Federal Communications Commission DA 13-1998
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
AT&T Mobility, LLC 
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      File No.:  EB-SED-13-00009047
1
      Acct. No.:  201332100017
      FRN:  0018624742
ORDER
Adopted:  September 30, 2013 Released:  September 30, 2013  
By the Acting 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 
Mobility, LLC (AT&T Mobility).  The Consent Decree resolves and terminates the Bureau’s 
investigation into possible violations of Section 301 of the Communications Act of 1934, as amended
(Act),
2
and Sections 1.929(b) and 1.947(a) and (b) of the Commission’s rules (Rules),
3
pertaining to the 
timely filing of applications to modify a carrier’s Cellular Geographic Service Area.
2. The Bureau and AT&T Mobility have negotiated the Consent Decree that resolves this 
matter.  A copy of the Consent Decree is attached hereto and incorporated herein by reference.  
3. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree and terminating the 
investigation.
4. In the absence of material new evidence relating to this matter, we conclude that our 
investigation raises no substantial or material questions of fact as to whether AT&T Mobility 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 Sections 4(i), 4(j), and 503(b) of the 
Act
4
and Sections 0.111 and 0.311 of the Rules,
5
the Consent Decree attached to this Order IS 
ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigation IS 
TERMINATED.
                                                
1
The investigation initiated under File No. EB-09-SE-117 was subsequently assigned File No. EB-SED-13-
00009047.  Any future correspondence with the FCC concerning this matter should reflect the new case number.
2
47 U.S.C. § 301.
3
47 C.F.R. §§ 1.929(b), 1.947(a)-(b).
4
47 U.S.C. §§ 154(i), 154(j), 503(b).
5
47 C.F.R. §§ 0.111, 0.311.
           Federal Communications Commission DA 13-1998
2
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 Teri Lindsay, Vice President –
Global Engineering Support, AT&T Services, Inc., 1120 20th Street, N.W., Suite 100, Washington, DC 
20036.
FEDERAL COMMUNICATIONS COMMISSION
Robert H. Ratcliffe
Acting Chief, Enforcement Bureau
             Federal Communications Commission DA 13-1998
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
AT&T Mobility, LLC 
)
)
)
)
)
File No.:  EB-SED-13-00009047
1
Acct. No.:  201332100017
FRN:  0018624742   
             
CONSENT DECREE
The Enforcement Bureau of the Federal Communications Commission and AT&T Mobility, 
LLC, by their respective authorized representatives, hereby enter into this Consent Decree for the purpose 
of terminating the Enforcement Bureau’s investigation into possible violations of Section 301 of the 
Communications Act of 1934, as amended,
2
and Sections 1.929(b) and 1.947(a) and (b) of the 
Commission’s rules (Rules),
3
pertaining to the timely filing of applications to modify a carrier’s Cellular 
Geographic Service Area.  
I. DEFINITIONS
1. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended, 47 U.S.C. §§ 151 et 
seq.
(b) “Adopting Order” means an order of the Bureau adopting the terms of this 
Consent Decree without change, addition, deletion, or modification.
(c) “AT&T Mobility” or “Company” means AT&T Mobility, LLC, and its 
predecessors-in-interest and successors-in-interest. 
(d) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(e) “Cellular Geographic Service Area” or “CGSA” is the geographic area 
considered by the FCC to be served by a cellular system, and within which a 
cellular system is entitled to protection from interference.
4
(f) “CGSA Modification Rules” means Sections 1.929(b), 1.947(a), and 22.911 of 
the Rules and other Communications Laws governing the filing of applications to 
expand a licensee’s CGSA.
                                                
1
The investigation initiated under File No. EB-09-SE-117 was subsequently assigned File No. EB-SED-13-
00009047.  Any future correspondence with the FCC concerning this matter should reflect the new case number.
2
47 U.S.C. § 301.
3
47 C.F.R. §§ 1.929(b), 1.947(a)-(b).
4
See id. § 22.911.
           Federal Communications Commission DA 13-1998
2
(g) “Commission” and “FCC” mean the Federal Communications Commission and 
all of its bureaus and offices.
(h) “Communications Laws” means collectively, the Act, the Rules, and the 
published and promulgated orders and decisions of the Commission to which 
AT&T Mobility is subject by virtue of its business activities, including but not 
limited to the CGSA Modification Rules.
(i) “Compliance Plan” means the compliance obligations and compliance program 
described in this Consent Decree at paragraph 11 hereof.
(j) “Covered Employees” means all employees and agents of AT&T Mobility who 
perform duties, or supervise, oversee, or manage the performance of duties, that 
relate to AT&T Mobility’s responsibilities under the CGSA Modification Rules, 
but excludes those employees or agents of AT&T Mobility who perform 
construction or similar tasks related to the physical maintenance of AT&T 
Mobility’s cellular network.
(k) “Effective Date” means the date on which the Bureau releases the Adopting 
Order.
(l) “Investigation” means, collectively, the investigation commenced by the 
Bureau’s June 11, 2009, letter of inquiry
5
pertaining to possible violations of the 
CGSA Modification Rules, including (i) AT&T Mobility’s subsequent disclosure 
to the Bureau of certain additional applications involving possible violations of 
the CGSA Modification Rules,
6
and (ii) AT&T Mobility’s disclosure to the 
Bureau of its discontinuance of cellular service at AT&T Mobility’s former cell 
site at Roger’s Peak in the Death Valley National Park, California.
(m) “Operating Procedures” means the standard, internal operating procedures and 
policies established by AT&T Mobility to implement the Compliance Plan and 
ensure that it complies with the CGSA Modification Rules.
(n) “Parties” means AT&T Mobility, LLC and the Bureau, each of which is a 
“Party.”
(o) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
II. BACKGROUND
2. Sections 1.929(b) and 1.947(a) of the Rules classify applications proposing network 
modifications that would expand the CGSA of an existing cellular system as major change applications 
necessitating prior Commission approval.
7
  Under Sections 1.929(k) and 1.947(b) of the Rules, network 
                                                
5
See Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division, FCC Enforcement Bureau, to 
Jacquelyne Flemming, Assistant Vice President Federal Regulatory, AT&T Mobility, LLC (June 11, 2009) (on file 
in EB-SED-13-00009047).
6
See Letter from Jacquelyne Flemming, AVP-External Affairs/Regulatory, AT&T Services, Inc., to John Poutasse, 
Chief, Spectrum Enforcement Division, FCC Enforcement Bureau (Aug. 5, 2013) (on file in EB-SED-13-
00009047).
7
See 47 C.F.R. §§ 1.929(b), 1.947(a).
           Federal Communications Commission DA 13-1998
3
modifications that would reduce a cellular system’s CGSA are classified as minor change applications, 
and a licensee implementing such system modifications must file a minor change notification within 
thirty days of making any such change.  In the 2000 Biennial Review Reconsideration Order,
8
the 
Commission adopted the “secondary operations policy,” which permits cellular licensees to “extend into 
adjacent unserved area[s] of less than 50 square miles without prior approval by the Commission, and 
without first undergoing the major modification process.”
9
  Licensees are required to notify the 
Commission within thirty (30) days after implementing such changes.
10
3. Prior to the sunset of analog cellular coverage, AT&T Mobility conducted a review of its 
network coverage to determine whether shutting down analog service would result in any reduction in 
service to its customers.  Following that review, in January 2007, AT&T Mobility disclosed to the 
Wireless Telecommunications Bureau (Wireless Bureau) that many of AT&T Mobility’s CGSA records 
were out of date.  Thereafter, AT&T Mobility filed major change applications and minor change 
notifications (collectively, the Applications) to modify certain of its CGSAs.
11
  In June 2009, the Wireless 
Bureau granted certain of the Applications without prejudice to future enforcement action.  The Wireless 
Bureau subsequently referred this matter to the Bureau for investigation and possible enforcement 
action.
12
   
4. On June 11, 2009, the Bureau’s Spectrum Enforcement Division issued a letter of inquiry 
(LOI) to AT&T Mobility, directing the company to submit a sworn written response to a series of 
questions relating to the Applications.
13
  AT&T Mobility responded to the LOI on July 31, 2009.
14
  In its 
LOI Response, AT&T Mobility noted that it had initiated efforts to update the internal protocols and 
controls followed by its network personnel to facilitate the timely filing of applications to modify 
CGSAs.
15
  AT&T Mobility subsequently filed various supplements to its LOI Response, submitting 
                                                
8
See Year 2000 Biennial Review – Amendment of Part 22 of the Commission’s Rules to Modify or Eliminate 
Outdated Rules Affecting the Cellular Radiotelephone Service and Other Commercial Mobile Radio Services, Order 
on Reconsideration, 19 FCC Rcd 3239 (2004) (2000 Biennial Review Reconsideration Order).
9
Id. at 3256–57, para. 41.  An “unserved area” is that portion of the licensee’s Cellular Market Area (CMA) Block 
not built out within the five-year period after the grant of the initial construction authorization for that CMA Block.  
Id. at 3253, para. 34.  Any such extension would be on a secondary basis only and would not become part of the 
licensee’s CGSA unless the licensee filed a major change application and such application was granted.  Id. at 3256, 
para. 41.
10
Id.  See also 47 C.F.R. 1.947(b).
11
Sunset of the Cellular Radiotelephone Service Analog Service Requirement and Related Matters, Memorandum 
Opinion and Order, 22 FCC Rcd 11243 (2007) (Analog Sunset MO&O) (permitting  licensees, “in lieu of making a 
revised CGSA showing, to certify that the discontinuance of [analog] service will not result in any loss of wireless 
coverage throughout the carrier’s CGSA.”).  Licensees that could not so certify were required to file a revised 
CGSA determination.  Id. at 11267, para. 49.
12
On September 21, 2011, AT&T Mobility filed a major modification application to modify the Roger’s Peak site 
and expand the CGSA for call sign KNKN209.  See File No. 0004882280 (filed Sept. 21, 2011).  At some point 
during the summer of 2011, AT&T Mobility ceased transmitting from the Roger’s Peak site, but did not file the 
appropriate modification application with the Commission until October 10, 2012.  Simultaneously with filing the 
application to remove the Roger’s Peak site from the license for call sign KNKN209, AT&T Mobility voluntarily 
disclosed the matter to the Bureau.  See File No. 0005441786.   The Commission granted the application on October 
25, 2012.  
13
See supra note 5.
14
See Letter from Robert Vitanza, General Attorney, AT&T Services, Inc., to Thomas D. Fitz-Gibbon, Staff 
Attorney, Spectrum Enforcement Division, FCC Enforcement Bureau (July 31, 2009) (on file in EB-SED-13-
00009047) (LOI Response).  
15
Id. at 8.  
           Federal Communications Commission DA 13-1998
4
additional information relevant to the Investigation.
16
  The Bureau and AT&T Mobility entered into 
tolling agreements to toll the statute of limitations.
17
5. We note that the Commission is currently considering whether to alter its site-based 
licensing framework.  On February 15, 2012, the Commission issued a Notice of Proposed Rulemaking 
and Order proposing to transition the existing site-based licensing model for the Cellular Radiotelephone 
Service (Cellular Service) to a geographic-based approach, which would generally authorize construction
within a particular geographic boundary (subject to certain interference protection and other technical 
requirements) and would not entail applications for prior Commission approval of specific transmitter 
locations.
18
  The Commission also adopted an immediate freeze on the filing of certain Cellular Service 
applications claiming an unserved area in “Covered” CMA Blocks, including new-system Cellular 
Service licenses and major modifications to expand existing systems if claiming an unserved area that is 
not contiguous to the existing CGSA.
19
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.  AT&T Mobility agrees that the Bureau has jurisdiction over it and the 
matters contained in this Consent Decree and that the Bureau 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.  As of 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 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
                                                
16
See, e.g., Letter from Robert Vitanza, General Attorney, AT&T Services, Inc., to Marlene H. Dortch, Secretary, 
Federal Communications Commission (Oct. 7, 2009) (on file in EB-SED-13-00009047); Letter from Robert 
Vitanza, General Attorney, AT&T Services, Inc., to Marlene H. Dortch, Secretary, Federal Communications 
Commission (Dec. 7, 2009) (on file in EB-SED-13-00009047); Letter from Robert Vitanza, General Attorney, 
AT&T Services, Inc., to Marlene H. Dortch, Secretary, Federal Communications Commission (Mar. 11, 2010) (on 
file in EB-SED-13-00009047); Letter from Robert Vitanza, General Attorney, AT&T Services, Inc. to Marlene H. 
Dortch, Secretary, Federal Communications Commission (Feb. 22, 2011) (on file in EB-SED-13-00009047).
17
See, e.g., Tolling Agreement Extension, executed by and between John D. Poutasse, Chief, Spectrum Enforcement 
Division, FCC Enforcement Bureau, and Robert Vitanza, General Attorney, AT&T Mobility, LLC (July 3, 2013) 
(on file in EB-SED-13-00009047).
18
See Amendment of Parts 1 and 22 of the Commission’s Rules with Regard to the Cellular Service, Including 
Changes in Licensing of Unserved Area; Amendment of the Commission’s Rules with Regard to Relocation of Part 24 
to Part 2; Interim Restrictions and Procedures for Cellular Service Applications, WT Docket No. 12-40, Notice of 
Proposed Rulemaking and Order, 27 FCC Rcd 1745 (2012).  Specifically, the Commission proposed to issue 
geographic-area “Overlay Licenses” through competitive bidding in two stages.  Id. at 1746, para. 2. 
19
Id. at 1771-74, paras. 67-75.  The Commission defined “Covered Blocks” to be those Blocks preliminarily 
determined to be “Substantially Licensed” and those preliminarily determined to be more than 90% but less than 
95% licensed.  Id. at 1772-73, para. 69. 
           Federal Communications Commission DA 13-1998
5
terminate the Investigation.  In consideration for the termination of the Investigation, AT&T Mobility 
agrees to the terms, conditions, and procedures contained herein.  The Bureau further agrees that in the 
absence of new material evidence, the Bureau will not use the facts developed in the Investigation 
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 Mobility 
concerning the matters that were the subject of the Investigation.  The Bureau also agrees that in the 
absence of new material evidence it will not use the facts developed in the Investigation through the 
Effective Date, 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 AT&T Mobility with respect to AT&T 
Mobility’s basic qualifications, including its character qualifications, to be a Commission licensee or to 
hold Commission licenses or authorizations.
10. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, AT&T 
Mobility shall designate a senior corporate manager with the requisite corporate and organizational 
authority to serve as Compliance Officer and to discharge the duties set forth below.  The Compliance 
Officer shall be responsible for developing, implementing, and administering the compliance procedures, 
detailed below, that AT&T must implement to ensure compliance with the terms and conditions of this 
Consent Decree.  In addition to the general knowledge of the Communications Laws necessary to 
discharge his/her duties under this Consent Decree, the Compliance Officer shall have specific knowledge 
of the CGSA Modification Rules prior to assuming his/her duties.
11. Compliance Plan.  For purposes of settling the matters set forth herein and based on the 
circumstances presented in this case (including the Commission’s pending rulemaking proceeding in WT 
Docket No. 12-40
20
), AT&T Mobility agrees that it shall within sixty (60) calendar days after the 
Effective Date, develop and implement a Compliance Plan designed to ensure future compliance with the 
Communications Laws and with the terms and conditions of this Consent Decree.
21
  With respect to the 
CGSA Modification Rules, AT&T Mobility shall implement the following procedures:
(a) Operating Procedures and Compliance Manual.  Within sixty (60) calendar 
days after the Effective Date, AT&T Mobility shall review and augment its 
existing Operating Procedures pertaining to compliance with the CGSA 
Modification Rules.
22
  AT&T Mobility’s Operating Procedures shall explain the 
CGSA Modification Rules and set forth the procedures that all Covered 
Employees must follow to help ensure AT&T Mobility’s compliance with the 
CGSA Modification Rules, which shall include internal procedures and policies
specifically designed to ensure that all applications and notifications filed by 
AT&T Mobility with respect to the modification of a CGSA are timely filed in 
accordance with the CGSA Modification Rules.  AT&T Mobility shall distribute 
                                                
20
See supra note 18.
21
AT&T Mobility represents that it has comprehensive organizational structures, plans, and procedures in place that 
are intended to ensure compliance with the Communications Laws.  See, e.g., AT&T, Inc., Order, 28 FCC Rcd 5994, 
6000-04, paras. 11-14 (Enf. Bur. 2013) (re: Telecommunications Relay Services and TRS Fund); AT&T, Inc., Order, 
27 FCC Rcd 13492, 13496-501, paras. 10-16 (Enf. Bur. 2012) (re: 47 U.S.C. §§ 201(b), 202(a) (re: truth-in-billing); 
AT&T, Inc., Order, 26 FCC Rcd 3332, 3336-37, para. 8 (Enf. Bur. 2011) (re: network outage reporting); AT&T, 
Inc., 25 FCC Rcd 16196, 16201-03, para. 10 (re: CPNI).  This Consent Decree does not require new organizational 
structures, plans, or procedures except as necessary to implement paragraphs 10-13 of this Consent Decree.
22
AT&T Mobility represents that it maintains written Operating Procedures (which serve as a Compliance Manual) 
on the CGSA Modification Rules and that these documents provide guidance on standard operating procedures with 
which Covered Employees must comply, include a detailed explanation of AT&T’s obligations under the CGSA 
Modification Rules, and outline general principles of business conduct in connection with AT&T’s compliance with 
these rules.
           Federal Communications Commission DA 13-1998
6
the Operating Procedures to all Covered Employees within sixty (60) calendar 
days after the Effective Date.  AT&T Mobility shall periodically review and 
revise its Operating Procedures as necessary to ensure that the information set 
forth therein remains current and complete, and shall distribute any revisions to 
the Operating Procedures promptly to all Covered Employees.
(b) Compliance Training.  AT&T Mobility shall establish and implement a 
Compliance Training Program on compliance with the CGSA Modification 
Rules and the Operating Procedures.  As part of the Compliance Training 
Program, Covered Employees shall be advised of AT&T Mobility’s obligation to 
report noncompliance under paragraph 12 of this Consent Decree and shall be 
instructed on how to disclose noncompliance to the Compliance Officer.  All 
Covered Employees shall be trained pursuant to the Compliance Training 
Program within sixty (60) calendar days after the Effective Date, except that any 
person who becomes a Covered Employee at any time after the Effective Date 
shall be trained within thirty (30) calendar days after the date such person 
becomes a Covered Employee. AT&T Mobility shall repeat the compliance 
training on an annual basis, and shall periodically review and revise the 
Compliance Training Program as necessary to ensure that it remains current and 
complete and to enhance its effectiveness.
12. Reporting Noncompliance.  AT&T Mobility shall report any noncompliance with the 
CGSA Modification Rules and with the terms and conditions of this Consent Decree within fifteen (15) 
calendar days after the discovery of such noncompliance.  Such reports shall include a detailed 
explanation of: (i) each instance of noncompliance; (ii) the steps that AT&T Mobility has taken or will 
take to remedy such noncompliance; (iii) the schedule on which such remedial actions will be taken; and 
(iv) the steps that AT&T Mobility has taken or will take to prevent the recurrence of any such 
noncompliance.  All such reports of noncompliance shall be submitted to the Chief, Spectrum 
Enforcement Division, Enforcement Bureau, Federal Communications Commission, 445 12
th
Street, 
S.W., Room 3-C366, Washington, DC 20554, with a copy submitted electronically to Linda Nagel at 
Linda.Nagel@fcc.gov and to Ricardo Durham at Ricardo.Durham@fcc.gov.
13. Compliance Reports.  AT&T Mobility shall file compliance reports with the 
Commission ninety (90) days after the Effective Date, twelve (12) months after the Effective Date, and 
twenty-four (24) months after the Effective Date.
(a) Each compliance report shall include a detailed description of AT&T Mobility’s 
efforts during the relevant period to comply with the terms and conditions of the 
Consent Decree and the CGSA Modification Rules, including updates to or 
changes in the Operating Procedures designed to ensure future compliance with 
such rules.  In addition, each Compliance Report shall include a certification by 
the Compliance Officer, as agent of and on behalf of AT&T Mobility, stating that 
the Compliance Officer has personal knowledge that AT&T Mobility (i) has 
established and implemented the Compliance Plan; (ii) has utilized the Operating 
Procedures since the implementation of the Compliance Plan; and (iii) 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 12 
hereof. 
(b) 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 
           Federal Communications Commission DA 13-1998
7
the Rules
23
and be subscribed to as true under penalty of perjury in substantially 
the form set forth therein.
(c) If the Compliance Officer cannot provide the requisite certification, the 
Compliance Officer, as an agent of and on behalf of AT&T Mobility, shall 
provide the Commission with a detailed explanation of the reason(s) why and 
describe fully: (i) each instance of noncompliance; (ii) the steps that AT&T 
Mobility has taken or will take to remedy such noncompliance, including the 
schedule on which proposed remedial actions will be taken; and (iii) the steps 
that AT&T Mobility has taken or will take to prevent the recurrence of any such 
noncompliance, including the schedule on which such preventive action will be 
taken.
(d) All Compliance Reports shall be submitted to the Chief, Spectrum Enforcement 
Division, Enforcement Bureau, Federal Communications Commission, 445 12th 
Street, S.W., Room 3-C366, Washington, DC 20554, with a copy submitted 
electronically to Linda Nagel at Linda.Nagel@fcc.gov and to Ricardo Durham at 
Ricardo.Durham@fcc.gov.
14. Termination Date.  Unless stated otherwise, the obligations set forth in paragraphs 10 
through 13 of this Consent Decree shall expire twenty-four (24) months after the Effective Date.
15. 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 AT&T Mobility 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 complaints 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 AT&T Mobility with the 
Communications Laws.
16. Voluntary Contribution.  AT&T Mobility agrees that it will make a voluntary 
contribution to the United States Treasury in the amount of six hundred thousand dollars ($600,000)
within thirty (30) calendar days after the Effective Date.		AT&T Mobility shall also send electronic 
notification of payment to Linda Nagel at Linda.Nagel@fcc.gov, Ricardo Durham at 
Ricardo.Durham@fcc.gov, and to Samantha Peoples at Sam.Peoples@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 Advice) must be submitted.
24
  When completing the FCC Form 
159, enter the Account Number in block number 23A and enter the letters “FORF” in block number 24A 
(payment type code).  Below are additional instructions that AT&T Mobility should follow based on the 
form of payment it selects:
? 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.
                                                
23
47 C.F.R. § 1.16.
24
An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
           Federal Communications Commission DA 13-1998
8
? 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 AT&T Mobility has questions regarding payment procedures, it should contact the Financial 
Operations Group Help Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.      
17. Waivers.  AT&T Mobility 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.  AT&T Mobility shall retain the right to challenge Commission interpretation of the Consent 
Decree or any terms contained herein.  If any Party (or the United States on behalf of the Commission) 
brings a judicial action to enforce the terms of the Adopting Order, AT&T Mobility and the Commission 
shall not contest the validity of the Consent Decree or of the Adopting Order, and AT&T Mobility shall 
waive any statutory right to a trial de novo.  AT&T Mobility hereby agrees to waive any claims it may 
have under the Equal Access to Justice Act
25
relating to the matters addressed in this Consent Decree.  
18. 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.  
19. 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 AT&T Mobility does not 
expressly consent), that provision will be superseded by such Rule or Commission order.
20. Successors and Assigns.  AT&T Mobility agrees that the provisions of this Consent 
Decree shall be binding on its successors, assigns, and transferees. 
21. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.  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 Communications Laws.  
22. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
23. 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.
                                                
25
Equal Access to Justice Act, Pub L. No. 96-481, 94 Stat. 2325 (1980) (codified at 5 U.S.C. § 504); see also
47 C.F.R. §§ 1.1501-1.1530.
           Federal Communications Commission DA 13-1998
9
24. Authorized Representative.  The individual signing this Consent Decree on behalf of 
AT&T Mobility represents and warrants that she is authorized by AT&T Mobility to execute this Consent 
Decree and to bind AT&T Mobility to the obligations set forth herein.  The FCC signatory represents that 
he is signing this Consent Decree in his official capacity and that he is authorized to execute this Consent 
Decree.
25. 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. 
____________________________
Robert H. Ratcliffe
Acting Chief
Enforcement Bureau
____________________________
Date
____________________________
Teri Lindsay
Vice President - Global Engineering Support
AT&T Services, Inc.
____________________________
Date