Federal Communications Commission FCC 18-27
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Gregory Manasher et al.
Petition for Declaratory Ruling
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)
)
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CG Docket No. 98-170
DECLARATORY RULING
Adopted:  March 13, 2018 Released:  March 15, 2018
By the Commission:  Commissioner O’Rielly approving in part, dissenting in part, and issuing a statement.
I. INTRODUCTION
1. With this order, we respond to eight questions posed by a federal district court related to 
a telecommunications carrier’s bill descriptions and whether they violate the Commission’s Truth-in-
Billing rules and Section 201(b) of the Communications Act of 1934, as amended (the Act).
1
   We find 
that vague charge descriptions on a bill may violate the rules and the Act, but emphasize that a final 
determination will require the court to apply our ruling to the facts at issue in the case. 
II. BACKGROUND
A. The Truth-in-Billing Rules
2. In 1999, the Commission adopted Truth-in-Billing rules in response to growing consumer 
confusion related to billing for telecommunications service, and in response to an increase in the number 
of entities willing to take advantage of this confusion.
2
  The statutory authority for the rules is Section 
201(b) of the Act, which prohibits unjust and unreasonable practices by telecommunications carriers,
3
 and 
Section 258, which prohibits slamming, i.e., switches in carriers without following Commission-
1
 See Gregory Manasher and Frida Sirota, Plaintiffs, v. NECC Telecom, Defendant, Opinion & Order Certifying 
Questions to the FCC, Case No. 2:06-cv-10749, 2010 WL 1416974 (E.D. Mich. April 8, 2010) (Manasher Opinion 
and Order).  The court’s questions have been presented to us in a petition for declaratory ruling jointly filed by the 
parties to the litigation.  See Gregory Manasher et al., Petition for Declaratory Ruling, CG Docket No. 98-170, filed 
July 13, 2010 (Petition) attached to Consumer and Governmental Affairs Bureau Seeks Comment On Petition For 
Declaratory Ruling of Gregory Manasher, et al. On Applicability of the Communications Act and Commission Rules 
Regarding Truth-In-Billing, Public Notice, 27 FCC Rcd 13010 (CGB 2012) (Public Notice).  
2
 See Truth-in-Billing and Billing Format, First Report and Order and Further Notice of Proposed Rulemaking, CC 
Docket No. 98-170, 14 FCC Rcd 7492 (1999) (Truth-in-Billing Order).
3
 Id.  Section 201(b) requires that common carriers’ “practices . . . for and in connection with . . . communications 
service, shall be just and reasonable, and any such . . . practice . . .  that is unjust or unreasonable is hereby declared 
to be unlawful . . . .”  47 U.S.C. § 201(b).  The Truth-in-Billing Order noted that “the Supreme Court has ruled that 
Section 201(b) provides the Commission with authority to implement all of the provisions of the Act, including 
those that apply to intrastate communications.” Truth-in-Billing Order, 14 FCC Rcd at 7503-04, para. 21; see also 
AT&T Corp. v. Iowa Utils. Bd., 119 U.S. 721 (1999). 
Federal Communications Commission FCC 18-27
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prescribed procedures to verify the consumer’s choice in carriers.
4
  In promulgating the Truth-in-Billing 
rules, the Commission sought “to define more specifically what would constitute a violation of Section 
201 in the billing context for the covered carriers”
5
 to help consumers identify potentially erroneous 
charges.
3. Section 64.2401(b) of the Truth-in-Billing rules requires that charges contained on 
telephone bills be “accompanied by a brief, clear, non-misleading, plain language description of the 
service or services rendered.”
6
  In responding to the court’s questions, we think it important to highlight 
the approach adopted by the Commission in adopting these rules.  That approach was to adopt “broad, 
binding principles to promote truth-in-billing, rather than mandate detailed rules that would rigidly govern 
the details or format of carrier billing practices.”
7
  It “reflects a recognition that there are typically many 
ways to convey important information to consumers in a clear and accurate manner.”
8
  
4. To ensure full (and non-misleading) descriptions of the service charges that appear on the 
bill, the Commission required that the services included on the bill must be accompanied by “a brief, 
clear, plain language description of the services rendered.”
9
  The Commission singled out for criticism 
charges identified simply as “monthly fee” or “basic access,” or “miscellaneous” charges, without further 
explanation.
10
  The goal is to require sufficient clarity “to enable a customer reasonably to identify and to 
understand the service for which the customer is being charged.”
11
  The Commission noted that “clear 
communication and disclosure of the nature of the service for which payment is expected is fundamental 
to a carrier’s obligation of reasonable charges and practices.”
12
B. The Petition
5. The Petition arises from litigation before the United States District Court for the Eastern 
District of Michigan, Manasher et al. v. NECC Telecom.
13
  Gregory Manasher and Frida Sirota 
(collectively, “Plaintiffs”) alleged that NECC Telecom (NECC) violated Section 64.2401 and Section 
201(b) by billing, charging, and collecting monies from Plaintiffs which were unjustly, unreasonably, and 
deceptively billed as “recurring fees” and “other fees.”
14
  The Plaintiffs also alleged that NECC billed 
Plaintiffs “for amounts in excess of the actual cost for telephone services.”
15
  
4
 Id. at 7503-04, para. 21.  Section 258(a) makes it unlawful for any telecommunications carrier to “submit or 
execute 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 Commission shall prescribe.”  47 U.S.C. § 258(a).  
5
 Truth in Billing Order, 15 FCC Rcd at 7506, para. 24.
6
 47 CFR § 64.2401(b).
7
 Truth in Billing Order, 14 FCC Rcd at 7498, para 9.
8
 Id. at 7499, para. 10.
9
 Id. at 7516, para. 38.
10
 Id. at 7517-18, paras. 40-41.
11
 Id. at 7517-18, para. 40.
12
 Id. at 7516, para. 37.
13
 Gregory Manasher and Frida Sirota, Plaintiffs, v. NECC Telecom, Defendant, Motion for Leave to File a First 
amended Complaint, Case No. 2:06-cv-10749 (E.D. Mich. Oct. 31, 2006) (First Amended Complaint).
14
 Id. at para. 39.
15
 Id. at para. 40.
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6. NECC disagreed, and argued that a violation of Section 64.2401 does not necessarily 
constitute a violation of Section 201(b).
16
  Both parties addressed Global Crossing Telecommunications, 
Inc. v. Metrophones Telecommunications, Inc., in which the Supreme Court held that a violation of a 
regulation that lawfully implements Section 201(b)’s requirements is also necessarily a violation of 
Section 201(b) itself.
17
  NECC asserted that “unlike the post-rulemaking decision relied on by the 
Supreme Court in Global Crossing, the FCC has not made an unequivocal ruling that a violation of 
Section 64.2401 is unreasonable under Section 201(b).”
18
 Plaintiffs argued that the Commission did in 
fact make such a ruling, citing the Commission’s statement that “a carrier’s provision of misleading or 
deceptive billing information is an unjust and unreasonable practice in violation of Section 201(b) of the 
Act.”
19
  
7. The court found that the Commission had not yet ruled on whether a violation of Section 
64.2401 is unreasonable for purposes of Section 201(b)
20
 and referred questions on Truth-in-Billing 
practices to the Commission for consideration under the doctrine of primary jurisdiction.
21
  The court 
emphasized that it was not asking the Commission to make factual findings.
22
  Manasher, Sirota, and 
NECC then jointly filed the Petition seeking a declaratory ruling on whether the billing practices 
identified by the court violate the Commission’s Truth-in-Billing rules and, if so, whether these practices 
also violate Section 201(b).  
8. According to the Petition, the court asked these eight questions:
23
  
1.  “To the extent that billing information is deemed to be unclear, rather than misleading or 
deceptive, under 47 C.F.R. §64.2401(b), would such a violation of 47C.F.R. §64.2401(b) also 
violate 47 U.S.C. §201(b)?”
2.  “Does listing charges on a phone bill without also providing an accompanying description of 
what those charges are: a. Violate 47 C.F.R, §64.2401(b)? i. If so, would this violation constitute 
the provision of: (1) misleading billing information and/or; (2) deceptive billing information 
and/or; (3) unclear billing information? ii. If so, and if this violation constitutes only unclear –   
but not also misleading or deceptive – billing information, would this violation also violate 47 
U.S.C. §201(b)?”
3.  “Does listing a charge for a ‘recurring fee’ without providing an explanation on the bill as to 
what a ‘recurring’ fee is: a. Violate 47 C.F.R. §64.2401(b)? i. If so, would this violation constitute 
the provision of: (1) misleading billing information and/or; (2) deceptive billing information 
and/or; (3) unclear billing information? ii. If so, and if this violation constitutes only unclear –  
but not also misleading or deceptive – billing information, would this violation also violate 47 
U.S.C. §201(b)?”
16
 Gregory Manasher and Frida Sirota, Plaintiffs, v. NECC Telecom, Defendant, Order Denying Plaintiff’s Motion 
for Modification of the Court’s Order Dated September 18, 2007, Case No. 2:06-cv-10749, 2008 WL 2622956 at *2 
(E.D. Mich. July 2, 2008) (Manasher Order).
17
 Id. at *3; see also Global Crossing Telecommunications, Inc. v. Metrophones Telecommunications, Inc., 550 U.S. 
45 (2007) (Global Crossing).
18
 Manasher Order at *15.
19
 Id. (citing Truth-in-Billing Order, 14 FCC Rcd at 7506, para. 24).
20
 Id.
21
 Id. at *16.
22
 Id. at *4.
23
 Petition at 2-5.
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4. “Does charging $4.99 for what is called a ‘recurring fee’ (without a description) for being late 
and a 1.5% charge which is called a ‘late fee’: a. Violate 47 C.F.R. §64.2401(b)? i. If so, would 
this violation constitute the provision of: (1) misleading billing information and/or; (2) deceptive 
billing information and/or; (3) unclear billing information? ii. If so, and if this violation 
constitutes only unclear – but not also misleading or deceptive – billing information, would this 
violation also violate 47 U.S.C. §201(b)?”
5. “Does charging $4.99 for what is called a ‘recurring fee’ (without a description) for receiving a 
special rate: a. Violate 47 C.F.R. §64.2401(b)? i. If so, would this violation constitute the 
provision of: (1) misleading billing information and/or; (2) deceptive billing information and/or; 
(3) unclear billing information? ii. If so, and if this violation constitutes only unclear – but not 
also misleading or deceptive – billing information, would this violation also violate 47 U.S.C. 
§201(b)?”
6. “Does listing a charge for ‘other fees’ without providing an explanation on the bill as to what 
‘other fees’ are: a. Violate 47 C.F.R. §64.2401(b)? i. If so, would this violation constitute the 
provision of: (1) misleading billing information and/or; (2) deceptive billing information and/or; 
(3) unclear billing information? ii. If so, and if this violation constitutes only unclear – but not 
also misleading or deceptive – billing information, would this violation also violate 47 U.S.C. 
§201(b)?”
7. “Does the improper charging and collection of a late fee without refunding the late fee after 
discovery of the error unless a customer requested a refund: a. Violate 47 C.F.R. §64.2401(b)? i. 
If so, would this violation constitute the provision of: (1) misleading billing information and/or; 
(2) deceptive billing information and/or; (3) unclear billing information? ii. If so, and if this 
violation constitutes only unclear – but not also misleading or deceptive – billing information, 
would this violation also violate 47 U.S.C. §201(b)?”
8. “Does the incorrect tallying of monthly charges (the amount billed to the customer is greater 
than the tally of the individual charges): a. Violate 47 C.F.R. §64.2401(b)? i. If so, would this 
violation constitute the provision of: (1) misleading billing information and/or; (2) deceptive 
billing information and/or; (3) unclear billing information? ii. If so, and if this violation 
constitutes only unclear – but not also misleading or deceptive – billing information, would this 
violation also violate 47 U.S.C. §201(b)?”
9. On October 16, 2012, the Consumer and Governmental Affairs Bureau sought comment 
on the Petition.
24
  Three comments were filed.  The National Association of State Utility Consumer 
Advocates (NASUCA) stated that “there is nothing more violative of the concept of Truth-in-Billing than 
the placement of charges on consumer bills with descriptions so vague that consumers cannot ascertain 
what the billings are for or whether the billings were authorized and hence owing.”
25
  While the 
Independent Telephone and Telecommunications Alliance (ITTA) acknowledged the Truth-in-Billing 
rules’ objective to ensure bill clarity for consumers, it emphasized the need to recognize carrier flexibility 
and discretion in achieving compliance.
26
  United States Telecom Association (USTelecom), on the other 
hand, argued that bills for telecommunications services can vary in bill formats and presentations, 
including length, names of charges, order of charges, and level of detail.  USTelecom argues that it would 
be premature to answer the Petition’s questions absent facts such as contractual agreements between the 
parties (which may explicate terms used on the bill face), the bill format, information provided by the 
24
 See Consumer and Governmental Affairs Bureau Seeks Comment on Petition for Declaratory Ruling of Gregory 
Manasher, et al. on Applicability of the Communications Act and Commission Rules Regarding Truth-in-Billing, CG 
Docket No. 98-170, Public Notice, 27 FCC Rcd 13010 (2012) (Public Notice).
25
 NASUCA Comments at 2.
26
 ITTA Comments at 2, 4.
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carrier outside the bill, and context.
27
  Plaintiffs argue that “violations of the truth-in-billing rules due to 
unclear information are . . . violations of Section 201(b) of the Act.”  They also argue that USTelecom’s 
comments related to factors and context are not responsive to the Commission’s Public Notice, in light of 
the court’s statement that it was not asking the Commission to make factual findings pertinent to the 
case.
28
III. DISCUSSION
10. Below we answer each of the court’s questions in turn, as the Petition presents them.  As 
a result, we have not applied the answers to any specific set of facts.    
A. Question One 
11. We find that billing information that is unclear, rather than misleading or deceptive, 
under Section 64.2401(b) also violates Section 201(b).  The Commission’s Truth-in-Billing requirements, 
including Section 64.2401(b), were established “to define more specifically what would constitute a 
violation of Section 201 in the billing context for the covered carriers.”
29
  As the Commission also stated, 
“[P]roviding clear communication and disclosure of the nature of the service for which payment is 
expected is fundamental to a carrier’s obligation of reasonable charges and practices.”
30
  The reference to 
the obligation of “reasonable charges and practices” was to the language of Section 201(b).
31
 
12. Our view is consistent with the Supreme Court’s decision in Global Crossing.  In Global 
Crossing, the Supreme Court held that “to violate a regulation that lawfully implements Section 201(b)’s 
requirements is to violate the statute.”
32
  
B. Question Two
13. We clarify that listing charges on a bill with no accompanying description violates 
Section 64.2401(b) and thus Section 201(b), except where context and the mere name of the charge makes 
its nature so obvious to the consumer that no description is necessary.
33
  As noted above, Section 
64.2401(b) requires that telephone bills contain a brief, clear, non-misleading, plain language description 
of services, and that the bill content is sufficiently clear in scope for a reasonable consumer to 
understand.
34
  Section 64.2401(b) therefore clearly requires that a consumer’s monthly bill contain 
descriptions of all billed charges so consumers are fully informed about the basis of the charges.
35
    The 
Commission’s rule is designed to ensure that the billing information provides customers with information 
sufficient to allow them to accurately assess that the services for which they are billed correspond to those 
that they have requested and received, and that the cost assessed for those services conform to their 
understanding of the price charged.
36
  As stated above, if the charge violates Section 64.2401(b), it  
violates Section 201(b) as well.  
27
 USTelecom Reply Comments at 3.
28
 Plaintiffs’ Reply Comments at 2-3.
29
 Truth-in-Billing Order, 14 FCC Rcd at 7506, para. 24.
30
 Id. at 7516, para. 37.
31
 See note 3 supra.
32
 Global Crossing, 550 U.S. at 54.
33
 See infra para. 16.
34
 See 47 CFR § 64.2401(b).
35
 See, e.g., Empowering Consumers To Prevent and Detect Billing For Unauthorized Charges (“Cramming”) et al.,  
Report and Order and Further Notice of Proposed Rulemaking, 27 FCC Rcd 4436, 4474, para. 106 (2012) (Truth-in-
Billing rules “are sufficiently broad to encompass all charges that appear on a telephone bill . . . . ”).  
36
 47 CFR § 64.2401(b).
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C. Question Three
14. We find that a charge labeled “recurring fee” without additional description or clarifying 
context violates the rules and Section 201(b), even if non-misleading.  When the Commission adopted 
Section 64.2401(b), it expressed concern about complaints from consumers who alleged that they often 
paid unauthorized recurring charges for several months before realizing the questionable nature of such 
charges.
37
  The Commission indicated its concern with charges identified on local telephone bills simply 
as “monthly fee” without further explanation.
38
  We find “recurring fee,” absent additional description or 
clarifying context, is similarly confusing and so unclear as to not provide consumers the ability to detect 
billing errors because such a charge is not specific enough without further description or clarifying 
context to ensure that the customer can reasonably understand the reason for the charge and whether it is 
consistent with the service they received.  
15. As noted above, the Commission determined in adopting its Truth-in-Billing rules to 
adopt broad, binding principles and not to mandate detailed rules that would rigidly govern the details or 
format of carrier bills.  This approach reflects a recognition that “there are typically many ways to convey 
important information to consumers in a clear and accurate manner.”
39
  Thus, we emphasize that the 
context of such a charge would inform our analysis.  For example, if a “recurring fee” were the only 
charge to appear on a customer’s monthly phone bill, we would be more likely to find that label clear, 
whereas if such a charge appeared on a bill with other fees that also recur from one bill to the next, we 
would be more likely to find it unclear.  
D. Question Four
16. We find that a 1.5% charge labelled “late fee” that lacks any additional description does 
not violate Section 64.2401(b) or Section 201(b).  “Late fee” is sufficiently clear and non-misleading that 
it does not require additional description.  In the Truth-in-Billing Order, the Commission noted that while 
“carriers must provide sufficient information . . . full descriptions do not mean redundant or unnecessary 
explanations.”
40
  The Commission further stated that carriers need not define those terms that are already 
generally understood by consumers, such as “long distance service.”
41
  We believe that the general 
reference to a “late fee” in this case similarly is sufficiently understood by consumers to not require 
additional description.  
17. By contrast, we find that a $4.99 charge labelled “recurring fee” that is imposed “for 
being late” without additional explanation or clarifying context is inherently misleading and unclear and 
thus violates the Truth-in-Billing rules and thus Section 201(b).  
E. Question Five 
18. Similar to our answer to Question Three above, a $4.99 charge for receiving a special rate 
simply labeled “recurring fee” without additional description or clarifying context is unclear and violates 
the Truth-in-Billing rules and Section 201(b).  As we found with Question Three above, a charge labeled 
simply “recurring fee” without additional explanation or clarifying context – which here is $4.99 for 
receiving a “special rate” – is unclear, even if it is not misleading in that it could occur from bill-to-bill.  
And, as we have found above, any such violation of the Truth-in-Billing rules would also violate Section 
201(b).  
37
 See Truth-in-Billing Order, 14 FCC Rcd at 7514, para. 34.  
38
 See id. at 7517, para. 39 (“many complaints we have received involve charges identified on local telephone bills 
simply as ‘monthly fee’ or ‘basic access,’ without further explanation”).
39
 Id. at 7499, para. 10.
40
 Truth-in-Billing Order, 14 FCC Rcd at 7518, para. 41.
41
 Id.
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19. We again emphasize that the context of such a charge (e.g., whether and how the 
consumer is informed of the nature of any such “special rate”) would inform our analysis.  As noted 
above, if such a “recurring fee” charge appeared on a bill with other fees that also recur from one bill to 
the next, we would be more likely to find it unclear.
F. Question Six
20. We find that labeling a charge as “other fees” without additional explanation or clarifying 
context is unclear and violates the Truth-in-Billing rules and Section 201(b).  As with our answers to 
Questions Three and Five above, we find that “other fees” is so unclear in description that the customers 
cannot reasonably be expected to understand the reason for the charge and whether it is consistent with 
the service they received absent additional explanation or clarifying context.  
21. We emphasize that the context of such a charge would inform our analysis.  For example, 
if such a charge appeared on a bill with additional fees similarly labeled with broad descriptions like 
“other fees,” we would be more likely to find it unclear in description.
G. Question Seven
22. The Truth-in-Billing rules focus on the format and clarity of a consumer bill, and do not 
reach the actual bill charge.
42
  Thus, charging and collecting a late fee without refunding the late fee after 
discovery of the error does not violate the Truth-in-Billing rules.
43
  We have not been asked, and do not 
determine, whether or when such a practice may violate any other Commission rule or provision of the 
Act.
44
   
H. Question Eight
23. For similar reasons, incorrect tallying of monthly charges so that the billed amount is 
greater than the individual charges does not violate our Truth-in-Billing rules,
45
 which focus on bill 
format and clarity.  While such a bill might be confusing because of calculation discrepancies, the 
customer would be in a position to read the bill and obtain clarification of the error from the carrier, and 
thereby to have been provided enough information so as to reasonably identify and understand the service 
being charged.  We have not been asked, and do not determine, whether or when such a practice may 
violate any other Commission rule or provision of the Act.
46
 
42
 Id. at 7496, para. 4 (noting that the truth-in-billing rules are intended to ensure “that consumer telephone bills be 
clearly organized, clearly identify the service provider, and highlight any new providers” and “contain clear and 
conspicuous disclosure of any information the consumer may need to make inquiries about, or contest charges, on 
the bill”).  The only exception to this principle, not relevant here, is that universal service charges and regulatory 
fees for which the Commission has indicated it is unreasonable and misleading to collect amounts that exceed any 
caps on those charges.  See Truth-in-Billing and Billing Format; National Association of State Utility Consumer 
Advocates’ Petition for Declaratory Ruling Regarding Truth-in-Billing, 20 FCC Rcd 6448, 6461-62, paras. 28-29 
(2005).
43
 Petition at 4.
44
 However, we note that other provisions of the Act and the Commission’s rules may apply to this set of facts. For 
example, section 201 of the Act requires all telecommunications carrier “charges” to be “just and reasonable.” 47 
U.S.C. § 201.
45
 Id. at 4-5.
46
 However, we note that other provisions of the Act and the Commission’s rules may apply to this set of facts. For 
example, section 201 of the Act requires all telecommunications carrier “charges” to be “just and reasonable.” 47 
U.S.C. § 201.
Federal Communications Commission FCC 18-27
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IV. ORDERING CLAUSES
24. Accordingly, IT IS ORDERED, pursuant to sections 1-4, and 201(b) of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 151-54, 201(b), and sections 1.2 and 64.2401(b) 
of the Commission’s rules, 47 CFR §§ 1.2, 64.2401(b), that the Petition for Declaratory Ruling filed by 
Gregory Manasher et al. in CG Docket No. 98-170 on July 13, 2010, IS GRANTED to the extent set forth 
herein and IS OTHERWISE DENIED.
25. IT IS FURTHER ORDERED that this Declaratory Ruling shall be effective upon release.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
Secretary
Federal Communications Commission FCC 18-27
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APPENDIX A
List of Commenters
The following parties filed comments in response to the October 16, 2012, Public Notice (CG Docket 98-
170):
Commenter Abbreviation
The Independent Telephone & Telecommunications Alliance ITTA
National Association of State Utility Consumer Advocates NASUCA
United States Telecom Association USTelecom
Federal Communications Commission FCC 18-27
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STATEMENT OF 
COMMISSIONER MICHAEL O’RIELLY
APPROVING IN PART AND DISSENTING IN PART
Re: Gregory Manasher et al. Petition for Declaratory Ruling, CG Docket No. 98-170.
When the Commission approved the 1999 Truth-in-Billing Order, it repeatedly emphasized that it 
chose to “adopt broad, binding principles to promote truth-in-billing, rather than mandate detailed rules 
that would rigidly govern the details or format of carrier billing practices” because the agency wanted to 
“allow carriers considerable discretion to satisfy their obligations.”
1
  Indeed, the Commission 
“envision[ed] that carriers may satisfy these obligations in widely divergent manners that best fit their 
own specific needs and those of their customers.”
2
  These often serve as ways providers use to 
differentiate themselves from their competitors.  
While protecting consumers from unscrupulous providers seeking to permeate confusion or 
downright deception remains a key obligation of the Commission, I am concerned that the Declaratory 
Ruling, issued on the basis of a 2006 court challenge and a record that concluded in 2012, could now be 
read to limit the scope of intentional truth-in-billing discretion.  As the item acknowledges, commenters 
emphasized the need to retain carrier discretion and noted that charges that might appear to lack context 
on the face of the bill may actually be clear when read in conjunction with the other materials, including 
the contract or other information provided apart from the bill itself.  Therefore, I disagree with the 
portions of this item that suggest that clarifying information must be contained on the bill itself.  These 
same commenters also expressed concerns, which I see some merit in, about broadly answering questions 
about billing practices that are, by their very nature, fact-specific. 
I am also troubled that we take this action, which understandably only applies to traditional 
common carrier voice providers, against the backdrop of a flourishing voice market.  If consumers are 
unhappy with the level of detail contained on their traditional voice telephone bills, the market has 
responded by providing a number of other options to choose from, many of which offer advanced 
technological capabilities.  In the presence of this reality this item should strike a more careful balance.  
Instead, its effort to explicitly or implicitly constrain billing practices could make compliance more 
burdensome for providers of legacy services or confuse consumers with more billing detail than helpful.  
1
 Truth-in-Billing and Billing Format, First Report and Order and Further Notice of Proposed Rulemaking, CC 
Docket No. 98-170, 14 FCC Rcd 7492, paras. 6, 9 (1999).
2
 Id. at para. 9.