.  The 
payments 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 
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. GIT 
will also send electronic notification on the date said payment is made to Mika Savir at 
Mika.Savir@fcc.gov and to Pam Slipakoff at Pam.Slipakoff@fcc.gov.
16. Notification.  GIT also agrees to post a notice on its website, until termination of this 
Consent Decree pursuant to the terms of paragraph 13 above, stating:  “If you were a customer between 
January 2005 and June 2008, it is possible we may have collected Universal Service funds from you that 
were higher than we were required to pay. If you would like us to check your account, please contact us at 
Federal Communications Commission DA 10-1250
8
Service@gitsat.com.” GIT will place a link to this notice, entitled “GIT Notices” on the homepage of its 
website at www.gitsat.com.  To the extent that GIT issues refunds to customers or former customers as a 
result of this notice and provides to the Bureau sufficient documentation of such refunds, the amount of 
the voluntary contribution set forth in paragraph 15 remaining due during months 13 through 24 of the 
payment period shall be reduced by the amount refunded.
17. Waivers.  GIT 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 Adopting Order, provided the Commission issues an Order adopting the Consent Decree 
without change, addition, modification, or deletion.  GIT 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 
GIT nor the Commission shall contest the validity of the Consent Decree or the Adopting Order, and GIT 
shall waive any statutory right to a trial de novo.  GIT hereby agrees to waive any claims they 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.
18. 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 GIT does not expressly consent) 
that provision will be superseded by such Commission rule or order.
19. Successors and Assigns. GIT agrees that the provisions of this Consent Decree shall be 
binding on their successors, assigns, and transferees.  
20. 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 admission of liability, an admission of noncompliance, 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.  
21. Modifications. This Consent Decree cannot be modified without the advance written 
consent of both Parties.
22. 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.
23. Authorized Representative.  Each party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.
24. 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.
Federal Communications Commission DA 10-1250
9
________________________________
P. Michele Ellison
Chief, Enforcement Bureau
Federal Communications Commission
________________________________
Date
________________________________
Ginger Washburn
President
Global Information Technologies
________________________________
Date