Federal Communications Commission DA 10-692
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
ComSpan Communications Inc.
f/k/a Wantel, Inc.
)
)
)
)
)
)
File No. EB-08-IH-0665
File No. EB-08-TC-3549
NAL/Acct. No. 201032080006
FRN No. 0007799125
ORDER
Adopted:  May 24, 2010 Released:  May 26, 2010
By the Enforcement Bureau: 
1. In this Order, we adopt the attached Consent Decree entered into between the 
Enforcement Bureau (“Bureau”) and ComSpan Communications Inc. f/k/a Wantel, Inc. (“ComSpan” or 
the “Company”).  The Consent Decree terminates an investigation by the Bureau against ComSpan for 
possible violations of sections 9, 254(d), 225, and 251(e)(2) of the Communications Act of 1934, as 
amended (the “Act”),1 and sections 1.1157, 52.17, 52.32, 54.706, 54.711, 64.604, and 64.1195 of the 
Commission’s rules,2 concerning the payment of annual regulatory fees; contributions to the Universal 
Service Fund (“USF”) and Telecommunications Relay Services (“TRS”) Fund; contributions to cost-
recovery mechanisms for North American Numbering Plan (“NANP”) and Local Number Portability 
(“LNP”) administration; and the submission of information as set forth on the Telecommunications 
Reporting Worksheets (i.e., FCC Forms 499-A and 499-Q).  The Consent Decree also terminates an 
investigation and Notice of Apparent Liability for Forfeiture (“NAL”) by the Bureau against ComSpan for 
possible violations of section 222 of the Act,3 section 64.2009(e) of the Commission’s rules,4 and the 
Commission’s EPIC CPNI Order,5 regarding ComSpan’s apparent failure to timely file a compliant 
annual customer proprietary network information (“CPNI”) certification pursuant to section 64.2009(e) of 
the Commission’s rules.6  
2. The Bureau and ComSpan have negotiated the terms of a Consent Decree that resolve 
these matters.  A copy of the Consent Decree is attached hereto and incorporated herein by reference.  
  
1 47 U.S.C. §§ 159, 225, 251(e)(2), and 254(d).
2 47 C.F.R. §§ 1.1157, 52.17, 52.32, 54.706, 54.711, 64.604, and 64.1195.
3 47 U.S.C. § 222.
4 47 C.F.R. § 64.2009(e).  
5 Implementation of the Telecomms. Act of 1996: Telecomms. Carriers’ Use of Customer Proprietary Network Info. 
& Other Customer Info.; IP-Enabled Servs., Report and Order and Further Notice of Proposed Rulemaking, 22 FCC 
Rcd 6927, 6953 (2007) (“EPIC CPNI Order”); aff’d sub nom. Nat’l Cable & Telecomms. Assoc. v. FCC, 555 F.3d 
996 (DC Cir. 2009).
6 See Annual CPNI Certification; Omnibus Notice of Apparent Liability for Forfeiture, Omnibus Notice of Apparent 
Liability for Forfeiture, 24 FCC Rcd 2299 (Enforcement Bureau 2009) (“CPNI Omnibus NAL”).
Federal Communications Commission DA 10-692
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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 our 
investigations raise no substantial or material questions of fact as to whether ComSpan 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 Act,7 and sections 
0.111 and 0.311 of the Commission’s rules,8 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 certified mail, return receipt requested, to Mr. Jimmy Byrd, Chief Executive Officer, ComSpan 
Communications Inc., 6405 Mira Mesa Boulevard, Suite 100, San Diego, California, 92121. 
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
  
7 47 U.S.C. § 154(i).
8 47 C.F.R. §§ 0.111, 0.311.
Federal Communications Commission DA 10-692
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
ComSpan Communications Inc.
f/k/a Wantel, Inc.
)
)
)
)
)
)
File No. EB-08-IH-0665
File No. EB-08-TC-3549
NAL/Acct. No. 201032080006
FRN No. 0007799125
CONSENT DECREE
1. The Enforcement Bureau (“Bureau”) and ComSpan Communications Inc. f/k/a Wantel, 
Inc. (“ComSpan” or the “Company”), by their authorized representatives, hereby enter into this Consent 
Decree for the purpose of terminating the Bureau’s investigation into whether the Company violated 
sections 9, 254(d), 225, and 251(e)(2) of the Communications Act of 1934, as amended (the “Act”),1 and 
sections 1.1157, 52.17, 52.32, 54.706, 54.711, 64.604, and 64.1195 of the Commission’s rules,2
concerning the payment of annual regulatory fees; contributions to the Universal Service Fund (“USF”) 
and Telecommunications Relay Services (“TRS”) Fund; contributions to cost-recovery mechanisms for 
North American Numbering Plan (“NANP”) and Local Number Portability (“LNP”) administration; and 
the submission of information as set forth on the Telecommunications Reporting Worksheets (i.e., FCC 
Forms 499-A and 499-Q).  The Bureau and ComSpan also enter into this Consent Decree for the purpose 
of terminating the Bureau’s investigation and Notice of Apparent Liability for Forfeiture (“NAL”) by the 
Bureau against ComSpan for possible violations of section 222 of the Act,3 section 64.2009(e) of the 
Commission’s rules,4 and the Commission’s EPIC CPNI Order,5 regarding ComSpan’s apparent failure 
to timely file a compliant annual customer proprietary network information (“CPNI”) certification.6
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.
  
1 47 U.S.C. §§ 159, 225, 251(e)(2), and 254(d).
2 47 C.F.R. §§ 1.1157, 52.17, 52.32, 54.706, 54.711, 64.604, and 64.1195.
3 47 U.S.C. § 222.
4 47 C.F.R. § 64.2009(e).  
5 Implementation of the Telecomms. Act of 1996: Telecomms. Carriers’ Use of Customer Proprietary Network Info. 
& Other Customer Info.; IP-Enabled Servs., Report and Order and Further Notice of Proposed Rulemaking, 22 FCC 
Rcd 6927, 6953 (2007) (“EPIC CPNI Order”); aff’d sub nom. Nat’l Cable & Telecomms. Assoc. v. FCC, 555 F.3d 
996 (DC Cir. 2009).
6 See Annual CPNI Certification; Omnibus Notice of Apparent Liability for Forfeiture, Omnibus Notice of Apparent 
Liability for Forfeiture, 24 FCC Rcd 2299 (Enforcement Bureau 2009) (“CPNI Omnibus NAL”).
Federal Communications Commission DA 10-692
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(b) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(c) “Commission” and “FCC” mean the Federal Communications Commission and 
all of its bureaus and offices.  
(d) “CPNI Compliance Plan” means the program described in this Consent Decree at 
paragraph 17.
(e) “Effective Date” means the date on which the Commission releases the Adopting 
Order.
(f) “Federal Regulatory Reporting and Contribution Compliance Plan” means the 
program described in this Consent Decree at paragraph 16.
(g) “Investigations” mean (1) the investigation commenced by the Bureau’s March 
13, 2008 letter of inquiry7 regarding whether ComSpan violated sections 1.1157, 
52.17, 52.32, 54.706, 54.711, 64.604, and 64.1195 of the Commission’s rules, 
concerning the payment of annual regulatory fees; contributions to the USF and 
TRS Fund; contributions to cost-recovery mechanisms for NANP and LNP 
administration; and the submission of information as set forth on the 
Telecommunications Reporting Worksheets;8 and (2) the investigation
commenced by the Bureau’s September 5, 2008 letter of inquiry9 regarding 
whether ComSpan violated the requirements of section 222 of the Act, and 
section 64.2009(e) of the Commission’s rules, by failing to file a compliant CPNI 
certification.10  
(h) “ComSpan Communications Inc. f/k/a Wantel, Inc.” or “ComSpan” means 
ComSpan Communications Inc. f/k/a Wantel, Inc. and its predecessors-in-interest 
and successors-in-interest.
(i) “Order” or “Adopting Order” means an Order of the Commission adopting the 
terms of this Consent Decree without change, addition, deletion, or modification.
(j) “Parties” means ComSpan Communications Inc. f/k/a Wantel, Inc. and the 
Bureau.
  
7 See ComSpan Communications Inc. f/k/a Wantel, Inc., EB-08-IH-0665, Letter from Trent B. Harkrader, Deputy 
Chief, Investigations & Hearings Division, Enforcement Bureau, Federal Communications Commission to John 
Stadter, Chief Executive Officer, Wantel, Inc. (Mar. 13, 2008) (“March 13, 2008 LOI”).  
8 47 C.F.R. §§ 1.1157, 52.17, 52.32, 54.706, 54.711, 64.604, 64.1195.
9 See ComSpan Communications Inc., EB-08-TC-3549, Letter from Marcy Greene, Deputy Chief, 
Telecommunications Consumers Division, Enforcement Bureau, Federal Communications Commission to John 
Stadter, Chief Executive Officer, Wantel, Inc. (Sept. 5, 2008) (“September 5, 2008 LOI”).
10 47 U.S.C. § 222; 47 C.F.R. 64.2009(e).
Federal Communications Commission DA 10-692
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(k) “Rules” means the Commission’s regulations found in Title 47 of the Federal 
Regulations.
II. BACKGROUND
A. Federal Regulatory Reporting and Contribution Obligations
3. Pursuant to section 254(d) of the Act and sections 54.706 and 54.711 of the 
Commission’s rules, telecommunications service providers that provide interstate telecommunications 
services are required to file annual and quarterly Telecommunications Reporting Worksheets (FCC Form 
499-A and FCC Form 499-Q) and contribute to the federal USF.11
4. Pursuant to section 251(e) of the Act and sections 52.17 and 52.32 of the Commission’s 
rules, telecommunications service providers are required to contribute to the costs of establishing 
numbering administration and local number portability.12  
5. Pursuant to section 225(b)(1) of the Act and section 64.604 of the Commission’s rules, 
providers of interstate telecommunications services are required to contribute to the TRS Fund.13
6. Pursuant to section 9(a)(1) of the Act and sections 1.1154 and 1.1157 of the 
Commission’s rules, interstate telecommunications carriers are required to pay regulatory fees.14  
7. ComSpan offers interstate and international telecommunications services and is subject to 
the requirements discussed in paragraphs 3 through 6 above. 
8. On March 13, 2008, the Bureau issued a letter of inquiry (“LOI”) to ComSpan.15 The 
March 13, 2008 LOI directed ComSpan, among other things, to submit a sworn written response to a 
series of questions regarding whether ComSpan violated sections 1.1157, 52.17, 52.32, 54.706, 54.711, 
64.604, and 64.1195 of the Commission’s rules,16 concerning the payment of annual regulatory fees; 
contributions to the USF and TRS Fund; contributions to cost-recovery mechanisms for NANP and LNP 
administration; and the reporting of information as set forth on the Telecommunications Reporting 
Worksheets. ComSpan responded to the March 13, 2008 LOI on April 1, July 25, August 14, and 
September 25, 2008.17 As of the Effective Date, ComSpan has paid all invoiced amounts to the USF, 
  
11 47 U.S.C. § 254(d); 47 C.F.R. §§ 54.706, 54.711.
12 47 U.S.C. § 251(e); 47 C.F.R. §§ 52.17, 52.32.
13 47 U.S.C. § 225(b)(1); 47 C.F.R. § 64.604.
14 47 U.S.C. § 9(a)(1); 47 C.F.R. §§ 1.1154, 1.1157.
15 See supra note 7.  
16 47 C.F.R. §§ 1.1157, 52.17, 52.32, 54.706, 54.711, 64.604, and 64.1195.
17 See ComSpan Communications Inc. f/k/a Wantel, Inc., EB-08-IH-0665, Letter from Raymond Hazlett, Chief 
Financial Officer, ComSpan Communications Inc. to David Janas, Special Counsel, Investigations & Hearings 
Division, Enforcement Bureau, Federal Communications Commission (Apr. 1, 2008); ComSpan Communications 
Inc. f/k/a Wantel, Inc., EB-08-IH-0665, Letter from Candice Alderson, Director, Legal Services, ComSpan 
Communications Inc. to David Janas, Special Counsel, Investigations & Hearings Division, Enforcement Bureau, 
Federal Communications Commission (Jul. 25, 2008); ComSpan Communications Inc. f/k/a Wantel, Inc., EB-08-IH-
0665, Letter from Al Soreng, Controller, ComSpan Communications Inc. to David Janas, Special Counsel, 
Investigations & Hearings Division, Enforcement Bureau, Federal Communications Commission (Aug. 14, 2008); 
Federal Communications Commission DA 10-692
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TRS Fund, cost recovery mechanisms for NANP and LNP administration, and regulatory fees, as well as 
complied with the regulatory reporting obligations discussed above.
B. CPNI Obligations
9. Section 222 of the Act imposes a duty on telecommunications carriers to protect the 
confidentiality of their subscribers’ proprietary information.18 The Commission has issued rules 
implementing section 222 of the Act, and required carriers to establish and maintain a system designed to 
ensure that carriers adequately protect their subscribers’ CPNI.19 Section 64.2009(e) of the Commission’s 
rules is one such requirement.20
10. In 2006, some companies, known as “data brokers,” advertised the availability of records 
of wireless subscribers’ incoming and outgoing telephone calls for a fee.21 Data brokers also advertised 
the availability of certain landline toll calls.22  On April 2, 2007, the Commission strengthened its privacy 
rules with the release of the EPIC CPNI Order,23 which adopted additional safeguards to protect CPNI 
    
ComSpan Communications Inc. f/k/a Wantel, Inc., EB-08-IH-0665, Letter from Al Soreng, Controller, ComSpan 
Communications Inc. to David Janas, Special Counsel, Investigations & Hearings Division, Enforcement Bureau, 
Federal Communications Commission (Sept. 25, 2008).
18 Section 222 of the Act, 47 U.S.C § 222, provides as follows:  “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 amendments to the 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 Telecomms. Act of 1996: Telecomms. Carriers’ Use of Customer Proprietary Network 
Info. & Other Customer Info. & Implementation of Non-Accounting Safeguards of Sections 271 and 272 of the 
Commc’ns Act of 1934, as Amended, Second Report and Order and Further Notice of Proposed Rulemaking, 13 
FCC Rcd 8061, 8068-70, ¶ 7 (1998) (“CPNI Order”) (describing the Commission’s privacy protections for 
confidential customer information in place prior to the 1996 amendments to the Act).
19 See CPNI Order, supra note 18; Implementation of the Telecomms. Act of 1996: Telecomms. Carriers' Use of 
Customer Proprietary Network Info. & Other Customer Info. & Implementation of the Non-Accounting Safeguards 
of Sections 271 and 272 of the Commc’ns Act of 1934, as Amended, Order on Reconsideration and Petitions for 
Forbearance, 14 FCC Rcd 14409 (1999); Implementation of the Telecomms. Act of 1996: Telecomms. Carriers’ Use 
of Customer Proprietary Network Info. & Other Customer Info. & Implementation of the Non-Accounting 
Safeguards of Sections 271 and 272 of the Commc’ns Act of 1934, as Amended; 2000 Biennial Regulatory Review --
Review of Policies & Rules Concerning Unauthorized Changes of Consumers’ Long Distance Carriers, Third 
Report and Order and Third Further Notice of Proposed Rulemaking, 17 FCC Rcd 14860 (2002); EPIC CPNI 
Order, supra note 5.
20 47 C.F.R. 64.2009(e).
21 See, e.g., http://www.epic.org/privacy/iei/ (accessed June 25, 2009).
22 See id.
23 See supra note 5.  Specifically, pursuant to section 64.2009(e) of the Commission’s rules, 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 Part 64, Subpart U of 
the Commission’s rules.  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 
Federal Communications Commission DA 10-692
5
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.24  
11. On September 5, 2008, the Bureau issued an LOI to ComSpan, which directed ComSpan, 
among other things, to submit a sworn written response to a series of questions regarding whether 
ComSpan timely filed a CPNI compliance certificate for 2007, which was due by March 1, 2008 pursuant 
to section 64.2009(e) of the Commission’s rules, or an explanation as to why no certification was filed.25  
On September 16, 2008, ComSpan submitted a response to the Bureau’s September 5, 2008 LOI.26 The 
Bureau concluded that ComSpan failed to submit satisfactory evidence of its timely filing of the annual 
CPNI compliance certification, and on February 24, 2009, released the CPNI Omnibus NAL against 
numerous companies, including ComSpan, proposing a monetary forfeiture of $20,000 for ComSpan’s 
apparent failure to comply with section 64.2009(e) of the Commission’s rules, and the Commission’s 
EPIC CPNI Order.27
III. TERMS OF AGREEMENT
12. 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.
13. Jurisdiction. ComSpan 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.
14. 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.
15. 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 its investigations against ComSpan.  In consideration for the termination of said investigations, 
ComSpan 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 these 
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 
    
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).
24 EPIC CPNI Order, 22 FCC Rcd at 6928.
25 See supra note 9.
26 ComSpan Communications Inc., EB-08-TC-3549, Letter from Michelle Elkins, Regulatory Assistant, ComSpan 
Communications Inc. to Marcy Greene, Deputy Chief, Telecommunications Consumers Division, Enforcement 
Bureau, Federal Communications Commission (Sept. 16, 2008).
27 See CPNI Omnibus NAL, supra note 6; see also 47 C.F.R. § 64.2009(e); EPIC CPNI Order, supra note 5.
Federal Communications Commission DA 10-692
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motion against ComSpan concerning the matters that were the subjects 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 ComSpan with respect to 
ComSpan’s basic qualifications, including its character qualifications, to be a Commission licensee or 
authorized common carrier.
 
16. Federal Regulatory Reporting and Contribution Compliance Plan. For purposes of 
settling the matters set forth herein, within 30 days of the Effective Date, ComSpan agrees to create and 
maintain a compliance plan related to future compliance with the Act and the Commission’s rules and 
orders concerning federal regulatory reporting and contribution obligations.  The Plan will include, at a 
minimum, the following components:   
(a) Compliance Manual.  ComSpan shall create, maintain and update a manual to ensure future 
compliance with ComSpan’s obligations concerning the payment of annual regulatory fees; 
contributions to the USF and TRS Fund; contributions to cost-recovery mechanisms for 
NANP and LNP administration; and the submission of information as set forth on the 
Telecommunications Reporting Worksheets.  ComSpan personnel who engage in activities 
related to federal reporting and contribution requirements will follow the procedures 
contained in the Compliance Manual.  The Compliance Manual will, among other things, 
describe the rules and requirements as they apply to ComSpan regarding ComSpan’s federal 
regulatory reporting and contribution obligations.  The Compliance Manual will set forth a 
schedule of filing and payment dates associated with annual regulatory fees; contributions to 
the USF and TRS Fund; contributions to cost-recovery mechanisms for NANP and LNP 
administration; and the submission of information as set forth on the Telecommunications 
Reporting Worksheets.  ComSpan will create compliance notifications that alert ComSpan 
personnel to upcoming filing and payment dates.  The Compliance Manual will require 
personnel to contact ComSpan’s Designated Contact, and if appropriate regulatory legal 
counsel, with any questions or concerns that arise with respect to ComSpan’s federal 
regulatory reporting and contribution obligations.
(b) Compliance Training Program.  ComSpan will ensure that all personnel who engage in 
activities related to ComSpan’s federal reporting and contribution obligations are 
appropriately trained and supervised.  
(c) Designated Contact.  ComSpan designates its Controller as the point of contact for its federal 
reporting and contribution obligations.
(d) Review and Monitoring.  ComSpan will review the Compliance Manual and Compliance 
Training Program to ensure that they are maintained in the proper manner and continue to 
address future compliance with ComSpan’s obligations concerning the payment of annual 
regulatory fees; contributions to the USF and TRS Fund; contributions to cost-recovery 
mechanisms for NANP and LNP administration; and the reporting of information as set forth 
on the Telecommunications Reporting Worksheets.
(e) Audits.  ComSpan will ensure that any internal reviews of the Compliance Plan, if conducted, 
specifically consider compliance with pertinent federal reporting and contribution 
obligations.
(f) Compliance Reports.  ComSpan will file compliance reports with the Commission ninety 
days after the Effective Date, twelve months after the Effective Date, and 48 months after the 
Federal Communications Commission DA 10-692
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Effective Date.  Each compliance report shall include a compliance certificate from an 
officer, as an agent of ComSpan, stating that the officer has personal knowledge that 
ComSpan 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 Hillary 
DeNigro, Chief, Investigations & Hearings Division, Enforcement Bureau, Federal 
Communications Commission, 445 12th Street, S.W., Room 4-C330, Washington, D.C. 
20554.  ComSpan must also transmit a copy of the reports via email to 
hillary.denigro@fcc.gov.
17. CPNI Compliance Plan.  ComSpan further agrees to take all measures necessary to 
achieve full compliance with Section 64.2009(e) of the Commission’s rules.28 ComSpan agrees to train 
its personnel regarding when they are and are not authorized to use CPNI. ComSpan further agrees to 
have an express disciplinary process in place for the unauthorized use of CPNI.  Additionally, ComSpan 
agrees to submit a copy of its annual 64.2009(e) compliance certificate for each of four (4) 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.  ComSpan will also send 
an electronic copy of its certification to other Telecommunications Consumers Division staff as directed 
by the Division Chief.  
18. Termination Date. Unless stated otherwise, the requirements of the Federal Regulatory 
Reporting and Contribution Compliance Plan and Consent Decree will expire 48 months after the 
Effective Date.  The requirements of the CPNI Compliance Plan will expire 48 months after the Effective 
Date or upon the termination of the certification requirement set forth in sections 64.2009(e) of the 
Commission’s rules, whichever is earlier.  
19. 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 ComSpan or its affiliates 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 ComSpan of the Act, the rules, or the 
Order.
20. Voluntary Contribution.  ComSpan agrees that it will make a voluntary contribution to 
the United States Treasury in the amount of $200,000 in 48 monthly installments of $4,166.67.  The first 
payment will be made within 10 days after the Effective Date of the Adopting Order, with subsequent 
payments made by the 15th day or each subsequent month for 47 months.  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 the 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 
by wire transfer may be made to ABA Number 021030004, receiving bank TREAS/NYC, and account 
number 27000001.  ComSpan will also send electronic notification on the date said payment is made to 
david.janas@fcc.gov. 
  
28 47 C.F.R. § 64.2009(e).
Federal Communications Commission DA 10-692
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21. Waivers.  ComSpan 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.  ComSpan 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 ComSpan nor the Commission shall contest the validity of the 
Consent Decree or the Adopting Order, and ComSpan shall waive any statutory right to a trial de novo.  
ComSpan hereby agrees to waive any claims it may otherwise have under the Equal Access to Justice 
Act,29 relating to the matters addressed in this Consent Decree.
22. 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 ComSpan does not expressly 
consent) that provision will be superseded by such Commission rule or order.
23. Successors and Assigns. ComSpan agrees that the provisions of this Consent Decree 
shall be binding on its successors, assigns, and transferees.  
24. 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.  
25. Modifications. This Consent Decree cannot be modified without the advance written 
consent of both parties.
26. 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.
27. Authorized Representative.  Each party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.
28. 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.
  
29 5 U.S.C. § 504; 47 C.F.R. Part 1, Subpart K.
Federal Communications Commission DA 10-692
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________________________________
P. Michele Ellison
Chief
Enforcement Bureau 
________________________________
Date
________________________________
Jimmy Byrd
Chief Executive Officer
ComSpan Communications Inc.
________________________________
Date