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INTRODUCTION \ I. A. 1. a.(1)(a) i) a) I. 1. 1. a.(1)(a) i) a) By the Commission:  XG41. ` ` In this order we grant in part and deny in part a formal complaint filed by  X04Consumer.Net, pro se, against AT&T Corporation (AT&T) pursuant to section 208 of the Communications Act of 1934, as amended (the Act). Consumer.Net seeks a Commission order (1) declaring that AT&T's telemarketing practices at issue violated the Telephone  X4Consumer Protection Act of 1991 (TCPA)D yOf'ԍ47 U.S.C.  227.D and certain of the Commission's rules and orders implementing the TCPA; (2) enjoining AT&T from conducting further telephone solicitations;  X4and (3) imposing fines of approximately $100 million against AT&T.X {O 'ԍSee Consumer.Net Brief at 14; see also Consumer.Net Complaint at 56 (Complaint). For the reasons discussed below, we find that, on one occasion, AT&T violated the Commission's rules by failing to make a copy of its donotcall policy available upon demand. We also find that, on one occasion, AT&T violated the Commission's rules by initiating a telephone solicitation despite a residential telephone subscriber's prior donotcall request. We further find that, with respect to all of the other alleged violations of law, Consumer.Net has failed to satisfy its burden of proof. "5"0*''JJ "Ԍ X'ԙ<g II. BACKGROUND Đ X'\  X'A.The Telephone Consumer Protection Act  X42. ` ` On December 20, 1991, Congress enacted the TCPA, which amended Title II of the Act by adding a new section, 47 U.S.C.  227. The TCPA, among other things, directed the Commission to establish regulations to protect the privacy rights of citizens by  X_4restricting the use of the telephone network for unsolicited advertising.b_ yO'Ѝ47 U.S.C.  227. An "unsolicited advertisement" is defined as "any material advertising the commercial availability or quality of any property, goods, or services which is transmitted to any person without that person's prior express invitation or permission." 47 U.S.C.  227(a)(4). The TCPA also restricts the use of automatic telephone dialing systems, prerecorded voice messages, and telephone facsimile machines for  {O 'telemarketing purposes. See id. Those restrictions are not at issue in this proceeding.b In particular, the TCPA instructed the Commission to adopt rules "concerning the need to protect residential telephone subscribers' privacy rights to avoid receiving telephone solicitations to which they  X 4object."J z yOE'ԍ47 U.S.C.  227(c)(1).J  X 43. ` ` As directed by Congress, the Commission established rules governing telephone solicitations that balanced the privacy concerns that the TCPA seeks to protect against the  X 4continued viability of the telemarketing industry.:  {Oy'ԍSee H.R. Rep. No. 102317, 102nd Cong. at 12 (1991) (stating that the "bill makes several findings regarding modern telemarketing technology and practices; intrusions upon individual privacy rights and public  {O 'safety concerns; and the need for a federal solution that both protects the privacy rights of individual residential  {O'telephone subscribers and permits legitimate telemarketing practices) (emphasis added). See also TCPA Report  {O'and Order, 7 FCC Rcd at 8752. A "telephone solicitation" is defined as: Xthe initiation of a telephone call or message for the purpose of encouraging the purchase or rental of, or investment in, property, goods, or services, which is transmitted to any person, . . . [not including] a call or message (A) to any person with that person's prior express invitation or permission, (B) to any person with whom the caller has an established business relationship, or (C) by a tax exempt nonprofit organization.   {O'47 U.S.C.  227(a)(3). The Commission also adopted rules and procedures, inter alia, governing solicitations by facsimile machines and by autodialers. Those rules are not at issue in this proceeding.: As part of this rulemaking, the Commission concluded that requiring the maintenance of companyspecific donotcall lists would be the most effective and efficient means for telephone subscribers to avoid unwanted  Xy4telephone solicitations.Qy {O#'ԍSee id. at 8765, para. 23.Q Thus, the Commission adopted a rule requiring that no person or entity shall engage in any telephone solicitation unless such person or entity has instituted"b^0*%%JJ&" procedures for maintaining a list of residential subscribers who do not wish to be called by  X4that person or entity (donotcall list).]X yOb'ԍ47 C.F.R.  64.1200(e)(2) (stating that "no person or entity shall initiate any telephone solicitation to a residential telephone subscriber . . . unless such person or entity has instituted procedures for maintaining a list of persons who do not wish to receive telephone solicitations . . . .").]  X44. ` ` The Commission also adopted specific rules for establishing and maintaining  X4such companyspecific donotcall lists. {O= 'ԍSee TCPA Report and Order, 7 FCC Rcd at 8766, para. 24; see also 47 C.F.R.  64.1200(e)(2)(i)(vi). The Commission's rules require, among other things, that persons or entities making telephone solicitations to residential telephone subscribers must: (1) develop written policies for maintaining their donotcall lists and make such written policies available upon demand; (2) inform and train their personnel engaged in any aspect of telephone solicitation about the existence and use of the donotcall list; (3) place consumers that request not to receive further telephone solicitations on a donotcall list; (4) identify themselves and the entity on whose behalf the telephone solicitation is made to called parties; and (5) honor each donotcall request for 10 years from the time the request is made. The Commission further concluded that, in the absence of a specific request to the contrary, a residential telephone subscriber's donotcall request generally applies only to the particular business entity making the call (or on whose behalf the call is being made), rather  X 4than to entities affiliated with the soliciting entity. z {O'ԍSee 47 C.F.R.  64.1200(e)(2)(iv); see also TCPA Report and Order, 7 FCC Rcd at 8767, para. 24. Finally, our rules establish that the entity on whose behalf the solicitation is made ultimately will be liable for the maintenance of its  Xy4donotcall list and for any problems arising in the maintenance and accuracy of the list.n y  {O6'ԍSee TCPA Report and Order, 7 FCC Rcd at 8766, para. 24.n  XK' B.Consumer.Net's Complaint   X45. ` ` Consumer.Net alleges that AT&T violated the TCPA and Commission rules  X4regarding telephone solicitations "in virtually every aspect of [its] telemarketing program."  yOU'ԍComplaint at 1. Consumer.Net appears to be an organization primarily devoted to curbing unwanted telephone solicitations. Consumer.Net did not describe its functions or purposes in either its complaint or in subsequent pleadings. Based on information gleaned from Consumer.Net's webpage, Consumer.Net purports to  {O 'inform consumers about their rights regarding the receipt of unwanted telephone solicitations. See Consumer.Net's web page (visited March 3, 1999) . Russell Smith is the  {O?"'director of Consumer.Net. See Consumer.Net Complaint at 6. Consumer.Net bases these allegations on telephone solicitations from AT&T (or AT&T's agent) to Consumer.Net's director, Russell Smith (Smith), and two additional residential" 0*%%JJ{"  X4telephone subscribers, Robert Biggerstaff (Biggerstaff) and Richard Zelma (Zelma). " yOy'ԍConsumer.Net attached to its complaint supporting factual statements from Biggerstaff and Zelma, who are not parties to the complaint. Consumer.Net does not allege that it was harmed by the allegedly unlawful  {O 'conduct. See 47 U.S.C.  208 (stating that "[n]o complaint shall at any time be dismissed because of the absence of direct damage to the complainant.").  In particular, Consumer.Net contends that AT&T violated the TCPA and Commission rules by failing: (1) to provide AT&T's written donotcall policy to Biggerstaff and Zelma upon  X4demand;_  {O 'ԍSee Consumer.Net Brief at 2, 4, 6._ (2) to properly record Biggerstaff and Zelma's donotcall requests;PD {O 'ԍSee id. at 4, 810.P (3) to apply  X4Zelma's donotcall request to AT&T's affiliated entities;H {O+ 'ԍSee id. at 1112.H and (4) to honor Zelma's donot X4call request for 10 years.Fh  {O'ԍSee id.Ġat 5. F   X_'C III. DISCUSSION Đ\  X1' A.The Complainant Has the Burden of Proof in a Formal Complaint Proceeding.  X 46. ` ` It is well established that the complainant has the burden of proof in a formal  X 4complaint proceeding under section 208 of the Act.P  {O'ԍSee 47 U.S.C.  208; see also Directel, Inc. v. American Telephone and Telegraph Company,  {Oa'Memorandum Opinion and Order, 11 FCC Rcd 7554, 756061, paras. 1415 (1996); Amendment of Rules  {O+'Governing Procedures to be Followed when Formal Complaints are Filed Against Common Carriers, Report and  {O'Order, 12 FCC Rcd 22,497 (1997); Amendment of Rules Concerning Procedures to be Followed when Formal  {O'Complaints are Filed Against Common Carriers, Report and Order, 8 FCC Rcd 2614 (1993); Connecticut Office  {O'of Consumer Counsel v. AT&T Communications, Memorandum Opinion and Order, 4 FCC Rcd 8130 (1989),  {OS'aff'd sub nom. Connecticut Office of Consumer Counsel v. FCC, 915 F.2d 75 (2d Cir. 1990), cert. denied, 499  {O'U.S. 920 (1991). See generally 47 C.F.R.  1.7201.735. Thus, in order to prevail, the complainant must demonstrate by a preponderance of the evidence that the alleged violation  X 4of the Act or the Commission's rules actually occurred.{  {O 'ԍSee, e.g., Sea Island Broadcasting Corp. of S.C. v. FCC, 627 F.2d 240, 243 (D.C. Cir. 1980); see also Implementation of the NonAccounting Safeguards of Sections 271 and 272 of the Communications Act of 1934,  {O"'as Amended, First Report and Order and Further Notice of Proposed Rulemaking, 11 FCC Rcd 21,905, 22,068,  {O"'para. 337 (1996); Bender v. Clark, 744 F.2d 1424 (10th Cir. 1984) (stating that "the traditional standard required in a civil or administrative proceeding is proof by a preponderance of the evidence.").{ In other words, a complainant must  X 4provide facts, which if true, are sufficient to constitute a violation of the Act or of a" 0*%%JJ "  X4Commission rule or orders,S {Oy'ԍSee 47 C.F.R.  1.720(b).S and such facts must be persuasively supported by affidavit or  X4other relevant documentation.aZ {O'ԍXSeeĠ47 C.F.R.  1.720(c).(#a  X47. ` ` Although Consumer.Net's complaint alleged violations of the Act and the Commission's rules and orders, it contained neither a complete statement of the facts on which the complaint was based nor documentation sufficient to substantiate its allegations.  Xv4Nonetheless, because Consumer.Net pursued this action as a pro se complainant, the former Enforcement Division of the Common Carrier Bureau (Division) endeavored to ensure that Consumer.Net had adequate opportunity to explain its allegations and to provide the necessary evidence to support its claims. Towards that end, the Division held status conferences with the parties on August 11, 1998 and on August 12, 1998. During these status conferences, the  X 4Division explained what information would be necessary to support the claims and defenses."  {O'ԍSee, e.g., Letter to Parties from Jennifer Myers, Staff Attorney, Enforcement Division, Common Carrier Bureau, FCC (August 12, 1998) (summarizing the August 12, 1998 status conference and stating that the "parties must state [in their briefs] the factual information upon which they rely and cite to documents demonstrating that  yO'factual information").İ The Division then permitted the parties to submit briefs in order to elucidate and support their  X 4positions as completely as possible.|  {O^'ԍSee id. AT&T filed a motion to strike several of Consumer.Net's pleadings, including, Complainant's Opposition to AT&T's Opposition to Consumer.Net's Request for Admissions and Complainant's Opposition to AT&T's Opposition to Consumer.Net's Request for Deposition, stating that the pleadings were prohibited under the formal complaint rules. The Division denied Consumer.Net's discovery requests during the status conference.  {O'See Status Conference Transcript at 1316. Accordingly, AT&T's motion to strike is denied as moot. AT&T filed a motion to dismiss the complaint. Because we are here addressing the issues raised in the pleadings,  yO'AT&T's motion to dismiss is dismissed as moot.   X '   X 'B.XConsumer.Net Largely Has Not Met Its Burden of Proving that AT&T Failed to  X'Make AT&T's Written DoNotCall Policy Available on Demand. (#   Xd48. ` ` Section 64.1200(e)(2)(i) of the Commission's rules requires, inter alia, that "[p]ersons or entities making telephone solicitations must have a written policy, available  X84upon demand, for maintaining a donotcall list."S8 yO"'ԍ47 C.F.R.  64.1200(e)(2)(i). S Consumer.Net contends that AT&T violated that rule in several ways. More specifically, Consumer.Net argues that: (1) AT&T's 30day delay in sending its donotcall policy to Zelma after one of his requests was unreasonable; (2) AT&T failed to provide either Biggerstaff or Zelma with a copy of AT&T's"0*%%JJ" donotcall policy upon certain of their requests; and (3) AT&T's provision of a letter to Biggerstaff and Zelma describing AT&T's donotcall policy does not constitute the provision  X4of a written copy of AT&T's donotcall policy.Z {OK'ԍSee Consumer.Net Brief at 34, 6. Z AT&T denies these allegations and argues,  X4inter alia, that the numerous copies of its donotcall policy attached to the complaint refute Consumer.Net's allegations that AT&T failed to make its donotcall policy available upon  X4demand.NZ {O'ԍSee AT&T Brief at 912.N For the reasons discussed below, we conclude that, with regard to all but one claim, Consumer.Net has failed to establish that AT&T did not make its donotcall policy available on demand.  X3' 1.` ` Consumer.Net has not met its burden of proving that AT&T failed to make available to Zelma a copy of AT&T's donotcall policy within a  X 'reasonable period after Zelma's request on or about July 7, 1997. (#`  X 49. ` ` Consumer.Net argues that AT&T violated section 64.1200(e)(2)(i) of the Commission's rules by not making available to Zelma AT&T's written donotcall policy  X 4within a reasonable period after Zelma's request on or about July 7, 1997.S  {OF'ԍSee Consumer.Net Brief at 4.S In support of its position, Consumer.Net contends that AT&T did not send a copy of AT&T's donotcall  X{4policy to Zelma until August 11, 1997, nearly five weeks after Zelma's July 7, 1997 request.F{~ {O'ԍSee id. The parties may have made minor errors as to both the date of Zelma's request for the donotcall policy and the date of AT&T's response. Although Consumer.Net asserts that Zelma made the request on July 9, 1997, AT&T's answers to interrogatories, on which Consumer.Net relies, indicate that Zelma requested a  {O'copy of AT&T's donotcall policy from AT&T on July 7, 1997, not July 9, 1997. See AT&T Corp. Responses to Complainant's First Set of Interrogatories at 6. Moreover, although Consumer.Net asserts that AT&T responded on August 9, 1997, it appears that AT&T sent a copy of its donotcall policy to Zelma on August 11,  {O^'1997. See August 11, 1997 AT&T Letter. These discrepancies do not affect our decision. In this order, we assume that the correct dates are July 7, 1997, and August 11, 1997.   Xd4Consumer.Net relies on a decision by a California small claims court, which found that a bank violated section 64.1200(e)(2)(i) of the Commission's rules by sending a copy of the bank's  X64donotcall policy five weeks after request therefor.Z6  {Os 'ԍSee Arkow v. Bank of America, N.T.S.A., Municipal Court of the Newhall Judicial District, For the County of Los Angeles, State of California, Small Claims Division, Case No. S/C 95S00592 (Consumer.Net Brief at Exh. 15).  X4 10. ` ` Section 64.1200(e)(2)(i) of the Commission's rules requires "[p]ersons or entities making telephone solicitations [to] have a written policy, available upon demand, for"0*%%JJ"  X4maintaining a donotcall list."Q yOy'ԍ47 C.F.R.  64.1200(e)(2)(i).Q Neither the Commission's rules nor the Commission's orders defines the term "available upon demand." Therefore, whether an entity has made a written copy of its donotcall policy "available upon demand" requires an analysis of the facts and circumstances of each particular case. Based on the facts before us, we find that AT&T in this instance did make a copy of its donotcall policy available to Zelma upon demand within the meaning of section 64.1200(e)(2)(i).  X_4 11. ` ` Consumer.Net states that Zelma requested a copy of AT&T's donotcall policy  XH4on July 7, 1997, and that AT&T did not send its policy to Zelma until August 11, 1997.SHX {OQ 'ԍSee Consumer.Net Brief at 4.S Consumer.Net's own documentation, however, refutes its claim that AT&T did not send the policy to Zelma until August 11, 1997. The record indicates that AT&T responded to  X 4Zelma's July 7, 1997 request by sending its donotcall policy to Zelma on July 14, 1997.a  {O'ԍSee July 14, 1997 AT&T Letter.a The record indicates that Zelma again contacted AT&T to request a copy of AT&T's donot X 4call policy on July 30, 1997.  | {O'ԍSee AT&T Corp. Responses to Complainant's First Set of Interrogatories at 9; AT&T Brief at 10; Consumer.Net Brief at 4. On August 11, 1997, AT&T sent its donotcall policy to  X 4Zelma in response to his July 30, 1997 request.W!  {OE'ԍSee August 11, 1997 AT&T Letter.W In sum, the record illustrates that, contrary to Consumer.Net's contention, AT&T's August 11, 1997 letter was a timely response to Zelma's July 30, 1997 request, rather than an untimely response to Zelma's July 7, 1997 request. Moreover, we find that AT&T's response times of seven days and twelve days, respectively, are reasonable, given the facts and circumstances in this case. Indeed, Consumer.Net does not contend that such response times are unreasonable. Accordingly, we find that AT&T made a copy of its donotcall policy available to Zelma upon demand in  X4accordance with section 64.1200(e)(2)(i) of the Commission's rules." h  yO6'ԍAs stated above, whether a person or entity makes its donotcall policy "available upon demand" within the meaning of section 64.1200(e)(2)(i) of our rules depends upon the facts and circumstances of each particular case. Thus, our finding in this case does not mean that we always would find a response time of seven days to be reasonable, or that we always would find a response time of greater than twelve days to be unreasonable. "P "0*%%JJ"Ԍ X' v2.` ` Consumer.Net has met its burden of proving that AT&T failed to make AT&T's donotcall policy available to Biggerstaff upon his May 8, 1997  X'demand. (#`  X4 12. ` ` Consumer.Net contends that AT&T violated the Commission's rules and orders  X4by not making available to Biggerstaff AT&T's written donotcall policy upon demand.vV# {O'ԍSee Consumer.Net Brief at 4, 6.V In  Xv4response, AT&T argues that Biggerstaff never requested AT&T's donotcall policy.O$vZ {O 'ԍSeeĠAT&T Brief at 1011.O For the reasons discussed below, we find that AT&T failed to make a copy of its donotcall policy available to Biggerstaff upon his demand, in violation of the Commission's rules.  X 4 13. ` ` Consumer.Net contends that (1) Biggerstaff requested a copy of AT&T's donotcall policy during the course of a May 8, 1997 telephone solicitation, and (2) AT&T  X 4failed to honor Biggerstaff's request.%  {O'ԍSee Consumer.Net Brief at 6; but see AT&T Brief at 1011 (stating that its call records do not indicate  yOS'that Biggerstaff requested a copy of AT&T's donotcall policy). In support of this contention, Consumer.Net submitted a cassette tape that contains a recording of a May 8, 1997 telephone solicitation from an  X 4AT&T representative to Biggerstaff.& F {O'ԍSee Biggerstaff Aff. (Sept. 17, 1998) (attaching the cassette tape to the affidavit and explaining what is  yO'recorded on the tape) (hereinafter we refer to the tape as the " Biggerstaff Tape"). AT&T does not contest the accuracy or the  X 4authenticity of the Biggerstaff Tape.'  yO'ԍNor does AT&T allege that the taped conversations should not be considered by the Commission for any legal or policy reasons. AT&T also does not contest that it failed to provide Biggerstaff with its donotcall policy in response to the May 8, 1997 call. AT&T argues only that Biggerstaff did not make an unequivocal request for its donotcall policy during the  Xb4May 8, 1997 call.L(b  {O 'ԍSee AT&T Brief at 11.L  X44 14. ` ` We find that the Biggerstaff Tape demonstrates that Biggerstaff did request a copy of AT&T's donotcall policy on May 8, 1997. Specifically, Biggerstaff stated to the  X4AT&T telemarketer: "I would like you to send me a copy of your donotcontact policy."B)  yOA"'ԍBiggerstaff Tape.B In response, the AT&T telemarketer stated that she was unsure whether she had the authority to send the policy but offered to check with her supervisor. The telemarketer's authority to provide AT&T's donotcall policy, however, should not have been a subject for discussion;")0*%%JJ" AT&T should have had procedures in place to process such requests, and the telemarketer should have known of them. Thus, we find that AT&T violated section 64.1200(e)(2)(i) of the Commission's rules by not making a copy of AT&T's donotcall policy available to Biggerstaff upon his May 8, 1997 demand.  X'ԋ 3.` ` Consumer.Net has not met its burden of proving that AT&T failed to  Xv'make AT&T's donotcall policy available to Zelma upon demand. (#`  XH415. ` ` Consumer.Net also contends that AT&T failed to honor a February 24, 1998  X14request from Zelma for AT&T's donotcall policy.S*1d {O 'ԍSee Consumer.Net Brief at 4.S In response, AT&T states that it  X 4provided Zelma a copy of its donotcall policy on several occasions.O+ Zd {O% 'ԍSeeĠAT&T Brief at 1011.O Consumer.Net's only record evidence that Zelma requested AT&T's donotcall policy in this instance is Zelma's written but unsworn assertion that he "received [a] solicitation for the AT&T Universal Card" on February 24, 1998, and "called the number provided to complain [and] asked for the  X 4written policy but never received one.",. d {O['ԍZelma Statement (Consumer.Net Brief at Exh. 12); see also Consumer.Net Brief at 4 (stating that Zelma "requested the AT&T donotcall policy after the February 24, 1998 telephone solicitation made by AT&T but  yO'did not receive one and had to call back on March 20, 1998."). It is unclear from Zelma's statement when Zelma initially contacted AT&T to request its donotcall policy. Consumer.Net does not state whether Zelma received a donotcall policy subsequent to his March 20, 1998 call to AT&T. AT&T states that its contemporaneous call records are unavailable for Zelma's alleged call to AT&T on or about February 24, 1998;  {O 'therefore, AT&T does not have a record of whether Zelma requested a copy of AT&T's donotcall policy. See AT&T Brief at 10. We find AT&T's lessthancomplete recordkeeping troubling and urge carriers to fulfill their responsibilities to maintain such records. In its answers to interrogatories, however, AT&T states that Zelma contacted AT&T's Chairman's Executive Response Center on February 24, 1998, and that as a result of that telephone call, AT&T placed Ms. Michele Zelma on the Universal Card Services (UCS) donotcall list.  {O'SeeĠAT&T's Answers to Interrogatories at 9. It is unclear whether the contemporaneous call records referred to in AT&T's brief are the same as the records for the Chairman's Executive Response Center.   X416. ` ` We conclude that Consumer.Net has not provided sufficient evidence to satisfy its burden of proving that Zelma indeed contacted AT&T on February 24, 1998 and requested a copy of AT&T's donotcall policy. Although the Division met with Consumer.Net on several occasions to explain the evidence necessary to support a claim and allowed Consumer.Net to file additional supporting materials, Consumer.Net has failed to provide the information necessary to support its claim. First, Consumer.Net did not provide a sworn statement (or statement filed under penalty of perjury) from Zelma. In any event, Zelma's statement does not provide essential corroborative information such as the particular AT&T number contacted, the specific AT&T division called, or the name of the person with whom" ,0*%%JJ-" he allegedly spoke. Such information also is essential to providing the defendant with a reasonable opportunity to investigate, and thereby rebut, the allegations. Finally, the record indicates that AT&T on two previous occasions provided Zelma with copies of its donotcall  X4policy promptly upon Zelma's request.M-d {O4'ԍSee supra paras. 911.M We find, therefore, that Zelma's unsworn statement, without any additional evidence substantiating that Zelma contacted AT&T to request a copy of AT&T's donotcall policy on February 24, 1998, is insufficient to prove by a preponderance of the evidence that Zelma actually made such a request. Accordingly, we conclude that Consumer.Net has failed to meet its burden of proof that AT&T violated section 64.1200(e)(2)(i) of the Commission's rules by not providing to Zelma AT&T's donotcall  X14policy upon a demand allegedly made on February 24, 1998. Ŋ   X ' 4.` ` Consumer.Net has failed to demonstrate that two of AT&T's letters to  X 'Zelma are insufficient to constitute AT&T's donotcall policy. (#`  X 417. ` ` Consumer.Net contends that AT&T violated section 64.1200(e)(2)(i) of the Commission's rules by sending Zelma two letters describing AT&T's donotcall policy  X4instead of sending AT&T's actual donotcall policy.&.Z {O'ԍSee Consumer.Net Brief at 4, 6 (referring to July 14, 1997 AT&T Letter and August 11, 1997 AT&T  {Oe'Letter). The substance of each letter is identical. July 14, 1997 AT&T Letter; August 11, 1997 AT&T Letter. & Consumer.Net argues that the AT&T letters are not "sufficient in scope to describe AT&T's do not call policy," or to inform  Xb4consumers how they can be placed on AT&T's donotcall list.P/b yO'ԍConsumer.Net Brief at 6. P  X4418. ` ` Based on our review of the two AT&T letters in question, we reject Consumer.Net's contentions in this regard. There is no evidence to suggest that AT&T's letters to Zelma do not contain its actual policy. In any event, the letters sufficiently detail AT&T's method and policy for maintaining a donotcall list. In particular, the letters state how AT&T processes a donotcall request. The letters also state that the consumer will receive a written confirmation of his or her donotcall request and provide an address to  X4which to direct any inquiries regarding its donotcall list.x0F {O'ԍSee July 14, 1997 AT&T Letter; August 11, 1997 AT&T Letter.x We thus conclude that AT&T  X4complied with the requirement to make a donotcall policy available upon demand.1$ yO"'ԍIt appears that Consumer.Net also argues that AT&T's failure to make its donotcall policy available on  {O"'AT&T's webpage violates section 64.1200(e)(i) of the Commission's rules. See Consumer.Net Brief at 4. We  {O#'disagree. Nothing in the Commission's rules requires carriers to make available their donotcall policies on the internet. " 10*%%JJ"Ԍ  X' C.X Consumer.Net Has Not Met Its Burden of Proving that AT&T Failed to Properly Record Biggerstaff's DoNotCall Requests or that AT&T Failed to Honor  X'Biggerstaff's DoNotCall Requests for a Period of 10 Years. (#  X419. ` ` Section 64.1200(e)(2) of the Commission's rules requires that in response to a  Xv4donotcall request, the solicitor must, inter alia, record the solicitee's name and the telephone  Xa4number called.2a yO'ԍ47 C.F.R.  64.1200(e)(2)(iii) (stating in pertinent part, "the person or entity must record the [donot yO 'call] request and place the subscriber's name and telephone number on the donotcall list . . . ."). Thus, the donotcall request applies to a particular telephone number"not all telephone numbers associated with the person's name"absent a specific request to the contrary. The solicitor must then honor the donotcall request for ten years from the time the  X 4request is made.\3  {O 'ԍSee 47 C.F.R.  64.1200(e)(2)(vi).\ Moreover, absent a specific request or reasonable expectation to the contrary, the donotcall request applies only to the particular business entity making the call,  X 4and not ordinarily to affiliated entities.4   yOQ'ԍ47 C.F.R.  64.1200(e)(2)(v) ("in the absence of a specific request by the subscriber to the contrary, a residential subscriber's donotcall request shall apply to the particular business entity making the call (or on whose behalf the call is made), and will not apply to affiliated entities unless the consumer reasonably would expect them to be included given the identification of the caller and the product being advertised.").   X 420. ` ` Consumer.Net alleges that AT&T continued to place telephone solicitations to Biggerstaff after he requested to be placed on AT&T's long distance donotcall list, in violation of section 64.1200(e)(2) of the Commission's rules. In particular, liberally  X{4construing Consumer.Net's pro se pleading, Consumer.Net apparently contends that AT&T: (1) failed to record Biggerstaff's donotcall requests, in violation of section 64.1200(e)(2)(iii), and (2) failed to honor Biggerstaff's donotcall requests for ten years from the time the  X84requests were made, in violation of section 64.1200(e)(2)(vi).c58 {O'ЍSee Consumer.Net Brief at 1014. c Consumer.Net bases its claims on evidence in the record regarding telephone calls to certain of Biggerstaff's telephone  X 4numbers on the following dates: May 8, 1997; May 6, 1998; and June 4, 1998.6 ,  {O'ԍSee AT&T Corp. Responses to Complainant's First Set of Interrogatories at 5. See alsoĠBiggerstaff Aff. at paras. 78 (Aug. 31, 1998). On each occasion, AT&T placed the telephone solicitation calls to offer the same product, AT&T long  X4distance.7  {O$'ԍSee AT&T Brief at note 35; Biggerstaff Tape. Biggerstaff has several different telephone numbers. For privacy, only part of the telephone number will be used in this order. Although the Division met with Consumer.Net on several occasions to explain the" 70*%%JJ{" evidence necessary to support a claim and allowed Consumer.Net to file additional information to support its position, Consumer.Net submitted neither a sworn statement from the consumer nor any corroborating evidence.  X421. ` ` Telephone Solicitation to (803) XXX3805 on May 8, 1997. Consumer.Net contends that AT&T initiated a telephone solicitation to Biggerstaff on May 8, 1997, in  Xv4violation of Biggerstaff's prior donotcall requests.8v {O'ԍSee Consumer.Net Brief at 9; see also Consumer.Net Brief at Exh. 25 (Biggerstaff Aff. at para. 4 (June 18, 1998)) (Biggerstaff Aff. (June 18, 1998)). In response, AT&T states that Biggerstaff did not request that any of his telephone numbers be placed on any AT&T donot XH4call list until July 28, 1998.K9H" {O 'ԍSee AT&T Brief at 9.K   X 422. ` ` To support its claim that Biggerstaff requested that telephone number (803) XXX3805 be placed on AT&T's long distance services donotcall list prior to May 8, 1997, Consumer.Net relies solely on Biggerstaff's June 18, 1998 affidavit. Biggerstaff's affidavit states, in pertinent part, "[p]rior to November 4, 1996, I received multiple telephone solicitations at my home by or on behalf of AT&T . . . . In each and every one of these calls  X 4. . . I requested the caller to not call me again.":   yO 'ԍBiggerstaff Aff. at para. 3 (June 18, 1998). Consumer.Net also relies on this affidavit to substantiate its claim that the other telephone solicitations violated Biggerstaff's prior donotcall requests. The same deficiencies of the statement regarding the pre1996 telephone solicitations with respect to the May 8, 1997 telephone solicitation are present for all subsequent calls.   Xy423. ` ` We find that Biggerstaff's affidavit is insufficient to demonstrate that he requested that telephone number (803) XXX3805 be placed on AT&T's long distance services donotcall list prior to receiving the May 8, 1997 telephone solicitation. Biggerstaff does not state which of his several telephone numbers he requested be placed on AT&T's do X4notcall list,; {Oj'ԍSee Biggerstaff Aff. at para. 3 (Sept. 17, 1998) (Consumer.Net Brief at Exh. 28) (stating that Mr. Biggerstaff maintains several different telephone numbers). nor does he provide any information as to when these requests were made, other  X4than to state that they were made prior to November 4, 1996.N<Z  {O 'ԍSee id. (stating "Prior to November 4, 1996, I received multiple telephone solicitations at my home by or on behalf of AT&T that I did not keep a record of. In each and every one of these calls, numbering approximately five, . . . I requested the caller to not call me again.").N In addition, Biggerstaff does not indicate which AT&T entity (e.g., AT&T long distance services, AT&T International Services) solicited him in the telephone solicitations prior to May 8, 1997, or which AT&T entity he requested not to contact him. We find that such vague assertions do not provide" <0*%%JJX" defendant with a reasonable basis to investigate or rebut the allegations. We therefore find that Consumer.Net has not met its burden of substantiating this claim.  X424. ` ` Telephone Solicitation to (803) XXX8524 on May 6, 1998. Consumer.Net also contends that AT&T's May 6, 1998 telephone solicitation to Biggerstaff's telephone  X4number (803) XXX8524 violated Biggerstaff's donotcall request made on May 8, 1997.S= {O'ԍSee Consumer.Net Brief at 9.S AT&T again argues that Biggerstaff did not request that telephone number (803) XXX8524  X_4be placed on AT&T's donotcall list until July 28, 1998.L>_Z {Oj 'ԍSee AT&T Brief at 17.L  X1425. ` ` Consumer.Net relies solely on Biggerstaff's June 18, 1998 affidavit, which states, in pertinent part, that he requested to be placed on AT&T's donotcall list during the  X 4course of the May 8, 1997 telephone solicitation.g?  {O'ԍSee Biggerstaff Aff. at para. 4 (June 18, 1998).g The record shows, however, that AT&T made the May 8, 1997 telephone solicitation to telephone number (803) XXX3805, not the telephone number contacted during the May 6, 1998 telephone solicitation, which the record  X 4shows to have been made to (803) XXX8524.|@ ~ {O'ԍSee AT&T Corp. Response to Commission Request for Information at 23.| As stated above, absent a particular request otherwise, a donotcall request applies to a specific telephone number, not to all telephone  X4numbers associated with the requestor.]A {OQ'ԍSee 47 C.F.R.  64.1200(e)(2)(iii).] Consumer.Net has not demonstrated that Biggerstaff specifically requested that telephone number (803) XXX8524 be placed on any AT&T donotcall list prior to receiving the May 6, 1998 telephone solicitation. In fact, the Biggerstaff Tape indicates that he did not request that any particular number, or all of his telephone  X44numbers, be placed on AT&T's donotcall list.PB4 {O'ԍSee supra para. 14.P Therefore, Consumer.Net has not met its burden of demonstrating that Biggerstaff requested telephone number (803) XXX8524 be placed on AT&T's donotcall list prior to receiving the May 6, 1998 telephone solicitation.  X426. ` ` Telephone Solicitation to (803) XXX8524 on June 4, 1998. Consumer.Net also contends that AT&T initiated a telephone solicitation on June 4, 1998, to Biggerstaff's telephone number (803) XXX8524, in violation of Biggerstaff's donotcall request made on" 4 B0*%%JJ\"  X4May 6, 1998.C" yOy'ԍConsumer.Net Brief at 9. Consumer.Net does not mention the June 4, 1998 telephone solicitation in its complaint or in its brief. Biggerstaff, in his affidavit, however, states that he received a June 4, 1998 telephone  {O 'solicitation in violation of his donotcall request. Because Consumer.Net is pro se, we liberally construe its complaint to encompass the June 4, 1998 telephone solicitation referenced in Biggerstaff's affidavit. To support its contention that Biggerstaff received a telephone solicitation on June 4, 1998, Consumer.Net provides a tape recording of the June 4, 1998 telephone solicitation. The recording indicates that AT&T's telemarketer reached Biggerstaff's answering machine on May 6, 1998. Consumer.Net contends that Biggerstaff's answering machine greeting contained a request to any telemarketer to be placed on that telemarketer's donotcall list.  X_427. ` ` We find that Consumer.Net has failed to demonstrate that Biggerstaff requested that telephone number (803) XXX8524 be placed on AT&T's donotcall list prior to receiving the June 4, 1998 telephone solicitation. Consumer.Net relies solely on the  X 4assumption that the caller listened to the following recorded message, in its entirety, which was conveyed by Biggerstaff's answering machine: XHello [brief pause] . . . excuse me, could you please state who is calling [brief pause]. I'm sorry, you've gotten the machine. If this is a solicitation call, please wait until the end of this message and leave all disclosures as required  X4by the telemarketing statute, and place this number on your donotcall list.BD yO'ԍBiggerstaff Tape.B   Xd428. ` ` The record does not indicate that the AT&T telemarketer remained on the line long enough to hear Biggerstaff's entire recorded message. As the above quotation reveals, Biggerstaff does not request to be placed on the telemarketer's donotcall list until the very end of the message, and after notifying the caller that s/he has received an answering machine. We cannot simply assume that the caller actually heard the donotcall request. Accordingly, we conclude that Consumer.Net has not met its burden of proving that AT&T failed to honor Biggerstaff's alleged May 6, 1998 donotcall request by making the June 4,  X41998 telephone solicitation.EB yO'ԍConsumer.Net also argues that AT&T initiated telephone solicitations on July 3, July 28, and July 30, each in violation of Biggerstaff's donotcall request. Each separate call is a separate cause of action. These calls occurred after Consumer.Net filed its formal complaint, and therefore are not properly before us.  {O!'Consumer.Net cannot raise new claims after the formal complaint has been filed. See GE Capital  {O!'Communications Services v. AT&T, Memorandum Opinion and Order, 13 FCC Rcd 13,138, 13,149, para. 24 (1998) (declining to resolve issues raised for the first time in the complainant's brief).  " E0*%%JJ"Ԍ X' D v.X Consumer.Net Has Met its Burden of Proving that AT&T Violated the Commission's Rules by Initiating a Telephone Solicitation to Zelma on October 29, 1997, in Violation of Zelma's Prior CompanyWide (#  X'DoNotCall Request.   X429. ` ` vThe Commission's rules mandate that, "in the absence of a specific request to the contrary, a residential subscriber's donotcall request shall apply to the particular business entity making the call (or on whose behalf the call is being made), and will not apply to affiliated entities unless the consumer reasonably would expect them to be included given the  X14identification of the caller and the product being advertised."QF1 yO 'ԍ47 C.F.R.  64.1200(e)(2)(v).Q Consumer.Net contends that Zelma made a specific request to be placed on a donotcall list of all entities affiliated with AT&T (a companywide donotcall list) prior to receiving a telephone solicitation on October  X 429, 1997, from Universal Card Services Corporation (UCS), an AT&T affiliate.ZG X {O'ԍSee Consumer.Net Brief at 10.Z Consumer.Net contends that AT&T failed to coordinate Zelma's AT&T companywide donotcall request among affiliated entities, in violation of section 64.1200(e)(2)(v) of the Commission's rules, and failed to honor Zelma's donotcall request for "10 years from the time the request is made," in violation of section 64.1200(e)(2)(vi) of the Commission's  Xy4rules.>Hy {O'ԍSee id.>  XK430. ` ` To support its claim, Consumer.Net provides an unsworn statement from Zelma stating that, prior to June 1997, he requested by mail and phone to be placed on an AT&T  X4companywide donotcall list.I| {OJ'ԍSee Statement of Richard M. Zelma (June 17, 1998) (Consumer.Net Brief at Exh. 12). Consumer.Net also relies on a letter from AT&T to Zelma  X4dated August 11, 1997, stating that Zelma would be placed on AT&T's donotcall list.KJ\ {O'ԍSee Letter to Richard Zelma from Mary Beth Kessler, Manager, AT&T Customer Relations Center (Aug. 11, 1997) (Consumer.Net Brief at Exh. 20) (This August 11, 1997 letter is not the same as the letter  {OW'referred to earlier as the August 11, 1997 Letter).K Consumer.Net contends that the text and letterhead of this letter indicate that Zelma requested  X4placement "on a[n] AT&T list, not a specific company [list] within AT&T."JK2  yO!'ԍConsumer.Net Brief at 11.J In response, AT&T states that Zelma never requested placement on an AT&T companywide donotcall  X4list.BL  yO%'ԍAT&T Brief at 13.B AT&T also states that Zelma did not request placement on UCS's donotcall list until"R L0*%%JJ\"  X4September 7, 1997, which makes UCS's solicitation "only" seven weeks later lawful.DM {Oy'ԍId. at 1314.D AT&T further states that the "use of the AT&T name by an AT&T business entity does not automatically lead a consumer to reasonably expect that a donotcall request would apply to  X4all affiliated entities."INZ yO'ԍAT&T Reply Brief at 89.I  X431. ` ` Zelma's statement that he requested placement on an AT&T companywide donotcall list, in conjunction with the August 11, 1997 letter from AT&T to Zelma, persuades us that Zelma requested placement on AT&T's companywide donotcall list prior to August 11, 1997. In this situation, unlike the situation involving Zelma's February 24, 1998  X14telephone call,O1 {O 'ԍSee supra para. 16 (discussing why Zelma's unsworn statement is insufficient to demonstrate that Zelma requested a copy of AT&T's donotcall policy). Zelma's unsworn statement is corroborated by wholly independent and  X 4probative evidence: AT&T's own August 11, 1997 letter to Zelma.P D {O'ԍSee Letter to Richard Zelma from Mary Beth Kessler, Manager, AT&T Customer Relations Center (Aug. 11, 1997) (Consumer.Net Brief at Exh. 20).  X 432. ` ` The August 11, 1997 letter provides corroboration in several ways. First of all, the letter bears generic AT&T letterhead. Moreover, nowhere in the text of the letter does AT&T refer to a specific AT&T entity. In fact, the text of the letter refers generically to "AT&T Products and Services," not specifically to any particular AT&T product or service. Furthermore, this letter states that "[r]ecently you contacted AT&T and indicated that you do  Xy4not wish to be contacted regarding any marketing communications. . . . We are taking the  Xd4necessary steps to remove your account information from our future communications."VQd {O'ԍSee id. (emphasis added).V We find that this letter both supports a conclusion that Zelma requested to be placed on all AT&T corporate donotcall lists and that a reasonable consumer would understand that AT&T had done so.  X4 33. ` ` Indeed, in contrast to these global, generic characteristics of the August 11, 1997 letter from AT&T to Zelma, evidence on the record indicates that AT&T does use entityspecific letterhead (e.g., AT&T long distance services, AT&T international consumer  X4long distance) to respond to entityspecific donotcall requests.R0  {O#'ԍSee, e.g., Letter to Richard Zelma from Joan Lichtenstein, Manager, Alternate Channels, International Consumer Long Distance, AT&T (Dec. 3, 1996) (Consumer.Net Brief at Exh. 30). For example, in response to" R0*%%JJ5" an inquiry, Zelma received a letter specifically from AT&T International Consumer Long Distance. This letter contains letterhead specifically referencing "AT&T International  X4Consumer Long Distance" and mentions the specific service within the letter.:S {OK'ԍId.:  X4!34. ` ` The foregoing evidence satisfies Consumer.Net's burden of proving that Zelma requested to be placed on an AT&T companywide donotcall list prior to August 11, 1997. Therefore, we find that the October 29, 1997 telephone solicitation by UCS violated Zelma's request. We thus find that AT&T failed: (1) to apply Zelma's donotcall request to affiliated entities, in violation of section 64.1200(e)(2)(v) of the Commission's rules; (2) to properly record Zelma's request, in violation of section 64.1200(e)(2)(iii) of the Commission's rules; and (3) to honor Zelma's request for 10 years from the time the request was made, in violation of section 64.1200(e)(2)(vi).  X ' E .XConsumer.Net Has Met Its Burden of Proving that AT&T Violated the Commission's Rules by Initiating a Telephone Solicitation to Michele Zelma on  X 'February 24, 1998. (#  Xy4"35. ` ` Consumer.Net also argues that AT&T (via its affiliate, UCS) initiated a telephone solicitation on February 24, 1998, in violation of Mr. Zelma's prior donotcall  XK4request.TTKZ {OV'ԍSee Consumer.Net Brief at 14.T In response, AT&T contends that the telephone solicitation did not violate Mr.  X44Zelma's donotcall request because the solicitation was specifically directed to Michele Zelma  X4(not Richard Zelma).QU {O'ԍSee AT&T Brief at 14 n.33.Q  X4#36. ` ` Because we find that the Commission's rules require donotcall lists to be maintained on a telephone number basis (rather than requiring requests from every individual at a particular residence), we conclude that AT&T's February 24, 1998 telephone solicitation violated the Commission's rules and orders. Both section 227 and the Commission's rules mandate certain obligations to protect the rights of residential telephone subscribers. Specifically, section 64.1200(e)(2)(iii) of the Commission's rules requires telemarketers to  Xg4"place the subscriber's name and telephone number on the donotcall list at the time the  XR4request is made."DV  R~ yO"'ԍ47 C.F.R.  64.1200(e)(2)(iii) (emphasis added). Section 64.1200(e)(2)(iii) states in pertinent part, XIf a person or entity making a telephone solicitation (or on whose behalf a solicitation is made) receives a request from a residential telephone subscriber not to receive calls from that person"$U0*%%$" or entity, the person or entity must record the request and place the subscriber's name and telephone number at the time the request is made.   {M'Id.D Additionally, in the TCPA Memorandum Opinion and Order, the"RV0*%%JJ[" Commission recognized that some consumers wishing to be placed on a donotcall list will not want to provide telemarketers with their name. The Commission emphasized that such consumers must still be placed on the donotcall list based on their telephone number and explained that "interpreting the rule more narrowly would defeat the objective of protecting  X4consumer privacy."!W {O 'ԍTCPA Memorandum Opinion and Order, 10 FCC Rcd at 12,395, para. 9. The Commission declined to modify the requirement that solicitors record both a name and number. The Commission stated, however, that "[t]elemarketers will not be in violation of the rule so long as they request the called party's name. Indeed, we expect telemarketers to respect the privacy of those who specifically refuse to give a name by simply making a  {O' 'notation to that effect." Id.! For the same reason, we find that when a telemarketer receives a request that a particular telephone number be placed on its donotcall list, our rules require  Xv4the telemarketer to comply with that request by placing the "subscriber's name and telephone  Xa4number on the donotcall list." The placement of the number on the donotcall list may not be circumscribed by the telemarketer's claim that it was trying to reach someone else at that same number.  X 4$37. ` ` AT&T acknowledges that some of its donotcall lists"such as those for long  X 4distance services"are maintained by number (and name if given), because AT&T markets those services to households, not individuals. In contrast, AT&T states that the donotcall  X 4list for AT&T's affiliate UCS is maintained by name and number, because AT&T markets  X 4this particular service to individuals, not households.~X d  {O'ԍSee AT&T Brief at 4 n.8 (discussing UCS's donotcall list procedures).~ AT&T argues that such a distinction is  X4consistent with our rules.>Y  {O='ԍSee id.> We disagree. There is nothing in either section 227 of the Act or the Commission's rules that varies a telemarketer's donotcall list obligations depending upon the service being marketed. Both section 227 of the Act and the Commission's rules grant rights to consumers that only can be effectuated if a single request from someone in a particular household suffices to stop future calls to the same number. Indeed, the distinction proffered by AT&T potentially would eviscerate the policy goals of the statute in protecting telephone subscribers from unwanted telemarketing calls by creating a virtually irrefutable defense that the telemarketer was trying to reach "someone else" at that number.  X4%38. ` ` We add that our interpretation of section 64.1200(e)(2)(iii) is consistent with our holding above that a donotcall request applies to a particular telephone number, not all" Y0*%%JJ"  X4numbers associated with that person's name, absent a specific request to the contrary.JZ {Oy'ԍSee supra para. 19.J In contrast, we find AT&T's position in this instance to be inconsistent with its position on certain other counts in this complaint. On certain counts in this complaint, such as Consumer.Net's allegations that AT&T failed to honor Biggerstaff's donotcall requests, we found in favor of AT&T, because Consumer.Net had not demonstrated that the telephone numbers to which AT&T made the allegedly violative telephone solicitations had been requested to be placed on a particular AT&T donotcall list. We reached this conclusion, in part, even though it was conceded that multiple telephone lines belonged to the same subscriber, because we found that"absent a specific request to the contrary"a donotcall request applies to a particular telephone number. Our conclusion in this instance"that a do X 4notcall request applies by number"is based upon the same premise, and consistent with our overall policy goals of the statute and the rules, to protect individuals from unwanted telephone solicitations.  X 4&39. ` ` AT&T admits that it placed Mr. Zelma's telephone number on the UCS donotcall list on September 7, 1997, and we have found that Mr. Zelma requested to be placed on  X4all AT&T donotcall lists prior to August 11, 1997.L[Z {O'ԍSee AT&T Brief at 13.L Accordingly, we find that AT&T violated section 64.1200(e)(2)(vi) by placing a telephone solicitation to Michele Zelma on February 24, 1998.  XO'   X8'F.Miscellaneous Claims  X 4'40. ` ` In its complaint, Consumer.Net also appears to allege that AT&T (1) initiated telephone solicitations to Smith in violation of his donotcall request; (2) failed to provide a  X4copy of AT&T's donotcall policy to Smith; and (3) improperly trained its telemarketers.~\ {Oy'ԍSeeĠConsumer.Net Complaint at 6; Status Conference Transcript at 2627.~ Consumer.Net has not provided any factual information, either in the complaint itself or anywhere else in the record, to support any of these claims. Therefore, even though we  X4liberally construe pro se pleadings, we cannot construe Consumer.Net's pleadings to have met"~\0*%%JJ"  X4the burden of proof applicable to the foregoing claims.<] {Oy'ԍSee Status Conference Transcript at 811. In its brief, Consumer.Net appears to challenge the sufficiency of the information in various AT&T, APAC TeleServices, Inc., and Citibank donotcall policies that  {O 'Smith received. SeeĠConsumer.Net Brief at 57. Consumer.Net also appears to raise issues concerning the practices of the telemarketers AT&T used to telemarket AT&T's products and services. Consumer.Net also appears to argue that AT&T's procedures for maintaining a physical donotcall list do not comply with our  {Oe'rules. See id. at 1213. These claims were raised only in Consumer.Net's brief, and not in its complaint.  {O/'Therefore, these claims are not properly before us, and we need not address them. See 47 C.F.R.  1.721(a); see  {O'also GE Capital Communications Services v. AT&T, 13 FCC Rcd at 13,149, para. 24 (declining to resolve issues raised for the first time in the complainant's brief). < Accordingly, we hereby deny all of these claims. ` `  X' IV. REQUESTS FOR RELIEF \  X4(41. ` ` Consumer.Net requests that the Commission assess forfeitures against AT&T for violation of the Commission's rules and orders, issue a cease and desist order to prevent AT&T from conducting further telephone solicitations in the United States, and order AT&T  XH4to pay damages in the amount of $1,500 per violation.T^H {O'ԍSee Consumer.Net Brief at 14.T For the following reasons, we deny all of Consumer.Net's requests for relief.  X 4)42. ` ` Sections 206208 of the Act establish private remedies for parties aggrieved by carriers, while section 503(b) of the Act gives the Commission the discretion to assess  X 4forfeitures payable to the United States.h_ 4  yO'ԍ47 U.S.C.  208, 503(b); 47 C.F.R.  1.80(e).h Accordingly, a formal complaint proceeding under sections 206208 of the Act is not an appropriate venue for the Commission's imposition of a forfeiture. If the Commission determines that AT&T's telephone solicitation practices warrant the issuance of a Notice of Apparent Liability for Forfeiture under section 503 of the Act, the  Xy4Commission will do so in a separate proceeding.6`y  {O'ԍSee Halprin v. MCI Telecommunications Corp., Memorandum Opinion and Order, 13 FCC Rcd 22,568, 22,581, at para. 29 (1998). While the violations at issue here standing alone do not fall within the oneyear statute of limitations period established in section 503(b)(6)(B) of the Act, 47 U.S.C.  503(b)(6)(B), the Commission is concerned with AT&T's failure to comply fully with the TCPA and the Commission's parallel regulations, and will bring appropriate enforcement action if such violations recur. 6 Consumer.Net's request that we prohibit AT&T from telephone solicitations is denied, because Consumer.Net has not shown widespread violations or the potential for future misconduct or harm necessary to warrant such relief. "v`0*%%JJ"Ԍ X4*43. ` ` We also deny Complainant's claim for damages. As explained above, although Consumer.Net has shown that AT&T violated the Commission's rules in relation to Biggerstaff and Zelma, Consumer.Net has not shown that AT&T violated the Commission's rules in its dealings with Consumer.Net itself. Consumer.Net has standing to recover damages  X4only for harm to itself, not for harm suffered by others.aa {O'ԍSee, e.g., 47 U.S.C.  206 (providing that, if a common carrier violates the Act, "such common carrier  {O'shall be liable to the person or persons injured thereby for the full amount of damages sustained") (emphasis  {O'added). See also Halprin v. MCI Telecommunications Corp., 13 FCC Rcd at 22,581, para. 29 (holding that class action lawsuits are neither contemplated by, nor consistent with, the private remedies created under sections 206 through 209 of the Act). Nonetheless, it is appropriate for the Commission to resolve the legal and factual issues presented by Consumer.Net's complaint, in light of the statutory mandate that such complaint not be dismissed  {O 'solely for lack of direct injury. SeeĠ47 U.S.C.  208. a This conclusion is premised on a determination that Biggerstaff and Zelma are not parties to this proceeding. It follows from such a conclusion, of course, that nothing in this order affects their rights to seek damages directly either by filing a complaint with the Commission or with a court of proper  XH4jurisdiction.bH yO 'ԍPursuant to section 227(c)(5) a person who has received telephone solicitations in violation of the Commission's rules and the Act may "if otherwise permitted by the laws or rules of court of a State bring in an appropriate court of that State" an action to enjoin such violation and/or an action to recover actual monetary  {Oa'loss or $500 per violation. Id. Section 227 further provides that the court may increase the amount to not more than $1,500 per violation if the court finds that "the defendant wilfully or knowingly violated the regulations prescribed under this subsection." 47 U.S.C.  227(c)(5)(C). Section 227 does not provide a similar monetary recovery for those complaints brought before the Commission; complainants, however, may file a section 208  {O'formal complaint for the recovery of actual damages. See 47 U.S.C.  206208. During a status conference, Commission staff informed Consumer.Net that Biggerstaff and Zelma could file a formal complaint on their own behalf or seek to be joined as parties to the Consumer.Net complaint if they wished to recover actual damages.    X '@ V. CONCLUSION Đ\  X 4+44. ` ` For the reasons discussed above, we conclude that (1) AT&T violated section 64.1200(e)(2)(i) by failing to make its donotcall policy available to Biggerstaff upon his May 8, 1997 demand; (2) AT&T violated section 64.1200(e)(2)(iii) by failing to properly record Zelma's donotcall request on or about February 24, 1998; (3) AT&T violated section 64.1200(e)(2)(v) by failing to apply Zelma's AT&T companywide donotcall request to affiliated entities; (4) AT&T violated section 64.1200(e)(2)(vi) by failing to honor Zelma's donotcall request for a period of 10 years from the time the request was made; and (5) Consumer.Net has failed to show by a preponderance of the evidence that AT&T violated the Act or the Commission's rules or orders in any other respects. "b0*%%JJo"Ԍ X'! VI. ORDERING CLAUSES \  X4,45. ` ` Accordingly, IT IS ORDERED, pursuant to sections 4(i), 4(j), 208, and 227 of the Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), 208, and 227 that the complaint filed by Consumer.Net IS GRANTED IN PART to the extent described herein and otherwise DENIED and DISMISSED WITH PREJUDICE, and this proceeding is TERMINATED.  XH4-46. ` ` IT IS FURTHER ORDERED, pursuant to sections 4(i), 4(j), and 208 of the Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), and 208, that AT&T's Motion to Dismiss filed on July 13, 1998 IS DENIED. H  X 4.47. ` ` IT IS FURTHER ORDERED, pursuant to sections 4(i), 4(j), and 208 of the Communications Act of 1934, as amended, 47 U.S.C.  154(i), 154(j), and 208, that AT&T's Motion to Strike filed on July 31, 1998 IS DENIED.  ` `   ` ` hhCFEDERAL COMMUNICATIONS COMMISSIONH   ` `  hhCMagalie Roman Salas ` `  hhCSecretary