Federal Communications Commission DA 12-1146
1
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Verizon
Compliance with the Commission’s Rules and 
Regulations Governing Customer Proprietary 
Network Information and Toll Free Numbering
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File Nos.:  EB-TCD-12-00000304,
 EB-TCD-12-000004401
Account No.:  201232170009
FRN:  0016304214
ADOPTING ORDER
Adopted:  July 26, 2012 Released:  July 26, 2012
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 and Verizon.  The Consent Decree 
terminates the investigations initiated by the Bureau regarding Verizon’s compliance with Sections 201(b) 
and 222(c)(1) of the Communications Act of 1934, as amended, 47 U.S.C. §§ 201(b), 222(c)(1) and 
Sections 52.105 and 64.2010(f) of the Commission’s rules, 47 C.F.R. §§ 52.105, 64.2010(f).
2. The Bureau and Verizon have negotiated the terms of the 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 Verizon 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 Sections 0.111 and 0.311 of the 
Commission’s rules, 47 C.F.R. §§ 0.111 and 0.311, that the attached Consent Decree IS ADOPTED.
  
1 In January 2011, the Telecommunications Consumers Division transitioned pending cases to a new electronic case 
management system.  As part of that transition, cases received new, electronically assigned file numbers.  The 
investigation now numbered EB-TCD-12-00000304 was formerly numbered EB-10-TC-445.  The investigation now 
numbered EB-TCD-12-00000440 was previously numbered EB-11-TC-011.
Federal Communications Commission DA 12-1146
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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, to Tamara Preiss, Vice President, 
Federal Regulatory Affairs, 1300 I Street, NW, Suite 400 West, Washington, DC 20005.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
Federal Communications Commission DA 12-1146
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Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Verizon
Compliance with the Commission’s Rules and 
Regulations Governing Customer Proprietary 
Network Information and Toll Free Numbering
)
)
)
)
)
)
)
File Nos.:  EB-TCD-12-00000304,
 EB-TCD-12-000004402
Account No.:  201232170009
FRN:  0016304214
CONSENT DECREE
The Enforcement Bureau of the Federal Communications Commission and Verizon, by their 
authorized representatives, hereby enter into this Consent Decree for the purpose of terminating the 
Enforcement Bureau’s investigations into potential violations by Verizon of Sections 201(b) and 222(c)(1) 
of the Communications Act of 1934, as amended,3 and Sections 52.105 and 64.2010(f) of the 
Commission’s rules.4  
I. DEFINITIONS
1. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” or “Communications Act” means the Communications Act of 1934, as 
amended, 47 U.S.C. § 151 et seq.
 
(b) “Adopting Order” means an order of the Bureau adopting the terms of this 
Consent Decree without change, addition, deletion, or modification.
(c) “Affiliate” shall have the same meaning defined in Section 153(1) of the 
Communications Act, 47 U.S.C. § 153(1). 
(d) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(e) “Commission” and “FCC” mean the Federal Communications Commission and 
all of its bureaus and offices.
  
2 In January 2011, the Telecommunications Consumers Division transitioned pending cases to a new electronic case 
management system.  As part of that transition, cases received new, electronically assigned file numbers.  The 
investigation now numbered EB-TCD-12-00000304 was formerly numbered EB-10-TC-445.  The investigation now 
numbered EB-TCD-12-00000440 was previously numbered EB-11-TC-011.
3 47 U.S.C. §§ 201(b), 222(c)(1).
4 47 C.F.R. §§ 52.105, 64.2010(f).
Federal Communications Commission DA 12-1146
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(f) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which Verizon is 
subject by virtue of its business activities, including but not limited to Sections 
201(b) and 222(c)(1) of the Act and Sections 52.105 and 64.2010(f) of the Rules.
(g) “Compliance Plan” means the compliance obligations and compliance program 
described in this Consent Decree at paragraph 10.  
(h) “CPNI” shall have the meaning set forth at 47 C.F.R. § 222(h)(1).  
(i) “CPNI Investigation” means the investigation commenced by the Bureau’s LOI, 
dated May 3, 2011,5 regarding Verizon’s possible noncompliance with Section 
222(c)(1) of the Act, 47 U.S.C. § 222(c)(1), and Section 64.2010(f) of the 
Commission’s rules, 47 C.F.R. § 64.2010(f).          
(j) “CPNI Rules” means the rules set forth at 47 C.F.R. § 64.2001 et seq. and any 
amendments or additions to those rules subsequent to the Effective Date.
(k) “Effective Date” means the date on which the Bureau releases the Adopting 
Order. 
(l) “Investigations” means both the CPNI Investigation and the Toll Free 
Investigation.  
(m) “June 2010 Settlement” means the Consent Decree executed by and between the 
Bureau and Verizon, released on June 28, 2010, and set forth at 25 FCC Rcd 8019 
(Enf. Bur. 2010).  
(n) “LOI” means letter of inquiry.  
(o) “Parties” means Verizon and the Bureau, each of which is a “Party.”
(p) “RespOrg” or “Responsible Organization” shall have the meaning set forth at 47 
C.F.R. § 52.101(b). 
(q) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations. 
(r) “Toll Free Number” shall have the meaning set forth at 47 C.F.R. § 52.101(f).  
(s) “Toll Free Number Investigation” means the investigation commenced by the 
Bureau’s LOI dated August 16, 2010, regarding Verizon’s possible 
noncompliance with Section 52.105 of the Rules.6
  
5 Letter from Richard A. Hindman, Chief, Telecommunications Consumers Division, FCC Enforcement Bureau, to 
Tamara Preiss, Vice President, Federal Regulatory Affairs, Verizon (May 3, 2011) (on file in EB-11-TC-011).
6 Letter from Kurt Schroeder, Deputy Chief, Telecommunications Consumers Division, FCC Enforcement Bureau, to 
Verizon Select Services aka Verizon Business (Aug. 16, 2010) (on file in EB-10-TC-445).
Federal Communications Commission DA 12-1146
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(t) “Toll Free Number Rules” means the rules set forth at 47 C.F.R. §§ 52.105–52.111 
and any amendments or additions to those rules subsequent to the Effective Date.
(u) “Verizon” or “Company” means the regulated, wholly owned subsidiaries of 
Verizon Communications Inc. and their successors and assigns.
II. BACKGROUND
2. Pursuant to Section 222 of the Act,7 the Commission has adopted rules to protect the 
confidentiality of customer proprietary network information (CPNI).  Among other things, these rules 
generally require customer notification when a significant account change (SAC), such as a password 
change, occurs on a customer’s account.8  
3. On June 28, 2010, Verizon entered into a consent decree with the Bureau that terminated 
another CPNI investigation.9 The compliance plan contained in the consent decree required Verizon to 
perform weekly checks for SAC transaction errors.  Verizon was also required under the consent decree to 
report any noncompliance with the consent decree provisions to the Bureau.  On March 9, 2011, Verizon 
informed the Bureau that its review had identified certain systems requiring modification to ensure that 
required SAC notices were timely sent to customers as required by the CPNI Rules.    
4. The Bureau issued an LOI to Verizon on May 3, 2011.10 The Bureau met with Verizon on 
June 1, 2011, at which time Verizon detailed additional instances in which Verizon’s systems and 
processes required modification to ensure that SAC notices were sent to consumers.  On June 10, 2011, 
Verizon submitted a letter detailing those additional issues.11 Verizon submitted its response to the LOI on 
June 30, 2011.12
5. Section 52.105 of the Rules prohibits the warehousing of Toll Free Numbers.  
Warehousing, generally, is when a Responsible Organization reserves a Toll Free Number from the Toll 
Free Number database without having an actual subscriber for that Toll Free Number.13
To investigate potential violations by Verizon of the Toll Free Number Rules, on August 16, 2010, the 
Bureau issued an LOI to Verizon Select Services, Inc. (VSSI),14 and on September 29, 2010, a subpoena to 
  
7 47 U.S.C. § 222.
8 See 47 C.F.R. § 64.2010(f).
9 Verizon, Adopting Order and Consent Decree, 25 FCC Rcd 8019 (Enf. Bur. 2010).    
10 See supra note 4.
11 See Letter from Tamara Preiss, Vice President, Federal Regulatory Affairs, Verizon, to Richard A. Hindman, 
Chief, Telecommunications Consumers Division, FCC Enforcement Bureau (June 10, 2011) (on file in EB-11-TC-
011).
12 Letter from Edward Shakin and Mark Montano, Verizon, to Kimberly A. Wild, Assistant Chief, 
Telecommunications Consumers Division, FCC Enforcement Bureau (June 30, 2011) (on file in EB-11-TC-011).  On 
August 3, 2011, and August 5, 2011, Verizon provided supplemental responses regarding data on SACs prior to 
January 1, 2010, for the portals or call centers that were included in their June 30, 2011, response.
13 See 47 C.F.R. § 52.105(a).
14 Letter from Kurt Schroeder, Deputy Chief, Telecommunications Consumers Division, FCC Enforcement Bureau, 
to Verizon Select Services aka Verizon Business (Aug. 16, 2010) (on file in EB-10-TC-445).
Federal Communications Commission DA 12-1146
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VSSI .15 Verizon provided information in response to the LOI and the subpoena on various dates. 16 On 
March 18, 2011, the Bureau issued a second LOI,17 and on April 6, 2011, a second subpoena to Verizon.18  
Verizon provided information in response to the second LOI and subpoena on various dates.19 According 
to Verizon’s May 16, 2011, subpoena response, Verizon had reserved toll free numbers in advance of a 
subscriber request from 2005 to 2011.20  
III. TERMS OF AGREEMENT
6. Adopting Order.  The Parties agree that the provisions of this Consent Decree shall be 
subject to final approval by the Bureau by incorporation of such provisions by reference in the Adopting 
Order.
7. Jurisdiction.  Verizon 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 as defined herein.  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 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 the CPNI Investigation and the Toll Free Number Investigation.  In consideration for the 
termination of the Investigations, Verizon agrees to the terms, conditions, and procedures contained herein.  
The Bureau agrees that absent new material evidence, it will not use the facts developed in the CPNI 
Investigation through the Effective Date, or the existence of this Consent Decree, to institute, on its own 
motion, or refer to the Commission, any new proceeding, formal or informal, or to take, on its own motion, 
or refer to the Commission, any action against Verizon concerning the matters that were the subject of the 
investigation or with respect to Verizon’s basic qualifications, including its character qualifications, to be a 
Commission licensee or hold Commission authorizations.  The Bureau also agrees that absent new 
material evidence, it will not use the facts developed in the Toll Free Number Investigation through the 
  
15 Letter from Kurt Schroeder, Deputy Chief, Telecommunications Consumers Division, FCC Enforcement Bureau, 
to Verizon Select Services aka Verizon Business (Sept. 29, 2010) (on file in EB-10-TC-445).
16 See Letter from Verizon to Kurt Schroeder, Deputy Chief, Telecommunications Consumers Division, FCC 
Enforcement Bureau (Oct. 13, 2010) (on file in EB-10-TC-445); Letter from Verizon to Acting Chief, 
Telecommunications Consumers Division, FCC Enforcement Bureau (Oct. 6, 2010) (on file in EB-10-TC-445); 
Letter from Verizon to Kurt Schroeder, Deputy Chief, Telecommunications Consumers Division, FCC Enforcement 
Bureau (Sept. 22, 2010) (on file in EB-10-TC-445).
17 Letter from Richard A. Hindman, Chief, Telecommunications Consumers Division, FCC Enforcement Bureau, to 
Verizon  (Mar. 18, 2011) (on file in EB-10-TC-445).
18 Letter from Suzanne M. Tetreault, Deputy Chief, FCC Enforcement Bureau, to Verizon (Apr. 6, 2011) (on file in 
EB-10-TC-445).
19 See Letter from Verizon to Richard A. Hindman, Chief, Telecommunications Consumers Division,  FCC 
Enforcement Bureau  (May 16, 2011) (on file in EB-10-TC-445) (Supplemental Response); Letter from Verizon to 
Richard A. Hindman, Chief, Telecommunications Consumers Division, FCC Enforcement Bureau (Apr. 18, 2011) 
(on file in EB-10-TC-445).
20 See Supplemental Response at 3.
Federal Communications Commission DA 12-1146
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Effective Date, or the existence of this Consent Decree, to institute, on its own motion, or refer to the 
Commission, any new proceeding, formal or informal, or to take, on its own motion, or refer to the 
Commission, any action against Verizon concerning the matters that were the subject of the investigation 
or with respect to Verizon’s basic qualifications, including its character qualifications, to be a Commission 
licensee or hold Commission authorizations. 
10. Compliance Plan.  For purposes of settling the matters set forth herein, Verizon shall 
within thirty (30) calendar days after the Effective Date, develop and implement a Compliance Plan 
relating to Verizon’s future compliance with those portions of the Communications Laws relating to the 
CPNI Rules and Toll Free Number Rules, and with the terms and conditions of this Consent Decree.  
Verizon represents that it has one or more management employees in each of its business units who has 
responsibility for compliance with each of the Communications Laws that are relevant to its operations; 
that there are at least twenty (20) such management employees; and that, collectively, these management 
employees exercise responsibility for Verizon’s compliance with all of the Communications Laws that are 
relevant to its operations.  Verizon agrees that it will either maintain this compliance structure, or, if it 
makes changes, shall ensure that it maintains equivalent management oversight over compliance with all 
Communication Laws that are applicable to its operations.  The Compliance Plan shall include, at a 
minimum, the following components:  
a) Compliance Officer.  Within thirty (30) days of the Effective Date, Verizon shall designate 
two senior corporate managers to serve as the Compliance Officers for the CPNI Rules and 
Toll Free Number Rules issues, respectively.  The Compliance Officers will be responsible for 
implementing and administering Verizon’s Compliance Plan.  
b) Notice of Consent Decree.  Within thirty (30) days after the Effective Date, Verizon shall 
notify all directors, officers (including the Compliance Officers), managers, and employees 
responsible for managing and overseeing Verizon’s SAC notice procedures and toll free 
number reservation and assignment of the terms and conditions set forth herein.  
CPNI
c) June 2010 Settlement Obligations. Paragraph 9(B)-(E) of the June 2010 Settlement is 
hereby incorporated by reference and made a part of this Consent Decree, except for those 
portions of paragraph 9(B)-(E) that are unrelated to SAC notification. 
d) SAC Compliance Review Prior to Material Changes.  Beginning sixty (60) days after the 
Effective Date, Verizon shall perform a monthly review of each of its mechanisms to 
disseminate SAC notices to its customers to ensure (1) that such mechanisms in fact are 
disseminating SAC notices as required by the CPNI Rules, and (2) that Verizon employees 
(including employees of Verizon Affiliates) responsible for managing and overseeing 
Verizon’s SAC notice dissemination mechanisms are communicating effectively to all 
necessary personnel any changes to such mechanisms.
e) CPNI Training.  Within sixty (60) days after the Effective Date, Verizon shall reinforce its 
existing annual CPNI training and implement an SAC Notice Training Program for the 
Verizon employees (including employees of Verizon Affiliates) responsible for managing the 
process by which Verizon SAC notices are distributed to customers, as well as for any 
managers overseeing such employees.  At a minimum, Verizon shall do the following:
i. Modify its training materials to place additional focus on the requirements of Section 
64.2010(f).  
Federal Communications Commission DA 12-1146
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ii. Conduct training that
1. Describes the requirements and prohibitions set forth in the CPNI Rules, in 
particular those set forth in Section 64.2010(f) and Section 64.2010(g); and
2. Addresses the potential internal and regulatory consequences of failing to 
comply with the Commission’s CPNI Rules and Verizon’s methods and 
procedures concerning CPNI.  
iii. Provide the above-described training to new and reassigned employees responsible for 
developing or disseminating SAC notices within forty-five (45) days of when the 
employees assume such responsibilities, provided such date is no less than fifteen (15) 
days following the Effective Date.
Toll Free Numbers
f) Remedial Measures.  Within ten (10) days of the Effective Date, Verizon shall certify by 
letter to the Commission, directed to the Chief, Telecommunications Consumers Division, that 
as of April 18, 2011, Verizon has implemented changes to the process and procedures of 
Verizon’s RespOrgs to ensure that none of Verizon’s RespOrgs reserves or places in working 
status any Toll Free Number unless the Verizon RespOrg has a subscriber for whom it is 
reserving or placing the number in working status.  
g) Toll Free Number Training.  Within sixty (60) days of the Effective Date, Verizon shall 
provide training to each Verizon employee (including employees of Verizon Affiliates) who is 
responsible for reserving any Toll Free Numbers or assigning any Toll Free Number to 
working status for Verizon RespOrgs.  At a minimum, the training shall accomplish the 
following:
i. Describe the requirements and prohibitions set forth in the Toll Free Number Rules, in 
particular Section 52.105 and what it means for a RespOrg to have an “actual toll free 
subscriber” when reserving a toll free number or assigning it to working status.
ii. Address the potential internal and regulatory consequences of failing to comply with 
the Commission’s Toll Free Rules and Verizon’s methods and procedures concerning 
toll free numbers.
iii. Be provided to new and reassigned employees who are responsible for reserving any 
Toll Free Number or assigning any Toll Free Number to working status for Verizon 
RespOrg within forty-five (45) days of when the employees assume their Toll Free 
Numbering responsibilities, provided such date is no less than fifteen (15) days 
following the Effective Date.
Other Terms
h) Compliance Reports.  Verizon shall submit compliance reports to the Bureau six (6), twelve 
(12), eighteen (18), and twenty-four (24) months after the Effective Date (Compliance 
Reports).    
i. Each Compliance Report shall include a certification by each Compliance Officer, as 
an agent of and on behalf of Verizon, stating that the Compliance Officer has personal 
knowledge that Verizon has established and implemented the Compliance Plan, and 
Federal Communications Commission DA 12-1146
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after due inquiry is not aware of any instances of noncompliance with the terms and 
conditions of this Consent Decree, including the reporting obligations set forth in 
paragraph 11.  
ii. The Compliance Officer’s certification shall be accompanied by a statement 
explaining the basis for such certification and 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.
iii. If the Compliance Officer is not able to so certify, the Compliance Officer, as an agent 
of and on behalf of Verizon, shall provide the Commission with a detailed explanation 
of the reason(s) why and describe fully each instance of noncompliance; the steps 
Verizon has taken or will take to remedy such noncompliance, including the schedule 
on which Verizon will take the proposed remedial actions; and the steps Verizon has 
taken or will take to prevent the recurrence of any such noncompliance, including the 
schedule on which Verizon will take such preventive action.
iv. All Compliance Reports shall be in writing and directed to the Chief, 
Telecommunications Consumers Division, Enforcement Bureau, Federal 
Communications Commission, 445 12th Street, SW, Washington, DC 20554.  Verizon 
shall also send an electronic copy of each Compliance Report to 
Donna.Cyrus@fcc.gov and Andra.Cunningham@fcc.gov. 
i) Termination.  The requirements relating to the Compliance Plan shall expire twenty-four (24) 
months after the Effective Date, except where this Consent Decree specifies a different time 
period.   
11. Reporting Noncompliance. Verizon shall report any noncompliance with the terms and 
conditions of this Consent Decree (including paragraph 9(B)-(E) in the June 2010 Settlement that is 
incorporated by reference in this Consent Decree as set forth in paragraph 10(c) above), any 
noncompliance with Section 64.2010(f) of the Rules to the extent that such noncompliance is more than an 
anomaly, or any noncompliance with the Toll Free Number Rules, within fifteen (15) business days after 
discovery of such noncompliance.  Such reports shall include a detailed explanation of (i) each instance of 
noncompliance, (ii) the steps that Verizon has taken or will take to remedy such noncompliance, (iii) the 
schedule on which Verizon will take the proposed remedial actions, and (iv) the steps that Verizon has 
taken or will take to prevent the recurrence of any such noncompliance.  All reports of noncompliance 
shall be submitted to the Chief, Telecommunications Consumers Division, Enforcement Bureau, Federal 
Communications Commission, 445 12th Street, SW, Rm. 4-C224, Washington, DC 20554, with a copy 
submitted electronically to Donna.Cyrus@fcc.gov and Andra.Cunningham@fcc.gov.  The reporting 
obligations set forth in this paragraph shall expire twenty-four (24) months after the Effective Date.  In 
addition, beginning on the Effective Date, Verizon shall, at the request of the Bureau, meet with the 
Bureau once each 60-day period during the term of the Compliance Plan to discuss Verizon’s adherence to 
the Compliance Plan and its performance under the CPNI Rules. Verizon agrees to provide the Bureau 
with information the Bureau requests concerning these topics.
12. Voluntary Contribution.  Verizon agrees that it will make a voluntary contribution to the 
United States Treasury in the amount of nine hundred seventy thousand dollars ($970,000) within thirty 
(30) calendar days after the Effective Date.  Verizon shall also send electronic notification of payment to 
Johnny Drake at johnny.drake@fcc.gov on the date said payment is made. The payment must be made by 
check or similar instrument, wire transfer, or credit card, and must include the NAL/Account number and 
FRN referenced above. Regardless of the form of payment, a completed FCC Form 159 (Remittance 
Federal Communications Commission DA 12-1146
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Advice) must be submitted.21 When completing the FCC Form 159, enter the Account Number in block 
number 23A (call sign/other ID) and enter the letters “FORF” in block number 24A (payment type code).  
Below are additional instructions you should follow based on the form of payment you select:
? Payment by check or money order must be made payable to the order of the Federal 
Communications Commission. Such payments (along with the completed Form 159) must be 
mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-
9000, or sent via overnight mail to U.S. Bank – Government Lockbox #979088, SL-MO-C2-
GL, 1005 Convention Plaza, St. Louis, MO 63101.
? Payment by wire transfer must be made to ABA Number 021030004, receiving bank 
TREAS/NYC, and Account Number 27000001. To complete the wire transfer and ensure 
appropriate crediting of the wired funds, a completed Form 159 must be faxed to U.S. Bank at 
(314) 418-4232 on the same business day the wire transfer is initiated.
? Payment by credit card must be made by providing the required credit card information on 
FCC Form 159 and signing and dating the Form 159 to authorize the credit card payment.   
The completed Form 159 must then be mailed to Federal Communications Commission, P.O. 
Box 979088, St. Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank –
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
63101.
If you have questions regarding payment procedures, please contact the Financial Operations Group Help 
Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov. 
13. Waivers.  Verizon 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 Bureau issues an Adopting Order as defined 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 or Consent Decree, neither Verizon nor the Commission shall contest the validity of 
the Consent Decree or the Adopting Order, and Verizon shall waive any statutory right to a trial de novo.  
Verizon hereby agrees to waive any claims it may otherwise have under the Equal Access to Justice Act, 5 
U.S.C. § 504 and 47 C.F.R. § 1.1501 et seq., relating to the matters addressed in this Consent Decree.
14. Subsequent Rule or Order.  The Parties agree that if any provision of this 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 Verizon does not expressly 
consent), such provision will be superseded by such Rule or order.  
15. Successors and Assigns.  Verizon agrees that the provisions of this Consent Decree shall 
be binding on its successors, assigns, and transferees.
16. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties to the CPNI Investigation and the Toll Free Investigation.  
17. Modifications.  This Consent Decree cannot be modified or amended without the advance 
written consent of both Parties.
  
21 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
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18. Paragraph Headings.  The headings of the paragraphs in this Consent Decree are inserted 
for convenience only and are not intended to affect the meaning or interpretation of this Consent Decree.
19. 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, 47 U.S.C. § 208, against Verizon 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 evidence of noncompliance by Verizon of the Act or the Rules.
20. Invalidity.  In the event that this Consent Decree in its entirety is rendered invalid by any 
court of competent jurisdiction, it shall become null and void and may not be used in any manner in any 
legal proceeding. 
21. Authorized Representative.  The individual signing this Consent Decree on behalf of 
Verizon represents and warrants that he or she is authorized by Verizon to execute this Consent Decree 
and to bind Verizon to the obligations set forth herein.  The FCC signatory represents that she is signing 
this Consent Decree in her official capacity and that she is authorized to execute this Consent Decree.
22. Counterparts.  This Consent Decree may be signed in any number of counterparts 
(including by facsimile or scanned form), 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.
For:  Federal Communications Commission
__________________________________________
P. Michele Ellison   
Chief
Enforcement Bureau
__________________________________________
Date
For:  Verizon 
__________________________________________
Kathleen G. Ramsey
Associate General Counsel
__________________________________________
Date