20220624ID Nez Perce Tribe - Certificate of Service.pdf

Lance J.M. Steinhart, P.C. Attorneys At Law 1725 Windward Concourse Suite 150 Alpharetta, Georgia 30005 Also Admitted in New York Telephone: [phone] Email: [e-mail] Facsimile: [phone] June 24, 2022 Certified USPS Mail Office of Legal Counsel Nez Perce Tribe of Idaho 120 Bever Grade Rd, Lapwai, ID 83540 Re: AirVoice Wireless, LLC d/b/a AirTalk Application for Limited Designation as an Eligible Telecommunications Carrier Dear Sir, Madam, Please find enclosed a copy of AirVoice Wireless, LLC d/b/a AirTalk 's Application and amended application for Limited Designation as an Eligible Telecommunications Carrier in the State of Idaho. These were filed with the Commission March 23, 2022 and April 22, 2022. If you have any questions, or if I may provide you with additional information, please do not hesitate to contact me. Thank you. Respectfully submitted, Lance J.M. Steinhart, Esq. Managing Attorney Lance J.M. Steinhart, P.C.
Attorneys for AirVoice Wireless, LLC
d/b/a AirTalk Wireless Enclosures cc: Henry Do
Lance J.M. Steinhart, P.C.
Attorneys At Law
1725 Windward Concourse
Suite 150
Alpharetta, Georgia 30005

Also Admitted in New York Telephone: [phone]
Email: [e-mail] Facsimile: [phone]

March 22, 2022

VIA EMAIL DELIVERY TO
[e-mail]

Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702

Re: AirVoice Wireless, LLC d/b/a AirTalk
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 Carrier 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.

Respectfully submitted,

Lance J.M. Steinhart, Esq.
Managing Attorney
Lance J.M. Steinhart, P.C.
Attorneys for AirVoice Wireless, LLC
d/b/a AirTalk Wireless

Enclosures
cc: Henry Do

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION

AirVoice Wireless, LLC
d/b/a AirTalk Wireless
Application for Designation as an Eligible
Telecommunications Carrier
_____________________________________
) ) ))))
Case No. ____

APPLICATION

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: [e-mail]

Attorneys for AirVoice Wireless, LLC
d/b/a AirTalk Wireless

March 22, 2022
2

TABLE OF CONTENTS
I. INTRODUCTION ...............................................................................................................4
II. COMPANY OVERVIEW ...................................................................................................6
III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF
WIRELESS ETCS ...............................................................................................................5
IV. AIRVOICE SATISFIES THE REQUIREMENTS FOR DESIGNATION AS
AN ETC UNDER 47 C.F.R. § 54.201 .................................................................................8
V. AIRVOICE SATISFIES THE ADDITIONAL REQUIREMENTS FOR ETC
DESIGNATION UNDER 47 C.F.R. § 54.202(a) ..............................................................16
VI. DESIGNATION OF AIRVOICE AS AN ETC WOULD PROMOTE THE
PUBLIC INTEREST .........................................................................................................23
VII. CONCLUSION ..................................................................................................................27

3

TABLE OF EXHIBITS

Exhibit

Certification ...............................................................................................................1

FCC-Approved Compliance Plan ...............................................................................2

Coverage Area ...........................................................................................................3

Key Management Bios ...............................................................................................4

Proposed Lifeline Offering ........................................................................................5

Sample Advertisement ...............................................................................................6

4

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION

AirVoice Wireless, LLC
AirTalk Wireless
Application for Designation as an Eligible
Telecommunications Carrier
_____________________________________
)))))
Case No. ____

I. INTRODUCTION
AirVoice Wireless, LLC d/b/a AirTalk Wireless (“AirVoice” or the “Company”), by its
undersigned counsel, and pursuant to Section 214(e)(2) of the Communications Act of 1934, as
amended (the “Act”),1 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 qualifying Idaho
consumers; it will not (and is not eligible to) seek access to funds from the federal Universal
Service Fund (“USF”) for the purpose of participating in the Link-Up program or providing service
to high-cost areas.3 AirVoice requests that its designation as an ETC include the authority to

1 47 U.S.C. § 214(e)(2)
2 47 C.F.R. §§ 54.101-54.207.
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.

5

participate in and receive reimbursement from the Idaho Telephone Service Assistance Program
(ITSAP).
As demonstrated herein, and as certified in Exhibit 1 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
Modernization Order,5 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/b/a AirTalk Wireless
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005

4 In the Matter 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. 11-42,
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 12-11 (rel. Feb. 6, 2012) (“Lifeline and Link Up Reform Order”).
5 In the Matter of Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for
Universal Service 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,
2016) (hereinafter, “Third Report and Order” or “Lifeline Modernization Order”).
6 In the Matter of Bridging the Digital Divide for Low-Income Consumers, Lifeline and Link Up Reform and
Modernization, Telecommunications Carriers Eligible for Universal Service Support, WC Docket No. 17-287, WC
Docket No. 11-42, WC Docket No. 09-197, Fifth Report and Order, Memorandum Opinion and Order and Order on
Reconsideration, and Further Notice of Proposed Rulemaking, FCC 19-111 (rel. Nov. 14, 2019) (hereinafter, “Fifth
Report and Order”).
6

[phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
II. COMPANY OVERVIEW
AirVoice is a Michigan limited liability company,7 with its principal office located at 9920
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 (“MVNO”).
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 of the 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 d/b/a SFone
Wireless, a Delaware limited liability company (“Cintex”), that provides Lifeline-only wireless
services as an ETC in Arkansas, Maryland, Maine, Rhode Island, 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.
7

(“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, 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; (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 of the 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, California, Colorado, Iowa,
Kentucky, Louisiana, Maine, Maryland, Michigan, Minnesota, Missouri, Nevada, Oklahoma,
Pennsylvania, South Carolina, Texas, West Virginia and Wisconsin.9
Under current ownership, neither AirVoice nor its affiliates have been subject to
enforcement sanctions related to the Low-Income Fund or ETC revocation proceedings in any
state except as noted below.10

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.
9 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.
10 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 settled a
Notice of Apparent Liability with the FCC (See File No. EB-IHD-13-00010671), which all occurred under prior
ownership and management. By Order adopted December 16, 2021 (See File No. EB-IHD-20-00031449), NewPhone
entered into a Consent Decree with the Enforcement Bureau of the FCC for the purpose of terminating the Bureau’s
investigation on whether NewPhone, 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
8

AirVoice will provide affordable prepaid mobile phone service and high-quality customer
service. AirVoice’s service offering will include: (1) 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 of the 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.
9

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.
III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF WIRELESS
ETCS
Section 214(e)(2) of the Act provides state public utility commissions with the “primary
responsibility” for the designation of ETCs.11 Although Section 332(c)(3)(A) 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 214(e)(1).
AirVoice recognizes that Section 214(e)(1)(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 of this facilities requirement to carriers seeking
Lifeline-only ETC designation.13 Section 10(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

11 47 U.S.C. § 214(e)(2).
12 USF Order, at 8858–59, ¶ 145.
13 See Lifeline and Link Up Reform Order at ¶ 368.
10

[Federal Communications] Commission has determined to forbear from applying under subsection
(a) of this section.” As such, the Commission is required by Section 10(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 214(e)(2) of the Act to
grant AirVoice’s request for designation as an ETC throughout the State of Idaho.

IV. AIRVOICE SATISFIES THE REQUIREMENTS FOR DESIGNATION AS AN
ETC UNDER 47 C.F.R. § 54.201
Section 254(e) of the Act provides that, “only an eligible telecommunications carrier
designated under section 214(e) shall be eligible to receive specific federal universal service
support.” Section 214(e)(2) 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.14 Section 214(e)(1) 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 of the 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.15 As detailed below, AirVoice
satisfies each of the above-listed requirements.

14 See Federal-State Joint Board on Universal Service, First Report and Order, 12 FCC Rcd 8776, 8858-59, ¶ 145
(1997) (“USF Order”).
15 See 47 U.S.C. § 214(e)(1) and 47 C.F.R. § 54.201(d)(2).
11

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 214(e)(1)(A) for carriers that are, or seek to become, Lifeline-only
ETCs, subject to the following conditions:16
(1) the carrier must comply with certain 911 requirements [(a) providing its Lifeline
subscribers with 911 and E911 access, regardless of activation status and availability of
minutes; (b) providing its Lifeline subscribers with E911-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 Order]; 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, 2012.17 The FCC approved
AirVoice’s Revised Compliance Plan on December 23, 202118 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

16 See Lifeline and Link Up Reform Order at ¶¶ 368, 373, and 379.
17 See FCC Public Notice DA 12-2063, https://www.fcc.gov/document/wcb-approves-nine-lifeline-compliance-
plans.
18 See Public Notice DA 21-1641, https://www.fcc.gov/document/wcb-approves-revised-compliance-plan-airvoice-
wireless-llc.
12

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.19
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. § 54.101(a)) as follows:
1. Voice Telephony Service
As set forth in 47 C.F.R. § 54.101(a)(1), eligible Voice Telephony Services must provide
the following:
Voice Grade Access to the Public Switched Telephone Network. AirVoice provides
voice grade access to the public switched telephone network (“PSTN”) through the purchase of
wholesale CMRS services from its Underlying Carriers.
Local Usage 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 911 and E911 access for all of its
customers to the extent the local government in its service area has implemented 911 or E911
systems. As noted, calls to 911 emergency services will always be free and will be available
regardless of service activation status or availability of minutes. AirVoice also complies with the

19 Implementation of Sections 3(n) and 332 of the Communications Act, Regulatory Treatment of Mobile Services, GN
Docket No. 93-252, Second Report and Order, 9 FCC Rcd 1411, 1425 ¶ 37, 1454-55 ¶ 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)(1)(A) (“mobile services” providers are common carriers); see also PCIA
Petition for Forbearance for Broadband PCS, WT Docket No. 98-100, (Memorandum Opinion and Order and Notice
of Proposed Rulemaking, 13 FCC Rcd 16857, 16911 ¶ 111 (1998) ("We concluded [in the Second Report and Order]
that CMRS also includes the following common carrier services: cellular service, … all mobile telephone services and
resellers of such services.") (emphasis added).
13

FCC’s regulations governing the deployment and availability of E911 compatible handsets.
Toll Limitation. In its Lifeline and Link Up Reform Order, the FCC provided that toll
limitation would no longer be deemed a supported service.20 “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.”21 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. AirVoice’s 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 Internet 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 defined 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 Up Reform Order at ¶ 367.
21 See id. at ¶ 49.
22 See 47 C.F.R. § 8.2(a).
14

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 justify 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, 214(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 13-44 released April
15, 2013) authorized forbearance from the service area conformance requirements with respect to
carriers seeking to provide Lifeline-only service.24 In light of this forbearance, the Commission
has the authority to designate ETCs such as AirVoice in rural areas without concern for the service
area conformance requirement.25

23 See Western Wireless Corporation Petition for Designation as an Eligible Telecommunications Carrier in the State
of Wyoming, Memorandum Opinion and Order, 16 FCC Rcd 48, 55 (2000).
24 See In the Matter of Telecommunications Carriers Eligible for Support, Lifeline and Link Up Reform, WC Docket
No. 09-197, WC Docket No. 11-42, Memorandum Opinion and Order, FCC 13-44 (rel. April 15, 2013).
25 See 47 C.F.R. § 54.207(c).
15

E. AirVoice Will Advertise the Availability of Supported Services
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 qualify 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
16

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. § 54.202(a).
A. Service Commitment Throughout the Proposed Designated Service Area
AirVoice will provide service in Idaho 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)(1)(i), and by the certification attached in Exhibit 1,
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(a)(1)(ii), 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.

17

B. Ability to Remain Functional in Emergency Situations
In accordance with 47 C.F.R. § 54.202(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 1 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 satisfy applicable consumer protection and service quality standards, and wireless applicants
may satisfy 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. § 54.202(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 Universal 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 Aug. 16, 2012).
18

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. In 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.27 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. § 54.101(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 attached Exhibit 4 for key management bios.
19

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.28 Lifeline customers that also
elect to receive ACP benefits from AirVoice will receive unlimited talk and text with 15 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 (611). Emergency (911) 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 qualifying
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 concerned 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 federally recognized tribal lands includes
unlimited talk, unlimited text, and unlimited data.
20

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).29 AirVoice will certify and verify initial and continued
consumer eligibility in accordance with 47 C.F.R. § 54.410 and will notify 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 qualifying 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

29 FCC Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program, WC Docket
No. 11-42, Public Notice, “Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline
Program,” DA 18-161 (rel. Feb. 20, 2018). The standard application/certification forms are available on USAC’s
website (See USAC, Lifeline Forms, http://www.usac.org/li/tools/forms/default.aspx).
21

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” restriction 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. § 54.407(c)(2). An account will be considered active if the
authorized subscriber establishes usage, as “usage” is defined by 47 C.F.R. § 54.407(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. § 54.405(e)(3), currently a period of fifteen (15) days. In accordance with 47 C.F.R.
§ 54.405(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: (1) Duplicate Same-Month Lifeline Subsidies
(Double Dip): any name/address that is already receiving a lifeline subsidy from the Company will
22

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 internal 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 ITSAP 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.1 (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.

23

VI. DESIGNATION OF AIRVOICE AS AN 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.30 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 consumers—particularly 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.”31 Given this context, designating AirVoice as an ETC would
significantly benefit low-income consumers eligible for Lifeline services in Idaho—the intended
beneficiaries of universal service.

30 Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56.
31 See Lifeline Modernization Order ¶ 2.
24

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 911 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
25

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 Idaho

32 See, e.g., Specialized Common Carrier Services, 29 FCC Rcd 870 (1971).
33 See 47 U.S.C. § 254(b)(1).
26

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 in the Lifeline and Link Up 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 qualified 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.

27

VII. CONCLUSION
Based on the foregoing, designation of AirVoice as an ETC in the State of Idaho complies
with the requirements of Section 214(e)(2) 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.
Respectfully 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: [e-mail]

Attorneys for AirVoice Wireless, LLC
d/b/a AirTalk Wireless

March 22, 2022

EXHIBIT 2

FCC-Approved Compliance Plan
Lance J.M. Steinhart, P.C. Attorneys At Law 1725 Windward Concourse Suite 150 Alpharetta, Georgia 30005

Also Admitted in New York Telephone: [phone]
Email: [e-mail] Facsimile: [phone] May 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 Docket Nos. 09-197
and 11-42
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.1 The Wireline Competition Bureau (Bureau)
approved AirVoice’s Compliance Plan on December 26, 2012.2

1 See 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 Nos. 11-42 and 03-109, CC Docket No. 96-45, and WC Docket No. 12-23,
Report and Order and Further Notice Of Proposed Rulemaking, FCC 12-11 (reI. Feb. 6, 2012).
2 Wireline Competition Bureau Approves the Compliance Plans of 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 11-42, Public Notice, DA 12-2063 (rel. December 26, 2012).

Marlene H. Dortch May 17, 2021 Page 2

AirVoice now seeks expedited approval of the enclosed Revised Compliance Plan,
which has been revised to: (1) 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 Interest Purchase Agreement dated May 17,
2021, 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 (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.
Respectfully submitted, s/ Lance Steinhart
Lance J.M. Steinhart, Esq.
Managing Attorney Lance J.M. Steinhart, P.C. Attorneys for AirVoice Wireless, LLC

Enclosures
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

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 Docket No. 11-42

AIRVOICE WIRELESS, LLC REVISED COMPLIANCE PLAN
AirVoice Wireless, LLC (“AIRVOICE” or the “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”) 2012 Lifeline
Reform Order, 2015 Lifeline Second Report and Order,2 and Third Report and Order.3
1 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 Up, Federal-State Joint Board on Universal Service, Advancing Broadband Availability Through Digital Literacy Training, WC Docket No. 11-42, 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 12-11 (Feb. 6, 2012) (“2012 Lifeline Reform Order”). See Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service Support, Connect America Fund, WC Docket Nos. 11-42, 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, ¶ 249 (rel. June 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 Docket Nos. 09-197, 11-42, Public Notice, DA 12-314 (rel. Feb. 29, 2012) (Compliance Plan Public Notice).
3 See In the Matter of Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service Support, Connect America Fund, WC Docket No. 11-42,
2
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 911 requirements as described below and qualifies for blanket
forbearance from the facilities requirement of section 214(e)(1)(A) of the Communications Act to
participate as an ETC in the Lifeline program.5
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. 10-90, Third Report and Order, Further Report and Order, and Order on Reconsideration, FCC 16-38 (rel. Apr. 27, 2016) (“Third Report and Order”).
4 Wireline Competition Bureau Approves the Compliance Plans of 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 11-42, Public Notice, DA 12-2063 (rel. December 26, 2012).
5 See 2012 Lifeline Reform Order ¶ 368. Although AIRVOICE qualifies for and seeks to avail itself of the Commission’s grant of forbearance from the facilities requirement of section 214(e)(1)(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.
3
generally.6 This Revised Compliance Plan describes the specific measures that the Company has
implemented to achieve these objectives. Specifically, this Revised Compliance Plan: (1)
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.
ACCESS TO 911 AND E911 SERVICES7
Pursuant to the 2012 Lifeline Reform Order, forbearance is conditioned upon the
Company: (1) providing its Lifeline subscribers with 911 and E911 access, regardless of activation
status and availability of minutes; and (2) providing its wireless Lifeline subscribers with E911-
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 911 and E911 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 911 and E911 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 2012 Lifeline Reform Order ¶ 373.
4
AIRVOICE’s existing practices currently provide access to 911 and E911 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 911
calls from the Company’s customers in the same manner as 911 calls from their own retail
customers. To the extent that AIRVOICE’s Underlying Carriers are certified in a given PSAP
territory, this 911 capability will function the same for the Company. AIRVOICE also currently
enables 911 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.
E911-Compliant Handsets. AIRVOICE’s handsets used in connection with the wireless
Lifeline service offering have always been and will continue to be 911 and E911-compliant. The
Company’s phones have passed a stringent certification process, which ensures that the handset
models used meet all 911 and E911 requirements. As a result, any existing wireless customer that
qualifies for and elects Lifeline service will already have a 911/E911-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
AIRVOICE’s Lifeline voice telephony service is assured of receiving a 911/E911-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.9
The Commission further requires such providers to offer the choice to Lifeline customers of devices
9 See Third Report and Order at ¶ 366.
5
that are equipped with hotspot functionality.10 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(f).

COMPLIANCE PLAN
I. PROCEDURES TO ENROLL A SUBSCRIBER IN LIFELINE11
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: (1) household income at or below one hundred-thirty five percent (135%)
of the Federal Poverty 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.
10 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).
11 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. 11-42, Public Notice, DA 19-1290 (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.
6
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.14 Customers that enroll electronically will use the National
13 See infra Section I.F. regarding use of the NLAD.
14 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 Reconsideration ¶ 224.
7
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 identify 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.15
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 ‘[l]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
15 See Petition of TracFone Wireless, Inc. for Forbearance from 47 U.S.C. § 214(e)(1)(A) and 47 C.F.R. § 54.201(i), CC Docket No. 96-45, Order, FCC 05-165, ¶ 19 (2005).
16 2012 Lifeline Reform Order ¶ 110.
8
Lifeline program’s enrollment, recertification, and reimbursement processes including
involvement of representatives.17
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 certify and verify the customer’s Lifeline eligibility.
All Representatives are instructed that the company has zero tolerance for waste, fraud or
abuse, and that they should notify 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 internal compliance
personnel.
De-Enrollment for Ineligibility. 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

17 In the Matter of Bridging the Digital Divide for Low-Income Consumers, Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service Support, WC Docket No. 17-287, WC Docket No. 11-42, WC Docket No. 09-197, Fifth Report and Order, Memorandum Opinion and Order and Order on Reconsideration, and Further Notice of Proposed
Rulemaking, FCC 19-111 (rel. Nov. 14, 2019) (“Fifth Report and Order”).
9
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(f), 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.19 Live customer service and bilingual operators
can currently be reached for Lifeline service support from 10 AM to 10 PM Eastern, Monday
through Saturday, with 24/7 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. § 54.410(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 qualifying programs as well as a breakdown of
18 See 2012 Lifeline Reform Order ¶ 143; 47 C.F.R. § 54.405(e)(1).
19 See 47 C.F.R. § 54.405(e)(5).
20 See FCC Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program, WC Docket No. 11-42, Public Notice, DA 18-161 (rel. Feb. 20, 2018). The standard application/certification forms are available on USAC’s website (See USAC, Lifeline Forms, https://www.usac.org/lifeline/additional-requirements/forms/). See Compliance Plan Public Notice at 3.
10
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.21
Disclosures. The Universal Forms include the following disclosures, which the Company
also includes on its website or electronic application platform: (1) 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(d)(2)-(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-certify 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
21 See 2012 Lifeline Reform Order ¶ 123.
22 See id. ¶ 121; 47 C.F.R. § 54.410(d)(1).
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 transmitted 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(b)(9).
11
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-certify 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.25
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.
§ 54.407(c)(2). An account will be considered active if the authorized subscriber establishes
usage, as “usage” is defined by 47 C.F.R. § 54.407(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 2012 Lifeline Reform Order. This type of educational recertification message is consistent with the 2012 Lifeline 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.” 2012 Lifeline Reform Order ¶ 145.
25 See 2012 Lifeline Reform Order ¶ 257; 47 C.F.R. § 54.407(c)(1).
12
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. In accordance with 47 C.F.R. § 54.405(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. AIRVOICE will update the NLAD within one (1) 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 enrollment27 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.28
26 See 2012 Lifeline 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. In those states, AIRVOICE will follow the duplicates detection process required by the state.
28 See 2012 Lifeline Reform Order ¶ 203. The Company transmits to the NLAD the information required for each new Lifeline subscriber. See id., ¶¶ 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.
13
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 training 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 household29
through the use of Universal Forms discussed above, National Verifier and NLAD database
checks, 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 certifying compliance with
29 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 ¶ 74; section 54.400(h).
30 See 2012 Lifeline Reform Order ¶ 78.
14
the one-per-household rule in accordance with 47 C.F.R. § 54.410(g).31
If 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: (1) 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.34 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
31 The Household Worksheet is available at https://www.usac.org/lifeline/additional-requirements/forms/.
32 See 2012 Lifeline Reform Order ¶ 275; 47 C.F.R. § 54.405(c).
33 See 2012 Lifeline Reform Order ¶ 275; 47 C.F.R. § 54.405(c).
34 See 2012 Lifeline Reform Order ¶ 275; 47 C.F.R. § 54.405(c).
15
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.35 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 1st 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
certifying, under penalty of perjury, that the Company: (1) has policies and procedures in place to
ensure that its Lifeline subscribers 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. §54.408.39 The Company
provides the results of its re-certification efforts, performed pursuant to section 54.410(f) of the
Commission’s rules, as amended, annually by January 31st, for its re-certification efforts of the
previous year.40
35 See 2012 Lifeline Reform Order ¶ 128; 47 C.F.R. § 54.407(d).
36 See 47 C.F.R. § 54.407(a).
37 See id. at § 54.407(e).
38 See id. at § 54.422.
39 See id. at § 54.416(a).
40 See id. at § 54.416(b).
16
II. Description of Lifeline Service Offerings41
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 VOICE TEXT DATA LIFELINE
PRICE
1000 Voice/500 Text/ 4.5 GB Data 1000 500 (SMS) 4.5 GB $0.00

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 911 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/).
III. Demonstration of Financial and Technical Capabilities and Certifications Required for ETC Designation42
Financial and Technical Capabilities. Section 54.202(a)(4)43 requires carriers petitioning
for ETC designation to demonstrate financial and technical capability to comply with the
41 See Compliance Plan Public Notice at 3.
42 See Compliance Plan Public Notice at 3.
17
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 Interest Purchase Agreement dated May 17, 2021,
2021, 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 (100%) 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 d/b/a SFone Wireless, a Delaware limited liability company (“Cintex”), that
provides non-Lifeline wireless services throughout the United States, and provides Lifeline-only
43 See 47 C.F.R. § 54.202(a)(4).
44 See 2012 Lifeline Reform Order ¶¶ 387-388 (revising Commission rule 54.202(a)(4)).
18
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
19
have been subject to enforcement sanctions related to the Low Income Fund or ETC revocation
proceedings in any state.45 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 Company’s Support. The Compliance Plan Public
Notice requires carriers to include “certifications required under newly amended section 54.202 of
the Commission’s rules.”46 AIRVOICE certifies that it will comply with the service requirements
applicable to the support the Company receives.47 AIRVOICE’s Lifeline supported voice services
will meet the minimum service standards set forth in 47 C.F.R. § 54.408. AIRVOICE’s Lifeline
45 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 settled a Notice of Apparent Liability with the FCC (See File No. EB-IHD-13-00010671).
46 Compliance Plan Public Notice at 3.
47 See 47 C.F.R. § 54.202(a)(1).
20
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(f), 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 Internet access
service (“BIAS”), a supported service as of December 2, 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 II 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 911 and E911 where available, and will comply
with any Commission requirements regarding E911-compliant handsets. As discussed above, the
Company will comply with the Commission’s applicable forbearance grant conditions relating to
the provision of 911 and E911 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
21
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.
Respectfully 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: [e-mail]

Legal and Regulatory Counsel May 17, 2021
48 See 2012 Lifeline Reform Order ¶ 230.

EXHIBIT A ORGANIZATIONAL CHARTS

Pre-Transaction

Post Transaction

Wail Dickow 10%
Falah Bahri 15%
Jim Bahri
15% Kenny
Hannawa
30%
Nick Hannawa 15%
Kyle
Hannawa 15%
Hung Do
US Citizen
100%
LLC d/b/a SFone Wireless
Wireless, LLC Communications, LLC Technologies, LLC Holdings, LLC
Wireless, LLC

EXHIBIT 3

Coverage Area

zip primary_citystate county
83201 Pocatello ID Bannock County
83202 Pocatello ID Bannock County
83204 Pocatello ID Bannock County
83210 Aberdeen ID Bingham County
83211 American FallsID Power County
83212 Arbon ID Power County
83213 Arco ID Butte County
83214 Arimo ID Bannock County
83215 Atomic CityID Bingham County
83217 Bancroft ID Caribou County
83220 Bern ID Bear Lake County
83221 Blackfoot ID Bingham County
83226 Challis ID Custer County
83227 Clayton ID Custer County
83228 Clifton ID Franklin County
83229 Cobalt ID Lemhi County
83230 Conda ID Caribou County
83232 Dayton ID Franklin County
83234 Downey ID Bannock County
83235 Ellis ID Custer County
83236 Firth ID Bingham County
83237 Franklin ID Franklin County
83238 Geneva ID Bear Lake County
83241 Grace ID Caribou County
83243 Holbrook ID Oneida County
83244 Howe ID Butte County
83245 Inkom ID Bannock County
83246 Lava Hot SpringsID Bannock County
83250 MccammonID Bannock County
83251 Mackay ID Custer County
83252 Malad City ID Oneida County
83253 May ID Lemhi County
83254 MontpelierID Bear Lake County
83255 Moore ID Butte County
83262 Pingree ID Bingham County
83263 Preston ID Franklin County
83271 Rockland ID Power County
83272 Saint CharlesID Bear Lake County
83274 Shelley ID Bingham County
83276 Soda SpringsID Caribou County
83277 Springfield ID Bingham County
83278 Stanley ID Custer County
83283 Thatcher ID Franklin County
83285 Wayan ID Bonneville County
83286 Weston ID Franklin County
83287 Fish Haven ID Bear Lake County
83301 Twin Falls ID Twin Falls County
83302 Rogerson ID Twin Falls County
83311 Albion ID Cassia County
83313 Bellevue ID Blaine County
83314 Bliss ID Gooding County
83316 Buhl ID Twin Falls County
83318 Burley ID Cassia County
83320 Carey ID Blaine County
83321 Castleford ID Twin Falls County
83322 Corral ID Camas County
83323 Declo ID Cassia County
83324 Dietrich ID Lincoln County
83325 Eden ID Jerome County
83327 Fairfield ID Camas County
83328 Filer ID Twin Falls County
83330 Gooding ID Gooding County
83332 Hagerman ID Gooding County
83333 Hailey ID Blaine County
83334 Hansen ID Twin Falls County
83335 Hazelton ID Jerome County
83336 Heyburn ID Minidoka County
83337 Hill City ID Camas County
83338 Jerome ID Jerome County
83340 Ketchum ID Blaine County
83341 Kimberly ID Twin Falls County
83342 Malta ID Cassia County
83344 Murtaugh ID Twin Falls County
83346 Oakley ID Cassia County
83347 Paul ID Minidoka County
83348 Picabo ID Blaine County
83349 Richfield ID Lincoln County
83350 Rupert ID Minidoka County
83352 Shoshone ID Lincoln County
83355 Wendell ID Gooding County
83401 Idaho Falls ID Bonneville County
83402 Idaho Falls ID Bonneville County
83404 Idaho Falls ID Bonneville County
83406 Idaho Falls ID Bonneville County
83420 Ashton ID Fremont County
83422 Driggs ID Teton County
83423 Dubois ID Clark County
83424 Felt ID Teton County
83425 Hamer ID Jefferson County
83427 Iona ID Bonneville County
83428 Irwin ID Bonneville County
83429 Island Park ID Fremont County
83431 Lewisville ID Jefferson County
83434 Menan ID Jefferson County
83435 MonteviewID Jefferson County
83436 Newdale ID Fremont County
83440 Rexburg ID Madison County
83442 Rigby ID Jefferson County
83443 Ririe ID Jefferson County
83444 Roberts ID Jefferson County
83445 Saint AnthonyID Fremont County
83446 Spencer ID Clark County
83448 Sugar City ID Madison County
83449 Swan ValleyID Bonneville County
83450 Terreton ID Jefferson County
83451 Teton ID Fremont County
83452 Tetonia ID Teton County
83455 Victor ID Teton County
83462 Carmen ID Lemhi County
83463 GibbonsvilleID Lemhi County
83464 Leadore ID Lemhi County
83466 North Fork ID Lemhi County
83467 Salmon ID Lemhi County
83469 Shoup ID Lemhi County
83501 Lewiston ID Nez Perce County
83520 Ahsahka ID Clearwater County
83522 CottonwoodID Idaho County
83523 Craigmont ID Lewis County
83524 Culdesac ID Nez Perce County
83525 Elk City ID Idaho County
83526 Ferdinand ID Idaho County
83530 GrangevilleID Idaho County
83533 GreencreekID Idaho County
83535 Juliaetta ID Latah County
83536 Kamiah ID Idaho County
83537 Kendrick ID Latah County
83539 Kooskia ID Idaho County
83540 Lapwai ID Nez Perce County
83541 Lenore ID Clearwater County
83542 Lucile ID Idaho County
83543 Nezperce ID Lewis County
83544 Orofino ID Clearwater County
83545 Peck ID Nez Perce County
83546 Pierce ID Clearwater County
83547 Pollock ID Idaho County
83548 Reubens ID Lewis County
83549 Riggins ID Idaho County
83552 Stites ID Idaho County
83553 Weippe ID Clearwater County
83554 White Bird ID Idaho County
83555 WinchesterID Nez Perce County
83602 Banks ID Boise County
83604 Bruneau ID Owyhee County
83605 Caldwell ID Canyon County
83607 Caldwell ID Canyon County
83610 Cambridge ID Washington County
83611 Cascade ID Valley County
83612 Council ID Adams County
83615 Donnelly ID Valley County
83616 Eagle ID Ada County
83617 Emmett ID Gem County
83619 Fruitland ID Payette County
83622 Garden ValleyID Boise County
83623 Glenns FerryID Elmore County
83624 Grand ViewID Owyhee County
83626 Greenleaf ID Canyon County
83627 Hammett ID Elmore County
83628 Homedale ID Owyhee County
83629 Horseshoe BendID Boise County
83631 Idaho City ID Boise County
83632 Indian ValleyID Adams County
83633 King Hill ID Elmore County
83634 Kuna ID Ada County
83636 Letha ID Gem County
83637 Lowman ID Boise County
83638 Mccall ID Valley County
83639 Marsing ID Owyhee County
83641 Melba ID Canyon County
83642 Meridian ID Ada County
83643 Mesa ID Adams County
83644 Middleton ID Canyon County
83645 Midvale ID Washington County
83646 Meridian ID Ada County
83647 Mountain HomeID Elmore County
83648 Mountain Home AFBID Elmore County
83650 Murphy ID Owyhee County
83651 Nampa ID Canyon County
83654 New MeadowsID Adams County
83655 New PlymouthID Payette County
83657 Ola ID Gem County
83660 Parma ID Canyon County
83661 Payette ID Payette County
83666 Placerville ID Boise County
83669 Star ID Ada County
83670 Sweet ID Gem County
83672 Weiser ID Washington County
83676 Wilder ID Canyon County
83677 Yellow PineID Valley County
83686 Nampa ID Canyon County
83687 Nampa ID Canyon County
83702 Boise ID Ada County
83703 Boise ID Ada County
83704 Boise ID Ada County
83705 Boise ID Ada County
83706 Boise ID Ada County
83708 Boise ID Ada County
83709 Boise ID Ada County
83712 Boise ID Ada County
83713 Boise ID Ada County
83714 Garden CityID Ada County
83716 Boise ID Ada County
83801 Athol ID Kootenai County
83802 Avery ID Shoshone County
83803 Bayview ID Kootenai County
83804 Blanchard ID Bonner County
83805 Bonners FerryID Boundary County
83808 Calder ID Shoshone County
83809 CareywoodID Bonner County
83810 Cataldo ID Kootenai County
83811 Clark Fork ID Bonner County
83812 Clarkia ID Shoshone County
83813 Cocolalla ID Bonner County
83814 Coeur D AleneID Kootenai County
83815 Coeur D AleneID Kootenai County
83821 Coolin ID Bonner County
83822 Oldtown ID Bonner County
83823 Deary ID Latah County
83824 Desmet ID Benewah County
83830 Fernwood ID Benewah County
83832 Genesee ID Latah County
83833 Harrison ID Kootenai County
83834 Harvard ID Latah County
83835 Hayden ID Kootenai County
83836 Hope ID Bonner County
83837 Kellogg ID Shoshone County
83839 Kingston ID Shoshone County
83842 Medimont ID Kootenai County
83843 Moscow ID Latah County
83845 Moyie SpringsID Boundary County
83846 Mullan ID Shoshone County
83847 Naples ID Boundary County
83848 Nordman ID Bonner County
83850 Pinehurst ID Shoshone County
83851 Plummer ID Benewah County
83852 Ponderay ID Bonner County
83854 Post Falls ID Kootenai County
83855 Potlatch ID Latah County
83856 Priest RiverID Bonner County
83857 Princeton ID Latah County
83858 Rathdrum ID Kootenai County
83860 Sagle ID Bonner County
83861 Saint MariesID Benewah County
83864 Sandpoint ID Bonner County
83868 SmeltervilleID Shoshone County
83869 Spirit Lake ID Kootenai County
83870 Tensed ID Benewah County
83871 Troy ID Latah County
83872 Viola ID Latah County
83873 Wallace ID Shoshone County
83874 Murray ID Shoshone County
83876 Worley ID Kootenai County

EXHIBIT 4

Key Management Bios

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 a variety 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.

MVNO/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 2018
Employment Duration 20 yrs
Location Houston
Developing simple software solutions fit to client's needs. Providing turn 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 strategy, 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 – Jul 2015 Employment Duration 9 mos
Location Houston, Texas Area Luminess Air
Lead Internet Marketing Associate Dates Employed Jan 2011 – 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 1 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, returned or excess handset inventory. For regional carriers or MVNO’s, HTH
is the leading provider of high-quality refurbished 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 modify 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 4G/5G 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.
Hugo Vo

IT Professional with 3 years of experience, and a proven knowledge of hardware engineering,
configuration and troubleshooting. Proven ability to develop and implement IT solutions that
support business needs.

HTH Communications, LLC
IT & Development Manager May 2021 – Present
IT Support Jan 2019 – May 2021
Phone Technician / Helpdesk Jul 2018 – Jan 2019
Employment Duration 3 yrs 5 mos
Location Houston, Texas, U.S

Creative Bay
Web Developer May 2012 – Dec 2013
Employment Duration 1 yr 8 mos
Location Vietnam

UNIVERSITY OF GREENWICH
Degree Name Bachelor of Science (B.S.)

EXHIBIT 5

Proposed Lifeline Offering

Minutes & Data

1,000 anytime minutes per month
500 text messages per month
4.5 GB data per month
LTE or 5G Network
Net cost to Lifeline customer: $0

ADDITIONAL AIRTIME

Available for purchase at www.airtalkwireless.com

All packages include:

 Free SIM card or Handset
 Free calls to AirVoice Customer Service
 Free calls to 911 emergency services
 Free access to Voicemail, Caller-ID, and Call Waiting features
 Voice minutes may be used for Domestic Long Distance at no extra cost

EXHIBIT 6

Sample Advertisements
Apply Online at airtalkwireless.com
E-mail us at [e-mail]
Call us toll-free at [phone]
QUICK &EASY!
APPLYING IS
is now Government Assistance Program
LIFELINE & ACP
PROGRAM to RECEIVE a
FREE iPhone 7,
Samsung S9 &
UNLIMITED
Data, Talk & Text
Unlimited Data is provided by the Affordable Connectivity Program.See Terms & Conditions for additional information. The above devices are available while supplies last.If models are no longer available, a similar device will be offered.
&ACP&
M to RECEIV
one 7,
ng S9 &
TED
alk & Text
om
VE a
fo d
a
Tablets
For$10.01!
FREESamsung
S9FREE
iPhone

7
Keeping Our Communities Connected
Affordable Connectivity
Program
Congress recently created the
Affordable Connectivity
Program, a long-term, $14 billion
program, which will replace the
Emergency Broadband Benefit
Program. This investment in
broadband affordability will help
ensure we can afford the
internet connections we need for
work, school, health care, and
more for a long time.
You Can Qual˜˙y if You
Participate in One of the
Following Programs:
AirTalk Wireless is a program
provided by HTH Communications
serving eligible American
households. The company is an
FCC-licensed Eligibility
Telecommunication Carrier (ETC)
which offers Lifeline and the
Affordable Connectivity Program
(ACP) to eligible customers
across America.
About Us
Why Should You
Choose AirTalk ?
Offers the best FREE Phone
Offers the best FREE service
plan
Nationwide Coverage & 23+
years in business
Dedicated Customer Service
Our customers are happy
Applying is quick & easy
Fast & Free Shipping
SNAP/FOOD STAMPS
MEDICAID
SSI
VETERANS SURVIVORS PENSION
BENEFITS FUND
FEDERAL PUBLIC HOUSING
ASSISTANCE
or through income base
qualifications and MANY MORE!
Contact Us:
Monday - Friday : 8:00 a.m - 5:00 p.m CST & Saturday: 10:00 a.m - 7:00 p.m CST
Website: www.airtalkwireless.com Email: [e-mail] Phone: [phone]
Lance J.M. Steinhart, P.C.
Attorneys At Law
1725 Windward Concourse
Suite 150
Alpharetta, Georgia 30005

Also Admitted in New York Telephone: [phone]
Email: [e-mail] Facsimile: [phone]

April 22, 2022

VIA EMAIL TO [e-mail]

Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702

Re: Air Voice Wireless, LLC d/b/a AirTalk
Case No. AVW-T-22-01

Dear Ms. Noriyuki:

Air Voice Wireless, LLC d/b/a AirTalk Wireless (“Air Voice”) filed an Application for
Limited Designation as an Eligible Telecommunications Carrier (the “Application”) on March 23,
2022. Air Voice respectfully requests to supplement its Application with information in support of
its technical capabilities attached hereto as Exhibit 8.

If you have any questions, or if I may provide you with additional information, please do not
hesitate to contact me at 770-232-9200 or [e-mail]. Thank you.

Respectfully submitted,

Lance J.M. Steinhart, Esq.
Managing Attorney
Lance J.M. Steinhart, P.C.
Attorneys for Air Voice Wireless, LLC d/b/a AirTalk Wireless

Attachments
cc: Henry Do
Johan E. Kalala-Kasanda

EXHIBIT 8

Technical Capabilities

SOLUTIONS OVERVIEW
JANUARY 2021
TABLE OF CONTENTS
1.ABOUT HTH
2.COMPREHENSIVE SERVICE OFFERING
o HANDSET SALES
o MVNE SERVICES
o 4PL SOLUTIONS
o REPAIR & REFURBISHING
3.THE HTH TEAM
4.TIMELINE OF OUR GROWTH
5.QUALITY STANDARDS WE MAINTAIN
6.CUSTOMERS WE SERVE
7.BRANDS WE CARRY
8.COMPETITIVE ADVANTAGE
9.WORKING TOGETHER
10.HTH COMMUNICATIONS AFFILIATE COMPANIES
PROVIDING SUSTAINABLE SOLUTIONS FOR THE WIRELESS INDUSTRY
ABOUT HTH
For customers across the globe, HTH is delivering value into
their supply chain through programs that lower cost of
acquisition, reduce churn and increase returns on investment.
At HTH, we believe that sustainability is ensuring that our
customers achieve their business goals year after year. We
believe that sustainability means investing in our employees
and creating a culture of success. And, we believe that
sustainability means operating our business in accordance
with global quality standards designed to ensure the well-being
and prosperity of future generations.
Handset Sales
MVNE Services
4PL Services
WE MANAGE THE SECONDARY MARKETPLACE SO YOU DON’T HAVE TOCOMPREHENSIVE SERVICE OFFERING
Repair and Refurbishing
In the secondary marketplace, value is derived from high-
quality products, efficient services and expandable
infrastructure. HTH knows this and that’s why our
comprehensive service offering is used by over 50 MVNO’s,
4 National Carriers and numerous OEMs. Our service
platform enables success and delivers maximum returns to
our partners.
HANDSET SALES
BUY FROM US
Our customers demand full-features phones at second life prices.
Whether you’re looking for a smartphone or a basic feature phone,
we have a wide selection of devices to choose from in a variety of
conditions and grades. Each customer is assigned a dedicated
account manager who provides:
o Weekly inventory reports
o Promotional offers
o Same day order fulfillment
o Flexible financing offers
o Device warranty
o Logistics expertise
o Exceptional service
HANDSET SALES
SELL TO US
We understand that carriers, OEM’s and insurance providers all
carry millions of dollars in inventory and have financial targets
to meet. That’s why we participate in numerous disposition
programs to purchase returned, trade-in, buy-back and excess
inventory; always delivering returns to help your company
achieve its goals.
MVNE SERVICES
OPERATIONAL
TOOLS
WHITE LABEL
SOLUTIONS
RISK REWARD
MODELS CAP EX DEFERRALS
AIRTIME BUNDLES OPERATING
SYSTEM SUPPORT
DEVICE
MANAGEMENT
VIRTUAL
WAREHOUSING
4PL SERVICES
VIRTUAL
WAREHOUSING TRANSPORTATION DROP SHIPMENT TRACKING AND
REPORTING
FORWARD LOGISTICS REVERSE LOGISTICS
REPAIR & REFURBISHING
PARTS RECOVERY &
RECLAMATION
OEM NEW &
REFURBISHED PARTS
PROPRIETARY
TESTING EQUIPMENT
OEM CERTIFIED
FACILITY
Triage Disassembly Assembly Picture Packs Distribution
HTH PROCESS
OVERVIEW:
CULTURE OF SUCCESS
THE HTH TEAM
HTH was founded in July 2008 by Henry Do. Holding degrees in Economics and Finance, Henry began his career at a private equity firm serving the wireless
industry where he recognized the need for a repair company that was laser focused on quality and efficiency. Nothing affected the bottom line of companies
more than those two factors. With that, HTH was formed. Over the past twelve years, HTH has grown in size and scope and it has done so by creating a
culture of success for employees. Enabling employees to grow and excel within the company, ensuring employees do their jobs with integrity and attention to
detail, and rewarding employees when they achieve their goals are all part of the HTH culture.
Henry Do, CEO Leadership Warehouse and
Technical Staff Customer Service
WHEN OUR CUSTOMERS SUCCEED, WE SUCCEEDTIMELINE OF OUR GROWTH
20142008201020122009
HTH
Communications
founded and
operated in
1,500-SF facility
in Houston, TX
Moved into 10,000-SF
facility less than a
year later to
accommodate growth.
Selected as exclusive
distributor of Cricket’s
refurbished handsets
HTH becomes a
downstream vendor
to Sprint, US Cellular,
MetroPCS, AT&T and
T-Mobile
Moved into a 50,000-
SF facility to
accommodate
growing team and
expansion of services
HTH expanded
marketing efforts
and began attending
trade shows such as
CTIA, CCA and
participating in
Carrier Summits
2016
HTH receives R2, ISO
9001, ISO 14001 and
ISO OHSAS 45001
certifications
2019
HTH celebrates
over a decade in
business and
relocates to its
privately owned
125,000-SF
state-of-the-art
headquarters
QUALITY & EFFICIENCY
ARE THE CORE OF OUR SOLUTIONS
QUALITY STANDARDS WE MAINTAIN
ISO 45001
OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT SYSTEMS
ISO 9001
QUALITY MANAGEMENT
SYSTEMS
ISO 14001
ENVIRONMENTAL STANDARDS SYSTEMS
R2
RESPONSIBLE ELECTRONICS RECYCLING
Choice Wireless
Amazon
eBay
Retailers & Etailers
Carolina West
Affinity Cellular
ClearTalk Wireless
Rural & Small Carriers
Assurant
Asurion
Immerge Wireless
Enterprise Providers
Samsung
Alcatel
LG
Quality One
Manufacturers &
Wholesalers
Sprint
T-Mobile
Verizon
AT&T
Metro PCS
US Cellular
Nationwide Carriers
TracPhone
Ready Wireless
Red Pocket Mobile
Assist Wireless
Credo
Easy Wireless
Safety Net Wireless
MVNO’s & Lifeline
CUSTOMERS WE SERVE
BRANDS CONSUMERS DEMAND
ARE THE BRANDS WE CARRY
ALL GRADESGrade AGrade BGrade CGrade D
Grade BER
ALL TYPESSmartphonesFeature PhonesTabletsWiFiModems
Smart Accessories
ALL BRANDSAppleSamsungLGMotorola
Kyocera
ALL CONDITIONSNewUsedCertified Pre-OwnedRefurbished
Functionally Tested
OUR STRENGTH IS IN THE NUMBERS
COMPETITIVE ADVANTAGE
Numbers can tell a powerful story.
The success of our business and commitment to
customers are best illustrated in these numbers.
125,000-square-foot
state-of-the-art
facility
200+ SKU’s in
Inventory
1.5M Annual Unit
Volume
15 In-house
Software Engineers
Financially Strong 12+ Years of
Positive Growth
Direct Access to
Carriers
200 Full-time
Employees
LET’S DEVELOP A
SOLUTION FOR YOU!
WORKING TOGETHER
ONE SOURCE SOLUTION
We simplify supply chain for our customers by offering a full scope of solutions. One vendor. One location.
One point of contact. Easy.
EXPERIENCE, SCALE, FLEXIBILITYWe have the team, the financial strength and the operations to put
together a program designed specifically for you!
COMMITMENT TO EXCELLENCEQuality and Efficiency are the core
values in running our business.Our customers deserve nothing less.
ONE SOURCE
SOLUTION
HTH COMMUNICATIONS AFFILIATE COMPANIES
Working with us is easy. We can provide you with a single service or
put together a comprehensive offering.
o Owned by Henry Hung Do
o Headquarters office is located at 9920 Brooklet Drive, Houston, TX 77099
o A distributor for wireless resellers
o Operating on the Sprint & T-Mobile Network
o B2C Products & Services
�-SOFTEL
./�) TECHNOLOGIES
WHAT WE OFFER

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION

AirVoice Wireless, LLC
d/b/a AirTalk Wireless
Application for Designation as an Eligible
Telecommunications Carrier
_____________________________________
) ) ))))
Case No. ____

APPLICATION

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: [e-mail]

Attorneys for AirVoice Wireless, LLC
d/b/a AirTalk Wireless

March 22, 2022
2

TABLE OF CONTENTS
I. INTRODUCTION ...............................................................................................................4
II. COMPANY OVERVIEW ...................................................................................................6
III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF
WIRELESS ETCS ...............................................................................................................5
IV. AIRVOICE SATISFIES THE REQUIREMENTS FOR DESIGNATION AS
AN ETC UNDER 47 C.F.R. § 54.201 .................................................................................8
V. AIRVOICE SATISFIES THE ADDITIONAL REQUIREMENTS FOR ETC
DESIGNATION UNDER 47 C.F.R. § 54.202(a) ..............................................................16
VI. DESIGNATION OF AIRVOICE AS AN ETC WOULD PROMOTE THE
PUBLIC INTEREST .........................................................................................................23
VII. CONCLUSION ..................................................................................................................27

3

TABLE OF EXHIBITS

Exhibit

Certification ...............................................................................................................1

FCC-Approved Compliance Plan ...............................................................................2

Coverage Area ...........................................................................................................3

Key Management Bios ...............................................................................................4

Proposed Lifeline Offering ........................................................................................5

Sample Advertisement ...............................................................................................6

4

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION

AirVoice Wireless, LLC
AirTalk Wireless
Application for Designation as an Eligible
Telecommunications Carrier
_____________________________________
)))))
Case No. ____

I. INTRODUCTION
AirVoice Wireless, LLC d/b/a AirTalk Wireless (“AirVoice” or the “Company”), by its
undersigned counsel, and pursuant to Section 214(e)(2) of the Communications Act of 1934, as
amended (the “Act”),1 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 qualifying Idaho
consumers; it will not (and is not eligible to) seek access to funds from the federal Universal
Service Fund (“USF”) for the purpose of participating in the Link-Up program or providing service
to high-cost areas.3 AirVoice requests that its designation as an ETC include the authority to

1 47 U.S.C. § 214(e)(2)
2 47 C.F.R. §§ 54.101-54.207.
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.

5

participate in and receive reimbursement from the Idaho Telephone Service Assistance Program
(ITSAP).
As demonstrated herein, and as certified in Exhibit 1 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
Modernization Order,5 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/b/a AirTalk Wireless
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005

4 In the Matter 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. 11-42,
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 12-11 (rel. Feb. 6, 2012) (“Lifeline and Link Up Reform Order”).
5 In the Matter of Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for
Universal Service 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,
2016) (hereinafter, “Third Report and Order” or “Lifeline Modernization Order”).
6 In the Matter of Bridging the Digital Divide for Low-Income Consumers, Lifeline and Link Up Reform and
Modernization, Telecommunications Carriers Eligible for Universal Service Support, WC Docket No. 17-287, WC
Docket No. 11-42, WC Docket No. 09-197, Fifth Report and Order, Memorandum Opinion and Order and Order on
Reconsideration, and Further Notice of Proposed Rulemaking, FCC 19-111 (rel. Nov. 14, 2019) (hereinafter, “Fifth
Report and Order”).
6

[phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
II. COMPANY OVERVIEW
AirVoice is a Michigan limited liability company,7 with its principal office located at 9920
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 (“MVNO”).
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 of the 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 d/b/a SFone
Wireless, a Delaware limited liability company (“Cintex”), that provides Lifeline-only wireless
services as an ETC in Arkansas, Maryland, Maine, Rhode Island, 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.
7

(“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, 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; (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 of the 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, California, Colorado, Iowa,
Kentucky, Louisiana, Maine, Maryland, Michigan, Minnesota, Missouri, Nevada, Oklahoma,
Pennsylvania, South Carolina, Texas, West Virginia and Wisconsin.9
Under current ownership, neither AirVoice nor its affiliates have been subject to
enforcement sanctions related to the Low-Income Fund or ETC revocation proceedings in any
state except as noted below.10

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.
9 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.
10 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 settled a
Notice of Apparent Liability with the FCC (See File No. EB-IHD-13-00010671), which all occurred under prior
ownership and management. By Order adopted December 16, 2021 (See File No. EB-IHD-20-00031449), NewPhone
entered into a Consent Decree with the Enforcement Bureau of the FCC for the purpose of terminating the Bureau’s
investigation on whether NewPhone, 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
8

AirVoice will provide affordable prepaid mobile phone service and high-quality customer
service. AirVoice’s service offering will include: (1) 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 of the 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.
9

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.
III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF WIRELESS
ETCS
Section 214(e)(2) of the Act provides state public utility commissions with the “primary
responsibility” for the designation of ETCs.11 Although Section 332(c)(3)(A) 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 214(e)(1).
AirVoice recognizes that Section 214(e)(1)(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 of this facilities requirement to carriers seeking
Lifeline-only ETC designation.13 Section 10(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

11 47 U.S.C. § 214(e)(2).
12 USF Order, at 8858–59, ¶ 145.
13 See Lifeline and Link Up Reform Order at ¶ 368.
10

[Federal Communications] Commission has determined to forbear from applying under subsection
(a) of this section.” As such, the Commission is required by Section 10(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 214(e)(2) of the Act to
grant AirVoice’s request for designation as an ETC throughout the State of Idaho.

IV. AIRVOICE SATISFIES THE REQUIREMENTS FOR DESIGNATION AS AN
ETC UNDER 47 C.F.R. § 54.201
Section 254(e) of the Act provides that, “only an eligible telecommunications carrier
designated under section 214(e) shall be eligible to receive specific federal universal service
support.” Section 214(e)(2) 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.14 Section 214(e)(1) 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 of the 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.15 As detailed below, AirVoice
satisfies each of the above-listed requirements.

14 See Federal-State Joint Board on Universal Service, First Report and Order, 12 FCC Rcd 8776, 8858-59, ¶ 145
(1997) (“USF Order”).
15 See 47 U.S.C. § 214(e)(1) and 47 C.F.R. § 54.201(d)(2).
11

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 214(e)(1)(A) for carriers that are, or seek to become, Lifeline-only
ETCs, subject to the following conditions:16
(1) the carrier must comply with certain 911 requirements [(a) providing its Lifeline
subscribers with 911 and E911 access, regardless of activation status and availability of
minutes; (b) providing its Lifeline subscribers with E911-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 Order]; 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, 2012.17 The FCC approved
AirVoice’s Revised Compliance Plan on December 23, 202118 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

16 See Lifeline and Link Up Reform Order at ¶¶ 368, 373, and 379.
17 See FCC Public Notice DA 12-2063, https://www.fcc.gov/document/wcb-approves-nine-lifeline-compliance-
plans.
18 See Public Notice DA 21-1641, https://www.fcc.gov/document/wcb-approves-revised-compliance-plan-airvoice-
wireless-llc.
12

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.19
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. § 54.101(a)) as follows:
1. Voice Telephony Service
As set forth in 47 C.F.R. § 54.101(a)(1), eligible Voice Telephony Services must provide
the following:
Voice Grade Access to the Public Switched Telephone Network. AirVoice provides
voice grade access to the public switched telephone network (“PSTN”) through the purchase of
wholesale CMRS services from its Underlying Carriers.
Local Usage 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 911 and E911 access for all of its
customers to the extent the local government in its service area has implemented 911 or E911
systems. As noted, calls to 911 emergency services will always be free and will be available
regardless of service activation status or availability of minutes. AirVoice also complies with the

19 Implementation of Sections 3(n) and 332 of the Communications Act, Regulatory Treatment of Mobile Services, GN
Docket No. 93-252, Second Report and Order, 9 FCC Rcd 1411, 1425 ¶ 37, 1454-55 ¶ 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)(1)(A) (“mobile services” providers are common carriers); see also PCIA
Petition for Forbearance for Broadband PCS, WT Docket No. 98-100, (Memorandum Opinion and Order and Notice
of Proposed Rulemaking, 13 FCC Rcd 16857, 16911 ¶ 111 (1998) ("We concluded [in the Second Report and Order]
that CMRS also includes the following common carrier services: cellular service, … all mobile telephone services and
resellers of such services.") (emphasis added).
13

FCC’s regulations governing the deployment and availability of E911 compatible handsets.
Toll Limitation. In its Lifeline and Link Up Reform Order, the FCC provided that toll
limitation would no longer be deemed a supported service.20 “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.”21 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. AirVoice’s 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 Internet 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 defined 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 Up Reform Order at ¶ 367.
21 See id. at ¶ 49.
22 See 47 C.F.R. § 8.2(a).
14

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 justify 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, 214(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 13-44 released April
15, 2013) authorized forbearance from the service area conformance requirements with respect to
carriers seeking to provide Lifeline-only service.24 In light of this forbearance, the Commission
has the authority to designate ETCs such as AirVoice in rural areas without concern for the service
area conformance requirement.25

23 See Western Wireless Corporation Petition for Designation as an Eligible Telecommunications Carrier in the State
of Wyoming, Memorandum Opinion and Order, 16 FCC Rcd 48, 55 (2000).
24 See In the Matter of Telecommunications Carriers Eligible for Support, Lifeline and Link Up Reform, WC Docket
No. 09-197, WC Docket No. 11-42, Memorandum Opinion and Order, FCC 13-44 (rel. April 15, 2013).
25 See 47 C.F.R. § 54.207(c).
15

E. AirVoice Will Advertise the Availability of Supported Services
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 qualify 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
16

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. § 54.202(a).
A. Service Commitment Throughout the Proposed Designated Service Area
AirVoice will provide service in Idaho 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)(1)(i), and by the certification attached in Exhibit 1,
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(a)(1)(ii), 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.

17

B. Ability to Remain Functional in Emergency Situations
In accordance with 47 C.F.R. § 54.202(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 1 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 satisfy applicable consumer protection and service quality standards, and wireless applicants
may satisfy 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. § 54.202(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 Universal 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 Aug. 16, 2012).
18

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. In 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.27 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. § 54.101(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 attached Exhibit 4 for key management bios.
19

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.28 Lifeline customers that also
elect to receive ACP benefits from AirVoice will receive unlimited talk and text with 15 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 (611). Emergency (911) 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 qualifying
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 concerned 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 federally recognized tribal lands includes
unlimited talk, unlimited text, and unlimited data.
20

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).29 AirVoice will certify and verify initial and continued
consumer eligibility in accordance with 47 C.F.R. § 54.410 and will notify 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 qualifying 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

29 FCC Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program, WC Docket
No. 11-42, Public Notice, “Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline
Program,” DA 18-161 (rel. Feb. 20, 2018). The standard application/certification forms are available on USAC’s
website (See USAC, Lifeline Forms, http://www.usac.org/li/tools/forms/default.aspx).
21

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” restriction 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. § 54.407(c)(2). An account will be considered active if the
authorized subscriber establishes usage, as “usage” is defined by 47 C.F.R. § 54.407(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. § 54.405(e)(3), currently a period of fifteen (15) days. In accordance with 47 C.F.R.
§ 54.405(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: (1) Duplicate Same-Month Lifeline Subsidies
(Double Dip): any name/address that is already receiving a lifeline subsidy from the Company will
22

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 internal 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 ITSAP 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.1 (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.

23

VI. DESIGNATION OF AIRVOICE AS AN 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.30 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 consumers—particularly 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.”31 Given this context, designating AirVoice as an ETC would
significantly benefit low-income consumers eligible for Lifeline services in Idaho—the intended
beneficiaries of universal service.

30 Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56.
31 See Lifeline Modernization Order ¶ 2.
24

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 911 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
25

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 Idaho

32 See, e.g., Specialized Common Carrier Services, 29 FCC Rcd 870 (1971).
33 See 47 U.S.C. § 254(b)(1).
26

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 in the Lifeline and Link Up 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 qualified 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.

27

VII. CONCLUSION
Based on the foregoing, designation of AirVoice as an ETC in the State of Idaho complies
with the requirements of Section 214(e)(2) 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.
Respectfully 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: [e-mail]

Attorneys for AirVoice Wireless, LLC
d/b/a AirTalk Wireless

March 22, 2022

EXHIBIT 2

FCC-Approved Compliance Plan
Lance J.M. Steinhart, P.C. Attorneys At Law 1725 Windward Concourse Suite 150 Alpharetta, Georgia 30005

Also Admitted in New York Telephone: [phone]
Email: [e-mail] Facsimile: [phone] May 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 Docket Nos. 09-197
and 11-42
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.1 The Wireline Competition Bureau (Bureau)
approved AirVoice’s Compliance Plan on December 26, 2012.2

1 See 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 Nos. 11-42 and 03-109, CC Docket No. 96-45, and WC Docket No. 12-23,
Report and Order and Further Notice Of Proposed Rulemaking, FCC 12-11 (reI. Feb. 6, 2012).
2 Wireline Competition Bureau Approves the Compliance Plans of 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 11-42, Public Notice, DA 12-2063 (rel. December 26, 2012).

Marlene H. Dortch May 17, 2021 Page 2

AirVoice now seeks expedited approval of the enclosed Revised Compliance Plan,
which has been revised to: (1) 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 Interest Purchase Agreement dated May 17,
2021, 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 (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.
Respectfully submitted, s/ Lance Steinhart
Lance J.M. Steinhart, Esq.
Managing Attorney Lance J.M. Steinhart, P.C. Attorneys for AirVoice Wireless, LLC

Enclosures
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

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 Docket No. 11-42

AIRVOICE WIRELESS, LLC REVISED COMPLIANCE PLAN
AirVoice Wireless, LLC (“AIRVOICE” or the “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”) 2012 Lifeline
Reform Order, 2015 Lifeline Second Report and Order,2 and Third Report and Order.3
1 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 Up, Federal-State Joint Board on Universal Service, Advancing Broadband Availability Through Digital Literacy Training, WC Docket No. 11-42, 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 12-11 (Feb. 6, 2012) (“2012 Lifeline Reform Order”). See Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service Support, Connect America Fund, WC Docket Nos. 11-42, 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, ¶ 249 (rel. June 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 Docket Nos. 09-197, 11-42, Public Notice, DA 12-314 (rel. Feb. 29, 2012) (Compliance Plan Public Notice).
3 See In the Matter of Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service Support, Connect America Fund, WC Docket No. 11-42,
2
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 911 requirements as described below and qualifies for blanket
forbearance from the facilities requirement of section 214(e)(1)(A) of the Communications Act to
participate as an ETC in the Lifeline program.5
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. 10-90, Third Report and Order, Further Report and Order, and Order on Reconsideration, FCC 16-38 (rel. Apr. 27, 2016) (“Third Report and Order”).
4 Wireline Competition Bureau Approves the Compliance Plans of 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 11-42, Public Notice, DA 12-2063 (rel. December 26, 2012).
5 See 2012 Lifeline Reform Order ¶ 368. Although AIRVOICE qualifies for and seeks to avail itself of the Commission’s grant of forbearance from the facilities requirement of section 214(e)(1)(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.
3
generally.6 This Revised Compliance Plan describes the specific measures that the Company has
implemented to achieve these objectives. Specifically, this Revised Compliance Plan: (1)
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.
ACCESS TO 911 AND E911 SERVICES7
Pursuant to the 2012 Lifeline Reform Order, forbearance is conditioned upon the
Company: (1) providing its Lifeline subscribers with 911 and E911 access, regardless of activation
status and availability of minutes; and (2) providing its wireless Lifeline subscribers with E911-
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 911 and E911 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 911 and E911 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 2012 Lifeline Reform Order ¶ 373.
4
AIRVOICE’s existing practices currently provide access to 911 and E911 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 911
calls from the Company’s customers in the same manner as 911 calls from their own retail
customers. To the extent that AIRVOICE’s Underlying Carriers are certified in a given PSAP
territory, this 911 capability will function the same for the Company. AIRVOICE also currently
enables 911 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.
E911-Compliant Handsets. AIRVOICE’s handsets used in connection with the wireless
Lifeline service offering have always been and will continue to be 911 and E911-compliant. The
Company’s phones have passed a stringent certification process, which ensures that the handset
models used meet all 911 and E911 requirements. As a result, any existing wireless customer that
qualifies for and elects Lifeline service will already have a 911/E911-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
AIRVOICE’s Lifeline voice telephony service is assured of receiving a 911/E911-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.9
The Commission further requires such providers to offer the choice to Lifeline customers of devices
9 See Third Report and Order at ¶ 366.
5
that are equipped with hotspot functionality.10 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(f).

COMPLIANCE PLAN
I. PROCEDURES TO ENROLL A SUBSCRIBER IN LIFELINE11
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: (1) household income at or below one hundred-thirty five percent (135%)
of the Federal Poverty 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.
10 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).
11 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. 11-42, Public Notice, DA 19-1290 (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.
6
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.14 Customers that enroll electronically will use the National
13 See infra Section I.F. regarding use of the NLAD.
14 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 Reconsideration ¶ 224.
7
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 identify 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.15
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 ‘[l]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
15 See Petition of TracFone Wireless, Inc. for Forbearance from 47 U.S.C. § 214(e)(1)(A) and 47 C.F.R. § 54.201(i), CC Docket No. 96-45, Order, FCC 05-165, ¶ 19 (2005).
16 2012 Lifeline Reform Order ¶ 110.
8
Lifeline program’s enrollment, recertification, and reimbursement processes including
involvement of representatives.17
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 certify and verify the customer’s Lifeline eligibility.
All Representatives are instructed that the company has zero tolerance for waste, fraud or
abuse, and that they should notify 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 internal compliance
personnel.
De-Enrollment for Ineligibility. 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

17 In the Matter of Bridging the Digital Divide for Low-Income Consumers, Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service Support, WC Docket No. 17-287, WC Docket No. 11-42, WC Docket No. 09-197, Fifth Report and Order, Memorandum Opinion and Order and Order on Reconsideration, and Further Notice of Proposed
Rulemaking, FCC 19-111 (rel. Nov. 14, 2019) (“Fifth Report and Order”).
9
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(f), 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.19 Live customer service and bilingual operators
can currently be reached for Lifeline service support from 10 AM to 10 PM Eastern, Monday
through Saturday, with 24/7 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. § 54.410(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 qualifying programs as well as a breakdown of
18 See 2012 Lifeline Reform Order ¶ 143; 47 C.F.R. § 54.405(e)(1).
19 See 47 C.F.R. § 54.405(e)(5).
20 See FCC Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program, WC Docket No. 11-42, Public Notice, DA 18-161 (rel. Feb. 20, 2018). The standard application/certification forms are available on USAC’s website (See USAC, Lifeline Forms, https://www.usac.org/lifeline/additional-requirements/forms/). See Compliance Plan Public Notice at 3.
10
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.21
Disclosures. The Universal Forms include the following disclosures, which the Company
also includes on its website or electronic application platform: (1) 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(d)(2)-(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-certify 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
21 See 2012 Lifeline Reform Order ¶ 123.
22 See id. ¶ 121; 47 C.F.R. § 54.410(d)(1).
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 transmitted 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(b)(9).
11
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-certify 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.25
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.
§ 54.407(c)(2). An account will be considered active if the authorized subscriber establishes
usage, as “usage” is defined by 47 C.F.R. § 54.407(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 2012 Lifeline Reform Order. This type of educational recertification message is consistent with the 2012 Lifeline 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.” 2012 Lifeline Reform Order ¶ 145.
25 See 2012 Lifeline Reform Order ¶ 257; 47 C.F.R. § 54.407(c)(1).
12
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. In accordance with 47 C.F.R. § 54.405(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. AIRVOICE will update the NLAD within one (1) 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 enrollment27 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.28
26 See 2012 Lifeline 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. In those states, AIRVOICE will follow the duplicates detection process required by the state.
28 See 2012 Lifeline Reform Order ¶ 203. The Company transmits to the NLAD the information required for each new Lifeline subscriber. See id., ¶¶ 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.
13
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 training 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 household29
through the use of Universal Forms discussed above, National Verifier and NLAD database
checks, 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 certifying compliance with
29 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 ¶ 74; section 54.400(h).
30 See 2012 Lifeline Reform Order ¶ 78.
14
the one-per-household rule in accordance with 47 C.F.R. § 54.410(g).31
If 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: (1) 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.34 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
31 The Household Worksheet is available at https://www.usac.org/lifeline/additional-requirements/forms/.
32 See 2012 Lifeline Reform Order ¶ 275; 47 C.F.R. § 54.405(c).
33 See 2012 Lifeline Reform Order ¶ 275; 47 C.F.R. § 54.405(c).
34 See 2012 Lifeline Reform Order ¶ 275; 47 C.F.R. § 54.405(c).
15
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.35 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 1st 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
certifying, under penalty of perjury, that the Company: (1) has policies and procedures in place to
ensure that its Lifeline subscribers 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. §54.408.39 The Company
provides the results of its re-certification efforts, performed pursuant to section 54.410(f) of the
Commission’s rules, as amended, annually by January 31st, for its re-certification efforts of the
previous year.40
35 See 2012 Lifeline Reform Order ¶ 128; 47 C.F.R. § 54.407(d).
36 See 47 C.F.R. § 54.407(a).
37 See id. at § 54.407(e).
38 See id. at § 54.422.
39 See id. at § 54.416(a).
40 See id. at § 54.416(b).
16
II. Description of Lifeline Service Offerings41
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 VOICE TEXT DATA LIFELINE
PRICE
1000 Voice/500 Text/ 4.5 GB Data 1000 500 (SMS) 4.5 GB $0.00

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 911 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/).
III. Demonstration of Financial and Technical Capabilities and Certifications Required for ETC Designation42
Financial and Technical Capabilities. Section 54.202(a)(4)43 requires carriers petitioning
for ETC designation to demonstrate financial and technical capability to comply with the
41 See Compliance Plan Public Notice at 3.
42 See Compliance Plan Public Notice at 3.
17
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 Interest Purchase Agreement dated May 17, 2021,
2021, 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 (100%) 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 d/b/a SFone Wireless, a Delaware limited liability company (“Cintex”), that
provides non-Lifeline wireless services throughout the United States, and provides Lifeline-only
43 See 47 C.F.R. § 54.202(a)(4).
44 See 2012 Lifeline Reform Order ¶¶ 387-388 (revising Commission rule 54.202(a)(4)).
18
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
19
have been subject to enforcement sanctions related to the Low Income Fund or ETC revocation
proceedings in any state.45 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 Company’s Support. The Compliance Plan Public
Notice requires carriers to include “certifications required under newly amended section 54.202 of
the Commission’s rules.”46 AIRVOICE certifies that it will comply with the service requirements
applicable to the support the Company receives.47 AIRVOICE’s Lifeline supported voice services
will meet the minimum service standards set forth in 47 C.F.R. § 54.408. AIRVOICE’s Lifeline
45 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 settled a Notice of Apparent Liability with the FCC (See File No. EB-IHD-13-00010671).
46 Compliance Plan Public Notice at 3.
47 See 47 C.F.R. § 54.202(a)(1).
20
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(f), 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 Internet access
service (“BIAS”), a supported service as of December 2, 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 II 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 911 and E911 where available, and will comply
with any Commission requirements regarding E911-compliant handsets. As discussed above, the
Company will comply with the Commission’s applicable forbearance grant conditions relating to
the provision of 911 and E911 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
21
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.
Respectfully 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: [e-mail]

Legal and Regulatory Counsel May 17, 2021
48 See 2012 Lifeline Reform Order ¶ 230.

EXHIBIT A ORGANIZATIONAL CHARTS

Pre-Transaction

Post Transaction

Wail Dickow 10%
Falah Bahri 15%
Jim Bahri
15% Kenny
Hannawa
30%
Nick Hannawa 15%
Kyle
Hannawa 15%
Hung Do
US Citizen
100%
LLC d/b/a SFone Wireless
Wireless, LLC Communications, LLC Technologies, LLC Holdings, LLC
Wireless, LLC

EXHIBIT 3

Coverage Area

zip primary_citystate county
83201 Pocatello ID Bannock County
83202 Pocatello ID Bannock County
83204 Pocatello ID Bannock County
83210 Aberdeen ID Bingham County
83211 American FallsID Power County
83212 Arbon ID Power County
83213 Arco ID Butte County
83214 Arimo ID Bannock County
83215 Atomic CityID Bingham County
83217 Bancroft ID Caribou County
83220 Bern ID Bear Lake County
83221 Blackfoot ID Bingham County
83226 Challis ID Custer County
83227 Clayton ID Custer County
83228 Clifton ID Franklin County
83229 Cobalt ID Lemhi County
83230 Conda ID Caribou County
83232 Dayton ID Franklin County
83234 Downey ID Bannock County
83235 Ellis ID Custer County
83236 Firth ID Bingham County
83237 Franklin ID Franklin County
83238 Geneva ID Bear Lake County
83241 Grace ID Caribou County
83243 Holbrook ID Oneida County
83244 Howe ID Butte County
83245 Inkom ID Bannock County
83246 Lava Hot SpringsID Bannock County
83250 MccammonID Bannock County
83251 Mackay ID Custer County
83252 Malad City ID Oneida County
83253 May ID Lemhi County
83254 MontpelierID Bear Lake County
83255 Moore ID Butte County
83262 Pingree ID Bingham County
83263 Preston ID Franklin County
83271 Rockland ID Power County
83272 Saint CharlesID Bear Lake County
83274 Shelley ID Bingham County
83276 Soda SpringsID Caribou County
83277 Springfield ID Bingham County
83278 Stanley ID Custer County
83283 Thatcher ID Franklin County
83285 Wayan ID Bonneville County
83286 Weston ID Franklin County
83287 Fish Haven ID Bear Lake County
83301 Twin Falls ID Twin Falls County
83302 Rogerson ID Twin Falls County
83311 Albion ID Cassia County
83313 Bellevue ID Blaine County
83314 Bliss ID Gooding County
83316 Buhl ID Twin Falls County
83318 Burley ID Cassia County
83320 Carey ID Blaine County
83321 Castleford ID Twin Falls County
83322 Corral ID Camas County
83323 Declo ID Cassia County
83324 Dietrich ID Lincoln County
83325 Eden ID Jerome County
83327 Fairfield ID Camas County
83328 Filer ID Twin Falls County
83330 Gooding ID Gooding County
83332 Hagerman ID Gooding County
83333 Hailey ID Blaine County
83334 Hansen ID Twin Falls County
83335 Hazelton ID Jerome County
83336 Heyburn ID Minidoka County
83337 Hill City ID Camas County
83338 Jerome ID Jerome County
83340 Ketchum ID Blaine County
83341 Kimberly ID Twin Falls County
83342 Malta ID Cassia County
83344 Murtaugh ID Twin Falls County
83346 Oakley ID Cassia County
83347 Paul ID Minidoka County
83348 Picabo ID Blaine County
83349 Richfield ID Lincoln County
83350 Rupert ID Minidoka County
83352 Shoshone ID Lincoln County
83355 Wendell ID Gooding County
83401 Idaho Falls ID Bonneville County
83402 Idaho Falls ID Bonneville County
83404 Idaho Falls ID Bonneville County
83406 Idaho Falls ID Bonneville County
83420 Ashton ID Fremont County
83422 Driggs ID Teton County
83423 Dubois ID Clark County
83424 Felt ID Teton County
83425 Hamer ID Jefferson County
83427 Iona ID Bonneville County
83428 Irwin ID Bonneville County
83429 Island Park ID Fremont County
83431 Lewisville ID Jefferson County
83434 Menan ID Jefferson County
83435 MonteviewID Jefferson County
83436 Newdale ID Fremont County
83440 Rexburg ID Madison County
83442 Rigby ID Jefferson County
83443 Ririe ID Jefferson County
83444 Roberts ID Jefferson County
83445 Saint AnthonyID Fremont County
83446 Spencer ID Clark County
83448 Sugar City ID Madison County
83449 Swan ValleyID Bonneville County
83450 Terreton ID Jefferson County
83451 Teton ID Fremont County
83452 Tetonia ID Teton County
83455 Victor ID Teton County
83462 Carmen ID Lemhi County
83463 GibbonsvilleID Lemhi County
83464 Leadore ID Lemhi County
83466 North Fork ID Lemhi County
83467 Salmon ID Lemhi County
83469 Shoup ID Lemhi County
83501 Lewiston ID Nez Perce County
83520 Ahsahka ID Clearwater County
83522 CottonwoodID Idaho County
83523 Craigmont ID Lewis County
83524 Culdesac ID Nez Perce County
83525 Elk City ID Idaho County
83526 Ferdinand ID Idaho County
83530 GrangevilleID Idaho County
83533 GreencreekID Idaho County
83535 Juliaetta ID Latah County
83536 Kamiah ID Idaho County
83537 Kendrick ID Latah County
83539 Kooskia ID Idaho County
83540 Lapwai ID Nez Perce County
83541 Lenore ID Clearwater County
83542 Lucile ID Idaho County
83543 Nezperce ID Lewis County
83544 Orofino ID Clearwater County
83545 Peck ID Nez Perce County
83546 Pierce ID Clearwater County
83547 Pollock ID Idaho County
83548 Reubens ID Lewis County
83549 Riggins ID Idaho County
83552 Stites ID Idaho County
83553 Weippe ID Clearwater County
83554 White Bird ID Idaho County
83555 WinchesterID Nez Perce County
83602 Banks ID Boise County
83604 Bruneau ID Owyhee County
83605 Caldwell ID Canyon County
83607 Caldwell ID Canyon County
83610 Cambridge ID Washington County
83611 Cascade ID Valley County
83612 Council ID Adams County
83615 Donnelly ID Valley County
83616 Eagle ID Ada County
83617 Emmett ID Gem County
83619 Fruitland ID Payette County
83622 Garden ValleyID Boise County
83623 Glenns FerryID Elmore County
83624 Grand ViewID Owyhee County
83626 Greenleaf ID Canyon County
83627 Hammett ID Elmore County
83628 Homedale ID Owyhee County
83629 Horseshoe BendID Boise County
83631 Idaho City ID Boise County
83632 Indian ValleyID Adams County
83633 King Hill ID Elmore County
83634 Kuna ID Ada County
83636 Letha ID Gem County
83637 Lowman ID Boise County
83638 Mccall ID Valley County
83639 Marsing ID Owyhee County
83641 Melba ID Canyon County
83642 Meridian ID Ada County
83643 Mesa ID Adams County
83644 Middleton ID Canyon County
83645 Midvale ID Washington County
83646 Meridian ID Ada County
83647 Mountain HomeID Elmore County
83648 Mountain Home AFBID Elmore County
83650 Murphy ID Owyhee County
83651 Nampa ID Canyon County
83654 New MeadowsID Adams County
83655 New PlymouthID Payette County
83657 Ola ID Gem County
83660 Parma ID Canyon County
83661 Payette ID Payette County
83666 Placerville ID Boise County
83669 Star ID Ada County
83670 Sweet ID Gem County
83672 Weiser ID Washington County
83676 Wilder ID Canyon County
83677 Yellow PineID Valley County
83686 Nampa ID Canyon County
83687 Nampa ID Canyon County
83702 Boise ID Ada County
83703 Boise ID Ada County
83704 Boise ID Ada County
83705 Boise ID Ada County
83706 Boise ID Ada County
83708 Boise ID Ada County
83709 Boise ID Ada County
83712 Boise ID Ada County
83713 Boise ID Ada County
83714 Garden CityID Ada County
83716 Boise ID Ada County
83801 Athol ID Kootenai County
83802 Avery ID Shoshone County
83803 Bayview ID Kootenai County
83804 Blanchard ID Bonner County
83805 Bonners FerryID Boundary County
83808 Calder ID Shoshone County
83809 CareywoodID Bonner County
83810 Cataldo ID Kootenai County
83811 Clark Fork ID Bonner County
83812 Clarkia ID Shoshone County
83813 Cocolalla ID Bonner County
83814 Coeur D AleneID Kootenai County
83815 Coeur D AleneID Kootenai County
83821 Coolin ID Bonner County
83822 Oldtown ID Bonner County
83823 Deary ID Latah County
83824 Desmet ID Benewah County
83830 Fernwood ID Benewah County
83832 Genesee ID Latah County
83833 Harrison ID Kootenai County
83834 Harvard ID Latah County
83835 Hayden ID Kootenai County
83836 Hope ID Bonner County
83837 Kellogg ID Shoshone County
83839 Kingston ID Shoshone County
83842 Medimont ID Kootenai County
83843 Moscow ID Latah County
83845 Moyie SpringsID Boundary County
83846 Mullan ID Shoshone County
83847 Naples ID Boundary County
83848 Nordman ID Bonner County
83850 Pinehurst ID Shoshone County
83851 Plummer ID Benewah County
83852 Ponderay ID Bonner County
83854 Post Falls ID Kootenai County
83855 Potlatch ID Latah County
83856 Priest RiverID Bonner County
83857 Princeton ID Latah County
83858 Rathdrum ID Kootenai County
83860 Sagle ID Bonner County
83861 Saint MariesID Benewah County
83864 Sandpoint ID Bonner County
83868 SmeltervilleID Shoshone County
83869 Spirit Lake ID Kootenai County
83870 Tensed ID Benewah County
83871 Troy ID Latah County
83872 Viola ID Latah County
83873 Wallace ID Shoshone County
83874 Murray ID Shoshone County
83876 Worley ID Kootenai County

EXHIBIT 4

Key Management Bios

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 a variety 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.

MVNO/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 2018
Employment Duration 20 yrs
Location Houston
Developing simple software solutions fit to client's needs. Providing turn 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 strategy, 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 – Jul 2015 Employment Duration 9 mos
Location Houston, Texas Area Luminess Air
Lead Internet Marketing Associate Dates Employed Jan 2011 – 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 1 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, returned or excess handset inventory. For regional carriers or MVNO’s, HTH
is the leading provider of high-quality refurbished 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 modify 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 4G/5G 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.
Hugo Vo

IT Professional with 3 years of experience, and a proven knowledge of hardware engineering,
configuration and troubleshooting. Proven ability to develop and implement IT solutions that
support business needs.

HTH Communications, LLC
IT & Development Manager May 2021 – Present
IT Support Jan 2019 – May 2021
Phone Technician / Helpdesk Jul 2018 – Jan 2019
Employment Duration 3 yrs 5 mos
Location Houston, Texas, U.S

Creative Bay
Web Developer May 2012 – Dec 2013
Employment Duration 1 yr 8 mos
Location Vietnam

UNIVERSITY OF GREENWICH
Degree Name Bachelor of Science (B.S.)

EXHIBIT 5

Proposed Lifeline Offering

Minutes & Data

1,000 anytime minutes per month
500 text messages per month
4.5 GB data per month
LTE or 5G Network
Net cost to Lifeline customer: $0

ADDITIONAL AIRTIME

Available for purchase at www.airtalkwireless.com

All packages include:

 Free SIM card or Handset
 Free calls to AirVoice Customer Service
 Free calls to 911 emergency services
 Free access to Voicemail, Caller-ID, and Call Waiting features
 Voice minutes may be used for Domestic Long Distance at no extra cost

EXHIBIT 6

Sample Advertisements
Apply Online at airtalkwireless.com
E-mail us at [e-mail]
Call us toll-free at [phone]
QUICK &EASY!
APPLYING IS
is now Government Assistance Program
LIFELINE & ACP
PROGRAM to RECEIVE a
FREE iPhone 7,
Samsung S9 &
UNLIMITED
Data, Talk & Text
Unlimited Data is provided by the Affordable Connectivity Program.See Terms & Conditions for additional information. The above devices are available while supplies last.If models are no longer available, a similar device will be offered.
&ACP&
M to RECEIV
one 7,
ng S9 &
TED
alk & Text
om
VE a
fo d
a
Tablets
For$10.01!
FREESamsung
S9FREE
iPhone

7
Keeping Our Communities Connected
Affordable Connectivity
Program
Congress recently created the
Affordable Connectivity
Program, a long-term, $14 billion
program, which will replace the
Emergency Broadband Benefit
Program. This investment in
broadband affordability will help
ensure we can afford the
internet connections we need for
work, school, health care, and
more for a long time.
You Can Qual˜˙y if You
Participate in One of the
Following Programs:
AirTalk Wireless is a program
provided by HTH Communications
serving eligible American
households. The company is an
FCC-licensed Eligibility
Telecommunication Carrier (ETC)
which offers Lifeline and the
Affordable Connectivity Program
(ACP) to eligible customers
across America.
About Us
Why Should You
Choose AirTalk ?
Offers the best FREE Phone
Offers the best FREE service
plan
Nationwide Coverage & 23+
years in business
Dedicated Customer Service
Our customers are happy
Applying is quick & easy
Fast & Free Shipping
SNAP/FOOD STAMPS
MEDICAID
SSI
VETERANS SURVIVORS PENSION
BENEFITS FUND
FEDERAL PUBLIC HOUSING
ASSISTANCE
or through income base
qualifications and MANY MORE!
Contact Us:
Monday - Friday : 8:00 a.m - 5:00 p.m CST & Saturday: 10:00 a.m - 7:00 p.m CST
Website: www.airtalkwireless.com Email: [e-mail] Phone: [phone]
Lance J.M. Steinhart, P.C.
Attorneys At Law
1725 Windward Concourse
Suite 150
Alpharetta, Georgia 30005

Also Admitted in New York Telephone: [phone]
Email: [e-mail] Facsimile: [phone]

April 22, 2022

VIA EMAIL TO [e-mail]

Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702

Re: Air Voice Wireless, LLC d/b/a AirTalk
Case No. AVW-T-22-01

Dear Ms. Noriyuki:

Air Voice Wireless, LLC d/b/a AirTalk Wireless (“Air Voice”) filed an Application for
Limited Designation as an Eligible Telecommunications Carrier (the “Application”) on March 23,
2022. Air Voice respectfully requests to supplement its Application with information in support of
its technical capabilities attached hereto as Exhibit 8.

If you have any questions, or if I may provide you with additional information, please do not
hesitate to contact me at 770-232-9200 or [e-mail]. Thank you.

Respectfully submitted,

Lance J.M. Steinhart, Esq.
Managing Attorney
Lance J.M. Steinhart, P.C.
Attorneys for Air Voice Wireless, LLC d/b/a AirTalk Wireless

Attachments
cc: Henry Do
Johan E. Kalala-Kasanda

EXHIBIT 8

Technical Capabilities

SOLUTIONS OVERVIEW
JANUARY 2021
TABLE OF CONTENTS
1.ABOUT HTH
2.COMPREHENSIVE SERVICE OFFERING
o HANDSET SALES
o MVNE SERVICES
o 4PL SOLUTIONS
o REPAIR & REFURBISHING
3.THE HTH TEAM
4.TIMELINE OF OUR GROWTH
5.QUALITY STANDARDS WE MAINTAIN
6.CUSTOMERS WE SERVE
7.BRANDS WE CARRY
8.COMPETITIVE ADVANTAGE
9.WORKING TOGETHER
10.HTH COMMUNICATIONS AFFILIATE COMPANIES
PROVIDING SUSTAINABLE SOLUTIONS FOR THE WIRELESS INDUSTRY
ABOUT HTH
For customers across the globe, HTH is delivering value into
their supply chain through programs that lower cost of
acquisition, reduce churn and increase returns on investment.
At HTH, we believe that sustainability is ensuring that our
customers achieve their business goals year after year. We
believe that sustainability means investing in our employees
and creating a culture of success. And, we believe that
sustainability means operating our business in accordance
with global quality standards designed to ensure the well-being
and prosperity of future generations.
Handset Sales
MVNE Services
4PL Services
WE MANAGE THE SECONDARY MARKETPLACE SO YOU DON’T HAVE TOCOMPREHENSIVE SERVICE OFFERING
Repair and Refurbishing
In the secondary marketplace, value is derived from high-
quality products, efficient services and expandable
infrastructure. HTH knows this and that’s why our
comprehensive service offering is used by over 50 MVNO’s,
4 National Carriers and numerous OEMs. Our service
platform enables success and delivers maximum returns to
our partners.
HANDSET SALES
BUY FROM US
Our customers demand full-features phones at second life prices.
Whether you’re looking for a smartphone or a basic feature phone,
we have a wide selection of devices to choose from in a variety of
conditions and grades. Each customer is assigned a dedicated
account manager who provides:
o Weekly inventory reports
o Promotional offers
o Same day order fulfillment
o Flexible financing offers
o Device warranty
o Logistics expertise
o Exceptional service
HANDSET SALES
SELL TO US
We understand that carriers, OEM’s and insurance providers all
carry millions of dollars in inventory and have financial targets
to meet. That’s why we participate in numerous disposition
programs to purchase returned, trade-in, buy-back and excess
inventory; always delivering returns to help your company
achieve its goals.
MVNE SERVICES
OPERATIONAL
TOOLS
WHITE LABEL
SOLUTIONS
RISK REWARD
MODELS CAP EX DEFERRALS
AIRTIME BUNDLES OPERATING
SYSTEM SUPPORT
DEVICE
MANAGEMENT
VIRTUAL
WAREHOUSING
4PL SERVICES
VIRTUAL
WAREHOUSING TRANSPORTATION DROP SHIPMENT TRACKING AND
REPORTING
FORWARD LOGISTICS REVERSE LOGISTICS
REPAIR & REFURBISHING
PARTS RECOVERY &
RECLAMATION
OEM NEW &
REFURBISHED PARTS
PROPRIETARY
TESTING EQUIPMENT
OEM CERTIFIED
FACILITY
Triage Disassembly Assembly Picture Packs Distribution
HTH PROCESS
OVERVIEW:
CULTURE OF SUCCESS
THE HTH TEAM
HTH was founded in July 2008 by Henry Do. Holding degrees in Economics and Finance, Henry began his career at a private equity firm serving the wireless
industry where he recognized the need for a repair company that was laser focused on quality and efficiency. Nothing affected the bottom line of companies
more than those two factors. With that, HTH was formed. Over the past twelve years, HTH has grown in size and scope and it has done so by creating a
culture of success for employees. Enabling employees to grow and excel within the company, ensuring employees do their jobs with integrity and attention to
detail, and rewarding employees when they achieve their goals are all part of the HTH culture.
Henry Do, CEO Leadership Warehouse and
Technical Staff Customer Service
WHEN OUR CUSTOMERS SUCCEED, WE SUCCEEDTIMELINE OF OUR GROWTH
20142008201020122009
HTH
Communications
founded and
operated in
1,500-SF facility
in Houston, TX
Moved into 10,000-SF
facility less than a
year later to
accommodate growth.
Selected as exclusive
distributor of Cricket’s
refurbished handsets
HTH becomes a
downstream vendor
to Sprint, US Cellular,
MetroPCS, AT&T and
T-Mobile
Moved into a 50,000-
SF facility to
accommodate
growing team and
expansion of services
HTH expanded
marketing efforts
and began attending
trade shows such as
CTIA, CCA and
participating in
Carrier Summits
2016
HTH receives R2, ISO
9001, ISO 14001 and
ISO OHSAS 45001
certifications
2019
HTH celebrates
over a decade in
business and
relocates to its
privately owned
125,000-SF
state-of-the-art
headquarters
QUALITY & EFFICIENCY
ARE THE CORE OF OUR SOLUTIONS
QUALITY STANDARDS WE MAINTAIN
ISO 45001
OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT SYSTEMS
ISO 9001
QUALITY MANAGEMENT
SYSTEMS
ISO 14001
ENVIRONMENTAL STANDARDS SYSTEMS
R2
RESPONSIBLE ELECTRONICS RECYCLING
Choice Wireless
Amazon
eBay
Retailers & Etailers
Carolina West
Affinity Cellular
ClearTalk Wireless
Rural & Small Carriers
Assurant
Asurion
Immerge Wireless
Enterprise Providers
Samsung
Alcatel
LG
Quality One
Manufacturers &
Wholesalers
Sprint
T-Mobile
Verizon
AT&T
Metro PCS
US Cellular
Nationwide Carriers
TracPhone
Ready Wireless
Red Pocket Mobile
Assist Wireless
Credo
Easy Wireless
Safety Net Wireless
MVNO’s & Lifeline
CUSTOMERS WE SERVE
BRANDS CONSUMERS DEMAND
ARE THE BRANDS WE CARRY
ALL GRADESGrade AGrade BGrade CGrade D
Grade BER
ALL TYPESSmartphonesFeature PhonesTabletsWiFiModems
Smart Accessories
ALL BRANDSAppleSamsungLGMotorola
Kyocera
ALL CONDITIONSNewUsedCertified Pre-OwnedRefurbished
Functionally Tested
OUR STRENGTH IS IN THE NUMBERS
COMPETITIVE ADVANTAGE
Numbers can tell a powerful story.
The success of our business and commitment to
customers are best illustrated in these numbers.
125,000-square-foot
state-of-the-art
facility
200+ SKU’s in
Inventory
1.5M Annual Unit
Volume
15 In-house
Software Engineers
Financially Strong 12+ Years of
Positive Growth
Direct Access to
Carriers
200 Full-time
Employees
LET’S DEVELOP A
SOLUTION FOR YOU!
WORKING TOGETHER
ONE SOURCE SOLUTION
We simplify supply chain for our customers by offering a full scope of solutions. One vendor. One location.
One point of contact. Easy.
EXPERIENCE, SCALE, FLEXIBILITYWe have the team, the financial strength and the operations to put
together a program designed specifically for you!
COMMITMENT TO EXCELLENCEQuality and Efficiency are the core
values in running our business.Our customers deserve nothing less.
ONE SOURCE
SOLUTION
HTH COMMUNICATIONS AFFILIATE COMPANIES
Working with us is easy. We can provide you with a single service or
put together a comprehensive offering.
o Owned by Henry Hung Do
o Headquarters office is located at 9920 Brooklet Drive, Houston, TX 77099
o A distributor for wireless resellers
o Operating on the Sprint & T-Mobile Network
o B2C Products & Services
�-SOFTEL
./�) TECHNOLOGIES
WHAT WE OFFER
Lance J.M. Steinhart, P.C. Attorneys At Law 1725 Windward Concourse Suite 150 Alpharetta, Georgia 30005 Also Admitted in New York Telephone: [phone] Email: [e-mail] Facsimile: [phone] June 24, 2022 Certified USPS Mail Office of Legal Counsel Coeur d’ Alene Tribe 850 A Street Plummer, ID 83851 Re: AirVoice Wireless, LLC d/b/a AirTalk Application for Limited Designation as an Eligible Telecommunications Carrier Dear Sir, Madam, Please find enclosed a copy of AirVoice Wireless, LLC d/b/a AirTalk 's Application and amended application for Limited Designation as an Eligible Telecommunications Carrier in the State of Idaho. These were filed with the Commission March 23, 2022 and April 22, 2022. If you have any questions, or if I may provide you with additional information, please do not hesitate to contact me. Thank you. Respectfully submitted, Lance J.M. Steinhart, Esq. Managing Attorney Lance J.M. Steinhart, P.C.
Attorneys for AirVoice Wireless, LLC
d/b/a AirTalk Wireless Enclosures cc: Henry Do
Lance J.M. Steinhart, P.C.
Attorneys At Law
1725 Windward Concourse
Suite 150
Alpharetta, Georgia 30005

Also Admitted in New York Telephone: [phone]
Email: [e-mail] Facsimile: [phone]

March 22, 2022

VIA EMAIL DELIVERY TO
[e-mail]

Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702

Re: AirVoice Wireless, LLC d/b/a AirTalk
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 Carrier 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.

Respectfully submitted,

Lance J.M. Steinhart, Esq.
Managing Attorney
Lance J.M. Steinhart, P.C.
Attorneys for AirVoice Wireless, LLC
d/b/a AirTalk Wireless

Enclosures
cc: Henry Do

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION

AirVoice Wireless, LLC
d/b/a AirTalk Wireless
Application for Designation as an Eligible
Telecommunications Carrier
_____________________________________
) ) ))))
Case No. ____

APPLICATION

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: [e-mail]

Attorneys for AirVoice Wireless, LLC
d/b/a AirTalk Wireless

March 22, 2022
2

TABLE OF CONTENTS
I. INTRODUCTION ...............................................................................................................4
II. COMPANY OVERVIEW ...................................................................................................6
III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF
WIRELESS ETCS ...............................................................................................................5
IV. AIRVOICE SATISFIES THE REQUIREMENTS FOR DESIGNATION AS
AN ETC UNDER 47 C.F.R. § 54.201 .................................................................................8
V. AIRVOICE SATISFIES THE ADDITIONAL REQUIREMENTS FOR ETC
DESIGNATION UNDER 47 C.F.R. § 54.202(a) ..............................................................16
VI. DESIGNATION OF AIRVOICE AS AN ETC WOULD PROMOTE THE
PUBLIC INTEREST .........................................................................................................23
VII. CONCLUSION ..................................................................................................................27

3

TABLE OF EXHIBITS

Exhibit

Certification ...............................................................................................................1

FCC-Approved Compliance Plan ...............................................................................2

Coverage Area ...........................................................................................................3

Key Management Bios ...............................................................................................4

Proposed Lifeline Offering ........................................................................................5

Sample Advertisement ...............................................................................................6

4

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION

AirVoice Wireless, LLC
AirTalk Wireless
Application for Designation as an Eligible
Telecommunications Carrier
_____________________________________
)))))
Case No. ____

I. INTRODUCTION
AirVoice Wireless, LLC d/b/a AirTalk Wireless (“AirVoice” or the “Company”), by its
undersigned counsel, and pursuant to Section 214(e)(2) of the Communications Act of 1934, as
amended (the “Act”),1 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 qualifying Idaho
consumers; it will not (and is not eligible to) seek access to funds from the federal Universal
Service Fund (“USF”) for the purpose of participating in the Link-Up program or providing service
to high-cost areas.3 AirVoice requests that its designation as an ETC include the authority to

1 47 U.S.C. § 214(e)(2)
2 47 C.F.R. §§ 54.101-54.207.
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.

5

participate in and receive reimbursement from the Idaho Telephone Service Assistance Program
(ITSAP).
As demonstrated herein, and as certified in Exhibit 1 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
Modernization Order,5 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/b/a AirTalk Wireless
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005

4 In the Matter 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. 11-42,
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 12-11 (rel. Feb. 6, 2012) (“Lifeline and Link Up Reform Order”).
5 In the Matter of Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for
Universal Service 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,
2016) (hereinafter, “Third Report and Order” or “Lifeline Modernization Order”).
6 In the Matter of Bridging the Digital Divide for Low-Income Consumers, Lifeline and Link Up Reform and
Modernization, Telecommunications Carriers Eligible for Universal Service Support, WC Docket No. 17-287, WC
Docket No. 11-42, WC Docket No. 09-197, Fifth Report and Order, Memorandum Opinion and Order and Order on
Reconsideration, and Further Notice of Proposed Rulemaking, FCC 19-111 (rel. Nov. 14, 2019) (hereinafter, “Fifth
Report and Order”).
6

[phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
II. COMPANY OVERVIEW
AirVoice is a Michigan limited liability company,7 with its principal office located at 9920
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 (“MVNO”).
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 of the 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 d/b/a SFone
Wireless, a Delaware limited liability company (“Cintex”), that provides Lifeline-only wireless
services as an ETC in Arkansas, Maryland, Maine, Rhode Island, 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.
7

(“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, 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; (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 of the 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, California, Colorado, Iowa,
Kentucky, Louisiana, Maine, Maryland, Michigan, Minnesota, Missouri, Nevada, Oklahoma,
Pennsylvania, South Carolina, Texas, West Virginia and Wisconsin.9
Under current ownership, neither AirVoice nor its affiliates have been subject to
enforcement sanctions related to the Low-Income Fund or ETC revocation proceedings in any
state except as noted below.10

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.
9 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.
10 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 settled a
Notice of Apparent Liability with the FCC (See File No. EB-IHD-13-00010671), which all occurred under prior
ownership and management. By Order adopted December 16, 2021 (See File No. EB-IHD-20-00031449), NewPhone
entered into a Consent Decree with the Enforcement Bureau of the FCC for the purpose of terminating the Bureau’s
investigation on whether NewPhone, 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
8

AirVoice will provide affordable prepaid mobile phone service and high-quality customer
service. AirVoice’s service offering will include: (1) 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 of the 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.
9

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.
III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF WIRELESS
ETCS
Section 214(e)(2) of the Act provides state public utility commissions with the “primary
responsibility” for the designation of ETCs.11 Although Section 332(c)(3)(A) 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 214(e)(1).
AirVoice recognizes that Section 214(e)(1)(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 of this facilities requirement to carriers seeking
Lifeline-only ETC designation.13 Section 10(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

11 47 U.S.C. § 214(e)(2).
12 USF Order, at 8858–59, ¶ 145.
13 See Lifeline and Link Up Reform Order at ¶ 368.
10

[Federal Communications] Commission has determined to forbear from applying under subsection
(a) of this section.” As such, the Commission is required by Section 10(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 214(e)(2) of the Act to
grant AirVoice’s request for designation as an ETC throughout the State of Idaho.

IV. AIRVOICE SATISFIES THE REQUIREMENTS FOR DESIGNATION AS AN
ETC UNDER 47 C.F.R. § 54.201
Section 254(e) of the Act provides that, “only an eligible telecommunications carrier
designated under section 214(e) shall be eligible to receive specific federal universal service
support.” Section 214(e)(2) 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.14 Section 214(e)(1) 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 of the 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.15 As detailed below, AirVoice
satisfies each of the above-listed requirements.

14 See Federal-State Joint Board on Universal Service, First Report and Order, 12 FCC Rcd 8776, 8858-59, ¶ 145
(1997) (“USF Order”).
15 See 47 U.S.C. § 214(e)(1) and 47 C.F.R. § 54.201(d)(2).
11

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 214(e)(1)(A) for carriers that are, or seek to become, Lifeline-only
ETCs, subject to the following conditions:16
(1) the carrier must comply with certain 911 requirements [(a) providing its Lifeline
subscribers with 911 and E911 access, regardless of activation status and availability of
minutes; (b) providing its Lifeline subscribers with E911-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 Order]; 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, 2012.17 The FCC approved
AirVoice’s Revised Compliance Plan on December 23, 202118 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

16 See Lifeline and Link Up Reform Order at ¶¶ 368, 373, and 379.
17 See FCC Public Notice DA 12-2063, https://www.fcc.gov/document/wcb-approves-nine-lifeline-compliance-
plans.
18 See Public Notice DA 21-1641, https://www.fcc.gov/document/wcb-approves-revised-compliance-plan-airvoice-
wireless-llc.
12

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.19
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. § 54.101(a)) as follows:
1. Voice Telephony Service
As set forth in 47 C.F.R. § 54.101(a)(1), eligible Voice Telephony Services must provide
the following:
Voice Grade Access to the Public Switched Telephone Network. AirVoice provides
voice grade access to the public switched telephone network (“PSTN”) through the purchase of
wholesale CMRS services from its Underlying Carriers.
Local Usage 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 911 and E911 access for all of its
customers to the extent the local government in its service area has implemented 911 or E911
systems. As noted, calls to 911 emergency services will always be free and will be available
regardless of service activation status or availability of minutes. AirVoice also complies with the

19 Implementation of Sections 3(n) and 332 of the Communications Act, Regulatory Treatment of Mobile Services, GN
Docket No. 93-252, Second Report and Order, 9 FCC Rcd 1411, 1425 ¶ 37, 1454-55 ¶ 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)(1)(A) (“mobile services” providers are common carriers); see also PCIA
Petition for Forbearance for Broadband PCS, WT Docket No. 98-100, (Memorandum Opinion and Order and Notice
of Proposed Rulemaking, 13 FCC Rcd 16857, 16911 ¶ 111 (1998) ("We concluded [in the Second Report and Order]
that CMRS also includes the following common carrier services: cellular service, … all mobile telephone services and
resellers of such services.") (emphasis added).
13

FCC’s regulations governing the deployment and availability of E911 compatible handsets.
Toll Limitation. In its Lifeline and Link Up Reform Order, the FCC provided that toll
limitation would no longer be deemed a supported service.20 “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.”21 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. AirVoice’s 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 Internet 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 defined 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 Up Reform Order at ¶ 367.
21 See id. at ¶ 49.
22 See 47 C.F.R. § 8.2(a).
14

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 justify 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, 214(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 13-44 released April
15, 2013) authorized forbearance from the service area conformance requirements with respect to
carriers seeking to provide Lifeline-only service.24 In light of this forbearance, the Commission
has the authority to designate ETCs such as AirVoice in rural areas without concern for the service
area conformance requirement.25

23 See Western Wireless Corporation Petition for Designation as an Eligible Telecommunications Carrier in the State
of Wyoming, Memorandum Opinion and Order, 16 FCC Rcd 48, 55 (2000).
24 See In the Matter of Telecommunications Carriers Eligible for Support, Lifeline and Link Up Reform, WC Docket
No. 09-197, WC Docket No. 11-42, Memorandum Opinion and Order, FCC 13-44 (rel. April 15, 2013).
25 See 47 C.F.R. § 54.207(c).
15

E. AirVoice Will Advertise the Availability of Supported Services
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 qualify 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
16

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. § 54.202(a).
A. Service Commitment Throughout the Proposed Designated Service Area
AirVoice will provide service in Idaho 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)(1)(i), and by the certification attached in Exhibit 1,
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(a)(1)(ii), 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.

17

B. Ability to Remain Functional in Emergency Situations
In accordance with 47 C.F.R. § 54.202(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 1 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 satisfy applicable consumer protection and service quality standards, and wireless applicants
may satisfy 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. § 54.202(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 Universal 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 Aug. 16, 2012).
18

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. In 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.27 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. § 54.101(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 attached Exhibit 4 for key management bios.
19

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.28 Lifeline customers that also
elect to receive ACP benefits from AirVoice will receive unlimited talk and text with 15 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 (611). Emergency (911) 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 qualifying
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 concerned 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 federally recognized tribal lands includes
unlimited talk, unlimited text, and unlimited data.
20

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).29 AirVoice will certify and verify initial and continued
consumer eligibility in accordance with 47 C.F.R. § 54.410 and will notify 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 qualifying 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

29 FCC Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program, WC Docket
No. 11-42, Public Notice, “Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline
Program,” DA 18-161 (rel. Feb. 20, 2018). The standard application/certification forms are available on USAC’s
website (See USAC, Lifeline Forms, http://www.usac.org/li/tools/forms/default.aspx).
21

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” restriction 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. § 54.407(c)(2). An account will be considered active if the
authorized subscriber establishes usage, as “usage” is defined by 47 C.F.R. § 54.407(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. § 54.405(e)(3), currently a period of fifteen (15) days. In accordance with 47 C.F.R.
§ 54.405(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: (1) Duplicate Same-Month Lifeline Subsidies
(Double Dip): any name/address that is already receiving a lifeline subsidy from the Company will
22

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 internal 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 ITSAP 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.1 (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.

23

VI. DESIGNATION OF AIRVOICE AS AN 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.30 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 consumers—particularly 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.”31 Given this context, designating AirVoice as an ETC would
significantly benefit low-income consumers eligible for Lifeline services in Idaho—the intended
beneficiaries of universal service.

30 Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56.
31 See Lifeline Modernization Order ¶ 2.
24

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 911 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
25

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 Idaho

32 See, e.g., Specialized Common Carrier Services, 29 FCC Rcd 870 (1971).
33 See 47 U.S.C. § 254(b)(1).
26

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 in the Lifeline and Link Up 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 qualified 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.

27

VII. CONCLUSION
Based on the foregoing, designation of AirVoice as an ETC in the State of Idaho complies
with the requirements of Section 214(e)(2) 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.
Respectfully 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: [e-mail]

Attorneys for AirVoice Wireless, LLC
d/b/a AirTalk Wireless

March 22, 2022

EXHIBIT 2

FCC-Approved Compliance Plan
Lance J.M. Steinhart, P.C. Attorneys At Law 1725 Windward Concourse Suite 150 Alpharetta, Georgia 30005

Also Admitted in New York Telephone: [phone]
Email: [e-mail] Facsimile: [phone] May 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 Docket Nos. 09-197
and 11-42
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.1 The Wireline Competition Bureau (Bureau)
approved AirVoice’s Compliance Plan on December 26, 2012.2

1 See 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 Nos. 11-42 and 03-109, CC Docket No. 96-45, and WC Docket No. 12-23,
Report and Order and Further Notice Of Proposed Rulemaking, FCC 12-11 (reI. Feb. 6, 2012).
2 Wireline Competition Bureau Approves the Compliance Plans of 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 11-42, Public Notice, DA 12-2063 (rel. December 26, 2012).

Marlene H. Dortch May 17, 2021 Page 2

AirVoice now seeks expedited approval of the enclosed Revised Compliance Plan,
which has been revised to: (1) 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 Interest Purchase Agreement dated May 17,
2021, 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 (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.
Respectfully submitted, s/ Lance Steinhart
Lance J.M. Steinhart, Esq.
Managing Attorney Lance J.M. Steinhart, P.C. Attorneys for AirVoice Wireless, LLC

Enclosures
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

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 Docket No. 11-42

AIRVOICE WIRELESS, LLC REVISED COMPLIANCE PLAN
AirVoice Wireless, LLC (“AIRVOICE” or the “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”) 2012 Lifeline
Reform Order, 2015 Lifeline Second Report and Order,2 and Third Report and Order.3
1 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 Up, Federal-State Joint Board on Universal Service, Advancing Broadband Availability Through Digital Literacy Training, WC Docket No. 11-42, 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 12-11 (Feb. 6, 2012) (“2012 Lifeline Reform Order”). See Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service Support, Connect America Fund, WC Docket Nos. 11-42, 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, ¶ 249 (rel. June 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 Docket Nos. 09-197, 11-42, Public Notice, DA 12-314 (rel. Feb. 29, 2012) (Compliance Plan Public Notice).
3 See In the Matter of Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service Support, Connect America Fund, WC Docket No. 11-42,
2
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 911 requirements as described below and qualifies for blanket
forbearance from the facilities requirement of section 214(e)(1)(A) of the Communications Act to
participate as an ETC in the Lifeline program.5
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. 10-90, Third Report and Order, Further Report and Order, and Order on Reconsideration, FCC 16-38 (rel. Apr. 27, 2016) (“Third Report and Order”).
4 Wireline Competition Bureau Approves the Compliance Plans of 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 11-42, Public Notice, DA 12-2063 (rel. December 26, 2012).
5 See 2012 Lifeline Reform Order ¶ 368. Although AIRVOICE qualifies for and seeks to avail itself of the Commission’s grant of forbearance from the facilities requirement of section 214(e)(1)(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.
3
generally.6 This Revised Compliance Plan describes the specific measures that the Company has
implemented to achieve these objectives. Specifically, this Revised Compliance Plan: (1)
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.
ACCESS TO 911 AND E911 SERVICES7
Pursuant to the 2012 Lifeline Reform Order, forbearance is conditioned upon the
Company: (1) providing its Lifeline subscribers with 911 and E911 access, regardless of activation
status and availability of minutes; and (2) providing its wireless Lifeline subscribers with E911-
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 911 and E911 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 911 and E911 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 2012 Lifeline Reform Order ¶ 373.
4
AIRVOICE’s existing practices currently provide access to 911 and E911 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 911
calls from the Company’s customers in the same manner as 911 calls from their own retail
customers. To the extent that AIRVOICE’s Underlying Carriers are certified in a given PSAP
territory, this 911 capability will function the same for the Company. AIRVOICE also currently
enables 911 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.
E911-Compliant Handsets. AIRVOICE’s handsets used in connection with the wireless
Lifeline service offering have always been and will continue to be 911 and E911-compliant. The
Company’s phones have passed a stringent certification process, which ensures that the handset
models used meet all 911 and E911 requirements. As a result, any existing wireless customer that
qualifies for and elects Lifeline service will already have a 911/E911-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
AIRVOICE’s Lifeline voice telephony service is assured of receiving a 911/E911-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.9
The Commission further requires such providers to offer the choice to Lifeline customers of devices
9 See Third Report and Order at ¶ 366.
5
that are equipped with hotspot functionality.10 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(f).

COMPLIANCE PLAN
I. PROCEDURES TO ENROLL A SUBSCRIBER IN LIFELINE11
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: (1) household income at or below one hundred-thirty five percent (135%)
of the Federal Poverty 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.
10 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).
11 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. 11-42, Public Notice, DA 19-1290 (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.
6
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.14 Customers that enroll electronically will use the National
13 See infra Section I.F. regarding use of the NLAD.
14 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 Reconsideration ¶ 224.
7
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 identify 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.15
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 ‘[l]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
15 See Petition of TracFone Wireless, Inc. for Forbearance from 47 U.S.C. § 214(e)(1)(A) and 47 C.F.R. § 54.201(i), CC Docket No. 96-45, Order, FCC 05-165, ¶ 19 (2005).
16 2012 Lifeline Reform Order ¶ 110.
8
Lifeline program’s enrollment, recertification, and reimbursement processes including
involvement of representatives.17
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 certify and verify the customer’s Lifeline eligibility.
All Representatives are instructed that the company has zero tolerance for waste, fraud or
abuse, and that they should notify 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 internal compliance
personnel.
De-Enrollment for Ineligibility. 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

17 In the Matter of Bridging the Digital Divide for Low-Income Consumers, Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service Support, WC Docket No. 17-287, WC Docket No. 11-42, WC Docket No. 09-197, Fifth Report and Order, Memorandum Opinion and Order and Order on Reconsideration, and Further Notice of Proposed
Rulemaking, FCC 19-111 (rel. Nov. 14, 2019) (“Fifth Report and Order”).
9
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(f), 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.19 Live customer service and bilingual operators
can currently be reached for Lifeline service support from 10 AM to 10 PM Eastern, Monday
through Saturday, with 24/7 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. § 54.410(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 qualifying programs as well as a breakdown of
18 See 2012 Lifeline Reform Order ¶ 143; 47 C.F.R. § 54.405(e)(1).
19 See 47 C.F.R. § 54.405(e)(5).
20 See FCC Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline Program, WC Docket No. 11-42, Public Notice, DA 18-161 (rel. Feb. 20, 2018). The standard application/certification forms are available on USAC’s website (See USAC, Lifeline Forms, https://www.usac.org/lifeline/additional-requirements/forms/). See Compliance Plan Public Notice at 3.
10
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.21
Disclosures. The Universal Forms include the following disclosures, which the Company
also includes on its website or electronic application platform: (1) 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(d)(2)-(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-certify 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
21 See 2012 Lifeline Reform Order ¶ 123.
22 See id. ¶ 121; 47 C.F.R. § 54.410(d)(1).
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 transmitted 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(b)(9).
11
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-certify 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.25
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.
§ 54.407(c)(2). An account will be considered active if the authorized subscriber establishes
usage, as “usage” is defined by 47 C.F.R. § 54.407(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 2012 Lifeline Reform Order. This type of educational recertification message is consistent with the 2012 Lifeline 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.” 2012 Lifeline Reform Order ¶ 145.
25 See 2012 Lifeline Reform Order ¶ 257; 47 C.F.R. § 54.407(c)(1).
12
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. In accordance with 47 C.F.R. § 54.405(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. AIRVOICE will update the NLAD within one (1) 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 enrollment27 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.28
26 See 2012 Lifeline 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. In those states, AIRVOICE will follow the duplicates detection process required by the state.
28 See 2012 Lifeline Reform Order ¶ 203. The Company transmits to the NLAD the information required for each new Lifeline subscriber. See id., ¶¶ 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.
13
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 training 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 household29
through the use of Universal Forms discussed above, National Verifier and NLAD database
checks, 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 certifying compliance with
29 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 ¶ 74; section 54.400(h).
30 See 2012 Lifeline Reform Order ¶ 78.
14
the one-per-household rule in accordance with 47 C.F.R. § 54.410(g).31
If 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: (1) 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.34 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
31 The Household Worksheet is available at https://www.usac.org/lifeline/additional-requirements/forms/.
32 See 2012 Lifeline Reform Order ¶ 275; 47 C.F.R. § 54.405(c).
33 See 2012 Lifeline Reform Order ¶ 275; 47 C.F.R. § 54.405(c).
34 See 2012 Lifeline Reform Order ¶ 275; 47 C.F.R. § 54.405(c).
15
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.35 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 1st 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
certifying, under penalty of perjury, that the Company: (1) has policies and procedures in place to
ensure that its Lifeline subscribers 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. §54.408.39 The Company
provides the results of its re-certification efforts, performed pursuant to section 54.410(f) of the
Commission’s rules, as amended, annually by January 31st, for its re-certification efforts of the
previous year.40
35 See 2012 Lifeline Reform Order ¶ 128; 47 C.F.R. § 54.407(d).
36 See 47 C.F.R. § 54.407(a).
37 See id. at § 54.407(e).
38 See id. at § 54.422.
39 See id. at § 54.416(a).
40 See id. at § 54.416(b).
16
II. Description of Lifeline Service Offerings41
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 VOICE TEXT DATA LIFELINE
PRICE
1000 Voice/500 Text/ 4.5 GB Data 1000 500 (SMS) 4.5 GB $0.00

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 911 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/).
III. Demonstration of Financial and Technical Capabilities and Certifications Required for ETC Designation42
Financial and Technical Capabilities. Section 54.202(a)(4)43 requires carriers petitioning
for ETC designation to demonstrate financial and technical capability to comply with the
41 See Compliance Plan Public Notice at 3.
42 See Compliance Plan Public Notice at 3.
17
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 Interest Purchase Agreement dated May 17, 2021,
2021, 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 (100%) 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 d/b/a SFone Wireless, a Delaware limited liability company (“Cintex”), that
provides non-Lifeline wireless services throughout the United States, and provides Lifeline-only
43 See 47 C.F.R. § 54.202(a)(4).
44 See 2012 Lifeline Reform Order ¶¶ 387-388 (revising Commission rule 54.202(a)(4)).
18
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
19
have been subject to enforcement sanctions related to the Low Income Fund or ETC revocation
proceedings in any state.45 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 Company’s Support. The Compliance Plan Public
Notice requires carriers to include “certifications required under newly amended section 54.202 of
the Commission’s rules.”46 AIRVOICE certifies that it will comply with the service requirements
applicable to the support the Company receives.47 AIRVOICE’s Lifeline supported voice services
will meet the minimum service standards set forth in 47 C.F.R. § 54.408. AIRVOICE’s Lifeline
45 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 settled a Notice of Apparent Liability with the FCC (See File No. EB-IHD-13-00010671).
46 Compliance Plan Public Notice at 3.
47 See 47 C.F.R. § 54.202(a)(1).
20
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(f), 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 Internet access
service (“BIAS”), a supported service as of December 2, 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 II 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 911 and E911 where available, and will comply
with any Commission requirements regarding E911-compliant handsets. As discussed above, the
Company will comply with the Commission’s applicable forbearance grant conditions relating to
the provision of 911 and E911 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
21
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.
Respectfully 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: [e-mail]

Legal and Regulatory Counsel May 17, 2021
48 See 2012 Lifeline Reform Order ¶ 230.

EXHIBIT A ORGANIZATIONAL CHARTS

Pre-Transaction

Post Transaction

Wail Dickow 10%
Falah Bahri 15%
Jim Bahri
15% Kenny
Hannawa
30%
Nick Hannawa 15%
Kyle
Hannawa 15%
Hung Do
US Citizen
100%
LLC d/b/a SFone Wireless
Wireless, LLC Communications, LLC Technologies, LLC Holdings, LLC
Wireless, LLC

EXHIBIT 3

Coverage Area

zip primary_citystate county
83201 Pocatello ID Bannock County
83202 Pocatello ID Bannock County
83204 Pocatello ID Bannock County
83210 Aberdeen ID Bingham County
83211 American FallsID Power County
83212 Arbon ID Power County
83213 Arco ID Butte County
83214 Arimo ID Bannock County
83215 Atomic CityID Bingham County
83217 Bancroft ID Caribou County
83220 Bern ID Bear Lake County
83221 Blackfoot ID Bingham County
83226 Challis ID Custer County
83227 Clayton ID Custer County
83228 Clifton ID Franklin County
83229 Cobalt ID Lemhi County
83230 Conda ID Caribou County
83232 Dayton ID Franklin County
83234 Downey ID Bannock County
83235 Ellis ID Custer County
83236 Firth ID Bingham County
83237 Franklin ID Franklin County
83238 Geneva ID Bear Lake County
83241 Grace ID Caribou County
83243 Holbrook ID Oneida County
83244 Howe ID Butte County
83245 Inkom ID Bannock County
83246 Lava Hot SpringsID Bannock County
83250 MccammonID Bannock County
83251 Mackay ID Custer County
83252 Malad City ID Oneida County
83253 May ID Lemhi County
83254 MontpelierID Bear Lake County
83255 Moore ID Butte County
83262 Pingree ID Bingham County
83263 Preston ID Franklin County
83271 Rockland ID Power County
83272 Saint CharlesID Bear Lake County
83274 Shelley ID Bingham County
83276 Soda SpringsID Caribou County
83277 Springfield ID Bingham County
83278 Stanley ID Custer County
83283 Thatcher ID Franklin County
83285 Wayan ID Bonneville County
83286 Weston ID Franklin County
83287 Fish Haven ID Bear Lake County
83301 Twin Falls ID Twin Falls County
83302 Rogerson ID Twin Falls County
83311 Albion ID Cassia County
83313 Bellevue ID Blaine County
83314 Bliss ID Gooding County
83316 Buhl ID Twin Falls County
83318 Burley ID Cassia County
83320 Carey ID Blaine County
83321 Castleford ID Twin Falls County
83322 Corral ID Camas County
83323 Declo ID Cassia County
83324 Dietrich ID Lincoln County
83325 Eden ID Jerome County
83327 Fairfield ID Camas County
83328 Filer ID Twin Falls County
83330 Gooding ID Gooding County
83332 Hagerman ID Gooding County
83333 Hailey ID Blaine County
83334 Hansen ID Twin Falls County
83335 Hazelton ID Jerome County
83336 Heyburn ID Minidoka County
83337 Hill City ID Camas County
83338 Jerome ID Jerome County
83340 Ketchum ID Blaine County
83341 Kimberly ID Twin Falls County
83342 Malta ID Cassia County
83344 Murtaugh ID Twin Falls County
83346 Oakley ID Cassia County
83347 Paul ID Minidoka County
83348 Picabo ID Blaine County
83349 Richfield ID Lincoln County
83350 Rupert ID Minidoka County
83352 Shoshone ID Lincoln County
83355 Wendell ID Gooding County
83401 Idaho Falls ID Bonneville County
83402 Idaho Falls ID Bonneville County
83404 Idaho Falls ID Bonneville County
83406 Idaho Falls ID Bonneville County
83420 Ashton ID Fremont County
83422 Driggs ID Teton County
83423 Dubois ID Clark County
83424 Felt ID Teton County
83425 Hamer ID Jefferson County
83427 Iona ID Bonneville County
83428 Irwin ID Bonneville County
83429 Island Park ID Fremont County
83431 Lewisville ID Jefferson County
83434 Menan ID Jefferson County
83435 MonteviewID Jefferson County
83436 Newdale ID Fremont County
83440 Rexburg ID Madison County
83442 Rigby ID Jefferson County
83443 Ririe ID Jefferson County
83444 Roberts ID Jefferson County
83445 Saint AnthonyID Fremont County
83446 Spencer ID Clark County
83448 Sugar City ID Madison County
83449 Swan ValleyID Bonneville County
83450 Terreton ID Jefferson County
83451 Teton ID Fremont County
83452 Tetonia ID Teton County
83455 Victor ID Teton County
83462 Carmen ID Lemhi County
83463 GibbonsvilleID Lemhi County
83464 Leadore ID Lemhi County
83466 North Fork ID Lemhi County
83467 Salmon ID Lemhi County
83469 Shoup ID Lemhi County
83501 Lewiston ID Nez Perce County
83520 Ahsahka ID Clearwater County
83522 CottonwoodID Idaho County
83523 Craigmont ID Lewis County
83524 Culdesac ID Nez Perce County
83525 Elk City ID Idaho County
83526 Ferdinand ID Idaho County
83530 GrangevilleID Idaho County
83533 GreencreekID Idaho County
83535 Juliaetta ID Latah County
83536 Kamiah ID Idaho County
83537 Kendrick ID Latah County
83539 Kooskia ID Idaho County
83540 Lapwai ID Nez Perce County
83541 Lenore ID Clearwater County
83542 Lucile ID Idaho County
83543 Nezperce ID Lewis County
83544 Orofino ID Clearwater County
83545 Peck ID Nez Perce County
83546 Pierce ID Clearwater County
83547 Pollock ID Idaho County
83548 Reubens ID Lewis County
83549 Riggins ID Idaho County
83552 Stites ID Idaho County
83553 Weippe ID Clearwater County
83554 White Bird ID Idaho County
83555 WinchesterID Nez Perce County
83602 Banks ID Boise County
83604 Bruneau ID Owyhee County
83605 Caldwell ID Canyon County
83607 Caldwell ID Canyon County
83610 Cambridge ID Washington County
83611 Cascade ID Valley County
83612 Council ID Adams County
83615 Donnelly ID Valley County
83616 Eagle ID Ada County
83617 Emmett ID Gem County
83619 Fruitland ID Payette County
83622 Garden ValleyID Boise County
83623 Glenns FerryID Elmore County
83624 Grand ViewID Owyhee County
83626 Greenleaf ID Canyon County
83627 Hammett ID Elmore County
83628 Homedale ID Owyhee County
83629 Horseshoe BendID Boise County
83631 Idaho City ID Boise County
83632 Indian ValleyID Adams County
83633 King Hill ID Elmore County
83634 Kuna ID Ada County
83636 Letha ID Gem County
83637 Lowman ID Boise County
83638 Mccall ID Valley County
83639 Marsing ID Owyhee County
83641 Melba ID Canyon County
83642 Meridian ID Ada County
83643 Mesa ID Adams County
83644 Middleton ID Canyon County
83645 Midvale ID Washington County
83646 Meridian ID Ada County
83647 Mountain HomeID Elmore County
83648 Mountain Home AFBID Elmore County
83650 Murphy ID Owyhee County
83651 Nampa ID Canyon County
83654 New MeadowsID Adams County
83655 New PlymouthID Payette County
83657 Ola ID Gem County
83660 Parma ID Canyon County
83661 Payette ID Payette County
83666 Placerville ID Boise County
83669 Star ID Ada County
83670 Sweet ID Gem County
83672 Weiser ID Washington County
83676 Wilder ID Canyon County
83677 Yellow PineID Valley County
83686 Nampa ID Canyon County
83687 Nampa ID Canyon County
83702 Boise ID Ada County
83703 Boise ID Ada County
83704 Boise ID Ada County
83705 Boise ID Ada County
83706 Boise ID Ada County
83708 Boise ID Ada County
83709 Boise ID Ada County
83712 Boise ID Ada County
83713 Boise ID Ada County
83714 Garden CityID Ada County
83716 Boise ID Ada County
83801 Athol ID Kootenai County
83802 Avery ID Shoshone County
83803 Bayview ID Kootenai County
83804 Blanchard ID Bonner County
83805 Bonners FerryID Boundary County
83808 Calder ID Shoshone County
83809 CareywoodID Bonner County
83810 Cataldo ID Kootenai County
83811 Clark Fork ID Bonner County
83812 Clarkia ID Shoshone County
83813 Cocolalla ID Bonner County
83814 Coeur D AleneID Kootenai County
83815 Coeur D AleneID Kootenai County
83821 Coolin ID Bonner County
83822 Oldtown ID Bonner County
83823 Deary ID Latah County
83824 Desmet ID Benewah County
83830 Fernwood ID Benewah County
83832 Genesee ID Latah County
83833 Harrison ID Kootenai County
83834 Harvard ID Latah County
83835 Hayden ID Kootenai County
83836 Hope ID Bonner County
83837 Kellogg ID Shoshone County
83839 Kingston ID Shoshone County
83842 Medimont ID Kootenai County
83843 Moscow ID Latah County
83845 Moyie SpringsID Boundary County
83846 Mullan ID Shoshone County
83847 Naples ID Boundary County
83848 Nordman ID Bonner County
83850 Pinehurst ID Shoshone County
83851 Plummer ID Benewah County
83852 Ponderay ID Bonner County
83854 Post Falls ID Kootenai County
83855 Potlatch ID Latah County
83856 Priest RiverID Bonner County
83857 Princeton ID Latah County
83858 Rathdrum ID Kootenai County
83860 Sagle ID Bonner County
83861 Saint MariesID Benewah County
83864 Sandpoint ID Bonner County
83868 SmeltervilleID Shoshone County
83869 Spirit Lake ID Kootenai County
83870 Tensed ID Benewah County
83871 Troy ID Latah County
83872 Viola ID Latah County
83873 Wallace ID Shoshone County
83874 Murray ID Shoshone County
83876 Worley ID Kootenai County

EXHIBIT 4

Key Management Bios

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 a variety 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.

MVNO/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 2018
Employment Duration 20 yrs
Location Houston
Developing simple software solutions fit to client's needs. Providing turn 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 strategy, 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 – Jul 2015 Employment Duration 9 mos
Location Houston, Texas Area Luminess Air
Lead Internet Marketing Associate Dates Employed Jan 2011 – 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 1 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, returned or excess handset inventory. For regional carriers or MVNO’s, HTH
is the leading provider of high-quality refurbished 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 modify 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 4G/5G 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.
Hugo Vo

IT Professional with 3 years of experience, and a proven knowledge of hardware engineering,
configuration and troubleshooting. Proven ability to develop and implement IT solutions that
support business needs.

HTH Communications, LLC
IT & Development Manager May 2021 – Present
IT Support Jan 2019 – May 2021
Phone Technician / Helpdesk Jul 2018 – Jan 2019
Employment Duration 3 yrs 5 mos
Location Houston, Texas, U.S

Creative Bay
Web Developer May 2012 – Dec 2013
Employment Duration 1 yr 8 mos
Location Vietnam

UNIVERSITY OF GREENWICH
Degree Name Bachelor of Science (B.S.)

EXHIBIT 5

Proposed Lifeline Offering

Minutes & Data

1,000 anytime minutes per month
500 text messages per month
4.5 GB data per month
LTE or 5G Network
Net cost to Lifeline customer: $0

ADDITIONAL AIRTIME

Available for purchase at www.airtalkwireless.com

All packages include:

 Free SIM card or Handset
 Free calls to AirVoice Customer Service
 Free calls to 911 emergency services
 Free access to Voicemail, Caller-ID, and Call Waiting features
 Voice minutes may be used for Domestic Long Distance at no extra cost

EXHIBIT 6

Sample Advertisements
Apply Online at airtalkwireless.com
E-mail us at [e-mail]
Call us toll-free at [phone]
QUICK &EASY!
APPLYING IS
is now Government Assistance Program
LIFELINE & ACP
PROGRAM to RECEIVE a
FREE iPhone 7,
Samsung S9 &
UNLIMITED
Data, Talk & Text
Unlimited Data is provided by the Affordable Connectivity Program.See Terms & Conditions for additional information. The above devices are available while supplies last.If models are no longer available, a similar device will be offered.
&ACP&
M to RECEIV
one 7,
ng S9 &
TED
alk & Text
om
VE a
fo d
a
Tablets
For$10.01!
FREESamsung
S9FREE
iPhone

7
Keeping Our Communities Connected
Affordable Connectivity
Program
Congress recently created the
Affordable Connectivity
Program, a long-term, $14 billion
program, which will replace the
Emergency Broadband Benefit
Program. This investment in
broadband affordability will help
ensure we can afford the
internet connections we need for
work, school, health care, and
more for a long time.
You Can Qual˜˙y if You
Participate in One of the
Following Programs:
AirTalk Wireless is a program
provided by HTH Communications
serving eligible American
households. The company is an
FCC-licensed Eligibility
Telecommunication Carrier (ETC)
which offers Lifeline and the
Affordable Connectivity Program
(ACP) to eligible customers
across America.
About Us
Why Should You
Choose AirTalk ?
Offers the best FREE Phone
Offers the best FREE service
plan
Nationwide Coverage & 23+
years in business
Dedicated Customer Service
Our customers are happy
Applying is quick & easy
Fast & Free Shipping
SNAP/FOOD STAMPS
MEDICAID
SSI
VETERANS SURVIVORS PENSION
BENEFITS FUND
FEDERAL PUBLIC HOUSING
ASSISTANCE
or through income base
qualifications and MANY MORE!
Contact Us:
Monday - Friday : 8:00 a.m - 5:00 p.m CST & Saturday: 10:00 a.m - 7:00 p.m CST
Website: www.airtalkwireless.com Email: [e-mail] Phone: [phone]
Lance J.M. Steinhart, P.C.
Attorneys At Law
1725 Windward Concourse
Suite 150
Alpharetta, Georgia 30005

Also Admitted in New York Telephone: [phone]
Email: [e-mail] Facsimile: [phone]

April 22, 2022

VIA EMAIL TO [e-mail]

Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702

Re: Air Voice Wireless, LLC d/b/a AirTalk
Case No. AVW-T-22-01

Dear Ms. Noriyuki:

Air Voice Wireless, LLC d/b/a AirTalk Wireless (“Air Voice”) filed an Application for
Limited Designation as an Eligible Telecommunications Carrier (the “Application”) on March 23,
2022. Air Voice respectfully requests to supplement its Application with information in support of
its technical capabilities attached hereto as Exhibit 8.

If you have any questions, or if I may provide you with additional information, please do not
hesitate to contact me at 770-232-9200 or [e-mail]. Thank you.

Respectfully submitted,

Lance J.M. Steinhart, Esq.
Managing Attorney
Lance J.M. Steinhart, P.C.
Attorneys for Air Voice Wireless, LLC d/b/a AirTalk Wireless

Attachments
cc: Henry Do
Johan E. Kalala-Kasanda

EXHIBIT 8

Technical Capabilities

SOLUTIONS OVERVIEW
JANUARY 2021
TABLE OF CONTENTS
1.ABOUT HTH
2.COMPREHENSIVE SERVICE OFFERING
o HANDSET SALES
o MVNE SERVICES
o 4PL SOLUTIONS
o REPAIR & REFURBISHING
3.THE HTH TEAM
4.TIMELINE OF OUR GROWTH
5.QUALITY STANDARDS WE MAINTAIN
6.CUSTOMERS WE SERVE
7.BRANDS WE CARRY
8.COMPETITIVE ADVANTAGE
9.WORKING TOGETHER
10.HTH COMMUNICATIONS AFFILIATE COMPANIES
PROVIDING SUSTAINABLE SOLUTIONS FOR THE WIRELESS INDUSTRY
ABOUT HTH
For customers across the globe, HTH is delivering value into
their supply chain through programs that lower cost of
acquisition, reduce churn and increase returns on investment.
At HTH, we believe that sustainability is ensuring that our
customers achieve their business goals year after year. We
believe that sustainability means investing in our employees
and creating a culture of success. And, we believe that
sustainability means operating our business in accordance
with global quality standards designed to ensure the well-being
and prosperity of future generations.
Handset Sales
MVNE Services
4PL Services
WE MANAGE THE SECONDARY MARKETPLACE SO YOU DON’T HAVE TOCOMPREHENSIVE SERVICE OFFERING
Repair and Refurbishing
In the secondary marketplace, value is derived from high-
quality products, efficient services and expandable
infrastructure. HTH knows this and that’s why our
comprehensive service offering is used by over 50 MVNO’s,
4 National Carriers and numerous OEMs. Our service
platform enables success and delivers maximum returns to
our partners.
HANDSET SALES
BUY FROM US
Our customers demand full-features phones at second life prices.
Whether you’re looking for a smartphone or a basic feature phone,
we have a wide selection of devices to choose from in a variety of
conditions and grades. Each customer is assigned a dedicated
account manager who provides:
o Weekly inventory reports
o Promotional offers
o Same day order fulfillment
o Flexible financing offers
o Device warranty
o Logistics expertise
o Exceptional service
HANDSET SALES
SELL TO US
We understand that carriers, OEM’s and insurance providers all
carry millions of dollars in inventory and have financial targets
to meet. That’s why we participate in numerous disposition
programs to purchase returned, trade-in, buy-back and excess
inventory; always delivering returns to help your company
achieve its goals.
MVNE SERVICES
OPERATIONAL
TOOLS
WHITE LABEL
SOLUTIONS
RISK REWARD
MODELS CAP EX DEFERRALS
AIRTIME BUNDLES OPERATING
SYSTEM SUPPORT
DEVICE
MANAGEMENT
VIRTUAL
WAREHOUSING
4PL SERVICES
VIRTUAL
WAREHOUSING TRANSPORTATION DROP SHIPMENT TRACKING AND
REPORTING
FORWARD LOGISTICS REVERSE LOGISTICS
REPAIR & REFURBISHING
PARTS RECOVERY &
RECLAMATION
OEM NEW &
REFURBISHED PARTS
PROPRIETARY
TESTING EQUIPMENT
OEM CERTIFIED
FACILITY
Triage Disassembly Assembly Picture Packs Distribution
HTH PROCESS
OVERVIEW:
CULTURE OF SUCCESS
THE HTH TEAM
HTH was founded in July 2008 by Henry Do. Holding degrees in Economics and Finance, Henry began his career at a private equity firm serving the wireless
industry where he recognized the need for a repair company that was laser focused on quality and efficiency. Nothing affected the bottom line of companies
more than those two factors. With that, HTH was formed. Over the past twelve years, HTH has grown in size and scope and it has done so by creating a
culture of success for employees. Enabling employees to grow and excel within the company, ensuring employees do their jobs with integrity and attention to
detail, and rewarding employees when they achieve their goals are all part of the HTH culture.
Henry Do, CEO Leadership Warehouse and
Technical Staff Customer Service
WHEN OUR CUSTOMERS SUCCEED, WE SUCCEEDTIMELINE OF OUR GROWTH
20142008201020122009
HTH
Communications
founded and
operated in
1,500-SF facility
in Houston, TX
Moved into 10,000-SF
facility less than a
year later to
accommodate growth.
Selected as exclusive
distributor of Cricket’s
refurbished handsets
HTH becomes a
downstream vendor
to Sprint, US Cellular,
MetroPCS, AT&T and
T-Mobile
Moved into a 50,000-
SF facility to
accommodate
growing team and
expansion of services
HTH expanded
marketing efforts
and began attending
trade shows such as
CTIA, CCA and
participating in
Carrier Summits
2016
HTH receives R2, ISO
9001, ISO 14001 and
ISO OHSAS 45001
certifications
2019
HTH celebrates
over a decade in
business and
relocates to its
privately owned
125,000-SF
state-of-the-art
headquarters
QUALITY & EFFICIENCY
ARE THE CORE OF OUR SOLUTIONS
QUALITY STANDARDS WE MAINTAIN
ISO 45001
OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT SYSTEMS
ISO 9001
QUALITY MANAGEMENT
SYSTEMS
ISO 14001
ENVIRONMENTAL STANDARDS SYSTEMS
R2
RESPONSIBLE ELECTRONICS RECYCLING
Choice Wireless
Amazon
eBay
Retailers & Etailers
Carolina West
Affinity Cellular
ClearTalk Wireless
Rural & Small Carriers
Assurant
Asurion
Immerge Wireless
Enterprise Providers
Samsung
Alcatel
LG
Quality One
Manufacturers &
Wholesalers
Sprint
T-Mobile
Verizon
AT&T
Metro PCS
US Cellular
Nationwide Carriers
TracPhone
Ready Wireless
Red Pocket Mobile
Assist Wireless
Credo
Easy Wireless
Safety Net Wireless
MVNO’s & Lifeline
CUSTOMERS WE SERVE
BRANDS CONSUMERS DEMAND
ARE THE BRANDS WE CARRY
ALL GRADESGrade AGrade BGrade CGrade D
Grade BER
ALL TYPESSmartphonesFeature PhonesTabletsWiFiModems
Smart Accessories
ALL BRANDSAppleSamsungLGMotorola
Kyocera
ALL CONDITIONSNewUsedCertified Pre-OwnedRefurbished
Functionally Tested
OUR STRENGTH IS IN THE NUMBERS
COMPETITIVE ADVANTAGE
Numbers can tell a powerful story.
The success of our business and commitment to
customers are best illustrated in these numbers.
125,000-square-foot
state-of-the-art
facility
200+ SKU’s in
Inventory
1.5M Annual Unit
Volume
15 In-house
Software Engineers
Financially Strong 12+ Years of
Positive Growth
Direct Access to
Carriers
200 Full-time
Employees
LET’S DEVELOP A
SOLUTION FOR YOU!
WORKING TOGETHER
ONE SOURCE SOLUTION
We simplify supply chain for our customers by offering a full scope of solutions. One vendor. One location.
One point of contact. Easy.
EXPERIENCE, SCALE, FLEXIBILITYWe have the team, the financial strength and the operations to put
together a program designed specifically for you!
COMMITMENT TO EXCELLENCEQuality and Efficiency are the core
values in running our business.Our customers deserve nothing less.
ONE SOURCE
SOLUTION
HTH COMMUNICATIONS AFFILIATE COMPANIES
Working with us is easy. We can provide you with a single service or
put together a comprehensive offering.
o Owned by Henry Hung Do
o Headquarters office is located at 9920 Brooklet Drive, Houston, TX 77099
o A distributor for wireless resellers
o Operating on the Sprint & T-Mobile Network
o B2C Products & Services
�-SOFTEL
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WHAT WE OFFER