Federal CommunicationsCommission FCC 00 - 46
Before the
FEDERAL COMMUNICATIONS COMMISSION 
Washington, D.C. 20554
In the Matter of )
) FileNo.ENF-99-01 
Long Distance Direct, Inc. )
) NAL/Acct. No. 916EF0003 
Apparent Liability for Forfeiture )
MEMORANDUM OPINION AND ORDER
Adopted: February 9, 2000; Released: February 17, 2000 
By the Commission:
I. INTRODUCTION
1. In this Order, we assess a forfeiture of $2,000,000 against Long Distance Direct, 
Inc. (LDDI), an interexchange carrier (IXC), for willfully or repeatedly violating section 258 of the 
Communications Act of 1934, as amended (Act),1 and rules and orders issued by the Commission 
under the Act,2 by submitting a change in the primary interexchange carrier (PIC) of 25 consumers 
without proper authorization (a practice known as "slamming"). We also find that LDDI willfully 
or repeatedly violated section 201 (b)3 of the Act by imposing charges on Complainants' telephone 
bills for unauthorized services ( a practice known as "cramming"). The $2,000,000 forfeiture 
assessed here represents a $40,000 penalty for each of the 25 slamming violations and a $40,000
1 The Act at section 258 provides in relevant part, "No telecommunications carrier shall submit... a change in 
a subscriber's selection of a provider of telephone exchange service or telephone toll service except in accordance 
with such verification procedures as the Commissions shall prescribe."
See, e.g., 47 C.F.R. § 64.1150; Implementation of the Subscriber Carrier Selection Changes Provisions of the 
Telecommunications Act of 1996 and Policies and Rules Concerning Unauthorized Changes of Consumers' Long 
Distance Carriers, CC Docket No. 94-29, Further Notice of Proposed Rule Making and Memorandum Opinion and 
Order on Reconsideration, 12 FCC Red 10674 (1997); Policies and Rules Concerning Unauthorized Changes of 
Consumers' Long Distance Carriers, 10 FCC Red 9560 (1995) (LOA Order), stayed in part, 11 FCC Red 856 
(1995) (In-bound Stay Order); Policies and Rules Concerning Changing Long Distance Carriers, 1 FCC Red 1038 
(1992) (PIC-Change Order), recon. deniedSFCC Red 3215 (1993); Investigation of Access and Divestiture Related 
Tariffs, 101 FCC 2d 911 (1985) (Allocation Order), Investigation of Access and Divestiture Related Tariffs, 101 
FCC 2d 935 (Com. Car. Bur. 1985) (Waiver Order), recon. (of both Allocation Order and Waiver Order) denied, 
102 FCC 2d 503 (1985) (Reconsideration Order).
3 The Act at section 20 l(b) provides in relevant part, "All charges, practices, classifications,and regulations for and 
in connection with such 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 unlawfu 1...."
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penalty for each of the 25 cramming violations.
II. BACKGROUND
2. The facts and circumstances surrounding this case are set forth in the Notice of 
Apparent Liability previously issued by the Commission (LDDINAL)* and need not be reiterated 
at length. Between January 1,1998 and October 31,1998, more than 800 consumers contacted the 
Commission and alleged that they had been slammed and, in many cases, crammed, by LDDI. The 
Commission investigated the allegations of 25 of these consumers (Complainants), and obtained a 
written statement from each as to the matters at issue.
3. Each of the Complainants stated that they were both slammed and crammed by 
LDDI. Complainants discovered that their long distance service had been changed to LDDI only 
after reviewing their long distance telephone bills or being so informed during a solicitation by 
another carrier. Complainants then attempted to contact LDDI to determine why LDDI had 
changed their PIC. Many were unable to reach LDDI even after repeated attempts. Those who 
were successful in reaching LDDI were often told that the PIC-change had been authorized by a 
call made from the Complainant's telephone to the "Friends to Friends" psychic hotline. After 
Complainants notified LDDI of the unauthorized PIC-change, they discovered on their next 
telephone bill not only that LDDI had continued to provide service, but also that it had imposed a 
"membership fee" (purportedly for membership in the "Friends to Friends" psychic hotline), and 
"other charges." A number of Complainants recall telephoning the "Friends to Friends" psychic 
hotline, but state that they were immediately put on hold and never spoke to anyone. The 
remaining Complainants say they had no contact with the "Friends to Friends" hotline.
4. We issued the LDDINAL in December 1998. We found LDDI's submission of 
unauthorized PIC-changes and imposition of unauthorized "membership" and "other" charges to 
constitute apparent violations of sections 25 8 and 201 (b) of the Act, and of Commission rules and 
orders. We found these apparent violations to be particularly egregious, as they were repeated, and 
continued over a period of months. In addition, they appeared to be far more than minor technical 
failures: not one of the Complainants could reasonably be said to have authorized service by LDDI 
or the imposition of the charges at issue. Based upon our review of the facts and circumstances 
surrounding these apparent violations, we proposed that LDDI be liable for a forfeiture in the 
amount of $40,000 for each of the slamming violations, and $40,000 for each of the cramming 
violations, resulting in a total forfeiture amount of $2,000,000.s
4 See, In the Matter of Long Distance Direct, Inc., Notice of Apparent Liability for Forfeiture, 14 FCC Red 314 
(1998)at316-330.
5 LDDINAL at 2.
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5. LDDI submitted a response (Response) to the LDDINAL on February 4, 1999. In 
its Response, LDDI does not deny that it submitted PIC-change orders to Complainants' local 
exchange carriers.6 Nor does it deny that it billed Complainants for "membership fees" and 
"other charges." Instead, LDDI states that, in January of 1998, it entered into a "joint marketing 
alliance" with Inphomation, Inc., d/b/a The Psychic Friends Network (PFN) to market LDDI's 
long distance services together with PFN's "Friends to Friends" psychic services network. 
Pursuant to this arrangement, LDDI and PFN produced and aired television infomercials 
promoting the "Friends to Friends" psychic network and the LDDI long distance network. The 
infomercials displayed 800 numbers "owned and controlled" by PFN which consumers could call 
to request service by LDDI and membership in "Friends to Friends." LDDI asserts that it directed 
PFN to obtain and confirm customers' authorizations in accordance with Commission rules, and 
that PFN was then to submit the names and telephone numbers of those customers to LDDI.7
III. DISCUSSION
6. LDDI contests the Commission's finding of apparent liability. LDDI argues first 
that a forfeiture order should not be issued at all. Alternatively, LDDI argues that, if the 
Commission does determine that a forfeiture is warranted, it should be in an amount substantially 
less than $2,000,000. As discussed below, we affirm the findings in the LDDINAL and decline to 
reduce the forfeiture amount.
A. Imposition of a Forfeiture
7. LDDI argues that a forfeiture order should not be issued because: 1) LDDI 
delegated to PFN responsibility for obtaining proper authorization and verification of PIC-changes 
and membership in "Friends to Friends," and PFN was an independent contractor; 2) LDDI took 
the "affirmative step" of telephoning prospective customers and sending them a postcard to thank 
them for subscribing to its services; and, 3) the Commission allegedly does not have jurisdiction to 
impose penalties for imposing unauthorized charges on consumer telephone bills.
6 The Commission's rules and orders require that IXCs such as LDDI subrr.it PIC-change orders to local 
exchange carriers, who are then obligated to make the PIC-change absent some indication that the request is not 
legitimate. See LOA Order, 10 FCC Red 9560 (1995); PIC-change Order, 1 FCC Red 1038 (1992); Allocation 
Order, 101 FCC 2d 911 (1985); Waiver Order, 101 FCC 2d 935 (Com. Car. Bur. :i985).
7 Response at 3 - 4. Complainants' allegations, together with a review of the "welcome postcard" LDDI 
asserts it mailed to new customers, indicates that PFN's "Friends to Friends" psychic services network was a pay- 
per-call service in which "psychics" provided personal advice to the caller.
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(1) Liability for the Acts of an Independent Contractor
8. LDDI argues first that the Commission should not issue a forfeiture because PFN, 
not LDDI, was responsible for obtaining and verifying consumers' authorization to be switched to 
LDDI and join "Friends to Friends," and LDDI directed PFN to do so in accordance with the law. 
LDDI asserts that PFN was an independent contractor, and contends that section 217 of the Act 
does not impose liability for the acts of an independent contractor.8
9. The Commission has ruled on numerous occasions that carriers are responsible for 
the conduct of third parties acting on the carrier's behalf, including third party marketers.9 LDDI is 
not relieved of liability merely because it directed PFN to secure consumer authorizations in 
accordance with the law. Section 217 of the Act deems "the act, omission or failure of any ... 
person acting for or employed by" any carrier to be the act, omission or failure of that carrier. This 
language is extremely broad and clearly extends to PFN, which was "acting for" LDDI in securing 
PIC-change authorizations. Identical language in another federal statute has been construed to 
impose criminal liability upon an employer for the acts of its independent contractor. The court 
reasoned there: "The fact that [the party who violated the statute] is said to have been an 
independent contractor rather than an employee is of no significance here because the section uses 
the disjunctive 'acting for or employed by.'"10 Congress's clear intent in enacting section 217 was 
to ensure that common carriers not flout their statutory duties by delegating them to third parties.1 ' 
To hold that the section does not include independent contractors would create a gaping loophole in 
the requirements of the Act and frustrate legislative intent. Moreover, the construction urged by 
LDDI is contrary to long-established principles of common law holding statutory duties to be
s The Act at section 217 provides, "In construing and enforcing the provisions of this Act, the act, omission, 
or failure of any officer, agent, or other person acting for or employed by any common carrier or user, acting within 
the scope of his employment, shall in every case be also deemed to be the act, omission, or failure of such carrier or 
user as well as that of the person."
9 The Commission has repeatedly held that the failure of a third party marketerto obtain proper authorization 
for a PIC-change does not relieve the carrier of its independent obligation to ensure compliance with Commission rules. 
See, Heartline Communications,Inc., 11 FCC Red 18487 (1996); Excel Telecommunications, Inc., 11 FCC Red 
19765 (1997); Target Telecom, Inc., 13 FCC Red 4456 (1998); MCI Telecommunications Corp., 11 FCC Red 1821 
(1996).
10 United States of America v. Corbin Farm Service, 444 F. Supp. 510, 525 ( E.D. Cal.), off don other 
grounds, 578 F.2d 259 (9th Cir. 1978). In that case, the court was charged with the construction of section 
1361(b)(4) of the Insecticide, Fungicide, and Rodenticide Act, 7 U.S.C. §§ 1 etseq.
11 See, e.g., Miller's Apple Valley Chevrolet Olds-Geo, Inc. v. Goodwin, 177 F.3d 232, 234 (4* Cir. 1999) 
("Statutory interpretation begins with the language of the Act.... [T]he intent of Congress is expressed in the text 
of the statute... ")-
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nondelegable.12
LDDF s "Affirmative Steps"
1 0. LDDI argues next that a forfeiture should not be imposed because, in addition to 
directing PFN to obtain consumer authorization in accordance with the law, it took the "affirmative 
step, above and beyond that required by applicable FCC rules" of making a "courtesy call" to 
prospective subscribers to thank them for switching to LDDI and mailing mem a "welcome postcard".13
1 1 . Not one of the Complainants reported receiving a courtesy telephone call, and the 
few Complainants who recall a "welcome postcard" state that they received it only after being 
slammed and crammed. Moreover, there is no evidence that, prior to submitting PIC-changes 
and charging "membership fees", LDDI even attempted to confirm that the authorizations 
submitted by PFN were valid. Having failed to fulfill such a fundamental obligation, LDDI 
cannot reasonably assert that its actions went "above and beyond" the law.
12. In fact, LDDI's actions fell far short of the law. A number of Complainants state 
that they had no contact with LDDI or "Friends to Friends" prior to being slammed and 
crammed. The remaining Complainants telephoned "Friends to Friend:;" but were immediately 
put on hold and spoke to no one. Commission rules in effect during the period at issue provided 
that, when a consumer initiated a call to an IXC and authorized a switch in service, the IXC was 
not required to verify that authorization. These rules certainly did not relieve the carrier of the 
obligation to obtain authorization in the first instance. 14 LDDI violated these rules, for it never 
obtained Complainants' authorization. Those Complainants who had no contact with LDDI or 
PFN provided no authorization. Nor had those Complainants who telephoned PFN and never 
spoke to anyone: The mere act of placing a telephone call does not constitute authorization for 
being switched to a different IXC and charged "membership fees".
12 Employers are routinely held liable for breach of statutory duties, even where the failings are those of an 
independent contractor, and even where the party seeking redress is other than the government. See Restatement 
[Second] of Torts § 409, comment b at 371. See also, e.g., Aha Steamship Co., Ltd. v. City of New York, 616 F.2d 
605, 609 (2d Cir. 1980) (exception to the rule of nonliability for the negligence of independent contractor is "the 
negligence of an independent contractor who performs a duty imposed by statute on the employer").
13 Response at 10.
14 In-bound Stay Order, 11 FCC Red at 856. As stated in the Order, the Commission was "persuaded that 
temporarily staying the PIC verification requirements as they pertain to consumer-initiated calls will allow the 
Commission to develop a complete record upon which we can conduct meaningful cost-benefit analysis and make a 
more informed decision." Id.
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C3) Jurisdiction to Impose a Forfeiture for Cramming
13. LDDI argues that a forfeiture may not be imposed with respect to the "membership" 
and "other" charges it placed on Complainants' phone bills, as the Commission does not have 
jurisdiction over the unauthorized placement of charges on a telephone bill for enhanced services.
14. LDDI is incorrect. Section 201 (b) of the Act prohibits "unjust and unreasonable" 
practices by carriers "in connection with [interstate or foreign] communication service". LDDI's 
inclusion of "membership" and "other" fees on Complainants' telephone bills was an "unjust and 
unreasonable" practice because the fees were unauthorized. That practice was "in connection with" 
communication service because it was inextricably intertwined with LDDF s long distance service.
15. The record underscores the extent to which the unauthorized "membership" and 
"other" fees imposed by LDDI were "in connection with" its marketing, billing, and provision of 
long distance service. By its own admission, LDDI joined PFN in a "joint marketing alliance" 
pursuant to which LDDI's long distance services were to be promoted together with the "Friends to 
Friends" psychic network. The infomercial produced by LDDI and PFN advertised the services of 
both companies. PFN was to obtain subscribers to LDDI' s IXC services through the "Friends to 
Friends" hotline. The telephone bills imposing the "membership" and "other" fees were generated 
and mailed to Complainants by LDDI. These bills state, "as a ["Friends to Friends"] Charter 
member you are entitled to ... our discount long distance service." LDDI's welcome postcard 
provides that, "As a Friends to Friends Charter Member you have been switched free of charge to .. 
. LDDI... ." Further, LDDI received a significant amount of the "membership" fees imposed upon 
consumers more than $3 million in the first six months of 1998.15 In short, LDDI's practice of 
imposing "membership" and "other" fees was so inextricably intertwined with its marketing, billing 
and provision of long distance service that the practice was clearly "in connection with" 
communication service. The Commission correctly exercises its jurisdiction here to remedy 
violations of section 201 (b).16
15 The consolidated Securities and Exchange Commission Form 10-QSB filed by Long Distance Direct 
Holdings, Inc., LDDI's parent corporation, for the quarter ending June 30, 1998 states that, in the first six months of 
1998, "the Company's psychic marketing program generated $3,254,980 or 34% of revenue through membership fees 
charged to the Company's customers...".
16 LDDI argues in the alternative that, even if the Commission does have jurisdiction over cramming, that 
jurisdiction is shared with, and better exercised by, the Federal Trade Commission. Response at 5, 11 - 15. But LDDI 
does not deny that slamming violations are properly before the Commission. The interdependency of the slamming 
and cramming violations at issue, as well as considerations of administrative efficiency, establish that the 
Commission is correct in exercising its jurisdiction here. We are fortified in our conclusion by the fact that the 
cramming at issue involved ostensible membership in "Friends to Friends", a pay-per-call service . At section 228 
of the Act, Congress specifically "recognize[dj the Commission's authority to prescribe regulations and 
enforcement procedures and conduct oversight to afford reasonable protection to consumers of pay-per-call services
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B. Amount of the Forfeiture
16. LDDI argues alternatively that, if the Commission determines that a forfeiture 
should be imposed, the amount of the forfeiture should be substantially reduced. Invoking the 
factors set forth in section 503(b)(2)(D) of the Act,17 LDDI asserts that: 1) LDDI's violations were 
not "particularly egregious"; 2) LDDI is a responsible carrier; and, 3) LDDI is not able to pay a 
penalty of $2,000,000.
(1) Gravity of the Violations
17. LDDI argues that a penalty of $40,000 for each of the slamming and cramming 
violations is inconsistent with the Commission's Forfeiture Policy Statement1* and prior 
Commission decisions.19 LDDI urges first that its violations are not "p;irticularly egregious", 
finding it significant that the unauthorized PIC-changes and "membership fees" did not result from 
forged letters of authorization, but from Complainants telephoning a number advertised in the 
LDDI/PFN infomercials. 20 According to LDDI, the fact that Complainants made these calls "at the 
very least, evidenced the end-user's interest in the advertised services."21
18. Neitherthe Forfeiture Policy Statement nor the Commission's prior decisions 
suggests that the $40,000 base forfeiture amount for slamming is limited to situations involving 
forged letters of authorization. The violations at issue here are particularly egregious. They were 
repeated, and continued over a period of months. And they were more than minor technical 
failures, as not one of the Complainants can reasonably be said to have: authorized the charges at 
issue here. The record indicates that those who telephoned the "Friends to Friends" psychic hotline 
were put on hold and never spoke to anyone. The record further indicates that the remaining
17 The Act at section 503(b)(2)(D) provides that, in determining the amount of the forfeiture penalty, the 
Commission is required to take into account "the nature, circumstances, extent, and gravity of the violation and, with 
respect to the violator, the degree of culpability, and history of prior offenses, ability to pay, and such other matters as 
justice may require."
18 Commission's Fofeiture Policy Statement and Amendment of Section l.SO of the Rules to Incorporate the 
Forfeiture Guidelines, Report and Order, 12 FCC Red 17808 (1997) (Forfeiture Policy Statement).
19 See Response at 19 n. 50 and the cases cited therein.
20 Response at 17-20.
21 Response at 17.
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Complainants had no contact with LDDI or PFN prior to being slammed and crammed. Contrary to 
LDDI' s assertion, the fact that certain Complainants telephoned "Friends to Friends" does not 
demonstrate that they were interested in switching to LDDI or joining "Friends to Friends." In any 
event, mere "interest" is a far cry from the actual authorization required under the Act and our rules.
19. LDDI argues further that a penalty of $40,000 for each cramming violation is 
inconsistent with the Forfeiture Policy Statement because the Commission "conspicuously 
omit[ted] reference to .unauthorized charges on consumers' telephone bills.. .".22 LDDI is incorrect. 
Although the Forfeiture Policy Statement does not establish a forfeiture amount for cramming, it 
does state that, "any omission of a specific rule violation... should not signal that the Commission 
considers any unlisted violation as nonexistent or unimportant."23 In addition, the Commission 
retains the discretion to depart from the Forfeiture Policy Statement and issue forfeitures on a case- 
by-case basis under the general forfeiture authority granted it by section 503 of the Act.24 The 
imposition of charges on a telephone bill for "services" the consumer has not authorized is 
sufficiently egregious to warrant a forfeiture in an amount equal to that for slamming. In the case 
both of slamming and cramming, the consumer is charged without consent, and consumer 
confusion is exploited. Moreover, as discussed earlier, the cramming violations at issue here were 
not minor infractions. Complainants were charged for "services" they had not authorized and never 
received. Accordingly, by analogy to the standard forfeiture for slamming provided by the 
Forfeiture Policy Statement, $40,000 is an appropriate forfeiture for these unauthorized charges.
(2) Degree of Culpability and Prior Offenses
20. LDDI argues that the forfeiture is excessive because it has been "an exemplary long 
distance carrier."25 It notes that it has never before been the subject of an enforcement action, and 
asserts that the acts at issue were those of PFN, an independent contractor. LDDI points again to its 
alleged "affirmative steps" of making courtesy calls and sending welcome postcards to prospective 
subscribers. Additionally, LDDI emphasizes that it took appropriate remedial measures when it 
learned that PFN had not obtained proper authorizations: it ended the relationship with PFN, 
reimbursed Complainants, provided timely and detailed responses to the Commission's notices of 
informal complaint, and implemented rigorous measures to prevent future unauthorized PIC- 
changes.26
22 Response at 17-18.
23 Forfeiture Policy Statement, 12 FCC Red at 17099.
24 Id.
25 Response at 7.
26 Response at 20-21,23.
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21. The size of the penalty imposed here merely reflects the large number of violations: 
25 acts of slamming and 25 acts of cramming. While LDDI has never before been the subject of an 
enforcement action, we view these violations as particularly egregious. As discussed earlier, 
LDDI's failure to ensure that Complainants had authorized a change to LDDI and membership in 
"Friends to Friends" cannot be cured by courtesy calls and welcome postcards. Finally, LDDI's 
remedial efforts after being confronted by the Commission were no more than might be expected of 
any carrier. In particular, we note that LDDI has not shown that it has taken any remedial action 
regarding the hundreds of consumers (other than Complainants) who contacted the Commission 
asserting that they were switched to LDDI without their permission.
Ability to Pay
22. LDDI argues that the forfeiture amount should be reduced because LDDI has 
sustained operating losses for each year of its existence, and because a $2,000,000 forfeiture 
"would mean the certain demise of LDDI as a viable business concern . . . ",27 LDDI's assertion 
that it suffered operating losses is unavailing. We have repeatedly held that that a carrier's gross 
revenues are the best indicator of its ability to pay a forfeiture ."[Tjheuse of gross revenues to 
determine a party's ability to pay is reasonable, appropriate, and a useful yardstick in helping to 
analyze a company's financial condition for forfeiture purposes."28
23. LDDI has not demonstrated that its gross revenues are such that LDDI cannot pay a 
$2,000,000 forfeiture. LDDI asserts that its gross revenues in 1 998 were $12 million, 29 but has 
provided no reliable information as to its gross revenues in 1 999. LDDI submitted its parent 
company's consolidated SEC Form 10-Q for the period ending March 31, 1998, and refers in its 
Response to the same Form 1 0-Q for the period ending June 30, 1 998. Yet those forms do not 
provide recent financial information, and establish only that LDDI's parent has significant assets. 
We are unable to locate any more recent SEC filings. We repeatedly requested that LDDI provide
27 Response at 22.
28 Target Telecom, Inc., 13 FCC Red at 4458 (1998). See also PJB Communications of Virginia, 7 FCC Red 
2088; David L Hollingsworth d/b/a Worldand Services, 7 FCC Red 6640 (1992). LDDI cites Applications of First 
Greenville Corp., 11 FCC Red 7399 (1996) and Benito Rish, 10 FCC Red 2861 (1995). Response at 21. But those 
cases are readily distinguishable, as they involve forfeitures imposed upon small radio stations, not 
telecommunications resellers. Further, in Applications of First Greenville Corp , the radio licensee established that 
its sole shareholder had not received any income whatsoever from the stations and had lent the stations 
considerable sums. LDDI has made no such showing here. In Benito Rish, the Commission reduced the penalty 
because the radio licensee was licensed to a community of 425 and a reduced penalty would adequately deter future 
misconduct.
29 Response at 22.
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probative evidence of its current financial status.30 Yet LDDI responded by providing an income 
statement for the quarter ended March 30,1999, which is neither audited, attested to as accurate by 
an officer of the company nor even authenticated. LDDI simply has not met its burden of proving 
that it is unable to pay a $2,000,000 forfeiture.
IV. CONCLUSION
24. After reviewing the information filed by LDDI in its Response, we find that LDDI 
has failed to identify facts or circumstances to persuade us that there is any basis for reconsidering 
the LDDINAL. Further, LDDI has not shown any mitigating circumstances sufficientto warrant a 
reduction of the $2,000,000 forfeiture penalty for which it is liable.
ORDERING CLAUSES
25. Accordingly, IT IS ORDERED THAT, pursuant to section 503(b) of the Act, 47 
U.S.C. § 503(b), and sections 0.111,0.311 and 1.80(f)(4) of the Commission's rules, 47 C.F.R. §§ 
0.111,0.311 and 1.80(f)(4), that LDDI SHALL FORFEIT to the United States Government the 
sum of two million dollars ($2,000,000) for violating sections 201 (b) and 258 of the Act, 47 U.S.C. 
§§ 201(b), 258, as well as the Commission's rules and orders.31
30 Commission staff met with principals of LDDI and their legal counsel on May 5, 1999, and requested that, 
by June 6, 1999, LDDI provide audited financial statements for the year ending December 31, 1999. LDDI did not 
respond. On June 16, 1999, Commission staff contacted LDDFs counsel, warned him that LDDI had the burden of 
proof to show that the forfeiture should not issue, and advised him that the carrier would have only until June 29 to 
substantiate its claims. LDDI then provided the March 30, 1999 income statement discussed above.
31 The forfeiture amount should be paid by check or money order drawn to the order of the Federal 
Communications Commission. Reference should be made on the check or money order to "NAL/Acct. No. 
916EF0003." Such remittances should be mailed to Forfeiture Collection Section, Finance Branch, Federal 
Communications Commission, P.O. Box. 73482, Chicago, Illinois 60673-7482.
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26. IT IS FURTHER ORDERED that a copy of this Order of Forfeiture shall be sent by 
certified United States mail to Steven Lampert, President and Chief Executive Officer, Long 
Distance Direct, Inc., One Blue Hill Plaza, Suite 1430, Pearl River, New York 10965.
FEDERAL COMMUNICATIONSCOMMISSION
Magalie Roman Salas 
Secretary
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