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Comment Sought on Petition of Ad Hoc Coalition of International Telecommunications Companies For Declaratory Rulings or Rulemaking Regarding Universal Service Contributions

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Released: October 27, 2009


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 09-2118

Release Date: September 28, 2009




WC Docket No. 06-122

Comment Date: October 28, 2009
Reply Comment Date: November 12, 2009

The Ad Hoc Coalition of International Telecommunications Companies (Coalition) filed a
petition on September 8, 2009, requesting that the Commission issue a declaratory ruling that the
Universal Service Administrative Company (USAC) lacks authority to indirectly assess universal service
contribution assessments on international-only providers.1 In addition, the Coalition requests that the
Commission declare that it lacks jurisdiction over certain non-U.S. international providers.2 In the
alternative, if the Commission does not issue a declaratory ruling, the Coalition requests that the
Commission initiate a rulemaking proceeding to examine these issues.3
Interested parties may file comments on or before October 28, 2009, and reply comments on
or before November 12, 2009. All pleadings are to reference

WC Docket No. 06-122

. Comments may
be filed using the Commission's Electronic Comment Filing System (ECFS), or by filing paper copies.4

Electronic Filers: Comments may be filed electronically using the Internet by accessing the
ECFS: Filers should follow the instructions provided on the
website for submitting comments.

1 Petition of the Ad Hoc Coalition of International Telecommunications Companies for Declaratory Rulings that (1)
The Universal Service Administrative Company Lacks Authority to Indirectly Assess Universal Service Fund Fees
on International Only Providers; and (2) The FCC Lacks Jurisdiction Over Certain Non-U.S. International Providers,
or, in the Alternative, to Initiate a Rulemaking to Examine These Issues, WC Docket No. 06-122 (filed Sept. 8,
2 See id.
3 Id.
4 See Electronic Filing of Documents in Rulemaking Proceedings, GC Docket No. 97-113, Report and Order, 13
FCC Rcd 11322 (1998).

For ECFS filers, if multiple docket or rulemaking numbers appear in the caption of this
proceeding, filers must transmit one electronic copy of the comments for each docket or
rulemaking number referenced in the caption. In completing the transmittal screen, filers should
include their full name, U.S. Postal Service mailing address, and the applicable docket or
rulemaking number. Parties may also submit an electronic comment by Internet e-mail. To get
filing instructions, filers should send an e-mail to, and include the following words
in the body of the message, "get form." A sample form and directions will be sent in response.

Paper Filers: Parties who choose to file by paper must file an original and four copies of each
filing. If more than one docket or rulemaking number appears in the caption of this proceeding,
filers must submit two additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail (although we continue to experience delays in receiving U.S.
Postal Service mail). All filings must be addressed to the Commission's Secretary, Office of the
Secretary, Federal Communications Commission.
The Commission's contractor will receive hand-delivered or messenger-delivered paper filings
for the Commission's Secretary at 236 Massachusetts Avenue, N.E., Suite 110, Washington, D.C. 20002.
The filing hours at this location are 8:00 a.m. to 7:00 p.m. All hand deliveries must be held together with
rubber bands or fasteners. Any envelopes must be disposed of before entering the building. Commercial
overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must be sent to 9300 East
Hampton Drive, Capitol Heights, MD 20743. U.S. Postal Service first-class, Express, and Priority mail
should be addressed to 445 12th Street, S.W., Washington D.C. 20554.
People with Disabilities: To request materials in accessible formats for people with disabilities
(Braille, large print, electronic files, audio format), send an e-mail to or call the
Consumer & Governmental Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (tty).

In addition, one copy of each pleading must be sent to each of the following:

(1) The Commission's duplicating contractor, Best Copy and Printing, Inc., 445 12th Street, S.W., Room
CY-B402, Washington, D.C. 20554,; phone: (202) 488-5300 fax: (202) 488-
(2) Cindy Spiers, Telecommunications Access Policy Division, Wireline Competition Bureau, 445 12th
Street, S.W., Room 5-B432, Washington, D.C. 20554; e-mail:; and
(3) Antoinette Stevens, Telecommunications Access Policy Division, Wireline Competition Bureau, 445
12th Street, S.W., Room 5-B521, Washington, D.C. 20554; e-mail:
Filings and comments are also available for public inspection and copying during regular
business hours at the FCC Reference Information Center, Portals II, 445 12th Street, S.W., Room CY-
A257, Washington, D.C. 20554. They may also be purchased from the Commission's duplicating
contractor, Best Copy and Printing, Inc., Portals II, 445 12th Street, S.W., Room CY-B402, Washington,
D.C. 20554, telephone: (202) 488-5300, fax: (202) 488-5563, or via e-mail

This matter shall be treated as a "permit-but-disclose" proceeding in accordance with the
Commission's ex parte rules.5 Persons making oral ex parte presentations are reminded that memoranda
summarizing the presentations must contain summaries of the substance of the presentation and not
merely a listing of the subjects discussed. More than a one or two sentence description of the views and
arguments presented generally is required.6 Other rules pertaining to oral and written ex parte
presentations in permit-but-disclose proceedings are set forth in section 1.1206(b) of the Commission's
For further information, please contact Cindy Spiers, Telecommunications Access Policy
Division, Wireline Competition Bureau at (202) 418-1593 or TTY (202) 418-0484.
- FCC -

5 47 C.F.R. 1.1200 et seq.
6 See 47 C.F.R. 1.1206(b)(2).
7 47 C.F.R. 1.1206(b).

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