10 FCC Red No. 21 Federal Communications Commission Record DA 95-1905
Before the
Federal Communications Commission 
Washington, D.C. 20554
LETTER 
September 1,1995
Released: September 1,1995
Ronald J. Marlowe, Esq.
Cohen, Berke, Bernstein, Brodie,
Kondell & Laszlo
Terremark Centre
19th Floor
2601 South Bayshore Drive
Miami, Florida 33133-5460
Dear Mr. Marlowe:
This is in response to your informal request for a staff 
ruling regarding the legality of certain information and/or 
entertainment programs provided pursuant to tariffed rates 
for international communications services. Your inquiry is 
made on behalf of clients who apparently are interested in 
tariffing "international long distance services" for the trans 
mission of information and/or entertainment programs. 
You present scenarios whereby calls to foreign destinations 
providing audio information programs would be transmit 
ted through three different dialing sequences: (1) 10XXX 
+ international number; (2) 1-500-NXX-XXXX; or (3) 
1-700-NXX-XXXX. In each case, the calls would be trans 
mitted by an entity authorized to provide international 
direct dialed telecommunications services pursuant to Sec 
tion 214 of the Communications Act (the Act) at a tariffed 
rate. Calls to the international information programs would 
be billed to telephone subscribers at that tariffed rate as 
standard toll charges. No charges would be assessed by the 
information provider directly to the caller or subscriber. 
You ask whether the legality of the arrangement would be 
affected if: (1) the carrier remits a portion of the transport 
charge to the party advertising the destination number; or 
(2) the carrier remits a portion of the transport charge to 
the destination entity for providing the information. You 
also inquire whether the arrangement is lawful if steps are 
taken so that the destination number could not be accessed 
through any other carrier, and whether such calls may be 
billed on a separate page with consumer disclosures as 
non-deniable (so that disputes do not lead to disconnection 
of service).
As explained below, the staff concludes that it is a viola 
tion of federal law for any entity to provide tariffed com 
mon carrier communications services in an arrangement - 
whether domestic or international - where charges are 
assessed for calls to information programs in the manner 
you describe and/or when the carrier blocks access to a 
number from other carriers. Common carriers engaged in 
such practices are not providing common carrier commu 
nications services in a just and reasonable manner as re 
quired by Section 201(b) of the Act, and are violating both 
the letter and spirit of Section 228 of the Act.
Traditionally, information and entertainment programs 
have been provided to telephone subscribers at rates ex 
ceeding the tariffed transmission rates charged by the trans 
mitting common carrier. Such interstate information 
services are regulated as "pay-per-call" services under the 
Telephone Disclosure and Dispute Resolution Act 
(TDDRA) (codified at Section 228 of the Act) and im 
plementing regulations adopted by both this Commission 
and the Federal Trade Commission. Our rules require that 
all pay-per-call services must be provided on the 900 ser 
vice access code. Common carriers involved in either trans 
mitting and/or billing subscribers for pay-per-call services 
are subject to several statutory requirements intended to 
ensure that consumers are able to prevent access to or 
charges for unwanted information services. Specifically, the 
TDDRA requires carriers to offer telephone subscribers the 
option of blocking access to pay-per-call services and pro 
hibits the disconnection of basic telecommunications ser 
vices for failure to pay pay-per-call charges. While the 
statute establishes a comprehensive system for federal regu 
lation of pay-per-call services, it specifically exempts from 
pay-per-call status "any service the charge for which is 
tariffed" and services offered pursuant to a 
"presubscription or comparable arrangement."
In determining whether an entity licensed as a common 
carrier may lawfully provide service in the manner you 
describe, we note first that information programs should 
not be tariffed as common carrier services. Rather, com 
mon carriers may offer information programs only as non- 
tariffed "enhanced" services in accordance with Section 
64.702 of the Commission's rules. Moreover, it is a basic 
and central principle of common carriage that a carrier 
may provide tariffed service only as an objective conduit of 
a customer's communication, without influence or control 
in determining either the content of the communication or 
the destination of a customer's calls within its authorized 
service area. See Amendment of Parts 2, 91, and 99 of the 
Commission's Rules Insofar as They Relate to the Indus 
trial Radiolocation Service, Report and Order, 5 FCC 2d 
197, 202 (1966). Through payments to an information pro 
vider or destination entity (other than standard settlement 
payments), a carrier would abandon objectivity and acquire 
a direct interest in promoting the delivery of calls to a 
particular number for the provision of a particular com 
munication. This precept applies regardless of the particu 
lar dialing sequence used to place calls. Also, any carrier 
that is involved, either directly or indirectly, in blocking 
access to the called number by other carriers or in deter 
mining or influencing the content of the communications 
delivered through its network is not, we believe, offering a 
common carrier service. We recognize that long distance 
carriers lawfully assign numbers in limited circumstances 
and are the sole carrier to transport calls to such numbers. 
Restricting access to a particular telephone number that 
has been assigned for access by multiple carriers, however 
(or creating fictitious numbers), so that calls to that num 
ber can be completed only on one carrier's system is 
anticompetitive and an unjust and unreasonable practice, 
because that action deprives consumers of their right to use 
their preferred carrier. A carrier may lawfully provide 
service to information providers is only if it has absolutely 
no involvement or interest in the communications made 
through its network and does not engage in any action to 
encourage calls to a particular number or limit access to 
that number to callers using its transmission services. In 
summary, in the service scenarios you describe the carrier 
would appear to be providing an enhanced service, not a
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DA 95-1905 Federal Communications Commission Record 10 FCC Red No. 21
basic common carrier communications service. Accord 
ingly, imposing tariffed charges for the service would be an 
unjust and unreasonable practice under Section 201(b) of 
the Act. This conclusion is reinforced by the implication 
that your clients apparently plan to deliver calls only to a 
limited group of people (information providers), rather 
than making their service available to call any number at 
competitive rates using standard communications operator 
and billing procedures.
The services you describe are also unlawful under Sec 
tion 228 of the Act and the Commission's implementing 
rules. It appears from your description of the proposed 
services that your clients desire to operate -within the 
"tariffed service" exception to the definition of pay-per-call 
service, and thus evade the letter and spirit of those provi 
sions and the important consumer safeguards for informa 
tion services. The Commission is committed to eliminating 
abusive practices which deprive consumers of their statu 
tory rights concerning such services. Although Congress 
exempted from the pay-per-call definition services that are 
provided on a tariffed basis, we do not believe that the 
service you describe is encompassed within that exception. 
The fact that the consumer does not directly pay the in 
formation provider does not exclude the service from the 
definition of pay-per-call if the payment is simply paid to 
the information provider by the carrier and then recovered 
from the consumer through the transport charge. In this 
case, the transport tariff is a sham; the consumer has, in 
fact, paid the carrier for transport and the provider, albeit 
indirectly, for the information. Section 64.1506 of the 
Commission's rules requires that such calls be provided 
only on the 900 service access code. Clearly, Congress did 
not intend that the carefully crafted provisions of the 
TDDRA and Section 228 of the Act could be evaded by the 
arrangement you describe.
The payment of commissions in this instance is not 
comparable to carriers' payments to aggregators such as pay 
telephone owners. Those commissions simply compensate 
aggregators for their costs of making services and facilities 
available to the transient public for its communications 
need. See AT&T's Private Payphone Compensation Plan, 3 
FCC Red 5834, 5836 (Com. Car. Bur. 1988), recon. and 
review denied, 1 FCC Red 7135 (1992). The Commission 
has found that such commissions are a legitimate business 
practice so long as callers are not prevented from using any 
other carrier to place a call. Id., National Telephone Ser 
vices, Inc., 8 FCC Red 654, 655 (Com. Car. Bur 1993). In 
contrast, the proposed payments to information providers 
are expressly designed to evade the consumer safeguards set 
forth in the TDDRA and the Commission's rules.
Finally, we note that carriers are issued certificates of 
authorization under Section 214 of the Act when the Com 
mission determines that such issuance serves the public 
interest and convenience. We believe that the inherently 
evasive and anti-consumer and anti-competitive actions that 
you describe are contrary to the Section 214 mandate 
applicable to carriers providing international service even 
absent specific violations of the Act and the Commission's 
rules. For example, assigning a 500 number to an informa 
tion provider for termination in a country where the ter 
minating carrier pays the provider to route calls to that 
location would be, in the staffs view, inconsistent with the 
public interest mandate in Section 214. Thus, entities who 
have applied for or hold such authorizations may place 
such applications or authorizations in jeopardy if they 
conduct such activities.
Because the staff believes that the calling arrangements 
you describe would violate Sections 201(b) and 228 of the 
Act, and would be inconsistent with the public interest 
considerations set forth in Section 214 of the Act, we need 
not address the manner in which the calls may be billed. 
Carriers may not bill subscribers for unlawful calls.
This is a staff ruling issued pursuant to Section 0.291 of 
the Commission's rules, 47 C.F.R. § 0.291. Applications for 
review must be filed within 30 days of public notice of this 
action. See 47 C.F.R. § 1.115.
Sincerely,
John B. Muleta
Chief, Enforcement Division
Common Carrier Bureau
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