Federal Communications Commission DA 14-679
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
MATRIX TELECOM, INC.
)
)
)
)
)
File No.:  EB-IHD-13-00011204
1
Acct. No.:  201432080032
FRN:  0004333068
ORDER
Adopted:  June 4, 2014 Released:  June 4, 2014
By the Acting Chief, Enforcement Bureau:
1. In this Order and Consent Decree, we settle allegations that Matrix Telecom, Inc. (Matrix 
or Company) violated federal laws by failing to complete long-distance calls to rural areas on a just, 
reasonable, and non-discriminatory basis.  These laws operate to ensure  that long-distance calls to rural 
destinations, whether business or residential in nature, are completed as dialed, without undue delay, and 
with all attendant information (e.g., Caller ID) intact, just as such calls are completed to non-rural areas of 
the nation.  In this case, the Commission’s Rural Call Completion Task Force received and investigated 
information that the Company failed to ensure adequate long-distance call completion to rural areas for its 
retail and wholesale customers.  For purposes of the settlement, Matrix will pay $875,000 to resolve the 
allegations and implement a three-year compliance plan.
2. In this Order, we adopt the Consent Decree entered into between the Enforcement Bureau 
(Bureau) and Matrix.  The Consent Decree resolves and terminates the Bureau’s investigation into 
whether Matrix violated Sections 201(b) and 202(a) of the Communications Act of 1934, as amended 
(Act),
2
with respect to its call completion practices to rural areas, including its use and oversight of 
intermediate providers (entities used by Matrix to route calls to specified destinations) for call completion 
purposes. 
3. A copy of the Consent Decree negotiated by the Bureau and Matrix is attached to this 
Order and is incorporated herein by reference.
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 the Company possesses the 
basic qualifications, including those related to character, to hold or obtain any Commission license or 
authorization.
5. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest will be served by adopting the Consent Decree and terminating the 
investigation.
                                                     
1
This investigation was initiated under File No. EB-13-IH-0282 and subsequently assigned File No. EB-IHD-13-
00011204.
2
See 47 U.S.C. §§ 201(b), 202(a); see also Developing an Unified Intercarrier Compensation Regime, Declaratory 
Ruling, 27 FCC Rcd 1351 (Wireline Comp. Bur. 2012) (Rural Call Completion Declaratory Ruling).  
Federal Communications Commission DA 14-679
2
6. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i), 4(j), and 503(b) of the 
Act,
3
and Sections 0.111 and 0.311 of the Rules,
4
the Consent Decree attached to this Order IS 
ADOPTED.
7. IT IS FURTHER ORDERED that the above-captioned investigation IS 
TERMINATED.
8. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by both First Class U.S. Mail and Certified Mail to Bob Beaty, CEO, Matrix Telecom, Inc., 433 E. 
Las Colinas Boulevard, Irving, Texas 75039.
FEDERAL COMMUNICATIONS COMMISSION
Travis LeBlanc
Acting Chief, Enforcement Bureau
                                                     
3
See 47 U.S.C. §§ 154(i), 154(j), 503(b).
4
See 47 C.F.R. §§ 0.111, 0.311.
Federal Communications Commission DA 14-679
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
MATRIX TELECOM, INC.
)
)
)
)
)
File No.:  EB-IHD-13-00011204
1
Acct. No.:  201432080032
FRN:  0004333068
CONSENT DECREE
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission and 
Matrix Telecom, Inc. (Matrix or Company), by their authorized representatives, hereby enter into this 
Consent Decree for the purpose of terminating the Bureau’s investigation into possible violations of 
Sections 201(b) and 202(a) of the Communications Act of 1934, as amended (Act),
2
with respect to
Matrix’s call completion practices to rural areas, including its use and oversight of Intermediate 
Providers.  
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 the Company is
subject by virtue of its business activities.
(f) “Compliance Plan” means the compliance obligations, program, and procedures
described in this Consent Decree at paragraph 17.
(g) “Covered Employees” means all employees and agents of the Company who 
supervise, oversee, or manage the performance of, duties that relate to the 
Company’s responsibilities under this Consent Decree, Sections 201(b) and 202(a) 
of the Act, as interpreted in the Rural Call Completion Declaratory Ruling, and the 
rules adopted in the Rural Call Completion Order.
3
                                                     
1
This investigation was initiated under File No. EB-13-IH-0282 and subsequently assigned File No. EB-IHD-13-
00011204.
2
See 47 U.S.C. §§ 201(b), 202(a); see also Developing an Unified Intercarrier Compensation Regime, Declaratory 
Ruling, 27 FCC Rcd 1351 (Wireline Comp. Bur. 2012) (Rural Call Completion Declaratory Ruling).  
3
Rural Call Completion, Report and Order and Further Notice of Proposed Rulemaking, 28 FCC Rcd 16154 (2013) 
(Rural Call Completion Order).  
Federal Communications Commission DA 14-679
2
(h) “Effective Date” means the date on which the Bureau releases the Adopting Order.
(i) “Intermediate Provider” has the meaning provided in Section 64.1600(f) of the 
Rules,
4
but excludes a tandem provider to which the terminating carrier subtends or 
a carrier to which the terminating carrier requires an indirectly interconnecting 
carrier to deliver traffic.
(j) “Investigation” means the investigation commenced by the Bureau’s March 21, 2013 
Letter of Inquiry (LOI)
5
regarding Matrix’s possible violations of Sections 201(b)
and 202(a) of the Act.
(k) “Matrix” or “Company” means Matrix Telecom, Inc., including all of its subsidiaries, 
affiliates, predecessors-in-interest, and successors-in-interest.
(l) “Operating Procedures” means the standard, internal operating procedures and 
compliance policies established by the Company to implement the Compliance Plan.  
(m) “Parties” means Matrix and the Bureau, each of which is a “Party.”
(n) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
II. BACKGROUND
3. Section 201(b) of the Act provides, “[a]ll charges, practices, classifications, and 
regulations for and in connection with [interstate and foreign] communication service, shall be just and 
reasonable, and any such charge, practice, classification, or regulation that is unjust or unreasonable is 
hereby declared to be unlawful.”
6
  Section 202(a) states, “[i]t shall be unlawful for any common carrier to 
make any unjust or unreasonable discrimination in charges, practices, classifications, regulations, 
facilities, or services for or in connection with like communication service, directly or indirectly, by any 
means or device, . . . or to subject any particular person, class of persons, or locality to any undue or 
unreasonable prejudice or disadvantage.”
7
4. The Commission has emphasized that “it is vital that our Nation maintains a 
communications network that offers reliable and resilient service.”
8
  The Commission has also recognized 
that “permitting blocking or the refusal to deliver voice telephone traffic, whether as a means of ‘self-
help’ to address perceived unreasonable intercarrier compensation charges or otherwise, risks 
‘degradation of the country’s telecommunications network.’”
9
  To prevent that result, the Commission has 
                                                     
4
47 C.F.R. § 64.1600(f).
5
Letter from Theresa Cavanaugh, Chief, Investigations & Hearings Division, FCC Enforcement Bureau, to Jerry 
Ou, President and CEO, Matrix Telecom, Inc. (Mar. 21, 2013) (on file in EB-IHD-13-00011204).
6
47 U.S.C. § 201(b).  
7
Id. § 202(a).
8
Reliability and Continuity of Communications Networks, Including Broadband Technologies, Notice of Inquiry, 26 
FCC Rcd 5614, 5616, para. 5 (2011); see also Establishing Just and Reasonable Rates for Local Exchange Carriers, 
Declaratory Ruling and Order, 22 FCC Rcd 11629, para. 1 (Wireline Comp. Bur. 2007) (explaining that “the 
ubiquity and reliability of the nation’s telecommunications network is of paramount importance to the explicit goals 
of the Communications Act”) (Call Blocking Declaratory Ruling).  
9
Connect America Fund, Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 17663, 
18029, para. 973 (2011), pets. for review pending sub nom. In re: FCC 11-161, No. 11-9900 (10th Cir. filed Dec. 
2011) (quoting Access Charge Reform, Seventh Report and Order and Further Notice of Proposed Rulemaking, 16 
FCC Rcd 9923, 9933, para. 24 (2001)) (footnotes omitted).  
Federal Communications Commission DA 14-679
3
consistently held that telecommunications carriers, including interexchange carriers, generally may not 
“‘block, choke, reduce or restrict traffic in any way.’”
10
5. In June 2011, a coalition of trade associations representing rural rate-of-return incumbent 
local exchange carriers (LECs) sent a letter to the Bureau concerning “a nationwide and industry-wide 
epidemic” of calls to rural LEC service areas failing to complete or having poor call quality.
11
  In 
September 2011, the Commission announced that it had created a Rural Call Completion Task Force “to 
investigate and address the growing problem of calls to rural customers that are being delayed or that fail 
to connect.”
12
  
6. On February 6, 2012, the Commission’s Wireline Competition Bureau (WCB) clarified 
in the Rural Call Completion Declaratory Ruling that “it is an unjust and unreasonable practice in 
violation of section 201 of the Act for a carrier that knows or should know that it is providing degraded 
service to certain areas to fail to correct the problem or to fail to ensure that intermediate providers, least-
cost routers, or other entities acting for or employed by the carrier are performing adequately.”
13
  Thus, 
for example, “if carriers continue to hand off calls to agents, intermediate providers, or others that a 
carrier knows are not completing a reasonable percentage of calls or are otherwise restricting traffic . . ., 
that is an unjust or unreasonable practice prohibited by section 201 of the Act.”
14
  WCB further clarified 
that “adopting or perpetuating routing practices that result in lower quality service to rural or high-cost 
localities than like service to urban or lower cost localities (including other lower cost rural areas) may, in 
the absence of a persuasive explanation, constitute unjust or unreasonable discrimination in practices, 
facilities, or services and violate section 202 of the Act.”
15
7. Matrix offers retail telecommunications services to retail and business customers 
throughout the United States, and it offers wholesale service to other service providers, including long-
distance providers.  Calls delivered to Matrix by its wholesale customers account for a substantial 
majority of the interstate long-distance traffic carried by the Company.  
8. The Bureau initiated an investigation of Matrix (and companies Matrix had acquired, 
including Excel Telecommunications and Vartec Telecom) based on allegations and information 
concerning the Company’s performance in completing long-distance calls to rural areas.  The Bureau 
represents that this material included allegations and information from consumers and from rural carriers,
responses by long-distance providers to complaints served by the Commission’s Rural Call Completion 
Task Force, and performance data from carriers that used Matrix as an Intermediate Provider.
16
  On 
                                                     
10
Id. at 17903, para. 734 (quoting Call Blocking Declaratory Ruling, 22 FCC Rcd at 11631, para. 6).  The 
Commission has permitted call blocking “only under rare and limited circumstances.”  See Call Blocking 
Declaratory Ruling, 22 FCC Rcd at 11631, para. 6 n.20.  
11
Letter from Michael Romano, National Telecommunications Cooperative Association, et al., to Theresa Z. 
Cavanaugh, Acting Chief, Investigations & Hearings Division, FCC Enforcement Bureau, and Margaret Dailey, 
Attorney Advisor, Investigations & Hearings Division, FCC Enforcement Bureau at 3 (June 13, 2011).  
12
FCC Launches Rural Call Completion Task Force to Address Call Routing and Termination Problems in Rural 
America, News Release, 2011 WL 4454097 (Sept. 26, 2011), available at http://www.fcc.gov/document/fcc-
launches-rural-call-completion-task-force-sets-oct-18-workshop.  The Task Force conducted a workshop on rural 
call completion issues on October 18, 2011.  See http://www.fcc.gov/events/rural-call-completion-workshop.  
13
See Rural Call Completion Declaratory Ruling, 27 FCC Rcd at 1355–56, para. 12 (footnote omitted).  
14
Id.
15
Id. at 1357–58, para. 14. 
16
The Bureau forwarded one consumer inquiry regarding rural call completion to the Company, and the Company 
responded to that inquiry. See Letter from James Lister, Birch Horton Bittner & Cherot, to Marlene Dortch, 
(continued….)
Federal Communications Commission DA 14-679
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March 21, 2013, the Bureau issued an LOI to Matrix seeking information about its performance, and the 
performance of its Intermediate Providers, in completing long-distance calls.
17
  
9. Pursuant to an agreement with the Bureau,
18
on May 20, 2013, Matrix submitted narrative 
responses to most of the questions in the LOI and produced relevant documents.
19
  On June 20, 2013, 
Matrix responded to the remaining questions in the LOI and produced call answer data for specified one 
week samples covering six months between 2012 and 2013.
20
  Matrix provided multiple supplemental 
responses to the LOI and additional material from July through November 2013, and it cooperated fully 
with the Investigation.
21
10. In the months immediately following its receipt of the LOI, Matrix significantly reduced 
the number of Intermediate Providers it used to deliver long-distance calls to rural areas.  As a result of 
those routing changes, Matrix’s call completion performance to rural areas substantially improved.  Also, 
after it received the LOI, Matrix made significant investments to upgrade its network and related 
operations to improve rural call completion performance.
11. On November 8, 2013, the Commission released the Rural Call Completion Order, 
which adopted rules requiring covered providers to record, retain, and report to the Commission call 
answer rates for long-distance calls.
22
  The Commission found that “rural call completion problems are 
serious and widespread,”
23
and that “[t]hese failures have significant and immediate public interest 
ramifications, causing rural businesses to lose customers, cutting families off from their relatives in rural 
areas, and creating potential for dangerous delays in public safety communications in rural areas.”
24
  The 
new rules require “covered providers”
25
to record and retain detailed information about long-distance calls 
(Continued from previous page)                                                            
Secretary, FCC (filed May 20, 2013 in EB-IHD-13-00011204).  The Bureau did not share other allegations and 
information with Matrix due to confidentiality concerns.
17
See supra n.5.
18
E-mail from Theodore Marcus, Attorney Advisor, Investigations & Hearings Division, FCC Enforcement Bureau, 
to Aurora Ares, Assistant General Counsel, Matrix Telecom, Inc. (Mar. 29, 2013, 13:34 EDT) (on file in EB-IHD-
13-00011204).
19
See Letter from James Lister, Birch Horton Bittner & Cherot, to Marlene Dortch, Secretary, FCC (filed May 20, 
2013 in EB-IHD-13-00011204).  
20
See Letter from James Lister, Birch Horton Bittner & Cherot, to Marlene Dortch, Secretary, FCC (filed June 20, 
2013 in EB-IHD-13-00011204).  
21
See Letter from James Lister, Birch Horton Bittner & Cherot, to Marlene Dortch, Secretary, FCC (filed July 11, 
2013 in EB-IHD-13-00011204); James Lister, Birch Horton Bittner & Cherot, to Marlene Dortch, Secretary, FCC 
(filed Aug. 8, 2013 in EB-IHD-13-00011204); James Lister, Birch Horton Bittner & Cherot, to Marlene Dortch, 
Secretary, FCC (filed Aug. 30, 2013 in EB-IHD-13-00011204); James Lister, Birch Horton Bittner & Cherot, to 
Marlene Dortch, Secretary, FCC (filed Sept. 10, 2013 in EB-IHD-13-00011204); James Lister, Birch Horton Bittner 
& Cherot, to Marlene Dortch, Secretary, FCC (filed Sept. 20, 2013 in EB-IHD-13-00011204); James Lister, Birch 
Horton Bittner & Cherot, to Marlene Dortch, Secretary, FCC (filed Nov. 1, 2013 in EB-IHD-13-00011204).  
22
See Rural Call Completion Order, 28 FCC Rcd at 16211–14, Appendix A.  
23
Id. at 16161, para. 14.  
24
Id. at 16155, para. 1.  
25
“Covered provider” means a “provider of long-distance voice service that makes the initial long-distance call path 
choice for more than 100,000 domestic retail subscriber lines.”  Id. at 16165, 16211, para. 20, Appendix A 
§ 64.2101(c).  
Federal Communications Commission DA 14-679
5
to customers of incumbent rural LECs,
26
as identified by Operating Company Numbers (OCNs).
27
  The 
rules also require covered providers to report to the Commission, on a quarterly basis, answer rates for 
long-distance calls delivered to each rural OCN and answer rates for long-distance calls delivered to non-
rural OCNs in the aggregate.
28
  The information collections required by the Rural Call Completion Order
will go into effect after the Office of Management and Budget approves the information collections and 
the Commission publishes a notice in the Federal Register announcing their effective date(s).
29
III. TERMS OF AGREEMENT
12. Adopting Order.  The Parties agree that the provisions of this Consent Decree shall be 
subject to final approval by the Bureau by incorporation of such provisions by reference in the Adopting 
Order.
13. Jurisdiction.  The Company 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.
14. 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.
15. 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 the termination of the Investigation, the Company 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 the Company 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 the Company with respect to the Company’s basic 
qualifications, including its character qualifications, to be a Commission licensee or hold Commission
licenses or authorizations.
                                                     
26
The Commission concluded that “the only call attempts that need to be retained are those to incumbent LECs that 
are rural telephone companies” because “rural call completion problems are largely confined to such carriers.”  Id. at 
16177–78, para. 49; see also 47 U.S.C. § 153(44).  
27
An OCN is an alphanumeric code that uniquely identifies providers of local telecommunications service.  See 
Alliance for Telecom. Industry Solutions, ATIS Telecom Glossary, available at
http://www.atis.org/glossary/definition.aspx?id=8448 (last visited May 13, 2014).  The Commission ordered the 
National Exchange Carrier Association, Inc. (NECA), which maintains lists of incumbent LEC OCNs, to update 
those lists annually.  See Rural Call Completion Order, 28 FCC Rcd at 16187–88, para. 73.  A list of incumbent 
rural LEC OCNs is available at
http://www.neca.org/WorkArea/linkit.aspx?LinkIdentifier=id&ItemID=8874&libID=8894 (last visited May 13, 
2014).  
28
Rural Call Completion Order, 28 FCC Rcd at 16184, para. 65.  
29
Id. at 16207, para. 131.  
Federal Communications Commission DA 14-679
6
16. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, the 
Company 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 the Company’s compliance 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 Sections 201(b) and 202(a) of the Act, as interpreted in the 
RuralCall Completion Declaratory Ruling, and the rules adopted in the Rural Call Completion Order
prior to assuming his/her duties. 
17. Compliance Plan.  For purposes of settling the matters set forth herein, the Company 
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 Sections 201(b) and 202(a) of the Act, as 
interpreted in the Rural Call Completion Declaratory Ruling, with the rules adopted in the Rural Call 
Completion Order,
30
and with the terms and conditions of this Consent Decree.  With respect to Sections
201(b) and 202(a) of the Act, as interpreted in the Rural Call Completion Declaratory Ruling, and the 
rules adopted in the Rural Call Completion Order, the Company shall implement the following 
procedures:
(a) Operating Procedures.  Within sixty (60) calendar days after the Effective Date, the 
Company shall establish Operating Procedures that all Covered Employees shall follow 
to help ensure the Company’s compliance with Sections 201(b) and 202(a) of the Act, as 
interpreted in the Rural Call Completion Declaratory Ruling, and with the rules adopted 
in the Rural Call Completion Order.  The Company’s Operating Procedures shall include 
internal procedures and policies specifically designed to ensure the Company’s 
compliance with Sections 201(b) and 202(a) of the Act, as interpreted in the Rural Call 
Completion Declaratory Ruling, and the rules adopted in the Rural Call Completion 
Order. The Company shall also develop a Compliance Checklist that describes the steps 
that a Covered Employee must follow to ensure compliance with Sections 201(b) and 
202(a) of the Act, as interpreted in the Rural Call Completion Declaratory Ruling, and 
the rules adopted in the Rural Call Completion Order.
(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, all of whom shall follow the procedures detailed in the Compliance Manual.  
Distribution of the Compliance Manual by e-mail or an e-mail link to an internal intranet 
site shall be deemed to comply with the distribution requirement in this paragraph.  The 
Compliance Manual shall explain Sections 201(b) and 202(a) of the Act, as interpreted in
the Rural Call Completion Declaratory Ruling, and the rules adopted in the Rural Call 
Completion Order, and set forth the Operating Procedures that Covered Employees shall 
follow to help ensure the Company’s compliance with Sections 201(b) and 202(a) of the 
Act, as interpreted in the Rural Call Completion Declaratory Ruling, and the rules 
adopted in the Rural Call Completion Order.  At least once annually, the Company shall 
review and revise the Compliance Manual as necessary to ensure that the information set 
forth therein remains current and accurate.  The Company shall distribute any revisions to 
the Compliance Manual promptly to Covered Employees.  The Compliance Manual shall 
require Covered Employees to contact the Company’s Compliance Officer and, if 
                                                     
30
The Company shall have no obligation to comply with the information collections required by the Rural Call 
Completion Order until they become effective.  See supra n.29 and accompanying text.  
Federal Communications Commission DA 14-679
7
appropriate, regulatory legal counsel with any questions or concerns that arise with 
respect to the Company’s obligations under Sections 201(b) and 202(a) of the Act, as 
interpreted in the Rural Call Completion Declaratory Ruling, and the rules adopted in the 
Rural Call Completion Order.
(c) Compliance Training Program.  The Company shall establish and implement a 
Compliance Training Program on compliance with Sections 201(b) and 202(a) of the Act, 
as interpreted in the Rural Call Completion Declaratory Ruling, the rules adopted in the 
Rural Call Completion Order, and the Operating Procedures.  As part of the Compliance 
Training Program, Covered Employees shall be advised of the Company’s obligation to 
report any noncompliance with the rules adopted in the Rural Call Completion Order
under paragraph 18 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 ninety (90) calendar days after the 
Effective Date. Any person who becomes a Covered Employee at any time thereafter 
shall be trained within thirty (30) calendar days after the date such person becomes a 
Covered Employee.  The Company shall repeat the compliance training on an annual 
basis.  At least once annually, the Company shall review and revise the Compliance 
Training Program as necessary to ensure that it remains current and complete and to 
enhance its effectiveness. 
(d) Compliance With the Rural Call Completion Order.  Matrix agrees that while this 
Consent Decree is in effect, the Company shall be treated as a “covered provider” for 
purposes of the rules adopted in the Rural Call Completion Order, regardless of whether 
the Company makes the initial long-distance call path choice for more than 100,000 
domestic retail subscriber lines.
(e) Testing.  The Company will cooperate with the FCC and with rural LECs to undertake 
commercially reasonable steps to establish test points and uniform test criteria to evaluate 
rural call completion when complaints, or data collected in accordance with the Rural 
Call Completion Order, indicate potential rural call completion problems.  
(f) Resolution of Call Completion Problems.  The Company will notify any Intermediate  
Provider it has reason to believe is causing call completion problems, and it will work 
cooperatively with each such Intermediate Provider to analyze and resolve such problems 
as soon as practicable.  If complaints, testing, or data collected in accordance with the 
Rural Call Completion Order show that an Intermediate Provider has sustained 
inadequate performance on a particular route, as reasonably determined by the Company, 
the Company will cease using the Intermediate Provider on that route, provided that other 
Intermediate Providers offer commercially reasonable options for reaching that location.   
18. Reporting Noncompliance.  The Company shall report any noncompliance with the 
rules adopted in the Rural Call Completion Order or with the terms and conditions of this Consent Decree 
within fifteen (15) calendar days after the Compliance Officer or any Covered Employee becomes aware 
of the matter (whether from a report from an employee or otherwise).  Such reports shall include a 
detailed explanation of (i) each instance of noncompliance; (ii) the steps that the Company 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 the Company has taken or will take to prevent the recurrence of any such 
noncompliance.  All reports of noncompliance shall be submitted to the Chief, Investigations & Hearings 
Division, Enforcement Bureau, Federal Communications Commission, Room 4-C330, 445 12th Street, 
SW, Washington, DC 20554, with copies submitted electronically to Theresa Z. Cavanaugh at 
Terry.Cavanaugh@fcc.gov and Theodore C. Marcus at Theodore.Marcus@fcc.gov.  
Federal Communications Commission DA 14-679
8
19. Compliance Reports.  The Company 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 the Company’s efforts 
during the relevant period to comply with the terms and conditions of this Consent 
Decree, with Sections 201(b) and 202(a) of the Act, as interpreted in the Rural Call 
Completion Declaratory Ruling, and with the rules adopted in the Rural Call Completion 
Order.  In addition, each Compliance Report shall include a certification by the 
Compliance Officer, as an agent of and on behalf of the Company, stating that the 
Compliance Officer has personal knowledge that the Company (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 18 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.
31
(c) If the Compliance Officer cannot provide the requisite certification, the Compliance 
Officer, as an agent of and on behalf of the Company, 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 the Company 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 the Company 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, SW, Washington, DC 20554, with copies submitted electronically to 
Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov and Theodore C. Marcus at 
Theodore.Marcus@fcc.gov.
                                                     
31
See 47 C.F.R. § 1.16.
Federal Communications Commission DA 14-679
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20. Termination Date. Unless stated otherwise, the requirements set forth in paragraphs 16
through 19 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.
21. 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
32
against the Company 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 the Company with the 
Communications Laws.
22. Voluntary Contribution.  The Company agrees that it will make a voluntary
contribution to the United States Treasury in the amount of eight hundred seventy-five thousand dollars
($875,000) (Voluntary Contribution).  Such Voluntary Contribution shall be made in seven installments 
(each an Installment Payment) in the amount of one hundred twenty-five thousand dollars ($125,000.00)
apiece.  The first Installment Payment is due on June 16, 2014.  Thereafter, Installment Payments are due 
and payable on the following dates: January 5, 2015, July 1, 2015, January 4, 2016, July 1, 2016, January 
6, 2017 and a final Installment Payment on July 3, 2017 (Maturity Date).  Matrix 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).
33
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, Matrix 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.  Matrix
shall also send electronic notification of payment to Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov 
and Theodore C. Marcus at Theodore.Marcus@fcc.gov on the date each Installment Payment is made.
23. Installment Payments must be made by check or similar instrument, wire transfer, or 
credit card, and must include the Account Number and FRN referenced in the caption to the Adopting
Order.  Regardless of the form of payment, a completed FCC Form 159 (Remittance Advice) must be 
submitted.
34
  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.  
                                                     
32
47 U.S.C. § 208.
33
See Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 1358 (Apr. 26, 1996).
34
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 14-679
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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.
Questions regarding payment procedure should be addressed to the Financial Operations Group Help 
Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.
24. Event of Default.  Matrix agrees that an Event of Default shall occur upon the failure by
the Company to pay the full amount of any Installment Payment on or before the due dates specified in 
paragraph 22 of this Consent Decree.
25. 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 Matrix.
26. Waivers.  The Company 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 in 
this Consent Decree.  The Company 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 the Company
nor the Commission shall contest the validity of the Consent Decree or the Adopting Order, and the 
Company shall waive any statutory right to a trial de novo.  The Company hereby agrees to waive any 
claims it may otherwise have under the Equal Access to Justice Act
35
relating to the matters addressed in 
this Consent Decree.  
27. 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.
28. 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 the Company does not expressly 
consent) that provision will be superseded by such Commission rule or order.
29. Successors and Assigns.  The Company agrees that the provisions of this Consent 
Decree shall be binding on its successors, assigns, and transferees.  
30. 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 and shall not be construed as either an adjudication on 
the merits or a factual or legal finding or determination regarding any compliance or noncompliance with 
the requirements of the Communications Laws.  The Parties also agree that this Consent Decree does not 
                                                     
35
See 5 U.S.C. § 504; 47 C.F.R. Part 1, Subpart K.
Federal Communications Commission DA 14-679
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constitute an admission of liability by the Company or a concession by the Commission that its 
Investigation was not well-founded.
31. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
32. 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.
33. Authorized Representative.  Each Party represents and warrants to the other Parties that 
it has full power and authority to enter into this Consent Decree.  Each person signing this Consent 
Decree on behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this 
Consent Decree and to bind the Party to its terms and conditions.  
34. Counterparts.  This Consent Decree may be signed in counterparts and may be delivered
by facsimile or electronic delivery.  Each counterpart, when executed and delivered, shall be an original, 
and all of the counterparts together shall constitute one and the same fully executed instrument.
________________________________
Travis LeBlanc
Acting Chief
Enforcement Bureau
______________________________
Date
________________________________
Bob Beaty
President & CEO
Matrix Telecom, Inc.
______________________________
Date