REDACTED
Federal Communications Commission FCC 11-89
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Main Street Telephone Company
Apparent Liability for Forfeiture
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File No. EB-10-TC-468
NAL/Acct. No.: 201132170021
FRN: 0007630379
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted:  June 7, 2011 Released:  June 16, 
2011
By the Commission: 
I. INTRODUCTION
1. In this Notice of Apparent Liability for Forfeiture (“NAL”), we find that Main 
Street Telephone Company (“Main Street” or “Company”)1 has apparently willfully and 
repeatedly violated section 201(b) of the Communications Act of 1934, as amended 
(“Communications Act” or “Act”),2 by “cramming” monthly charges for its dial-around long 
distance service on consumers’ local telephone bills without authorization of any kind from 
them.  Based upon our review of the facts and surrounding circumstances, we find that Main 
Street is apparently liable for a proposed forfeiture in the amount of four million two hundred 
thousand dollars ($4,200,000). 
II. BACKGROUND
2. Cramming, the practice of adding charges to a customer’s local telephone bill 
without the customer’s authorization, results in significant consumer harm.  Charges can often 
range from $2.99 to as much as $19.99 per month and can go undetected by consumers for many 
months or longer because they are not generally disclosed clearly or conspicuously on the bill.  
The cramming entity can be the customer’s own local exchange carrier (“LEC”) or an 
unaffiliated third-party service provider such as Main Street, in the instant case.  The charges can 
  
1 Main Street Telephone Company’s principal address is 470 Norristown Road, Suite 201, Blue Bell, Pennsylvania 
19422.  The “Managing Member” is listed as Frank Scardino.  Thomas Glynn is listed as Main Street’s President 
and CEO.  Accordingly, all references in this NAL to “Main Street” also encompass Mr. Scardino, Mr. Glynn, and 
all other principals and officers of this entity, as well as the corporate entity itself.  
2 47 U.S.C. § 201(b).
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Federal Communications Commission FCC 11-89
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be for additional telephone services, voice mail and similar services, or for other unrelated 
products and services such as chat lines, diet plans, and cosmetics.3  
3. The Enforcement Bureau (“Bureau”) began its investigation of Main Street on 
September 23, 2010, by issuing a letter of inquiry to Main Street requesting information and 
documents relating to its charges for long distance service.4 In its initial response, dated 
November 30, 2010,5 Main Street represented, among other things, that it provides domestic 
interexchange telecommunications service on a resale basis through a “dial-around” service 
plan.6 Main Street’s Save4Less plan offers customers 284 minutes of long distance calling per 
month for $13.90, a rate of 4.9¢ per minute if all the minutes are used.7 Consumers must call 
Main Street’s toll free access number and enter a PIN to use its service.  Main Street states that it 
“currently services approximately 19,000 Save4Less customers.”8
4. Main Street’s process for billing consumers involves three parties:  Main Street; 
its billing aggregator, Billing Service Group (“BSG”); and the LEC that issues the bill to the 
consumer.  BSG uses the name “USBI” in billing for long distance services.  The LEC is 
compensated by BSG/USBI for placing the charges on the consumers’ bills; BSG/USBI is paid 
by Main Street to manage billing requests and payments between the LEC and Main Street; and 
Main Street ultimately receives the money collected from the consumers who pay the charges.  
Generally, the third-party carrier supplies only a consumer’s telephone number and the amount 
to be charged to the billing aggregator, which directs the LEC to place the charge on the 
consumer’s telephone bill.  Proof of consumer authorization is not provided by the third-party 
carrier nor required by the LEC.
  
3 See “BBB Issues Warning on Web Companies Linked to Adept Results,” Nov. 11, 2009, 
http://wisconsin.bbb.org/article/bbb-issues-warning-on-web-companies-linked-to-adept-results-13501.
4 See Letter from Kimberly A. Wild, Assistant Division Chief, Telecommunications Consumers Division, 
Enforcement Bureau, Federal Communications Commission, to Main Street Telephone Company (Sept. 23, 2010) 
(“LOI”).  The Bureau sent a second LOI to Main Street on February 25, 2011.  See Letter from Kimberly A. Wild, 
Assistant Division Chief, Telecommunications Consumers Division, Enforcement Bureau, Federal Communications 
Commission, to Main Street Telephone Company (Feb. 25, 2011) (“Second LOI”).  
5 See Letter from Steven A. Augustino, Counsel to Main Street Telephone Company, to Kimberly A. Wild, Assistant 
Division Chief, Telecommunications Consumers Division, Enforcement Bureau, FCC (Nov. 30, 2010) (“Response 
to LOI”).  Main Street supplemented its response to the first LOI.  See Letter from Steven A. Augustino, Counsel to 
Main Street Telephone Company, to Kimberly A. Wild, Assistant Division Chief, Telecommunications Consumers 
Division, Enforcement Bureau, Federal Communications Commission (Jan. 14, 2011) (“Supplemental LOI 
Response”).  Main Street also submitted a response to the Bureau’s second LOI.  See Letter from Steven A. 
Augustino, Counsel to Main Street Telephone Company, to Kimberly A. Wild, Assistant Division Chief, 
Telecommunications Consumers Division, Enforcement Bureau, FCC (Mar. 30, 2011) (“Response to Second LOI”).
6 Response to LOI at 3.  “Dial around” long distance service allows a telephone subscriber to bypass (i.e., dial 
around) the subscriber’s preselected long distance telephone carrier, if any, and instead use the dial around carrier’s 
long distance service for a particular phone call.  For each phone call, the subscriber must use the dial around 
carrier’s number and, in some instances, enter a PIN to connect the call.
7 Id. An additional fee is collected for Universal Service.  Minutes used in excess of 284 minutes are billed at the 
rate of $.049 per minute.  Id.
8 Id.
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Federal Communications Commission FCC 11-89
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5. [REDACTED].9  [REDACTED].10 Online enrollment forms used to sign up 
customers allow for the input of the consumer’s first name, last name, address, home telephone 
number, email address and date of birth.11 The enrollment form contains Main Street’s terms and 
conditions and a statement that the customer signing up for the long distance service plan will be 
billed on their telephone bill.12  
6. In the course of the investigation, Main Street identified nearly [REDACTED]
consumer complaints about its service, and provided copies of more than [REDACTED] of 
those complaints, which the Bureau reviewed.13 These included complaints that had been filed 
not only with the FCC, but also with state regulatory authorities, the Better Business Bureau, or 
with Main Street directly.  All of the complainants contended that Main Street had charged them 
for service without their authorization.  
7. These complaints notwithstanding, Main Street claims that it “has rigorous 
procedures in place to verify each order and its authenticity before a customer receives any 
charge for the service.”  According to Main Street, a “Confirmation Page” requires customers to 
reconfirm the personal data entered on the enrollment form and discloses the billing 
information.14 Main Street contends that it validates the orders by comparing the name listed on 
the order form with the name registered to the telephone number; examining the email address; 
and verifying that the state, zip code, and telephone area code match.15 Main Street asserts that 
the order is accepted only if the customer’s last name, address, and telephone number match.16
8. According to Main Street, if the order passes the Company’s validation process, it 
then sends three emails to confirm the order, describe the service, how to use the service and 
how to cancel it.17 The consumer is not required to confirm that the emails were received or to 
otherwise respond to the emails before Main Street begins charging for the service. 
  
9 Id. at 14.
10 Id. at 13.  Main Street contends that the agreement between Main Street and [REDACTED].  Id.
11 Response to LOI at Exhibit A.
12 Id.
13 Main Street provided [REDACTED] consumer complaints it received between January 1, 2010 and November 1, 
2010.  In a supplemental response to the LOI, dated January 14, 2011, Main Street provided a spreadsheet listing 
[REDACTED] additional consumer complaints (but not providing the supporting documentation) from the same 
time period, for a total of [REDACTED] complaints.  In response to the second LOI seeking more recent 
complaints, Main Street provided [REDACTED] complaints and a spreadsheet listing [REDACTED] additional 
complaints.  In all, Main Street identified a total of [REDACTED] complaints in response to both LOIs. 
14 Response to LOI at 5.
15 Id. 
16 Id. at 6.
17 Id.
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Federal Communications Commission FCC 11-89
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III. DISCUSSION
A. Violation of Section 201(b) of the Act
9. Section 201(b) of the Act states, in pertinent part, that “[a]ll charges, practices, 
classifications, and regulations for and in connection with [interstate or foreign] communication 
service [by wire or radio], shall be just and reasonable, and any such charge, practice, 
classification, or regulation that is unjust or unreasonable is hereby declared to be unlawful. . . 
.”18 The Commission has found that the inclusion of unauthorized charges and fees on 
consumers’ telephone bills is an “unjust and unreasonable” practice under section 201(b).19  
10. We find that Main Street has willfully and repeatedly placed, or caused to be 
placed, charges on consumers’ telephone bills for services the consumers did not request or 
authorize.  As indicated above, each of the more than [REDACTED] consumer complaints that 
the Bureau reviewed – whether they were filed with the FCC, state regulatory authorities, the 
Better Business Bureau or with Main Street directly – contends that Main Street charged 
consumers for service without their authorization.  The complainants consistently state they did 
not sign up for Main Street’s service, did not have any contact with Main Street prior to 
discovering the charges, and in most cases, do not even know the person whom Main Street 
alleges authorized the service.20  
11. For instance, [REDACTED] 21  [REDACTED] experience with Main Street is 
far from unique.  Complainant [REDACTED].22 Similarly, Complainant [REDACTED].23  
Complainant [REDACTED].24 Complainant [REDACTED].25
12. [REDACTED].26
13. In some cases, the consumers who were signed up for Main Street’s services were 
surprised to find out that the authorization form they had allegedly provided was over the 
Internet because they do not own computers or have Internet access.  For example, Complainant 
  
18 47 U.S.C. § 201(b).
19 See Long Distance Direct, Inc. Apparent Liability for Forfeiture, Memorandum Opinion and Order, 15 FCC Rcd 
3297, 3302, ¶ 14 (2000) (“LDDI Forfeiture Order”) (finding that the company’s practices of cramming membership 
and other unauthorized fees on consumer telephone bills was an unjust and unreasonable practice in connection with 
communication services).  
20 In the other cases, the name in Main Street’s records was that of the consumer, but other identifying information 
was wrong.
21 See Complaint from [REDACTED].  Similarly, [REDACTED].
22 Complaint from [REDACTED].
23 Complaint from [REDACTED].
24 Complaint from [REDACTED].  Main Street recorded [REDACTED].
25 Complaint from [REDACTED].
26 Complaint from [REDACTED].
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Federal Communications Commission FCC 11-89
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[REDACTED].27 Complainant [REDACTED]..28 Complainant [REDACTED]. 29  
Complainant [REDACTED].30
14. Other consumers pointed out that they had unlimited long distance service with 
another carrier and would have no need to pay a monthly fee for additional service with Main 
Street.  For example, Complainant [REDACTED].31 Complainant [REDACTED].32  
Complainant [REDACTED].33
15. The complainants’ contention that Main Street “crammed” charges for its dial-
around long distance service on their bills is corroborated by the fact that, between March 2010 
and February 2011, Main Street placed charges on a total of over [REDACTED] monthly 
telephone bills.34 Nevertheless, in response to our LOI request that the Company provide 
information about the its “customers” who actually used its service, Main Street stated that it 
[REDACTED].35 We find this implausible given that Main Street claims to provide customers 
with 284 minutes per month for a monthly fee and that customers will incur additional charges 
after those minutes are used – unless, of course, it is unnecessary because so few “customers” 
actually use the service.
16. To the extent it actually uses them, Main Street’s validation and verification 
processes are clearly inadequate to confirm that the person who “enrolled” in its plan, i.e., the 
one whom Main Street will charge for service, in fact authorized the service.  As indicated, Main 
Street asserts that it confirms every service order using a five-stage validation process to ensure 
that the customer has both ordered the services and authorized billing for the services.36 The fact 
remains that, in many cases, the name and address in Main Street’s enrollment records do not 
match the name and address of the customer who was charged for service.37 Similarly, the email 
  
27 Complaint from [REDACTED].  [REDACTED].  Id.
28 Complaint from [REDACTED]. Main Street recorded [REDACTED].
29 Complaint from [REDACTED].
30 Complaint from [REDACTED].
31 Complaint from [REDACTED].  See also Complaint from [REDACTED].
32 Complaint from [REDACTED].
33 Complaint from [REDACTED].  See also Complaint from [REDACTED].
34 Response to Second LOI at 9-10.  The number of billed customers per month fluctuated from [REDACTED] to 
[REDACTED].  Id.
35 See Response to Second LOI at 10.  Main Street went on to say that [REDACTED]. Id. In a subsequent email, 
Main Street’s attorney said:  “Main Street stated that it did not have the information that is requested.”  See email 
from Steven A. Augustino, Counsel to Main Street Telephone Company, to Mika Savir, Attorney, 
Telecommunications Consumers Division, Enforcement Bureau, FCC, (Mar. 31, 2011).
36 See Response to LOI at 5.  In its supplemental response, Main Street acknowledges there were times when it did 
not employ all procedures of its verification process.  See Supplemental Response to LOI at 2.
37 The fact that the name and address in Main Street’s records do not match the name and address of the person 
billed for the service shows that even a cursory examination of the authorization would have determined that it was 
(continued….)
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Federal Communications Commission FCC 11-89
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address used to sign up for service often does not belong to the customer who is billed for the 
service.38 The only information that consistently belonged to the customer whom the Company 
charged was, in fact, his or her telephone number.  Moreover, we find no evidence that, as Main 
Street suggests, consumers authorized the service and then “did not read the information 
presented to them during the sign-up process, had forgotten that they signed up for the service, or 
someone else in the household signed up for and authorized the service.”39 Based on our review 
of the record, it appears that any validation procedure that Main Street actually performed simply 
verified the general existence of the telephone number and that the number was a working 
number – and in no way verified that an enrollee actually in any way intended to subscribe to 
Main Street’s dial-around service.
17. Main Street’s claims that it “verifies” a service request by sending three emails to 
the email address identified on the form is likewise of no consequence.40 The process does not 
require any action on the part of the consumer to confirm either that the consumer received the 
emails or that the consumer signed up for or agreed to be charged for Main Street’s service.  
Indeed, many of the complainants assert they never received any emails or other communications 
from Main Street regarding its long distance service.  This would not be surprising given that, as 
noted above, the email address in Main Street’s records is generally not the consumer’s.  Even if 
a consumer did, in fact, receive this verification material, it is possible, if not probable, that he or 
she might reasonably discard the material as “junk” mail or spam, given that the consumer did 
not create a relationship with, or even know of the existence of, Main Street.  On these facts, if a 
consumer did not authorize Main Street’s service, the mere act of sending an email without 
requiring a response from the consumer is not sufficient “verification.”41
18. Main Street’s success in what appears to be a constructively fraudulent enterprise 
seems to rely on the fact that individuals and businesses the Company enrolled in its service 
failed to notice the unauthorized charges on their multipage telephone bills and so simply 
proceeded to pay them, often unaware that they contained charges from an entity other than their 
own telephone company. The charges were often listed on the last pages of the bill and/or did 
not contain clear descriptions of the services provided.  It would be difficult for someone who 
(Continued from previous page)    
invalid.  Nevertheless, because the so-called authorizations contain names and addresses that are publicly available 
information, matching the billed party’s name and address is no indication that the authorization is valid.
38 See, e.g., Complaint from [REDACTED]; Complaint from [REDACTED]. 
39 See Response to LOI at 2.
40 See Response to LOI at 6.
41 Indeed, we note that much of the identifying information Main Street requests of a person when signing up for its 
long distance service – name, address, email address, telephone number, and date of birth – can be obtained through 
the purchase of aggregated lists of consumers that are commercially sold or from free internet websites such as 
whitepages.com.  Nothing within Main Street’s sign-up webpage prevents the individual who is inputting the data 
from using someone else’s identifying information or otherwise falsifying that data.  If the person signing up for 
Main Street’s service inputs someone else’s telephone number, the person associated with that telephone number 
will be billed by Main Street regardless of whether the other information in the application is correct. (In some cases 
we were not provided with the address of the complainant, but the name was clearly not that of the person 
“authorizing” service).  See, e.g., [REDACTED].
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Federal Communications Commission FCC 11-89
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had never heard of Main Street or “USBI” (the billing aggregator) to recognize an unauthorized 
charge from them on the bill.42  
19. If and when consumers ever discovered Main Street’s charges, the Company 
required them to expend significant time and effort to attempt to have charges removed from 
their bills.  For example, in many cases we reviewed, Main Street made it difficult for 
consumers to obtain full refunds of unauthorized charges, and only offered consumers a partial 
refund.  Complainant [REDACTED].43 In other cases, refunds were not provided until after the 
consumer filed a complaint with a state or federal regulatory authority.  For example, 
Complainant [REDACTED].44
20. As another example of the difficulty consumers experienced in attempting to 
obtain refunds, Complainant [REDACTED].45 Main Street similarly refused to issue a full 
refund to Complainant [REDACTED].46 Numerous other complainants say they were told by 
Main Street’s customer service representatives that someone in the home had ordered the 
services and that the enrollment form was proof that the service was authorized.47 Many 
consumers were instructed to submit their complaints in writing.48 Others were forced to make 
several calls to Main Street before any refund was issued; some were hung up on when they 
called Main Street.49  
21. Based on the record, we conclude that Main Street apparently has willfully and 
repeatedly placed, or caused to be placed, charges on complainants’ telephone bills that they 
never authorized.  The facts suggest that Main Street engaged in this conduct deliberately.  To 
the extent it did not, we find that Main Street either knew, or reasonably should have known, 
through numerous customer inquiries and complaints that many of its customers had not 
authorized service and that most were likely not using its service – yet Main Street nevertheless 
proceeded to charge these consumers for months and sometimes years.  Main Street’s 
dismissive responses to the consumer complaints is further evidence that it apparently is 
deliberately billing consumers for services they did not authorize.  Accordingly, we find that 
Main Street’s cramming constitutes an unjust and unreasonable practice and demonstrates 
apparent willful and repeated violations of section 201(b) of the Act.  
  
42 A practice that “convey[s] insufficient information as to the company’s identity, rates, practices, and range of 
services” may constitute a violation of section 201(b).  See Telecommunications Research & Action Center & 
Consumer Action, 4 FCC Rcd 2157, 2159, ¶ 14 (Com.Car.Bur. 1989).
43 See Complaint from [REDACTED].  See also Complaint from [REDACTED].
44 See Complaint from [REDACTED].
45 See Complaint from [REDACTED].
46 See Complaint from [REDACTED].
47 See, e.g., Complaint from [REDACTED].
48 See, e.g., Complaint from [REDACTED].
49 See, e.g., Complaint from [REDACTED].  See Complaint from [REDACTED].
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Federal Communications Commission FCC 11-89
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B. Proposed Forfeiture Pursuant to Section 503(b) of the Act
22. Section 503(b)(1) of the Act states that any person that willfully or repeatedly 
fails to comply with any provision of the Act or any rule, regulation, or order issued by the 
Commission, shall be liable to the United States for a forfeiture penalty.50 Section 503(b)(2)(B) 
of the Act authorizes the Commission to assess a forfeiture of up to $150,000 for each violation, 
or each day of a continuing violation, up to a statutory maximum of $1,500,000 for a single act 
or failure to act by common carriers.51 In determining the appropriate forfeiture amount, we 
consider the factors enumerated in section 503(b)(2)(E) of the Act, including “the nature, 
circumstances, extent and gravity of the violation, and, with respect to the violator, the degree of 
culpability, any history of prior offenses, ability to pay, and such other matters as justice may 
require.”52  Although the forfeiture guidelines do not establish a forfeiture amount for unjust or 
unreasonable practices, such as the imposition of unauthorized charges on consumers’ telephone 
bills, the guidelines do state that, “. . . any omission of a specific rule violation from the. . . 
[forfeiture guidelines]. . .  should not signal that the Commission considers any unlisted violation 
as nonexistent or unimportant.”53 The Commission retains the discretion to depart from the 
guidelines and issue forfeitures on a case-by-case basis, under its general forfeiture authority 
contained in section 503 of the Act.54  
23. In Long Distance Direct, Inc. (“LDDI”), the Commission found that the 
“imposition of unauthorized charges on consumers’ telephone bills is a practice which is unjust 
and unreasonable within the meaning of section 201(b) of the Act,”55 and assessed a $40,000 
penalty for each cramming violation investigated in that case.56 Consistent with LDDI, we find 
that each charge Main Street caused to be placed on a consumer’s bill without the consumer’s 
authorization constitutes an independent unjust and unreasonable practice, and thus a separate 
and distinct violation of section 201(b) of the Act.  There appear to be thousands of such 
violations in this case for which the Commission is empowered to assess a penalty.57
  
50 47 U.S.C. § 503(b)(1)(B); see also 47 C.F.R. § 1.80(a)(2).
51 47 U.S.C. § 503(b)(2)(B); see also 47 C.F.R. § 1.80(b)(2).  In 2008 the Commission amended section 1.80(b)(2) 
of the rules, 47 C.F.R. § 1.80(b)(2), to increase the maximum forfeiture amounts in accordance with the inflation 
adjustment requirements contained in the Debt Collection Improvement Act of 1996, 28 U.S.C. § 2461.  See 
Amendment of Section 1.80 of the Commission’s Rules and Adjustment of Forfeiture Maxima to Reflect Inflation, 
Order, 23 FCC Rcd 9845 (2008) (inflation adjustment to $150,000/$1,500,000).
52 47 U.S.C. § 503(b)(2)(E).
53 See Forfeiture Policy Statement and Amendment of Section 1.80 of the Rules to Incorporate Guidelines, Report 
and Order, 12 FCC Rcd 17087, 17099, ¶ 22 (1997) (“Forfeiture Policy Statement”); recon. denied, 15 FCC Rcd 303 
(1999).  
54 Forfeiture Policy Statement, 12 FCC Rcd at 17099, ¶ 22.
55 See Long Distance Direct, Inc., Notice of Apparent Liability for Forfeiture, 14 FCC Rcd 314, 333, ¶ 25 (1998).
56 Id. at 337, ¶ 30.
57 As noted in the text, Main Street apparently caused unauthorized charges to be placed on more than 
[REDACTED] bills dated between March 2010 and February 2011.  More than [REDACTED] of these bills date 
from June 2010 – within one year of the instant NAL – and thus remain actionable under the statute of limitations 
set forth in section 503(b)(6)(B) of the Act.  47 U.S.C. § 503(b)(6)(B).
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Federal Communications Commission FCC 11-89
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24. Weighing the facts before us and taking into account the extent and gravity of 
Main Street’s egregious conduct, as well as its culpability and information in the current record 
about its revenues, we find that a total forfeiture amount of $4,200,000 is appropriate under the 
specific circumstances of this case.58  As noted above, Main Street placed unauthorized charges 
of at least $13.90 on more than [REDACTED] telephone bills over a twelve-month period alone 
and therefore billed nearly $[REDACTED] to consumers over that time period through its 
cramming operation.  The forfeiture clearly must exceed this amount in order to serve as an 
adequate deterrent and reflect the apparently intentional nature of Main Street’s conduct.  We 
therefore propose a forfeiture in the amount of $4,200,000. In the event Main Street continues to 
engage in conduct that apparently violates section 201(b)’s prohibition against unjust and 
unreasonable practices, such apparent violations could result in future NALs proposing 
substantially greater forfeitures and revocation of Main Street’s operating authority.  Other third-
party service providers are also on notice that practices such as those engaged in by Main Street 
are unjust and unreasonable, and that we may propose more significant forfeitures in the future 
as high as is necessary, within the range of our statutory authority, to ensure that such companies 
do not charge consumers for unauthorized services.
IV. CONCLUSION
25. We have determined that Main Street Telephone Company apparently violated 
section 201(b) of the Act as identified above.  We have further determined that Main Street 
Telephone Company is apparently liable for a forfeiture in the amount of $4,200,000.
V. ORDERING CLAUSES
26. Accordingly, IT IS ORDERED, pursuant to section 503(b)(2)(B) of the 
Communications Act of 1934, as amended, 47 U.S.C. § 503(b)(2)(B), and section 1.80 of the 
Commission’s rules, 47 C.F.R. § 1.80, that Main Street Telephone Company is hereby 
NOTIFIED of this APPARENT LIABILITY FOR A FORFEITURE in the amount of 
$4,200,000, for willful or repeated violations of section 201(b) of the Act, 47 U.S.C. § 201(b).
27. IT IS FURTHER ORDERED that, pursuant to section 1.80 of the 
Commission’s rules,59 within thirty (30) days of the release date of this Notice of Apparent 
Liability for Forfeiture, Main Street Telephone Company SHALL PAY the full amount of the 
proposed forfeiture or SHALL FILE a written statement seeking reduction or cancellation of the 
proposed forfeiture.
28. Payment of the forfeiture must be made by check or similar instrument, payable to 
the order of the Federal Communications Commission.  The payment must include the 
NAL/Account Number and FRN referenced above.  Payment by check or money order may be 
mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.  
  
58 The $4.2 million penalty we propose is equivalent to applying a $40,000 penalty to 105 violations, but as 
indicated above the record shows that Main Street’s conduct involves a considerably higher number of violations 
during the actionable time period.
59 47 C.F.R. § 1.80.
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Federal Communications Commission FCC 11-89
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Payment by overnight mail may be sent to U.S. Bank – Government Lockbox #979088, SL-MO-
C2-GL, 1005 Convention Plaza, St. Louis, MO 63101.  Payment by wire transfer may be made 
to ABA Number 021030004, receiving bank TREAS/NYC, and account number 27000001.  For 
payment by credit card, an FCC Form 159 (Remittance Advice) must be submitted. When 
completing the FCC Form 159, enter the NAL/Account number in block number 23A (call 
sign/other ID), and enter the letters “FORF” in block number 24A (payment type code).  Main 
Street Telephone Company will also send electronic notification to Johnny.Drake@fcc.gov on 
the date said payment is made.  Requests for full payment under an installment plan should be 
sent to: Chief Financial Officer -- Financial Operations, 445 12th Street, S.W., Room 1-A625, 
Washington, D.C. 20554.  Please contact the Financial Operations Group Help Desk at 1-877-
480-3201 or Email: ARINQUIRIES@fcc.gov with any questions regarding payment procedures.  
29. The written statement, if any, must be mailed both to: Marlene H. Dortch, 
Secretary, Federal Communications Commission, 445 12th Street, SW, Washington, DC 20554, 
ATTN:  Enforcement Bureau – Telecommunications Consumers Division; and to Richard A. 
Hindman, Division Chief, Telecommunications Consumers Division, Enforcement Bureau, 
Federal Communications Commission, 445 12th Street, SW, Washington, DC 20554, and must 
include the NAL/Acct. No. referenced in the caption.  Documents sent by overnight mail (other 
than United States Postal Service Express Mail) must be addressed to: Marlene H. Dortch, 
Secretary, Federal Communications Commission, Office of the Secretary, 9300 East Hampton 
Drive, Capitol Heights, MD 20743.  Hand or messenger-delivered mail should be directed, 
without envelopes, to: Marlene H. Dortch, Secretary, Federal Communications Commission, 
Office of the Secretary, 445 12th Street, SW, Washington, DC 20554 (deliveries accepted 
Monday through Friday 8:00 a.m. to 7:00 p.m. only).  See www.fcc.gov/osec/guidelines.html for 
further instructions on FCC filing addresses.
30. The Commission will not consider reducing or canceling a forfeiture in response 
to a claim of inability to pay unless the petitioner submits: (1) federal tax returns for the most 
recent three-year period; (2) financial statements prepared according to generally accepted 
accounting practices; or (3) some other reliable and objective documentation that accurately 
reflects the petitioner’s current financial status.  Any claim of inability to pay must specifically 
identify the basis for the claim by reference to the financial documentation submitted.
31. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability for 
Forfeiture shall be sent by Certified Mail Return Receipt Requested and First Class mail to Main 
Street Telephone Company, attention:  Steven A. Augustino, Kelly Drye & Warren, LLP, 
Washington Harbour, Suite 400, 3050 K Street, N.W., Washington, D.C. 20007-5108.  
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
Secretary