Federal Communications Commission DA 10-2224 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of AT&T Inc. Compliance with the Commission’s Rules and Regulations Governing Customer Proprietary Network Information ) ) ) ) ) ) ) ) ) File No.: EB-09-TC-382 File No.: EB-09-TC-385 File No.: EB-10-TC-384 Acct. No.: 201132170003 FRN: 0005193701 ADOPTING ORDER Adopted: November 29, 2010 Released: November 29, 2010 By the Chief, Enforcement Bureau: 1. In this Order, we adopt the attached Consent Decree entered into between the Enforcement Bureau (“Bureau”) of the Federal Communications Commission (“Commission”) and AT&T Inc. on behalf of all AT&T Inc. subsidiaries that are subject to the CPNI rules (collectively “AT&T” or “Company”). The Consent Decree terminates investigations initiated by the Bureau regarding AT&T’s compliance with section 222(c)(1) of the Communications Act of 1934, as amended, 47 U.S.C. § 222(c)(1), and sections 64.2007, 64.2008(d) and 64.2008(d)(3)(v) of the Commission’s rules, 47 C.F.R. §§ 64.2007, 64.2008(d) and 64.2008(d)(3)(v). 2. The Bureau and AT&T have negotiated the terms of a Consent Decree that resolves these matters. 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 referenced investigations. 4. In the absence of material new evidence relating to this matter, we conclude that our investigations raise no substantial or material questions of fact as to whether AT&T possesses the basic qualifications, including those related to character, to hold or obtain any Commission license or authorization. 5. Accordingly, IT IS ORDERED, pursuant to Section 4(i) of the Communications Act of 1934, as amended, 47 U.S.C. § 154(i), and the authority delegated by Section 0.111 and 0.311 of the Commission’s rules, 47 CFR §§ 0.111 and 0.311, that the attached Consent Decree IS ADOPTED. Federal Communications Commission DA 10-2224 2 6. IT IS FURTHER ORDERED that the above-captioned matter IS 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, to AT&T Services, Inc., 1120 20th Street, NW, Suite 1000, Washington, DC 20036. FEDERAL COMMUNICATIONS COMMISSION P. Michele Ellison Chief, Enforcement Bureau Federal Communications Commission DA 10-2224 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of AT&T Inc. Compliance with the Commission’s Rules and Regulations Governing Customer Proprietary Network Information ) ) ) ) ) ) ) ) ) File No.: EB-09-TC-382 File No.: EB-09-TC-385 File No.: EB-10-TC-384 Acct. No.: 201132170003 FRN: 0005193701 CONSENT DECREE I. INTRODUCTION 1. The Enforcement Bureau of the Federal Communications Commission and AT&T Inc., on behalf of all AT&T Inc. subsidiaries that are subject to the CPNI rules (collectively “AT&T” or “Company”), by their authorized representatives, hereby enter into this Consent Decree for the purpose of terminating the Bureau’s investigations regarding AT&T’s compliance with section 222(c)(1) of the Communications Act of 1934, as amended (“Communications Act” or “Act”),1 and sections 64.2007, 64.2008(d), and 64.2008(d)(3)(v) of the Commission’s rules.2 II. DEFINITIONS 2. For 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. “AT&T” or “Company” means all AT&T Inc. subsidiaries that are subject to the CPNI rules, including any such companies that may be created or acquired by AT&T during the term of this Consent Decree. AT&T represents that Attachment A contains a complete list of such companies currently in operation. c. “Bureau” means the Enforcement Bureau of the Federal Communications Commission. d. “Commission” or “FCC” means the Federal Communications Commission and all of its bureaus and offices. 1 47 U.S.C. § 222(c)(1). 2 47 C.F.R. §§ 64.2007, 64.2008(d), 64.2008(d)(3)(v). Federal Communications Commission DA 10-2224 2 e. “Compliance Plan” means the program described in this Consent Decree at paragraph 10. f. “Effective Date” means the date on which the Bureau releases the Adopting Order. g. “Investigation EB-09-TC-382” means the investigation commenced by the Bureau’s August 5, 2009 Letter of Inquiry to AT&T described in paragraph 2 below. h. “Investigation EB-08-TC-385” means the investigation commenced by the Bureau’s August 5, 2009 Letter of Inquiry to AT&T described in paragraph 4 below. i. “Investigation EB-10-TC-384” means the investigation commenced by the Bureau’s March 16, 2010 Letter of Inquiry to AT&T described in paragraph 5 below. j. “Investigations” means each and all of Investigation EB-09-TC-382, Investigation EB-08-TC-385, and Investigation EB-10-TC-384. k. “Order” or “Adopting Order” means an Order of the Bureau adopting the terms and conditions of this Consent Decree without change, addition, or modification, and formally terminating the above-captioned Investigations. l. “Parties” means AT&T and the Bureau, each of which is a “Party.” m. “Rules” means those rules and regulations codified in Title 47 of the Code of Federal Regulations. III. BACKGROUND Investigation EB-09-TC-382 3. On June 1, 2009, pursuant to section 64.2009(f) of the Commission’s rules,3 AT&T filed a notice with the Commission reporting failures in its customer proprietary network information (“CPNI”) opt-out mechanism.4 According to AT&T, the CPNI toll-free number used by small business customers to opt-out was mistakenly disconnected. AT&T reported that when small business customers called the toll-free number during business hours, they were automatically routed to a call center to speak to a live representative, but after hours, they were unable to leave an opt-out request in the voicemail box. According to AT&T, this resulted in the improper use of the CPNI of 55 customers in 86 marketing campaigns. The Bureau issued a letter 3 47 C.F.R. § 64.2009(f). 4 See Notification Under Section 64.2009(f), CC Docket No. 96-115, Letter from Davida Grant, General Attorney, AT&T Inc., to William Dever, Acting Chief, Competition Policy Division, Wireline Competition Bureau, and Erica McMahon, Chief, Consumer Policy Division, Consumer & Governmental Affairs Bureau, Federal Communications Commission (June 1, 2009) (“June 1, 2009 Opt-Out Failure Notice”). Federal Communications Commission DA 10-2224 3 of inquiry (“LOI”) to AT&T on August 5, 2009.5 AT&T submitted its response to the LOI on September 4, 2009.6 Investigation EB-09-TC-385 4. On June 11, 2009, AT&T reported an additional failure in its CPNI opt-out mechanism.7 AT&T reported that, in April 2008, it decided to send terms and conditions for its inside wire plan in the Welcome Package of any new small business that purchased inside wire protection. According to AT&T, however, the company was unaware of a previous but erroneous instruction by pre-merger Bellsouth to the distribution vendor to remove CPNI notices in Welcome Packages sent to accounts with inside wire protection. AT&T reports that this resulted in 71,823 customers who did not receive CPNI notices, but whose CPNI nonetheless, was used by AT&T in 620 small business marketing campaigns. The Bureau sent an LOI to AT&T on August 5, 2009,8 and AT&T submitted its response on September 4, 2009.9 Investigation EB-10-TC-384 5. On October 30, 2009, AT&T reported a third failure in its CPNI opt-out mechanism involving its interactive voice response system or “IVR.”10 Small business customers calling a toll-free number to opt-out were directed to leave their requests through the IVR. AT&T reported that on October 14, 2008, a security cleanup of the system inadvertently deleted the coding that instructed the IVR to send the requests to the CPNI opt-out database. AT&T states that, despite monitoring of the system, AT&T did not discover the error until a year later on October 7, 2009. AT&T states further that it does not make outbound telemarketing calls, and cannot determine with certainty whether it marketed to the 158 customers who called in during 5 See Letter of Inquiry from Marcy Greene, Deputy Division Chief, Telecommunications Consumers Division, Enforcement Bureau, to Davida Grant, General Attorney, AT&T Inc. (August 5, 2009). 6 See Letter from Davida Grant, General Attorney, AT&T Inc., to Marcy Greene, Deputy Division Chief, Telecommunications Consumers Division, Enforcement Bureau (September 4, 2009). 7 See Notification Under Section 64.2009(f), CC Docket No. 96-115, Letter from Davida Grant, General Attorney, AT&T Inc., to William Dever, Acting Chief, Competition Policy Division, Wireline Competition Bureau, and Erica McMahon, Chief, Consumer Policy Division, Consumer & Governmental Affairs Bureau, Federal Communications Commission (June 11, 2009) (“June 11, 2009 Opt-Out Failure Notice”). 8 See supra, fn. 2. 9 See supra, fn. 3. 10 See Notification Under Section 64.2009(f), CC Docket No. 96-115, Letter from Davida Grant, General Attorney, AT&T Inc., to William Dever, Acting Chief, Competition Policy Division, Wireline Competition Bureau, and Erica McMahon, Chief, Consumer Policy Division, Consumer & Governmental Affairs Bureau, Federal Communications Commission (October 30, 2009) (“October 30,2009 Opt-Out Failure Notice”). Federal Communications Commission DA 10-2224 4 the relevant period. The Bureau sent an LOI to AT&T on March 16, 2010,11 and AT&T submitted its response on April 6, 2010.12 IV. 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. AT&T’s decision to enter into this Consent Decree is expressly contingent upon the Bureau’s issuance of an Adopting Order. 7. Jurisdiction. AT&T 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 Effective Date. Upon the Effective Date, 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 Commission 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 contained herein, and to avoid expenditure of additional public resources, the Bureau agrees to terminate the Investigations. In consideration for the termination of these matters and in accordance with the terms of this Consent Decree, AT&T agrees to the terms, conditions, and procedures contained herein. The Bureau agrees that, in the absence of new material evidence related to these matters, it will not use the facts developed in the Investigations through the Effective Date, 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 AT&T, concerning the matters that were the subject of the Investigations, or with respect to AT&T’s basic qualifications, including its character qualifications, to be a Commission licensee or authorized common carrier, provided that AT&T satisfies all of its obligations under this Consent Decree. 10. Compliance Plan. To resolve and terminate the Investigations, and to ensure compliance with the Commission’s CPNI opt-out rules, AT&T agrees to implement a Compliance Plan that shall include, but is not limited to, the terms set forth below. The Compliance Plan shall be applicable to the AT&T companies that are subject to the CPNI rules as described above in paragraph 2(b). During the term of this Consent Decree, the Compliance Plan shall also be applicable to any such entities acquired by AT&T beginning ninety (90) days after consummation of the acquisition. 11 See Letter of Inquiry from Colleen K. Heitkamp, Division Chief, Telecommunications Consumers Division, Enforcement Bureau, to Davida Grant, General Attorney, AT&T Inc. (March 16, 2010). 12 See Letter from Davida Grant, General Attorney, AT&T Inc., to Colleen Heitkamp, Division Chief, Telecommunications Consumers Division, Enforcement Bureau (August 6, 2010). Federal Communications Commission DA 10-2224 5 A. Opt-out Mechanism Review. AT&T shall perform a monthly review of its CPNI opt-out mechanisms designed to ensure: (1) that its opt-out mechanisms are working accurately, (2) that AT&T employees or AT&T-affiliated company employees responsible for managing and overseeing AT&T’s opt-out mechanisms are communicating effectively regarding any changes to AT&T’s opt-out mechanisms and that the communication methods have relayed effectively all changes to AT&T’s opt-out mechanisms to all necessary personnel, and (3) that validation testing is completed successfully, as described below. Specifically, AT&T shall do the following: i. Review its CPNI notices to ensure that the opt-out instructions included in such notices are complete and accurate and that customers can respond as required by the Rules. This review shall include all notices regardless of the method (e.g., Welcome Package, web page, email, etc.) used to deliver the notice to customers. ii. Review all instructions, including dissemination instructions, provided to vendors and/or internal organizations related to the delivery of CPNI notices. This review shall compare the proposed instructions against any existing instructions to ensure against unintended results. This review shall be designed to ensure that CPNI notices are included in applicable Welcome Packages, customer bills, emails, web pages, etc. iii. Review sample CPNI notices generated by any new instructions prior to approving dissemination. iv. Make a test call to each telephone number included in a CPNI notice (including, but not limited to, any Interactive Voice Response Systems) both during and after business hours to ensure that the number is working properly. Verify that a customer can make an opt-out request, including electronic ones, and verify that applicable CPNI databases are updated to reflect the opt-out request. B. Training. AT&T shall ensure that, within sixty (60) days of the Effective Date, its employees and any employees of its affiliated companies responsible for managing the preparation and distribution of CPNI opt-out notices and/or responsible for the proper operation of AT&T’s opt-out mechanisms have received training regarding the CPNI rules. Such training shall be repeated annually during the term of this Consent Decree. AT&T shall ensure that any new (or reassigned) employee of AT&T or an affiliated company assigned the responsibilities noted in the previous sentence receives CPNI training within forty-five (45) days of starting employment (or the new assignment). This training shall focus on federal CPNI opt-out requirements and the terms of this Plan. C. Reporting Non-Compliance. AT&T shall report any non-compliance with this Consent Decree to the Enforcement Bureau within thirty (30) days after the discovery of non-compliance. D. Compliance Report. AT&T shall provide a Compliance Report from an officer, as an agent of the Company, one (1) year after the Effective Date, and at the end of the two (2) year term, stating that the officer has personal knowledge that the Federal Communications Commission DA 10-2224 6 Company (i) has established operating procedures intended to ensure compliance with this Consent Decree together with an accompanying statement explaining the basis for the officer's certification; (ii) has been utilizing those procedures for the entire term of the Consent Decree; and (iii) the officer is not aware of any instances of non-compliance with this Consent Decree that have not otherwise been disclosed pursuant to subsection (C) above. The certification must comply with Section 1.16 of the Rules and be subscribed to as true under penalty of perjury in substantially the form set forth therein. Such certification must be mailed within fifteen (15) days of the one (1) and the two (2) year anniversary, and AT&T must mail its certification to the Chief, Telecommunications Consumers Division, Enforcement Bureau, Federal Communications Commission, 445 12th Street, S.W., Washington, D.C. 20554, and must include the file numbers listed above. AT&T shall also send an electronic copy of its certification to other Telecommunications Consumers Division staff as directed by the Division Chief. E. Term of the Compliance Plan. AT&T shall implement the Compliance Plan within sixty (60) days of the Effective Date. The term of the Compliance Plan shall expire two (2) years after the Effective Date. 11. Voluntary Contribution. In consideration for the termination of the Investigations in accordance with the terms of this Consent Decree, AT&T agrees to make a voluntary contribution to the United States Treasury, without further protest or recourse to a trial de novo, in the amount of two hundred thousand dollars ($200,000) within thirty (30) days after the Effective Date. This voluntary payment does not constitute a forfeiture under the Act or FCC rules. The 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 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. AT&T will also send electronic notification to johnny.drake@fcc.gov on the date said payment is made. 12. Waivers. Provided the Bureau issues an Adopting Order, AT&T 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. 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 AT&T nor the Bureau shall contest the validity of the Consent Decree or the Adopting Order, and AT&T and the Bureau shall waive any statutory right to a trial de novo with respect to the issuance of the Adopting Order and shall consent to a judgment incorporating the terms of this Consent Decree. AT&T 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 contained in this Consent Decree. 13. Invalidity. In the event that this Consent Decree is rendered invalid by a court of competent jurisdiction, it shall become null and void and may not be used in any manner in any legal proceeding. 14. Privileged and Confidential Documents. By this Consent Decree, AT&T neither waives nor alters its right to assert and seek protection from disclosure of any privileged Federal Communications Commission DA 10-2224 7 or otherwise confidential and protected documents and information, or to seek appropriate safeguards of confidentiality for any competitively sensitive or proprietary information. 15. Subsequent Rule or Order. The Parties agree that if any provision of this Consent Decree is inconsistent with any subsequent rule or order adopted by the Commission, that provision will be superseded by such Commission rule or order. In the event that the opt-out requirements set forth in sections 64.2001-2009 of the Commission’s rules (47 C.F.R. §§ 64.2001-2009) are repealed, this Consent Decree shall be terminated when the action repealing the rules becomes final. 16. Successors and Assigns. AT&T agrees that the provisions of this Consent Decree shall be binding on its successors, assigns, and transferees. 17. Final Settlement. The Parties agree and acknowledge that this Consent Decree shall constitute a final settlement of the above-described Investigations. The Parties 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 by AT&T with the requirements of the Act or the Commission’s rules or orders. The Parties agree that this Consent Decree is for settlement purposes only, and that by agreeing to this Consent Decree, AT&T does not admit or deny any noncompliance, violation, or liability associated with or arising from its actions or omissions involving the Act or the Commission’s rules that are the subject of this Consent Decree. 18. Modifications. This Consent Decree cannot be modified without the advance written consent of both parties. 19. 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. 20. Section 208 Complaints; Subsequent Investigations. Nothing in this Consent Decree shall prevent the Bureau from instituting or recommending any new Investigation or enforcement proceeding against AT&T in the event of any alleged future misconduct involving violation of this Consent Decree, or violation of the Act or the Commission’s Rules. Nothing in this Consent Decree shall prevent the Commission or Bureau from adjudicating complaints filed pursuant to section 208 of the Act, 47 U.S.C. § 208, against AT&T for alleged violations of the Act, or for any other type of alleged misconduct, regardless of when such misconduct took place. The Bureau’s adjudication of any such complaint will be based solely on the record developed in that proceeding. 21. Counterparts. This Consent Decree may be signed in 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 10-2224 8 22. Authorized Representative. Each Party represents and warrants to the other that it has full power and authority to enter into this Consent Decree. For: AT&T Inc. __________ ________________________________ Date Gary L. Phillips General Attorney and Associate General Counsel AT&T Inc., on behalf of the AT&T subsidiaries subject to the CPNI rules For: Federal Communications Commission __________ ________________________________ Date P. Michele Ellison Chief, Enforcement Bureau Federal Communications Commission DA 10-2224 ATTACHMENT A AT&T Entity FCC Registration Number Acadiana Cellular General Partnership 0001837814 ACC Corp. 0014553119 ACC National Telecom Corp 0013443718 Alascom, Inc. 0001572676 Alton CellTel Co. Partnership 0003767290 American Cellular, LLC 0017334806 Ameritech Payphone Services, Inc. 0007586175 AT&T Communications of California, Inc. 0003301702 AT&T Communications of Delaware, LLC. 0012838504 AT&T Communications of Hawaii, Inc. 0014532501 AT&T Communications of Illinois, Inc. 0003301793 AT&T Communications of Indiana, GP 0012838421 AT&T Communications of Maryland, LLC 0012838512 AT&T Communications of Michigan, Inc. 0003301876 AT&T Communications of Nevada, Inc. 0003301959 AT&T Communications of New York, Inc. 0012838462 AT&T Communications of NJ, LP 0012838520 AT&T Communications of Ohio, Inc. 0003301736 AT&T Communications of Pennsylvania, LLC 0012838538 AT&T Communications of Texas, Inc. 0016657918 AT&T Communications of the Midwest, Inc. 0003301751 AT&T Communications of the Mountain States, Inc. 0003301892 AT&T Communications of the Pacific Northwest, Inc. 0003301710 AT&T Communications of the South Central States, LLC 0012838561 AT&T Communications of the Southern States, LLC 0012838553 AT&T Communications of the Southwest, Inc. 0003301918 AT&T Communications of Virginia, LLC 0012838546 AT&T Communications of Washington, D.C., LLC 0012838488 AT&T Communications of West Virginia, Inc. 0003301785 AT&T Communications of Wisconsin, LP 0012838454 AT&T Corp 0005937974 AT&T Mobility LLC 0004979233 AT&T Mobility of Galveston LLC 0016658122 AT&T Mobility Spectrum LLC 0014980726 AT&T Mobility Texas LLC 0016658148 AT&T of Puerto Rico, Inc. 0001731462 AT&T of the Virgin Islands, Inc. 0003464344 AWACS, Inc. 0010852523 Bauce Communications of Beaumont, Inc. 0001562040 Bellingham Cellular Partnership 0004312559 BellSouth Entertainment, LLC 0005095963 BellSouth International, LLC 0005858907 BellSouth Long Distance d/b/a AT&T Long Distance 0003733318 BellSouth Mobile Data, Inc. 0013935085 BellSouth Telecommunications, Inc. 0005795679 BizTel, Inc. 0003998978 Federal Communications Commission DA 10-2224 2 AT&T Entity FCC Registration Number Bloomington Cellular Telephone Company 0001573328 Bradenton Cellular Partnership 0004312591 Bremerton Cellular Telephone Company 0004312609 Cagal Cellular Communications Corporation 0001803246 CCPR of the Virgin Islands, Inc. 0004499034 CCPR Services, Inc. 0003473709 Centennial Beauregard Cellular LLC 0012921946 Centennial Caldwell Cellular LLC 0008816779 Centennial Cellular Tri-State Operating Partnership 0012926176 Centennial Claiborne Cellular Corp 0012926184 Centennial Communications Corp. 0009631136 Centennial Hammond Cellular LLC 0012926341 Centennial Lafayette Communications LLC 0012926424 Centennial Michiana License Company LLC 0003296480 Centennial Michigan RSA 6 Cellular Corp. 0010310688 Centennial Michigan RSA 7 Cellular Corp. 0008816944 Centennial Morehouse Celllular LLC 0003574142 Centennial Puerto Rico License Corp. 0003572864 Centennial Puerto Rico Operations Corp. 0003572849 Centennial Randolph Cellular LLC 0008816795 Centennial Southeast License Company LLC 0003296472 Centennial USVI Operations Copr. 0007467384 Champaign CellTelco 0001460537 Chattanooga MSA Limited Partnership 0001842723 Cincinnati SMSA Limited Partnership 0004160842 Cingular Wireless of Texas RSA #11 Limited Partnership 0003294048 Cingular Wireless of Texas RSA #16 Limited Partnership 0003294006 DC Newco Parent, LLC 0017235060 Decatur RSA Limited Partnership 0004588455 Dobson Cellular Systems of Alaska, LLC 0015568579 Dobson Cellular Systems, LLC 0017334780 Dobson Communications LLC 0017334889 Edge Wireless, LLC 0003800679 Elkhart Cellular Telephone Company 0012927109 Elkhart Metronet, Inc. 0003594991 Florida RSA No. 2B (Indian River) Limited Partnership 0001837566 Georgia RSA No. 3 Limited Partnership 0001836998 Highland Cellular, LLC 0008951170 Hood River Cellular Telephone Company, Inc. 0001572924 Houma-Thibodaux Cellular Partnership 0004547931 Illinois Bell Telephone Company 0002860856 Indiana Bell Telephone Company, Inc. 0002904654 Lafayette Cellular Telephone Company 0001545771 Lafayette MSA Limited Partnership 0001682509 Louisiana RSA No. 7 Cellular General Partnership 0001837798 Louisiana RSA No. 8 Limited Partnership 0001837830 Lubbock SMSA Limited Partnership 0001650787 Madison SMSA Limited Partnership 0002842060 Federal Communications Commission DA 10-2224 3 AT&T Entity FCC Registration Number McAllen-Edinburg-Mission SMSA Limited Partnership 0001658467 Medford Cellular Telephone Company, Inc. 0004312772 Mega Comm LLC 0012927208 Melbourne Cellular Telephone Company 0004312799 Michiana Metronet, Inc. 0003595147 Michigan Bell Telephone Company 0002776771 Milwaukee SMSA Limited Partnership 0002846293 Missouri RSA 11/12 Limited Partnership 0001658418 Missouri RSA 8 Limited Partnership 0001658442 Missouri RSA 9B1 Limited Partnership 0001658426 Nevada Bell Telephone Company 0001552173 New Cingular Wireless PCS, LLC 0003291192 Northeastern Georgia RSA Limited Partnership 0001837152 Ocala Cellular Telephone Co., Inc. 0001573492 Oklahoma City SMSA Limited Partnership 0001658392 Oklahoma Independent RSA 7 Partnership 0010698884 Oklahoma RSA 3 Limited Partnership 0001658376 Oklahoma RSA 9 Limited Partnership 0001658368 Olympia Cellular Telephone Company, Inc. 0004312807 Orlando SMSA Limited Partnership 0001843036 Pacific Bell Telephone Company 0001551530 Pine Bluff Cellular, Inc. 0001722271 Provo Cellular Telephone Company 0004312815 Reno Cellular Telephone Company 0004312864 Rural Newco LLC 0017233826 Salem Cellular Telephone Company 0004312880 Santa Barbara Cellular Systems Ltd. 0004312898 Sarasota Cellular Telephone Company 0004312906 SBC Internet Services, Inc. d/b/a AT&T Internet Services 0012536033 SBC Long Distance, LLC 0003763497 SNET America, Inc. 0003737707 SNET Diversified Group, Inc. 0007586423 South Bend Metronet Inc. 0008816910 Southwestern Bell Telephone Company 0016627473 St. Cloud Cellular Telephone Company, Inc. 0001572742 TC Systems, Inc. 0012833513 TCG America, Inc. 0003476611 TCG Chicago 0014531990 TCG Colorado 0014532022 TCG Connecticut 0014532048 TCG Dallas 0014532089 TCG Detroit 0014532113 TCG Illinois 0014532162 TCG Indianapolis 0014532204 TCG Joint Venture Holdings Inc. dba TCG Oregon 0014532238 TCG Kansas City, Inc. 0014532261 TCG Los Angeles, Inc. 0014532287 TCG Maryland 0014532303 Federal Communications Commission DA 10-2224 4 AT&T Entity FCC Registration Number TCG Midsouth, Inc. 0014532345 TCG Milwaukee, Inc. 0014532386 TCG Minnesota, Inc. 0014532410 TCG New Jersey, Inc. 0017516725 TCG of the Carolinas, Inc. 0014532428 TCG Ohio 0014532451 TCG Omaha 0014532469 TCG Oregon 0014535009 TCG Phoenix 0014532550 TCG Pittsburgh 0014532576 TCG Rhode Island 0014532592 TCG San Diego 0014532642 TCG San Francisco 0014533004 TCG Seattle 0014533053 TCG South Florida 0014533079 TCG St. Louis 0014533087 TCG Utah 0014533111 TCG Virginia, Inc. 0014533145 TeleCorp Communications, LLC 0011499910 Teleport Communications – Washington DC, Inc. 0014533368 Teleport Communications Atlanta, Inc. 0014533178 Teleport Communications Houston, Inc. 0014533277 Teleport Communications New York 0014533301 Texas RSA 18 Limited Partnership 0001666072 Texas RSA 19 Limited Partnership 0001666056 Texas RSA 20B1 Limited Partnership 0001665058 Texas RSA 6 Limited Partnership 0001665991 Texas RSA 7B1 Limited Partnership 0001666007 Texas RSA 9B1 Limited Partnership 0001666023 Texas RSA No. 2 Limited Partnership 0004550547 The Ohio Bell Telephone Company 0002946986 The Southern New England Telephone Company 0005049150 Topeka SMSA Limited Partnership 0001658632 Visalia Cellular Telephone Company 0004312971 Wisconsin Bell, Inc. 0002716561