Federal Communications Commission DA 13-785
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Teleplus, LLC
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)
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File No.:  EB-08-IH-5217
Acct. No.:  200932080046
FRN:  0014157283
ORDER
Adopted:  May 6, 2013                      Released:  May 6, 2013
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 Teleplus, LLC 
(Teleplus).  The Consent Decree terminates and resolves an investigation by the Bureau into whether 
Teleplus violated Section 214 of the Communications Act of 1934, as amended (Act), and Section 63.18 
of the Commission’s rules (Rules) by failing to apply for and obtain an international Section 214 
authorization before providing international telecommunications service.
1
2. A copy of the Consent Decree negotiated by the Bureau and Teleplus, which includes a 
three-year compliance plan requirement, 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 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 the 
investigation raises no substantial or material questions of fact as to whether Teleplus 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,
2
and Sections 0.111 and 0.311 of the Rules,
3
the Consent Decree attached to this Order IS 
ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigation IS 
TERMINATED.
                                                
1
47 U.S.C. § 214; 47 C.F.R. § 63.18.
2
47 U.S.C. §§ 154(i), 154(j), 503(b).
3
47 C.F.R. §§ 0.111, 0.311.
Federal Communications Commission DA 13-785
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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 Glenn B. Manishin, Counsel for 
Teleplus, LLC, Troutman Sanders, LLP, 401 9th Street, N.W., Suite 1000, Washington, D.C. 20004-
2134.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau 
Federal Communications Commission DA 13-785
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Teleplus, LLC
)
)
)
)
)
File No.:  EB-08-IH-5217
Acct. No.:  200932080046
FRN:  0014157283
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and Teleplus, 
LLC, by their authorized representatives, hereby enter into this Consent Decree for the purpose of 
terminating the Enforcement Bureau’s investigation into whether Teleplus violated Section 214 of the 
Communications Act of 1934, as amended,
1
and Section 63.18 of the Commission’s rules,
2
by willfully or 
repeatedly failing to apply for and obtain international Section 214 authorization before providing 
international telecommunications service.
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.
(b) “Adopting Order” means an Order of the Bureau adopting the terms of this Consent 
Decree without change, addition, deletion, or modification.
(c) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(d) “Commission” and “FCC” mean the Federal Communications Commission and all of 
its bureaus and offices.
(e) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which Teleplus is 
subject by virtue of its business activities, including but not limited to the Section 214 
Rules.
(f) “Compliance Plan” means the compliance obligations, programs, and procedures 
described in this Consent Decree at paragraph 13.
(g) “Covered Employees” means all employees and agents of Teleplus who perform, or 
supervise, oversee, or manage the performance of, duties that relate to Teleplus’s 
responsibilities under the Section 214 Rules.
(h) “Effective Date” means the date on which the Bureau releases the Adopting Order.
                                                
1
47 C.F.R. § 214.
2
47 C.F.R. § 63.18.
Federal Communications Commission DA 13-785
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(i) “Investigation” means the investigation initiated by the Bureau in File No.
EB-08-IH-5217 regarding possible violations of the Section 214 Rules.
(j) “Operating Procedures” means the standard, internal operating procedures and 
compliance policies established by Teleplus to implement the Compliance Plan.
(k) “Parties” means Teleplus, LLC and the Bureau, each of which is a “Party.”
(l) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
(m) “Section 214 Rules” means Section 214 of the Act and other Communications Laws 
governing the construction, acquisition, operation, or transmission of lines of 
communication, including any Rules implementing Section 214 and any related 
Commission orders.
(n) “Teleplus” or “Company” means Teleplus, LLC and its affiliates, subsidiaries, 
predecessors-in-interest, and successors-in-interest.
II. BACKGROUND
3. Section 214(a) of the Act prohibits any carrier from constructing, extending, acquiring, or 
operating any line, or engaging in transmission through any such line, without first obtaining a certificate 
of authorization from the Commission.
3
  While the Commission has granted “blanket” Section 214 
authority to carriers providing domestic service,
4
meaning that such carriers need not apply to the 
Commission before providing domestic service, the Commission has not done the same for providers of 
international telecommunications services.
5
4. Section 63.18 of the Rules requires any carrier that seeks Section 214 authority “for 
provision of common carrier communication services between the United States, its territories or 
possessions, and a foreign point” to request such authority by application.
6
  This application requirement 
applies to carriers that resell the international services of another authorized carrier, as well as to 
facilities-based international service providers.
7
  The applicant must provide the Commission with, among 
other items, contact information, ownership information, information on any affiliations the applicant 
may have with foreign carriers, certification that it will comply with the Rules, and certification that the 
                                                
3
47 U.S.C. § 214(a).
4
47 C.F.R. § 63.01(a) (“Any party that would be a domestic interstate communications common carrier is 
authorized to provide domestic, interstate services to any domestic point and to construct or operate any domestic 
transmission line as long as it obtains all necessary authorizations from the Commission for use of radio 
frequencies.”).
5
Implementation of Section 402(b)(2)(A) of the Telecomm. Act of 1996, Report and Order in CC Docket No. 97-11, 
Second Memorandum Opinion & Order in AAD File No. 98-43, 14 FCC Rcd 11364, para. 2 & n.8 (1999) (grant of 
blanket authority is only for domestic interstate services and does not extend to the provision of international 
services).
6
47 C.F.R. § 63.18.
7
Id. § 63.18(e)(1)-(2); see Start Wireless Group, Inc. d/b/a/ Page Plus Cellular, Notice of Apparent Liability for 
Forfeiture, 27 FCC Rcd 350 (Enf. Bur. 2012).
Federal Communications Commission DA 13-785
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applicant is not subject to denial of Federal benefits pursuant to the Anti-Drug Abuse Act of 1988.
8
  
Section 63.18(e)(2) establishes specific requirements for parties “applying for authority to resell the 
international services of authorized common carriers,” and Section 63.23 of the Rules, in turn, identifies 
the conditions that apply to “carriers authorized to resell the international services of other authorized 
carriers.”
9
5. Teleplus is a Florida-based company that has provided international telecommunications 
services since May 2005.
10
  Teleplus provides prepaid calling cards that are mainly used by consumers to 
make U.S. interstate, intrastate, and international telephone calls.
11
  Teleplus sells its prepaid calling cards 
directly to consumers through the www.callingcardplus.com web site, as well as through distributors and 
resellers.
12
6. On February 17, 2006, Teleplus submitted an application for international Section 214 
authority in which it stated that it had not previously received authority under Section 214 of the Act.
13
  
Because Teleplus was owned by foreign nationals, the application was referred to the Executive Branch 
for review for national security, law enforcement, foreign policy, and trade concerns.
14
  On June 19, 2008, 
after the conclusion of the Executive Branch review, the International Bureau granted Teleplus’s Section 
214 application without prejudice to subsequent enforcement action by the Commission for non-
compliance with the Act or the Rules.
15
Thereafter, the matter was referred to the Bureau, which 
commenced its investigation.
7. On March 30, 2009, the Bureau issued a Letter of Inquiry (LOI) regarding the matters 
recited above.
16
  Teleplus responded to the LOI on April 10, 2009.
17
  On June 4, 2009, the Bureau issued 
a Notice of Apparent Liability (NAL) to Teleplus for failing to obtain an international Section 214 
authorization before providing international telecommunications service.
18
  Teleplus responded to the 
                                                
8
47 C.F.R. § 63.18(e)(1)-(2).
9
47 C.F.R. §§ 63.18(e)(2), 63.23.
10
See Teleplus, LLC, Notice of Apparent Liability for Forfeiture, 24 FCC Rcd 7666, 7667, para. 3 (Enf. Bur. 2009) 
(NAL) (citing Response of Teleplus, LLC to the Enforcement Bureau’s March 30, 2009, Letter of Inquiry, Response 
to Inquiry No. 6 (Apr. 10, 2009)).
11
See NAL, 24 FCC Rcd at 7667, para. 3.
12
See E-mail from Anteneh “Alonzo” T. Beyene, Regulatory Consultant to Teleplus, Regnum Group, Inc., to 
Jennifer Rockoff, National Security Division, U.S. Department of Justice and Mikelle Morra, International Bureau, 
FCC (May 15, 2008) (on file in EB-08-IH-5217); see also http://www.callingcardplus.com (last visited 
Mar. 18, 2013).
13
See Teleplus Application for FCC 214 Authority, IBFS Application No. ITC-214-20060217-00099.
14
See Rules and Policies on Foreign Participation in the U.S. Telecommunications Market, Report and Order and 
Order on Reconsideration, 12 FCC Rcd 23891, 23919–21, paras. 61–66 (1997), Order on Reconsideration, 
15 FCC Rcd 18158 (2000).
15
See International Authorizations Granted, Public Notice, Rep. No. TEL-01280, DA No. 08-1441 (rel. June 19,
2008).
16
See Letter from Trent B. Harkrader, Deputy Chief, Investigations & Hearings Division, Enforcement Bureau, 
FCC, to Amr Ibrahim, Chief Executive Officer, Teleplus, LLC (Mar. 30, 2009) (LOI).
17
Response of Teleplus, LLC to the Enforcement Bureau’s March 30, 2009, Letter of Inquiry (Apr. 10, 2009).
18
See NAL, 24 FCC Rcd at 7666.
Federal Communications Commission DA 13-785
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NAL on January 11, 2010,
19
and supplemented its response on March 8, 2013.
20
  The Parties thereafter 
entered into settlement discussions.
III. TERMS OF AGREEMENT
8. 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.
9. Jurisdiction.  Teleplus 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.
10. 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.
11. 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 
terminate the Investigation.  In consideration for termination of the investigation, Teleplus 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 this 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 Teleplus 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 this 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 Teleplus with respect to Teleplus’s basic qualifications, including its character 
qualifications, to be a Commission licensee or hold Commission licenses or authorizations.
12. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, Teleplus 
shall designate a senior corporate manager with the requisite corporate and organizational authority to 
serve as a Compliance Officer and to discharge the duties set forth below.  The person designated as the 
Compliance Officer shall be responsible for developing, implementing, and administering the Compliance 
Plan and ensuring that Teleplus complies with the terms and conditions of the Compliance Plan and 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 Section 214 Rules prior to assuming his/her duties.
13. Compliance Plan.  For purposes of settling the matters set forth herein, Teleplus 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 
                                                
19
Letter from Glenn B. Manishin, Counsel for Teleplus, LLC to Marlene H. Dortch, Secretary, Federal 
Communications Commission (Jan. 6, 2010) (on file in EB-08-IH-5217).
20
Letter from Glenn B. Manishin, Counsel for Teleplus, LLC to Joy Ragsdale, Attorney, Federal Communications 
Commission (Mar. 8, 2013) (on file in EB-08-IH-5217).
Federal Communications Commission DA 13-785
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terms and conditions of this Consent Decree.  With respect to the Section 214 Rules, Teleplus shall 
implement the following procedures:
(a) Operating Procedures.  Within sixty (60) calendar days after the Effective Date, 
Teleplus shall establish Operating Procedures that all Covered Employees must follow 
to help ensure Teleplus’s compliance with the Section 214 Rules.  In addition to 
implementing the required policies and procedures in Section 63.18 of the Rules, 
Teleplus’s Operating Procedures shall include internal procedures and policies 
specifically designed to ensure that Teleplus complies with the Section 214 Rules.  
Teleplus shall also develop a Compliance Checklist that describes the steps a Covered 
Employee must follow to ensure compliance with the Section 214 Rules.
(b) Compliance Manual.  Within sixty (60) calendar days after the Effective Date, the 
Compliance Officer shall develop and distribute a Compliance Manual to all Covered 
Employees.  The Compliance Manual shall explain the Section 214 Rules, and set forth 
the Operating Procedures that Covered Employees shall follow to help ensure 
Teleplus’s compliance with the Section 214 Rules.  Teleplus shall periodically review 
and revise the Compliance Manual as necessary to ensure that the information set forth 
therein remains current and accurate.  Teleplus shall distribute any revisions to the 
Compliance Manual promptly to Covered Employees.  
(c) Compliance Training Program.  Teleplus shall establish and implement a 
Compliance Training Program on compliance with the Section 214 Rules and the 
Operating Procedures.  As part of the Compliance Training Program, Covered 
Employees shall be advised of Teleplus’s obligation to report any noncompliance with 
the Section 214 Rules under paragraph 14 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.  Any person who becomes a Covered 
Employee at any time after the initial Compliance Training Program shall be trained 
within thirty (30) calendar days after the date such person becomes a Covered 
Employee.  Teleplus 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.
14. Reporting Noncompliance.  Teleplus shall report any noncompliance with the Section 
214 Rules and with the terms and conditions of this Consent Decree within fifteen (15) calendar days 
after discovery of such noncompliance.  Such reports shall include a detailed explanation of (i) each 
instance of noncompliance; (ii) the steps that Teleplus 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 
Teleplus has taken or will take to prevent the recurrence of any such noncompliance.  All reports of 
noncompliance shall be submitted to the Chief, Investigations and Hearings Division, Enforcement 
Bureau, Federal Communications Commission, Room 3-C330, 445 12th Street, S.W. Washington, D.C. 
20554, with a copy submitted electronically to Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov, 
William A. Kehoe at William.Kehoe@fcc.gov, and Joy M. Ragsdale at Joy.Ragsdale@fcc.gov.
15. Compliance Reports.  Teleplus shall file compliance reports with the Commission 
ninety (90) calendar days after the Effective Date, twelve (12) months after the Effective Date, twenty-
four (24) months after the Effective Date, and thirty-six (36) months after the Effective Date.
(a) Each Compliance Report shall include a detailed description of Teleplus’s efforts 
during the relevant period to comply with the terms and conditions of this Consent 
Federal Communications Commission DA 13-785
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Decree and the Section 214 Rules.  In addition, each Compliance Report shall include 
a certification by the Compliance Officer, as an agent of and on behalf of Teleplus, 
stating that the Compliance Officer has personal knowledge that Teleplus (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 14 of this Consent 
Decree.
(b) The Compliance Officer’s certification shall be accompanied by a statement 
explaining the basis for such certification and shall 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.
21
(c) If the Compliance Officer cannot provide the requisite certification, the Compliance 
Officer, as an agent of and on behalf of Teleplus, 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 Teleplus 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 Teleplus 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, Investigations & Hearings 
Division, Enforcement Bureau, Federal Communications Commission, Room
4-C330, 445 12th Street, S.W., Washington, D.C. 20554, with a copy submitted 
electronically to Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov, William A.
Kehoe at William.Kehoe@fcc.gov, and Joy M. Ragsdale at Joy.Ragsdale@fcc.gov.
16. Termination Date.  Unless stated otherwise, the obligations set forth in paragraphs 12 
through 15 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.
17. 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
22
against Teleplus 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 Teleplus with the Communications 
Laws.
18. Voluntary Contribution.  Teleplus agrees that it will make a voluntary contribution to 
the United States Treasury in the aggregate amount of Eighty Thousand dollars ($80,000) (Voluntary 
Contribution).
(a) Such Voluntary Contribution shall be made in installments (each an Installment 
Payment).  The first Installment Payment in the amount of Ten Thousand dollars 
                                                
21
47 C.F.R. § 1.16.
22
47 U.S.C. § 208.
Federal Communications Commission DA 13-785
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($10,000) is due within thirty (30) calendar days after the Effective Date.  The 
balance of the Voluntary Contribution will be made in eight payments of Eight 
Thousand, Seven Hundred Fifty dollars ($8,750), payable on August 30, 2013, 
November 30, 2013, February 28, 2014, May 30, 2014, August 30, 2014, November 
30, 2014, February 28, 2015, with the final payment due on April 30, 2015 (Maturity 
Date).  Teleplus acknowledges and agrees that upon execution of this Consent 
Decree, the Voluntary Contribution and each Installment Payment shall become a 
“Claim” or “Debt” as defined in 31 U.S.C. § 3701(b)(1).
23
Upon an Event of Default 
(as defined below), all procedures for collection as permitted by law may, at the 
Commission’s discretion, be initiated.  In addition, Teleplus agrees that it will make 
the first and all subsequent Installment Payments in United States Dollars without 
further demand or notice by the dates specified above.  Teleplus shall also send 
electronic notification of payment to Theresa Z. Cavanaugh at 
Terry.Cavanaugh@fcc.gov, William A. Kehoe at William.Kehoe@fcc.gov, and 
Joy M. Ragsdale at Joy.Ragsdale@fcc.gov on the date said Installment Payment is 
made.  
19. Installment Payments must be made by check or similar instrument, wire transfer, or 
credit card, and must include the 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 (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.
                                                
23
Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 1358 (Apr. 26, 1996).
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 13-785
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20. Event of Default.  Teleplus agrees that an Event of Default shall occur upon the failure 
by Teleplus to pay the full amount of any Installment Payment on or before the due date specified in this 
Consent Decree.
21. Interest, Charges for Collection, and Acceleration of Maturity Date.  After an Event 
of Default has occurred under this Consent Decree, the then unpaid amount of the Voluntary 
Contribution shall accrue interest, computed using the U.S. Prime Rate in effect on the date of the Event 
of Default plus 4.75 percent, from the date of the Event of Default until payment in full.  Upon an Event 
of Default, the then unpaid amount of the Voluntary Contribution, together with interest, as aforesaid, 
any penalties permitted and/or required by the law, including but not limited to 31 U.S.C. § 3717 and 
administrative charge(s), plus the costs of collection, litigation, and attorneys’ fees, shall become 
immediately due and payable, without notice, presentment, demand, protest, or notice of protest of any 
kind, all of which are waived by Teleplus.
22. Waivers.  Teleplus 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 the Adopting Order as defined 
herein.  Teleplus 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 Teleplus nor the Commission shall 
contest the validity of the Consent Decree or the Adopting Order, and Teleplus shall waive any statutory 
right to a trial de novo.  Teleplus hereby agrees to waive any claims it may otherwise have under the 
Equal Access to Justice Act,
25
relating to the matters addressed in this Consent Decree.
23. 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.
24. 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 Teleplus does not expressly 
consent) that provision will be superseded by such Rule or Commission order.
25. Successors and Assigns.  Teleplus agrees that the provisions of this Consent Decree 
shall be binding on its successors, assigns, and transferees.
26. 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.
27. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
28. 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
See 5 U.S.C. § 504; 47 C.F.R. Part 1, Subpart K.
Federal Communications Commission DA 13-785
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29. Authorized Representative.  The individual signing this Consent Decree on behalf of 
Teleplus represents and warrants that he is authorized by Teleplus to execute this Consent Decree and to 
bind Teleplus 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.
30. 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.
________________________________
P. Michele Ellison
Chief
Enforcement Bureau 
________________________________
Date
________________________________
Mohamed Abdelmeguid
Managing Partner
Teleplus, LLC
________________________________
Date