FCC Record, Volume 28, No. 4, Pages 2764 to 3699, March 18 - March 29, 2013 Page: 2,821
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5. On January 23, 2012, the Bureau issued a Letter of Inquiry (LOI) and subpoena to ANI
seeking information to assess whether the Company complied with the TRS Rules and Commission
orders governing Internet-based TRS, including whether the Company had established a reasonable
process for verifying information provided by users registering for ten-digit numbers.'3 The LOI and
subpoena required ANI to submit specific information associated with registrations completed since
January 1, 2009.
6. On February 22, 2012, ANI submitted its response, which indicated that ANI may have
billed the TRS Fund for calls by unregistered Internet-based TRS users after the date that such conduct
was impermissible.'4 In subsequent discussions, the Company acknowledged that it had determined that
ANI's subcontractor failed to register any IP Relay users but still processed calls and ANI billed the TRS
Fund for them. After conducting an internal review, the Company determined that it was financially
unable to proceed as an ongoing operation and decided to cease providing TRS.
7. ANI subsequently met with the Bureau for purposes of reaching agreement to resolve all
outstanding issues related to its compliance with the Act, the Rules, and Commission orders, and
terminating the Bureau's Investigation.
8. The Administrator is currently holding $183,462.65 that is associated with claims for
compensation filed by ANT.
III. TERMS OF AGREEMENT
9. Adopting Order. The Parties agree that the provisions of this Consent Decree shall be
subject to final approval by the Bureau by incorporation of such provisions by reference in the Adopting
10. Jurisdiction. ANI agrees that the Bureau has jurisdiction over it and the matters
contained in this Consent Decree and that the Bureau has the authority to enter into and adopt this
11. Effective Date; Violations. The Parties agree that this Consent Decree shall become
effective on the Effective Date, as defined herein. As of the Effective Date, the Adopting Order and this
Consent Decree shall have the same force and effect as any other order of the Commission. Any violation
of the Adopting Order or of the terms of this Consent Decree shall constitute a separate violation of a
Commission order, entitling the Commission to exercise any rights and remedies attendant to the
enforcement of a Commission order.
12. Termination of Tnvestigation. In express reliance on the covenants and representations
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to
terminate the Investigation. In consideration for the termination of the Investigation, ANI agrees to the
terms, conditions, and procedures contained herein. ANI also agrees that for a period of two years from
the Effective Date, neither the Company nor its principals will engage in any business activities related to
provisioning or otherwise providing any form of TRS (e.g., offer TRS, manage TRS call centers,
subcontract to provide any services) where the Company or any Company principal is reimbursed directly
13 See Letter from Richard A. Hindman, Chief, TCD, FCC Enforcement Bureau, to Kent Charugundla,
President, American Network, Inc., (January 23, 2012) (on file in EB-11-TC-021/EB-TCD-I 2-00000342).
14 See Letter from Kent Charugundla, President, American Network, Inc., to Sharon Lee, Deputy Division
Chief, TCD, FCC Enforcement Bureau (February 23, 2012) (on file in EB-I 1-TC-021/EB-TCD-12-00000342).
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United States. Federal Communications Commission. FCC Record, Volume 28, No. 4, Pages 2764 to 3699, March 18 - March 29, 2013, book, March 2013; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc177414/m1/74/: accessed May 28, 2018), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.