20220323Application.pdf

Lance J.M. Steinhart, P.C.
Attomeys At Law
I 725 Windward Concourse
Suite 150
Alpharett4 Georgia 30005
March 22,2022
RECF IVED
202? NitAtT 23 AN{ '1 1:0(t
lL)n HC) Pt jt1l.l(,
U l ll ll'lE.s (i( )Millsstc)NJ
Telephone: [phone]
Facsimile: [phone]
Avd'r - Ll-b I
VIA EMAIL DELIVERY TO
j an.noriyuki@Iuc. idaho. gov
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise,Idaho 83702
AirVoice Wireless, LLC dlbl aAirTalk
Application for Limited Designation as an Eligible Telecommunications Carrier
Dear Ms. Noriyuki:
Please find for filing AirVoice Wireless, LLC d/b/a AirTalk 's Application for Limited
Designation as an Eligible Telecommunications Carier in the State of Idaho.
If you have any questions, or if I may provide you with additional information, please do not
hesitate to contact me. Thank you.
Respectfu lly submitted,
Also Admitted in New York
Email: [e-mail]
Enclosurescc: Henry Do
Re
ffi
Lance J.M. Steinhart, Esq.
Managing Attomey
Lance J.M. Steinhart, P.C.
Attorneys for AirVoice Wireless, LLC
d/b/a AirTalkWireless
BETORE TEE
IDAHO PI]BLIC UTILITIDS COMIIISSION
AirVoicc Wircless, LLC
d/b/a AirTalk lVirclcss
Application for Designation as an Eligible
Tslccommunications Carrier
March 22,2A22
CaseNo.Arrul.'izl-o I
APPLICATION
Lance J.M. Steintmrt
lvlanaging Attorncy
Lance J.M. Steinhart, P.C.
1725 \flindward Concourse, Suitc 150
Alphatetta" Georgis 30005
Q70)232-9200 (Phone)
Q7q232-9208 (Fax)
EMail: [e-mail]
Attorneys for AirYoice Wireless, LLC
d/b/a AirTal.k Wireless
I.
II.
m.
ry.
V.
u.
VII
TABLE OF CONTENTS
INTRODUCTION
COMPANY OVERVIEW
THE COMMISSION H,AS JURISDICTION OVER DESIGNATION OF
WIRELESS ETCS
AIRVOICE SATISFIES THE REQUIREMENTS FOR DESIGNATION AS
AN ETC UNDER 47 C.F.R. $ 54.201
AIRVOICE SATISFIES TI{E ADDITIONAL REQUIREMENTS FOR ETC
DESIGNATION LJNDER4T C.F.R. $ sa.202(a)
DESIGNATION OF AIRVOICE AS AN ETC WOULD PROMOTE THE
PUBLIC INTEREST
.4
.6
5
t6
.23
.27
2
TABLE OX'EXHIBITS
Exhibit
Certification I
FCC-Approved Compliance Plan...........
Coverage Area . "........
Key Management Bios.....
Proposed Lifeline Offering
Sample Advettisement..................
)
?
3
BEF'ORE THE
IDAIIO PUBLIC UTILITIES COMI\ISSION
AirVoice Wireless, LLC
AirTalk Wireless
Application for Designation as an Eligible
Telecommunications Carrier
I. INTRODUCTION
AirVoice Wireless, LLC dlbla AirTalk Wireless ("AirVoice" or the "Company"), by its
undersigned counsel, and pursuant to Section zla@)Q) of the Communications Act of 1934, as
amended (the "Act"),l Sections 54.101 through 54.207 of the Rules of the Federal
Communications Commission ("FCC"),2 and the rules and regulations of the Idaho Public Utilities
Commission ("Commission"), hereby submits this Application for Designation as an Eligible
Telecommunications Carrier (*ETC") in the State of Idaho (this "Application").
AirVoice seeks ETC designation solely to provide Lifeline service to quali$ing Idaho
consumers; it will not (and is not eligible to) seek access to funds from the federal Universal
Service Fund ("USF") forthe purpose ofparticipating in the Link-Upprogram orproviding service
to high-cost areas.3 AirVoice requests that its designation as an ETC include the authority to
' 47 U.S.C. $ 2la(e)(2)
2 47 C.F.R. $$ 54.10r-54.207.
3 Given that the Company only seeks Lifeline support from the low-income program and does not seek any high-cost
support, ETC certification requirements for the high-cost program are not applicable to the Company.
)
)
)
)
)
No.Case
4
participate in and receive reimbursement from the ldaho Telephone Service Assistance Program
(rrsAP).
As demonstrated herein, and as certified in Exhibit I attached hereto, AirVoice meets all
the statutory and regulatory requirements for designation as an ETC in the State of Idaho, including
the requirements outlined in the FCC's Lifeline and Link Up Reform Order,4 Lifeline
Modernizotion Order,s and Fifth Report and Order.6 Furthermore, AirVoice is positioned to reach
unserved and underserved Lifeline-eligible consumers. Rapid grant of AirVoice's request,
therefore, would advance the public interest because it would enable the Company to commence
much needed Lifeline services to a wide array of low-income Idaho residents as soon as possible.
Accordingly, the Company respectfully requests that the Commission expeditiously approve this
Application.
All correspondence, communications, pleadings, notices, orders and decisions relating to
this Application should be addressed to:
Lance J.M. Steinhart
Managing Attorney
Lance J.M. Steinhart, P.C.
Attorneys for AirVoice Wireless, LLC
d/bla AirTalk Wireless
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005
a In the Motter of Lifeline and Link Up Reform and Modernization, Lifeline and Link Up, Federal-State Joint Board
on Universal Service, Advancing Broadband Availability Through Digital Literacy Training, WC Docket No. ll-42,
WC Docket No. 03-109, CC Docket No. 96-45, WC Docket No. 12-23, Report and Order and Further Notice of
Proposed Rulemaking, FCC 12- l I (rel. Feb. 6,2012) (" Lifeline and Link Up Reform Ordef').
5 In the Matter of Lifeline and Link (lp Reform and Modernization, Telecommunications Caruiers Eligible for
Universal Sentice Support, Connect America Fund, WC Docket No . 11-42, WC Docket No .09-197, WC Docket No.
10-90, Third Report and Order, Further Report and Order, and Order on Reconsideration, FCC 16-38 (rel. Apr.27,
20I6) (hereinafter,"Third Report and Order" or"LifeLine Modernization Order").
6 In the Matter of Bridging the Digilal Divide for Low-Income Consumers, Lifeline and Link Up Reform and
Modernization, Telecommunications Carriers Eligible for Universql Sentice Support, WC Docket No. 17-287, WC
Docket No. l1-42, WC Docket No. 09-197, Fifth Report and Order, Memorandum Opinion and Order and Order on
Reconsideration, and Further Notice of Proposed Rulemaking, FCC l9-l I I (rel. Nov. 14, 2019) (hereinafter, "Fifih
Report and Order").
5
[phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
II. COMPAIYY OVERVIEW
AirVoice is a Michigan limited liability company,T with its principal office located at9920
Brooklet Drive, Houston, Texas 77099. AirVoice is a provider of commercial mobile radio service
("CMRS") and provides prepaid wireless telecommunications services to consumers by using the
underlying wireless networks of AT&T Mobility LLC and T-Mobile USA, Inc. ( its "Underlying
Carriers") on a wholesale basis. AirVoice obtains the network infrastructure and wireless
transmission facilities from its Underlying Carriers to allow the Company to operate as a Mobile
Virtual Network Operator ("M\4{O").
AirVoice is currently designated as an ETC and providing Lifeline services in the
following jurisdictions: California, Kentucky, Michigan, Mississippi, New York, Ohio,
Oklahoma, Pennsylvania, South Carolina and Wisconsin. AirVoice also provides non-Lifeline
mobile phone services and is an approved provider of broadband services under the FCC's
Affordable Connectivity Program ("ACP"). AirVoice is a wholly owned subsidiary of VTel
Holdings, LLC, a Texas limited liability company ("VTel"). Henry Hung Do, a United States
citizen and a resident ofthe State of Texas, owns one hundred percent (100%) of: (a) VTel, which
was formed to acquire 100% ownership interest in AirVoice; (b) Cintex Wireless, LLC dlbla SFone
Wireless, a Delaware limited liability company ("Cintex"), that provides Lifeline-only wireless
services as an ETC in Arkansas, Maryland, Maine, Rhode lsland, and West Virginia and non-
Lifeline wireless services throughout the United States, and is approved to provide ACP services
in over 45 jurisdictions; (c) NewPhone Wireless, LLC, a Louisiana limited liability company
7 Airvoice was formed in the State of Michigan on May 7, 1999
6
('NewPhone"), that is authorized to provide non-Lifeline wireless service throughout the United
States and ACP services in over 45 jurisdictions, and provides Lifeline-only wireless services as
an ETC in Louisiana; (d) HTH Communications, LLC,aTexas limited liability company, a global
and one of the largest mobile device distributors in the United States, which has been in business
for more than thirteen (13) years; (e) SofTel Technologies, LLC, a Texas limited liability company,
that provides distribution services to wireless providers; and (f) Softel Holdings, LLC, a Texas
limited liability company which was formed to acquire 100% ownership interest in TAG Mobile,
LLC ("TAG Mobile")8, a limited liability company organized under the laws ofthe State of Texas.
TAG Mobile provides wireless Lifeline services to customers in the following nineteen (19) states
in which it has been designated an ETC: Arizona, Arkansas, Califomia, Colorado, Iowa,
Kentucky, Louisiana, Maine, Maryland, Michigan, Minnesota, Missouri, Nevada, Oklahoma,
Pennsylvania, South Carolina, Texas, West Virginia and Wisconsin.e
Under current ownership, neither AirVoice nor its afliliates have been subject to
enforcement sanctions related to the Low-lncome Fund or ETC revocation proceedings in any
state except as noted below.lo
8 In connection with the proposed transaction with Softel Holdings, LLC (the "Transaction"), TAG Mobile formed
TAG Mobile Bankruptcy Sale Entity, LLC ("New TAG Mobile") as a wholly owned subsidiary. New TAG Mobile
is a Texas limited liability company created to receive the regulated assets of TAG Mobile at the closing of the
Transaction. New TAG Mobile currently owns no assets and has no debts. Upon consummation of the Transaction,
New TAG Mobile will acquire all of the regulated assets of TAG Mobile, including its Lifeline customers, wireless
authorizations and its designations as an ETC. Thereafter, New TAG Mobile will operate pursuant to those wireless
authorizations and designations to provide Lifeline services to eligible consumers in its designated service areas.
e TAG Mobile holds Section 214 authority from the FCC. Filings for necessary approvals of the Transaction in
connection with this authority are pending with the FCC.
l0 Pursuant to aMembership Interest Purchase Agreement dated February 6,2}lg,Henry Hung Do purchased 100%
of the equity of Cintex. Pursuant to an Order and Consent Decree adopted on December 22, 2017 , Cintex settled a
Notice of Apparent Liability with the FCC (See File No. EB-IHD-13-00010671), which all occurred under prior
ownershipandmanagement. ByOrderadoptedDecember16,202l (SeeFileNo.EB-IIID-20-00031449),NewPhone
entered into a Consent Decree with the Enforcement Bureau of the FCC for the purpose of terminating the Bureau's
investigafion on whetherNewPhone, as an ETC, claimed support from the Lifeline program of the Universal Service
Fund (USF or Fund) for duplicate or otherwise ineligible subscribers. On September 23,2020, the Bureau issued
NewPhone an LOI to obtain information about the claims in question. NewPhone filed its response to the LOI on
7
AirVoice will provide affordable prepaid mobile phone service and high-quality customer
service. AirVoice's service offering will include: (l) local and long-distance calling; (2) access to
the following custom calling features at no charge: (a) Caller ID; (b) Call Waiting; (c) Call
Forwarding; (d) 3-Way Calling; and (e) Voicemail; (3) text messaging; (4) broadband access; and
(5) the option for a consumer to "bring their own device". AirVoice may offer user-friendly
handsets or hotspot devices. AirVoice's products and plans will be specially geared toward serving
lower income communities, especially in rural areas that are predominantly unserved by other
ETCs designated in the state, and its service models and pricing plans will reflect this mission.
The Company will not require service contracts from its customers, and it will always ensure
competitively low pricing for its services and products. AirVoice will manage all aspects of the
customer experience, including setting service pricing, handset selection, marketing materials, and
live customer service. The Company's prepaid, budget-friendly pricing will give many low-
income consumers the option of having mobile phone service and broadband access without the
burden of hidden costs, varying monthly charges, or contractual commitments. Customers will be
able to customize their AirVoice service to suit their needs with AirVoice's available bundles of
minutes, broadband data, and text packages to supplement their monthly plan.
AirVoice's Lifeline customers will be low-income consumer households, and the majority
are unlikely to have had phone service or broadband access of any kind prior to enrollment.
AirVoice's customers will depend on, and benefit greatly from, AirVoice's inexpensive and
flexible pricing plans. AirVoice will not impose credit checks, nor will it require any deposits or
November 23, 2021. Within weeks after USAC notified NewPhone ofthe apparently improper use of beneficiary data,
the Company terminated its relationship with the Marketing Agents involved in the enrollments. USAC worked with
NewPhone from early August through October 2020 to address the issues raised by the claims. On October 30,2020,
NewPhone submitted revised claims which USAC agreed addressed the full amount at issue in its investigation.
Because USAC determined NewPhone had promptly submitted revised claims in the full amount USAC sought, there
was no need to issue a recovery letter. To resolve the matter, NewPhone agreed to implement a compliance plan and
make a $100,000 settlement payment.
8
contractual commitments. AirVoice's Customers may turn to AirVoice because they cannot afford
the postpaid services provided by traditional wireless carriers. AirVoice will affirmatively reach
out to the low-income sector of the consumer base to offer attractive and affordable
communications options. As such, AirVoice will contribute to the expansion of mobile wireless
and broadband services for low-income consumers in Idaho.
IIL TIIE COMMISSION HAS JURISDICTION OVER DESIGNATION OF WIRELESS
ETCS
Section 2la@)Q) of the Act provides state public utility commissions with the "primary
responsibility" for the designation of ETCs.rr Although Section 332(cX3XA) of the Act prohibits
states from regulating the entry of or the rates charged by any provider of commercial mobile
service or any private mobile service, this prohibition does not allow states to deny wireless carriers
ETC status.12 Under the Act, a state public utility commission with jurisdictional authority over
ETC designations must designate a common carrier as an ETC if the carrier satisfies the
requirements of Section 2 l (e)(l ).
AirVoice recognizes that Section 2la(e)(l)(A) of the Act states that ETCs shall offer
services, at least in part, over their own facilities and that Section 54.201(i) of the FCC's Rules (47
C.F.R. $ 54.201(i)) prohibits state commissions from designating as an ETC a telecommunications
carrier that offers services exclusively through the resale of another carrier's services. However,
the FCC has granted forbearance from enforcement ofthis facilities requirement to carriers seeking
Lifeline-only ETC designation.13 Section l0(e) of the Act (47 U.S.C. $ 160(e)) provides: "[a]
State commission may not continue to apply or enforce any provision of this chapter that the
" 47 U.S.C. $ 2la(eX2).
t2 USF Order,at 8858-59, fl 145.
t3 See Lifeline and Link llp Reform Order atl368.
9
[Federal Communications] Commission has determined to forbear from applying under subsection
(a) of this section." As such, the Commission is required by Section l0(e) to act in accordance
with the FCC's grant of forbearance, and therefore, may not apply the facilities-based requirement
to AirVoice. Therefore, the Commission has the authority under Section zla@)Q) of the Act to
grant AirVoice's request for designation as an ETC throughout the State of Idaho.
W. AIRVOICE SATISFIES THE REQUIREMENTS FOR DESIGNATION AS AN
ETC UNDER 47 C.F.R. S s4.20r
Section 25a@) of the Act provides that, "only an eligible telecommunications carrier
designated under section 2la@) shall be eligible to receive specific federal universal service
support." Section zla@)Q) of the Act authorizes state commissions, such as the Commission, to
designate ETC status for federal universal service purposes and authorizes the Commission to
designate wireless ETCs.ra Section 2la(e)(l) of the Act and Section 54.201(d) of the FCC's rules
provide that applicants for ETC designation must be common carriers that shall, throughout the
designated service area, offer all ofthe services supported by universal service, either using their
own facilities or a combination of their own facilities and the resale of another carrier's services,
except where the FCC has forborne from the "own facilities" requirement. Applicants also must
commit to advertise the availability and rates of such services.ls As detailed below, AirVoice
satisfies each of the aboveJisted requirements.
ta See Federal-State Joint Board on Universal Service, First Report and Order, 12 FCC Rcd 8776, 8858-59, fl 145
(1997) (*USF Order").
ts See 47 U.S.C. $ 2la(eXl) and 47 C.F.R. $ 54.201(dX2).
l0
A.AirVoice Will Provide Service Consistent with the FCC's Grant of
Forbearance from Section 214's Facilities Requirements
Although Section 214 requires ETCs to provide services using their facilities, at least in
part, the FCC has forborne from that requirement with respect to carriers such as AirVoice. In the
Lifeline and Link Up Reform Order, the FCC granted forbearance from the "own-facilities"
requirement contained in Section 2la(e)(l)(A) for carriers that are, or seek to become, Lifeline-only
ETCs, subject to the following conditions:16
(l) the carrier must comply with certain 9ll requirements [(a) providing its Lifeline
subscribers with 9ll and E9ll access, regardless of activation status and availability of
minutes; (b) providing its Lifeline subscribers with E9l l-compliant handsets and replacing,
at no additional charge to the subscriber, noncompliant handsets of Lifeline-eligible
subscribers who obtain Lifeline-supported services; and (c) complying with conditions (a) and
(b) starting on the effective date of this Orderl; and
(2) the carrier must file, and the Bureau must approve, a compliance plan providing specific
information regarding the carrier's service offerings and outlining the measures the carrier
will take to implement the obligations contained in this Order as well as further safeguards
against waste, fraud and abuse the Bureau may deem necessary.
In accordance with the Lifeline and Link Up Reform Order, AirVoice filed a Compliance
Plan with the FCC, which the FCC approved on December 26,2012.t7 The FCC approved
AirVoice's Revised Compliance Plan on December 23, 2O2l l8 as the final condition to the
Company's transfer of control to VTel. A copy of the Company's current FCC-Approved
Compliance Plan is attached hereto as Exhibit 2. AirVoice commits to providing Lifeline service
in Idaho in accordance with its FCC-approved Compliance Plan and in compliance with applicable
t6 See Lifeline and Link Up Reform Order at lJll 368, 373, and379.
r7 See FCC Public Notice DA 12-2063, https://www.fcc.sov/document/w'cb-approves-nine-lifeline-compliance-
plans.
r8 See Public Notice DA 2l-l&1,
wireless-llc.
/document/wc
ll
state and federal regulations, to the extent amendments thereto may supersede commitments made
in the Compliance Plan.
B. AirVoice Is a Common Carrier
CMRS providers like AirVoice are treated as common carriers.le
C. AirVoice Will Provide All Supported Services
Through its Underlying Carriers, AirVoice is able to provide all of the supported services
required by Section 54.101(a) of the FCC's Rules (47 C.F.R. $ 5a.l0l(a)) as follows:
1. Voice Telephony Service
As set forth in 47 C.F.R. $ 5a.l0l(a)(l), eligible Voice Telephony Services must provide
the following:
Voice Grade Access to the Public Switched Telephone Neturork. AirVoice provides
voice grade access to the public switched telephone network ("PSTN") through the purchase of
wholesale CMRS services from its Underlying Carriers.
Local Usase At No Additional Charge. AirVoice offers rate plans that provide its
customers with minutes of use for local service at no additional charge.
Access to Emergency Services. AirVoice provides 9ll and E9ll access for all of its
customers to the extent the local govemment in its service area has implemented 911 or E9l I
systems. As noted, calls to 9l I emergency services will always be free and will be available
regardless of service activation status or availability of minutes. AirVoice also complies with the
te Implementation of Sections 3(n) and 332 of the Communications Act, Regulalory Treatment of Mobile Servicec GN
Docket No. 93-252, Second Report and Order, 9 FCC Rcd l4ll, 1425 fl 37, 1454-55 fl 102 (1994) (wireless resellers
are included in the statutory "mobile services" category, and providers of cellular service are common carriers and
CMRS providers); 47 U.S.C. $ 332(c)(lXA) ("mobile seryices" providers are common carriers); see also PCIA
Pelitionfor Forbearancefor Broadband PCS, WT Docket No. 98-100, (Memorandum Opinion and Order and Notice
of Proposed Rulemaking, 13 FCC Rcd 16857, 169l I tT I 11 (1998) ("We concluded [in the Second Report and Orderl
that CMRS also includes the following common carrier services: cellular service, ... all mobile telephone sewices and
resellers of such services.") (emphasis added).
t2
FCC's regulations governing the deployment and availability of E9l I compatible handsets.
Toll Limitation. In its Lifeline and LinkUp Reform Order, the FCC provided thattoll
limitation would no longer be deemed a supported service.2o "ETCs are not required to offer toll
limitation service to low-income consumers if the Lifeline offering provides a set amount of
minutes that do not distinguish between toll and non-toll calls."2l Nonetheless, AirVoice's
offerings inherently allow Lifeline subscribers to control their usage, as its wireless service is
offered on a prepaid, or pay-as-you-go, basis. AirVoiceos service, moreover, is not offered on a
distance-sensitive basis and local and domestic long-distance minutes are treated the same.
2. Broadband Internet Access Services
While no longer a supported service under 47 C.F.R. $ 54.101(a), AirVoice provides
Broadband Intemet access service ("BIAS") in accordance with the FCC's minimum service
standards to ensure Lifeline customers receive full support. The FCC has stated that BIAS consists
of the ability for a user to receive "the capability to transmit data to and receive data from all or
substantially all Internet endpoints, including any capabilities that are incidental to and enable the
operation of the communications service, but excluding dial-up Internet access service."22
AirVoice provides BIAS to low-income consumers via resale of AT&T and T-Mobile services.
D. AirVoice Requests Designation Throughout Its Service Area
AirVoice is not a rural telephone company as defured in Section 153(37) of the Act (47
U.S.C. $ 153(37). Accordingly, AirVoice is required to describe the geographic area(s) within
which it requests designation as an ETC. AirVoice requests ETC designation that is statewide in
scope to allow the Company to provide Lifeline service wherever its underlying, facilities-based
20 See Lifeline and Link (lp Reform Order atl367
2t See id. at\49.
22 See 47 C.F.R. $ 8.2(a).
l3
providers have wireless coverage, including federally recognized tribal lands. The Company's
coverage is attached hereto as Exhibit 3. AirVoice understands that its service area overlaps with
rural carriers in Idaho but maintains that the public interest factors described below justifu its
designation in these carriers' service areas, especially because it seeks ETC designation solely to
utilize USF funding to provide Lifeline service to qualified low-income consumers. AirVoice is
not eligible for and does not seek Link-Up or high-cost support.
Therefore, designation of AirVoice as an ETC will cause no growth in the high-cost
portions of the USF and will not erode high-cost support from any rural telephone company. In
fact, the FCC has determined that "[d]esignation of competitive ETCs promotes competition and
benefits consumers in rural and high-cost areas by increasing customer choice, innovative services,
and new technologies."23 While federal rules (47 U.S.C. $$ 160, 2la(e)(5) and 47 C.F.R. $
54.207(b)) require that the service area of an ETC conform to the service area of any rural
telephone company serving the same area (the "service area conformance" requirement), the
FCC's Lifeline and Link Up Reform Memorandum Opinion and Order (FCC l3-44 released April
15,2013) authorized forbearance from the service area conformance requirements with respect to
carriers seeking to provide Lifeline-only service.2a In light of this forbearance, the Commission
has the authority to designate ETCs such as AirVoice in rural areas without concem for the service
area conformance requirement.2s
23 See Western Wireless Corporation Petitionfor Designation as an Eligible Telecommunications Carrier in the State
of llyoming, Memorandum Opinion and Order,16 FCC Rcd 48, 55 (2000).
2a See In the Matter of Telecommunications Carriers Eligible for Support, Lifeline and Link Up Reform, WC Docket
No.09-197, WC DocketNo.ll-42, Memorandum Opinion and Order, FCC l3-44 (rel. April 15,2013).
2s See 47 C.F.R. $ 54.207(c).
l4
E. AirVoice Will Advertise the Availability of Supported Seruices
AirVoice will advertise the availability and rates for the services described above using
media of general distribution as required by 47 C.F.R. $ 54.201(d)(2). AirVoice will comply with
the FCC's rules regarding information to be included in marketing materials, including FCC rule
section 54.405(c). Specifically, AirVoice's marketing materials will state, in easily understood
language, that: (i) the service is a Lifeline service; (ii) Lifeline is a government assistance program;
(iii) the service may not be transferred to someone else; (iv) consumers must meet certain
eligibility requirements before enrolling in the Lifeline program; (v) the Lifeline program permits
only one Lifeline discount per household; (vi) documentation is necessary for enrollment; and (vii)
AirVoice is the provider of the services. Moreover, the Lifeline application/certification form will
state that Lifeline is a federal benefit and that consumers who willfully make a false statement in
order to obtain the Lifeline benefit can be punished by fine or imprisonment or can be barred from
the program. Additionally, AirVoice will disclose the company name under which it does business
and the details of its Lifeline service offerings in any Lifeline-related marketing and advertising.
AirVoice will engage in advertising campaigns specifically targeted to reach those likely
to qualifu for Lifeline service, promoting the availability of cost-effective wireless services to this
neglected consumer segment. AirVoice may also promote the availability of its Lifeline offering
by distributing brochures at various state and local social service agencies and may partner with
nonprofit assistance organizations in order to inform customers of the availability of its Lifeline
service. In addition, AirVoice intends to utilize its network of retail partners (once established) to
help promote the availability of its Lifeline plans, especially retail outlets that are frequented by
low-income consumers. AirVoice will provide retail vendors with signage to be displayed where
Company products are sold, and with printed materials describing the Company's Lifeline
l5
program. AirVoice will also do on-line marketing which may include social media and other on-
line channels.
V. AIRVOICE SATISFIES THE ADDITIONAL REQUIREMENTS FOR ETC
DESIGNATION UNDER 47 C.F.R. $ 54.202(a)
AirVoice hereby provides the additional information and certifications required for carriers
seeking ETC designation as set forth in 47 C.F.R. $ 5a.202(a).
A. Service Commitment Throughout the Proposed Designated Service Area
AirVoice will provide service in ldaho by reselling service which it obtains from its
Underlying Carriers, whose networks are operational and largely built out. Thus, AirVoice will be
able to commence offering its Lifeline service to all locations served by its Underlying Carriers
very soon after receiving approval from the Commission.
In accordance with 47 C.F.R. $ 54.202(a)(l)(i), and by the certification attached in Exhibit l,
AirVoice commits to comply with the service requirements applicable to the low-income support
that it receives. Pursuant to 47 C.F.R. $ 54.202(axlXiD, a common carrier seeking designation as
a Lifeline-only ETC is not required to submit a five-year network improvement plan as part of its
application for designation as an ETC.
l6
B. Ability to Remain Functional in Emergency Situations
In accordance with 47 C.F.R. $ 5a.202(a)(2), AirVoice has the ability to remain functional
in emergency situations. As discussed, AirVoice will utilize the extensive and well-established
network facilities of Tier I wireless carriers to provide its Lifeline services. The Company
understands that its Underlying Carriers' networks have access to a reasonable amount of back-up
power to ensure functionality without an external power source, are able to reroute traffic around
damaged facilities, and are capable of managing traffic spikes resulting from emergency situations.
Indeed, its Underlying Carriers have repeatedly certified to the FCC that its network functions in
emergency situations.26 The Underlying Carriers provide this functionality to AirVoice and its
customers.
C. Commitment to Consumer Protection and Service Quality
In accordance with 47 C.F.R. $ 54.202(a)(3), an ETC applicant must demonstrate that it
will satisfu applicable consumer protection and service quality standards, and wireless applicants
may satisfr this requirement with a commitment to comply with the Cellular Telecommunications
and Internet Association's ("CTIA") Consumer Code for Wireless Service. AirVoice hereby
commits to comply with the CTIA Consumer Code for Wireless Service.
D. AirVoice is Financially and Technically Capable
In accordance with 47 C.F.R. $ 5a.202(a)(4), AirVoice is financially and technically capable
of providing Lifeline-supported services and is currently offering Lifeline service in ten (10)
jurisdictions. In addition, AirVoice has been providing non-Lifeline wireless service throughout
the United States since 1999. AirVoice receives revenue from a number of sources which are
26 See, e.g., In the Matter of Telecommunications Carriers Eligible for [Jniversal Service Support, Petition of AT&T
USA, Inc. for Designation as a Low-Income Eligible Telecommunications Carrier, et al., WC Docket No. 09-197, at
20 (released Alug. 16, 2012).
t7
completely independent from the revenue it will receive in the form of Lifeline support. AirVoice
does not and will not rely exclusively on USF disbursements to operate. [n addition, AirVoice's
financial and technical capabilities to provide service are demonstrated by its performance over
twenty-two (22) years in the wireless telephone industry, with consistently strong service, organic
growth, and robust protections to ensure its Lifeline customers meet eligibility requirements.
AirVoice's new ownership and affiliates will also provide additional financial, technical and
managerial support as needed.
Furthermore, the senior management of AirVoice has great depth in the
telecommunications industry and offers extensive telecommunications business technical and
managerial expertise to AirVoice.2T AirVoice will be providing resold wireless service, and
therefore will also rely upon the managerial and technical expertise of its Underlying Carriers.
E. Terms and Conditions of Proposed Lifeline Offering
AirVoice has the ability to provide all services supported by the universal service program,
as detailed in 47 C.F.R. $ 5a.l0l(a), throughout Idaho. AirVoice intends to be a leader in the
prepaid marketplace by offering consumers exceptional value and competitive amounts of voice
and broadband usage. AirVoice commits that its Lifeline-supported voice services will meet or
exceed the minimum service standards set forth in 47 C.F.R. $ 54.408, including as such standards
are updated going forward. AirVoice's Lifeline-supported broadband services will also meet the
minimum service standards set forth in 47 C.F.R. $ 54.408 for mobile broadband internet access
services, including for service speed and data usage allowance, as such standards are updated going
forward. To the extent AirVoice provides devices for use with Lifeline-supported broadband
service, such devices will meet the equipment requirements set forth in 47 C.F.R. $ 54.408(f), and
27 See altached Exhibit 4 for key management bios.
l8
AirVoice will not impose an additional or separate tethering charge for mobile data usage below
the minimum standard.
Attached hereto as Exhibit 5 is a summary table of the Company's proposed Lifeline service
offerings, showing that non-tribal Lifeline customers will receive 1000 voice minutes, unlimited
text messages, and 4.5 gigabytes (GB) of data per month with full access to its Underlying Carriers'
networks at a net cost of $0.00 after application of Lifeline support.2s Lifeline customers that also
elect to receive ACP benefits from AirVoice will receive unlimited talk and text with l5 GB data
(unlimited data for tribal customers) after application of Lifeline and ACP support. Customers
will be able to purchase additional minutes or data as needed. All plans will include nationwide
domestic long-distance at no extra per-minute charge, and AirVoice will not assess any usage for
access to its free customer services (61l). Emergency (91l) calls will be free, regardless of service
activation or availability of minutes, and will not count against the customer's airtime. The
Company's Lifeline offering will provide feature-rich mobile connectivity for qualiffing
subscribers without the burden of credit checks or service contracts. AirVoice's prepaid offering
will be an attractive alternative for consumers who need the mobility, security, and convenience
of a wireless phone, but who are concemed about usage charges or long-term contracts.
F. AirVoice Will Comply with the Lifeline Certification and Verification
Requirements
Customers interested in obtaining information on the Lifeline program will be directed to
a toll-free telephone number and to the Company's website, www.airtalkwireless.com, which will
contain information regarding the Company's Lifeline service plans, including a description of the
Lifeline program and eligibility criteria. Customers must then apply directly through the National
28 The current rate plan is based upon the December 2021 FCC minimum service standards ("MSS") and will change
based on the future MSS. AirVoice's rate plan for eligible residents of fbderally recognized tribal lands includes
unlimited talk, unlimited text, and unlimited data.
l9
Lifeline Eligibility Verifier ('National Verifier"), which they may do online or by submitting all
required documentation to the National Verifier by mail. Customers may download a copy of the
application form from the Internet (either from the National Verifier's or Company's website) or
request that a copy be mailed to them. AirVoice utilizes the standard Lifeline application forms as
required by FCC rules, and thus complies with the disclosure and information collection
requirements in 47 C.F.R. $ 54.410(d).2e Airvoice will certiff and veri$ initial and continued
consumer eligibility in accordance with 47 C.F.R. $ 54.410 and will notiff the applicant that the
prepaid service must be personally activated by the subscriber and the subscriber must use their
service every thirty (30) days. AirVoice further confirms that it will not provide a consumer with
an activated device and will not activate a Lifeline service unless or until it has confirmed that the
consumer is a qualiffing low-income household pursuant to 47 C.F.R. $ 54.409 and completed the
required eligibility determination and certification requirements of 47 C.F.R. $$ 54.410,54.404-
54.405. Processing of consumers' applications and determination of eligibility will be performed by
the National Verifier.
G. Prevention of Waste, Fraud and Abuse
AirVoice recognizes the importance of safeguarding the USF and has implemented
measures and procedures to prevent duplicate Lifeline benefits being awarded to the same
household. AirVoice complies with the requirements of the National Lifeline Accountability
Database ("NLAD") and section 54.404 of the FCC's rules. In Idaho, the National Verifier queries
the NLAD for every enrollment to determine whether a prospective subscriber is currently
2e FCC Wireline Compelition Bureau Provides Guidance on Universal Formsfor the Lifeline Program, WC Docket
No. ll-42, Public Notice, "Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline
Program," DA 18-16l (rel. Feb. 20,2018). The standard application/certification forms are available on USAC's
website (See USAC, Lifeline Forms, http://www.usac.ore/liltools/forrns/default.aspx).
20
receiving a Lifeline service from AirVoice or any other ETC, and whether anyone else living at
the prospective subscriber's residential address is currently receiving Lifeline service. In addition,
Company personnel emphasize the "one Lifeline service per household" restiction in their direct
sales contacts with potential customers. Furthermore, the FCC has taken steps to curb abuse in the
Lifeline program by establishing the National Verifier, which transfers the responsibility of
eligibility determination away from Lifeline providers. AirVoice will rely on the National Verifier
to determine initial and ongoing eligibility of Idaho Lifeline subscribers.
Consistent with federal regulations, the Company will not seek USF reimbursement for
new subscribers until they have personally activated the service, either by initiation and/or actual
use of the service and will de-enroll any subscriber that has not used the Company's Lifeline
service as set forth in 47 C.F.R. $ 5a.a07(c)(2). An account will be considered active if the
authorized subscriber establishes usage, as "usage" is defined by 47 C.F.R. $ 5a.a07(c)(2), during
the specified timeframe, currently a period of thirty (30) days, or during the notice period set forth
in 47 C.F.R. $ 54.a05(e)(3), currently a period of fifteen (15) days. [n accordance with 47 C.F.R.
$ 5a.a05(e)(3), AirVoice will provide the subscriber advanced notice, using clear, easily
understood language, that the subscriber's failure to use the Lifeline service within the notice
period will result in service termination for non-usage. Customers that have been deactivated may
participate in the Company's Lifeline service in the future by reapplying and re-establishing
eligibility.
To further protect the integrity of the USF, AirVoice contracts with a third-party Lifeline
service bureau, currently CGM, LLC, to edit all subsidy request data. CGM will process and
validate the Company's subsidy data to prevent: (l) Duplicate Same-Month Lifeline Subsidies
(Double Dip): any name/address that is already receiving a lifeline subsidy from the Company will
2t
be automatically prevented from receiving a second lifeline subsidy in that same month; and (2)
Inactive lines receiving subsidy: CGM's systems compare all subsidy requests to underlying
network status to ensure that subsidies are requested only for active lines. Moreover, AirVoice
has implemented an intemal auditing process to review NLAD and CGM findings as a final layer of
fraud prevention. Through the processes described above, AirVoice ensures that it does not over-
request from support funds.
H. AirVoice Will Comply With All Regulations Imposed By The Commission
By this Application, AirVoice hereby asserts its willingness and ability to comply with all
the rules and regulations that the Commission may lawfully impose upon the Company's provision
of service contemplated by this Application. AirVoice commits to comply with applicable ITSAP
regulations, including but not limited to required monthly reporting, as well as execution of a
Memorandum of Understanding with the Department of Health and Welfare. AirVoice further
commits to remit required TTSAP funds to the ITSAP Administrator. Upon Commission request,
AirVoice is prepared to answer questions or present additional testimony or other evidence about
its services within the state.
As the Company is not seeking high-cost support for its wireless service, it hereby requests
a waiver of the Commission Rules, Commission Order No. 29841 Section B.l (two-year network
improvement and maintenance plan based on high-cost support). Because the Company is not
seeking high-cost support, this rule is not applicable and therefore should be waived.
22
VI. DESIGNATION OF AIRVOICE AS AI\ ETC WOULD PROMOTE THE PUBLIC
INTEREST
One of the principal goals of the Act, as amended by the Telecommunications Act of 1996,
is "to secure lower prices and higher quality services for American telecommunications consumers
and encourage the rapid deployment of new telecommunications technologies" to all citizens,
regardless of geographic location or income.3o Designation of AirVoice as an ETC in Idaho will
further that public interest. Whether because of financial constraints, poor credit history, or
intermittent employment, many low-income consumers often lack the countless choices available
to most consumers and thus have yet to reap the full benefits of the intensely competitive wireless
market.
The instant request for ETC designation must be examined in light of the Act's goal of
providing low-income consumers with access to telecommunications services. The primary
purpose of universal service is to ensure that consumerrparticularly low-income consumers-
receive affordable and comparable telecommunications services. The FCC has in recent years
expanded the Lifeline program to cover broadband services, noting that "Only half of all
households in the lowest income tier subscribe to a broadband service and 43 percent say the
biggest reason for not subscribing is the cost of the service," and "Of the low income consumers
who have subscribed to mobile broadband, over 40 percent have to cancel or suspend their service
due to financial constraints."3l Given this context, designating AirVoice as an ETC would
significantly benefit low-income consumers eligible for Lifeline services in Idahc-the intended
beneficiaries of universal service.
30 Telecommunications Act of 1996, Pub. L. No. 104-104, I l0 Stat. 56
3t See Lifeline Modernization Orderl2.
23
A. Advantages of AirVoice's Service Offering
AirVoice offers a unique, easy to use, competitive, and highly affordable wireless
telecommunications service, which benefits qualified consumers who either have no other service
alternatives or who choose a wireless prepaid solution in lieu of more traditional service. The
public interest benefits of AirVoice's wireless service include larger calling areas (as compared to
traditional wireline carriers), the convenience and security afforded by mobile service, and voice
and broadband access included without cost (after application of the Lifeline support), as well as
either a free SIM card or handset, and free access to caller ID, call waiting, and Voicemail features,
and access to 9l I services regardless of the number of voice minutes remaining on the Lifeline
consumer's plan. These no cost to consumer services and low'cost minutes are an invaluable
resource for cash-strapped consumers, and the prepaid nature of the service also provides an
alternative for "unbanked" consumers.
AirVoice's Lifeline offerings compare favorably with those of other competitive ETCs,
and provide Lifeline customers with voice minutes, text messages, and a data allotment (meeting
the voice and broadband minimum service standards), at no net cost to the customer after
application of Lifeline support. AirVoice's Lifeline offering will be provided over its Underlying
Carriers' networks. AirVoice's prepaid wireless service is likely to be an especially attractive
option for low-income consumers because it alleviates customer concerns regarding hidden costs,
varying monthly charges and long-term contract issues.
In today's market, consumers, including qualified Lifeline customers, view the portability
and convenience of wireless service not as a luxury, but as a necessity. Mobile service allows
children to reach their parents wherever they may be, allows a person seeking employment greater
ability to be contacted by potential employers, and provides end users with the ability to contact
24
emergency service providers regardless of location. Mobile service often also serves as a key
bridge in closing the homework gap for students who live in rural areas with limited access to
broadband.
With the comprehensive strength and experience of AirVoice's management team, the
Company's technology-based business model, and AirVoice's solid history as a Lifeline provider,
AirVoice is uniquely positioned to meet the needs of Lifeline customers, utilizing the Company's
innovative outreach and high integrity enrollment process, and AirVoice remains committed to
careful stewardship of the Lifeline program. Without question, prepaid wireless services have
become essential for low-income customers, providing them with value for their money, access to
emergency services on wireless devices, and a reliable means of contact for prospective employers,
social service agencies or dependents. Providing AirVoice with the authority necessary to offer
discounted Lifeline service to those without wireless service-or most in danger of losing service
altogether-undoubtedly promotes the public interest.
B. The Benefits of Competitive Choice
The FCC has acknowledged the benefits to consumers of being able to choose from among
a variety of telecommunications service providers for more than three decades.32 Increasing
customer choice promotes competition and innovation, thus spurring other carriers to target low-
income consumers with service offerings tailored to their needs, ultimately resulting in improved
services to consumers. Designation of AirVoice as an ETC will help ensure that quality services
are available at'Just, reasonable, and affordable rates" as envisioned in the Act.33 Introducing
AirVoice into the market as an additional wireless ETC provider will afford low-income ldaho
32 See, e.g., Specialized Common Carrier Services, 29 FCC Rcd 870 (1971).
33 See 47 U.S.C. $ 254(bXl).
25
residents a wider choice of providers and available services while creating a competitive
marketplace as ETCs compete for a finite number of Lifeline-eligible customers. Increasing the
competitive marketplace of providers has the potential to effectively increase the penetration rate
and reduce the number of individuals not connected to the PSTN.
C. Impact on the Universal Service Fund
With Lifeline, ETCs only receive support for customers they obtain. The amount of
support available to an eligible subscriber is exactly the same whether the support is given through
a company such as AirVoice or the Incumbent LEC operating in the same service area. The
number of persons eligible for Lifeline support is the same regardless of the number of ETCs; thus,
AirVoice will only increase the amount of USF Lifeline funding in situations where it obtains
Lifeline customers not already enrolled in another ETC's Lifeline program. By implementing the
safeguards set forth inthe Lifeline and LinkUp Reform Order and utilizing the NLAD and National
Verifier, the likelihood that AirVoice's customers are not eligible or are receiving duplicative
support either individually or within their household is greatly minimized. AirVoice's ability to
increase the Lifeline participation rate of qualiflred low-income individuals will further the goal of
Congress to provide all individuals with affordable access to telecommunications service, and thus
any incremental increases in Lifeline expenditures are far outweighed by the significant public
interest benefits of expanding the availability of affordable wireless services to low-income
consumers.
26
VII. CONCLUSION
Based on the foregoing, designation of AirVoice as an ETC in the State of Idaho complies
with the requirements of Section 2la@)Q) of the Act and is clearly in the public interest.
WHEREFORE, AirVoice hereby respectfully requests that the Commission promptly
designate AirVoice as an ETC in the State of Idaho for the purpose of participating in the Lifeline
program.
Respectfu lly submitted,
/s/ Lance J.M. Steinhart
Lance J.M. Steinhart
Managing Attorney
Lance J.M. Steinhart, P.C.
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail : lsteinhart@te lecomcounsel.com
Attorneys for AirVoice Wireless, LLC
ilb/a AirTalkWireless
March 22,2022
27
DTHIBIT T
Certificetion
STATE OF TEXAS
COTTNTY OX'EARRIS
I, Henry Do, Chief Exeqtrive Offrcer of AirVoice Wircless, LLC dlbla AirTalk Wireless (the
"Company'), hereby state upon oattr and affirmstion of belief and personal knowledge that the
rnafiers, facts and statemeirts set fordr in the foregoing Petition are true to the best of my knowledge
and belief.
I certi$ that the Company will oomply with the servioe requirerrents applicable to the low-income
support it reoeives.
Executive Offiocr
AirVoice Wircless,LLC
d/b/a AirTalk lVireless
)
)
)
IDBlT
Lance J.M. Steinhart, P.C.
Attomeys At Law
1 725 Windward Concourse
Suite 150
Alpharett4 Georgia 30005
Also Admitted in New York
Email : [e-mail]
Telephone: [phone]
Facsimile: (7 7 0) 232-9208
ItrIay 17,2021
VIA ECFS
Marlene H. Dortch, Secretary
Federal Communications Commission
45 L Street NE
Washington,DC 20554
Re AirVoice Wireless, LLC Revised Compliance Plan, WC DocketNos.09-197
and ll-42
Dear Ms. Dortch:
On December 7,2012, AirVoice Wireless, LLC ("AirVoice" or the "Company") submitted
its Compliance Plan for wireless Lifeline services, outlining the measures it would take to
implement the conditions imposed by the Federal Communications Commission ("FCC" or the
"Commission") in its 2012 Lifeline Reform Order.l The Wireline Competition Bureau (Bureau)
approved AirVoice's Compliance Plan on December 26,2012.-
I See Lifeline and Link Up Reform and Modernization, Lifeline ond Link Up, Federal-State Joint
Board on Universal Service, Advancing Broadband Availability Through Digital Literacy
Training, WC Docket Nos. 11-42 and 03-109, CC Docket No. 96-45, and WC Docket No. l2-23,
Report and Order and Further Notice Of Proposed Rulemaking, FCC l2-l I (rel. Feb. 6, 2012).
2 Wireline Competition Bureau Approves the Compliance Plans o/AirVoice Wireless, LLC
(AirVoice); AmeriMex Communications Corp. (AmeriMex); Blue Jay Wireless, LLC (Blue Jay);
Millennium 2000, Inc. (Millennium 2000); Nexus Communications,Inc. (Nexus); PlatinumTel
Communications, LLC (PlatinumTel); Sage Telecom, [nc. (Sage); Telrite Corporation (Telrite);
and Telscape Communications, lnc. dlbla Telscape Wireless (Telscape), WC Dckt. Nos. 09-197
and ll-42, Public Notice, DA 12-2063 (rel. December 26,2012).
Marlene H. Dortch
May 17,2021
Page2
AirVoice now seeks expedited approval of the enclosed Revised Compliance Plan,
which has been revised to: (l) reflect a proposed change in ownership of the Company; and (2)
update the information provided in the Company's approved Compliance Plan due to
Commission rule changes and the passage of time.
Change in Ownership
Pursuant to the terms of the Membership lnterest Purchase Agreement dated May 17,
202l,by and among AirVoice Wireless, LLC,aMichigan limited liability company; Jim Bahri,
Falah Bahri, Wail Dickow, Kenny Hannawa, Nick Hannawa, and Kyle Hannawa, all individual
residents of the State of Michigan (collectively the "Seller"); and VTel Holdings, LLC, a Texas
Limited liability company (hereinafter "VTel"), VTel will purchase one hundred percent (100%)
of the membership interests of AirVoice (the "Transaction"). The consummation of the
Transaction is contingent upon any required regulatory approvals including this Revised
Compliance Plan. Following the proposed change in AirVoice's ownership, the Company's
corporate and trade names and identifiers will remain unchanged. The transaction will not result
in any loss or impairment of service for any customer, and customers will continue to receive
their existing services at the same or better rates, terms, and conditions currently in effect.
Updates Due to Rule Changes and Passage of Time
AirVoice also files this Revised Compliance Plan to update its policies and practices to
account for changes in the Commission's Lifeline rules, orders, and guidance and due to the
passage of time. This includes, without limitation, full implementation of the Lifeline National
Verifier, use of standardized application and recertification forms, and new requirements for
Lifeline enrollment representatives.
Respectfu I ly subm itted,
s/ Lance Steinhort
Lance J.M. Steinhart, Esq.
Managing Attorney
Lance J.M. Steinhart, P.C.
Attorneys for AirVoice Wireless, LLC
Enclosures
BEFORE THE
FEDERAL COMMUMCATIONS COMMISSION
Washington, D.C.20554
ArnVorcr Wmrt,ess, LLC REVISED ConplrAr\cE Plax
AirVoice Wireless, LLC ("AIRVOICE" or the o'Company"),1 through its undersigned
counsel, hereby respectfully submits and requests expeditious approval of these revisions to its
approved Compliance Plan (this "Revised Compliance Plan") outlining the measures it will take to
comply with the Federal Communications Commission's ("Commission" or "FCC") 2012Lifeline
Reform Order, 2015 Lifeline Second Report and Order,2 and Third Report and Order.3
I Changes in the Company's affiliates following a proposed change in ownership are discussed in
Section III herein; upon consummation, the Company's names and identifiers will remain the
same.
2 See Lifeline and Link Up Reform and Modernization, Lifeline and Link (Jp, Federal-State Joint
Board on Universal Service, Advancing Broadband Availability Through Digilal Literacy
Training, WC Docket No. I l-42,WC Docket No. 03-109, CC Docket No. 96-45, WC Docket No.
12-23, Report and Order and Further Notice Of Proposed Rulemaking, FCC l2-l I (Feb. 6,2012)
("2012 Lifeline Reform Order"). See Lifeline and Link Up Reform and Modernization,
Telecommunications Caruiers Eligiblefor Universal Service Support, Connect America Fund,WC
Docket Nos. ll-42,09-197, 10-90, Second Further Notice of Proposed Rulemaking, Order on
Reconsideration, Second Report and Order, and Memorandum Opinion and Order, FCC 15-71, fl249 (rel. hne 22, 2015) (Order on Reconsideration). The Company herein submits the
information required by the Compliance Plan Public Notice. See Wireline Competition Bureau
Provides Guidance for the Submission of Compliance Plans Pursuant to the Lifeline Reform
Order, WC Dockei Nos. 09-197, ll-42, puSlic Notice, DA 12-314 (rel. Fdb. 29, i0l2)
(Compliance Plan Public Notice).
3 See In the Matter of Lifeline and Link
Caniers Eligible for Universal Service
Up Reform and Modernization, Telecommunications
Support, Connect America Fund, WC DocketNo. I l-42,
In the Matter of
Telecommunications Carriers Eligible to
Receive Universal Service Support
Lifeline and Link Up Reform and Modernization
AIRVOICE WIRELESS,LLC
WC Docket No. 09-197
WC DocketNo. I l-42
AIRVOICE's Compliance Plan was originally approved by the Wireline Competition Bureau
("Bureau") on December 26,2012.4 AIRVOICE is designated as an eligible telecommunications
carrier ("ETC") to provide Lifeline services to low-income consumers on a wireless basis in
California, Kentucky, Michigan, Mississippi, New York, Ohio, Oklahoma, Pennsylvania, South
Carolina, and Wisconsin. AIRVOICE files this Revised Compliance Plan to update the
information provided due to the passage of time and to reflect a proposed change in ownership
described in Section III below.
AIRVOICE commends the Commission's commitment to a nationwide communications
system that promotes the safety and welfare of all Americans, including Lifeline customers.
AIRVOICE complies with 9l I requirements as described below and qualifies for blanket
forbearance from the facilities requirement of section 2la(e)(l)(A) of the Communications Act to
participate as an ETC in the Lifeline program.s
AIRVOICE complies fully with all conditions set forth in the 2012 Lifeline Reform Order
and Third Report and Order, as well as with the Commission's Lifeline rules and policies more
WC Docket No. 00-197, WC Docket No. l0-90, Third Report and Order, Further Report and
Order, and Order on Reconsideration, FCC l6-38 (rel. Apr. 27 ,2016) ("Third Report and Order").
a Wireline Competition Bureau Approves the Compliance Plans o/AirVoice Wireless, LLC
(AirVoice); AmeriMex Communications Corp. (AmeriMex); Blue Jay Wireless, LLC (Blue Jay);
Millennium 2000, Inc. (Millennium 2000); Nexus Communications,Inc. (Nexus); PlatinumTel
Communications, LLC (PlatinumTel); Sage Telecom,Inc. (Sage); Telrite Corporation (Telrite);
and Telscape Communications, Inc. d/b/a Telscape Wireless (Telscape), WC Dckt. Nos. 09-197
and ll-42, Public Notice, DA 12-2063 (rel. December 26,2012).
s See Z}l2Lifeline Reform Order fl 363. Although AIRVOICE qualifies for and seeks to avail
itself of the Commission's grant of forbearance from the facilities requirement of section
2la(e)(l)(A) for purposes of the federal Lifeline program, the Company reserves the right to
demonstrate to a state public utilities commission that it provides service using its own facilities in
a state for purposes of state universal service funding under state program rules and requirements.
AIRVOICE will follow the requirements of the Commission's Lifeline rules and this Compliance
Plan in all states in which it provides Lifeline service and receives reimbursements from the
federal Low-Income fund, including in any state where the public utilities commission determines
that AIRVOICE provides service using its own facilities for purposes of a state universal service
program.
')
generally.6 This Revised Compliance Plan describes the specific measures that the Company has
implemented to achieve these objectives. Specifically, this Revised Compliance Plan: (l)
describes in detail the measures that AIRVOICE takes to implement the obligations contained in
the 2012 Lifeline Reform Order and Third Report and Order, including (a) the procedures the
Company follows in enrolling a subscriber in Lifeline and submitting for reimbursement for that
subscriber from the Low Income Fund and (b) materials related to initial and ongoing certifications
and sample marketing materials; and (2) provides a detailed description of how AIRVOICE offers
Lifeline services, the geographic areas in which it offers services, and a detailed description of the
Company's Lifeline service plan offerings.
Accoss ro 911 ltvp E911 SrnvrcpsT
Pursuant to the 2012 Lifeline Reform Order, forbearance is conditioned upon the
Company: (l) providing its Lifeline subscribers with 9l I and E91l access, regardless of activation
status and availability of minutes; and (2) providing its wireless Lifeline subscribers with E9ll-
compliant handsets and replacing, at no additional charge to the subscriber, noncompliant handsets
of wireless Lifeline-eligible subscribers who obtain Lifeline-supported services.8 The Company
will provide its wireless Lifeline customers with access to 9l I and E9l I services immediately
upon activation of service. The Commission and consumers are hereby assured that all
AIRVOICE customers will have available access to emergency calling services at the time that
Lifeline voice telephony service is initiated, and that such 9l I and E9l I access will be available
from Company handsets, even if the account associated with the handset has no minutes
remaining.
6 AIRVOICE will update its associated Lifeline program forms and advertising, whenever
necessary, to reflect Commission changes to the applicable Lifeline program rules.
7 See Compliance Plan Public Notice at 3.
8 See 2}l}Lifeline Reform Order n3T.
J
AIRVOICE's existing practices currently provide access to 9l I and E9l I services for all
customers. AIRVOICE currently uses AT&T, and intends to use T-Mobile, as its underlying
wireless network providers/carriers ("Underlying Carriers"). These Underlying Carriers route 9l I
calls from the Company's customers in the same manner as 9l I calls from their own retail
customers. To the extent that AIRVOICE's Underlying Carriers are certified in a given PSAP
territory, this 9l I capability will function the same for the Company. AIRVOICE also currently
enables 9l I emergency calling services for all properly activated handsets regardless of whether
the account associated with the handset is active or suspended or has any remaining minutes.
E91l-Compliant Handsets. AIRVOICE's handsets used in connection with the wireless
Lifeline service offering have always been and will continue to be 9l I and E9l l-compliant. The
Company's phones have passed a stringent certification process, which ensures that the handset
models used meet all 9l I and E9l I requirements. As a result, any existing wireless customer that
qualifies for and elects Lifeline service will already have a glllBgll-compliant handset, which
will be confirmed at the time of enrollment in the Lifeline program. To the extent AIRVOICE
offers handsets for use with its Lifeline service, any new customer that qualifies for and enrolls in
AIRVOTCE's Lifeline voice telephony service is assured of receiving a 9ll/E9ll-compliant
handset.
To further obtain the benefits of a modernized Lifeline program, the Commission's Third
Report and Order also set forth the requirement that Lifeline providers providing both mobile
broadband services and devices to their consumers provide handset devices that are Wi-Fi enabled.e
The Commission further requires such providers to offer the choice to Lifeline customers of devices
4
e,See Third Report and Order at fl 366
that are equipped with hotspot functionality.ro To the extent AIRVOICE offers devices for use with
its Lifeline-supported broadband service, it commits to provide devices that meet the equipment
requirements set forth in 47 C.F.R. $ 54.408(0.
CovTInNCEPLAN
I. PnocppunEs To ENnoLl A SunscnrBER IN Lltr'nuxrll
A. Policy
AIRVOICE will comply with the uniform eligibility criteria established in section 54.409 of the
Commission's rules, as amended by and through the Third Report and Order. Therefore, all subscribers
will be required to demonstrate eligibility, as determined by the National Lifeline Eligibility Verifier
("National Verifier"),12 based on: (l) household income at or below one hundred+hirty five percent(135%)
of the Federal Poverly Guidelines for a household of that size; or (2) the household's participation in one of
the federal assistance programs listed in sections 54.409 of the Commission's rules. In addition, through
the certification requirements described below and the use of the National Lifeline Accountability Database
('NLAD"), the Company confirms that the subscriber is not already receiving a Lifeline service and no one
else in the subscriber's household is subscribed to a Lifeline service.
t0 See id. The Third Report and Order clarifies that the requirement to provide Wi-Fi-enabled
handsets does not apply to devices provided prior to the effective date of the rule (December 2,
2016).
tt See Compliance Plan Public Notice at 3.
12 The National Verifier is fully operational, except in NLAD Opt-out states where it is undergoing
a modified launch (see Wireline Competition Bureau Announces the Next National Lifeline
Eligibility Verifier Launch in Three States, WC Docket No. I I -42, Public Notice, DA l9- 1290
(Released Dec. 18, 2019).In these states, AIRVOICE will rely upon the National Verifier in
conjunction with the state administrator (together, the "National Verifier") for eligibility
determination.
5
B. Eligibility Determination
AIRVOICE relies on the National Verifier and NLAD (except in California where the
Company follows state requirements) to determine an applicant's eligibility for Lifeline service.
Eligible customers can enroll in AIRVOICE's Lifeline service in-person with field representatives,
AIRVOICE retail locations, apply electronically on the Company's website, or through live agents
at the company's call center. Customers may also apply directly with the National Verifier online
or by mail. Regardless of enrollment method, AIRVOICE relies upon the National Verifier for
determination of consumer eligibility for Lifeline.
AIRVOICE uses a web-based electronic Lifeline enrollment application ("ECP") for all
Lifeline customer enrollments. Applications are processed using CGM, LLC's ECP-used by
more than a dozen other ETCs-which works in conjunction with the National Verifier and
NLAD. The ECP works on a tablet or computer in tandem with the National Verifier Service
Provider portal to provide the required disclosures and collect applicant information, identity
documentation, and proof of eligibility, all of which is uploaded to the National Verifier for
eligibility determination and NLAD duplicate check. Each prospective customer is checked
against the NLAD to ensure that the applicant does not already receive Lifeline service before the
customer is enrolled.13 Upon approval in a state, AIRVOICE provides an approved Zip Code list to
CGM. This list is loaded into the ECP to ensure all prospective subscribers reside within
AIRVOICE's approved service area as designated by the state commission or the FCC.
When in person, AIRVOICE requires all prospective customers to provide a copy of their
valid government-issued identification.la Customers that enroll electronically will use the National
t3 See infra Section I.F. regarding use of the NLAD.
'o Any identification documentation collected, including documentation used in NLAD processes
to verify identity are now retained pursuant to the Order on Reconsideration. See Order on
Reconsiderationl224.
6
Verifier consumer portal to submit their Lifeline application, eligibility proof and copy of
government-issued identification directly to the National Verifier, or customers may submit such
documentation directly to the National Verifier by mail.
AIRVOICE does not collect, review, or maintain eligibility documentation, other than in
NLAD-opt out states (such as California). Additionally, the CGM application currently performs
additional checks, such as a check of AIRVOICE's subscriber database to identi$ and prevent
intra-company duplicate enrollments.
As discussed in further detail in Section I.F. below, all employees or representatives
("Representatives") who interact with current or prospective customers are trained regarding all
applicable eligibility and certification requirements, including the one-per-household requirement,
and told to inform potential customers of those requirements.
Further, AIRVOICE will not enroll customers at retail locations where AIRVOICE does
not have an agency agreement with the retailer. AIRVOICE will require a retailer to have any
employees involved in the enrollment process go through the standard AIRVOICE training
process, just as it would for any other Company Representative. By establishing contractual
relationships with all of its Representatives, including future retail outlets, AIRVOICE meets the
"deal directly" requirement adopted in the TracFone Forbearance Order.ls
The Commission determined in the 2012 Lifeline Reform Order that ETCs may permit
representatives to assist with the Lifeline application process because "the Commission has
consistently found that 'fl]icensees and other Commission regulatees are responsible for the acts
and omissions of their employees and independent contractors."'16 AIRVOICE further commits to
comply with the Commission's Fifth Report and Order which set forth reforms to strengthen the
ls See Petition of TracFone Wireless, Inc. for Forbearance from 47 U.S.C. $ 2la(e)(l)(1+) and 47
C.F.R. $ 54.201(i), CC Docket No. 96-45, Order, FCC 05-165, fl l9 (2005).
t6 2Ol2 Lifeline Reform Order lJ I10.
7
Lifeline program's enrollment, recertification, and reimbursement processes including
involvement of representatives. I 7
AIRVOICE is responsible for the actions of all of its Representatives, and a non-
commissioned AIRVOICE employee will be responsible for overseeing and finalizing every
Lifeline enrollment and request for reimbursement. The Company will therefore always "deal
directly" with its customers to certiff and verifu the customer's Lifeline eligibility.
All Representatives are instructed that the company has zero tolerance for waste, fraud or
abuse, and that they should notifu the compliance team if they suspect that anyone might be
providing false information or attempting to obtain a duplicate Lifeline benefit. In addition, if
personnel have any questions or concerns regarding eligibility and enrollment, the Company
strongly encourages them to bring such questions and concerns to the AIRVOICE compliance
team so that they can be researched and resolved in accordance with the Commission's Lifeline
rules and regulations. AIRVOICE provides personnel with refresher training, including to inform
them of changes to Lifeline program rules and regulations, including eligibility requirements.
Personnel will be disciplined, up to and including termination, for failing to comply with Lifeline
rules and regulations. AIRVOICE also provides comprehensive training to its intemal compliance
personnel.
De-Enrollment for Inelisibilitv. If AIRVOICE has a reasonable basis to believe that one of
its Lifeline subscribers no longer meets the eligibility criteria, the Company will notify the
subscriber of impending termination in writing, will comply with any state dispute resolution
t1 In the Matter of Bridging the Digital Divide for Low-Income Consumers, Lifeline and Link Up
Reform and Modernization, Telecommunications Carriers Eligiblefor Universal Service Support,
WC Docket No. 17-287, WC Docket No. I l-42, WC Docket No. 09-197, Fifth Report and Order,
Memorandum Opinion and Order and Order on Reconsideration, and Further Notice of Proposed
Rulemaking, FCC l9-l I I (rel. Nov. 14,2019) (Ffih Report and Order").
8
procedures applicable to Lifeline termination, and will give the subscriber thirty (30) days to
demonstrate continued eligibility.18 A demonstration of eligibility must comply with the annual
verification procedures below and found in rule section 54.410(0, including the submission of a
certification form.
As required by the Commission's rules, if a customer contacts the Company and states that
he or she is not eligible for Lifeline or wishes to de-enroll for any reason, the Company will de-
enroll the customer within two (2) business days.le Live customer service and bilingual operators
can currently be reached for Lifeline service support from l0 AM to l0 PM Eastern, Monday
through Saturday, with2417 access to assistance via IVR and online web portal.
C. Subscriber Certifications for Enrollment
AIRVOICE has implemented certification policies and procedures that enable consumers to
demonstrate their eligibility for Lifeline assistance in compliance with 47 C.F.R. $ 5a.al0(a). The
Company shares the Commission's concern about abuse of the Lifeline program and is thus
committed to the safeguards stated herein, with the belief that these procedures will prevent the
Company's customers from engaging in such abuse of the program, inadvertently or intentionally.
Every applicant will be required to complete the universal or National Verifier Lifeline application
forms required by FCC rules ("Universal Forms"), and thus AIRVOICE complies with the
disclosure and information collection requirements in 47 C.F.R. $ 54.410(d).20 The Universal
Forms, whether online or paper format, indicate qualifuing programs as well as a breakdown of
tB See 2012 Lifeline Reform Order fl 143; 47 C.F.R. $ 5a.a05(e)(l).
te See 47 C.F.R. $ sa.a05(e)(5).
20 See FCC lfireline Competition Bureau Provides Guidance on (Iniversal Forms for the Lifeline
Program, WC DocketNo. I l-42, Public Notice, DA l8-l6l (rel. Feb. 20,2018). fhe standird
application/certification forms are available on USAC's website (See USAC, Lifeline Forms,
https://www.usac.org/lifeline/additional-requirements/fonns0. See Compliance Plan Public Notice
at3.
9
income eligibility based upon the Federal Poverty Guidelines by household size. When enrolling
with AIRVOICE's assistance via the service provider portal, Company personnel will orally
explain the certifications to consumers.2l
Disclosures. The Universal Forms include the following disclosures, which the Company
also includes on its website or electronic application platform: (l) Lifeline is a federal benefit and
willfully making false statements to obtain the benefit can result in fines, imprisonment, de-
enrollment or being barred from the program; (2) only one Lifeline service is available per
household; (3) a household is defined, for purposes of the Lifeline program, as any individual or
group of individuals who live together at the same address and share income and expenses; (4) a
household is not permitted to receive Lifeline benefits from multiple providers; (5) violation of the
one-per-household limitation constitutes a violation of the Commission's rules and will result in
the applicant's de-enrollment from the program; and (6) Lifeline is a non-transferable benefit and
the applicant may not transfer his or her benefit to any other person.22 The Universal Forms further
collect the information and certifications required by 47 C.F.R. $$ 54.410(dX2)-(3), and require
the applicant to consent to transmission of the subscriber's information to the Administrator to
ensure the proper administration of the Lifeline program.23
D. Annual Verification Procedures
AIRVOICE relies upon the National Verifier to annually re-certi$ all subscribers in
compliance with section 54.410(f)(3) of the Commission's rules (the Company follows prescribed
modified processes in NLAD opt-out states such as California). The National Verifier is
2t See 2}l2Lifeline Reform Order n D3.
22 See id.nDt;47 C.F.R. $ 54.410(d)(l).
23 See 47 C.F.R. $ 54.404(b)(9). The application/certification form will also describe the
information that will be transmitted, that the information is being transmiffed to USAC to ensure
the proper administration of the Lifeline program and that failure to provide consent will result in
the applicant being denied the Lifeline service. See 47 C.F.R. $ 54.404(bX9).
l0
responsible to annually confirm a subscriber's current eligibility to receive Lifeline by querying the
appropriate income or eligibility databases, or contacting subscribers as needed to obtain a signed
certification from the subscriber on a form that meets the certification requirements in section
54.410(d). The National Verifier is responsible for sending notice to the subscriber explaining that
failure to respond to the re-certification request within sixty (60) days will result in the subscriber's
de-enrollment from the Lifeline program. If AIRVOICE is notified by the National Verifier that it
is unable to re-certiff a subscriber, AIRVOICE will comply with the de-enrollment requirements
provided for in $54.405(e)(4).24
E. Activation and Non-Usage
To the extent AIRVOICE offers Lifeline service that does not require the Company to
assess and collect a monthly fee from its subscribers, AIRVOICE will not consider a subscriber
activated, and will not seek Lifeline reimbursement for that subscriber, until the subscriber
activates the Company's service either by initiation and/or actual qualified use of the service by the
subscriber.2s
After service activation, AIRVOICE will not seek reimbursement from the USF for and will
de-enroll any subscriber that has not used AIRVOICE's Lifeline service as set forth in 47 C.F.R.
$ 5a.a07(c)(2). An account will be considered active if the authorized subscriber establishes
usage, as "usage" is defined by 47 C.F.R. $ 5a.a07(c)(2), during the specified timeframe, currently
24 AIRVOICE may send messages to its customers, as permitted by National Verifier
recertification processes, to educate them regarding the annual recertification process and
requirement, as contemplated by the 20l?Lifeline Reform Order. This type of educational
recertification message is consistent with the 20l2Lifeline Reform Order, which states that "ETCs
and states may also choose to notify subscribers about the re-certification requirements in their
Lifeline outreach materials. By taking these actions, ETCs and states will ensure that consumers
are aware of the importance of responding to re-certification efforts, and that they are not
inadvertently disconnected due to a lack of understanding of program rules." 2012Lifeline
Reform Order tT 145.
2s See 2012 Lifeline Reform Order n257;47 C.F.R. $ 5a.a07(c)(l).
1l
a period of thirty (30) days, or during the notice period set forth in 47 C.F.R. $ 54.405(e)(3),
currently a period of fifteen (15) days. [n accordance with 47 C.F.R. $ 5a.a05(e)(3), AIRVOTCE
will provide the subscriber advanced notice, using clear, easily understood language, that the
subscriber's failure to use the Lifeline service within the notice period will result in service
termination for non-usage. AIRVOICE will update the NLAD within one (l) business day of de-
enrolling a subscriber for non-use and will submit a non-usage de-enrollment report annually to
USAC.26
F. Additional Measures to Prevent Waste, Fraud and Abuse
To supplement its verification and certification procedures, and to better ensure that
customers understand the Lifeline service restrictions with respect to duplicates, AIRVOICE has
implemented measures and procedures to prevent duplicate Lifeline benefits being awarded to the
same household. These measures entail additional emphasis in written disclosures as well as live
due diligence.
Database. The Company complies with the requirements of the NLAD and section 54.404
of the Commission's rules. Through use of the National Verifier, the Company queries the NLAD
for every enrollment2T to determine whether a prospective subscriber is currently receiving a
Lifeline service from another ETC and whether anyone else living at the prospective subscriber's
residential address is currently receiving Lifeline service.2s
26 See 2Ol2Lifeline Reform Order at\257; see also 47 C.F.R. $$ 54.404(b)(10) and 54.405(e)(3),
respectively.
27 With the limited exception of states that have opted out of the NLAD. [n those states,
AIRVOICE will follow the duplicates detection process required by the state.
28 See 2}l2Lifeline Reform Order nzCf . The Company transmits to the NLAD the information
required for each new Lifeline subscriber. See id,ffi 189-195; 47 C.F.R. $ 54.404(b)(6). Further,
the Company updates each subscriber's information in the NLAD within ten (10) business days of
any change, except for de-enrollment, which will be transmitted within one business day. See 47
C.F.R. $ 54.404(b)(8),(10). These statements may not be applicable in states that have opted out
of the NLAD.
t2
In addition to checking the NLAD, Company personnel emphasize the "one Lifeline phone
per household" restriction in their direct sales contacts with potential customers. Training
materials include a discussion of the limitation to one Lifeline phone per household, and the need
to ensure that the customer is informed of this restriction. All Company personnel interacting with
existing and potential Lifeline customers undergo training regarding eligibility and certification
requirements. Representatives must acknowledge completion of the haining and agree to follow
the procedures outlined therein. Further, Representatives assisting with National Verifier or
NLAD transactions will be required to participate in the Representative Accountability Database
(RAD) in accordance with FCC rules. All Representatives are given a toll-free hotline and an
email address that can be used for any issues or questions regarding Lifeline services.
One-Per-Household Certification. AIRVOICE has implemented the requirements of the
2012 Lifeline Reform Order to ensure that it provides only one Lifeline benefit per household2e
through the use of Universal Forms discussed above, National Verifier and NLAD database
checkso and its marketing materials discussed below. Upon receiving an application for the
Company's Lifeline service, AIRVOICE will search its own internal records to ensure that it does
not already provide Lifeline-supported service to someone at the same residential address.30 If an
applicant shares an address with one or more existing Lifeline subscribers according to the NLAD
or National Verifier, the prospective subscriber may complete a form certiffing compliance with
2e A "household" is any individual or group of individuals who are living together at the same
address as one economic unit. A household may include related and unrelated persons. An
"economic unit" consists of all adult individuals contributing to and sharing in the income and
expenses of a household. An adult is any person eighteen years or older. If an adult has no or
minimal income, and lives with someone who provides financial support to him/her, both people
shall be considered part of the same household. Children under the age of eighteen living with
their parents or guardians are considered to be part of the same household as their parents or
guardians. See 2012 Lifeline Reform Order fl 74; section 5a.400(h).
30 See Z}l}Lifeline Reform Order fl 78.
l3
the one-per-household rule in accordance with 47 C.F.R. $ 54.410(g).3'
lf an applicant is determined to have an existing Lifeline service, AIRVOICE will explain
that a subscriber cannot have multiple Lifeline Program benefits with the same or different service
providers, and will obtain consent from the subscriber that the subscriber wishes to transfer their
existing Lifeline service to AIRVOICE (and acknowledges doing so will result in loss of the
Lifeline benefit with their former Lifeline service provider) prior to initiating a benefit transfer.
Marketing Materials. The Company includes the following information regarding its
Lifeline service on all marketing materials describing the service: (l) it is a Lifeline service, (2)
Lifeline is a government assistance program, (3) the service is non-transferable, (4) only eligible
consumers may enroll in the program, (5) the program is limited to one discount per household; (6)
that documentation is necessary for enrollment; and (7) the name of the ETC (AirVoice
Wireless).32 These statements are included in all print, audio video and web materials (including
social networking media) used to describe or enroll customers in the Company's Lifeline service
offering.33 This specifically includes the Company's website as well as outdoor signage.3a In
addition, the application forms state that consumers who willfully make a false statement in order
to obtain the Lifeline benefit can be punished by fine or imprisonment or can be barred from the
program.
G. Company Reimbursements from the Fund
To ensure that AIRVOICE does not seek reimbursement from the Fund without a
subscriber's consent, the Company certifies, as part of each reimbursement request, that it is in
3l The Household Worksheet is available at https://www.usac.ore/lifeline/additionat-
requirements/forms/.
32 See 2}l}Lifeline Reform Order n275;47 C.F.R. $ 5a.a05(c).
33 See 2012Lifeline Reform Order 1275;47 C.F.R. $ 54.a05(c).
3a See 2012 Lifeline Reform Order n275;47 C.F.R. $ 5a.a05(c).
t4
compliance with all of the Commission's Lifeline rules and, to the extent required, has obtained
valid certification and verification forms from each of the subscribers for whom it is seeking
reimbursement.3s Further, the Company will comply with the Commission's requirement to use a
first day of the month uniform snapshot date to request reimbursement from USAC for the
provision of Lifeline support.36 In addition, the Company will keep accurate records as directed by
USAC37 and as required by section 54.417 of the Commission's rules.
H. Annual Company Certifications
The Company submits an annual FCC Form 481 filing to the Commission by July l't of
each year, providing the Company's business and affiliate information, terms and conditions of
any voice telephony plans offered to Lifeline subscribers, and all other required information and
certifications.38 The Company also submits an annual Form 555 filing to the Commission
certiffing, under penalty of perjury, that the Company: (l) has policies and procedures in place to
ensure that its Lifeline subsuibers are eligible to receive Lifeline services; (2) that the Company is
in compliance with all federal Lifeline certification procedures; and (3) that the Company is in
compliance with the minimum service levels set forth in 47 C.F.R. $54.408.3e The Company
provides the results of its re-certification efforts, performed pursuant to section 54.410(0 of the
Commission's rules, as amended, annually by January 3ltt, for its re-certification efforts of the
prevlous year 40
3s See 2012 Lifeline Reform Order fl 128;47 C.F.R. $ 54.407(d).
36 See 47 C.F.R. $ 5a.a07(a).
37 See rd at $ 54.407(e).
38 See rd at g 54.422.
3e See rd at $ 54.416(a).
ao See rd at $ 54.416(b).
l5
II. Description of Lifeline Service Offeringsal
AIRVOICE will offer its Lifeline service in the service areas in the states where it is
designated as an ETC and throughout the coverage area of its respective underlying provider(s),
currently AT&T and T-Mobile. AIRVOICE's Lifeline-supported services will meet or exceed the
minimum service standards set forth in 47 C.F.R. $ 54.408. AIRVOICE offers its Lifeline service
under the brand designation "FeelSafe Wireless."
AIRVOICE's current wireless Lifeline offering based upon minimum service standards
effective December 1,2020 consists of the following plan option(s):
PLAN DESCRIPTION vorcE TEXT DATA TIFELINE
PRICE
1000 Voice/500 Text/ 4.5 GB Data 1000 s00 (sMs)4.5 GB So.oo
In addition to allotments of voice, text and broadband services, AIRVOICE's current
wireless Lifeline offering includes a free handset or SIM card and access to custom calling features
at no charge, including Caller ID, Call Waiting, and Voicemail. All wireless Lifeline plans include
domestic long-distance at no extra per minute charge. Calls to 9l I emergency services are always
free, regardless of service activation or availability of minutes. Lifeline customers can purchase
additional minutes or data through customer service, the Company's website, Point of Sale
locations, and through IVR. Additional information regarding the Company's wireless Lifeline
plans, rates and services can be found on its website (https://www.feelsafewireless.com,/).
II.Demonstration of Financial and Technical Capabilities and Certifications Required
for ETC Designationa2
Financial and Technical Capabilities. Section 5a.202(g@)43 requires carriers petitioning
for ETC designation to demonstrate financial and technical capability to comply with the
at See Compliance Plan Public Notice at 3
a2 See Compliance Plan Public Notice at 3
l6
Commission's Lifeline service requirements,44 and the Compliance Plan Public Notice requires
that carriers' compliance plan include this demonstration. Among the factors the Commission will
consider are the following: a carrier's prior offering of service to non-Lifeline subscribers, the
length of time the carrier has been in business, whether the carrier relies exclusively on Lifeline
reimbursement to operate; whether the carrier receives revenues from other sources and whether
the carrier has been the subject of an enforcement action or ETC revocation proceeding in any
state.
Pursuant to the terms of the Membership lnterest Purchase Agreement dated May 17,2021,
202l,by and among AirVoice Wireless, LLC, a Michigan limited liability company; Jim Bahri,
Falah Bahri, Wail Dickow, Kenny Hannawa, Nick Hannawa, and Kyle Hannawa, all individual
residents of the State of Michigan (hereafter collectively the "Seller"); and VTel Holdings, LLC, a
Texas Limited liability company (hereinafter the "Buyer" or "VTel"), Buyer will purchase one
hundred percent (10070) of the membership interests of AIRVOICE (the "Transaction"). The
consummation of the Transaction is contingent upon any required regulatory approval, including
this Revised Compliance Plan and FCC Section 214 international approval.
VTel is a Texas limited liability company with its principal offices located at 9920
Brooklet Drive, Houston, Texas 77009. VTel was created for purposes of the Transaction. VTel
has established considerable financial resources that will be available, as needed, to support
AIRVOICE in its operations and continuing growth. VTel is wholly owned by Henry Hung Do, a
United States citizen and resident of the State of Texas. Henry Hung Do also owns 100% of: (a)
Cintex Wireless, LLC dlbla SFone Wireless, a Delaware limited liability company ("Cintex"), that
provides non-Lifeline wireless services throughout the United States, and provides Lifeline-only
a3 See 47 C.F.R. $ 5a.202(a)(a).
aa See 2012 Lifeline Reform Order fltT 387-388 (revising Commission rule 5a.202(i(D.
l7
wireless services in Arkansas, Maryland, Maine, Rhode Island and West Virginia, in which it has
been designated as an ETC to provide Lifeline services to low-income consumers; (b) NewPhone
Wireless, LLC, a Louisiana limited liability company, that provides Lifeline-only wireless services
in Louisiana in which it has been designated as an ETC to provide Lifeline services to low-income
consumers, and is authorized to provide non-Lifeline wireless services throughout the United
States; (c) HTH Communications, LLC, a Texas limited liability company, a global and one of the
largest mobile device distributors in the United States, which has been in business for more than
thirteen (13) years; and (d) SofTel Technologies, a Texas limited liability, that provides
distribution services to Lifeline-only wireless providers. Neither VTel nor any of its affiliates have
foreign ownership and, like AIRVOICE, are not foreign carriers or affiliated with foreign carriers
in any market.
VTel brings to AIRVOICE not only financial stability, but also managerial and technical
resources available to VTel through its affiliates which have been providing telecommunications
service and handsets, including wireless Lifeline service, for over thirteen (13) years. VTel and its
affiliates receive revenue from a number of sources which are independent from the revenue it
receives in the form of Lifeline reimbursements, such as the following wholesale and non-Lifeline
wireless services: income from the sale of prepaid wireless services to non-Lifeline consumers as
well as the sale of replenishment airtime minutes and data to Lifeline consumers, the sale of
various other ancillary services, and the sale of wireless handsets. VTel will similarly move
forward with AIRVOICE operations such that AIRVOICE provides non-Lifeline services wholly
separate from and/or complementary to its Lifeline services. AIRVOICE has provided non-
Lifeline wireless services since 1999, and will continue to do so after the closing of the
Transaction. Consequently, AIRVOICE never has and will not be relying exclusively on Lifeline
reimbursement for its operating revenues. Under current ownership, neither VTel nor its affiliates
l8
have been subject to enforcement sanctions related to the Low Income Fund or ETC revocation
proceedings in any state.as Cintex and NewPhone currently provide wireless Lifeline services to
approximately 75,000 subscribers.
With respect to technical expertise, VTel and its affiliates have considerable experience
complying with the requirements of the federal Lifeline program. In addition, key members of
AIRVOICE's current operations team will remain with the Company post-Transaction, continuing
to work on day-to-day operations. As a result, the Transaction will bring together AIRVOICE's
current valued personnel, and the full strength of VTel and its affiliates' proven
telecommunications capabilities and business expertise, particularly with respect to compliance
and marketing in the low-income consumer sector. As a result, VTel's ownership will enable
AIRVOICE to achieve measurable growth at the same time as it develops improved operating
efficiencies, both necessary components for the Company to thrive. In addition, the Transaction
will not result in any loss or impairment of service for any customer, and customers will continue
to receive their existing services at the same or better rates, terms, and conditions currently in
effect.
Service Requirements Applicable to the Compan)r's Support. The Compliance Plan Public
Notice requires carriers to include "certifications required under newly amended section 54.202 of
the Commissionos ru1es."46 AIRVOICE certifies that it will comply with the service requirements
applicable to the support the Company receives.4T AIRVOICE's Lifeline supported voice services
will meet the minimum service standards set forth in 47 C.F.R. $ 54.408. AIRVOICE's Lifeline
as Pursuant to a Membership Interest Purchase Agreement dated February 6,2019, Henry Hung Do
purchased 100% of the equity of Cintex. Pursuant to an Order and Consent Decree adopted on
December 22,2017, Cintex seffled a Notice of Apparent Liability with the FCC (See File No.
EB-rHD-13-00010671).
a6 Compliance Plan Public Notice at 3.
a7 See 47 C.F.R. $ 5a.202(a)(l).
l9
supported broadband services will meet the minimum service standards set forth in 47 C.F.R. $
54.408 for mobile broadband internet access services, including for service speed and data usage
allowance, as such standards are updated on an annual basis. To the extent AIRVOICE provides
devices for use with Lifeline-supported broadband service, such devices will meet the equipment
requirements set forth in 47 C.F.R. $ 54.408(0, and AIRVOICE will not impose an additional or
separate tethering charge for mobile data usage below the minimum standard.
The Company provides all of the telecommunications services supported by the Lifeline
program and will make the services available to all qualified consumers throughout the states in
which it is designated as an ETC. The Company's services include broadband Intemet access
service ("BIAS"), a supported service as of December2,2016, as well as voice telephony services
that provide voice grade access to the public switched network or its functional equivalent.
Further, the Company's wireless service offerings included in Section ll supra provide its
customers with a set number of minutes of use at no additional charge to the customer beyond the
monthly plan rate, and can be used for local and domestic toll service.
The Company also will provide access to emergency services provided by local
government or public safety officials, including 9l I and E9l I where available, and will comply
with any Commission requirements regarding E9l l-compliant handsets. As discussed above, the
Company will comply with the Commission's applicable forbearance grant conditions relating to
the provision of 9l I and E9l I services and handsets (when applicable).
Finally, AIRVOICE will not provide toll limitation service ("TLS"), which allows low-
income consumers to avoid unexpected toll charges. However, since AIRVOICE is a prepaid
service provider, customers cannot be disconnected for failure to pay toll charges, nor are there
additional charges for exceeding their preset minutes. The Company, like most wireless carriers,
does not differentiate domestic long-distance toll usage from local usage and all usage is paid for
20
in advance. Pursuant to the 2012 Lifeline Reform Order, subscribers to such services are not
considered to have voluntarily elected to receive TLS.48
IV. Conclusion
AIRVOICE submits that its Revised Compliance Plan fully satisfies the conditions set forth
in the Commission's 2012 Lifeline Reform Order, the Compliance Plan Public Notice and the
Lifeline rules. Timely approval of this Revised Compliance Plan is essential to allow AIRVOICE
to consummate the ownership change as described herein and demonstrably strengthen the
Company's operating capabilities to the direct benefit of its Lifeline customers. Accordingly, the
Company respectfully requests that the Commission expeditiously approve the revisions to its
Compliance Plan.
Respectfu lly submitted,
/s/ Lance J.M. Steinhart
Lance J.M. Steinhart
Managing Attorney
Lance J.M. Steinhart, P.C.
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005
[phone] (Phone)
[phone] @ax)
E-Mail: [e-mail]
Legal and Regulatory Counsel
May 17,2021
a8 See 2}l2Lifeline Reform Order'!1230
2t
EXHIBIT A
ORGAI\(IZ ATIONAL CIIARTS
Pre-Transaction
Jim Bahri
ts%
Falah Bahri
t5%
Wail
Dickow
l0o/o
Kenny
Hannawa
30%
Nick
Hannawa
lsYo
Kyle
Hannawa
t5%
Post Transaction
Cintex Wireless,
LLC d/b/a SFone
Wireless
AirVoice Wireless, LLC (MD
I
Henry
Hung Do
US Citizen
NewPhone
Wireless,
LLC
HTH
Communisxti6.t,
LLC
SofTel
Technologies,
LLC
100%
VTel
Holdings,
LLC
AirVoice
Wireless,
LLC
zip
83201
83202
83204
83210
83211
832L2
83213
832L4
83215
832L7
83220
8322t
83226
83227
83228
83229
83230
83232
83234
8323s
83236
83237
83238
8324L
83243
83244
83245
83246
83250
83251
83252
83253
83254
83255
83262
83263
8327L
83272
83274
83276
83277
83278
83283
83285
83285
83287
primary_cistate
Pocatello lD
Pocatello lD
Pocatello lD
Aberdeen lD
American I lD
Arbon lD
Arco lD
Arimo lD
Atomic Cit lD
Bancroft lD
Bern lD
Blackfoot lD
Challis lD
Clayton lD
Clifton lD
Cobalt lD
Conda lD
Dayton lD
Downey lD
Ellis lD
Firth lD
Franklin lD
Geneva lD
Grace lD
Holbrook 1D
Howe lD
lnkom lD
Lava Hot SllD
Mccammo lD
Mackay lD
Malad City lD
May lD
MontpelietlD
Moore lD
Pingree lD
Preston lD
Rockland lD
Saint Charl lD
Shelley lD
Soda Sprin;lD
Springfield lD
Stanley lD
Thatcher lD
Wayan lD
Weston lD
Fish Haven lD
county
Bannock County
Bannock County
Bannock County
Bingham County
Power County
Power County
Butte County
Bannock County
Bingham County
Caribou County
Bear Lake County
Bingham County
Custer County
Custer County
Franklin County
LemhiCounty
Caribou County
Franklin County
Bannock County
Custer County
Bingham County
Franklin County
Bear Lake County
Caribou County
Oneida County
Butte County
Bannock County
Bannock County
Bannock County
Custer County
Oneida County
LemhiCounty
Bear Lake County
Butte County
Bingham County
Franklin County
Power County
Bear Lake County
Bingham County
Caribou County
Bingham County
Custer County
Franklin County
Bonneville County
Franklin County
Bear Lake County
83301
83302
83311
83313
83314
83315
83318
83320
83321
83322
83323
83324
8332s
83327
83328
83330
83332
83333
83334
8333s
83335
83337
83338
83340
83341
83342
83344
83346
83347
83348
83349
83350
83352
833ss
83401
83402
83404
83406
83420
83422
83423
83424
83425
83427
83428
83429
83431
Twin Falls lD
Rogerson lD
Albion lD
Bellevue lD
Bliss lD
Buhl lD
Burley lD
Carey lD
Castleford lD
Corral lD
Declo lD
Dietrich lD
Eden lD
Fairfield lD
Filer lD
Gooding lD
Hagerman lD
Hailey lD
Hansen lD
Hazelton lD
Heyburn lD
HillCity lD
Jerome lD
Ketchum lD
Kimberly lD
Malta lD
Murtaugh ID
Oakley lD
Paul lD
Picabo lD
Richfield lD
Rupert lD
Shoshone lD
Wendel! !D
ldaho Falls lD
ldaho Falls !D
ldaho Falls lD
ldaho Falls lD
Ashton lD
Driggs lD
Dubois lD
Felt lD
Hamer lD
lona lD
lruin lD
lsland Park lD
Lewisville lD
Twin Falls County
Twin Falls County
Cassia County
Blaine County
Gooding County
Twin Falls County
Cassia County
Blaine County
Twin Falls County
Camas County
Cassia County
Lincoln County
Jerome County
Camas County
Twin Falls County
Gooding County
Gooding County
Blaine County
Twin Falls County
Jerome County
Minidoka County
Camas County
Jerome County
Blaine County
Twin Falls County
Cassia County
Twin Falls County
Cassia County
Minidoka County
Blaine County
Lincoln County
Minidoka County
Lincoln County
Gooding County
Bonneville County
Bonneville County
Bonneville County
Bonneville County
Fremont County
Teton County
Clark County
Teton County
Jefferson County
Bonneville County
Bonneville County
Fremont County
Jefferson County
83434
83435
83435
83440
83442
83443
83444
83445
83446
83448
83449
83450
83451
83452
83455
83462
83463
83464
83466
83467
83469
83501
83520
83522
83523
83524
83525
83525
83530
83533
8353s
83536
83537
83s39
83540
83541
83542
83543
83544
83545
83545
83547
83548
83549
83552
835s3
83554
Menan lD
Montevieu lD
Newdale lD
Rexburg lD
Rigby lD
Ririe lD
Roberts lD
Saint Anthr lD
Spencer lD
Sugar City lD
Swan Valle lD
Terreton lD
Teton lD
Tetonia lD
Victor lD
Carmen lD
GibbonsvilllD
Leadore lD
North Fork lD
Salmon lD
Shoup lD
Lewiston lD
Ahsahka lD
Cottonwoc lD
Craigmont lD
Culdesac lD
Elk City lD
Ferdinand lD
Grangeville lD
Greencree lD
Juliaetta lD
Kamiah tD
Kendrick lD
Kooskia lD
Lapwai lD
Lenore lD
Lucile lD
Nezperce lD
Orofino lD
Peck lD
Pierce lD
Pollock lD
Reubens lD
Riggins lD
Stites lD
Weippe lD
White Bird lD
Jefferson County
Jefferson County
Fremont County
Madison County
Jefferson County
Jefferson County
Jefferson County
Fremont County
Clark County
Madison County
Bonneville County
Jefferson County
Fremont County
Teton County
Teton County
LemhiCounty
LemhiCounty
LemhiCounty
LemhiCounty
LemhiCounty
LemhiCounty
Nez Perce County
Clearwater County
ldaho County
Lewis County
Nez Perce County
ldaho County
ldaho County
ldaho County
ldaho County
Latah County
ldaho County
Latah County
ldaho County
Nez Perce County
Cleanryater County
ldaho County
Lewis County
Clearuvater County
Nez Perce County
Cleanrtrater County
ldaho County
Lewis County
ldaho County
ldaho County
Cleanryater County
ldaho County
83555
83602
83504
83505
83507
83610
83611
83512
83515
83615
836L7
83519
83622
83623
83624
83525
83627
83628
83529
83531
83632
83633
83534
83636
83637
83638
83539
83541
83642
83543
83644
83545
83546
83547
83648
83550
83551
83654
836ss
83557
83660
83661
83666
83559
83570
83672
83676
Wincheste lD
Banks lD
Bruneau lD
Caldwell lD
Caldwell lD
Cambridge lD
Cascade lD
Council lD
Donnelly lD
Eagle lD
Emmett lD
Fruitland lD
Garden Va lD
Glenns Fer lD
Grand Viev lD
Greenleaf lD
Hammett lD
Homedale lD
Horseshoe lD
ldaho City lD
lndian Vall,lD
King Hill lD
Kuna lD
Letha lD
Lowman lD
Mccall lD
Marsing lD
Melba lD
Meridian lD
Mesa lD
Middleton lD
Midvale lD
Meridian lD
Mountain llD
Mountain llD
Murphy lD
Nampa lD
New Mead lD
New Plym< lD
Ola lD
Parma lD
Payette lD
Placerville lD
Star lD
Sweet lD
Weiser lD
Wilder lD
Nez Perce County
Boise County
Owyhee County
Canyon County
Canyon County
Washington County
Valley County
Adams County
Valley County
Ada County
Gem County
Payette County
Boise County
Elmore County
Owyhee County
Canyon County
Elmore County
Owyhee County
Boise County
Boise County
Adams County
Elmore County
Ada County
Gem County
Boise County
Valley County
Owyhee County
Canyon County
Ada County
Adams County
Canyon County
Washington County
Ada County
Elmore County
Elmore County
Owyhee County
Canyon County
Adams County
Payette County
Gem County
Canyon County
Payette County
Boise County
Ada County
Gem County
Washin$on County
Canyon County
83677
83686
83587
83702
83703
83704
8370s
83706
83708
83709
837L2
837L3
837L4
837L6
83801
83802
83803
83804
8380s
83808
83809
83810
83811
83812
83813
83814
8381s
83821
83822
83823
83824
83830
83832
83833
83834
83835
83836
83837
83839
83842
83843
83845
83846
83847
83848
83850
838s1
Yellow Pinr lD
Nampa lD
Nampa lD
Boise lD
Boise lD
Boise lD
Boise lD
Boise lD
Boise lD
Boise lD
Boise lD
Boise lD
Garden Cit lD
Boise lD
Athol lD
Avery lD
Bayview lD
Blanchard lD
Bonners Ft lD
Calder lD
Careywooc lD
Cataldo lD
Clark Fork lD
Clarkia lD
Cocolalla lD
Coeur D Al lD
Coeur D Al lD
Coolin lD
Oldtown lD
Deary lD
Desmet lD
Fernwood lD
Genesee lD
Harrison lD
Harvard lD
Hayden lD
Hope lD
Kellogg lD
Kingston lD
Medimont lD
Moscow lD
Moyie SprilD
Mullan lD
Naples lD
Nordman lD
Pinehurst lD
Plummer 1D
Valley County
Canyon County
Canyon County
Ada County
Ada County
Ada County
Ada County
Ada County
Ada County
Ada County
Ada County
Ada County
Ada County
Ada County
Kootenai County
Shoshone County
Kootenai County
Bonner County
Boundary County
Shoshone County
Bonner County
Kootenai County
Bonner County
Shoshone County
Bonner County
Kootenai County
Kootenai County
Bonner County
Bonner County
Latah County
Benewah County
Benewah County
Latah County
Kootenai County
Latah County
Kootenai County
Bonner County
Shoshone County
Shoshone County
Kootenai County
Latah County
Boundary County
Shoshone County
Boundary County
Bonner County
Shoshone County
Benewah County
83852
838s4
838s5
83855
838s7
83858
838@
83851
83864
83868
83869
83870
83871
83872
83873
83874
83876
Ponderay lD
Post Falls lD
Potlatch lD
Priest RiverlD
Princeton lD
Rathdrum lD
Sagle lD
Saint ttlarlr lD
Sandpoint lD
Smeltervill lD
Splrit Lake lD
Tensed lD
Troy lD
Viola lD
Wallace lD
Murray !D
Worley lD
Bonner County
Kootenai County
Latah County
Bonner County
Latah County
Kootenai County
Bonner County
Benewah County
Bonner County
Shoshone County
Kootenai County
Benewah County
Latah County
Latah County
Shoshone County
Shoshone County
Kootenai County
David Stewart
Over 25 years of experience in software development including 18 years as owner of Danna Software
supporting the IT needs of organizations primarily working in Global Logistics and Supply Chain
Management. From evaluating business needs through development, implementation and training I enjoy
solving problems and creating streamlined solutions.
Throughout my career I've built relationships with avariety of businesses from small companies of 10
employees or less to Fortune 500's. My companies success has depended on the success of the clients I
serve. Over the years serving my clients I have learned how to evaluate a companies needs, business
objectives and their own clients needs.
MVItIO/Lifeline Operations Manager
HTH Communications, LLC.
Dates Employed Mar 2018 - Present
Employment Duration 3 yrs 9 mos
Location Houston, Texas Area
Owner
Danna Software
Dates Employed 1998 - Mar 201 8
Employment Duration 20 yrs
Location Houston
Developing simple software solutions fit to client's needs. Providing tum key solutions from
development implementation and training through life cycle updates adapting to new technologies.
University of Houston
Specialist in development of software solutions supporting global logistics and supply chain management.
Emily Shelton
Experienced Sales Marketing Manager with a demonstrated history of working in the wireless industry
Professionally skilled in event planning, sales, business development marketing stratery, and sales
management.
HTH Communications, LLC.
Marketing and Sales Manager
Dates Employed Jul 2015 - Present
Employment Duration 6 yrs 5 mos
Location Houston, Texas Area
Chappell Jordan Clock Galleries
Sales Consultant
Dates Employed Nov 2014 - ltl20l5
Employment Duration 9 mos
Location Houston, Texas Area
Luminess Air
Lead Internet Marketing Associate
Dates Employed Jan 20ll - Apr 2013
Employment Duration 2 yrs 4 mos
Location Houston, Texas Area
Customer Focused Systems
Marketing Specialist
Dates Employed Jul 2009 -Dec 2010
Employment Duration I yr 6 mos
Location Houston, Texas
St. Edward's University
Degree Name BA
Henry Do
After entering the professional work market as an accountant and financial analyst, Henry became a
business starter and entrepreneur gaining experience with all facets of financial management, including
financial budgeting and forecasting, strategic financial planning, general accounting, cost accounting,
business support, performance reporting, financial analysis and reporting, consolidations, cash management
and banks relations. Henry's strong quantitative, analytical, problem-solving skills and multi-tasking skills,
have been used to build a group of companies deeply integrated into telecom/ the mobile wireless service
ecosystem from the carrier level to the consumer. HTH's success has fueled the acquisition and founding
of multiple complementary affiliate companies, some of them being listed below.
Founder/CEO
HTH Communications, LLC.
Dates Employed Jul 2008 - Present
Employment Duration 13 yrs 5 mos
Location Houston, Texas Area
HTH is the vital link to the secondary marketplace. To national carriers, HTH is a trusted vendor delivering
the most value for their EOL, retumed or excess handset inventory. For regional carriers or MVNO's, HTH
is the leading provider of high-quality refrrbished devices, logistics and engineering services.
HTH attributes fourteen consecutive years of growth to staying true to these principles:
Quality and Efficiency. HTH has an efficient workforce that boasts of employee longevity. We procure
quality products focusing on top-level access and high volumes. We have an in-house software development
team that allows us to quickly and cost-effectively modiS product for the secondary market. We have a
smart and empowered salesforce that become trusted partners to their customers.
Whether its building an IT infrastructure that optimizes workflow and reinforces accountability, or
maintaining the world-class portfolio of quality designations including R2, ISO 9001, ISO 14001 and ISO
18001, HTH is committed to operational excellence.
Quality and Efficiency. The HTH beacon.
Owner/CEO
Cintex Wireless
Dates Employed Feb 2019 - Present
Employment Duration 2 yrs 10 mos
Location Houston, Texas, United States
Cintex Wireless is one of the nation's leading providers of EBB & Lifeline wireless services in 50 States
to those in need. Cintex's subscribers will receive a FREE 4Gl5G LTE smartphone along with FREE
monthly cell phone service to help them stay connected with family, school services, doctors, and
employers. Cell phone service includes nationwide coverage on one of America's largest 5G networks. Our
customers enjoy their free phone and free service at absolutely no cost to them. We also offer affordable
prepaid wireless cell phone service through SFone Wireless.
HugoVo
lT Professional with 3 years of experience, and a proven knowledge of hardware engineering,
configuration and troubleshooting. Proven ability to develop and implement lT solutions that
support business needs.
HTH Communications, LLC
lT & Development Manager May 2O2L- Present
lT Support Jan 2019 - May 2021
Phone Technician / Helpdesk Ju! 2018 -Jan 2019
Employment Duration 3 yrs 5 mos
Location Houston, Texas, U.S
Creative Bav
Web Developer May 2012 - Dec 2013
Employment Duration 1yr 8 mos
Location Vietnam
UNIVERSIW OF GREENWICH
Degree Name Bachelor of Science (8.S.)
ETilIIBIT 5
Proposed Lifeline Offoring
Minutes & Data
1,000 anytime minutes permonth
500 text messages permontr
4.5 GB datapermonth
LTE or SGNetwork
Net eost to Lifeline customer: $0
ADDITIONAL AIRTIME
Available for purchase at www.airtalkwireless.com
All packages include:
Free SIM card orllandset
Free calls to AirVoice Customer Service
Free calls to 9t I emergency services
Free acoess to Voicemail, Caller-ID, and Call Waiting features
Voice minutes may be used forDomestic Long Distarrce at no enta cost
FEE_I-SAEE A=WIRELESSE?
is now
I
AirTalk $-) Government Assistonce ProgromTRELESS
.rlr=-
Jo[m @ur
IIFEIINE & ACP
PROGRAM tO RECEIVE O
F REE iPhone 7,
Sonrs ung Sg &
UNLIMITED
Dofc, Talk & Text
A pply Online ot oirtolkwireless.com
E-moil rrs r,rt [e-mail]
Coll r,. 11rll Iree ot +t (gSS) 924-7825
Lfinnfited
tflmne offer
,sEC
tfsL
;*!
GI
ilr
m I/r*n, "'-
t
APPLYING IS
QUrCK EASY!
Unlimited Doto is provided by the Affordoble Connectivity Progrom.
See Terms & Conditions for odditionol informotion. The obove devices ore ovoiloble while supplies lost.
lf models ore no longer ovoiloble, o similor device will be offered.
Keeping Our Communities Connected
$flf,
About Us
AirTolk Wireless is o progrom
provided by HTH Communicotions
serving eligible Americon
households. The compony is on
FCC-licensed Eligibility
Telecommunicotion Corrier (rrC)
which offers Lifeline ond the
Affordoble Connectivity Progrom
(acP) to eligible customers
ocross Americo.
@
Atfordo ble Connectivity
Progrom
Congress recently creoted the
Affordoble Connectivity
Progrom, o long-term, $14 billion
progrom, which will reploce the
Emergency Broodbond Benefit
Progrom. This investment in
broodbond offordobility will help
ensure we con offord the
internet connections we need for
work, schoo!, heqlth core, ond
more for o long time.
You Gon Quolify if You
Porticipote in One of the
Following Progroms:
/ SNAP/FOOD STAMPS
/ MEDICAIDy SSI/ VETERANS SURVIVORS PENSION
BENEFITS FUNDy FEDERAL PUBLIC HOUSING
ASSISTANCE
Why Should You
Choose AirTqlk ?
/ Offers the best FREE Phoney Offers the best FREE service
plon
r/ Notionwide Coveroge & 23+
yeors in business/ Dedicoted Customer Service/ Our customers ore hoppy
r/ Applying is quick & eosy
r/ Fost & Free Shippingor through income bose
quolificotions ond MANV MoRE!
Offi 1,,r1^ H.,ql,T:@
Contoct Us.
Mondoy - Fridoy: 8:OO o.m - 5:OO p.m CST & Soturdoy: IO:OO o.m - 7:OO p.m CST
Website:www.oirtolkwireless.com Emoil: info6uoirtolkwireless.com Phone: +t (ASS) 924-7825