20160810Application.pdf

RE Cl=I VED
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of
Application of Boomerang Wireless, LLC d/b/a
enTouch Wireless for Designation as an Eligible
Telecommunications Carrier in the
State of Idaho for the Limited
Purpose of Offering Wireless Lifeline
Service to Qualified Households
(Low Income Only)
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CaseNo. }3 W [_ -j-} b-OJ
APPLICATION OF BOOMERANG WIRELESS, LLC D/B/A ENTOUCH WIRELESS
FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER IN
THE STATE OF IDAHO FOR THE LIMITED PURPOSE OF OFFERING WIRELESS
LIFELINE SERVICE TO QUALIFIED HOUSEHOLDS
Boomerang Wireless, LLC d/b/a enTouch Wireless ("enTouch Wireless" or the
"Company"), by and through its undersigned counsel, and pursuant to the Federal
Communications Act of 1934, as amended (the "Act"), 4 7 U .S.C. § 214( e )(2), implementing
rules of the Federal Communications Commission ("FCC") and the Idaho Public Utilities
Commission's ("the Commission's") requirements set forth in the Appendix to Commission
Order No. 29841 in Case No. WST-T-05-1 ("Order No. 29841") hereby requests that the
Commission designate enTouch Wireless as an Eligible Telecommunications Carrier ("ETC")
throughout the State of Idaho (the "Service Area") for the purpose of receiving federal low­
income universal service support for prepaid wireless services, specifically Lifeline and tribal
Lifeline. enTouch Wireless does not at this time seek ETC designation (1) for the purpose of
receiving federal universal service support for providing service to high-cost areas or (2) on a
ORIGINAL
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wireline basis.' A list of each exchange for which en Touch Wireless is requesting ETC status in
the State of Idaho along with a map is attached and incorporated herein as Exhibit A, which
includes certain tribal areas in Idaho. enTouch Wireless respectfully requests that the
Commission grant this Application and that it do so expeditiously so that enTouch Wireless may
begin providing wireless Lifeline service to qualified low-income households at the earliest
practicable time. In further support of its Application, en Touch Wireless states as follows:
INFORMATION REGARDING THE APPLICANT
1. Boomerang Wireless, LLC is an Iowa limited liability company with its principal
offices located at 955 Kacena Road, Suite A, Hiawatha, Iowa 52233. The Company's Articles of
Incorporation and authorization to transact business in Idaho are attached and incorporated
herein as Exhibit B.
2. As of the date of this Application, the Company has been designated as a wireless
ETC in twenty-four states: Arizona, Arkansas, California, Colorado, Georgia, Indiana, Iowa,
Kansas, Kentucky, Louisiana, Maryland, Michigan, Minnesota, Mississippi, Missouri, North
Dakota, Ohio, Oklahoma, Oregon, South Carolina, Texas, Washington, West Virginia, and
Wisconsin. Of these states, the Company currently serves Native American populations residing
on tribal lands in the states of Arizona, Iowa, Kansas, Michigan, Mississippi, Minnesota, North
Dakota, Oklahoma, Washington, and Wisconsin. In addition, the Company has applications
pending in seventeen jurisdictions for designation as an ETC on a wireless basis for federal
enTouch Wireless seeks only Lifeline support from the low-income mechanism of the federal Universal Service
Fund ("USF") and is not seeking support from the high-cost support mechanism. ETC certification
requirements related to the high-cost program are therefore not applicable to enTouch Wireless' application.
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support for Lifeline services.2 enTouch Wireless has never been denied ETC designation by any
state commission or by the FCC in connection with any state.
3. Correspondence or communications pertaining to this Application should be
directed to en Touch Wireless' attorneys of record:
Brian T. Hansen
Holland & Hart LLP
800 W. Main Street, Suite 1750
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Thorvald A. Nelson
Holland & Hart LLP
6380 S. Fiddlers Green Circle, Suite 500
Greenwood Village, CO 80111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
J. Andrew Gipson
Jones Walker, LLP
190 E. Capitol Street, Suite 800 (39201)
P. 0. Box 427
Jackson, Mississippi 39205-0427
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
4. Questions concerning the ongoing operations of enTouch Wireless following
certification should be directed to:
Ms. Kimberley Lehrman,
President & Chief Marketing Officer
Boomerang Wireless, LLC
Boomerang has ETC applications currently pending before the state commissions in Hawaii, Massachusetts,
New Jersey, New Mexico, Pennsylvania, and South Dakota. In addition, Boomerang has a pending petition
before the FCC for granting ETC designations in Alabama, Connecticut, Delaware, The District of Columbia,
Florida, Maine, New Hampshire, New York, North Carolina, Tennessee, and Virginia, WC Docket No. 09-197
(filed Dec. 29, 2010).
3
955 Kacena Road, Suite A
Hiawatha, Iowa 52233
Telephone: [phone]
Facsimile: [phone]
Emai I: [e-mail]
BACKGROUND
5. As a result of the work and cooperation of federal and state regulators, the FCC
has adopted a number of cost recovery policies and mechanisms designed to promote and
maintain universal service. One key component of universal service is the availability of
subsidies from the federal Universal Service Fund ("USF"), created by the Act. The USF was
created, in part, to provide support to qualifying low-income communications end-users such as
those serviced by enTouch Wireless. Mechanisms were also established to moderate the amount
of costs to be recovered through basic, recurring charges to low-income users, thereby assisting
efforts to maintain reasonable basic rate levels. Only a "common carrier" receiving designation
as an ETC under 47 U.S.C. § 214 is eligible to receive subsidies from the federal USF. Wireless
carriers are common carriers under federal law.3 Common carriers that provide services
consistent with the requirements of Section 214( e) may be deemed ETCs. 4 Section 214( e )(2) of
the Act5 provides that:
A State commission shall upon its own motion or upon request designate a
common carrier that meets the requirements of paragraph (1) as an eligible
telecommunications carrier for a service area designated by the State commission.
Upon request and consistent with the public interest, convenience, and necessity,
the State commission may, in the case of an area served by a rural telephone
company, and shall, in the case of all other areas, designate more than one
47 U.S.C. § 332(c){I).
4 7 U .S.C. § 214( e )(6) provides that wireless carriers not otherwise subject to state commission jurisdiction shall
be designated as ETCs if they meet the requirements of 47 U.S.C. § 214(e)(l) consistent with applicable federal
and state law.
47 U.S.C. § 214(e)(2).
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common carrier as an eligible telecommunications carrier for a service area
designated by the State commission, so long as each additional requesting carrier
meets the requirements of paragraph (I). Before designating an additional eligible
telecommunications carrier for an area served by a rural telephone company, the
State commission shall find that the designation is in the public interest.
Section 214( e )(I) of the Act6 provides:
A common carrier designated as an eligible telecommunications carrier under
paragraph (2), (3), or (6) shall be eligible to receive universal service support in
accordance with section 254 of this title and shall, throughout the service area for
which the designation is received-
(A) offer the services that are supported by Federal universal service support
mechanisms under section 254(c) of this title, either using its own facilities or a
combination of its own facilities and resale of another carrier's services (including
the services offered by another eligible telecommunications carrier); and
(B) advertise the availability of such services and the charges therefor using
media of general distribution.
6. The FCC has promulgated rules governing ETC designations, set forth at 47
C.F.R. § 54.101 , §§ 54.201-203, and §§ 54.205-207 (the "FCC Rules") to establish various
requirements for carriers to obtain ETC status. Applicants seeking ETC status in Idaho must
address and satisfy each of the ETC designation criteria under the FCC Rules. In addition,
applicants must also address the designation requirements set forth in the Appendix to
Commission Order No. 29841 , "Requirements for Eligible Telecommunications Carrier (ETC)
Designation, Reporting, and Certification."
7. Pursuant to 47 U.S.C. § 214(e)(2), the Commission has the statutory authority to
designate a common carrier as an ETC that offers the services supported by federal Universal
Service Fund support mechanisms and advertises "the availability of such services and the
charges therefore using media of general distribution."7
47 U.S.C. § 214(e)(1).
47 C.F.R. § 54.201(d)(2).
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8. enTouch Wireless is a common carrier and reseller of commercial mobile radio
service, and will offer all of the services and functionalities detailed in Section 54.101 (a) of the
FCC Rules and will provide competitive wireless services throughout its proposed Service Area
through resale of other carrier's services. enTouch Wireless meets the statutory designation
requirements under the Commission's Appendix (A) of Order No. 29841. The provision of
services through resale of other carrier's services will ensure that enTouch Wireless can provide
services to customers throughout the Service Area. 8 As discussed in subsequent sections of this
Application, en Touch Wireless has filed and received approval of its Compliance Plan with the
FCC. Additionally, enTouch Wireless will advertise the availability of such services and the
charges for these services using media of general distribution and commits to continue to
advertise the availability of its Lifeline program.
9. Further, as shown herein, enTouch Wireless meets the additional requirements set
forth in the FCC Rules for obtaining ETC designation for purposes of receiving Lifeline funding
support:9
(a) Certification of enTouch Wireless' compliance with the service
requirements applicable to the support that it receives;
(b) Demonstration of enTouch Wireless' ability to remain functional in
emergency situations, including a demonstration of possession of reasonable amount of back-up
power to ensure functionality without an external power source, and ability to reroute traffic
around damaged facilities, and capability of managing traffic spikes resulting from emergency
situations;
47 C.F.R. § 54.JOJ(a).
47 C.F.R. § 54.202.
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(c) Demonstration that enTouch Wireless satisfies the applicable consumer
protection and service quality standards;10
(d) Demonstration of enTouch Wireless' financial and technical capability of
providing the Lifeline service in compliance with subpart E of the FCC's rules and regulations.11
(e) Submission of information describing the terms and conditions of any
voice telephony service plans offered to Lifeline subscribers, including details on the number of
minutes provided as part of the plan, additional charges, if any, for toll calls, and rates for each
such plan; and
(f) Demonstration that ETC designation is in the public interest.
In meeting each of the foregoing, en Touch Wireless submits that it also meets each of the
requirements of the Commission's Appendix (8) to Order No. 29841 .
10. Finally, designation of en Touch Wireless as an ETC on a wireless basis is in the
public interest of the State of Idaho and its low-income telecommunications end-users. Upon
designation as an ETC, enTouch Wireless will make Lifeline service available to qualifying
customers in the Service Area pursuant to the guidelines and requirements of the universal
service program, 47 C.F.R. § 54.202 and the Commission's Appendix to Order No. 29841 .
ENTOUCH WIRELESS MEETS THE REQUIREMENTS FOR DESIGNATION AS AN
ETC TO SERVE DESIGNATED AREAS IN IDAHO
11 . As demonstrated below, enTouch Wireless meets the requirements for ETC
designation by the Commission pursuant to Section 214( e )(2) of the Act.12 In addition, en Touch
1° For wireless applicants compliance with the Cellular Telecommunications and Internet Association's Consumer
Code for Wireless Service satisfies this requirement.
II 47 C.F.R. §§ 54.401 to 422.
12 47 U.S.C. § 214(e)(2).
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Wireless complies with the standards established by the FCC for determining whether applicants
for ETC status serve the public interest.13
12. The Commission has jurisdiction to designate enTouch Wireless as an ETC.
Pursuant to the provisions of Section 214(e)(2) of the Act, state commissions, such as this
Commission, have primary responsibility for the designation of ETCs under Section 214(e)(2).
As shown in this Application, enTouch Wireless meets the requirements for designation as an
ETC in Idaho. The Commission may and should grant enTouch Wireless' application for ETC
status.
enTouch Wireless has the Financial and Tehcnical Capability
13. enTouch Wireless has the financial and technical capability to provide Lifeline
service. As part of the 2012 Lifeline Reform Order, the FCC amended its rules to require a
carrier seeking designation as a Lifeline-only ETC to demonstrate that it is financially and
technically capable of providing the supported Life] ine service in compliance with all of the low­
income program rules.14 enTouch Wireless satisfies these criteria as discussed below.
14. enTouch Wireless generates revenues from non-Lifeline services and has access
to capital from its investors. Boomerang Wireless, LLC, together with its parent and sister
companies, currently provides prepaid wireless services to more than 230,000 subscribers,
including more than 50,000 retail customers. Consequently, the Company has not relied, and
will not be relying exclusively on Lifeline reimbursement for its operating revenues. The
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14
See Federal-State Joint Board on Universal Service, Report and Order, CC Docket No. 96-45, 20 FCC Red
6371 , ,r 40-43 (Rel, March 17, 2005).
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) ("2012 Lifeline Reform Order").
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Company has not been subject to enforcement sanctions or ETC revocation proceedings in any
state.
15. enTouch Wireless attaches and incorporates hereto as Exhibit Ca current list of
its officers, along with biographical information for each, showing that it has the expertise
necessary to provide the services specified herein.
enTouch Wireless will provide the required Universal Services and Functionalities
16. enTouch Wireless will offer all required services and functionalities. Section
214(e)(l)(A) of the Act15 requires an ETC to offer the services that are supported by federal
universal service support mechanisms under Section 254(c). As published in the Federal
Register on May 24, 2016 pursuant to the Lifeline Modernization Order, the FCC amended
Section 54.101 (a) of its rules to add broadband service as a supported service as follows:
§ 54.101 Supported services for rural, insular and high cost
areas.
(a) Services designated for support. Voice telephony services
and broadband service shall be supported by federal universal
service support mechanisms.
(1) Eligible voice telephony services must provide voice grade
access to the public switched network or its functional
equivalent; minutes of use for local service provided at no
additional charge to end users; access to the emergency
services provided by local government or other public safety
organizations, such as 911 and enhanced 911, to the extent the
local government in an eligible carrier's service area has
implemented 911 or enhanced 911 systems; and toll limitation
services to qualifying low-income consumers as provided in
subpart E of this part.
(2) Eligible broadband Internet access services must provide
the capability to transmit data to and receive data by wire or
radio from all or substantially all Internet endpoints, including
any capabilities that are incidental to and enable the operation
15 47 U.S.C. § 214(e)(l).
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of the communications service, but excluding dial-up service.
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17. In addition, the FCC's 2016 Lifeline Order established certain minimum service
standards applicable to voice telephony.11 With respect to the mobile voice services to be
provided by the Company, these minimum service standards are as follows:
(3) The minimum service standard for mobile voice service will be:
(i) From December 1, 2016, until November 30, 2017, 500 minutes;
(ii) From December 1, 2017, until November 30, 2018, 750 minutes; and
(iii) On and after December 1, 2018, the minimum standard will be 1000
minutes.18
18. Upon designation as an ETC in Idaho, and consistent with state and federal
policies favoring universal service, enTouch Wireless will offer voice telephony services as
required under Section 54.101 of the FCC Rules, and as required by Appendix (A)(2) of the
Commission's Order No. 29841. As described in more detail later, the 500 Minute and Tribal
1100 Free Unit Lifeline plans offered by enTouch Wireless already meet the minimum service
standards applicable to voice telephony services, though not required until December 1, 2016.
The Company is in the process of developing its expanded broadband products and will
supplement this Application prior to December 1, 2016 to update its Lifeline plans with
broadband components meeting the minimum service requirements applicable to broadband
internet access services under the 2016 Lifeline Order. Accordingly, en Touch Wireless will
16 Federal Communications Commission Lifeline and Link Up Reform and Modernization, Telecommunications
Carriers Eligible for Universal Service Support, Connect America Fund; Final Rule, 81 Fed. Reg. 100, 33088-
89 (May 24, 2016) (to be codified at 4 7 C.F .R. § 54.101 (a)).
17 Id. at 33091-92 (to be codified at 47 C.F.R. § 54.408).
is Id.
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meet by December 1, 2016 the minimum service standards applicable to voice telephony services
or broadband internet access services as described in Section 54.408 as published in the Federal
Register on May 24, 2016.
19. The Company will also provide access to emergency services provided by local
government or public safety officials, including 911 and enhanced 911 ("E91 l ") where available
and will comply with any Commission requirements regarding E91 l-compatible handsets. The
Company will comply with the Commission 's forbearance grant conditions relating to the
provision of 911 and E911 services and handsets. enTouch Wireless also commits to remit 911
revenues to local authorities. The Company commits to pay in a timely manner all applicable
federal, state and local regulatory fees, including but not limited to universal service and E91 l
fees.19
20. Consistent with clarifications made by the FCC under the 2016 Lifeline Order,
enTouch Wireless will not be required to offer toll limitation service ("TLS"), because the
Company, like most wireless carriers, does not distinguish between toll and non-toll calls in the
pricing of the service.20
21. enTouch Wireless will provide wireless service through resale. Under Section
214( e )( 1 )(A) of the Act, an ETC must offer the services supported by federal universal service
support mechanisms throughout its Service Area "either using its own facilities or a combination
of its own facilities and resale of another carrier's services."21 1n its 2012 Lifeline Reform Order,
19 See Tracfone Wireless, Inc. Petition to Rescind State 91 I/E911 Condition, FCC Docket No. 96-
45 (May 3, 2010).
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21
See Federal Communications Commission Lifeline and Link Up Reform and Modernization,
Telecommunications Carriers Eligible for Universal Service Support, Connect America Fund; Final Rule, 81
Fed. Reg. 100, 33090 (May 24, 2016) (to be codified at 47 C.F.R. § 54.401(a)(2)).
47 U.S.C. § 214(e)(l)(A).
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the FCC decided to forbear, on its own motion, from applying the facilities requirement of
Section 214(e)(l)(A) to any telecommunications carrier that seeks limited ETC designation to
participate in the Lifeline program, conditioned on the ETC's compliance with certain 911
requirements and the ETC 's filing with and approval by the FCC of a compliance plan
describing the ETC 's adherence to certain protections prescribed by the FCC ("Blanket
Forbearance").
22. enTouch Wireless seeks limited ETC designation in Idaho to participate in the
Lifeline program and has opted to pursue Blanket Forbearance. On August 8, 2012, the FCC
approved the Company's Compliance Plan ("Compliance Plan"). A copy of the approved
Compliance Plan is attached and incorporated herein as Exhibit D. enTouch Wireless seeks
designation as an ETC by the Commission on an expedited basis in light of the FCC's approval
of the Compliance Plan.
23. en Touch Wireless, in its provision of wireless services, will offer resold services
which the Company will obtain from its underlying wireless providers, Sprint, Verizon, AT&T
as well as other Global System for Mobile Commissions ("GSM") carriers. This extended
footprint through multiple carriers allows enTouch Wireless to provide expanded coverage
throughout otherwise underserved markets as shown in Exhibit A.
24. enTouch Wireless has developed and implemented a diverse network that delivers
all of the services required by the Federal Lifeline guidelines, and employs Verizon, Sprint,
AT&T as well as other GSM carrier networks to ensure ubiquitous coverage. Additionally,
enTouch Wireless operates a network data facility located in Marion, Iowa, which is on line with
enTouch Wireless' remote call authorization array located at 630 E. Government Street,
Pensacola, Florida 32502, and its network switch platform located at 5500 REC Drive, Marion,
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Iowa 52302. All wireless voice traffic is monitored and gains network authorization/access from
enTouch Wireless' call authorization platform on a per call basis. This same intelligent calling
platform is used to transmit calls to the underlying carrier network for call completion, as well as
communication to enTouch Wireless ' IVR platform. International long distance, operator
services, and directory services traffic passes through the enTouch Wireless network system.
25. Through its service arrangements, enTouch Wireless is able to offer all of the
services and functionalities supported by the universal service program, as detailed in Section
54.lOI(a) of the FCC Rules, throughout its Service Area.
Advertising Requirements
26. enTouch Wireless will also advertise the availability of the supported services as
required by the FCC and Appendix (A)(3) of Order No. 29841. The FCC adopted specific
requirements for Lifeline advertising in its 2012 Lifeline Reform Order with which the Company
will comply.22 enTouch has developed clear and transparent methods of advertising as required
by the 2012 Lifeline Reform Order, to include 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) documentation necessary for enrollment; (7) enTouch Wireless' name (the ETC); (8) notice
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; and (9) details of the
Lifeline service offerings.23 These or similar statements will be included in print, audio, video
22 2012 Lifeline Reform Order at 11275-82.
23 2012 Lifeline Reform Order at 1275.
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and web materials (including social networking media) used to describe or enroll customers in
the Company 's Lifeline service offering, as well as the Company's application forms and
certification forms.24 This includes the Company's website and outdoor signage.25
27. enTouch Wireless is fully prepared to and will comply with federal requirements
that it advertise the availability of its services throughout its Service Area using media of general
distribution.26 enTouch Wireless further commits that it will also publicize the availability of
Lifeline service in a manner reasonably designed to reach those likely to qualify for the service.27
enTouch Wireless specifically targets its advertising so as to reach its intended market base of
low-income consumers who otherwise would be without service, or unaware of the program's
availability and benefits. Accordingly, more low-income Idaho residents will be made aware of
the opportunities afforded to them under the Lifeline program and will be able to take advantage
of those opportunities by subscribing to enTouch Wireless' service. A sample of enTouch
Wireless' updated planned advertising is attached and incorporated herein as Exhibit E.
28. As a designated ETC in Idaho, enTouch Wireless will annually notify in writing
each of its existing customers residing in the Service Area of the availability of federal Lifeline
and Tribal Linkup assistance programs pursuant to the FCC Rules. enTouch Wireless will also
provide new customers in the Service Area with written notification of Lifeline and Tribal
Link Up assistance programs within 30 days after receiving telecommunications services.
24 Id.
2s Id.
ADDITIONAL STATE ELIGIBILITY CRITERIA
Commitment and Ability to Provide Supported Services
26 4 7 C.F .R. § 54.20 I ( d)(2).
27 47 C.F.R. §§ 54.405(b) and Appendix (A)(3) of Commission Order No. 29841.
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29. enTouch Wireless is committed to providing service in Idaho. enTouch Wireless
not only commits to provide service throughout its Service Area, but also commits to provide
universal service in a timely manner to all customers who make a reasonable request for service
pursuant to Appendix (B)(l) of Commission Order No. 29841 and the FCC Rules. If designated
as a wireless ETC, enTouch Wireless will provide service throughout its Service Area through
the resale of services. enTouch Wireless commits to providing service on a timely basis to
requesting customers within the Service Area where the underlying network already passes the
potential customer's premises. If the requesting customer is within the Service Area but outside
enTouch Wireless' existing network coverage, enTouch Wireless will provide service within a
reasonable period of time if such service does not impose excessive or unreasonable cost as
required by Appendix (B)(I) of Commission Order No. 29841.
Ability to Remain Functional in Emergencies
30. Further, under the FCC Rules and Appendix (B)(2) of Commission Order No.
29841, an ETC applicant must demonstrate its ability to remain functional in emergency
situations.28 Since enTouch Wireless is providing service to its customers through the use of
facilities obtained from other carriers it is able to provide to its customers the same ability to
remain functional in emergency situations as currently provided by the carriers to their own
customers, including access to a reasonable amount of back-up power to ensure functionality
without an external power source, re-routing of traffic around damaged facilities, and the
capability of managing traffic spikes resulting from emergency situations. Facilities utilized by
en Touch Wireless are capable of remaining fully functional with generator back-up as described
above.
28 47 C.F.R. § 54.202(a)(2).
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Commitment to Consumer Protection and Service
31. Pursuant to Appendix (B)(3) of Commission Order No. 29841 and FCC
regulations, enTouch Wireless will comply with the consumer protection standards set by the
FCC, including:
(a) Customer Proprietary Network Information -enTouch Wireless will
satisfy all consumer privacy protection standards as provided in 47 C.F.R. § 64, Subpart U as
applicable and will protect Customer Proprietary Network Information ("CPNI") as required by
state and federal law and will certify compliance with the same on an annual basis; and
(b) Consumer Code for Wireless Service -enTouch Wireless certifies that it
will comply with the Cellular Telecommunications and Internet Association's ("CTIA")
Consumer Code for Wireless Service as required by 47 C.F.R. § 54.202(a)(3).
32. As a reseller of other carriers' wireless services, enTouch Wireless is able to offer
service of the same quality and reliability as the underlying vendors. enTouch Wireless cannot
guarantee that customers will never experience service disruptions, however, enTouch Wireless'
underlying carrier agreements allow its service to be as reliable as any other wireless service that
must deal with atmospheric and other conditions that sometimes result in dropped calls.
DESIGNATION OF ENTOUCH WIRELESS AS AN ETC IN CERTAIN EXCHANGES
WITHIN THE STATE OF IDAHO SERVES THE PUBLIC INTEREST
33. Upon designation enTouch Wireless will provide competitive wireless services
throughout its Service Area, including certain tribal areas, within the State of Idaho. enTouch
Wireless is a reseller of commercial mobile radio service, and will offer all of the services and
functionalities detailed in Section 54.101 (a) of the FCC Rules and will provide competitive
wireless services throughout its Service Area through resale of other carriers' services. The
provision of services through resale of other carriers' services will ensure that en Touch Wireless
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can provide services to customers throughout the Service Area. 29 The following factors
demonstrate that the designation of enTouch Wireless as an ETC is consistent with the public
interest, convenience, and necessity, and in areas served by a rural telephone company, that the
public interest will be met by designation of en Touch Wireless as an additional ETC.
34. Wireless ETC's per se promote the public interest. The FCC has determined that
while "[ d]esignation of competitive ETCs promotes and benefits consumers ... by increasing
customer choice," designation must include "an affirmative determination that such designation
is in the public interest regardless of whether the applicant seeks designation in an area served by
a rural or nonrural carrier."30 In areas served by nonrural ILECs, the Act does not require a
separate public interest finding. The FCC has previously held that designating a competitor as an
ETC in areas served by nonrural lLECs is per se in the public interest.31
35. enTouch Wireless submits that the public interest benefits of designating en Touch
Wireless as an ETC include (1) a larger local calling area and expanded coverage area via
multiple underlying carriers (as compared to traditional wireline carriers and single wireless
carriers); (2) the convenience, portability, and security afforded by mobile telephone service; (3)
the opportunity for customers to control cost by receiving a pre-set amount of flat-rate monthly
airtime; (4) the ability to purchase additional low-cost usage at multiple convenient locations in
the event that included usage has been exhausted; (5) the ability of users to use the supported
service to send and receive "SMS" or text messages as well as the option to send data and access
the public internet; (6) 911 and, where available, E911 service in accordance with current FCC
29 47 C.F.R. § 54.IOl(a).
30 See Federal-State Joint Board on Universal Service, 20 FCC Red 6371, ,r 42 (2005).
31 See Cellco Partnership, 16 FCC Red, at 45.
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requirements; and (7) outreach and service to potentially unserved or underserved Native
American populations residing on tribal lands. In addition, the inclusion of domestic telephone
toll calling as a part of en Touch Wireless' flat-rate wireless offering allows consumers to avoid
the risks of becoming burdened with significant and unexpected per-minute charges for domestic
telephone toll and overage charges. These per-minute overruns form the basis of a substantial
number of consumer complaints to state and federal regulators. Accordingly, en Touch Wireless'
offerings will help to reduce this burden on public utility regulatory boards by obviating the
cause for such complaints.
36. The FCC has also identified factors that are to be considered in determining
whether designation of additional ETCs will serve the public interest and whether the benefits of
an additional ETC would outweigh potential harms. These factors include: (1) the benefits of
increased competitive choice; and (2) the unique advantages of the applicant company's service
offerings.32 enTouch Wireless affirms that its ETC designation meets these criteria as described
below.
The Benefits of!ncreased Competitive Choice
37. The FCC has long acknowledged the benefits to consumers of being able to
choose from a variety of telecommunications providers and the resulting variety of
telecommunications services they provide. 33 This is of particular interest in cases where wireless
providers like enTouch Wireless seek to provide service as an alternative to the ILEC. In the
Highland Cellular case, the FCC recognized and affirmed that some households may not have
32 47 U.S.C. § 54.202(c).
33 See e.g. Specialized Common Carrier Services, 29 FCC2d 870 (1971).
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access to the public switched network as provided by the ILEC.34 The availability of a wireless
competitor benefits all consumers. The availability of a wireless competitor benefits consumers
who routinely drive long distances to attend work or school or to accomplish everyday tasks such
as shopping or attending community and social events. The wireless service offered by enTouch
Wireless will provide these consumers with a convenient and affordable alternative to traditional
telecommunications service that can be used while at home and away from home.
38. Added together, enTouch Wireless expects these additional competitive
advantages to create an atmosphere that will cause many qualified consumers, at their option, to
select enTouch Wireless ' low-income wireless Lifeline service in lieu of the more traditional
wireline or wireless services.
39. Designation of en Touch Wireless as an ETC also creates competitive pressure for
other wireline and wireless providers within the proposed service areas. In order to remain
competitive in low-income markets, therefore, all carriers will have greater incentives to improve
networks, increase service offerings and lower prices. This results in improved consumer
services and, consistent with federal law, benefits consumers by allowing enTouch Wireless to
offer the services designated for support at rates that are "just, reasonable, and affordable."35
Unique Advantages of en Touch Wireless ' Service Offerings
40. enTouch Wireless will offer a unique, easy to use, competitive and highly
affordable wireless telecommunications service, which it will make available to eligible
consumers who either have no other service alternatives or who choose a wireless prepaid
solution in lieu of more traditional services. enTouch Wireless' standard customer terms and
34
35
Federal-State Joint Bd. on Universal Serv., Highland Cellular, Inc., Memorandum Opinion and Order, 19
F.C.C.R. 6422 (2004).
47 u.s.c. § 254(b)(l).
19
..
conditions m connection with its wireless service offering can be found at
https://www.entouchwireless.com/pages/cell phone termsofservice.36
41. enTouch Wireless will announce and advertise telecommunications services as an
ETC in its Service Area and will publicize the availability of Lifeline services in a manner
reasonably designed to reach those likely to qualify for those services. Accordingly, more low­
income Idaho residents will be made aware of the opportunities afforded to them under the
Lifeline program and will be able to take advantage of those opportunities by subscribing to
enTouch Wireless' service. As stated previously, Exhibit E is a sample of enTouch Wireless'
planned advertising.
42. enTouch Wireless will provide universal service as an ETC in all of its Service
Area.
43. enTouch Wireless offers a local usage plan comparable to that offered by the
ILEC in the Service Area for which it seeks designation.
enTouch Wireless Prepaid Wireless Lifeline Plans
44. The following voice telephony services plan information further demonstrates the
public interest of this application, and is also provided pursuant to Appendix (B)(4) of
Commission Order No. 29841.
45. en Touch Wireless will, prior to December 1, 2016, offer qualified consumers their
choice of one of three Lifeline Service Plans. Lifeline is a component of one of four separate
federal universal service fund mechanisms37 known as the "low-income" support mechanism38
36 A copy of the Terms and Services is attached and incorporated herein as Exhibit F.
37 47 C.F.R. § 54.S(a)(l); See "Definitions" at second sentence.
38 47 C.F.R. § 54.S(a)(l) ); See "Definitions" at first sentence.
20
' .
I '
and is defined in 47 C.F.R. § 54.401 as "a retail local service offering" "available only to
qualified low-income consumers" "for which qualifying low-income consumers pay reduced
charges as a result of application of the Lifeline support amount" that includes the services or
functionalities enumerated in § 54.401, which enTouch Wireless will use to "[m]ake available
Lifeline service ... to qualifying low-income consumers."39
46. Prior to December I, 2016, enTouch Wireless' planned wireless Lifeline offering
will provide eligible customers with the following alternative Lifeline plans: (I) 500 Minute
Plan; (2) 250 Free Unit Plan; and (3) Tribal 1100 Free Unit Plan. The 250 Free Unit Plan and
Tribal 1100 Free Unit Plan are base plans with the ability to upgrade using the appropriate
Lifeline Upgrade Data Plans and with multiple options for acquiring a device. The 500 Minute
Plan and Tribal 1100 Free Unit Plans offered by en Touch Wireless already meet the minimum
service standards applicable to voice telephony services, though not required until December 1,
2016. As discussed previously, the Company is in the process of developing its expanded
broadband products and will supplement this Application prior to December 1, 2016.
47. 500 Minute Plan: This plan offers 500 voice minutes, 100 texts, and 10 MB of
data per month. Customers must provide their own device. There is no device available with this
offer, nor are discounts or promotions for devices available with this plan. Lifeline minutes,
texts, and data are automatically posted each month on the Lifeline customer's service
date. There is no rollover of minutes, texts or data, and any unused minutes, texts or data will
expire on the monthly service date.
48. 250 Free Unit Plan (base plan): This plan offers 250 units and 10 MB of data per
month. The 250 units can be utilized for voice and text, where 1 voice minute equals 1 unit and
39 47 C.F.R. §§ 54.401(a)(1), 54.401(a)(2), 54.401(a)(3), 54.405(a).
21
I •
1 text equals I unit. Lifeline free minutes and data are automatically posted each month on the
Lifeline customer's service. There is no rollover of units, minutes, texts or data.
49. Lifeline Upgrade Data Plan: This upgrade plan is available to a subscriber with
the 250 Free Unit Plan. In addition to the 250 Free Unit Plan (250 units and IO MB of data per
month without rollover), the Lifeline Upgrade Data Plan adds 250 MB of data per month. There
is no rollover of units, minutes, texts, or data. The cost of the Lifeline Upgrade Data Plan differs
depending on the device: (1) for customers who bring their own device, they will pay a $5 co­
pay for 90 days of service; (2) for customers who wish to purchase an entry-level smart phone
from en Touch Wireless, they can pay $25 for the phone, and the $5 co-pay will be waived for the
first 90 days; after the first 90 days, the $5 co-pay for 90 days of service will apply; (3) for
customers who wish to purchase an iPhone 4 or equivalent, they can pay $50 for the phone, and
the $5 co-pay will be waived for the first 90 days ; after the first 90 days, the $5 co-pay for 90
days of service will apply. Should a customer not wish to renew on the 90-day plan for $5, the
plan will convert to the 250 Free Unit Plan.
50. Tribal 1100 Free Unit Plan (base plan): This plan will be offered to qualified
customers who are eligible for the tribal subsidy. This plan offers 1100 units and I 00 MB of
data per month. The 1100 units can be utilized for voice and text, where 1 voice minute equals 1
unit and 1 text equals 1 unit. Lifeline free units and data are automatically posted each month on
the Lifeline customer's service. There is no rollover of units, minutes, texts or data. This plan is
only available to eligible applicants residing on Federally Recognized Tribal lands. The
additional minutes that exceed those offered in the 250 Free Unit Plan (described above) is due
to the additional $25.00 per month in Lifeline support to qualifying low-income consumers
living on Tribal lands.
22
..
51. Tribal Lifeline Upgrade Data Plan: This upgrade plan is available to eligible
customers residing on Tribal lands that have the Tribal 1100 Free Unit Plan. In addition to the
1100 Free Unit Plan (1100 units and 100 MB of data per month without rollover), the Tribal
Lifeline Upgrade Data Plan adds 500 MB of data per month . The cost of the Tribal Lifeline
Upgrade Data Plan also differs depending on the device: (1) customers can pay $5 for 90 days of
service, and will receive a free entry-level smartphone; or (2) customers can pay a one-time $25
fee for an iPhone 4 or equivalent, with the $5 co-pay waived for the first 90 days, and a $5 co­
pay for 90 days of service after that. Also, for the Tribal Lifeline Upgrade Data Plan, if a
customer chooses not to renew the paid plan, he or she will be converted to a Tribal 1100 Free
Unit Plan.
Tribal Notification
52. enTouch Wireless will offer qualified consumers who are eligible for the tribal
subsidy the Tribal 1100 Free Unit Plan described above. en Touch Wireless has a proven track
record of tribal engagement and service to Native American populations residing on tribal lands.
The Company currently serves tribes in the states of Arizona, Iowa, Kansas, Michigan,
Mississippi Minnesota, North Dakota, Oklahoma, Washington, and Wisconsin. With its
extensive experience serving tribal communities in other states, enTouch Wireless is well aware
of and attuned to the telecommunications needs of Native American populations throughout the
continental United States. As required by Appendix (A)(5) of Commission Order No. 29841,
enTouch Wireless attaches and incorporates herein as Exhibit G a list of affected tribal
governments or tribal regulatory authorities to whom a copy of this Application is being
provided. Upon designation, enTouch Wireless is prepared and committed to engage with these
Tribes to meet their tribal residents' wireless telecommunication Lifeline needs. enTouch
23
' .
Wireless submits that these factors further demonstrate the public interest will be served by
designation of en Touch Wireless as an ETC within the requested Rural Service Area.
53. All low-income universal service support will be used to allow enTouch Wireless
to provide the service with no monthly recurring charge, thus ensuring that consumer receives
100% of all universal service support funding for which en Touch Wireless will seek
reimbursement. In the event that all airtime has been used, Lifeline customers on any plan, both
Tribal and non-Tribal, will also have the capability of purchasing additional airtime to
supplement their Lifeline plans in the various denominations.40 enTouch Wireless will not
deduct airtime minutes for calls by Lifeline customers with service addresses for Lifeline service
in Idaho to en Touch Wireless' Customer Service (via 6 I I from their Lifeline phone or other
designated toll-free access dialing from any other phone), and calls from enTouch Wireless '
Customer Service to such Lifeline customers to address billing, customer care and customer
service issues.
54. Airtime replenishment cards will be made available at many retail outlets
frequented by low-income customers throughout the Service Area such as CVS, Dollar General,
Walgreens, Seven-Eleven, Freds, Rite Aid, as well as from the Company's website. There are a
hundred thousand retail locations across the country where Airfair and Get Ready airtime
replenishment cards can be purchased.
55. The wireless plans will also include the following custom calling features:
(a) Caller ID;
(b) Call Waiting;
(c) Call Forwarding;
(d) 3-Way Calling; and
(e) Voicemail.
40 The additional airtime denominations on pages 22-23 of the Compliance Plan have been updated since the
approval of the Compliance Plan in 2012.
24
56. Wireless handsets, when applicable, will be delivered at no charge to qualifying
customers, service will be activated, and the requisite number of minutes will be added upon
certification of the customer for Lifeline.
57. enTouch Wireless reiterates that it is applying for ETC designation solely for the
purpose of providing Lifeline discounts to qualified low-income consumers and to seek
reimbursement for the same and will not seek or accept high-cost support. Under the FCC Rules,
an ETC applicant must submit a five-year plan that describes with specificity the proposed
improvements or upgrades to the applicant's network on a wire-center-by-wire-center basis
throughout its proposed Service Area. The only circumstance warranting deviation from this
requirement is where an applicant's requested ETC serving territory would qualify it to receive
no "high cost" USF support, but only "low income" USF support. Because enTouch Wireless
seeks ETC designation solely for purposes of reimbursement for provision of subsidized Lifeline
services to eligible customers, submission of a network improvement plan is not required at this
time, as all funding will be used for provision of Lifeline services. Since Lifeline support is
designed to reduce the monthly cost of telecommunication services for eligible consumers, is
distributed on a per-customer basis, and is directly reflected in the price that the eligible
customer pays, it is assured that all support received by the carrier is used to provide Lifeline
services to consumers, thus promoting Lifeline and the availability of telephone service to low­
income users, which is clearly in the public interest. In addition, designation of enTouch
Wireless as an ETC will not pose any adverse effect in the growth in the high-cost portions of the
USF, nor will it create or contribute to an erosion of high-cost funding from any rural or nonrural
telephone company.
25
..
58. The FCC reaffirmed this position when it stated that "the potential growth of the
fund associated with high-cost support distributed to competitive ETCs" is not relevant to
carriers seeking support associated with the low-income program.41
59. The FCC also recognized that the total effect of additional low-income-only ETC
designations would have a minimal impact on the fund when it stated that "any increase in the
size of the fund would be minimal and would be outweighed by the benefit of increasing eligible
participation in the Lifeline program, furthering the statutory goal of providing access to low-
income consumers."42
60. It is also vital to recognize that in the case of Lifeline support, an ETC receives
USF support only for the customers it obtains. In the scenario where a competitive ETC obtains
a Lifeline customer from another ETC, only the "capturing" ETC provides Lifeline discounts and
as a result, only the "capturing" ETC receives support reimbursement.
61. In addition, all providers are required to contribute a portion of the interstate
revenues received from their customers to the Universal Service Fund. In accordance with
current federal regulations, en Touch Wireless will make contributions based on that portion of its
revenue that is determined to be interstate. As such, approving enTouch Wireless as an ETC will
actually create contributions to the USF that were previously non-existent.
62. Designation of enTouch Wireless as an ETC benefits the public interest of low-
income consumers throughout en Touch Wireless' Service Area. Approval of en Touch Wireless'
ETC Application will serve the public interest by increasing participation of qualified consumers
in the Lifeline program in the State of Idaho. It will also increase the number of carriers eligible
41
42
Petition ofTracFone Wireless, Inc. for Forbearance from 47 U.S.C. § 214(e)(l)(A) and 47 C.F.R. § 54.201(i),
CC Docket No. 96-45, Order, 20 FCC Red 15095 (2005) ("TracFone Forbearance Order") at, 17.
TracFone Forbearance Order, at , 17.
26
for federal USF support, thereby proportionately increasing the amount of federal USF dollars
available to Idaho consumers. Granting ETC status to enTouch Wireless will contribute to more
Idaho residents receiving Lifeline, thereby increasing the amount of federal USF dollars flowing
into and thereby benefiting Idaho residents. In short, Idaho residents will get more of their
money back.
63. The Lifeline service offered by enTouch Wireless also provides important
benefits that are especially needed by low-income Idaho residents in this time of economic
downturn. As the Commission is aware, the Dow Jones Average, a primary indicator of the
health of the economy, has been at low ebb for a considerable period of time. Savings accounts,
upon which many depend for emergencies and retirement, have significantly eroded. The
availability of a mobile telephone will be critical to the efforts of the unemployed as they search
for other employment opportunities. Without a regular paycheck, wireless telephone service
would become a luxury beyond the means of many of those persons.
64. enTouch Wireless' Lifeline program will enable thousands of residents to obtain
wireless service which would otherwise be unavailable to them. The economic circumstances
indicate that low-income individuals, now more than ever, can greatly benefit from the
advantages offered by enTouch Wireless' Lifeline service thus allowing those adversely
impacted by the failing economy or job loss to have access to a free wireless service to assist in
emergency situations, facilitate job search efforts, and to maintain contact with family members.
65. It is also a commonly accepted fact that in today's market, 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
27
''
person seeking employment the ability to be contacted by potential employers, and provides end
users with the ability to contact emergency service providers, regardless of location.
66. Finally, designation of en Touch Wireless as a wireless ETC will serve the public
interest by furthering the extensive role that enTouch Wireless believes it will play in the
provision of communications service to low-income consumers, transient users, and other
consumers who, due to the restrictive credit criteria, deposit requirements, and long-term
commitments of wireline and traditional wireless service providers, are without a viable
alternative and are likely to remain so.
67. enTouch Wireless will comply with the uniform eligibility criteria established in
new Section 54.409 of the FCC Rules as amended by the 2016 Lifeline Order to require that the
consumer's household income must be at or below 135% of the Federal Poverty Guidelines for a
household of that size; or the consumer, one or more of the consumer's dependents, or the
consumer's household must receive benefits from one of several specified federal assistance
programs.43 Therefore, all subscribers will be required to demonstrate eligibility based at least
on: (1) household income at or below 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 new Section 54.409(a)(2). In addition, the Company will confirm with the subscriber that
he/she is not already receiving a Lifeline service and no one else in the subscriber's household is
subscribed to a Lifeline service. enTouch already participates in the National Lifeline
Administrative Database ("NLAD") and will participate in the contemplated National Verifier
43 See Federal Communications Commission Lifeline and Link Up Reform and Modernization,
Telecommunications Carriers Eligible for Universal Service Support, Connect America Fund; Final Rule, 81
Fed. Reg. 100, 33093 (May 24, 2016) (to be codified at 47 C.F.R. § 54.409(a)(2) (listing qualifying federal
benefits to include Medicaid, SNAP, SSI, Federal Public Housing Assistance, or Veterans and Survivors
Pension Benefit).
28
: .
, '
system under the 2016 Lifeline Order. In addition to the eligibility criteria above, pursuant to
Section 54.410, low-income residents of Tribal lands may self-certify as to their residency on
Tribal lands.
68. enTouch Wireless will implement certification policies and procedures that enable
consumers to demonstrate their eligibility for Lifeline assistance to Company personnel as
detailed in the 2016 Lifeline Order, together with any additional state certification
requirements.44 Consistent with federal requirements, enTouch Wireless requires customers to
certify at the time of service activation and annually thereafter that they: (1) are the head of
household; (2) participate in one of the state-approved means tested programs; (3) will be
receiving Lifeline-supported services only from enTouch Wireless; (4) do not currently receive
Lifeline support; and (5) will notify enTouch Wireless in the event that they no longer participate
in the qualifying program.
69. If enTouch Wireless 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 and in compliance with any state dispute resolution procedures
applicable to Lifeline termination, and give the subscriber 30 days to demonstrate continued
eligibility.45 A demonstration of eligibility must comply with the annual verification procedures
found in Section 54.41 O(f), including the submission of a certification form.46
70. Furthermore, enTouch Wireless commits to comply with the FCC's 60-day non-
usage policy, as described in the Company's Approved Compliance Plan under current rules, and
44 Id. at 33093-94 ( to be codified at 47 C.F.R. § 54.410).
45 2012 Lifeline Reform Order at 1143; 47 C.F.R. § 54.405(e)(I).
46 47 C.F.R. §54.410 (effective April 2, 2012).
29
in the future as permitted under the 2016 Lifeline Order for activities such as completion of an
outbound call or usage of data, purchase or minutes or data, and sending a text message to
establish "usage."47
ENTOUCH WIRELESS WILL COMPLY WITH
ALL ANNUAL REPORTING REQUIREMENTS
71. Consistent with the requirements of 47 C.F.R. § 54.422 and Appendix (C) of
Commission Order No. 29841, enTouch Wireless will comply with state and federal annual
reporting requirements, including the recent 2016 Lifeline Order's requirements to certify
compliance with applicable minimum service standards by December 1, 2016 under 47 C.F.R. §
54.416.48
72. No party to this Application is subject to denial of federal benefits pursuant to
Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. § 862.
73. The proposed effective date of designation of enTouch Wireless as an ETC 1s
thirty (30) days from the date of this Application or as soon as practicable.
WHEREFORE, having demonstrated herein that enTouch Wireless satisfies all the
conditions of eligibility necessary for designation as an ETC in Idaho, and having shown that the
public interest and universal service interests of the telecommunications consumers of the State
of Idaho, including tribal consumers, will be properly served, enTouch Wireless respectfully
requests that the Commission promptly grant this Application and designate Boomerang
Wireless, LLC d/b/a enTouch Wireless as a wireless eligible telecommunications carrier
including tribal areas within the designated Service Area.
47 See Federal Communications Commission Lifeline and Link Up Reform and Modernization.
Telecommunications Carriers Eligible for Universal Service Support. Connect America Fund; Final Rule, 81
Fed. Reg. 100, 33091 (May 24, 2016) (to be codified at 47 C.F.R. § 54.407).
48 Id. at 33094-95 (May 24, 2016) (to be codified at 47 C.F.R. §§ 54.416 and 422).
30
' ..
8998200_2
Dated this 8th day of August, 2016.
Respectfully Submitted,
By:~~-~ -------'------7, __ k __
Brian T. Hansen, #6087
Holland & Hart LLP
800 W. Main Street, Suite I 750
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Thorvald A. Nelson
Holland & Hart LLP
6380 S. Fiddlers Green Circle, Suite 500
Greenwood Village, CO 8011 I
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
and
J. Andrew Gipson
Jones Walker, LLP
I 90 E. Capitol Street, Suite 800 (3920 I)
P. 0. Box 427
Jackson, Mississippi 39205-0427
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Boomerang Wireless LLC
dlb/a enTouch Wireless
31
L '
STATE OF IOWA
COUNTY OF LINN
ATTESTATION
PERSONALLY came and appeared before me, the undersigned party in and for the
jurisdiction aforesaid, the within named Kimberley Lehrman who after being duly sworn by me
stated under oath as follows: that I am President of Boomerang Wireless, LLC d/b/a enTouch
Wireless ("enTouch Wireless"); that I executed the foregoing pleading for and on behalf of
enTouch Wireless; that I am authorized to execute and file said pleading; and that the matters and
things set forth in said pleading are true and correct to the best of my knowledge, information and
belief.
SWORN TO AND SUBSCRIBED before me on this the __6__day of August, 2016.
Al$" JULIA REDMAN-CARTER ~ i Commission Number 733855 , • , My ColMlission Expires
1owt-April 7, 2017
My Commission Expires:
\ :
' '
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
EXHIBITS
Service Area
Articles of Incorporation
Officers
FCC Compliance Plan
Advertising Terms of Service
Terms of Service
Affected Tribal Governments/Regulatory Agencies
\'
Exhibit A
Service Area
I '
..
Exhibit A
Page I of 9
Saskatchewan
,• ·-·! t
• 500,000+ • 100,000 to "99,999
50,000 m 99,999 • 10,000 to 49,999
ltol0.000
0 33.J ... , 100 --
I '
~-·-·~··: .... .:·
..!.,~;~~~~f DA ::<>~7·.\ ..
Exhibit A
Page 2 of 9
Saskatdlewan
100
''
Exhibit A
Page 3 of 9
. '
/''>~,.;~~;~.;t> .. < r··-... :: ..
\.~---.L·L{})\i/;};
. . .... ~ •,,
Exhibit A
Page 4 of 9
Saskatchewan
. '
STATE SHORT SWITCH
ID BOITIDGD
ID BOISID35
ID BOISID37
ID BOISID81
ID BOISIDMA
ID BOISIDMA
ID BOISIDMA
ID BOISIDMA
ID BOISIDMA
ID BOISIDMA
ID BOISIDMA
ID BOISIDMA
ID BOISIDMA
ID BOISIDPZ
ID BOISIDZX
ID BOIUIDKZ
ID BRLYIDMA
ID BSCYIDOB
ID CRALID01
ID CRALIDXX
ID CRALIDXX
ID CRALIDXX
ID CRALIDXX
ID CRALIDXX
ID CRALIDXX
ID CRALIDXX
ID CRALIDXX
ID CRALIDXX
ID CRALIDXX
ID CRALIDXX
ID CRALIDXX
ID IDFLIDMA
ID KNWCWAXA
ID KTCHIDBC
ID LSTNIDAK
ID PCTLIDMA
ID PCTLIDMA
ID RPRTIDXC
ID SPKNWA01
ID SPKNWA01
ID SPKNWA01
ID SPKNWADZ
ID SPKNWAKY
ID SPKNWAOB
ID SPKNWAOB
ID STATIDMA
ID TWFLIDSG
ID WESRID04
ID ABRDIDXC
ID ALBNIDXC
ID ALMOIDXC
ID ARBNIDXC
ID ARCOIDXC
ID BNFYIDXX
ID BOVLIDXX
ID BRUNIDXC
ID BYVWIDXX
ID CARYIDXC
Boomerang Wireless, LLC.
Idaho Proposed Wire Center List
2016-07-20
OCN_NAME
SYRINGA NETWORKS, LLC -ID
TW TELECOM OF IDAHO LLC -ID
360NETWORKS (USA) INC. -ID
CTC TELECOM, INC.
BANDWIDTH.COM CLEC, LLC -ID
AT&T LOCAL
MCIMETRO ACCESS TRANSMISSION SERVICES LLC -ID
LEVEL 3 COMMUNICATIONS -ID
PAC -WEST TELECOMM, INC. -ID
YMAX COMMUNICATIONS CORP. -ID
BROADVOX-CLEC, LLC -ID
NEUTRAL TANDEM-IDAHO, LLC -ID
TC SYSTEMS, INC. -ID
ELECTRIC LIGHTWAVE, LLC DBA INTEGRA TELECOM -ID
MCLEODUSA TELECOMMUNICATIONS SERVICES, INC.-ID
TW TELECOM OF IDAHO LLC -ID
RED-BAN COMMUNICATIONS, LLC -ID
EL TOPIA COMMUNICATIONS, LLC-ID
ONEEIGHTY NETWORKS, INC.
360NETWORKS (USA) INC. -ID
EL TOPIA COMMUNICATIONS, LLC -ID
LEVEL 3 COMMUNICATIONS -ID
TIME WARNER CABLE INFORMATION SERVICES (IDAHO), ID
XO IDAHO, INC.
SPRINT COMMUNICATIONS COMPANY, L.P. -ID
ZAYO BANDWIDTH NORTHWEST, INC.
YMAX COMMUNICATIONS CORP. -ID
TW TELECOM OF IDAHO LLC -ID
MCIMETRO ACCESS TRANSMISSION SERVICES LLC -ID
AT&T LOCAL
TC SYSTEMS, INC. -ID
FRETEL COMMUNICATIONS, LLC -ID
LEVEL 3 COMMUNICATIONS -ID
COX IDAHO TELCOM, LLC -ID
XO IDAHO, INC.
LEVEL 3 COMMUNICATIONS -ID
MILLENNIUM NETWORKS, LLC -ID
PROJECT MUTUAL TEL. COOP. ASSN. INC. -ID
LEVEL 3 COMMUNICATIONS -ID
PAC -WEST TELECOMM, INC. -ID
MCIMETRO ACCESS TRANSMISSION SERVICES LLC
XO IDAHO, INC.
BANDWIDTH.COM CLEC, LLC -ID
360NETWORKS (USA) INC. -ID
EL TOPIA COMMUNICATIONS, LLC -ID
FRETEL COMMUNICATIONS, LLC -ID
PROJECT MUTUAL TEL. COOP. ASSN. INC. -ID
RURAL NETWORK SERVICES, INC. -ID
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
ALBION TELEPHONE CO. DBAATC COMMUNICATIONS
ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS
DIRECT COMMUNICATIONS ROCKLAND, INC.
ALBION TELEPHONE CO. DBA ATC COMMUNICATIONS
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
CENTURYTEL GEM STATE INC-ID DBA CENTURYLINK -ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
Exhibit A
Page 5 of 9
CATEGORY RC ABBRE
CAP BOISE
CLEC BOISE
CLEC POCATELLO
CLEC BOISE
CLEC POCATELLO
CLEC POCATELLO
CLEC POCATELLO
CLEC BLACKFOOT
CLEC CALDWELL
CLEC CALDWELL
CLEC BOISE
CLEC BOISE
CLEC BOISE
CLEC TWIN FALLS
CLEC POCATELLO
CLEC CALDWELL
CLEC POCATELLO
CLEC POCATELLO
CLEC COERDALENE
CLEC OROFINO
CLEC OROFINO
CLEC OROFINO
CLEC BAYVIEW
CLEC BAYVIEW
CLEC BAYVIEW
CLEC BONERSFRRY
CLEC SANDPOINT
CLEC COERDALENE
CLEC COERDALENE
CLEC COERDALENE
CLEC COERDALENE
CLEC IDAHOFALLS
CLEC COTTONWOOD
CLEC KETCHUM
CLEC LEWISTON
CLEC POCATELLO
CLEC POCATELLO
CLEC BURLEY
CLEC LEWISTON
CLEC LEWISTON
CLEC LEWISTON
CLEC JULIAETTA
CLEC LEWISTON
CLEC ROCKCREEK
CLEC LEWISTON
CLEC IDAHOFALLS
CLEC TWIN FALLS
CLEC WEISER
ILEC ABERDEEN
ILEC ALBION
ILEC ALMO
ILEC ARBON
ILEC ARCO
ILEC BONERSFRRY
ILEC BOVILL
ILEC BRUNEAU
ILEC BAYVIEW
ILEC CAREY
l '
STATE SHORT SWITCH
ID CHLSIDXC
ID CLFKIDXX
ID CMBRIDXC
ID CRALIDXX
ID CSCDIDXC
ID DERYIDXX
ID DNLYIDXC
ID DRGSIDMA
ID DUBSIDXC
ID EKBNIDXC
ID ELBAIDXC
ID FILRIDAA
ID FRDMWYXC
ID FRFDIDXC
ID FRFDWAXA
ID FRLDIDXX
ID GENSIDXX
ID GLFYIDCO
ID GRVWIDXC
ID GRVYIDXC
ID HAMRIDXC
ID HLBKIDXC
ID HLSTIDXC
ID HMDLIDXC
ID HOPEIDXX
ID HOWEIDXC
ID HRBNIDXC
ID HRSNIDXA
ID HYLKIDXX
ID IRWNIDXC
ID JLTIIDXA
ID KLGRIDXC
ID KLLGIDXX
ID KNDRIDXX
ID LEDRIDXC
ID LENRIDXA
ID LWMNIDXC
ID MALTIDXC
ID MCCLIDXC
ID MCKYIDXC
ID MDVAIDXC
ID MLCYIDXC
ID MLLNIDXX
ID MNDKIDXC
ID MNVWIDXC
ID MOORIDXC
ID MRNGIDXC
ID MSCWIDXX
ID NFRKIDXC
ID NWMDIDXC
ID NWPTWAXX
ID OKLYIDXC
ID ORFNIDXC
ID PARMIDXC
ID PARSIDXC
ID PAULIDXC
ID PLMRIDXX
ID PNHRIDXA
Boomerang Wireless, LLC.
Idaho Proposed Wire Center List
2016-07-20
OCN_NAME
CUSTER TELEPHONE COOPERATIVE, INC.
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
CAMBRIDGE TELEPHONE COMPANY
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
COLUMBINE TELCO OBA SILVER STAR COMMUNICATIPMS
MUD LAKE TELEPHONE COOPERATIVE ASSOICATION, INC.
CUSTER TELEPHONE COOPERATIVE, INC.
ALBION TELEPHONE CO. DBAATC COMMUNICATIONS
FILER MUTUAL TELEPHONE CO.
SILVER STAR TELEPHONE CO., INC.
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
FRONTIER COMMUNICATIONS NORTHWEST INC. -WA
FARMERS MUTUAL TELEPHONE CO.
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
RURAL TELEPHONE CO.
CENTURYTEL GEM STATE INC-ID OBA CENTURYLINK-ID
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
MUD LAKE TELEPHONE COOPERATIVE ASSOICATION, INC.
ALBION TELEPHONE CO. DBAATC COMMUNICATIONS
FILER MUTUAL TELEPHONE CO.
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
ALBION TELEPHONE CO. OBA ATC COMMUNICATIONS
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
SILVER STAR TELEPHONE CO., INC.
POTLATCH TELEPHONE CO., INC.
MUD LAKE TELEPHONE COOPERATIVE ASSOICATION, INC.
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
POTLATCH TELEPHONE CO., INC.
CENTURYTEL OF IDAHO, INC. OBA CENTURYLINK
INLAND TELEPHONE CO.
CAMBRIDGE TELEPHONE COMPANY
ALBION TELEPHONE CO. OBA ATC COMMUNICATIONS
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
ALBION TELEPHONE CO. OBA ATC COMMUNICATIONS
MIDVALE TELEPHONE EXCHANGE, INC.
ALBION TELEPHONE CO. DBAATC COMMUNICATIONS
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
PROJECT MUTUAL TELEPHONE COOP. ASSOCIATION, INC.
MUD LAKE TELEPHONE COOPERATIVE ASSOICATION, INC.
ALBION TELEPHONE CO. DBAATC COMMUNICATIONS
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
CENTURYTEL OF IDAHO, INC. OBA CENTURYLINK
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
FRONTIER COMMUNICATIONS NORTHWEST INC. -WA
PROJECT MUTUAL TELEPHONE COOP. ASSOCIATION, INC.
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
DIRECT COMMUNICATIONS ROCKLAND, INC.
PROJECT MUTUAL TELEPHONE COOP. ASSOCIATION, INC.
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
Exhibit A
Page 6 of 9
CATEGORY RC ABBRE
ILEC CHALLIS
ILEC CLARK FORK
ILEC CAMBRIDGE
ILEC COERDALENE
ILEC CASCADE
ILEC DEARY
ILEC DONNELLY
ILEC DRIGGS
ILEC DUBOIS
ILEC ELK BEND
ILEC ELBA
ILEC FILER
ILEC ALPINE
ILEC FAIRFIELD
ILEC ROCK CREEK
ILEC FRUITLAND
ILEC GENESEE
ILEC PRAIRIE
ILEC GRANDVIEW
ILEC GARDEN VLY
ILEC HAMER
ILEC HOLBROOK
ILEC HOLLISTER
ILEC HOMEDALE
ILEC ' HOPE
ILEC ARCO
ILEC HORSEHBEND
ILEC HARRISON
ILEC HAYDENLAKE
ILEC IRWIN
ILEC JULIAETIA
ILEC KILGORE
ILEC KELLOGG
ILEC KENDRICK
ILEC LEADORE
ILEC LENORE
ILEC LOWMAN
ILEC MALTA
ILEC MCCALL
ILEC MACKAY
ILEC MIDVALE
ILEC MALAD
ILEC MULLAN
ILEC MINIDOKA
ILEC MONTEVIEW
ILEC ARCO
ILEC MARSING
ILEC MOSCOW
ILEC SALMON
ILEC NEW MEADOWS
ILEC ALBENI
ILEC OAKLEY
ILEC OROFINO
ILEC PARMA
ILEC PARIS
ILEC PAUL
ILEC PLUMERWRLY
ILEC KELLOGG
' ' . '
STATE SHORT SWITCH
ID PRLKIDXX
ID PRRVIDXX
ID PSFLIDXX
ID PTLTIDXX
ID RCFDIDXC
ID RKLDIDXC
ID RPRTIDXC
ID RTHDIDXX
ID SLMNIDXC
ID SNPNIDXX
ID SPFDIDXC
ID SPLKIDXX
ID STATIDMA
ID STMRIDXX
ID SWETIDXC
ID TROYIDXX
ID TRTNIDXC
ID WAYNIDXC
ID WLDRIDXC
ID WLLCIDXX
ID WRLKIDXC
ID BOISID62
ID BOISIDW
ID BRLYIDAS
ID CRALIDEM
ID MNVWWYXC
ID PCTLIDMA
ID PCTLIDMA
ID PSFLIDAA
ID SDSPIDAS
ID SPKNWAGQ
ID TWFLIDSG
ID AMFLIDMA
ID BLFTIDMA
ID BLSSIDMA
ID BNCRIDMA
ID BOISIDMA
ID BOISIDNW
ID BOISIDSW
ID BOISIDWE
ID BRLYIDMA
ID BUHLIDMA
ID CLWLIDMA
ID CRGMID01
ID CSFRIDMA
ID CTWDID01
ID DECLIDMA
ID DWNYIDMA
ID DYTNIDMA
ID EAGLIDNM
ID EDHZIDMA
ID EMMTIDMA
ID FKLNIDMA
ID FRTHIDMA
ID GAVLID01
ID GDNGIDMA
ID GLFYIDMA
ID GRACIDMA
Boomerang Wireless, LLC.
Idaho Proposed Wire Center List
2016-07-20
OCN_NAME
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
CENTURYTEL GEM STATE INC-ID OBA CENTURYLINK-ID
DIRECT COMMUNICATIONS ROCKLAND, INC.
PROJECT MUTUAL TELEPHONE COOP. ASSOCIATION, INC.
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
CENTURYTEL OF IDAHO, INC. OBA CENTURYLINK
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
FREMONT TELCOM CO
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
POTLATCH TELEPHONE CO., INC.
MUD LAKE TELEPHONE COOPERATIVE ASSOICATION, INC.
SILVER STAR TELEPHONE CO., INC.
CITIZENS TELECOM IDAHO-FRONTIER COMM OF IDAHO
FRONTIER COMMUNICATIONS NORTHWEST, INC. -ID
MIDVALE TELEPHONE EXCHANGE, INC.
SPRINT SPECTRUM L.P.
LEAP WIRELESS INTL, INC. OBA CRICKET COMM, INC.
SYRINGA WIRELESS, LLC
LEAP WIRELESS INTL, INC. OBA CRICKET COMM, INC.
UNION TELEPHONE COMPANY
SYRINGA WIRELESS, LLC
GOLD STAR COMMUNICATIONS, LLC
SPRINT SPECTRUM L.P.
GOLD STAR COMMUNICATIONS, LLC
SPRINT SPECTRUM L.P.
SYRINGA WIRELESS, LLC
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
Exhibit A
Page 7 of 9
CATEGORY RC ABBRE
ILEC PRIESTLAKE
ILEC PRIEST RIV
ILEC BLUEBELL
ILEC POTLATCH
ILEC RICHFIELD
ILEC ROCKLAND
ILEC RUPERT
ILEC RATHDRUM
ILEC SALMON
ILEC SANDPOINT
ILEC SPRINGFLD
ILEC SPIRITLAKE
ILEC ASHTON
ILEC ST MARIES
ILEC SWEET
ILEC TROY
ILEC TERRETON
ILEC WAYAN
ILEC WILDER
ILEC WALLACE
ILEC WARM LAKE
PCS POCATELLO
PCS BOISE
PCS BURLEY
PCS COERDALENE
PCS POCATELLO
PCS POCATELLO
PCS DRIGGS
PCS SANDPOINT
PCS IRWIN
PCS LEWISTON
PCS TWIN FALLS
RBOC POCATELLO
RBOC BLACKFOOT
RBOC TWIN FALLS
RBOC POCATELLO
RBOC BOISE
RBOC BOISE
RBOC BOISE
RBOC BOISE
RBOC BURLEY
RBOC TWIN FALLS
RBOC CALDWELL
RBOC CRAIGMONT
RBOC TWIN FALLS
RBOC COTTONWOOD
RBOC BURLEY
RBOC POCATELLO
RBOC POCATELLO
RBOC BOISE
RBOC TWIN FALLS
RBOC EMMETT
RBOC POCATELLO
RBOC IDAHOFALLS
RBOC GRANGEVL
RBOC TWIN FALLS
RBOC MT HOME
RBOC POCATELLO
t '
STATE SHORT SWITCH
ID HALYIDMA
ID HGMNIDMA
ID IDCYIDMA
ID IDFLIDMA
ID INKMIDMA
ID JERMIDNM
ID KMBRIDMA
ID KOSKID01
ID KTCHIDMA
ID KUNAIDMA
ID LAPWID01
ID LHSPIDMA
ID LSMNIDMA
ID LSTNIDSH
ID MCCMIDMA
ID MDTNIDMA
ID MELBIDMA
ID MRDNIDMA
ID MRTGIDMA
ID MTHOIDMA
ID MTHOIDSO
ID MTPLIDMA
ID NMPAIDMA
ID NPMOIDMA
ID NZPRID01
ID PCTLIDMA
ID PCTLIDNO
ID PSTNIDMA
ID PYTTIDMA
ID RBRTIDMA
ID RGBYIDMA
ID RIRIIDMA
ID RVSDIDMA
ID RXBGIDMA
ID SDSPIDMA
ID SHLYIDMA
ID SHSHIDMA
ID STARIDNM
ID THTCIDMA
ID TWFLIDMA
ID WESRIDMA
ID WNDLIDMA
ID BLFTID01
ID BOISID15
ID BOISID37
ID BOISIDMA
ID BOISIDMA
ID BOISIDMA
ID BOISIDTH
ID BOISIDTH
ID BOISIDVP
ID BRLYIDAB
ID CRALIDAB
ID CRALIDAB
ID CRALIDBF
ID CRALIDCY
ID EAGLIDAA
ID GAVLIDAX
Boomerang Wireless, LLC.
Idaho Proposed Wire Center List
2016-07-20
OCN_NAME
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
QWEST CORPORATION
CELLCO PARTNERSHIP DBA VERIZON WIRELESS -ID
T-MOBILE USA, INC.
NEXTEL COMMUNICATIONS, INC.
NEXTEL COMMUNICATIONS, INC.
ALLIED WIRELESS COMMUNICATIONS LLC DBA ALL TEL-ID
NEW CINGULAR WIRELESS PCS, LLC
JOSEPH B. MCNEAL DBA PAGEDATA
JOSEPH B. MCNEAL DBA WAVESENT, LLC
T-MOBILE USA, INC.
CELLCO PARTNERSHIP DBA VERIZON WIRELESS -ID
CELLCO PARTNERSHIP DBA VERIZON WIRELESS -ID
NEW CINGULAR WIRELESS PCS , LLC
COEUR DALENE ANSWERING SERVICE, INC.
T-MOBILE USA, INC.
CELLCO PARTNERSHIP DBA VERIZON WIRELESS -ID
WASHINGTON RSA NO. 8 LIMITED PARTNERSHIP
Exhibit A
Page 8 of 9
CATEGORY RC ABBRE
RBOC KETCHUM
RBOC TWIN FALLS
RBOC BOISE
RBOC IDAHOFALLS
RBOC POCATELLO
RBOC TWIN FALLS
RBOC TWIN FALLS
RBOC KOOSKIA
RBOC KETCHUM
RBOC BOISE
RBOC LAPWAI
RBOC POCATELLO
RBOC RIGBY
RBOC LEWISTON
RBOC POCATELLO
RBOC BOISE
RBOC MELBA
RBOC BOISE
RBOC MURTAUGH
RBOC MT HOME
RBOC MT HOME
RBOC POCATELLO
RBOC NAMPA
RBOC NEW PLYMTH
RBOC NEZPERCE
RBOC POCATELLO
RBOC POCATELLO
RBOC POCATELLO
RBOC PAYETTE
RBOC RIGBY
RBOC RIGBY
RBOC IDAHOFALLS
RBOC BLACKFOOT
RBOC IDAHOFALLS
RBOC POCATELLO
RBOC IDAHOFALLS
RBOC TWIN FALLS
RBOC BOISE
RBOC POCATELLO
RBOC TWIN FALLS
RBOC WEISER
RBOC TWIN FALLS
WIRELESS BLACKFOOT
WIRELESS TWIN FALLS
WIRELESS CALDWELL
WIRELESS KETCHUM
WIRELESS SALMON
WIRELESS BOISE
WIRELESS POCATELLO
WIRELESS POCATELLO
WIRELESS TWIN FALLS
WIRELESS BURLEY
WIRELESS OROFINO
WIRELESS BAYVIEW
WIRELESS COERDALENE
WIRELESS COERDALENE
WIRELESS ABERDEEN
WIRELESS GRANGEVL
' '
STATE SHORT SWITCH
ID HRBNIDAB
ID IDFLIDMA
ID LSTNID13
ID LSTNIDBB
ID MLWDWAAA
ID MSCWIDDL
ID ORFNID02
ID PCTLID12
ID PCTLID26
ID PCTLIDMA
ID PCTLIDSG
ID PSFLIDAA
ID SNPNID03
ID SPKNWA01
ID SPKNWA01
ID SPKNWA98
ID SPKNWAQR
ID SWVYIDAA
ID TWFLIDMA
ID WESRIDAA
Boomerang Wireless, LLC.
Idaho Proposed Wire Center List
2016-07-20
OCN_NAME
CELLCO PARTNERSHIP OBA VERIZON WIRELESS -ID
NEXTEL COMMUNICATIONS, INC.
WASHINGTON RSA NO. 8 LIMITED PARTNERSHIP
CLARK COMMUNICATIONS, INC.
NEW CINGULAR WIRELESS PCS, LLC
WASHINGTON RSA NO. 8 LIMITED PARTNERSHIP
WASHINGTON RSA NO. 8 LIMITED PARTNERSHIP
CELLCO PARTNERSHIP OBA VERIZON WIRELESS -ID
T-MOBILE USA, INC.
CUSTER TELEPHONE COOPERATIVE, INC.
NEW CINGULAR WIRELESS PCS, LLC
NEXTEL COMMUNICATIONS, INC.
T-MOBILE USA, INC.
NEXTEL COMMUNICATIONS, INC.
ALLIED WIRELESS COMMUNICATIONS LLC OBA ALL TEL-ID
T-MOBILE USA, INC.
CELLCO PARTNERSHIP OBA VERIZON WIRELESS -ID
CELLCO PARTNERSHIP OBA VERIZON WIRELESS -ID
NEXTEL COMMUNICATIONS, INC.
CELLCO PARTNERSHIP OBA VERIZON WIRELESS -ID
Exhibit A
Page 9 of 9
CATEGORY RC ABBRE
WIRELESS HORSEHBEND
WIRELESS POCATELLO
WIRELESS LEWISTON
WIRELESS LEWISTON
WIRELESS LEWISTON
WIRELESS MOSCOW
WIRELESS OROFINO
WIRELESS POCATELLO
WIRELESS POCATELLO
WIRELESS POCATELLO
WIRELESS POCATELLO
WIRELESS SANDPOINT
WIRELESS SANDPOINT
WIRELESS LEWISTON
WIRELESS GRANGEVL
WIRELESS LEWISTON
WIRELESS LEWISTON
WIRELESS IRWIN
WIRELESS TWIN FALLS
WIRELESS WEISER
' '
' '
Exhibit B
Articles of Incorporation
' ' ..
O .. ·.:--,·-~· .
I
Exhibit B
Page 1 of 4
No. W00558689
Date: 02/08/200
8EC:RETARY OF STA.TE
490DLC-000357573
BOOMERANG WIRELESS, LLC
ACKNOWLEDGEMENT OF DOCUMENT FILED
The Secretary of State acknowledges receipt of the following docurnen
Articles of Organization
The document was filed on February 7, 2008, at 05:29 PM, to be
effective as of February 7, 2008, at 05:29 PM.
The amount of $50.00 was received in full payment of the filing fee.
'YY)~o.a A, (Y)~
MICHAELA MAURO SECRETARY OF STATE
~:;:-.:,_
' '
OZ/07/2008 18:32 PAX 3193660570 SIMMONS PERRINE Exhibl;t ~03 Page 2 ot 4
,f) '--~·
0
·c}
367573
ARTICLES OF 0B.GANIZATlON
OF
BOOMERANG W:t:JmLF.SS, LLC
. TO ll'BE SECllTARY O"I STATE OF T.8E STATE OF IOWA:
N
0 ~ <(
. a
Pursuant to Section 301 of the Iowa Limited Liability Company Act, the undersigned adopts the ~
foll~wing Articles of Organization: . · · · ~
ARTTCLBI
NAME
The name:: of the limited liability company is BOOMERANG WIRELESS, LLC (the .. Company").
ARTJCLEII · ·
J.NJTIAL REGISTERED AGENT AND REGISTERED OFFICE
The street address of the· Company's initial registered office is 115 Third Street SE, Suite 1200,
Cedar Rapids,~ 52401-1266, and tho name of its initial registered agent at that office is David J. Zylstra.
AR.TICLEfil
:PRINCIPAL OFFICE
The street address of the Company's principal office is 7424 Hampshire Drive NE, Cedar Rapids,
IA$2402.
AltTICL.E. IV
MANAGEMENT
The business and affairs of the Company shall be governed by its Managers in the manner
de~bod in the Company's Operatipg Agreement. No Manager's, Member's, officer's or otherpersoo's
ac~on will bind the Company except as authorized purSU3llt to the Company's Operating Agreement.
,,. , ........ ,,~
~· .... ~-"
RECEIVED -TIME FEB. 7. 5:29PM
\.rJ
._.
02/07/~008 18:32 FAX [phone] SIMMONS PERRINE ExhiqjJj~4
Page 3 ;r 4
0
/ ' :i : \ __ .
ARTICLEV
PERIOD OF DURATION
The Company's existence will commence upon the acceptance of these Articles of Organa.ation
for filing with the Secretary of State of Iowa in accordance with the Iowa Limited Liability Company Act
andfwill have a perpetual duration, unless dissolved sooner in accordance with the Iowa Limited Liability
CoipPany Act.
ARTICLE VI
NoN-LL\DlLlTY AND INl>EMNIFICA'J.'lON
. A. A Manager or Member of this Company shall not be personally liable to the Company or
its ]!lirembers for any action.taken, or failw-e to take any action as a Manager or as a Member with, which
maii1agement is vested, except for liability for: (i) the amount of a :financial benefit received by a
Maiinger or Member to which the Manager or Member is not entitled; (ii) an intentional infliction of hann
· on j:hc Company; (iii) a violation of Section 807 of the Iowa Limited Liability Company Act (or any
siqlar provision of any subsequent law enacted jn Iowa); or (iv) an intentional violation of criminal law.
B. The Company may, punuant to th~ Operating Agreement or by U118l'\iroous vote of the ·
~tcrested Members, indemnify and advance expenses to each individual who is or was a Manager or
Mef,nbcr of the Company (and the he;rs, executors, personal representatives or administrators of such
in~vidual) who was or is made a party to, or is involved in any threatened, pending or completed action,
sui~ or proceeding, whether civil, orimjnal, administrative or investigative, by reason of the fact that such
peJlon is or was a Manager or Member of the Company or is or . was serving at the requen of the
Co,ppany as a M8Dager,. director, officer, partner, trustee, ~ployee or agent of another limited liability
co~pany, ootporarion, partne~hip, joint venture, trust, employee benefit plan or other entezprise.
C. The rights and authority conferred in this Articfo shall not be exclusive of any other right
w*h any person may have or hereafter acquire under any statute, provision of the Articles of
Or~anizatiou or Operating Agreement of the Comp~y. agreement, vote ofMembers,_or otherwise.
D. Any repeal or amendment of this Article by the Membe.rs of the Company shall not
achjersely affect any right·or protection of a Member or officer existing at the time of such repeal or
am~dm-ent. ·
I'
ARTICLEVII
These Articles of Organization shall be effective on the date of filing.
DATED this 7-:/1.l.·day ofFebrumy, 2008.
2
RECEIVED TIME FEB. 7. 5:29PM
FILED
IOWA
SECRETARY OF STATE
/!.~ 7-tJ?
r:';~'1//H
i11ili111
, \ IDSOS CERTIFICATE OF EXISTENCE Pa~e 1 of 1 Exh101t B
Page 4 of 4
State of Idaho
li office of the Secretary of Statell
CERTIFICATE OF EXISTENCE
OF
BOOMERANG WIRELESS, LLC
File Number W-114106
I, LAWERENCE DENNEY, Secretary of State of the State of Idaho, hereby certify that I am the
custodian of the limited liability company records of this State.
I FURTHER CERTIFY That the records of this office show that the above-named limited
liability company was organized under the laws of IOWA and filed for authorization to transact
business in Idaho on 5/21/2012.
I FURTHER CERTIFY That the limited liability company's certificate of authority has not been
canceled.
Dated: 7/20/2016 4:16 PM
SECRETARY OF ST A TE
Authentic Access Idaho Document ( http://www.accessidaho.org/public/portal/authenticate.html )
Tag: b5ae5f5fT8d74087782df4aOb45d70a628f53e3e101a64e7d5a862ft)94e39aa071ce5c5babc2e499
https://www.accessidaho.org/secure/sos/corp/cert.html 7/20/2016
\ \
Exhibit C
Boomerang Officers Bios
" '
Executive Biographies
Dennis Henderson, CEO & Owner
Exhibit C
Page I of 3
Dennis Henderson is the CEO and co-founder of HH Ventures. Ready Wireless LLC and Boomerang. In this
role, Dennis is responsible for the strategic vision, executive team development, and senior relationships
with key suppliers. investors and partners. During his tenure, the company has experienced significant
growth, and has delivered profitable results to shareholders.
In his 25 year career in the telecommunications industry, Dennis has held senior level positions in high
growth, entrepreneurial companies including Mcleod USA. This background afforded him insight into both
carrier and distribution business models. including work with the leading national US wireless carriers, top tier
retailers. and C-level executives in enterprise accounts. His industry relationships and creative approach to
partnering has led Ready Wireless to become a significant aggregator of MVNO's in the United States. His
successes include building Ready Mobile PCS. a prepaid wireless brand powered by Ready Wireless. which
boasts distribution through 80K retail rooftops, a strong ecommerce business and emerging mobile
commerce revenues.
Dennis was awarded the Corridor Business Journal Entrepreneur of the Year in 2009. He holds a BA and MBA
from the University of Iowa.
Fred Haumesser, Executive Vice President & Owner
Fred Haumesser is the Exec VP of Sales and co-founder of HH Ventures. Ready Wireless LLC and
Boomerang. In this role. he has primary responsibility for revenue and margin performance of existing
business including retail and ETC partnerships. He also leads business development efforts to build new
distribution channels and partnerships. Fred's talent in networking and relationship development has led to
major national retail opportunities, including Walgreens, CVS, and Aarons as well as large white label
customers including AAA. Global Communication of America.
Fred has held senior level sales and business development positions in high growth, entrepreneurial
companies including VP Sales at ntan Wireless. Fred also has significant experience in Direct to Consumer
business models from his experience with The Allant Group.
His successes include building Ready Mobile PCS. a prepaid, wireless brand powered by Ready Wireless,
which boasts distribution through 80K retail rooftops. a strong ecommerce business and emerging mobile
commerce revenues.
Page 1 of 3
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Executive Biographies
Kim Lehrman, President Boomerang Wireless
Exhibit C
Page 2 of 3
Kim Lehrman is the President of Boomerang Wireless. In this role she is responsible for leading and
establishing Boomerang as a premier Lifeline Service provider in the country. As the Chief Marketing
Officer, Kim is also responsible for building the corporate brand and product portfolio to reach profitable
customer segments. She leads product research, vendor relationships, channel marketing and design
efforts.
Kim is an accomplished senior executive who has spent her career in high growth, entrepreneurial
companies building brands and increasing shareholder value. Before joining Ready Wireless, Kim rose to the
position of President of the third largest greeting card company in the US-Marian Heath Greeting Cards.
Her technology background includes 15 years in senior level management positions in software, internet
and telecomm companies. She was Owner/ VP Marketing in an internet start-up, LIVEware5, which was
purchased by Mcleod USA. During Parsons Technology's rapid ascent in the productivity software market,
Kim was a member of the executive team and had P&L responsibility for the retail & licensing division.
Kim graduated magne cum laude with a BBA from the University of Iowa. She has a personal interest in
organizational & talent development.
Jim Balvanz. Chief Financial Officer
Jim Balvanz is the Chief Financial Officer of HH Ventures, Ready Wireless and Boomerang Wireless. In this
role he has responsibility for financial relationships & reporting to stakeholders. He leads all budgeting,
business planning, forecasting, product profitability analysis. and revenue assurance. He is highly engaged
with regulatory compliance, and is the primary contact for legal and governmental liaison.
Jim has over 30 years of financial auditing & accounting executive experience primarily in
telecommunications & call center industries. During the fast past growth of McLeod USA he was the VP of
Finance Operations at this publicly held company. At Teleconnect. he led the financial operations as well
during a time of successful growth and profitability, which led to the company being acquired by MCI.
Jim is a graduate of University of Northern Iowa, holding a BBA. He is a CPA.
Julia Redman-Carter. Regulatorv and Compliance Officer
Julia Redman-Carter has had a successful 26 year career in the telecommunications industry, with over 20
years focused on regulatory and compliance roles. For major carriers, including US West, Mcleod USA and
PAETEC, she has worked directly with Public Utility Commissions and national organizations. Her expertise
includes translating federal and state legislation into methods and procedures that ensure the company is
aligned with regulatory requirements. She is skilled at creating audit management systems which monitor
and report on the company compliance history. The systems and processes she creates allow for broad
communication across the organization ensuring all individuals are trained in their roles related to meeting
federal and state guidelines. Julia's responsibilities over the last 15 months have been to build the en Touch
Wireless regulatory and compliance programs which are on the forefront of industry practice.
Other skill sets Julia has developed include: telecommunications interconnection negotiations, and merger
and acquisition due diligence. Her attention to detail and understanding of the legal and business
ramifications of decisions makes her a trusted partner and advisor.
Julia holds a BA Metropolitan State College in Denver, Colorado and a JD from the University of Colorado
in Boulder.
Page 2 of 3
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Executive Biographies
Dana Pinter Karasek, Vice President Administration
Exhibit C
Page 3 of 3
Dana Pinter Karasek is an experienced telecommunications executive with extensive knowledge of billing
systems, network turn ups, and cross functional strategic program management. Dana is responsible for
program management with our network, systems partners, and clients ensuring our projects are completed
on time, on budget and on specification.
Dana is a graduate of the University of Iowa and holds a BBA.
Mike Schmidt. Chief Technology Officer
Mike Schmidt has a proven track record of leading technology teams to model & build foundational
system infrastructure allowing for organizational growth. flexibility and cost management. Mike is
responsible for building a strong internal technology team to create a flexible, robust business platform. He
also manages external partners as we integrate systems and networks into our MVNO Engine.
Jake Poshusta, Director of Operations
Jake Poshusta. Director of Operations. is responsible for field audits, field support and internal process
development and implementation. With over 17 years of telecommunications experience with Verizon
Jake has managed many functions which are critical to the ETC business. These include: process
development and auditing; managing compliance teams; leading training efforts for cross functional
teams to ensure adherence to company policy. He is a graduate of Mount Mercy College with degrees in
Business Management and Accounting.
Eric Klein, Controller
Eric Klein, Controller, has 15 years of experience in the highly regulated waste management industry with
Waste Management Inc. He has also held the role of Controller for entrepreneurial companies. Eric has
proven talent for developing, communicating and auditing financial and government regulatory standards
in companies. Providing accurate, timely and complete reporting to senior management and third party
audit firms has been a centerpiece of his roles. Eric is also an experienced manager who puts internal
controls and processes in place to provide continual feedback on key metrics and legal requirements. Eric
is a graduate of Iowa State University with a BA in Accounting and he is a licensed CPA.
Kevin Rigdon. Director of Data & Systems Management
Kevin Rigdon, Director of Data & Systems Management, is a seasoned telecommunication executive with
30 years of experience managing systems, network and platform teams. At Teleconnect/MCI Kevin held
management roles in the IT organization. He also managed the billing and order management systems at
McLeod USA a large CLEC. Start-up experience includes time in New Zealand building a new phone
company called Clear Communications. At Yellow Book he helped them pivot their strategy from
publishing to online marketing. Kevin uses these experiences to guide en Touch Wireless systems and
process development to support the company growth and ensure we have management information and
reporting with high integrity.
Page 3 of3
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Exhibit D
FCC Compliance Plan
Exhibit D
• , Page 1 of 37
NEW YORK , NY
LOS ANGELES , CA
CHICAGO , IL
STAMFORD , CT
PARSIPPAN Y , NJ
BRUSSELS , BELGIUM
AFFILIATE OFFICES
MUMBAI , INDIA
VIAECFS
Marlene H. Dortch, Secretary
KELLEY DRYE & WARREN LLP
A LIMITED LIABILITY PARTNERSHIP
WASHINGTON HARBOUR, SUITE 400
3050 K STREET, NW
WASHINGTON, D.C. 20007-5108
[phone]
July 26, 2012
Federal Communications Commission
445 12th Street, S.W.
Washington, DC 20554
FACSIMILE
(202) 342 -8451
www. kel leydrye. com
DIRECT LINE : [phone]
EMAIL : [e-mail]
Re: Boomerang Wireless, LLC Revised Compliance Plan; WC Docket Nos.
09-197, 11-42
Dear Ms. Dortch:
On March 1, 2012, Boomerang Wireless, LLC ("Boomerang") submitted its
Compliance Plan outlining the measures it will take to implement the conditions imposed by the
Commission in its Lifeline Reform Order.1 On April 12, 2012, May 22, 2012, June 13, 2012 and
June 29, 2012 Boomerang submitted revised Compliance Plans to provide additional details.
Boomerang has further revised its Compliance Plan (p. 18) at the request of FCC
Staff to explain that Boomerang's customers may de-enroll from Lifeline supported service at
any time by simply calling Boomerang's toll-free customer service line. Boomerang does not
require submission of a written request by facsimile or otherwise. In addition, Boomerang is no
longer offering a 68 minute Lifeline plan and its Compliance Plan and Lifeline application form
have been revised accordingly.
Boomerang hereby re-submits its complete Compliance Plan with the above
rev1s1ons. Based on the minor nature of these changes, Boomerang reiterates its request for
expeditious approval of its Compliance Plan.
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).
I•
.. . .
Exhibit D
Page 2 of 37
KELLEY DRYE & WARREN LLP
Marlene H. Dortch, Secretary
July 26, 2012
Page Two
This letter and revised Compliance Plan is being filed electronically for inclusion
in the public record of the above-referenced proceedings. Please contact the undersigned with
any questions.
cc: Kim Scardino
Divya Shenoy
Gamet Hanly
Respectfully submitted,
John J. Heitmann
Joshua T. Guyan
Counsel to Boomerang Wireless, LLC
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
)
)
)
)
)
)
)
WC Docket No. 09-197
WC Docket No. 11-42
BOOMERANG WIRELESS, LLC REVISED COMPLIANCE PLAN
Exhibit D
Page 3 of 37
Boomerang Wireless, LLC d/b/a Ready Mobile ("Boomerang" or the "Company") is a prepaid
wireless telecommunications carrier seeking designation as an eligible telecommunications carrier
('ETC'') for the limited purpose of offering service supported by the Lifeline program.1 Boomerang
seeks to avail itself of the Federal Communications Commission's ("Commission") grant of
forbearance from the "own-facilities" requirement contained in Section 214(e)(l)(A), 2 subject to
certain conditions set forth in the Commission's Order released February 6, 2012.3 Specifically, the
Commission provided that a carrier seeking to become a Lifeline-only ETC must comply with certain
911 requirements and file a compliance plan "providing specific information regarding the carrier's
1 Boomerang currently has pending a petition for designation as a Lifeline-only ETC in certain states.
See Amended Petition of Boomerang Wireless, LLC for Designation as an Eligible
Telecommunications Carrier in Alabama, Connecticut, Delaware, the District of Columbia, New
Hampshire, New York, North Carolina, Tennessee and Virginia, WC Docket No. 09-197 (filed June 6,
2012) ('Petition''). Boomerang seeks authorization to provide Lifeline-only service to residents of
Tribal lands as well. Boomerang respectfully requests to incorporate the commitments made herein
into the pending Petition.
2 47 U.S.C. § 214(e)(l)(A).
3 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
Reform Order'').
Exhibit D
Page 4 of 37
service offerings and outlining the measures the carrier will take to implement the obligations
contained in [the] Order.',4
Boomerang submits this Revised Compliance Plan ("Compliance Plan") to detail the policies,
procedures and training programs it has developed to guard against waste, fraud and abuse in the
Lifeline program. This Revised Compliance Plan is intended to replace Boomerang's previously filed
compliance plan. Boomerang has continued to refine its planned policies and procedures for
enrolling eligible Lifeline customers and providing Lifeline services in accordance with the
Commission's Lifeline rules, has formed partnerships and has formulated and adopted internal
policies, procedures and training materials in line with the Commission's Lifeline reform. This
Compliance Plan discusses in more detail Boomerang's plans for qualifying and enrolling eligible
customers, includes more specifics about how Boomerang will review eligibility documentation and
guard against households receiving duplicate subsidies, and the process for service activation in
compliance with the Commission's new rules.
In this Compliance Plan, Boomerang will describe in more detail the mechanisms and
partnerships it already has in place to prevent duplicate benefits to the same household. Above and
beyond meeting the Commission's requirements for guarding against duplicates, Boomerang will go
a step further in its outreach by targeting currently unserved/underserved populations. A
substantial market segment has not yet been reached by current ETCs. As a result, millions of
eligible citizens need Lifeline-supported services but are not currently served by the program.
Boomerang has partnerships and established marketing outreach experience and future plans to
target this underserved population. This effort, together with Boomerang's procedures to prevent
duplicate subsidies, will serve the important public policy goals of the program to extend critical
services to Americans with the greatest needs.
Boomerang's business model, ethos and objectives support the Lifeline program and its
goals. Boomerang's commitments to comply with the Commission's Lifeline rules serve the program
4 Lifeline Reform Order ,i 368.
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Exhibit D
Page 5 of 37
and allow the Company to invest its capital in consumers who meet program eligibility requirements
now, but who require reliable, innovative, high quality services for the long haul. Boomerang is
continuously refining and improving its practices and procedures for satisfying all of the
Commission's Lifeline requirements in order to build a successful Lifeline business that serves
customers with the greatest needs.
Background
Boomerang is one of three wholly owned subsidiaries of HH Ventures LLC, an Iowa
company. 5 The other two subsidiaries are enMarket, LLC (''enMarket'') and Ready Wireless, LLC
(''Ready Wireless''). HH Ventures LLC ("HH Ventures'') is a profitable, cash flow positive wireless
telecommunications holding company, which employs forty full-time employees. The company's
core management team includes six senior executives with more than 100 years of combined
telecom experience.
Boomerang seeks ETC designation in order to provide handsets and domestic and
international voice services to low-income customers. Boomerang also intends to provide Lifeline­
only service to residents of Tribal lands. Boomerang has direct, network carrier contracts with Sprint
and Verizon, and is also negotiating a contract with a national GSM provider. The multi-carrier
wireless network platform provides robust wireless service coverage across the entire ETC footprint.
Boomerang has direct, in-depth experience with building voice, data and broadband products
directly with carriers.
HH Ventures formed enMarket in January 2012 to focus on event marketing and distribution
for ETCs. Full time employees create neighborhood events to build awareness of the Lifeline
program and to distribute phone services to eligible consumers. Event staff is trained on the
program compliance requirements, as detailed more fully below, and creates a positive community
experience. The company also diligently implements measures to prevent waste, fraud and abuse.
5 See Exhibit A for HH Holdings structure, ownership and brands.
- 3 -
Exhibit D
Page 6 of 37
In addition, the company has a national partnership to participate in Medicaid managed care
organization community events in order to reach a population with significant needs for access to
services. This unique partnership with organizations who serve Medicaid recipients is designed to
reach in person transient consumers and those who otherwise do not have access to the online,
telephone, or paper application process unless supported by another person at an in-person event.
Again, as detailed below, employees who engage with potential subscribers at these events receive
detailed and extensive training in the Commission's Lifeline eligibility, documentation and other
requirements, and how to communicate these requirements clearly to potential subscribers.
Ready Wireless offers an MVNE wholesale platform for ETCs and other non-ETC white label
partners as well as for the companies' own retail brands Ready Mobile, Ready Broadband and
Trumpet. The platform integrates technical, infrastructure and business operations in a scalable,
reliable environment. MVNO customers can select the features and capabilities that meet their
business needs. Key features include:
• multiple underlying facilities-based wireless carrier networks (Sprint, Verizon, GSM);
• an integrated operating system, which includes provisioning, inventory management,
interactive voice response (''IVR'') systems, billing, reporting;
• device certifications, procurement, warehousing, logistics;
• program management and marketing;
• additional features to enhance user experience, such as free 411 and competitively
priced international long distance; and
• access to thousands of reload locations, ensuring that ETC end user customers will be
able to purchase additional services to complement their subsidized services.
Boomerang has direct control over the databases, systems and processes controlling the customer
records, usage records, and reporting. This provides us direct ability to implement current Lifeline
guidelines as well as evolve to meet future program policy requirements.
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Exhibit D
Page 7 of 37
Ready Mobile is a national brand distributed in over 30,000 retail locations.6 The expertise
developed to meet the rigorous operational demands of publicly traded, chain accounts (i.e.
Walgreens, OJS, Meijers) is foundational to delivering superior services to ETC and other white label
partners. Boomerang offers two wireless services under the Ready Mobile brand: ReadyMobilePCS
and ReadyBroadband. ReadyMobilePCS offers data access to consumers across the country via
smart phone technology using recycled, web-enabled phones with broadband data plans. Under the
brand ReadyBroadband, the company also provides data access through devices such as laptops,
notebooks, tower computers, and a wide array of other equipment. Both smart phones and access
devices are provided with national broadband coverage and distributed through national retail chains
as well as sold on the e-commerce site (www.readymobile.com).
Boomerang has direct, network carrier contracts with Sprint and Verizon and is negotiating a
contract with a national GSM provider as well. The multi-carrier wireless network platform provides
robust wireless service coverage across the entire ETC footprint. HH Ventures and its subsidiaries
have direct, in-depth experience with building voice, data and broadband products directly with
carriers.
Boomerang is experienced in providing broadband data access to consumers across the
country. Boomerang is poised to play a part in achieving the Commission's goal of expanding
broadband access to low-income consumers. Boomerang understands that low income consumers
are not early technology adopters. Accessibility and ease of use of Boomerang's products, services
and systems allows low-income consumers to take advantage of the power of wireless technology so
that we can close the digital divide. Adding data to phone plans is a growing trend in the low­
income base of customers, but as the Commission recognizes, lags behind the national norm.
6 The history of the Ready Mobile brand goes back to Ready Mobile LLC. Ready Mobile LLC was
formed in 2005 and was focused on retail distribution of prepaid wireless products under the Ready
Mobile brand name. In May 2007, Titan Global Holdings purchased certain assets from Ready
Mobile LLC that included the Ready Mobile branding. Titan operated several other
telecommunications ventures. HH Ventures participated in a transaction by which it purchased
certain Titan assets, including the Ready Mobile brand on January 17, 2008. None of the Titan
owners are part of the HH Ventures ownership.
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Exhibit D
Page 8 of 37
Boomerang will have data availability turned on in each handset distributed to Lifeline customers
that could become the subscriber's daily access to the Internet if they should choose to add data
services to their phone.
Because the Company already has in place nationwide distribution channels and activation
processes, it is ready to offer broadband access services to low-income consumers. The Company
has competitive billing plans for smart phones and other devices, including the ability to bundle data
services on smart phones along with voice and text services. Because of the Company's established
multi-channel, multi-partner approach, it has the ability to reach eligible consumers throughout the
country. In addition, Boomerang will advertise the availability and prices of its services through a
variety of mediums, including online advertising, direct marketing campaigns, print advertising,
event-based distribution, seminars, lectures, pamphlet distribution, and meetings with government
agencies.
Compliance Plan
This Compliance Plan describes the specific measures that Boomerang intends to implement
to achieve the objectives of the Commission's Lifeline rules and policies.
I. Policy
Boomerang will comply with all certification and verification requirements for Lifeline
eligibility set forth in the Lifeline Reform Order; the Commission's Lifeline rules and policies; the
requirements, rules and policies governing the provision of Lifeline service to eligible subscribers
residing on reservations or Tribal lands; the provisions of this Compliance Plan; and all laws and
regulations governing Boomerang's provision of Lifeline-supported prepaid wireless services to
customers throughout the United States.
- 6 -
Exhibit D
Page 9 of 37
II. Unrestricted Access to Basic and E911 Services and Certification of Such Access
In the Lifeline Reform Order, the Commission stated that forbearance from the "own­
facilities" requirement is conditioned on a carrier seeking limited ETC designation "providing its
Lifeline subscribers with 911 and E911 access, regardless of activation status and availability of
minutes [and] 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" starting on the effective date of the order.7 Moreover, wireless
resellers have an independent obligation to provide access to basic and E911 service, to the extent
that the underlying facilities-based licensee has deployed the facilities necessary to deliver E911
information to the appropriate Public Safety Answering Point.8 Resellers also have an independent
obligation to ensure that all handsets or other devices offered to their customers for voice
communication are location capable.9
The Commission and consumers are hereby assured that all Boomerang Lifeline customers
will have available access to emergency calling services at the time that Lifeline service is initiated
and that such 911 and E911 access will be available from Boomerang handsets regardless of the
activation status and availability of minutes. Further, Boomerang will ensure that all handsets used
in connection with the Company's Lifeline service offering are E911-compliant. In the event that an
existing Boomerang customer does not have an E911-compliant handset, the Company will replace
it with a new 911/E911 compliant handset at no charge to the customer. Any new customer who
qualifies for and enrolls in the Lifeline program is assured of receiving a 911/E911 compliant handset
as well.
7 Lifeline Reform Order 1 373.
8 See47 C.F.R. § 20.18{m).
9 See id.
-7 -
\ \
III. Certification and Verification of Lifeline Customers' Eligibility
Exhibit D
Page 10 of37
Boomerang proposes the following Compliance Plan to implement the certification and
verification conditions outlined in the Lifeline Reform Order. Boomerang intends to keep these
measures in effect until the Commission implements its planned national eligibility database.
A. Policy
Boomerang will comply with all certification and verification requirements for Lifeline
eligibility established by states where it is designated as an ETC. In states where there are no state­
imposed requirements, no established rules or procedures in place, or in states that do not mandate
Lifeline support, Boomerang will obtain certification of eligibility at the outset and will verify
consumers' Lifeline eligibility in accordance with the Commission's requirements. Boomerang shares
the Commission's concerns about the potential abuse of the Lifeline program and is thus committed
to the safeguards stated herein, with the belief that these procedures will prevent Boomerang's
customers from engaging in such abuse of the program, inadvertently or intentionally.
B. Certification Procedures
Boomerang will implement certification procedures that enable consumers to demonstrate
their eligibility for Lifeline assistance to Boomerang employees or agents by contacting the Company
in person or via telephone, facsimile or the Internet. Although the specific process for each means
of contact differs slightly, as detailed below, regardless of the means of contact, at the point of sale,
consumers will be provided with printed information describing Boomerang's Lifeline program,
including eligibility requirements, and with instructions for enrolling. Consumers will be enrolled in
person or directed, via company literature, collateral or advertising, to a toll-free number and to the
Company's website, which will contain a link to information regarding the Company's Lifeline service
plans, including a detailed description of the program and state-specific eligibility criteria.
Boomerang's application form will identify that it is a "Lifeline" application. Except in states in which
applicants are enrolled through a designated state agency, Boomerang will have direct contact with
- 8 -
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Exhibit D
Page 11 of37
all customers applying for Lifeline service, either in person through its employees, agents or
representatives, or via the telephone (including facsimile) or mail.
Specifically, at events, Boomerang or enMarket personnel will explain the eligibility
requirements for the program, including participation in a qualifying program or earning income
below 135% of the Federal Poverty Guidelines and will verify the individual's eligibility. The
Boomerang or enMarket employees will also explain the program limitation of one Lifeline service
per household. In order to ensure potential customers are fully informed about the Lifeline program
and the eligibility process, Boomerang will provide a sufficient number of employees at each event
so that, while some individuals are handling the application and eligibility process with applicants,
other individuals are available to discuss the requirements with potential customers, answer
questions, identify appropriate documents and otherwise assist a customer in preparing for the
application/eligibility step. enMarket employees will begin educating potential subscribers as they
wait in line at events and explain the application process to prepare them. Employees are instructed
that the company has zero tolerance for waste, fraud or abuse, and that they should notify a team
lead immediately if they suspect that anyone might be providing false information or attempting to
obtain a duplicate Lifeline benefit for themselves or within the same household. At events, when a
potential subscriber reaches the front of the line, representatives will again confirm that no member
of the individual's household currently receives a Lifeline benefit from another carrier. The
representative will mention the name of major ETCs to assist applicants in determining whether they
already receive a Lifeline benefit. The representative will reiterate that Lifeline is a government
benefit, and that providing false information could subject the applicant to consequences including
penalty under perjury. After an applicant has completed the enrollment form, a representative will
check the CGM database to determine whether anyone at the same residential address currently
receives a Lifeline benefit. If so, the applicant will be asked whether the applicant is a member of a
separate household residing at the same address and to complete the form created by USAC to
certify that he or she resides in a separate household.
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' ' ' ' Exhibit D
Page 12 of 37
At events, upon completion of the application, representatives will photograph the
documentation provided by the customer to prove identity and/or address and program-or income­
based eligibility. After this information is reviewed and possibly subject to a compliance audit,
described in more detail herein, Boomerang will maintain a record of the type of documentation
reviewed to determine eligibility, but will not keep the documentation itself. Finally, representatives
will review with the customer instructions in the welcome packet for activating the service or, if the
customer explicitly requests, will activate the handset at that time. Boomerang will not seek Lifeline
reimbursement until the customer has activated the handset.
Boomerang will also be promoting sign up through online outreach. Boomerang will use
search engine optimization and targeted ad placement to reach eligible low-income consumers. To
apply for a Boomerang Lifeline service online, a customer will fill out an application, provide the
necessary information that all prospective Lifeline customers must provide, and be taken through
forms and screens that clearly explain all relevant legal eligibility requirements. If the customer is
seeking to qualify for Lifeline service based on their participation in a particular program (or income
level), the prospective customer may be able to either upload the forms from scanned documents or
print off a Document Submission worksheet and submit the documents to Boomerang where a sales
representative will input the prospective customer's information into an eligibility database (if
available for the relevant state). However, in most cases, the prospective consumer will fill out the
relevant eligibility forms on the computer, and then send copies of the records needed by
Boomerang to verify the customer's eligibility to participate in Lifeline.
With the CGM database, all applications will be processed against the only national database
compiled with over 2 million current ITC Lifeline subscribers. This real time review will identify two
types of duplicate applications: individual duplicate (i.e. same SSN, Name, DOB, etc) or duplicate
residential addresses. If the entire record is a duplicate, the applicant will receive a message that
the application has been rejected. If the residential address is a duplicate, the applicant will receive
instructions regarding the definition of household and the opportunity to complete a verification that
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' .
.. ' . Exhibit D
Page 13 of37
the applicant is a member of a unique household at that address that does not currently receive a
Lifeline benefit.
For all application processes, Boomerang has an in-house Compliance Officer and
compliance metrics to further protect against waste fraud and abuse. This includes real time review
of application submissions during events and random sampling of online and paper submissions.
Boomerang's internal team will provide another layer of review (i.e., handwriting, submission
locations, timing) to identify abuse and carry out disciplinary action.
Once the prospective customer is successfully verified by Boomerang, Boomerang will enroll
the customer in the service plan selected by the customer, and then mail the selected handset to
the customer. Along with the handset comes a welcome packet with instructions for activating the
service. Boomerang will not seek Lifeline reimbursement until the customer has activated the
handset by following the instructions detailed herein or by making an outgoing call.
For potential subscribers who avail themselves of the toll-free number to apply for service,
the IVR script will emphasize the "one Lifeline benefit per household" restriction through its
interaction with the activating customer as well as review the 60 day non-usage rule and Annual
Recertification requirements. If a customer wants more information, they will be passed to a live call
center operator. Boomerang's sales training materials for call centers will include a discussion of the
one benefit per household restriction and the need to ensure that the customer is informed of this
restriction.
Boomerang will provide Lifeline-specific training to all personnel, whether employees, agents
or representatives, who interact with actual or prospective consumers with respect to obtaining,
changing or terminating Lifeline services. The training provides an explanation of the creation and
purpose of the Lifeline program, the source of funds to provide access to qualified low-income
consumers, program-and income-based eligibility determinations, and a detailed explanation of the
one-benefit-per-household limitation. The training emphasizes the importance of clearly explaining
the eligibility criteria and limitations to applicants as well as the potential consequences for providing
-11-
' . Exhibit D
Page 14 of 37
false information on the application. Trainees learn what documentation is acceptable to verify
program-or income-based eligibility and that they must be able to communicate this information
clearly to applicants. Trainees are instructed to report to a supervisor if for any reason at all they
feel that an individual is trying to abuse the program or falsify eligibility. Trainees must ask an
applicant directly if they already have a Lifeline service, and more specifically, mention the names of
major Lifeline service providers in the geographic area, such as Safelink, Assurance, or Stand Up
Wireless. Trainees are given instruction in checking the available duplicates database to confirm
whether anyone else at that residential address is receiving a Lifeline benefit, and if so, to ask the
applicant if multiple households reside at the same address. Trainees are also given instruction
about when to provide the additional household verification form on which the applicant will certify
that his or her household is a separate economic unit and does not already receive a Lifeline benefit.
Trainees are instructed on activation procedures and restrictions, including that an account may only
be activated by the subscriber or upon the subscriber's express authorization to do so.
Boomerang personnel will take steps to ensure that applicants are eligible to participate in
the Lifeline program. All personnel who interact with current or prospective customers will be
trained to assist Lifeline applicants in determining whether they are eligible to participate based on
state-specific income-based or program-based criteria. These personnel will be trained to answer
questions about Lifeline eligibility, and will review required documentation to determine whether it
satisfies state-specific eligibility requirements using state-specific checklists. Acceptable
documentation of program eligibility includes: (1) the current or prior year's statement of benefits
from a qualifying state, federal or Tribal program; (2) a notice letter of participation in a qualifying
state, federal or Tribal program; (3) program participation documents ( e.g., the consumer's
Supplemental Nutrition Assistance Program (SNAP) electronic benefit transfer card or Medicaid
participation card (or copy thereof)); or (4) another official document evidencing the consumer's
participation in a qualifying state, federal or Tribal program.
-12 -
\ ',
' -.
ExhibitD
Page 15 of 37
Acceptable documentation of income eligibility includes the prior year's state, federal, or
Tribal tax return; current income statement from an employer or paycheck stub; a Social Security
statement of benefits; a Veterans Administration statement of benefits; a retirement/pension
statement of benefits; an Unemployment/Workmen's Compensation statement of benefits; federal
or Tribal notice letter of participation in General Assistance; or a divorce decree, child support
award, or other official document containing income information for at least three months' time.
Boomerang will establish policies and procedures to review such documentation and keep accurate
records detailing how the consumer demonstrated his or her eligibility, including collecting
information on the enrollment form about what documentation the applicant presented to
demonstrate program-based or income-based eligibility. Where Boomerang personnel conclude that
proffered documentation is insufficient to establish such eligibility, Boomerang will deny the
associated application and inform the applicant of the reason for such rejection. In the event that
Boomerang personnel cannot ascertain whether documentation of a specific type is sufficient to
establish an applicant's eligibility, the matter will be escalated to supervisory personnel at
Boomerang's corporate headquarters.
Consumers who do not complete the application process in person must return the signed
application and supporting documentation to the Company by mail, fax, email or other electronic
transmission. The Company will accept electronic signatures that meet the requirements of the
Electronic Signatures in Global and National Commerce Act, 15 U.S.C. §§ 7001-7006, and any
applicable state laws, and may verify consumers' signatures via IVR systems. Processing of
consumers' applications, including review of all application forms and relevant documentation, will
be performed under the Company's supervision by managers experienced in the administration of
the Lifeline program.
The enrollment form will include a place where the applicant must certify by his or her
signature under penalty of perjury that the applicant meets the relevant criteria and that the
-13 -
. '
' ' . ' Exhibit D
Page 16 of37
applicant's representations are true and correct.10 Applicants will also be required to initial a number
of disclosure statements intended to ensure that the applicant understands applicable eligibility
requirements-including a statement to the effect that to the best of his or her knowledge, the
applicant is not receiving Lifeline-supported service from any other Lifeline provider. Penalties for
perjury will be clearly stated on the certification form. The certification will also contain language
stating that a violation of the one-per-household requirement constitutes a violation of the
Commission's rules and will result in the consumer's de-enrollment from the program, and could
result in criminal prosecution by the United States government. Although the exact wording of the
disclosure statements described above may vary on a state-by-state basis, depending on state­
specific requirements or consultations with relevant state agencies, Boomerang plans for the
disclosures to be consistent with the following statements:
__ The information contained within this application is true and correct. I acknowledge
that providing false or fraudulent documentation in order to receive assistance is punishable
by law.
__ I understand that Lifeline is only available for one benefit per household, whether
landline or wireless. To the best of my knowledge, no one in my household is receiving
Lifeline service. I will only receive Lifeline from Boomerang and no other landline or wireless
telephone company.
__ I am not currently receiving a Lifeline telephone service from any other landline or
wireless telephone company.
__ I will not transfer my service to any other individual, including another eligible low­
income consumer.
__ I understand that I may be required to verify my continued eligibility for Boomerang's
Lifeline service at any time and that failure to do so will result in termination of Lifeline
benefits.
__ I will notify Boomerang immediately if I no longer qualify for Lifeline or if I have a
question as to whether I would still qualify.
In accordance with the Lifeline Reform Order, Boomerang will not retain copies of eligibility
documentation, but rather will maintain accurate records detailing how the customer demonstrated
his or her eligibility. Boomerang will check the eligibility of consumers seeking to enroll in Lifeline
10 A copy of Boomerang's proposed enrollment and certification form is attached at Exhibit B.
-14 -
\'
' ' ' . Exhibit D
Page 17 of 37
either by accessing electronic eligibility databases, where available, or by reviewing documentation
from the consumer demonstrating his or her eligibility for Lifeline service. Where the Company is
able to access a state or federal database to make determinations about customer eligibility, the
Company or its representative will note in its records what specific data was relied upon to confirm
the consumer's initial eligibility for Lifeline. In instances where a state agency or third-party
administrator is responsible for the initial determination of consumer eligibility, Boomerang will rely
on the state identification or database.
Boomerang personnel will assist applicants in determining whether they are ineligible to
participate in the Lifeline program because a member of the applicant's household already is
benefiting from a Lifeline discount. Boomerang will establish safeguards to prevent individual
subscribers and households from receiving more than one benefit. Boomerang personnel will
explain in prominent, plain, easily comprehensible language to all new and potential subscribers that
no consumer is permitted to receive more than one Lifeline subsidy. Boomerang will emphasize the
one-per-household restriction in its contacts with potential customers. Boomerang personnel also
will inform each Lifeline applicant that he or she may be receiving Lifeline support under another
name, and facilitate the applicant's understanding of what constitutes "Lifeline-supported service,"
and ability to determine whether he or she is already benefiting from Lifeline support by identifying
the leading wireline and wireless Lifeline offerings in the relevant market by brand name.
Boomerang's Lifeline application forms will require each applicant to provide his or her name
and primary residential address and a billing address for the service if the consumer's billing address
differs from his or her residential address. The application form will clearly state that Lifeline
participants must provide their new address to the Company within 30 days of moving. Boomerang
will incorporate this information into its customer information database.
Prior to initiating service for a customer, the Company will check the address of each Lifeline
applicant against the CGM compiled database to determine whether or not it is associated with a
customer that already receives Boomerang Lifeline service, and will then review the application to
-15 -
\ \.
\'
Exhibit D
Page 18 of 37
ascertain whether the applicant is attempting to receive Lifeline-supported service for more than one
service associated with the address. Boomerang Wireless has aligned with CGM, LLC of Roswell,
Georgia, a Lifeline service bureau, to participate in the only national effort to match ETC applications
against current ETC participants. This recognized compliance software provider is working across the
industry to help minimize duplicate service to eligible households. CGM's growing database currently
includes more than two million of the 15 million current ETC subscribers. As of this writing, it is, to
Boomerang's knowledge, the largest pooled national database.
Boomerang has contracted with CGM to check each name/address combination against its
aggregate duplicate database to confirm that the applicant is not already receiving a Lifeline subsidy
from Boomerang or any other CGM client. The database dip is done simultaneously with customer
sign-up through an API connection between Boomerang's provisioning platform and CGM. This
check ensures that each applicant is not receiving a duplicate subsidy, as well as identifying those
customers who share an address with current Boomerang customers and, therefore, may warrant
further review. If Boomerang determines that an individual at the applicant's residential address is
currently receiving Lifeline-supported service, the Company will take an additional step to ensure
that the applicant and the current subscriber are part of different households. In order to make this
demonstration, Boomerang will require applicants to complete and submit to the Company a written
document developed by USAC consistent with the Commission's directions in the Lifeline Reform
Order.11 Boomerang will deny the Lifeline application of any such individual residing at the same
address as a current Lifeline subscriber who is part of the same household and will advise the
applicant of the basis for the denial.
Prior to requesting a subsidy, Boomerang, in conjunction with CGM, will process and validate
its subsidy data to prevent duplicate same-month Lifeline subsidies. Any household that is already
receiving a Lifeline subsidy will automatically be prevented from receiving a second Lifeline subsidy
in that same month. Boomerang will immediately de-enroll any subscriber whom Boomerang knows
11 See Lifeline Reform Order ,i 84.
-16 -
\ · .. Exhibit D
Page 19 of 37
is receiving Lifeline-supported service from another ETC or knows is no longer eligible. Additionally,
each month, 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 be automatically prevented from receiving a second Lifeline subsidy
in that same month; and (2) inactive lines receiving subsidy. CGM's audits also compare all subsidy
requests to Boomerang's underlying carrier invoice to ensure that subsidies are requested only for
active lines. This process ensures that Boomerang does not request multiple subsidies from the
Universal Service Fund.
In addition, prior to requesting a subsidy, Boomerang will ensure that the customer has
activated the service in accordance with the Commission's requirements. Boomerang will provide
phone activation instructions in a welcome package provided with the handset and, at events, will
review these instructions with the customer. The activation process will allow the end user to
proactively establish service and have an opportunity to receive additional training on the device and
services available.
C. Procedures for Verification of Ongoing Consumer Eligibility
As required by the Commission's Lifeline Reform Order, Boomerang will require every
customer enrolled in the Lifeline program to verify on an annual basis that he or she receives
Lifeline-supported service only from Boomerang and, to the best of his or her knowledge, no one
else in the subscriber's household is receiving a Lifeline-supported service. Boomerang will submit
all required information to the relevant Tribal governments, as applicable, including its aggregated
re-certification data and annual re-certification results for subscribers residing on reservations or
Tribal lands. This re-certification may be done on a rolling basis throughout the year. Where
ongoing eligibility cannot be determined through access to a qualifying database either by the
Company or the state, and there is no state administrator verifying the continued eligibility of
Lifeline subscribers, the Company will recertify the continued eligibility of all of its subscribers by
contacting them-either in person, in writing, by phone, by text message, by email, or otherwise
-17 -
.. ', .. Exhibit D
Page 20 of 37
through the Internet-to confirm their continued eligibility. Such certifications may be obtained
through a written format, an IVR system, or a text message, in accordance with the Lifeline Reform
Order.12 In states where a state agency or a third party has implemented a database that carriers
may query to recertify the consumer's continued eligibility, the Company ( or state agency or third
party, where applicable) will instead query the database and maintain a record of what specific data
was used to re-certify eligibility and the date of recertification.
Boomerang will notify each of its Lifeline consumers by mail that he or she must confirm his
or her continued eligibility in accordance with the applicable requirements. The notice will explain
the actions the customer must take to retain Lifeline benefits, when Lifeline benefits may be
terminated, and how to contact Boomerang. Boomerang will provide written notice of impending
service termination to subscribers who do not respond to the annual re-certification within 30 days.
Any subscriber who does not respond to the impending termination letter within 30 days to
demonstrate that his or her Lifeline service should not be terminated will be de-enrolled from the
Company's Lifeline program.
De-Enrollment for Ineligibilitv. If Boomerang has a reasonable basis to believe that one of
its Lifeline subscribers no longer meets the eligibility criteria, Boomerang will notify the subscriber of
impending termination in writing and in compliance with any state dispute resolution procedures
applicable to Lifeline termination, and give the subscriber 30 days to demonstrate continued
eligibility.13 A demonstration of eligibility must comply with the annual verification procedures found
in new rule section 54.410(f), including the submission of a completed and signed certification form.
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 five business
days. Customers can make this request by calling the Company's customer service number and will
not be required to submit any documents.
12 See Lifeline Reform Order ,i,i 130, 132.
13 See Lifeline Reform Order, ,i 143; 47 C.F.R. § 54.405(e)(1).
-18 -
' '
., ' ' '
IV. Additional Measures to Prevent Waste, Fraud and Abuse
A. Usage Requirement
Exhibit D
Page 21 of 37
Boomerang will implement policies and procedures to ensure that it does not obtain Lifeline
support for an inactive subscriber who has failed to use his or her service in the first instance or has
discontinued using the service.
Boomerang will not seek universal service support for a qualifying low-income consumer
until that individual subscriber uses the supported service to either activate the service or complete
an outgoing call. Boomerang will provide phone activation instructions in its event and online or
paper product packages. The activation process will allow the end user to proactively activate
service and have an opportunity to receive additional training on the device and services available.
Specifically, to activate service, customers will be instructed to call the Boomerang IVR, press "2" to
activate the phone, and enter a PIN included in the Welcome Instructions the subscriber receives
with the phone a~er the eligibility and enrollment process has been completed as described above.
At that point, the IVR will notify the consumer that the Lifeline account is active. The IVR will
inform the customer that the customer must use the service in order to keep the account active and
provide options through a menu for obtaining additional information about the phone or the service
and direct the customer to the Company's website for additional information. At in-person events,
Boomerang will assist an individual with account activation upon being expressly authorized by the
subscriber to activate the service.
To comply with the Commission's continued usage requirements, Boomerang will implement
a non-usage policy whereby it will de-enroll Lifeline customers that have not used the Company's
Lifeline service for 60 days. The customer will be given a 30 day cure period before they would be
de-enrolled from the Lifeline service. Boomerang will notify its subscribers at service initiation about
the non-transferability of the phone service, its usage requirements, and the de-enrollment and
deactivation that will result following non-usage in any 60-day period of time. If no usage appears
on a Boomerang Lifeline customer's account during any continuous 60-day period, Boomerang will
-19 -
... ",
' .
Exhibit D
Page 22 of 37
deactivate Lifeline services for that customer after the 30 day notification & cure period. An account
will be considered active if during any 60-day period the authorized subscriber does at least one of
the following: makes a monthly payment; purchases minutes from Boomerang to add to an existing
pre-paid Lifeline account; completes an outbound call; answers an incoming call from anyone other
than Boomerang, its representative, or agent; or affirmatively responds to a direct contact from
Boomerang confirming that he or she wants to continue receiving the Lifeline-supported service.
Boomerang will take measures to continue to communicate with the customer to ensure the
customer understands the rules and requirements of the benefits. Boomerang has direct control
over customer databases and communication tools including: SMS messaging, outbound calling, IVR
messaging and direct mail communications. For example, if a customer has 45 days of non-usage,
Boomerang can text them to remind them about the non-usage rules.
B. Consumer Education with Respect to Duplicates
As required by the Lifeline Reform Order, Boomerang will establish safeguards to prohibit
more than one supported service for each household. In addition to its verification and certification
procedures, and to better ensure that customers understand the Lifeline service restrictions with
respect to duplicates, Boomerang will implement measures and procedures to prevent duplicate
Lifeline benefits being awarded to the same household, including use and development of an
appropriate database.
Specifically, Boomerang personnel will emphasize the one-per-household restriction in their
direct sales contacts with potential customers. At the point of sale, potential customers will be
provided with printed information describing Boomerang's Lifeline program, including eligibility
requirements, and instructions for enrolling. As part of these printed materials, Boomerang will also
reinforce the one-Lifeline-benefit-per-household limitation. Materials from USAC, that have been or
will be developed pursuant to the Lifeline Reform Order, may also be provided at the point of sale as
dictated by a customer's responses. Boomerang will likewise reinforce and explain the one-per­
household restriction in its marketing materials. The Company will emphasize in plain, easily
-20 -
Exhibit D
Page 23 of 37
comprehensible language that: (1) Lifeline is a federal benefit; (2) Lifeline service is available for
only one benefit or subscription 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; and ( 4) a household is not permitted to receive Lifeline benefits from
multiple providers. Boomerang will also include in its marketing materials (see Exhibit C)
substantially the following language in clear, easily understood language: the offering is a Lifeline­
supported service; that Lifeline is a government assistance program; that only eligible consumers
may enroll in the program; that documentation is necessary for enrollment; and the program is
limited to one benefit per household, consisting of either wireline or wireless service. Finally,
Boomerang will disclose the company name under which it does business and the details of its
Lifeline service offerings.
C. Internal Audit and Compliance Training for Boomerang Customer Service
In addition to detailed and thorough employee training, Boomerang will impose disciplinary
actions on employees who fail to abide by the requirements for determining eligibility for the Lifeline
benefit. Beyond the instructions for field and event training, Boomerang with provide its customer
service personnel with internal audit and compliance training. For incoming paper applications,
Boomerang will have a 100% compliance checklist to check applications for fraud and duplication.
The employee must check whether all fields on the certification and enrollment form are complete,
whether all necessary eligibility documents are attached, whether the eligibility documents align with
the information on the form, whether the handwriting is unique, whether all attestations are
initialed, and whether the form is signed.
For in-person and event outreach, in addition to the onsite eligibility determinations, a
Boomerang compliance officer will randomly check a representative sample of 3% to 10% of
applications as an additional check for errors or omissions or any sign of fraud. If the compliance
officer detects potential fraud or abuse in the application process, the affected applications will be
denied.
-21-
'· ",
' '
V. Lifeline Offering
Exhibit D
Page 24 of 37
Boomerang's marketing efforts will be focused on finding and serving eligible consumers
using distribution models designed to reach the target population on a broad geographic basis.
Creating a trusted brand and service through community outreach is a primary methodology for
educating and soliciting customers. Boomerang will enroll Lifeline customers through several
different marketing channels. Boomerang's current business model and plans for providing Lifeline
service are based on reaching about 85% of its subscribers in person, through event marketing
targeting currently underserved populations. Boomerang anticipates that, while most of its outreach
will succeed via direct contact with consumers, potential subscribers will also be able to avail
themselves of a toll-free number (inbound telemarketing) or website to obtain enrollment
information. Boomerang also has plans to offer its services through retail stores and agents who
understand the underserved consumers in communities Boomerang would service as an ETC.
National retail chains have expressed interest in partnering with Boomerang to support the Lifeline
service and outreach to underserved eligible populations. Boomerang has partnered with retailers to
use parking lots as locations for event-based outreach.
enMarket, Boomerang's sister event marketing and distribution company, will use
demographic segmentation information to identify locations of populations with great need. The
neighborhood marketing program will reach Tier 3 and Tier 4 and smaller communities where the
population has not seen an influx of Lifeline service providers. enMarket will organize positive and
informative neighborhood events to create a local presence.
The Company has a long history with retail distribution. If Boomerang is granted ETC
designation, it is prepared to work with several national companies to explore unique, focused
Lifeline program marketing.
Boomerang will offer its Lifeline service in the states where it is designated as an ETC and
throughout the coverage area of its underlying carriers. Boomerang has direct underlying
agreements with Sprint and Verizon today. Negotiations are underway for the addition of a national
-22 -
'• •,
GSM provider.
Exhibit D
Page 25 of 37
The company will use these network relationships to ensure a good product
experience for ETC consumers.
The Company's Lifeline offering will provide eligible customers with the following two Lifeline
plans: (1) 125 units that rollover where 1 minute equals 1 unit and 1 text equals 1 unit, and (2) 250
units without rollover where 1 minute equals 1 unit and 1 text equals 1 unit. Customers will have
the capability of purchasing additional bundles of minutes in the following denominations:
Denomination
Da s of Use
Minutes
Peak Minutes
NW Miniutes
Texts
Units Min+ Text
In addition to free voice services, Boomerang's Lifeline plans will include a free handset and
the following features: caller ID, call waiting and voicemail. Boomerang will turn on the data
capability for all of our handsets. This will allow customers to add a data plan to their phone service.
As a provider of Lifeline services to residents of Tribal lands, Boomerang will pass through
the full Tribal support amount to qualifying residents of Tribal lands, and under no circumstances
will it collect from the Universal Service Fund more than the rate charged to Tribal subscribers.
VI. Demonstration of Financial and Technical Ability to Provide Lifeline Services
Revised Commission Rule 54.202 requires carriers seeking designation as a Lifeline-only ETC
to demonstrate their technical and financial capacity to provide the supported service. Among the
factors that the Commission will consider are whether the applicant previously offered services to
non-Lifeline consumers, how long the applicant has been in business, whether the applicant intends
to rely exclusively on USF disbursements to operate, whether the applicant receives or will receive
-23 -
, .... ,
Exhibit D
Page 26 of 37
revenue from other sources, and whether it has been subject to enforcement action or ETC
revocation proceedings in any state.
Boomerang's parent company, HH Ventures, is a privately held cash-flow-positive wireless
telecommunications holding company. HH Ventures has been providing prepaid wireless
telecommunications services to non-Lifeline subscribers since 2008. Its core management team
includes six senior executives with significant telecommunications experience, and the company
employs 40 full time employees.
Boomerang currently provides prepaid wireless services to more than 350,000 subscribers,
including more than 50,000 retail customers. The company currently provides a complete
wholesale, MVNE platform to several ETCs and other white label partners.
Boomerang does not intend to rely exclusively on USF disbursements to operate, as it
receives revenue from providing other services. For the 2011 calendar year, Boomerang and its
sister company received no direct USF reimbursement for Lifeline support; 17% of revenue was
generated from wireless resale services provided to ETCs, 14 52% of revenue was generated from
wireless retail services, and 31 % of revenue was generated from other non-regulated telecom
services. Boomerang has not been subject to enforcement actions or ETC revocation proceedings in
any state.
Boomerang certifies that it will comply with all of the requirements of newly amended
Commission Rule 54.202. Pursuant to Commission Rule 54.202(a)(l)(i) Boomerang certifies that it
will comply with the service requirements applicable to the support it receives. Further, Section
54.202 requires that an ETC demonstrate its "ability to remain functional in emergency situations,
including a demonstration that it has a reasonable amount of back-up power to ensure functionality
without an external power source, is able to reroute traffic around damaged facilities, and is capable
of managing traffic spikes resulting from emergency situations."
14 In 2011, Boomerang only entered into wholesale MVNE arrangements with designated ETCs. This
year, Boomerang has entered into arrangements with other, non-ETC, white label partners.
-24 -
·,, •,
Exhibit D
Page 27 of 37
Boomerang will remain functional in emergencies. Back-up systems are in place to ensure
full functionality in the event of a loss of power or network functionality. And, Boomerang's
switching facilities are housed in a carrier-class data center with fully redundant power and HVAC, a
controlled temperature and humidity environment, fire-threat detection and suppression, year-round
critical monitoring and secure access with biometric security. The facility features redundant
generators and redundant fiber optic connectivity. The data center is a reinforced concrete building
located in a secure area and collocated with the area electrical utility headquarters. It is powered
from separate paths independent of any one electrical generation plant. All systems within the
facility are implemented on redundant servers, each with redundant data network and power.
Direct carrier access with Sprint and Verizon networks provides additional tools to escalate
network or hardware issues encountered on a local or regional basis. Contractual arrangements
include direct escalation processes for tiered support depending on outage severity and number of
customers affected.
Section 54.202 also requires ETC applicants to demonstrate that they will satisfy applicable
consumer protection and service quality standards. Boomerang hereby commits to comply with the
Cellular Telecommunications and Internet Association's Consumer Code for Wireless Service.
-25 -
', ',
Conclusion
Exhibit D
Page 28 of 37
Boomerang's Compliance Plan meets the conditions set forth in the Lifeline Reform Order
and promotes public safety by ensuring that Lifeline customers have access to 911 and E911
service. Boomerang requests that the Commission expeditiously approve the Company's Compliance
Plan and grant its pending ETC Petition so that Boomerang may begin providing the benefits of
Lifeline service to qualifying low-income consumers.
July 26, 2012
Respectfully submitted,
Chief Financial Officer
Boomerang Wireless, LLC
[phone]
[e-mail]
-26 -
'.. •,
I
Boomerang Wireless
LLC -*Seeking ETC
ldesignation
* 100% held by HH
Ventures
Exhibit A
HH Ventures LLC
~Holding company =11
I
I
enMarket LLC
-*Event Marketing
* Distribution
*100% held by HH
Ventures
-27 -
I
Exhibit D
Page 29 of 37
Ready W ireless
LLC
_,_
* MVNE Wholesale
ETCs
White Label
Ready Mobile™
Ready Broadband™
Trumpet
* Business operations
* 100% held by HH Ventures
' .
' .. \\
Exhibit D
Page 31 of 37
BOOM ., 955 Kacena Road. Suite A
Hiawatha, IA 52233
www.boomerang-wireless.com
Lifeline Self-Certification Form
• To enroll in the Lifeline America program you need to complete this form.
• The information is only used to certify with the Federal Communications
Commission (FCC) that you are participating in the program with us.
Lifeline Service Disclosure
Lifeline Program
I -
I Office Use Only
PLACE PHONE ID
STICKER HERE I
I
--------------------I
Lifeline is a government assistance program and willfully making false statements to obtain the benefit can result in fines, imprisonment, de­
enrollment or being barred from the program. Only one lifeline benefit is available per household. 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. Violation of the
one per household limitation constitutes a violation of the Federal Communications Commission's rules and will result in your de-enrollment from
the program, and lifeline is a non-transferable benefit and you may not transfer this benefit to any other person, regardless if they qualify for
Lifeline.
STEP 1: Applicant Information USE BLACK OR BLUE INK ONLY
Full Name: Phone:
Residential Address: Email:
Circle one:
Permanent Address
Temporary Address
I (No PO Box. Residence9itTribal lands must orovide descriotive address.)
City: New/ Conv?
State: New Phone:
Zipcode: ESN:
Billing Address: (if different) (if different) Last 4 SSN or Tribal ID number:
City/ State/ Zipcode: Your birthdate:
__ (init) I acknowledge and consent to Boomerang Wireless divulging my name, telephone number and address to the Universal Service Administrative
Company (the administrator of the program) and/or its agents for the purpose of verifying that the subscriber does not receive more than one Lifeline
benefit. In the event that USAC identifies me as receiving more than one Lifeline subsidy per household, I acknowledge and understand that all carriers
may be notified so that I may select one service and be de-enrolled from the other.
*Applicants living on Tribal lands who lack a social security number may instead provide an official Tribal government identification card number.
STEP 2: Certifications. I oarticioate in the followimz oublic assistance orol!rams /check one I:
Supplemental Nutrition Assistance Program {SNAP) National School Lunch Program {NSL)
Supplemental Security Income (551) Medicaid
Low-Income Home Energy Assistance program {LIHEAP) Food Distribution Program on Indian Reservations
Section 8 Federal Public Housing Assistance Tribally administered TANF
Temporary Assistance for Needy Families (TANF) Bureau of Indian Affairs General Assistance
Tribally administered Head Start (meeting the income
qualifications of Head Start.)
I My household income is at or below 135% offederal guidelines. I provided documentation confirming my household income level.
Number of people in your household: (add $5,346 per additional person above 6 to determine income guidelines)
# Persons in Household Income # Persons in Household
1 $15,080 4
2 $20,426 5
3 $25,772 6
____ (init) I am seeking Tribal lands Lifeline support and certify that I reside on Federally-recognized Tribal lands.
If you do not participate in one of these programs, and someone in your household does:
Relationship to Participant: ___________ _
Documents Reviewed for Certification: __________ ~
Name of Person Participatin.,_ ________ _
D I certify that person demonstrating program participation is a member of my household.
D I certify that the person name on the participation documentation is not already receiving a Lifeline discount.
Income
$31,118
$36,464
$41,810
r122806
....
[3nnM~'
w ;-;7l·/~ 'l -.-
ExhibitD
Page 32 of 37
STEP 3: Choose Your Plan: Choose one of the following plans. This plan will be reloaded to your phone monthly as long as you are eligible &
certified.
D 125 FREE D 250 FREE
FEATURE/ DESCRIPTION MONTHLY MINUTES MONTHLY MINUTES
• Local Calls y y
• National Long Distance y
• Voicemail y y
• Nationwide Text Y-1 text=l minute Y-1 text=l minute
• Free 411 y y
• Carry Over Minutes Month to Month y N
Step 4: Signature (read, initial & sign):
____ (init} I meet the income-based or program-based eligibility criteria for receiving Lifeline service and have provided
documentation of eligibility if required to do so.
____ (init) I understand that Lifeline is a federal government benefit program and that willfully making false statements in order to
obtain this benefit can be punished by fine or imprisonment or I may be barred from the program.
____ (init} My household will receive no more than one Lifeline-supported service. Lifeline service is available for only one
subscription per household. 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. A household is not permitted to receive Lifeline benefits from
multiple providers. I understand that violation of the one-per-household requirement constitutes a violation of the FCC's rules and
will result in my de-enrollment from the program, and could result in criminal prosecution by the United States government.
___ (init} I understand that I must notify Boomerang Wireless and provide my new address within 30 days of moving.
____ (init} If I do not have a permanent address and have supplied instead a temporary address above, I understand that
Boomerang Wireless will attempt to verify every 90 days that I continue to rely on that address, and that I must notify Boomerang
Wireless within 30 days of my new address after moving. If I do not respond to Boomerang Wireless' address verification attempts
within 30 days, I understand that I may be de-enrolled from Boomerang Wireless' Lifeline service.
___ (init} I understand that I must notify Boomerang Wireless within 30 days if (1) I cease to participate in a federal or state
qualifying program or my annual household income exceeds 135 percent of the federal poverty guidelines; (2) I receive more than
one Lifeline-supported service; or (3) Another member of my household is receiving a Lifeline benefit or (4) I for any other reason no
longer satisfy the criteria for receiving Lifeline support. I understand that I will be subject to penalties if I fail to follow this notification
requirement, including being de-enrolled from the Lifeline program.
___ (init) I understand and acknowledge that Lifeline service is a non-transferable benefit and that I may not transfer my service
to any other individual, including another low-income consumer.
___ (init} I acknowledge that I will be required to re-certify my eligibility for Lifeline benefits annually, and I may be required to
re-certify my continued eligibility for Lifeline at any time, and that failure to do so will result in the termination of my Lifeline benefits.
___ (1n1t1 I attest under penalty of perjury that the information herein is true and correct to the best of my knowledge.
Applicants Signature. ______________ _ Date ______________ _
r122806
Eligibility
~~~GN
Requirements
Lifeline is a federal benefit. You can
receive a discount on your phone service. Documentation of your eligibility
for this government assistance program is required.
1) You, or one of your dependents, participates in one of these programs:
supplemental Nutrltlo Assistance Program (SNAP) Temp:,rarr Assistance for Needy Families (TANF)
Supplemental Security Income (SSI) Na ional School unch Program (NSL)
ow-Income Heat & Energy Assistance (LIHEAP) MediCBid
Food Dtstribution Program on Indian Reser,ations. Bureau of
HOmestea!l Act lPUOllc Housing) lnctlan Affairs general assistance. Tribally a<1m1n1stered TANF or
Head Stan (meeting the Income-qualifying standards or Head
Start)
2) Limit 1 Lifeline benefit per household.
One Lifeline program (wireline or wireless) per household. Household is defined as
an individual or group of individuals living together at the same address and share
income and expenses. A household is not permitted to receive Lifeline benefits
from multiple providers.
3) If I am not in qualifying program, I may participate if income qualified.
# Persons in Household Income
1 $15,080
2 $20,426
3 $25,772
4 $31,118
4) Must have valid physical address.
Notify Boomerang Wireless of any change of address by calling 800-516-0414.
5) Cannot choose phone model or phone number
You are not able to choose the free handset, trade free handsets, or choose the
phone number on the free handset.
6) Recertify annually that you remain eligible for the Lifeline benefits.
Lifeline is a government assistance program. Once you receive the Lifeline benefit,
you must complete the annual recertification process. Learn more in your welcome
package.
7) Must be truthful in application process.
WARNING: If you make false statements to gain benefits, you can be punished
by fine or imprisonment or you can be barred from the Lifeline program.
8) Complete the application.
Be prepared to complete the application truthfully & accurately. You can print the
application, submit online or attend one of our neighborhood events. You will need
documentation for application process to include: Proof of identity ( i.e. Drivers
License); Program eligibility documentation: Current statement of benefits from
qualifying program, notice letter of participation, program document (i.e. SSI card),
Income eligibility documents (i.e. tax return, paycheck stub, VA benefit statements)
Exhibit D
'· Page 35 of 37
(~> PUBLIC NOTICE • llS ~ ,
Federal Communications Commission
445 12th St., S.W.
Washington, D.C. 20554
News Media Information 202 / 418-0500
Internet: http://www.fcc.gov
TTY: 1-888-835-5322
DA 12-1286
Release Date: August 8, 2012
WIRELINE COMPETITION BUREAU APPROVES THE COMPLIANCE PLANS OF BIRCH
COMMUNICATIONS, BOOMERANG WIRELESS, IM TELECOM, Q LINK WIRELESS AND
TAG MOBILE
WC Docket Nos. 09-197 and 11-42
The Wireline Competition Bureau (Bureau) approves the compliance plans of five carriers: Birch
Communications, Inc. (Birch); Boomerang Wireless, LLC (Boomerang); IM Telecom, LLC (IM); Q Link
Wireless, LLC (Q Link); and TAG Mobile, LLC (TAG). The compliance plans were filed pursuant to the
Lifeline Reform Order as a condition of obtaining forbearance from the facilities requirement of the
Communications Act of 1934, as amended (the Act), for the provision of Lifeline service.1
The Act provides that in order to be designated as an eligible telecommunications carrier for the
purpose of universal service support, a carrier must "offer the services that are supported by Federal
universal service support mechanisms ... either using its own facilities or a combination of its own
facilities and resale of another carrier's services .... "2 The Commission recently amended its rules to
define voice telephony as the supported service and removed directory assistance and operator services,
among other things, from the list of supported services.3 As a result of these amendments, many Lifeline­
only ETCs that previously met the facilities requirement by providing operator services, directory
assistance or other previously supported services no longer meet the facilities requirement of the Act.4 In
the Lifeline Reform Order, the Commission found that a grant of blanket forbearance of the facilities
requirement, subject to certain public safety and compliance obligations, is appropriate for carriers
1 See Lifeline and Link Up Reform and Modernization et al, WC Docket No.11-42 et al., Report and Order and
Further Notice of Proposed Rulemaking, 27 FCC Red 6656, 6816-17 at paras. 379-380 (2012) (Lifeline Reform
Order). A list of the compliance plans approved through this Public Notice can be found in the Appendix to this
Public Notice.
2 47 U.S.C. § 214(e)(l)(A).
3 See Connect America Fund, WC Docket No. 10-90 et al., Report and Order and Further Notice of Proposed
Rulemaking, 26 FCC Red 17663, 17692-93, paras. 77-78, 80 (2011 ); pets. for review pending sub nom. In re: FCC
11-161, No.11-9900 (10th Cir. filed Dec. 8, 2011); Connect America Fund, WC Docket No. 10-90 et al., Order on
Reconsideration, 26 FCC Red 17633, 17634-35, para. 4 (2011) ( USFIJCC Transformation Order on
Reconsideration).
4 See Lifeline Reform Order, 27 FCC Red 6812, at para. 366, App. A; USFIICC Transformation Order on
Reconsideration at para. 4. Some ETCs have included language in their compliance plans indicating that they have
facilities or plan to acquire facilities in the future. See, e.g., Blanket Forbearance Compliance Plan, WC Docket
Nos. 09-197 and 11-42, Q Link Wireless, LLC's Third Amended Compliance Plan at 4 n. 2 (filed July 30, 2012).
To the extent ETCs seek to avail themselves of the conditional forbearance relief established in the Lifeline Reform
Order, we presume they lack facilities to provide the supported service under section 54. IO I and 54.40 I of the
Commission's rules. See 47 C.F.R. §§ 54.101 and 54.401. Such ETCs must comply with the compliance plan
approved herein in each state or territory where they are designated as an ETC, regardless of their claim of facilities
for other purposes, such as eligibility for state universal service funding.
,, ..
''
Exhibit D
Page 36 of 37
seeking to provide Lifeline-only service.5 Therefore, in the Lifeline Reform Order, the Commission
conditionally granted forbearance from the Act's facilities requirement to all telecommunications carriers
seeking Lifeline-only ETC designation, subject to the following conditions: (1) compliance with certain
911 and enhanced 911 (E911) public safety requirements; and (2) Bureau approval of a compliance plan
providing specific information regarding the carrier and its service offerings and outlining the measures
the carrier will take to implement the obligations contained in the Order.6
The Bureau has reviewed the five plans listed in the Appendix for compliance with the conditions
of the Lifeline Reform Order, and now approves those five compliance plans.7
Filings, including the Compliance Plans identified in the Appendix, and comments are available
for public inspection and copying during regular business hours at the FCC Reference Information
Center, Portals II, 445 1th Street, S. W., Room CY-A257, Washington, D.C. 20554. They may also be
purchased from the Commission's duplicating contractor, Best Copy and Printing, Inc., Portals II, 445
1th Street, S.W., Room CY-B402, Washington, D.C. 20554, telephone: [phone], fax: (202) 448-
5563, or via email www.bcpiweb.com.
People with Disabilities: To request materials in accessible formats for people with disabilities
(Braille, large print, electronic files, audio format), send an email to [e-mail] or call the
Consumer & Governmental Affairs Bureau at [phone] or TTY [phone].
For further information, please contact Divya Shenoy, Telecommunications Access Policy
Division, Wireline Competition Bureau at [phone] or TTY [phone].
-FCC-
5 See Lifeline Reform Order, 27 FCC Red 6813-6817 at paras. 368-381 .
6 See id. at paras. 373 and 389. Subsequently, the Bureau provided guidance for carriers submitting compliance
plans pursuant to the lifeline Reform Order. Wireline Competition Bureau Provides Guidance for the Submission of
Compliance Plans Pursuant to the Lifeline Reform Order, WC Docket Nos. 09-197 and 11-42, Public Notice, 27
FCC Red 2186 (Wireline Comp. Bur. 2012).
7 The Commission has not acted on any pending ETC petitions filed by these carriers, and this Public Notice only
approves the compliance plans of the carriers listed above. While these compliance plans contain information on
each carrier's Lifeline offering, we leave it to the designating authority to determine whether or not the carrier's
Lifeline offerings are sufficient to serve consumers. See Lifeline Reform Order, 27 FCC Red 6679-80, 6818-19 at
paras. 50 and 387.
2
,, ...
' '
Petitioner
Birch Communications,
Inc.
Boomerang Wireless,
LLC
IM Telecom, LLC
Q Link Wireless, LLC
TAG Mobile, LLC
APPENDIX
Compliance Plans
As Captioned by Petitioner
Further Amended Compliance Plan of
Birch Communications, Inc.
Boomerang Wireless, LLC Revised
Compliance Plan
IM Telecom, LLC d/b/a lnfiniti Mobile
Compliance Plan
Q Link Wireless, LLC's Third
Amended Compliance Plan
TAG Mobile, LLC Compliance Plan
3
Date of Filing
July 2, 2012
July 26, 2012
July 5, 2012
July 30, 2012
July 26, 2012
Exhibit D
Page 37 of 37
Docket
Numbers
09-197; 11-42
09-197; 11-42
09-197; 11-42
09-197; 11-42
09-197; 11-42
' '
Exhibit E
Advertising
~
enTouch
WIRELESS
Exhibit E
Page 1 of 14
POWERED BY BOOMERANG WIRELESS MARKETING MATERIALS
I
'
' PHONE INTERNET MINUTES!
Not ,l L1folmo s11pportod fw11t>fit Supportod '>y Lrfelrno 'Jent.>f1t Supported by Life/me benefit
Provided by enTot1t 11 W1mloss A goverr1mont '>/JOnsorod program A government sponsored program
YOU MAY BE ELIGIBLE FOR THIS BENEFIT IF YOU PARTICIPATE IN:
FOOD STAMPS • MEDICAID • FREE LUNCH • PUBLIC HOUSING • SSI • OR MEET INCOME REQUIREMENTS
DATE: ______ _
TIME: (M-F) ____ _
(Sat} _____ _
PLACE: _______ _
enTouch Wireless
will provide a
FREE
PHONE I
~
enTouch
WIRELESS I]
PUASEMOTE:'t'tN.i-•oti.~to-ui.n.~A-g,:,-bl<>tllc.ltClorf'ICO<T-.~­,....."""*"""'" • ....,ICl.-too,g,,,c,.Lilomelt ...... lOONf' ........ Ol'II*'~.-'°"-'"" -yo.tcanl'Clll<Ml*·"'-~'11~s.......-.. ailatllo_ ........ ...-.cei.1o<:a1od.wflicnc.n 1>11muc..1i.,.,l:iuld,ngl,-.~.•~-11,-p110r11t1tOU!of-O-i,,...,~dllll911frcm•tandline~
Flyer - 8.5 x 11
Poster -11 x 17
www.entouchwireless.com
' . ~
enTouch
WIRELESS
POWERED BY BOOMERANG WIRELESS
Banner - 6' x 2'
www.entouchwireless.com
Exhibit E
Page 2 of 14
MARKETING MATERIALS
' . ~
enTouch
WIRELESS
Exhibit E
Page 3 of 14
POWERED BY BOOMERANG WIRELESS MARKETING MATERIALS
~
enTouch Eligibility Requirements
WIRELESS
POWERED BY BOOMERANG WIRELESS
Lifeline is a government sponsored benefit. You can receive
a discount on your phone service.
1) You, or one of your dependents, participates in one of these programs:
Supplemental Nutrition Assistance Program {SNAP) Medicaid
Supplemental Security Income (SSI) Food Distribution Program on Indian Reservations
Low-Income Heat & Energy Assistance (UHEAP) Tribally Administered TANF
Section 8 Federal Public Housing Assistance Bureau of Indian Affairs General Assistance
Temporary Assistance for Needy Families (TANF) Tribally Administered Head Start
National School Lunch Program (NSL) Free Program Only (meeting the income qualifications of Head Start)
There may be additional programs for various states. See state spectfic Lifeline application for a full list of appUcabte programs.
2) Limit 1 Lifeline benefit per household.
One Lifeline program (wireline or wireless) per household. Household is defined as an
individual or group of individuals living together at the same address as one economic unit.
Lifeline service is non-transferable.
3) If I am not in qualifying program, I may participate if income qualified.
# Persons in Household Income # Persons in Household Income
1 $16,038 4 $32,805
2 $21,627 5 $38,394
3 $27,216 6 $43,983
Incomes above reflect 135% of the 2016 FPO for income. See state specif'te Lifeline appltcatton to refkM:1: 150% FPG for Income for applteable states.
4) Must have valid physical address.
Notify us immediately of any change of address by calling customer service.
5) Cannot choose phone model or phone number.
You are not able to choose the free handset, trade free handsets, or choose the phone
number on the free handset.
6) Keep Active.
Use your phone every 60 days to keep Lifeline benefit active.
7) Must be truthful in application process.
WARNING: If you make false statements to gain benefits, you can be punished by fine or
imprisonment or you can be barred from the Lifeline program.
8) Complete the application. Personal documents required.
Complete the application truthfully & accurately.
Documentation for application process: Proof of identity (i.e., Government Issued ID).
Program eligibility documentation: Current statement of benefits from qualifying program,
notice letter of participation, program document (i.e., SS/ card), Income eligibility documents
(i.e., tax return, paycheck stub, VA benefit statements, etc).
9) Recertify annually that you remain eligible for the Lifeline benefits.
Once you receive the Lifeline benefit, you must complete the annual recertification process.
Learn more in your welcome package.
Eligibility Flyer -8.5 x 11
www.entouchwireless.com
' '
' '•
~
enTouch
W RE LESS
POWERED BY BOOMERANG WIRELESS
Exhibit E
Page 4 of 14
MARKETING MATERIALS
~
enTouch
WIRELESS
POWERED BY SOOMERANQ WIRELESS
DISCLOSURES
YOU WILL HAVE TO VERIFY AND SIGN THIS DISCLOSURE FORM
IN ORDER TO RECEIVE YOUR LIFELINE PHONE
I acknowledge and consent to enTouch Wireless divulging my name, telephone number,
address, date of birth, last four digits of SSN or Tribal ID, amount of support being sought,
means of qualification for support, and dates of service initiation and termination to the
Universal Service Administrative Company {the administrator of the program) and/or its agents
for the purpose of verifying that the subscriber does not receive more than one Lifeline benefit.
In the event that USAC identifies me as receiving more than one Lifeline subsidy per household,
I acknowledge and understand that all carriers may be notified so that I may select one service
and be de-enrolled from the other.
I meet the income-based or program-based eligibility criteria for receiving Lifeline service and
have provided documentation of eligibility if required to do so.
I understand that Lifeline is a federal government benefit program and that willfully making false
statements in order to obtain this benefit can be punished by fine or imprisonment or I may be
barred from the program.
My household will receive no more than one Lifeline-supported service. Lifeline service is
available for only one subscription per household. 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. A household is not permitted to receive Lifeline benefits from
multiple providers. I understand that violation of the one-per-household requirement constitutes
a violation of the FCC's rules and will result in my de-enrollment from the program, and could
result in criminal prosecution by the United States government.
I understand that I must notify enTouch Wireless and provide my new address within 30 days
of moving.
If I do not have a permanent address and have supplied instead a temporary address above,
I understand that en Touch Wireless will attempt to verify every 90 days that I continue to rely on
that address, and that I must notify enTouch Wireless within 30 days of my new address after
moving. If I do not respond to enTouch Wireless' address verification attempts within 30 days,
I understand that I may be de-enrolled from enTouch Wireless' Lifeline service.
I understand that I must notify enTouch Wireless within 30 days if (1) I cease to participate in a
federal or state qualifying program or my annual household income exceeds 135% (150% for
AZ, KS, Ml, OH, TX) of the federal poverty guidelines; (2) I receive more than one Lifeline
supported service; or 3) Another member of my household is receiving a Lifeline benefit or
(4) I for any other reason no longer satisfy the criteria for receiving Lifeline support. I understand
that I will be subject to penalties if I fail to follow this notification requirement, including being
de-enrolled from the Lifeline program.
I understand and acknowledge that Lifeline service is a non-transferable benefit and that I may
not transfer my service to any other individual, including another low-income consumer.
I acknowledge that I will be required to re-certify my eligibility for Lifeline benefits annually, and
I may be required to re-certify my continued eligibility for Lifeline at any time, and that failure to
do so will result in the termination of my Lifeline benefits.
I hereby authorize enTouch Wireless to send text messages to my en Touch Wireless
number about my Lifeline benefit. Text messages sent by enTouch Wireless will not decrement
my available wireless minutes or texts. Standard voice, data and text rates will apply to all
messages to and from anyone other than the Company.
I attest under penalty of perjury that the information herein is true and correct to the best of
my knowledge.
www.entouchwireless.com
Disclosures Poster -11 x 17
www.entouchwireless.com
' ' ~
enTouch
W RE LESS
Exhibit E
Page 5 of 14
POWERED BY BOOMERANG WIRELESS MARKETING MATERIALS
Lifeline Self-Certification Form
To enroll in the Lifeline America program you need to complete this form. The information is used to certify
with the Federal Communications Commission that you are participating in Lifeline with us.
Lifeline Service Disclosure
~
enTouch
WIRELESS
POWE.RED B'I' BOOMERANG WIRELESS
Lifeline is a government assistance program and willfully making false statements to obtain the benefit can result in fines, imprisonment, de-enrollment
or being barred from the program. Only one Lifeline benefit is available per household. 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. Violation of the one per household
limitation constitutes a violation of the Federal Communications Commission's rules and will result in your de-enrollment from the program, and
Lifeline is a non-transferable benefit and you may not transfer this benefit to any other person, regardless if they qualify for Ufeline.
Certifications: I have proof of participation in one of the following public assistance programs (check one):
Supplemental Nutrition Assistance Program (SNAP) National School Lunch Program (NSL) Free Program Only
Supplemental Security Income (SSI) Food Distribution Program on Indian Reservations
Temporary Assistance for Needy Families (TANF) Tribally Administered TANF
Section 8 Public Housing Assistance Bureau of Indian Affairs General Assistance
Medicaid Tribally Administered Head Start
Low-Income Energy Assistance Program (LIHEAP) Meeting the income qualifications of Head Start
My household income is at or below 135% of 2016 federal poverty guidelines. I provided documentation confirming my household income level.
# Persons in Household Income
1 $16,038
2 $21,627
3 $27,216
Signature (Read, Initial & Sign)
# Persons in Household
4
5
6
Income
$32,805
$38,394
$43,983
See state specific Ufeline
application to reflect 150% FPG for
Income for appHcable states.
___ (init) I acknowledge and consent to en Touch Wireless divulging my name, telephone number, address, date of birth, last four digits of SSN or
Tribal ID, amount of support being sought, means of qualification for support, and dates of service initiation and termination to the Universal Service
Administrative Company (the administrator of the program) and/or its agents for the purpose of verifying that the subscriber does not receive more than
one Lifeline benefit. In the event that USAC identifies me as receiving more than one Lifeline subsidy per household, I acknowledge and understand
that all carriers may be notified so that I may select one service and be de-enrolled from the other.
___ (init) I meet the income-based or program-based eligibility criteria for receiving Lifeline service and have provided documentation of eligibility
if required to do so.
___ Qnit) I understand that Lifeline is a federal government benefit program and that willfully making false statements in order to obtain this benefit
can be punished by fine or imprisonment or I may be barred from the program.
___ (init) My household will receive no more than one Lifeline-supported service. Lifeline service is available for only one subscription per
household. 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. A household is not permitted to receive Lifeline benefits from multiple providers. I understand that
violation of the one-per-household requirement constitutes a violation of the FCC's rules and will result in my de-enrollment from the program,
and could result in criminal prosecution by the United States government.
___ (init) I understand that I must notify en Touch Wireless and provide my new address within 30 days of moving.
___ (init) If I do not have a permanent address and have supplied instead a temporary address above, I understand that en Touch Wireless will
attempt to verify every 90 days that I continue to rely on that address, and that I must notify enTouch Wireless within 30 days of my new address after
moving. If I do not respond to en Touch Wireless' address verification attempts within 30 days, I understand that I may be de-enrolled from en Touch
Wireless' Lifeline service.
___ (init) I understand that I must notify en Touch Wireless within 30 days if (1) I cease to participate in a federal or state qualifying program or my
annual household income exceeds 135% (150% for />Z., KS, Ml, OH, TX) of the federal poverty guidelines; (2) I receive more than one
Lifeline-supported service; or (3) Another member of my household is receiving a Lifeline benefit or (4) I for any other reason no longer satisfy the
criteria for receiving Lifeline support. I understand that I will be subject to penalties if I fail to follow this notification requirement, including being
de-enrolled from the Lifeline program.
___ (init) I understand and acknowledge that Lifeline service is a non-transferable benefit and that I may not transfer my service to any other
individual, including another low-income consumer.
___ (init) I acknowledge that I will be required to re-certify my eligibility for Lifeline benefits annually, and I may be required to re-certify my
continued eligibility for Lifeline at any time, and that failure to do so will result in the termination of my Lifeline benefits.
___ (init) I hereby authorize the Company to send text messages to my Company provided wireless number about my Lifeline benefit.
Text messages sent by the Company will not decrement my available wireless minutes or texts. Standard voice, data and text rates will apply to
all messages to and from anyone other than the Company.
___ (init) I attest under penalty of perjury that the information herein is true and correct to the best of my knowledge.
One Sheet -8.5 x 11 -Pg. 1
www.entouchwireless.com
' ' ~
enTouch
W RE LESS
POWERED BY BOOMERANG WIRELESS
Exhibit E
Page 6 of 14
MARKETING MATERIALS
Lifeline Free Monthly Minutes
Choose Your Plan: Choose one of the following plans. This plan will be reloaded
to your phone monthly as long as you are eligible & certified .
. :,
FEATURE/ DESCRIPTION 250 FREE MONTHLY MINUTES 1000 PLUS BUNDLE PLAN
Local Calls y y
National Long Distance y y
Voicemail y y
Nationwide Text Y -1 text = 1 min. Y -1 text = 1 min.
Free 411 y
Data Enabled (website and email) y
Carry Over Minutes Month to Month N
P1ans availab~ my vary by state. See state spectt'tc Lifeline application for availab~ plans.
Top Up with Airfair
'f\.~ ~re-~~ i te-'1-t or Ja--m?
Look for these brands at your nearest retailer or call
Customer Service to top up.
enTouch Customer Service:
866.488.8719
y
y
N
Find top ups at a Airfair Retailer near you!
www.entouchwireless.com
Price TalkfTextUnlts
•s 0
'5 •10 •20 '30 '50
•10 0
•20 1500
air-Pair •so ~
w l,olo••
reload ~our L lei ,u, phone •so ~
Data
100-
500,ni,
0
0
4.,
Days
30
30
30
30
30
1 Unll•1 T..too1 Voloe...._
For the complete Terms of Service go to entouchwireless.com or call Customer Service at
866-488-8719 or dial 611 free from your Lifeline phone.
Lifeline is a government assistance program. en Touch Wireless represents the Lifeline service in your state.
PLEASE NOTE: You hawi to be eligible to receive Lifeline services. A current goverrment benefit card or Income docl.lTlent and your goverrment issued ID is needed to sign up. Lifeline is available to only cr,e
person per household. When yoo receive the service, you cannot transfer it to another person. 911 Emetgerq, Service is available where wireless service is located, which coo be reduced by buildings. weather,
mountains, etc. If yoor phone Is out of range in an emergency dial 911 from a landtine phone.
One Sheet -8.5 x 11 -Pg. 2
www.entouchwireless.com
' .
"•.
~
enTouch
W RE LESS
Exhibit E
Page 7 of 14
POWERED BY BOOMERANG WIRELESS MARKETING MATERIALS
~
enTouch Terms of Service -Summary
W I RELESS
POWERED BY li00r.1£1U,N0 WIJIELEI&
Lifeline is a government sponsored benefit. You can receive
a discount on your phone service.
Terms of Service for Communication Services -Effective as of May 6, 2013 until replaced.
The Terms of Service are part of your agreement with en Touch Wireless for Mobile Services.
Use of Services and Equipment: Services and equipment may not be used for any
unlawful, fraudulent or abusive purpose. en Touch Wireless service is for personal use only.
Phone Number: We assign telephone numbers and other personal identifiers in connection with the
Services. You do not have any property right to your phone number. It may be changed or reassigned.
Phones and Other Equipment: The only warranties on the phones or other equipment are any limited
warranties extended by the manufacturers.
Lost or Stolen Equipment: If your phone or other equipment is lost or stolen, you must notify us by
calling en Touch Wireless Customer Service. You are responsible for all charges for Services provided
to the Number for the lost or stolen equipment. We will deactivate Services to the Number upon
notification to us of any loss or theft. If the equipment is later found, we may require that you exchange
it for another phone or other equipment before we reactivate Services (if we do reactivate Services),
as well as require you to pay a reactivation or replacement fee of $25.00.
Service, Prepaid Services: Upon certification of eligibility, and continuing eligibility, you will receive
free voice services. This positive account balance will be applied every 30 days on the anniversary
of your service activation. You must maintain an ACTIVE ACCOUNT every 60 days: by having voice
usage (inbound or outbound); by buying additional product; or by responding affirmatively to our queries
regarding your desire to continue to receive services. You are required to recertify annually.
Misuse of Service: You have certified your eligibility to receive free services under the federally
funded Lifeline program. If your eligibility to participate in this program changes, you agree to
immediately notify enTouch Wireless at 1.866.488.8719. Lifeline is a non-transferable benefit. You agree
not to use the service or modify your handset in any fraudulent, unlawful, harassing, or abusive purpose,
or in such a way as to create damage or risk to our business.
Exchange Policy: Defective handsets or other defective equipment provided at no cost to you may
be eligible for exchange. To exchange a defective handset, please call Customer Service at
1.866.488.8719 to obtain a Return Authorization and shipping instructions.
Concerns, Complaints or Disputes: If you have questions, concerns, comments or complaints, please
contact enTouch Wireless at www.enTouchwireless.com or call Customer Care by dialing 611 from your
cell phone (does not use your Lifeline minutes) or dialing 1-866-488-8719 from another phone.
Termination of Access: en Touch Wireless may terminate your access without notice, for any conduct
that en Touch Wireless, in its sole discretion, believes to be harmful: to individual users; to en Touch
Wireless or any of its affiliates; to any rights of en Touch Wireless or any third party; or that violate
applicable laws.
Plan Offerings & Rates:
TRIBAL
FEATURE/ DESCRIPTION 250 FREE MONTHLY MINUTES 1000 PLUS BUNDLE PLAN
Local Calls Y y
National Long Distance Y y
Voicemail Y y
Nationwide Text Y - 1 text = 1 min. Y - 1 text = 1 min.
Free 411 Y y
Data Enabled (website and email) Y y
Carry Over Minutes Month to Month N N
Plans available my vary by state. See state specific Lifeline application for available plans.
PUASENOTE:You,-.IDbe~IO-Lif ...... _Aeurl'9fllp.-......... 1b9nefilc.dgrJ1Comedocum ... 1and,o.,,~1il....:ilDiar-.-.d101,g,,up.L.iflliineisawilllble1D~-i-sonpa,
~.Whalyou-tt,ewr-...;e,youcanno1irw.Nr~IO.-ICl!IM,rpwsot1..ll11Em9rgencySelw:ei&a,llilllblawhotr9_._,lr'IICelSioc:.9d.who;:h"911ber.,;IUQ9dbybuilding,5,~.mo.,ni.,,.,e1c:..H'IQI.II'
phcwle1Soutr:l~..,..,~di.ill11.,om•landlnll~.
Terms of Service Poster -11 x 17
www.entouchwireless.com
' '
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enTouch
V-1 R E L E S S
Exhibit E
Page 8 of 14
PC>WERED BY BOOMERANG WIRELESS MARKETING MATERIALS
Abbreviated Terms of Service for Communication Services
The Terms of Service are part of
your agreement with enTouch
Wireless for Mobile Services.
Use of Services and Equipment Services and
equipment may not be used for any unlawful,
fraudulent or abusive purpose. enTouch Wireless
service is for personal use only.
Phone Number. We assign telephooe numbers
and other persooal identifiers in cormection with
the Services. You do not have any property right
to your phcne number. It may be changed or
reassigned.
Phones and Other Equipment The only
warranties on the phooes or other equipment
are any limited warranties extended by the
manufacturers.
Lost or Stolen Equipment If your phone or
other equipment is lost or stolen. you must notify us by camng en Touch Wireless Custaner
Support You are responsible fer all charges for
Services provided to the Number for the lost or
stolen equipment. We will deactivate Services to
the Number upon notification to us of any loss
a theft. If the equipment is later found, we may
require that you exchange it for another phone
or other equipment before we reactivate
Services (if we do reactivate Services), as well as
require you to pay a reactivation or replacement
fee of $25.DO.
Service, Prepaid Services: Upon certification of
eligibility, and continuing eligibility, you will receive
free voice services. This positive account balance
will be applied every 30 days on the anniversary
of your service activation. You must maintain
an ACTIVE ACCOUNT every 60 days; by having
voice usage (inbound or outbound); by buying
additional product; or by responding affirmatively
to our queries regarding your desire to continue
to receive services. You are required to recertify
annually.
Misuse of Service: You have certified your
eligibility to receive free services under the
federally funded lifeline program. If your
eligibility to participate in this program changes.
you agree to immediately notify enTouch
Wireless at 1.866.488.8719. Lifeline is a
non-trasferable benefit. You agree not to use
the service or mcx:lify your handset in any
fraudulent, unlawful, harassing, or abusive
Effective asof 5/6/13 until replaced.
purpose, or in such a way as to create damage
or risk to our business.
Exchange Policy: Defective handsets or other
defective equipment provided at no cost to
you may be eligible for exchange within 30 days
of receiving the device. To exchange a
defective handset, please can Customer Support
at 1.866.488.8719 to obtain a Retum
Authorization and shipping instructicfls.
Concerns, Complaints or Disputes: If you have
questions. concerns, comments or
canplaints, please contact enTouch Wireless
at www.entouchwireless.com or call Custcrner
Suppcrt by dialing 611 from your ceU phone
(does not use your Lifeline minutes) or dialing
1-866-488-8719 from another phone.
Termination of Access: enTouch Wireless may
terminate your access without notice, for any
ccnduct that enTouch Wireless, in its sole
discretion, believes to be harmful: to ndividual
users; to en Touch Wireless or any of its affiliates;
to any rights of en Touch Wireless or any third
party; or that violate applicable laws.
For the compfete Terms of Service visit
www.entouchwl~ess.com.
State Commission Contact:
For unresolved questions or complaints you may contact
the applicable state COTimission or contact. ~
Arizona Corporation Commission
1200W. Wmhlngton St.• Phoenix, AZ. 85007
local: 602.542.4251 Toll F,-: B00.222.7CXXl
Colorado Public Utilities Commission Consumer Affairs
1560 BroDdwny • Suite 250 • 0enV8f, Colorado 80202
Toi F,-: 800.456.0858 Fu: 303.894.2532
E-mail: dorQ...poc_complaintsOstate.co.us
Kansas Corporation Commission,
Office of Public Affairs and Consumer Protection
1500 SW Armwt-i Rooo • Topeka, KS 66604
Top9!ka: 785.271.3140 Toll F,-: B00.662.oo27
HNring/llPNCh Impaired at TOO Kans.. Rlll-,c.m.r. 800.766.3777
Minnesota Public Utilities Commission
121 ,.. Place E., Suile 350 · Saini Ptaul, MN 55101-2147
Toi F,-: 800.657.3782 Fu: 651.297.7073
Oklahoma Corporation Commission
P.O. Box 52000 • OklohomaCity, OK 73152-2000
Locat 405.521.2331 Toll F,-: 800.522.8154
Washington State Office of the Attorney General
800 5"'Ave. Suile 2000 · Seo.Ille, WA• 98104-3188
Toll FrN: 1.800.551.4636 (ITT Washington only)
Local Phone: [phone]
WNhington Stat11 ~ Semee for thll H .. tng Impair.ct 1.800.833.6388
www.ntg.wa.gov
Phone#:
MyESN:
~ enTouch
WIRELES S
866.488.8719
•Your minutes will be added every 30 days from this date.
•sus minutos estaran agregados cada 30 dias desde esta fecha.
Bag Insert -folded to 5.5 x 4.25 -Pg. 1
en Touch
WIRELESS
POWERED IY IOOMERANQ WIRELEII
www.entouchwireless.com
wkt k.rre,\'I.~ "'°v-i?
What should I do when I receive my phone?
V<lhen you receive your phone in the mail, follow the
instructions below. Once you call to Activate, your Lifeline
Minutes will be activated on yrur phone.
What features come with my phone?
Yru will have excellent coverage with national wireless
networks. Free 411 calls. Voicemail, Call Forwarding,
Three Way Calling, Data Enabled & other features.
What do I receive with my service?
Yru will receive your free handset that is loaded monthly
with your Lifeline Minutes. Every 30 days after your
activation date, your balance will autanatically reload
on your phone as long as yru have an ACTIVE ACCOUNT.
tt you have not used yrur phone in 60 days your Lifeline
service will be deactivated.
Can I get more minutes, text or data?
You can add voice minutes, texts, and data at any time. See
backside for more talk, text & data plans. Look fer these brands
to top up with at your local retailers or call Customer Support
at 884U88..8719 to top up.
www.entouchwireless.com
' ' ~
enTouch
Yi R E L E S S
Exhibit E
Page 9 of 14
POWERED BY BOOMERANG WIRELESS MARKETING MATERIALS
i
~
enTouch
WIRELESS Follow these easy steps to get started. We will help you get started, answer
questions and give options to purchase more talk, text or data.
Welcome to the Lifeline Program.
Activate Phone: Call 319.471.4802 before leaving event
to activate.
Phone Number: Your phone number is located on the
inside of the battery door and circled on the outside
sticker of the bag you received your phone in.
Free Minutes: You get free minutes monthly from
Lifeline. (Programs vary by state.) Minutes will
automatically reload on your anniversary date.
Keep Active: Make a call on your phone regularly to keep
plan active. No use in 60 days will deactivate your device.
Check Balance: Dial 611 on your Lifeline phone.
Press 1 to hear balance.
Your Phone Company is enTouch Wireless
powered by Boomerang Wireless.
Questions? Dial 61 1 on your Lifeline phone or call
866.488.8719 from a land line phone.
Active el Telefono: Uame aJ 319.471.4802 antes de salir del
evento para activar su tel0fono.
Nllmero de Telefono: Su nUmero de tel0fono se indica en
el interior de la tapa de la bateria y tambi0n esta encerrado
en un cfrculo en la etiqueta exterior de la balsa en que le
entregaron su tel0fono.
Minutes Gratis: Cada mes, Lifeline le da minutes gratis. (Los
programas varian segUn el estado.) Los minutes se cargan
automaticamente cada mes en su fecha de aniversario.
Mantengale Active: Use el tel0fono con regularidad para
mantener activo su plan. Su dispositivo se desactivara si
no lo usa en 60 dfas.
Cempruebe: Marque 611 desde su tetefono Lifeline.
Presione 1 para escuchar el balance.
Su Compallia de Telefono es enTouch Wireless
powered by Boomerang Wireless.
Preguntas? Marque 611 desde su tel8fono Lifeline
o llame 866.488.8719 desde un tel0fono.
Questions? Access Information from Your Phone.
Dial 611 from your Lifeline phone or call 866.488.8719.
c.Tiene preguntas? Marque 611 desde su telefono Lifeline o llame 866.488.8719.
Press 1 to hear your air
time balance.
Presione 1 para escuchar
su balance de minutos.
Press 2 to add minutes
to your cell phone.
Presione 2 para anadir
minutos a su telefono
celular.
Want More Talk, Text or Data?
i,Necesita mas minutos?
Es fitci1 af'iadirle minutos a su teli!fooo. Vea los detalles del plan al dofSo.
Follow the directions below to top up through
Customer Support or at your local retaik!r.
~ Customer Support:
Dial 611 on your Lifeline phone or call
866.488.8719 from a land line phone.
Debit or credit card required.
Marque 611 desde su telefono Lifeline o
llame 866.488.8719. Se requiere tarjeta de
d0bito o de cf"edito.
Ja Retail:
Check our website for a retail location
near you I www.entouchwireless.com
Tiendas: Busque las tarjetas de recarga en
las siguientes tiendas locales.
) Press 3 for assistance
with your phone.
Presione 3 para obtener
ayuda con su telefono.
1 Press 4 to find out your
anniversary date.
Presione 4 para saber
su fecha de aniversario.
airf:~tr.>))
'5 0 100.. 30
•10 0 soo-30
•20 1500 0 30
•ao -· 0 30
•so -· 4,o 30
1UnH:•1Tnt ... 1Vo1c,alllln,A,. -------·--.. --.. ---
o,,.
s7 100 200 s... 7
s20 500 1,000 20m, 30
s30 1,000 1,200 30.... 30
~ enTouch 955 Kacena Rd, Ste A
Hiawatha, IA 52233 WIRELE SS
Bag Insert -folded to 5.5 x 4.25 -Pg. 2
www.entouchwireless.com
' . ~
enTouch
WIRELESS
POWERED BY BOOMERANG WIRELESS
Exhibit E
Page 10 of 14
MARKETING MATERIALS
Need More Talk, Text or Data?
airf:~,!: >) Price Talk/Text Units Data Days
$5 0 100mb
$10 0
Customer Support:
$2Q 866.488.8719 1500
Dial 611 on your Lifeline phone or call
$3Q 0 30 866.488.8719 from a landline phone. Unlimited"
Debit or Credit Card required.
$5Q Unlimited" 4gb 30 Retail Stores:
Look for the following reload 1 Unit= 1 Text oR 1 Voice Minute
cards at local retailers. Call • Subject to the 3000 units and Acceptable Use Policy Customer Support to locate a
retailer nearest you or visit
www.entouchwireless.com
Airfair Bag Insert -5.5 x 4.25
www.entouchwireless.com
' . ~
enTouch
Exhibit E
Page 11 of 14
WIRELESS
POWERED BY BOOMERANG WIRELESS MARKETING MATERIALS
FREE INTERNET 1100MB DATA
airf:~~!.:>))
BUY AIRFAIR AT YOUR LOCAL 7-11
$51 $10 I $20 I $30 I $50
~ Lifeline is a government assistance program. anTouch Wireless represents the Lifeline service in your state.
; :~ ~~~ =~~=/~=~~~r:=:e:~~~":;':~~;i:~=-~:~= ~nc=~d. E When you rt!Ceive the se,vice, you cannot transfer It to another person. 911 Emetgeocy Service is available wtlefe ~ ::~ ~:=;~~=h~;: = D/ b.Jildings, weather, moootains, etc. If your phone is o.,t of range
~
enTouch
WIRELESS
POWERED BY BOOMERANG WIRELESS
www.entouchwireless.com
Data Flyer -8.5 x 11
www.entouchwireless.com
E 0 <.> "C :ll 'E 8
E ,g
u, C 0 ~ E ~ Q)
C 0
5l .. .D
~ ~ :.;
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enTouch
WIRELESS
Exhibit E
Page 12 of 14
POWERED BY BOOMERANG WIRELESS MARKETING MATERIALS
YOU WILL NEED:
lljl YOU WILL NOT QUALIFY FOR A FREE PHONE
IF YOU DO NOT HAVE THESE DOCUMENTS.
\
• TRIBAL ID
SAMPLE II PROGRAM ELIGIBILITY DOCUMENT
JIil .
•
Supplement
• MEDICAID CARD
SAMPLE
SAMPLE
~
enTouch
WIRELESS
POWERED BY BOOMERANG WIRELESS
What You Need Poster -11 x 17
Nutrition
Assistance
Program
.'i..e..~~-
JOHN )O[
• SNAP CARD
• FREE LUNCH
• PUBLIC HOUSING VOUCHER
• SSI CARD
LAST
~-4NUMBERS
0 F SOCIAL
SECURITY#
OR TRIBAL ID#
Questions? 866.488.8719
www.entouchwireless.com
www.entouchwireless.com
~
enTouch
WIRELESS
Exhibit E
Page 13 of 14
POWERED BY BOOMERANG WIRELESS MARKETING MATERIALS
WANT MORE?
air f:~t~>))
Lifeline Reload
--~ ~nTouch
W t •ILIII ----
CMl.111 MCMVCUR l.ffl.N-----FlHlr __ __
Not a Lifeline supported benefit.
Price Talk/Text Units Data Days
$5 0 100mb 30
•10 0 600mb 30
•20 1600 0 30
•ao .,,,._. o 30
•so -....-4Gb 30
1 Unit• 1 Tut ao 1 Voloe Mlnula
Rates •19 stJbject to chenge without notice
• Subject to ltle 3000 units and Accep\Dble U• Policy
LOCATIONS WHERE YOU
CAN TOP UP WITH AIRFAIR:
Call Customer Service to Top Up:
~
enTouch
866.488.8719 WIRELESS
POWERED BY BOOMERANG WIRELESS
Visit us to find your local retailer:
www.airfairmobile.com
Airfair Top Up Poster -11 x 17
www.entouchwireless.com
• )
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~
enTouch
Exhibit E
Page 14 of 14
W RE LESS
POWERED BY BOOMERANG WIRELESS
~
enTouch
WIRELESS
POWERED BY BOOMERANG WIRELESS
MARKETING MATERIALS
ACCEPTABLE USAGE POLICY
Applies to all Lifeline products and services.
PROHIBITED NETWORK USE: Unlimited Services: Services and equipment may not be used for any unlawful,
fraudulent, harassing, or abusive purpose. enTouch Wireless service is for personal use only. By requesting Services,
you agree that you will not use Services and equipment in any unlawful, fraudulent or abusive manner. enTouch Wireless
reserves the right, without notice or limitation, to limit, deny, terminate, end, modify, disconnect, or suspend Service if
any individual engages in any prohibited voice, text, or data uses detailed below, or if en Touch Wireless determines, on
a case-by-case basis, that action is necessary to protect its wireless network, business, equipment, or Services from
harm or degradation resulting from such prohibited uses.
• VOICE AND TEXT SERVICES: en Touch Wireless provides its voice and text Services soley for live dialogue
between, and initated by, individuals for personal use and as otherwise described in this policy. You may not
use enTouch Wireless voice and text Services for monitoring services, data transmissions, transmission of
broadcasts, transmission of recorded material, telemarketing, broadcast or autodialed calls or texts, other
commercial uses, or other connections that do not consist of uninterrupted live dialogue between individuals.
This Service may not be used in a manner that interferes with other en Touch Wireless customer's use of the
service. Service levels of other customers may be impaired when users place abnormally high numbers of calls,
send or receive very high numbers of messages, or repeatedly make calls of abnormally long duration compared
with other enTouch Wireless customers.
• DATA SERVICES: enTouch Wireless data Services are provided only for personal (i.ei., non-commerical) use,
which includes web surfing, sending and receiving email, photographs and other similar messaging activities,
and the non-continuous streaming of videos, downloading files or online gaming. en Touch Wireless data
Services may not be used for any of the following uses: (1) to generate excessive levels of Internet traffic
through the continuous, unattended streaming, downloading or uploading of videos, music, or other files or to
operate hosting services including, but not limited to, web or gaming hosting; (2) to maintain continuous active
network connections to the Internet, for example, through a web camera or machine-to-machine connections
that do not involve active participation by a person; (3) to disrupt email use by others using automated or
manual routines, including, but not limited to "auto-responders" or cancel bots or other similar routines; (4) to
transmit or facilitate any unsolicited or unauthorized advertising, telemarketing, promotional materials, "junk
mail," unsolicited commercial or bulk email, or fax; (5) for activities that adversely affect the ability of other
people of system to use either en Touch Wireless' or other parties' Internet-based resources, including, but not
limited to, "denial of service" (DoS) attacks against another network host or individual user; (6) for an activity that
connects any device to Personal Computers (including without limitation, laptops), or other equipment for the
purpose of transmitting wireless data over the network (unless customer is using a en Touch Wireless handset
designated for such usage); or (7) for any other reason that violates our policy of providing Service for individual
use. The prohibited uses in this section also apply to unlimited plans. Unlimited does not mean unreasonable
use. If en Touch Wireless finds that you are using an unlimited voice, text, or data Service offering for any of the
prohibited uses in this section, en Touch Wireless may at its option terminate your Service or change your plan to
one with no unlimited usage components. en Touch Wireless will provide notice that it intends to take any of the
above actions, and will give you an opportunity to terminate the Agreement. Unlimited talk and text includes talk
and text within the U.S. only.
MISUSE OF LIFELINE SERVICE: You have certified your eligibility to receive free services under the federally funded
Lifeline program. If your eligibility to participate in this program changes, you agree to immediately notify en Touch
Wireless at 1.866.488.8719. Service is provided at our discretion and if terms and conditions are violated we can
terminate your wireless service without any further notification or obligation to you.
Acceptable Use Flyer - 8.5 x 11
Acceptable Use Poster -11 x 17
No refunds for purchased air time.
www.entouchwireless.com
www.entouchwireless.com
' .
' ..
Exhibit F
Terms of Service
Terms Of Service
enTouch Wireless Terms and Conditions for Communication Services
Effective as of August 9, 2016 until replaced.
Exhibit F
Page 1 of 14
Thank you for choosing enTouch Wireless powered by Boomerang Wireless ("enTouch Wireless"). These
terms and conditions are part of your agreement with en Touch Wireless for Mobile Services. For the most
current version of the terms and conditions, please visit our website at www.enTouchwireless.com or call
Customer Service at 1.866.488.8719. The terms and conditions included with your Mobile phone may not
be the most current version. If you activated Mobile Services before the effective date of these terms and
conditions, these terms and conditions replace and supersede any previous terms and conditions. If you
have questions about your en Touch Wireless Services, call en Touch Wireless Customer Service at
1.866.488.8719 or visit our website at www.enTouchwireless.com.
Your agreement ("Agreement") with en Touch Wireless powered by Boomerang Wireless and any of its
affiliates doing business as enTouch Wireless providing mobile phone services ("Services") to you is
made up of these terms and conditions of service ("Terms"). We use the words "we," "us" or "our" to refer
to enTouch Wireless powered by Boomerang Wireless and its affiliates doing business as enTouch
Wireless in these Terms. When you activate Services or attempt to use our Services (including, without
limitation, attempting to place a call) you accept the Agreement.
Non-Discrimination: Company offers Lifeline, a government assistance program, on a non­
discriminatory basis to any consumer who completes and submits the required Lifeline application and
supporting documentation that 1) meets and maintains the eligibility requirements as defined by the
Company policy and terms, federal and state rules and regulations including approval by the federal and
state Lifeline Administrator(s), rules and regulation(s), as and where applicable; and 2) resides within the
Company's approved service area for wireless telephone services. enTouch Wireless has been approved
by the California Public Utilities Commission as a California Lifeline Program provider. This benefit
program is available to eligible California low-income households and is funded by the State of
California.
Provision of Service: Your free phone or purchased digital mobile phone or other equipment does not
mean that we must provide Services to you. We may decide not to provide Services to you for any lawful
reason. We may request that you provide us with any information we reasonably require to determine
whether you qualify or are eligible under federal guidelines or the applicable state guidelines for Services.
Services in some areas are managed and provided under contract with en Touch Wireless by independent
affiliates to our network provider. Some Services may not be available or may operate differently in
certain affiliate markets.
Changes to Agreement: en Touch Wireless may modify this Agreement at any time by posting the
revised Agreement on the website. Any changes to the Terms are effective when we publish the revised
Terms of Service. If you use our Services or make any payment to us on or after the effective date of the
changes, you accept the changes. If you do not accept the changes, you may terminate Services. For
purposes of the Agreement, "use" includes keeping the right to access the enTouch Wireless Coverage
Area by not terminating Services. You may not modify the Agreement.
1
< '
Exhibit F
Page 2 of 14
Prohibited Network Use--ACCEPTABLE USE POLICY (Unlimited Services): Services and
equipment may not be used for any unlawful, fraudulent, harassing, or abusive purpose. en Touch Wireless
service is for personal use only. By requesting Services, you agree that you will not use Services and
equipment in any unlawful, fraudulent or abusive manner. enTouch Wireless reserves the right, without
notice or limitation, to limit, deny, terminate, end, modify, disconnect, or suspend Service if any
individual engages in any prohibited voice, text, or data uses detailed below, or if en Touch Wireless
determines, on a case-by-case basis, that action is necessary to protect its wireless network, business,
equipment, or Services from harm or degradation resulting from such prohibited uses.
• Voice and Text Services: enTouch Wireless provides its voice and text Services soley for
live dialogue between, and initated by, individuals for personal use and as otherwise
described in this policy. You may not use enTouch Wireless voice and text Services for
monitoring services, data transmissions, transmission of broadcasts, transmission of
recorded material, telemarketing, broadcast or autodialed calls or texts, other commercial
uses, or other connections that do not consist of uninterrupted live dialogue between
individuals. This Service may not be used in a manner that interferes with other en Touch
Wireless customer's use of the service. Service levels of other customers may be impaired
when users place abnormally high numbers of calls, send or receive very high numbers of
messages, or repeatedly make calls of abnormally long duration compared with other
en Touch Wireless customers. Use of more than 3,000 units within a 30-day period or less
may trigger a review of the usage in accordance with this Acceptable Use Policy.
• Data Services: enTouch Wireless data Services are provided only for personal (i.e., non­
commercial) use, which includes web surfing, sending and receiving email, photographs
and other similar messaging activities, and the non-continuous streaming of videos,
downloading files or online gaming. en Touch Wireless data Services may not be used for
any of the following uses: (I) to generate excessive levels oflnternet traffic through the
continuous, unattended streaming, downloading or uploading of videos, music, or other
files or to operate hosting services including, but not limited to, web or gaming hosting; (2)
to maintain continuous active network connections to the Internet, for example, through a
web camera or machine-to-machine connections that do not involve active participation by
a person; (3) to disrupt email use by others using automated or manual routines, including,
but not limited to "auto-responders" or cancel bots or other similar routines; (4) to transmit
or facilitate any unsolicited or unauthorized advertising, telemarketing, promotional
materials, "junk mail," unsolicited commercial or bulk email, or fax; (5) for activities that
adversely affect the ability of other people of system to use either en Touch Wireless' or
other parties' Internet-based resources, including, but not limited to, "denial of service"
(DoS) attacks against another network host or individual user; (6) for an activity that
connects any device to Personal Computers (including without limitation, laptops), or other
equipment for the purpose of transmitting wireless data over the network (unless customer
is using a enTouch Wireless handset designated for such usage); or (7) for any other reason
that violates our policy of providing Service for individual use.
2
Exhibit F
Page 3 of 14
The prohibited uses in this section also apply to unlimited plans. Unlimited does not mean unreasonable
use. If en Touch Wireless finds that you are using an unlimited voice or text Service offering for any of the
prohibited uses in this section, enTouch Wireless may at its option terminate your Service or change your
plan to one with no unlimited usage components. enTouch Wireless will provide notice that it intends to
take any of the above actions, and will give you an opportunity to terminate the Agreement. Unlimited
talk and text includes talk and text within the U.S. only.
Availability: Company provides the ability to send and receive voice-grade calls over all domestic
distances (local and long distance) via a wireless voice-grade connection to the public switched telephone
network. Our voice Services provide the ability to send and receive voice-grade calls within the
nationwide (domestic) operating range of the enTouch Wireless Coverage Area.There is power back-up
for the underlying en Touch systems that support en Touch LifeLine wireless service as well as underlying
carrier power backup systems including limitations due to power for equipment on towers or other
facilities in accordance with Federal and state requirements. Coverage and quality of Services may be
affected by conditions within or beyond our control, including atmospheric, geographic, or topographic
conditions. We do not guarantee that there will be no interruptions or delays in Services. Your enTouch
Wireless phone will not accept the services of any wireless provider other than en Touch Wireless.
Services unavailable at home: If you fail to receive a voice-grade connection, notify en Touch Customer
Service. en Touch Customer Service will 1) promptly attempt to restore voice service, or if not possible,
2) provide telephone service using a different network carrier if offered by en Touch and if you agree to
that change; or 3) allow you to discontinue service. No termination fees or penalties apply.
Phone Number: We assign telephone numbers and other personal identifiers in connection with the
Services. Unless we provide you advance notice in writing, you have no proprietary right to any such
identifiers, and we reserve the right to change them upon notice to you. You do not have any property
right to your phone number. It may be changed or reassigned. In the event that you become entitled to
transfer a personal identifier to another party to obtain any Services we provide you, we reserve the right,
prior to honoring the request for transfer, to charge a fee for the transfer and to collect any money owed
by you for Services and Equipment.
Charges: Eligible Lifeline subscribers will receive free airtime as part of your en Touch Wireless service.
Free and purchased airtime is measured in 'units' for voice and text service. One (1) unit equals one (1)
minute, and one (1) unit equals one (1) text message. "1 unit= 1 minute= 1 text." Airtime is used in one­
minute increments and any fraction of a minute is rounded up and charged at the full minute rate; calls are
measured from the time the network begins to process the call (before the phone rings or the call is
answered) through the termination of the call. Some plans include free data usage. Data is measured in
megabytes which is decremented at the rate of content downloaded/uploaded to the network. More
information on data plans & usage is available through customer service by dialing 611.
For California Residents only: en Touch Wireless has been approved by the California Public
Utilities Commission as a California LifeLine Program provider. This benefit program is available
to eligible California low-income households and is funded by the State of California. The
California LifeLine plan offerings enTouch has available are listed at the end of the Terms of
Service.
3
Exhibit F
Page 4 of 14
The Company does not differentiate domestic long distance telephone usage from local usage; customers
utilize their minutes of use at the same rate for each type of call. You may also choose to add Airtime
through a Top Up card or other commerce channel. This airtime may be invalidated if not paid for by the
retailer. Any rollover minutes associated with a plan offering expire after 60 days from the date the
minutes were issued.
For most forms of wireless Service, your usage will be charged from the time you first initiate contact
between your phone or other wireless device and the network until the network connection is broken,
whether or not you are successful in connecting with the service with which you seek to connect, even if
the connection is later broken or dropped. Your account is not charged for voice calls that are not
completed. You are charged for completed calls to your Number from the time shortly before the phone
starts ringing until the call is terminated by either party.
Unless noted otherwise, the following call types are provided with enTouch Services:
• 411 Directory Assistance: Directory Assistance calls are free; there is no additional charge.
Units/minutes for Directory Assistance are deducted from your available balance of units.
• 611 Company Customer Service: The Company's handsets can reach 611 Company
Customer Service regardless of units (minutes) available on your balance of units. And there
is no decrement of minutes when you dial 611 from their Lifeline phone.
• 711 Relay Service: (California only) For 711 calls, only the call to the 711 relay service for
the deaf or speech-disabled shall not be counted against Lifeline plan minutes, while the
relayed call itself may count toward applicable plan minutes.
(California only) Through its underlying carriers, Boomerang will provide access to California
Relay Service for deaf or hearing-impaired persons or persons with speech disabilities Access
to telephone relay services as provided for in Pub. Util. Code §2881 et seq.
• 911 Emergency Service: The Company's handsets can reach 911 Emergency services
regardless of units (minutes) available on your balance of units. There is no decrement of your
minutes when you dial 911 from their Lifeline phone. 911 emergency services are compliant
with state regulations.
• Nll Numbers: (California only) Public Safety, NI I Numbers (211,311,511, 711, and 811)
will be supported at a local and state level. There is no additional charge. Units/minutes for
NI I Numbers are deducted from your available balance of units. NI I Numbers are supported
for California LifeLine customers through the offering of plans with unlimited voice minutes.
• Operator Services: Access to operator services for en Touch Lifeline customers is offered
commensurate to its retail customers. There is no additional charge for accessing customer
service and no decrement of Units/minutes for these calls.
• Pay-Per-Call Service: The Company does not complete calls from your Number to 900, 976
and similar numbers for pay-per-call services.
4
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•
Exhibit F
Page 5 of 14
Toll Free Numbers: calls to Toll Free Numbers are free; there is no additional charge .
Units/minutes for Toll Free Numbers are deducted from your available balance of units.
No Termination Fee or Penalty: Company does not require you to enter into a service contract, so you are
not subject to termination fees or penalties.
Lifeline Activity Alerts and Other Text Messages: en Touch Wireless will use text messaging to keep in
touch with you for things like:
• Balance Alerts
• Activation Status
• Product Offers
• Reload Specials
When you sign up for Lifeline Services with enTouch Wireless you are asked to OPT IN to receive these
messages. You can also choose to not receive these messages. If you choose to OPT OUT of text
messages, then the only text messages you will receive are the Lifeline notifications required by the FCC,
such as the 30-day non-usage notice, the recertification notices, etc. The customer cannot opt out of the
required FCC notifications.
If you choose to OPT IN for these messages, they will be delivered to you based on your phone usage.
Outbound Usage Alerts do not decrement the consumer's plan balance. Responses to the Usage Alert
short codes do not decrement the consumer's plan balance. You must use your phone every 60-days to
maintain your Lifeline benefits. (See 'SERVICES, Prepaid Services' for more information on maintaining
an active account.) You must also recertify annually that you are eligible for Lifeline services.
-Shortcode 9127 from your Sprint powered phone: At any time, you may stop receiving
enTouch Wireless Lifeline Activity Alerts. Text STOP to 9127 about any message received to
discontinue receiving that message.
-Shortcodes 2560 and 2561 from your Verizon powered phone: At any time, you may STOP
receiving enTouch Wireless Lifeline Activity Alerts. Text STOP to 2560 or 2561 about any
message received to discontinue receiving that message.
-Shortcode 20954 from your AT&T powered phone: At any time, you may STOP receiving
en Touch Wireless Lifeline Activity Alerts. Text STOP to 20954 about any message received to
discontinue receiving that message.
Q
Wireless Network Services provided by a Red Pocket MOB I LE
-Shortcode 20954 from your T-Mobile powered phone: At any time, you may STOP receiving
enTouch Wireless Lifeline Activity Alerts. Text STOP to 20954 about any message received to
discontinue receiving that message.
You can also call 866.488.8719 to OPT OUT of enTouch Wireless messaging or send an email to
[e-mail]. The customer cannot opt out of the required FCC notifications.
5
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Exhibit F
Page 6 of 14
To receive SMS HELP dial 611 on your phone, or from another phone call 866.488.8719. You can also
email us at [e-mail].
Notices: You may get our current address for written notice by calling enTouch Wireless Customer
Service. Written notice is deemed delivered 3 days after deposit in the U.S. mail, postage prepaid, and
properly addressed. Unless required by this Agreement or Applicable Laws, (1) you may notify us by
calling enTouch Wireless Customer Service, and (2) we may notify you by leaving a message for you on
your enTouch Wireless Phone, answering machine or with your answering service. Notice addresses may
be changed by giving notice as provided in this section.
Phones and Other Equipment: Phones and other equipment may be provided at no charge to you as part
of the enTouch Wireless offering. Company policy is only one free device per customer in the most
recent 12 month period. Phones, which are refurbished or overstocked handsets, and other equipment
may also be purchased and returned as provided in the purchase documents. We are not the manufacturer
of the phones or other equipment. The only warranties on the phones or other equipment are any limited
warranties extended by the manufacturers. We have no liability in connection with the phones and other
equipment or for the manufacturers' acts or omissions.
Refurbished phones are used phones that have been inspected, tested, and restored to full working
condition at a factory or authorized service center. They may feature new housings or other new parts, or
they may simply be used phones that have been tested and certified. Many of the phones distributed are
refurbished phones that have been moderately used. They may show minor cosmetic imperfections or be
placed in new housings. Phone is data cleared and has been fully inspected, and functionally tested.
Device and accessories distributed consist of phone, battery, and wall charger.
Lost or Stolen Equipment: If your phone or other equipment is lost or stolen, you must notify us by
calling enTouch Wireless Customer Service. You are responsible for all charges for Services provided to
the Number for the lost or stolen equipment. We will deactivate Services to the Number upon notification
to us of any loss or theft. If the equipment is later found, we may require that you exchange it for another
phone or other equipment before we reactivate Services (if we do reactivate Services), as well as require
you to pay a reactivation or replacement fee of $25.00. You will need to send a money order or prepay
via credit card before we reactivate or send a replacement phone. We will deactivate Services to any
Number without prior notice to you ifwe suspect any unlawful or fraudulent use of the Number. You
agree to cooperate reasonably with us in investigating suspected unlawful or fraudulent use.
Caller ID: Caller ID display on incoming calls to your Number depends on receiving the information
from the calling party.
Pay-Per-Call Service: en Touch Wireless will not complete calls from your Number to 900, 976 and
similar numbers for pay-per-call services.
Limitation of Liability: Except as otherwise provided in this section, our sole liability to you for any loss
or damage arising out of providing or failing to provide Services (including mistakes, omissions,
interruptions, delays, errors, or defects) does not exceed (1) in cases related to a specific piece of
6
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Exhibit F
Page 7 of 14
equipment, the prorated Services to the piece of equipment during the affected period, or (2) in cases not
related to a specific piece of equipment, the prorated Services to you during the affected period.
Neither we nor our vendors, suppliers or licensors are liable for any damage arising out of or in
connection with:
• any act or omission of any telecommunications service or other service provider other than us;
• any directory listing;
• any dropped calls or inability to place or receive calls;
• any interruption of Services, including interruptions caused by equipment or facilities failure or
shortages, transmission limitations or system capacity limitations;
• traffic or other accidents, or any health-related claims allegedly arising from the use of Services,
phones, equipment or accessories used in connection with the Services;
• any late or failed message delivery;
• any interruption or failure of911 or E91 l emergency services or identification of the Number,
address or name associated with any person accessing or attempting to access emergency services
from your phone;
• the installation or repair of any products or equipment by parties who are not our authorized
employees or agents;
• events due to factors beyond our control, including acts of God (including, without limitation,
weather-related phenomena, fire or earthquake), war, riot, strike, or orders of governmental
authority;
• any act or omission of any third party or independent contractor that offers products or services in
conjunction with or through the Services; or
• your negligent or intentional act or omission.
• NO CONSEQUENTIAL OR OTHER DAMAGES: UNDER NO CIRCUMSTANCES ARE WE
LIABLE FOR ANY INCIDENTAL, CONSEQUENTIAL, PUNITIVE OR SPECIAL DAMAGES
OF ANY NATURE WHATSOEVER ARISING OUT OF OR IN CONNECTION WITH
PROVIDING OR FAILING TO PROVIDE SERVICES, PHONES OR OTHER EQUIPMENT
USED IN CONNECTION WITH THE SERVICES, INCLUDING, WITHOUT LIMITATION,
LOST PROFITS, LOSS OF BUSINESS, OR COST OF REPLACEMENT PRODUCTS AND
SERVICES. THIS SECTION SURVIVES TERMINATION OF THIS AGREEMENT.
Neither en Touch Wireless nor any of its affiliates, nor the directors, employees or other representatives of
any of them are liable for damages arising out of or in connection with the use of the products or services.
This is a comprehensive limitation of liability that applies to all damages of any kind, including
compensatory, direct, indirect or consequential damages, loss of data, income or profit, loss of or damage
to property and claims of third parties.
Indemnification: You indemnify and defend us, our partners, directors, officers, employees and agents
from and against any claim, action, damage, liability and expense arising out of or in connection with: ( 1)
your acts or omissions that occur in connection with your use of the Services or equipment used in
connection with the Services, and (2) any communications you make or receive using the Services. This
7
-------------------------------------------4·-------·
' . Exhibit F
Page 8 of 14
indemnification extends to and includes any attorney's fees and costs incurred by us arising from any
actions or claims to which this indemnification applies, or from the contesting of the applicability of this
provision. This section survives termination of this Agreement.
Governing law: For all states except for Minnesota:
This Agreement is governed by and must be construed under federal law and the laws of the State of
Iowa, without regard to choice of law principles. You agree to submit yourself to the person jurisdiction
of the courts in the state of Iowa.
Governing law: For the state of Minnesota:
For services provided pursuant to the Lifeline program, this Agreement is governed by and must
be construed under federal law and the laws of the State of Minnesota, without regard to choice of
law principles. You agree to submit yourself to the personal jurisdiction of the courts in the State
of Minnesota.
For services other than those provided pursuant to the Lifeline program, equipment, and top-up
cards, which are not a part of the Lifeline program, this Agreement is governed by and must be
construed under federal law and the laws of the State of Iowa, without regard to choice of law
principles. You agree to submit yourself to the personal jurisdiction of the courts in the State of
Iowa.
General: If either of us does not enforce any right or remedy available under this Agreement, that failure
is not a waiver of the right or remedy for any other breach or failure by the other party. Our waiver of any
requirement in any one instance is not a general waiver of that requirement and does not amend this
Agreement. If any part of this Agreement is held invalid or unenforceable, that part is interpreted
consistent with applicable laws as nearly as possible to reflect the original intentions of the parties and the
rest of this Agreement remains in full force and effect. You may not assign this Agreement to any other
person or entity without our prior written approval. This Agreement (including any referenced documents
and attachments) makes up the entire agreement between you and us and replaces all prior written or
spoken agreements, representations, promises or understandings between you and us. The provisions of
this Agreement that are contemplated to be enforceable after the termination of this Agreement survive
termination of this Agreement.
Copyright and Trademark: Trademarks, product names, and company names and logos appearing on
enTouch Wireless are the property of their respective owners. Users must obtain written permission from
en Touch Wireless before copying or using the owner's trademarks, product names and company names
and logos.
SERVICE, Prepaid Services: Upon certification of eligibility, and continuing eligibility, you will
receive free voice services. This positive account balance will be applied every 30 days on the anniversary
of your service activation. You must maintain an ACTIVE ACCOUNT every 60 days: by having voice
call usage (inbound or outbound), by buying additional product, by responding affirmatively to our
queries regarding your desire to continue to receive services. You may also elect to purchase additional
services, including additional voice minutes, text plans, etc. When purchasing prepaid services, you are
responsible for prepaying all charges for using the service. The balance in your prepaid account is reduced
8
.•
Exhibit F
Page 9 of 14
by the charges attributable to your use of the service. You must keep a positive balance in your prepaid
account to continue using the service. Anyone who purchases or uses the service, with or without the
purchaser's consent is considered a user and subject to the terms and conditions.
Service Limits and Coverage Maps: Service is available to your handset only when it is within the range
of our system or of an operator with which we have an applicable agreement. Coverage maps you may
have viewed are only estimates; actual service coverage and service quality may vary, and are not
guaranteed under the terms and conditions.
Misuse of Lifeline Service: You have certified your eligibility to receive free services under the federally
funded Lifeline program. If your eligibility to participate in this program changes, you agree to
immediately notify enTouch Wireless at 1.866.488.8719. Service is provided at our discretion and if
terms and conditions are violated we can terminate your wireless service without any further notification
or obligation to you.
Changes to Rates and Fees: All rates and fees are subject to change without notice. Service provided is
subject to our business policies, which can change without notice. Visit www.enTouchwireless.com for
current rates and information. For Customer Care, call 1.866.488.8719. To dispute charges you must
notify us within 15 days of the date of the disputed call. Terms and conditions can be modified without
notice; visit www.enTouchwireless.com for current terms and conditions.
Exchange Policy: Defective handsets or other defective equipment provided at no cost to you may be
eligible for exchange. This policy does not apply to breakage caused by customer negligence or water
damage. Note that the exchange policy, including the number of days for exchange, may be changed
without notice and the policy may not apply to certain products. To exchange a defective handset, please
call Customer Service at 1.866.488.8719 to obtain a Return Authorization and shipping instructions. You
must return the product at your expense, complete with all accessories that came with the handset, in the
original box with all materials and package inserts within 30 days of receiving the handset. Phones
returned after 30 days will require a replacement fee of $25.00 before the replacement phone is mailed.
The replacement fee may be paid by sending a money order or prepaying via credit card. Upon en Touch
Wireless' receipt of the returned product, en Touch Wireless will ship you the replacement handset. Any
other disputes should be handled by Customer Service. If you do not dispute any charge on your account
prior to its going inactive or within 30 days of the date of the receipt, whichever comes first, you give up
your right to dispute.
Concerns, Complaints or Disputes: If you have questions, concerns, comments or complaints, please
contact enTouch Wireless at www.enTouchwireless.com or call Customer Care by dialing 611 from your
cell phone (does not use your Lifeline minutes) or dialing 1-866-488-8719 from another phone.
-Applicable Time Frames: If disputing charges, you must notify en Touch Wireless within 15
days of the date of the disputed call. If you do not dispute any charge on your account prior to the
account going inactive or within 30 days of the date of the charge or the date of receipt a
replacement phone, whichever comes first, you give up your right to dispute.
-State Commission Contact: After contacting enTouch Customer Service and before proceeding
to Arbitration, you may also contact the applicable state commission or state authority who are
also committed to addressing customer concerns and complaints.
9
' -
Arizona Corporation Commission
Phoenix Office: 1200 W. Washington St.
Phoenix, AZ 85007
• Within Metro Phoenix: 602-542-4251
• Phoenix Toll Free: 1-800-222-7000
Tucson Office: 400 W. Congress, Ste. 218
Tucson, AZ 85701
• Within Metro Tucson: 520-628-6550
• Tucson Toll Free: 1-800-535-0148
Exhibit F
Page 10 of 14
• Link: http://www.azcc.gov/divisions/utilities/consumerservices.asp
California Public Utilities Commission
Consumer Affairs,
505 Van Ness Avenue
San Francisco, CA 94102
• Toll Free: 1-800-649-7570
• Link: http://www.cpuc.ca.gov/PUC/CEC/e complaint/
Colorado Public Utilities Commission
Consumer Affairs,
I 560 Broadway, Suite 250
Denver, Colorado 80202
• Phone: [phone]
• Toll Free: 800-456-0858
• Fax: [phone]
• E-mail: dora _puc _ [e-mail]
• Link: http://www.dora.state.eo.us/PUC./consumerassistance.htm
Georgia Public Service Commission
Consumer Affairs Unit
244 Washington Street, SW
Atlanta GA, 30334-9052
• Metro Altanta: 404-656-4501
• Toll Free in Georgia (outside Metro Atlanta): 800-282-5813
• Fax: [phone] I
• E-mail: [e-mail]
• Link: http://www.psc.state.ga.us/contactinfo.asp
10
Indiana Utility Regulatory Commission
Consumer Affairs Division
PNC Center, Suite 1500 East
101 W. Washington Street
Indianapolis, IN 46204
• Toll Free: 800.851.4268 (in Indiana only)
• Phone: [phone]
• Link: http://www.in.gov/iurc/
Kansas Corporation Commission,
Office of Public Affairs and Consumer Protection,
1500 SW Arrowhead Road,
Topeka, KS 66604
• in Topeka: [phone]
• Toll Free: [phone]
Exhibit F
Page 11 of 14
• Hearing or speech impaired at TDD Kansas Relay Center: [phone]
• Link: http://www.kcc.state.ks.us/pi/index.htm
Minnesota Public Utilities Commission
121 7th Place E., Suite 350
Saint Paul, MN 55101-2147
• Consumer Assistance: 651 .296.0406
• Administration: 651.296.7124
• Toll Free: 800.657.3782
• Fax: [phone]
• Link: http://www.puc.state.mn.us/puc/consumers/index.html
Mississippi Public Service Commission
P.O. Box 1174
Jackson, MS 39215-1174
• Phone: [phone]
• Link: www.mpus.ms.gov
Oklahoma Corporation Commission
P.O. Box 52000
Oklahoma City, OK 73152-2000
• Local: 405.521.2331
• Toll Free: 800.522.8154
11
Oregon Public Utility Commission
Consumer Services Section
P.O. Box 1088
Salem, OR 97308-1088
• Toll Free: 1.800.522.2404
• TTY: 1.800.648.3458
• Link: http://www.puc.state.or.us/Pages/contact us.aspx
Washington State Office of the Attorney General,
Consumer Protection,
800 5th Ave. Suite 2000,
Seattle, WA 98104-3188
• Toll Free: 800.551.4636 (in Washington only)
• Phone: [phone]
Exhibit F
Page 12 of 14
• Washington State Relay Service for the Hearing impaired: 800.833 .6388
• Link: http://www.atg.wa.gov
Arbitration: Any dispute arising out of the Agreement or relating to the Services and Equipment must be
settled by arbitration administered by the American Arbitration Association in Des Moines, Iowa.
Information regarding this procedure may be found at www.adr.org. Each party will bear the cost of
preparing and prosecuting its case. We will reimburse you for any filing or hearing fees to the extent they
exceed what your court costs would have been if your claim had been resolved in a state court having
jurisdiction. The arbitrator has no power or authority to alter or modify the Agreement, including the
foregoing Limitation of Liability section. All claims must be arbitrated individually, and there will be no
consolidation or class treatment of any claims. This provision is subject to the Federal Arbitration Act.
You maintain your right to file a complaint with the applicable state commission regarding the service
provided and/or charges imposed by en Touch Wireless. Nothing in this paragraph or this agreement in
any way eliminates or abridges that right. Please see 'Concerns, Complaints or Disputes' for more
information before proceeding to Arbitration.
Georgia Residents: Arbitration is the method for settling any dispute unless otherwise agreed to
by both parties. Arbitration will be held in Georgia unless otherwise agreed to by the parties.
No Warranties by enTouch Wireless: ENTOUCH WIRELESS MAKES NO EXPRESS
REPRESENTATIONS OR WARRANTIES ABOUT ITS SERVICES AND DISCLAIMS ANY
IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF
MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. ENTOUCH WIRELESS
DOES NOT AUTHORIZE ANYONE TO MAKE AW ARRANTY OF ANY KIND ON ITS BEHALF
AND USER MAY NOT RELY ON ANY STATEMENT OF WARRANTY.
12
' ' Exhibit F
Page 13 of 14
Termination of Access: enTouch Wireless may terminate your access without notice, for any conduct
that enTouch Wireless, in its sole discretion, believes to be harmful to individual users, enTouch Wireless
or any of its affiliates, or any rights of enTouch Wireless or any third party, or to violate applicable laws.
California LifeLine Plans: (California only) enTouch Wireless has been approved by the California
Public Utilities Commission as a California LifeLine Program provider. This benefit program is available
to eligible California low-income households and is funded by the State of California. The California
LifeLine plan offerings enTouch has available are:
• 1100 FREE Monthly Minute Plan (California LifeLine): This plan offers 1100
minutes/units per month for voice and text. LifeLine free minutes are automatically posted
each month on the LifeLine customer's service date. There is no roll over of minutes/units.
Consumers may choose to supplement their plan with additional units (voice, text or data)
or upgrade to the Unlimited Plans at any time in local retail outlets or by calling enTouch
Wireless Customer Service. (This offering meets the California unbundled offering
requirement.) Voice or data may be added with Airfair top-up cards.
• $5 for 250 voice/message units
• $10 for 250 voice/message units, plus 750 MB data
• $20 for unlimited voice/messages, plus 1.0 GB data
• $30 for unlimited voice/messages, plus 1.5 GB data
• $50 for unlimited voice/messages, plus 4.5 GM data
(Airfair top-up cards are not Lifeline orCalifomia LfileLine producs, but are available
to all subscribres. Airfar top up prices shown are standard retail prices.)
• Unlimited Voice & Text Plan (California LifeLine): This plan offers unlimited
minutes/units per month for voice and text plus 100 MB of data. The Unlimited Voice &
Text Plan can be purchased at local retail outlets or by calling Customer Service by dialing
611. This plan is effective for 30-days with no roll over of minutes/units from the date the
plan is loaded on your enTouch phone, which may differ from your LifeLine customer's
service date.) Data may be added with Airfair top-up cards.
• $5 for 250 MB
• $10 for 750 MB data
• $20 for 1.0 GB data
• $30 for 1.5 GB data
• $50 for 4.5 GM data
(Airfair top-up cards are not Lifeline orCalifomia LfileLine producs, but are available to all
subscribres. Airfar top up prices shown are standard retail prices.)
Plan includes handset (not to exceed one free phone per customer per continuous 12 month
period). Customer may, instead, use the customer's own handset for one-time "Bring­
Your-Own Device ("BYOD") fee of $15. This fee includes SIM card, plus three
consecutive months of 250 MB data in addition to data included in plan. BYOD customer
may purchase 250 MB data package for each subsequent consutive three-month period for
13
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Exhibit F
Page 14 of 14
$5. BYOD California LifeLine customer who subscribe to the Unlimited Voice & Text
Plan on BYOD basis will receive a$ IO Company-funded discount off price for Airfair top­
ups having a standard retail value of $20 or more.
Initial Phone Activation Fee: Boomerang will charge an Initial Phone Activation Fee for the
processing of the initial application paperwork and initial phone activation of $39.00 for California
LifeLine recipients.* A Phone Activation Fee of $39.00 will be charged for California non­
LifeLine consumers choosing Boomerang service. The fee does not apply to phone upgrades or
replacements.
* If the customer is approved for California LifeLine, the California Lifeline
participant may be eligible for a waiver. The waiver is funded by the California
LifeLine program and is available for no more than a total of two wireless service
activations (whether with the Company or any other wireless service provider) per
household per continuous twelve-month period. Eligibility for a waiver is subject
to confirmation of elibiliity by the California LifeLine program administrator.
Boomerang offers only pre-paid service with no overage fees.
14
' ' .,
. '
Exhibit G
Affected Tribal Government and Regulatory Agencies
. '
State Federal! Reco nized Tribe
ID Coeur D'Alene Tribe
ID Kootenai Tribe of Idaho
ID Nez Perce Tribe
Exhibit F
Boomerang Wireless
Idaho
Exhibit G
Page 1 of 1
83535,83536, 83537,83539, 83541,83543,83544, 83545,
83548 83552 83553 83555 85340
ID Shoshone-Bannock Tribes of the Fort Hall Reservation of Idaho 83201 83202 83203 83204 83212 83245