STATEMENT OF COMMISSIONER MIGNON CLYBURN
APPROVING IN PART AND CONCURRING IN PART
Re: Total Call Mobile, Inc. File No.: EB-IHD-14-00017650
Total Call Mobile’s actions were, in a word, reprehensible, which is why I support taking decisive 
enforcement action. This provider has not only violated our rules but also the trust of American 
consumers who contribute to the universal service fund.  Today’s Notice of Apparent Liability finds that 
Total Call Mobile enrolled the same consumers multiple times, without the customers’ knowledge, by 
making slight changes to each consumer’s identifying information.  This is fraud, plain and simple and 
represents the very reason why the Commission just voted to eliminate Lifeline providers from 
determining a customer’s eligibility. Preventing any provider from ever doing this again is why I 
advocated for the establishment of a neutral third party verifier to prevent such fraud in the future. 
Providers that show such blatant disregard for our rules should not be part of the Lifeline 
program. I therefore support the decision to require Total Call Mobile submit a report and explain why the 
Commission should not revoke Total Call Mobile’s compliance plan and suspend any future Lifeline 
payments to this company.    
Given the egregious nature of the alleged conduct, I believe a more significant forfeiture would 
have been appropriate. The Commission cannot tolerate such abuse and must send a strong signal that 
providers that violate our rules will face significant consequences.  I therefore vote to approve in part and 
concur in part.