20180620Application.pdf

Lance J.M. Steinhart, P.C. P'tr"CEIVED
,rrri$fflffiff:l[.,,," 'i'illu ']u]l 20 Al4 8:55
Suite 150 ri.,,.,i.,, ,,-.liii,!i.,..,n,Alpharett4 Georgia 30005 I ill I ili-: "' r-,r-ii,i'r'ilbutt'rt't
Also Admitted in New York
Email: [e-mail]
Telephone: [phone]
Facsimile: (7 1 0) 232-9208
June 19,2018
VIA OVERNIGHT DELIVERY
Diane Hanian
Commission Secretary
Idaho Public tJtilities Commission
472West Washington
Boise,ldaho 83702
$a - T- tij-or
Global Connection Inc. of America dba STAND UP WIRELESS
Application for Designation as an Eligible Telecommunications Carrier
Dear Ms. Hanian:
Enclosed please find fbr filing an original and two (2) copies of Global Connection Inc. of
America dba STAND UP WTRELESS' Application fbr Designation as an Eligible
Telecommunications Carrier in the State of Idaho.
I have also enclosed an extra copy of this letter to be date stamped and retumed to me in the
enclosed, self-addressed, postage prepaid envelope.
If you have any questions or if I may provide you with additional information, please do not
hesitate to contact me at 770-232-7805 or [e-mail]. Thank you.
Respectfully submitted,
Burton F. Peebles, Esq.
Associate Attorney
Lance J.M. Steinhart, P.C.
Attorneys for Global Connection Inc. of America
dba STAND UP WIRELESS
Enclosures
cc: Eric Schimpf
Re:
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of cASE No. 6 Lo - T- I s-o 1
GLOBAL CONNECTION INC. OF AMERICA
DBA STAI\D UP WIRBLESS FOR
DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER
Lance J.M. Steinhart
Managing Attomey
Lance J.M. Steinhart, P.C.
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail: [e-mail]
Attorneysfor Global Connection Inc. of America
dba STAND UP WIRELESS
June 18,2018
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APPLICATION OF GLOBAL CONNBCTION INC. OF AMBRICA
DBA STAND UP WIRELESS FOR DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS CARRIER
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TABLE OF CONTENTS
INTRODUCTION
BACKGROUND.
A. Company Overview
B. ProposedLifelineOffering.......
C. Plan Enrollment
D. Prevention of Waste, Fraud and Abuse.
E. The Commission Has Jurisdiction to Designate Wireless ETCs
STANDLIP WIRELESS SATISFIES THE REQUIREMENTS FOR
DESIGNATION AS AN ETC
A. StandUP Wireless Will Provide Service Consistent With the FCC's
Grant of Forbearance from Section 214's Facilities Requirements.........
B. StandUP Wireless Is a Common Carrier.......
C. StandUP Wireless Will Provide All Supported Services ...........
l. Voice Telephony Service......
2. Broadband Internet Access Services
D. StandUP Wireless Requests Designation Throughout its Service Area
in Idaho
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IV.
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E. StandUP Wireless Will Advertise the Availability of Supported
Services t7
F. Service Commitment Throughout the Proposed Designated Service
Area..........
G. Ability to Remain Functional in Emergency Situations
H. Commitment to Consumer Protection and Service Quality...... ..........19
I. Financial and Technical Capability ................19
J. StandUP Wireless Will Comply with the Lifeline Certification and
Verification Requirements ............... ...............24
K. StandUP Wireless Will Comply With All Regulations Imposed By The
Commission 24
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DESIGNATION OF STANDUP WIRELESS AS AN ETC WOULD
PROMOTE THE PUBLIC INTEREST ........,....
A. Advantages of StandUP Wireless' Service Offering.....
B. The Benefits of Competitive Choice.................
C. Impact on the Universal Service Fund..........
V. ANTI-DRUG ABUSE CERTIFICATION
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VI. CONCLUSION .........30
TABLE OF EXHIBITS
Exhibit
Certifi cation ......................,
Proposed Lifeline Offering
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StandUP Wireless' FCC-Approved Compliance Plan
Coverage Area .........
Sample Advertisernent .............
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Corporate Structure Diagrams ..6
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of
CASE NO (rto - -T- /s-o t
GLOBAL CONNBCTION INC. OF AMERICA
DBA STAI\D UP WIRELESS FOR
DBSIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER
APPLICATION OF GLOBAL CONNECTION INC. OF AMERICA
DBA STAND UP WIRELESS FOR DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS CARRIER
I. INTRODUCTION
Global Connection Inc. of America dba STAND UP WIRELESS ("StandUP Wireless" or
the "Compaoy"), by its undersigned counsel, and pursuant to Section 2la@)Q) of the
Communications Act of 1934, as amended (the "Act"),1 Sections 54.101 through 54.207 of the
Rules of the Federal Communications Commission ("FCC"),2 and the rules and regulations of
the ldaho Public Utilities Commission ("Commission"),3 hereby submits this Application for
Designation as an Eligible Telecommunications Carrier ("ETC") in the State of ldaho. StandUP
Wireless seeks ETC designation solely to provide Lifeline service to qualifying Idaho
consumers; it will not (and is not eligible to) seek access to funds from the federal Universal
Service Fund ("USF") for the purpose of participating in the Link-Up program or providing
I 47 U.S.C. $ 2la(eX2)
2 47 C.F.R. $$ 54.10r-54.207
3 See ln the Matter of the Application of IIWC l.Iolding Co., Inc. d/b/a Cellular-one Seeking Designation as an
Eligible Telecommunications Carrier lhat may Receive Federal Universal Service Supporl, Order No. 29841
(August 4,2005) ("Commission Order No. 29841").
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service to high cost areas.a StandUP Wireless requests that its designation as an ETC include the
authority to participate in and receive reimbursement from the Idaho Telephone Service
Assistance Program (ITSAP). As demonstrated herein, and as certified in Exhibit I to this
Application, StandUP Wireless meets all the statutory and regulatory requirements for
designation as an ETC in the State of Idaho, including the requirements outlined in the FCC's
US[\\CC Transformalion Order,s Lifeline and Link (tp Reform Order6 and Lifeline
Modernization Order.T Rapid grant of StandUP Wireless' request, moreover, would advance the
public interest because it would enable the Company to commence much needed Lifeline
services to low-income Idaho residents as soon as possible. Accordingly, the Company
respectfully requests that the Commission expeditiously approve this Application for ETC
designation.
All correspondence, communications, pleadings, notices, orders and decisions relating to
this Application should be addressed to:
Lance J.M. Steinhart
Lance J.M. Steinhart, P.C.
Attorney for Global Connection lnc. of America dba STAND UP WIRELESS
1725 Windward Concourse, Suite 150
a Given that the Company only seeks Lifeline support from the low-income program and does not seek any
high-cost support, ETC certification requirements for the high-cost program are not applicable to the Company.
s In the Matler of Connect America l'und, A National Broadband Plan for Our Future, Establishing Just and
Reasonable Rates for Local Exchange Carriers, High-Cost Universal Ser-vice Support, Developing a Unified
Intercarrier Compensation Regime, Federal-State Joint Board on Universal Service, Lifeline and Link-Up,
(Jniversal Service Reform Mobilily F-und, WC Docket No. 10-90, GN Docket No. 09-5 I , WC Docket No. 07- I 35,
WC Docket No. 05-337, CC Docket No. 96-45, WC Docket No. 03-109, WT Docket No. l0-208, Report and Order
and Further Notice of Proposed Rulemaking, FCC I I -l6l (rel. Nov. 18, 201 l) (*USF/ICC Transformation Order ").
6 In the Matter of Lifeline and Link Up Reform and Modernization, Lifeline and Link Up, Federal-Stale Joint Board
on {/niversal Service, Advancing Broadband Availabilily 'fhrough Digital Lileracy l-raining, WC Docket No. I I -42,
WC Docket No. 03-109, CC Docket No. 96-45, WC Docket No. 12-23, Report and Order and Further Notice of
Proposed Rulemaking, FCC l2-l I (rel. Feb. 6,2012) ("l,ifeline and Link (/p Reform Order").
1 In the Matter of Lifeline and l.ink Up Reform and Modernization, Tblecommunications Carriers Eligible for
Universal SeryiceSupporl,ConnectAmericaFund,WC DocketNo. ll-42,WCDocketNo.00-l97,WCDocket
No. 10-90, Third Report and Order, Further Report and Order, and Order on Reconsideration, FCC 16-38
(rel. Apr. 27,2016) (hereinafter, "T'hird Report and Order" or"Lifeline Modernization Order").
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Alpharetta, Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail : lstei nhart@,telecomcounsel.com
II. BACKGROUND
A. Company Overview
Global Connection Inc. of America ("Global Connection") is a Georgia Corporation,s with
its principal office located at 5555 Oakbrook Parkway, Suite 620, Norcross, Georgia 30093.
Global Connection is currently a wholly owned subsidiary of Global Connection Holdings
Corporation ("Global Holdings"), a U.S. company whose principal place of business is located at
5555 Oakbrook Parkway, Suite 620, Norcross, GA 30093. Global Holdings operates as a
holding company for Global Connection and does not provide telecommunications services.
Global Connection does not have any operating companies or telecommunications affiliates.e
Global Connection provides or is registered to provide prepaid wireline local exchange
and/or long distance services to residential customers in twenty-six (26) states,l0 and is
designated as an ETC to provide l,ifeline services to low-income consumers on a wireline basis
in twelve (12) states.ll Global Connection provides prepaid wireless telecommunications
8 Global Connection was incorporated in the State of Georgia on June l, 1998.
e Following the proposed change in Global Connection's majority ownership described further herein, the
Company's corporate and trade names and identifiers will remain unchanged and it will continue to have no separate
operating companies; however, it will be affiliated with Prepaid Wireless Group, LLC, Prepaid Wireless Wholesale,
LLC and X Wireless as discussed in detail in Section III.I herein, and Cintex Wireless, LLC,a Maryland limited
liability company providing Lifeline and non-Lifeline prepaid wireless services in Arkansas, Maryland, Maine,
Rhode Island and West Virginia, and wholesale wireless telecommunications services.
r0 Those states are: Alabama, Arkansas, Colorado, Florida, Georgia, Illinois, Indiana, Kansas, Kentucky, Louisiana,
Michigan, Minnesota, Missouri, Mississippi, Nebraska, New Mexico, North Carolina, Ohio, Oklahoma, Oregon,
South Carolina, Tennessee, Texas, Washington, West Virginia and Wisconsin. Global Connection also holds
domestic interstate and international section 214 authority from the FCC. The Company is properly registered with
the FCC to provide telecommunications services pursuant to 47 C.F.R. $ 64.1195.
rr Those twelve states are: Alabama, Arkansas, Florida, Georgia, Kentucky, Louisiana, Michigan, Mississippi, North
Carolina, South Carolina, Tennessee and Texas.
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services under its d/b/a StandUP Wireless in twenty-six (26) territories,12 is designated as an
ETC on a wireless basis in all twenty-six (26) of its wireless service territories. StandUP
Wireless currentlv has applications for wireless ETC designation pending with Hawaii. New
Jersey, Washington, and with the FCC (for Alabama, Connecticut, Delaware, District of
Columbia, Florida, New Hampshire, New York, North Carolina, Tennessee, and Virginia); no
such applications have been denied.
StandUP Wireless provides commercial mobile radio service ("CMRS") by using the
Sprint Spectrum L.P. ("Sprint") and 'f-Mobile USA C'T-Mobile") (collectively, "Underlying
Carriers") networks on a wholesale basis. StandUP Wireless obtains from its Underlying Carriers
the network infrastructure and wireless transmission facilities to allow StandUP Wireless to operate
as a Mobile Virtual Network Operator ("N4\rNO"), similar to TracFone Wireless, Inc.
("TracFone") and Virgin Mobile USA, L.P. ("Virgin Mobile"), who have been granted ETC status
by the Commission.l3
StandUP Wireless' prepaid wireless services are affordable, easy-to-use, and attractive to
low-income and lower-volume consumers, providing them with access to emergency services and
a reliable means of communication that can be used both at home and while traveling to remain in
touch with friends and family and for contacting prospective employers. StandUP Wireless offers
consumers simple and affordable prepaid calling plans, a variety of prepaid service plans,
easy-to-use handsets and high-quality customer service. Given its pricing and marketing strategy
12 Those territories are: Arkansas, Arizona, Califomia, Colorado, Georgia, Iowa, Kansas, Kentucky, Louisiana,
Massachusetts, Maryland, Michigan, Minnesota, Missouri, Nebraska, Nevada, Ohio, Oklahoma, Pennsylvania,
Puerto Rico, Rhode Island, South Carolin4 Texas, Utah, Wisconsin and West Virginia.
t3 See In the Malter of the Amended Applicalion of IiacFone llireless, Inc. for Designation as an liligible
Telecommunications Carrier in the State of ldahofor the Limited Purposes of (ffiring Lifeline Service to Qualified
Households- Case No. TFW-T-09-01. Order No. 32586 (lune 29,2012) ("T'racF-one ETC Order"); In the Matter of
the Petition of Virgin lvlobile USA for Limited Designation as an liligible Telecommunications Carrier. Case No.
VMU-T-11-01. Final OrderNo.32645 (Sept. 19,2012) ("Virgin Mobile ETC Order").
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and the demographics of other, similar MVNOs' customers, StandUP Wireless anticipates that
many of its customers will be from low-income backgrounds and will not previously have enjoyed
access to wireless service because of economic constraints. poor credit history, or sporadic
employment. StandUP Wireless does not conduct credit checks or require customers to enter into
long-term service contracts as a prerequisite to obtaining wireless service.
By providing affordable wireless plans and quality customer service to consumers who are
otherwise unable to afford them, or who were previously ignored by traditional carriers,
StandUp Wireless will expand the availability of wireless services to many more consumers, which
is the principal reason that Congress created the universal service program.
B. Proposed Lifeline Offering
StandUP Wireless has the ability to provide all services supported by the universal service
program, as detailed in Section 54.101(a) of the FCC's Rules (47 C.F.R. $ 54.101(a)) throughout
Idaho. StandUP Wireless intends to be a leader in the prepaid marketplace by offering
consumers exceptional value and competitive amounts of voice and broadband usage. The
Company's Lifeline service offering will provide customers with the same features and
functionalities enjoyed by all other StandUP Wireless prepaid customers, with one notable
exception: StandUP Wireless's prepaid Lifeline services will not require payment of an out-of-
pocket fee by subscribers, but instead, StandUP Wireless will receive support from the l-ifeline
program as compensation for providing those services.
StandUP Wireless commits that its Lifeline-supported voice services will meet or exceed
the minimum service standards set forth in 47 C.F.R. $ 54.408, including as such standards are
updated going forward. StandUP Wireless' Lifeline-supported broadband services will also meet
the minimum service standards set forth in 47 C.F.R. $ 54.408 for mobile broadband internet
access services, including for service speed and data usage allowance, as such standards are
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updated going forward. To the extent StandUP Wireless provides devices for use with Lifeline-
supported broadband service, such devices will meet the equipment requirements set forth in 47
C.F.R. $ 54.408(0. and StandtlP Wireless will not impose an additional or separate tethering
charge for mobile data usage below the minimum standard.
StandUP Wireless intends to launch a unique initiative aimed at ensuring Lifeline-eligible
veterans and military personnel are made aware of the program. Attached hereto as Exhibit 2 is a
summary table of the Company's proposed Lifeline service offerings, which offers the following
plan options at no net cost to the Lifeline customer after application of Lifeline support:la (1)
Voice Plan. 750 minutes, unlimited tcxt messages and 100 megabytes (MB) of data per month;
or (2) Broadband Plan. 500 voice minutes, unlimited text messages, and I gigabyte (GB) of data
per month. All Lifeline plans will also include a free handset and access to the following custom
calling features at no charge: (l) Caller ID; (2) Call Waiting; (3) Call Forwarding; (a) 3-Way
Calling; and (5) Voicemail.
Lifeline customers will have the ability to purchase additional airtime as needed. At this
time, additional credits may be purchased at the rate of $5.00 for 200 credits; $10.00 for 450
credits; $20.00 for 1000 credits, $30.00 for 1500 credits; and $50.00 for 2500 credits by calling
our toll-free number. Each credit provides one (l) minute of airtime or one (1) SMS text
message. Additional data may also be purchased, currently at the rate of $3.95 for 250 MB;
$7.95 for 500 MB; and $15.95 for I GB.
14 Lifeline prices reflect application of federal Lifeline subsidy and an additional Company discount. The
Company's Lifeline terms and conditions can be found at wlryv.StandUpWireless.com. Given the FCC's proposed
limitation of enhanced tribal support to only facilities-based providers, the Company does not propose an enhanced
tribaf Lifeline plan option at this time (see WC Docket No.09-197, FCC l7-155, Fourth Reporl and Order released
Dec. 1,2017, section II.D-E; the proposed rule would be effective the later of August 1,2018 or 90 days after
announcement of approval from the Office of Management and Budget (OMB).
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In contrast to ILEC plans, which contain relatively small local calling areas, Stand Up
Wireless customers can use their included minutes to place calls statewide and nationwide,
because Stand Up Wireless does not constrict customers' use by imposing a local calling area
requirement--{omestic long distance calls are included at no additional charge. Stand Up
Wireless will also provide Lifeline customers with E9l I capabilities and the customer calling
features mentioned above. Calls made to StandUP Wireless customer service made by customers
via their StandUP Wireless handset will not deplete the customer's available airtime.
StandUp Wireless customers can contact StandUp Wireless customer service by dialing a short
code (e.g. *61l) from their StandUp Wireless phone, at no cost and with no deduction of voice
minutes used in association with such calls. Customers whose balance of voice minutes has been
exhausted will still be able to make outbound calls to Stand[IP Wireless customer service as long
as their service is active. Calls to 9ll emergency services are always free, regardless of service
activation or availability of minutes. The very nature of the wireless phone, i.e. mobility, has a
tremendous benefit to many consumers, a benefit to which a monetary value cannot be easily
assigned.
StandUP Wireless's Lifeline offering will allow feature-rich mobile and broadband
connectivity for qualifying subscribers at no cost to the subscriber after application of Lifeline
support, without the burden of credit checks or service contracts. StandUP Wireless's prepaid
offering will be an attractive altemative for consumers who need the mobility, security, and
convenience of a wireless phone, but who are concerned about usage charges or long-term
contracts.
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C. PIan Enrollment
Customers interested in obtaining information on the Lifeline program will be directed to
a toll-free telephone number and to the Company's website. which will contain information
regarding the Company's Lifeline service plans, including a description of the Lifeline program
and eligibility criteria. Customers may then request that an enrollment form (hereinafter also
referred to as application or certification form) be mailed to them, complete the online
application, download a form from the lnternet or retrieve a form in person at a Company event.
The application/certification form, a sample of which is attached as Exhibit A of Exhibit 3 (the
Company's approved FCC Compliance Plan), will explain in clear, easily understandable
language the following disclosures: 1s
(l) Lifeline is a federal benefit and willfully making false statements to obtain the benefit
can result in fines, imprisonment, de-enrollment or being barred from the program;
(2) only one Lifeline service is available per household; (3) a household is defined, for
purposes of the Lifeline program, as any individual or group of individuals who live
together at the same address and share income and expenses; (4) a household is not
permitted to receive l,ifeline benefits from multiple providers; (5) violation of the one-
per-household limitation constitutes a violation of the Commission's rules and will result
in the applicant's de-enrollment from the program, and (6) I-ifeline is a non-transferable
benefit and the applicant may not transfer his or her benefit to any other person.
The application/certification form will also state that: (l) the service 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, and (5) the program is limited to one discount per
household.16 If not applying in person, the applicant must return the signed enrollment form and
any supporting documentation to the address provided by StandUP Wireless. Processing of
ts See 47 C.F.R. S 54.41O(dXl). StandUP Wireless will comply with the requirement to utilize the USAC standard
application/certification form beginning July l, 2018; See F'CC lttireline Compelition Bureau Provides Guidqnce on
Universal FormsJbr the Lifeline Program, WC Docket No, ll-42, Public Notice, "Wireline Competition Bureau
Provides Guidance on Universal Forms forthe Lifeline Program," DA l8-16l (rel. Feb.20,2018). The standard
application/certification forms are available on USAC's website (See USAC, Lifeline Forms,
http :/1www.usac.orgy'l i/tools/forms/default.aspx).
t6 See 47 C.F.R. S 54.405(c).
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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 [,ifeline program.
In addition, the Company will notify the applicant that the prepaid service must be
personally activated by the subscriber and the subscriber must use their service every thirty (30)
days. StandUp Wireless will annually re-certifo the continued eligibility of all of its Lifeline
subscribers in accordance with federal and Commission regulations, and the Company's
certification form will also require all consumers, at sign up and annually thereafter, to provide
the information and certifications, under penalty of perjury, required by FCC rules (47 C.F'R'
g 54.410(d) and (f1). See Exhibit 3 for more detailed enrotlment information.rT
D. Prevention of Waste, Fraud and Abuse
StandUP Wireless recognizes the importance of safeguarding the USF' StandUp Wireless
has implemented measures and procedures to prevent duplicate Lif'eline benefits being awarded
to the same household. StandUP Wireless complies with the requirements of the National
Lifeline Accountability Database ("NLAD") and section 54.404 of the FCC's rules. As such the
Company (or Eligibility Administrator, where applicable) queries the NLAD for every
enrollmentl8 to determine whether a prospective subscriber is currently receiving a Lifeline
service from StandUP Wireless or any other ETC, and whether anyone else living at the
prospective subscriber's residential address is currently receiving Lifeline service.le In addition,
ti See also the Company's Revised Compliance Plan filed April 16, 2Ol8 and currently pending with the FCC:
r{r With the limited exception of states that have opted out of the NLAD. In those states, the Company will query the
state duplicates database.
le See Lifeline and Link Up Reform Order \203'
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Company personnel emphasize the "one Lifeline service per household" restriction in their direct
sales contacts with potential customers.
Moreover- the FCC has taken steps to further curb abuse in the Lifeline program by
establishing the National Lifeline Eligibility Verifier ("National Verifier"), which transfers the
responsibility of eligibility determination away from Lifeline providers.2o StandUP Wireless
will rely on the National Verifier, once in place, to determine initial and ongoing eligibility of
Idaho Lifeline subscribers.
Consistent with federal regulations, the Company will not seek USF reimbursement for
new subscribers until they have personally activated the service, either by initiation and/or actual
use of the service, and will de-enroll any subscriber that has not used the Company's Lifeline
service as set forth in 47 C.F.R. $ 54.a07(c)(2). An account will be considered active if the
authorized subscriber establishes usage, as "usage" is defined by 47 C.F.R. $ 54.407(c)(2),
during the specified timeframe, currently a period of thirty (30) days. or during the notice period
set forth in 47 C.F.R. $ 54.405(e)(3), currently a period of fifteen (15) days. In accordance with
47 C.F.R. $ 54.a05(e)(3), StandUP Wireless will provide the subscriber advanced notice, using
clear, easily understood language, that the subscriber's failure to use the Lifoline service within
the notice period will result in service termination for non-usage. Customers that have been
deactivated may participate in the Company's Lifeline service in the future by reapplying and re-
establ ishing eligibi lity.
To further protect the integrity of the USF, StandtlP Wireless has contracted with
CGM, LLC of Roswell, Georgia, a lifeline service bureau, to edit all subsidy request data. CGM
will process and validate the Company's subsidy data to prevent: (l) Duplicate Same-Month
20 See l,ifeline Modernization Order, section III.C.
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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) Inaqtive lines receiving srrbsidv: CGM's systems compare all subsidy
requests to underlying network status to ensure that subsidies are requested only for active lines.
Through the processes described above, StandUP Wireless ensures that it does not over-request
from support funds.
E. The Commission Has Jurisdiction to Designate Wireless ETCs.
Section 2la@)Q) of the Act provides state public utility commissions with the "primary
responsibility" for the designation of ETCs.21 Although Section 332(c)(3)(A) of the Act
prohibits states from regulating the entry of or the rates charged by any provider of commercial
mobile service or any private mobile service, this prohibition does not allow states to deny
wireless carriers ETC status.22 Therefore, the Commission has the authority to designate
StandUP Wireless as an ETC. Pursuant to this authority, the Commission has designated
numerous carriers as ETCs in the State of ldaho, including wireless carriers.2s Under the Act, a
state public utility commission with jurisdictional authority over ETC designations must
designate a common carrier as an ETC if the carrier satisfies the requirements of Section
2la(e)(l). Stand[IP Wireless recognizes that Section zla@)Q)(A) of the Act states that ETCs
shall offer services, at least in part, over their own facilities and that Section 54.201(i) of the
FCC's Rules (47 C.F.R. $ 54.201(i)) prohibits state commissions from designating as an ETC a
telecommunications carrier that offers services exclusively through the resale of another carrier's
services. However, the FCC has granted forbearance from enforcement of this facilities
2' 47 u.s.c. g 2la(e)(2).
22 USF Order, at 8858-59, ![ 145.
21 See e.g., T'racFone ETC Order and Virgin Mobile ETC Order
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requirement to carriers seeking Lifeline-only ETC designation.2a Section 10(e) of the Act (47
U.S.C. $ 160(e)) provides: "[a] State commission may not continue to apply or enforce any
provision of this chapter that the [Federal Communications] Commission has determined to
forbear from applying under subsection (a) of this section." As such, the Commission is required
by Section l0(e) to act in accordance with the FCC's grant of forbearance, and therefore, may
not apply the facilities-based requirement to StandUP Wireless. Therefore, the Commission has
the authority under Section Ta@)Q) of the Act to grant StandUP Wireless' request for
designation as an ETC throughout the State of Idaho.
III. STANDUP WIRELESS SATISFIES THB REQUIREMENTS FOR DESIGNATION
AS AN ETC
Section 254(e) of the Act provides that, "only an eligible telecommunications carrier
designated under section 214(e) shall be eligible to receive specific federal universal service
support." Section zla@)Q) of the Act authorizes state commissions, such as the Commission, to
designate ETC status for federal universal service purposes and authorizes the Commission to
designate wiretess ETCs.25 Section 2la(e)(l) of the Act and Section 54.201(d) of the FCC's
rules provide that applicants for ETC designation must be common carriers that will offer all of
the services supported by universal service, either using their own facilities or a combination of
their own facilities and the resale of another carrier's services, except where the FCC has
forborne from the "own facilities" requirement. Applicants also must commit to advertise the
availability and rates of such services,26 and provide additional information set forth in
2a See Lifeline and Link Up Reform Order atl368.
2s See Federal-Stote Joint Board on Universal Service, First Report and Order, 12 FCC Rcd 8776, 8858-59, fl 145
(1997) (*USF Order").
26 See 47 U.S.C. $ 21a(e)(l) and 47 C.F.R. $ 54.201(dX2).
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47 C.F.R. $ 5a.202(a). As detailed below, StandUP Wireless satisfies each of the above-listed
requirements.
A.StandUP Wireless Will Provide Service Consistent with the FCC's Grant of
Forbearance from Section 214's Facilities Requirements
Although Section 214 requires ETCs to provide services using their facilities, at least in
part, the FCC has forborne from that requirement with respect to carriers such as
StandUP Wireless. In the Lifeline and Link Up Reform Order, the FCC granted forbearance from
the "own-facilities" requirement contained in Section 2la(e)(l)(A) for carriers that are, or seek to
become, I-ifeline-only ETCs, subject to the following conditions:27
(l) the carrier must comply with certain 9l I requirements [(a) providing its Lifelinc
subscribers with 9l I and E9l1 access, regardless of activation status and availability of
minutes; (b) providing its Lifeline subscribers with E9l l-compliant handsets and replacing,
at no additional charge to the subscriber, noncompliant handsets of Lifeline-eligible
subscribers who obtain I-ifeline-supported services; and (c) complying with conditions (a)
and (b) starting on the effective date of this Order]; and
(2) the carrier must file, and the Bureau must approve, a compliance plan providing specific
information regarding the carrier's service offerings and outlining the measures the
carrier will take to implement the obligations contained in this Order as well as further
safeguards against waste, fraud and abuse the Bureau may deem necessary.
In accordance with the Lifeline and Link Up Reform Order, StandUP Wireless filed a
Compliance Plan with the FCC, which the FCC approved on May 25,2012.28 A copy of its
FCC-Approved Compliance Plan is attached hereto as Exhibit 3. StandUP Wireless commits to
providing Lifeline service in Idaho in accordance with its FCC-approved Compliance Plan and in
compliance with applicable state and federal regulations, to the extent amendments thereto may
supersede commitments made in the Compliance Plan.
27 See Lifeline and Link Llp Reform Order atfl\368,373, and379.
28 Wireline Competition Bureau Approves the Compliance Plans oJ'American Broadband & I'elecommunicctlions,
Budget Prepay, Consumer Cellular, Global Connection, Terracom and Total Call, WC Dckt. Nos. 09-197 and
ll-42,DA 12-828 (rel. May 25,2012).
13
B. StandUP Wireless Is a Common Carrier
CMRS providers like StandUP Wireless are treated as common carriers.2e
C. StandIIP Wireless Will Provide All Supported Services
Through its Underlying Carriers, StandUP Wireless is able to provide all of the supported
services required by Section 54.101(a) of the FCC's Rules (47 C.F.R. $ 54.101(a)) as follows:
l. Voice Telephony Service
As set forth in 47 C.F.R. $ 54.101(a)(l), eligible Voice Telephony Services must provide
the following:
Voice Grade Access to the Public Switched Telephone Network. StandUP Wireless
provides voice grade access to the public switched telephone network ("PSTN") through the
purchase of wholesale CMRS services from its facilities-based underlying carriers.
Local Usase At No Additional Charee. StandUP Wireless offers rate plans that provide
its customers with minutes of use for localservice at no additionalcharge.
Access to Emergency Services. StandUP Wireless provides 9l I and E9l I access for all of
its customers to the extent the local government in its service area has implemented 911 or E9l1
systems. As noted, calls to 9l I emergency services will always be free and will be available
regardless of service activation status or availability of minutes. StandUP Wireless also complies
with the FCC's regulations governing the deployment and availability of E9ll compatible
handsets.
2e Implementation of Sections 3(n) and 332 of the Communicalions Act, Regulatory Trealmenl of Mobile Services,
GN Docket No. 93-252, Second Report and Order, 9 FCC Rcd l4l I, 1425 n 37 , 1454-55 n rcz 0994) (wireless
resellers are included in the statutory "mobile services" category, and providers of cellular service are common
carriers and CMRS providers); 47 U.S.C. $ 332(cXl)(A) ("mobile services" providers are common carriers); see
also PCIA Petitionfor Forbearance for Broadband PC.S, WT Docket No. 98-100, (Memorandum Opinion and
Order and Notice of Proposed Rulemaking, l3 FCC Rcd 16857, 16911 fl lll (1998) ("We concluded [in the Second
Report and Order) that CMRS also includes the following common carrier services: cellular service, ... all mobile
telephone services and re.sellers of such services.") (emphasis added).
14
Toll Limitation. In its Lifeline and Link Up Reform Order, the FCC provided that toll
limitation would no longer be deemed a supported service.30 "ETCs are not required to offer toll
limitation service to low-income consumers if the Lifeline offering provides a set amount of
minutes that do not distinguish between toll and non-toll calls."ll Nonetheless, StandUP
Wireless' offerings inherently allow Lifeline subscribers to control their usage, as its wireless
service is offered on a prepaid, or pay-as-you-go, basis. StandUP Wireless' service, moreover, is
not offered on a distance-sensitive basis and local and domestic long distance minutes are treated
the same. StandI-IP Wireless will not seek reimbursement for toll limitation service.
2. Broadband Internet Access Services
Broadband Intemet access service ("BIAS") is a supported service as of
December 2,2016. The FCC has stated that BIAS consists of the ability for a user to receive
"the capability to transmit data to and receive data from all or substantially all Intemet endpoints,
including any capabilities that are incidental to and enable the operation of the communications
service, but excluding dial-up Internet access service."32 StandUP Wireless provides BIAS to
low-income consumers via resale of its underlying carriers' mobile services.
D. StandUP Wireless Requests Designation Throughout Its Service Area in
Idaho
StandUP Wireless is not a rural telephone company as defined in Section 153(37) of the
Act (47 U.S.C. $ 153(37)). Accordingly, StandUP Wireless is required to describe the
geographic area(s) within which it requests designation as an ETC. StandUP Wireless requests
ETC designation that is statewide in scope (excluding tribal lands), to allow the Company to
provide Lifeline service wherever its underlying, facilities-based providers have wireless
10 See Liftline and Link (lp Rejbrm Order at\367
3t See id. at fl 49.
32 See 47 C.F.R. $ 8.2(a).
t5
coverage. The current zip code coverage footprint is attached hereto as Exhibit 4.
StandUP Wireless understands that its service area overlaps with rural carriers in ldaho, but
maintains that the public interest factors described below justify its designation in these carriers'
service areas, especially because it seeks ETC designation solely to utilize USF funding to
provide Lifeline service to qualified low-income consumers. StandUP Wireless is not eligible
for and does not seek Link-Up or high-cost support.
Therefore, designation of StandUP Wireless as an ETC will cause no groMh in the
high-cost portions of the USF and will not erode high-cost support from any rural telephone
company. In fact, the FCC has determined that "[d]esignation of competitive ETCs promotes
competition and benefits consumers in rural and high-cost areas by increasing customer choice,
innovative services, and newtechnologies."33 While federal rules (47 U.S.C. $$ 160,21a(e)(5)
and 47 C.F.R. $ 54.207(b)) require that the service area of an ETC conform to the service area of
any rural telephone company serving the same area (the "service area conformance"
requirement), the FCC's Lifeline and Link Up Reform Memorandum Opinion and Order (FCC
13-44 released April 15, 2013) authorized forbearance from the service area conformance
requirements with respect to carriers seeking to provide Lifeline-only service.3a In light of this
forbearance, the Commission has the authority to designate ETCs such as StandUP Wireless in
rural areas without concern for the service area conformance requirement.35
33 See Western ll'ireless Corporation Petition .for Designation as an Eligible T'elecommunicalions Carrier in the
State of lltyoming, Memorandum Opinion and Order, I 6 FCC Rcd 48, 55 (2000).
3a See In the Matter of Telecommunications Carriers liligible.for Support, Lifeline and Link Llp Reform, WC Docket
No. 09- 197, WC Docket No. I 1 -42, Memorandum Opinion and Order, FCC l3-44 (rel. April 15, 2013).
3s See 47 C.F.R. $ 54.207(c).
r6
E. StandUP Wireless Will Advertise the Availability of Supported Services
StandUP Wireless will advertise the availability and rates for the services described above
using media of general distribution as requiredby 47 C.F.R. $ 54.201(dX2) and the rules adopted
by this Commission. StandUP Wireless' advertising will comply with the requirements set forth
inthe Lifeline and Link Up Reform Order, as outlined in StandUP Wireless' Compliance Plan.36
The Company will advertise its services in a manner reasonably designed to reach those
likely to qualify for Lifeline service, using mediums for outreach such as the Internet, mass
media, outreach events, and community and charitable involvement. StandUP Wireless will
engage in advertising campaigns specifically targeted to reach those likely to qualifu for Lifeline
service, promoting the availability of cost-effective wireless services to this neglected consumer
segment. StandUP Wireless may also promote the availability of its Lifeline offering by
distributing brochures at various state and local social service agencies, and may partner with
nonprofit assistance organizations in order to inform customers of the availability of its Lifeline
service. In addition, StandUP Wireless intends to utilize its network of retail partners (once
established) to help promote the availability of its Lifeline plans, especially retail outlets that are
frequented by low-income consumers (such as MoneyGram locations). StandtIP Wireless will
provide retail vendors with signage to be displayed where Company products are sold, and with
printed materials describing the Company's Lifeline program.i7
36 S:ee Exhibit 3, section I.F. See also Lifeline and Link Up Reform Orcler at Section VII.F, and 47 C.F.R. S
54.405(c).
31 See attached Exhibit 5 for a sample advertisement.
17
F. Service Commitment Throughout the Proposed Designated Service Area
StandUP Wireless will provide service in Idaho by reselling service which it obtains from
its underlying carriers. These providers' networks are operational and largely built out. Thus,
StandUP Wireless will be able to commence offering its Lifeline service to all locations served
by its underlying carriers very soon after receiving approval from the Commission.
In accordance with 47 C.F.R. $ 5a.202(a)(lXi), and by the attached certification, StandUP
Wireless commits to comply with the service requirements applicable to the low-income support
that it receives. Pursuant to 47 C.F.R. $ 5a.202(axlXii), a common carrier seeking designation
as a Lifeline-only ETC is not required to submit a five-year network improvement plan as part of
its application for designation as an ETC.38
G. Ability to Remain Functional in Emergency Situations
In accordance with 47 C.F.R. $ 54.202(a)(2), StandUP Wireless has the ability to remain
functional in emergency situations. As discussed, StandUP Wireless will utilize the extensive
and well-established Sprint and/or T-Mobile networks and facilities to provide its Lifeline
services. The Company understands that the Underlying Carrier networks have access to a
reasonable amount of back-up power to ensure functionality without an external power source,
are able to reroute traffic around damaged facilities, and are capable of managing traffic spikes
resulting from emergency situations. Indeed, these Underlying Carriers have repeatedly certified
to the FCC that their networks function in emergency situations.3e The Underlying Carriers
provide the same functionality to StandflP Wireless and its customers as these carriers provide to
themselves and their own customers.
38 See also Lifeline and Link Up Reform Order atl386.
3e See, e.g., Sprint Nexlel Corporation Verified Filing in Compliance with 47 C.f-.R. S 51.209, CC Docket No. 96-
45, at 6 (filed Sept. 30, 2011); In the Matter of felecommunicalions Carriers liligible .for (lniversal Sen,ice Supporl,
Petition of T-Mobile USA, Inc. for Designation os a Low-Income Eligibla'I'elecommunications Carrier, et al., WC
Docket No. 09- I 97, at 20 (released Aug. I 6, 20 I 2).
18
H. Commitment to Consumer Protection and Service Quality
Under FCC guidelines, an ETC applicant must demonstrate that it will satisfy applicable
consumer protection and service quality standards, and wireless applicants may satisfu this
requirement with a commitment to comply with the Cellular Telecommunications and Internet
Association's ("CTIA") Consumer Code for Wireless Service.ao StandUP Wireless hereby
commits to comply with the CTIA Consumer Code for Wireless Service.
I. StandUP Wireless is Financially and Technically Capable
In accordance with 47 C.F.R. $ 54.202(a)(4), StandtlP Wireless is financially and
technically capable of providing Lifeline-supported services. Global Connection has been
offering non-Lifeline and Lifeline wireline service since 1998 and began providing non-Lifeline
and Lifeline-supported wireless service in April 2011. The Company generates revenues from
non-Lifeline services; consequently, Global Connection has not relied (and does not intend to
rely) exclusively on Lifeline reimbursement for the Company's operating revenues. In the event
that USAC ceases disbursements for a period of time, the Cornpany will still be able to provide
service to its customers. [n addition, StandUP Wireless has access to capital from its investors.
Currently, through its interests in Global Holdings, the majority investor in Global Connection is
Milestone Partners, a Pennsylvania private equity firm. Further, as explained below, financial
support will continue to be available to StandUP Wireless through the new majority ownership
proposed for the Company.
Pursuant to the terms of a Stock Purchase Agreement dated February 16,2017,by and
among Global Connection, Global Holdings, and Odin Mobile, LLC ("Odin Mobile")
(collectively, the "Parties"), Odin Mobile will acquire seventy five percent(75%) of the stock in
ao See 47 C.F.R. $ 5a.202(a)(3).
t9
Global Connection, which will become its majority-owned direct subsidiary (the
"Transaction").41 A majority (ninety-nine percent (99%)) interest in Odin Mobile (and thus, the
majority indirect interest in Global Connection) will be held post-close by Paul Greene, a [J.S.
citizen. Global Holdings will retain twenty five percent (25%) ownership of Global
Connection.42 A diagram of the corporate structure of Global Connection and Odin Mobile both
pre-Transaction and post-close is provided as Exhibit 6.
Odin Mobile is a Maryland limited liability company with its principal offices located at
11565 Old Georgetown Road, Rockville, Maryland 20852. Odin Mobile provides prepaid
wireless service, including to visually impaired consumers by using the T-Mobile and Sprint
wireless networks through the Mobile Virtual Network Enabler ("M\rNE") Prepaid Wireless
Wholesale, LLC ("PPWW"), which is owned by Paul Greene. Odin Mobile purchases wireless
services (for voice minutes, text messages, mobile data, etc.) from PPWW, a Maryland limited
liability company, on a wholesale basis, packages those services into Odin Mobile's own service
plans and pricing, and bundles the wireless service with Odin Mobile's handset selection, mobile
applications, marketing materials, web interface, and customer service to produce finished wireless
service offerings to sell to end-user customers. Odin Mobile currently provides wireless service in
49 states and Puerto Rico. Odin Mobile and its affiliates have established considerable financial
resources that will be available, as needed, to support Global Connection in its operations and
continuing growth. Upon approval of the transaction, Odin Mobile will own 75%o of Global
Connection and plans to transfer allprepaid wireless operations to Clobal Connection.
4r The Parties are in the process ofobtaining all required approvals for the proposed Transaction from the FCC and
all applicable state regulatory authorities.
o2 The transaction will not result in any change to the ownership of Global Holdings or Odin Mobile.
20
Paul Greene is also indirectly a majority owner (the only lloh or greater owner) of Prepaid
Wireless Group, LLC ("PWG"), an MVNE that supplies airtime through the T-Mobile network.
PWG, a Maryland limited liability corporation, holds the wholesale agreements with T-Mobile and
the technology that connects the two networks. Mr. Greene is also indirectly a majority owner (the
only l0% or greater owner) of PPWW, which is the exclusive sales and distribution partner for
PWG services to the Mobile Virtual Network Operator ("MVNO") market. PWG and PPWW have
no foreign ownership and, like Global Connection, are not foreign carriers and are not affiliated
with foreign carriers in any market. PWG is one of the nation's longest standing aggregators of
wireless services. PWG is financially strong, carrying zero debt or outside investment. PWG
participates in the National Lifeline Association to lobby fbr favorable rules and regulations that
promote longevity and stability of the program.
PWG provides integrated communications solutions - including MVNO enablement,
cellular carrier access aggregation, voice/text/data services, and machine-to-machine ("M2M") and
lntemet of Things ("IoT") connectivity. PWG provides services to PPWW. Through the exclusive
sales and marketing relationships, PPWW helps companies deploy mobile services to their
customers. These MVNOs market and sell while PPWW provides backend network connectivity,
billing, rating, and other enablement services necessary to execute their business objectives.
PWG owns and operates a carrier grade voice, text, and mobile data telecommunications
infrastructure. These carrier-connected network elements are the hub of PWG and PPWW's
business. When voice, text, or data events are initiated, those events are passed to PWG's network
for event approval, dynamic call routing, live event rating, billing, and reporting. PWG has a long-
term contractual and network relationship with T-Mobile. Specifically, PWG network elements are
inter-connected with T-Mobile and T-Mobile leverages PWG as an MVNO, M2M, and loT
21
aggregator. PWG's network infrastructure and T-Mobile relationship enables PWG to leverage
equipment, connectivity, software, and expertise from each partner to deliver a complete
telecommunication solution.
PWG and PPWW have completed the strategic planning, development, and deployment of
all hardware, software, and programming integration necessary to deliver carrier-grade
telecommunication enablement services to the U.S. MVNO market. The systems represent a
bidirectional hub between the carrier and each wholesale partner. PWG published and manages a
robust API architecture enabling real-time activations, customer management functions, and billing
record delivery. This architecture allows PPWW to fully integrate into the carrier's ordering API
platform. All wholesale partners integrate directly with PPWW.
PWG's network is fully-redundant. This includes power, circuits, hardware, and network
connections, and the networkdelivers 99.999% uptime and reliability. PWG has deployed disaster
recovery mechanisms that ensure talk, text, and data services remain available. PPWW systems are
built for rapid deployment and support of wholesale clients. Operational support includes API
integration, customer activations, rate plan management, customer life-cycle messaging, equipment
warehouse and fulfillment, 24/7 call center services and Tier 2 technical support. In addition,
PPWW maintains subject matter, development, and innovation experts to engage and retain
wholesale partners and subscribers.
In addition to PWG and PPWW, Mr. Greene also owns X Wireless, which manufactures
and distributes wireless devices, and Consumer Network Services, a commercial property holding
company.a3 Mr. Greene holds 90% or more ownership interest in these companies. Both companies
are based in Maryland.
ar Mr. Greene also owns interest in several other non-communications-related businesses.
22
With respect to technical expertise, Global Connection has demonstrated its capabilities
over eighteen years of operations, now providing service pursuant to wireline and wireless ETC
designations in a combined twenty-nine (29) jurisdictions. The Company has considerable
experience complying with the requirements of the federal Lifeline program. Global Connection has
hired Eric Schimpf as its Chief Operating Offrcer and Jennifer Carter as its Compliance Officer. Mr.
Schirnpf was the Vice President and General Manager of Lifeline operations for FreedomPop. He
was instrumental in the Lifeline growth for i-wireless, LLC working to secure 34 state ETC
designations. In addition, Mr. Schimpf spent 20 years at Cincinnati Bell working in wireline and
wireless operations. He served the company as the General Manager of Cincinnati Bell Wireless,
where he managed prepaid and postpaid wireless services for the regional carrier. Ms. Carter has
held compliance roles for two wireless Lifeline ETCs and most recently was the Director of
Compliance at FreedomPop. Ms. Carter performed the function of Chief Compliance Officer,
Security Offrcer and Data Protection Officer for the company. As a result, the transaction will bring
together the full strength of Global Connection's history and management team capabilities, and
Paul Greene and additional team members' business expertise. "fhe resulting synergy will enable
Global Connection to achieve measurable groMh at the same time as it develops improved
operating efficiencies, both necessary components for the Company to thrive.
Finally, the Company has not been subject to enfbrcement sanctions related to the Low
Income Fund or ETC revocation proceedings in any state.aa The Company did enter into a Consent
Order with the Georgia Public Service Commission on December 13,2010 during the course of
44 The FCC issued a Notice of Apparent Liability for Forfeiture ("NAL") to the Company on December ll,20l3
alleging that StandUP Wireless failed to comply with FCC rules by requesting and receiving reimbursement
payments from the federal USF for intra-company duplicate Lifeline enrollments, a claim which the Company
timely disputed. Even if the alleged duplicates actually were duplicates (which StandUP disputed), StandUP was
still 99.38% effective at identifoing and preventing duplicate enrollments. The Company entered into a Consent
Decree with the FCC (Order released December 29,2017, FCC l7-175) which resolved the NAL with no admission
of liability by StandUP Wireless.
23
Global Connection's application for wireline ETC status in Georgia, relating to the inclusion of a
surcharge on bills to collect from customers contributions to the Georgia Universal Access Fund,
and charging customers a late fee and a processing fee for switching carriers or terminating service.
in a manner inconsistent with its tariff. Global Connection agreed to pay a civil penalty in the
amount of $55,000 and its ETC application was ultimately granted by the Georgia Public Service
Commission on February 22,2011.
J. StandUP Wireless Will Comply with the Lifeline Certification and
Verification Requ irements
Section 54.410 of the FCC's Rules requires ETCs to certify and verify a Lifeline
customer's initial and continued eligibility. StandUP Wireless will certify and verify consumer
eligibility in accordance with 47 C.F.R. $ 54.410, utilizing the streamlined eligibility criteria
implemented by the Lifeline Modernization Order (see 47 C.F.R. $ 54.409), and will annually
re-certify the continued eligibility of allof its subscribers.
K.StandUP Wireless Will Comply With All Regulations Imposed By The
Commission
By this Application, StandUP Wireless hereby asserts its willingness and ability to
comply with all the rules and regulations that the Commission may lawfully impose upon the
Company's provision of service contemplated by this Application. StandUP Wireless commits to
comply with applicable ITSAP regulations, including but not limited to required monthly
reporting, as well as execution of a Memorandum of Understanding with the Department of
Health and Welfare. StandUP Wireless further commits to remit required ITSAP funds to the
ITSAP Administrator. Upon Commission request, StandUP Wireless is prepared to answer
questions or present additional testimony or other evidence about its services within the state.
24
As the Company is not seeking high-cost support for its wireless service, it hereby
requests a waiver of the Commission Rules, Commission Order No. 29841 Section B.1 (two-year
network improvement and maintenance plan based on high-cost support). Because the Company
is not seeking high-cost support, this rule is not applicable and therefore should be waived.
IV. DESIGNATION OF STAI{DUP WIRELESS AS AN ETC WOULD PROMOTE
THE PUBLIC INTEREST
One of the principal goals of the Act, as amended by the Telecommunications Act of
1996, is "to secure lower prices and higher quality services for American telecommunications
consumers and encourage the rapid deployment of new telecommunications technologies" to all
citizens, regardless of geographic location or income.4s Designation of StandUP Wireless as an
ETC in Idaho will further that public interest. Whether because of financial constraints, poor
credit history, or intermittent employment, many low-income consumers often lack the countless
choices available to most consumers and thus have yet to reap the full benefits of the intensely
competitive wireless market.
The instant request for ETC designation must be examined in light of the Act's goal of
providing low-income consumers with access to telecommunications services. The primary
purpose of universal service is to ensure that consumers-particularly low-income consumers-
receive affordable and comparable telecommunications services. Given this context, designating
StandUP Wireless as an ETC would significantly benefit low-income consumers eligible for
Lifeline services in Idaho-the intended beneficiaries of universal service.
A. Advantages of StandUP Wireless' Service Offering
The public interest benefits of StandUP Wireless' wireless service include larger local
calling areas (as compared to traditional wireline carriers), the convenience and security afforded
as TelecommunicationsActof 1996, Pub. L.No. 104-104, ll0 Stat.56.
25
by mobile telephone service, the opportunity for customers to control cost by receiving a preset
amount of monthly airtime and data at no net cost, the ability to purchase additional usage at
flexible and affordable amounts in the event that included usage has been exhausted, and
9lllBgl I service in accordance with current I"CC requirements. The mobility of
StandUP Wireless' service will be particularly attractive to Lifeline-eligible consumers who may
frequently change residences or work in migratory jobs. Wireless service offers a stable contact
method where traditional landline service would be unavailable or not a viable option.
StandUP Wireless' prepaid wireless service is an especially attractive option for low-income
consumers because it alleviates customer concerns regarding hidden costs, varying monthly
charges and long term contract issues. For consumers with limited resources, the ability to meet
their communications and broadband access needs, while at the same time anticipating and
controlling the associated costs, is critical.
StandUP Wireless' Lifeline program will provide low-income Idaho residents with the
convenience and security offered by wireless services----even if their financial position deteriorates.
StandUP Wireless' Lifeline offering is an invaluable resource for emergency services and for
cash-strapped consumers who may be seeking employment or simply need to maintain contact
with family members. It is also a commonly accepted fact that in today's market all consumers,
including qualified Lifeline customers, view the portability and convenience of wireless service
not as a luxury, but as a necessity. Mobile service allows children to reach their parents,
wherever they may be, allows a person seeking employment the ability to be contacted by
potential employers, and provides end users with the ability to contact emergency service
providers, regardless of location.
26
Furthermore, in an effort to expand awareness of the Lifeline program among veterans,
StandUP Wireless has partnered with "Cell Phones for Soldiers," a national non-profit
organization that has been serving troops and veterans with free communication services and
emergency funding based on private donations since 2004.46 One of the barriers to expanding
Lifeline to eligible consumers, veterans included, is determining how to effectively connect with
those in need who are eligible. Cell Phones for Soldiers has an existing platform for communication
with troops and veterans and over a decade of experience serving their needs. By partnering
together, Cell Phones fbr Soldiers and StandUP Wireless will be able to better ensure that these low-
income veterans are made aware of and able to benefit from the Lifeline program. Providing
StandUP Wireless with the authority necessary to offer Lifeline services to Idaho residents-
including those who have dedicated their lives to protecting our country-who may be currently
without access to or otherwise unable to afford essential telephone and broadband services, or in
danger of losing wireless service altogether, undoubtedly promotes the public interest.
Finally, grant of StandUP Wireless' Application will serve the public interest in increasing
the number of ETCs in Idaho. By granting ETC status to StandUP Wireless, the Commission will
enable StandUP Wireless to increase the number of Idaho residents receiving Lifeline support,
thereby increasing the amount of USF money flowing into ldaho. In sum, ETC designation in the
State of Idaho would enable StandUP Wireless to provide all of the public benefits cited by the
FCC in its analysis in the Virgin Mobile Order. Namely, StandUP Wireless would provide
"increased consumer choice, high-quality service offerings, and mobility,"47 as well as the safety
and security of effective 9l I and E91l services.a8
a6 S'ee http://www.cellphonesforsoldiers.com/.
a1 See Virgin Mobile Order,24 FCC Rcd at 3395 !l 38
as See Id. at3391 1123.
27
B. The Benefits of Competitive Choice
The FCC has acknowledged the benefits to consumers of being able to choose from
among a variety of telecommunications service providers for more than three decades.ae
Designation of StandUP Wireless as an ETC will promote competition and innovation, spurring
other carriers to target low-income consumers with service offerings tailored to their needs,
ultimately resulting in improved services to consumers. Designation of StandUP Wireless as an
ETC will help ensure that quality services are available at'Just, reasonable, and affordable rates"
as envisioned in the Act.50 Introducing StandUP Wireless into the market as an additional
wireless ETC provider will afford low-income Idaho residents a wider choice of providers and
available services while creating a competitive marketplace as ETCs compete for a finite number
of Lifeline-eligible customers. Increasing the competitive marketplace of providers has the
potential to effectively increase the penetration rate and reduce the number of individuals not
connected to the PSTN.
C. Impact on the Universal Service Fund
StanduPWireless'request for designation as an ETC solely for purposes of participating
in the Lifeline program would not unduly burden the USF or otherwise reduce the amount of
funding available to other ETCs. With Lifeline, ETCs only receive support for customers they
obtain. The amount of support available to an eligible subscriber is exactly the same whether the
support is given through a company such as StandUP Wireless or the lncumbent LEC operating
in the same service area. The number of persons eligible for Lifeline support is the same the
Company's designation as an ETC; Stand{JP Wireless will only increase the amount of USF
Lifeline funding in situations where it obtains Lifeline customers not already enrolled in another
ae See, e.g., Specialized Common Carrier Services,29 FCC Rcd 870 (1971).
so See 47 U.S.C. $ 254(bX l).
28
ETC's Lifeline program. By implementing the safeguards set forth in the Lifeline and Link Up
Reform Order and utilizing the NLAD and National Verifier (once in place), the likelihood that
StandUP Wireless' customers are not eligible or are receiving duplicative support either
individually or within their household is greatly minimized. StandUP Wireless' ability to
increase the Lifeline participation rate of qualified low-income individuals will further the goal
of Congress to provide all individuals with affordable access to telecommunications service, and
thus any incremental increases in Lifeline expenditures are far outweighed by the significant
public interest benefits of expanding the availability of affordable wireless services to low-
income consumers. According to the FCC, "the additional choice and service options of another
wireless reseller oflering a service for low-income consumers represents a significant benefit for
consumers and is in the public interest," and "[a] new entrant should incent existing wireless
reseller ETCs to offer better service and terms to their customers, which provides additional
evidence that forbearance in the context of the Lifeline program outweighs the potential costs."5l
V. ANTI-DRUG ABUSE CERTIFICATION
StandUP Wireless certifies that no party to tlris Application is subject to denial of federal
benefits, including FCC benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988.
st See Petition of i-wireless, LLCfitr ForbearanceJiom 47 U.S.C $ Zta@(t)(.1), Order, FCC I0-l l7 (rel. June 25,
2010) at !J 19.
29
VI. CONCLUSTON
Based on the foregoing, designation of StandUP Wireless as an ETC in the State of Idaho
accords ..,i,ith the requirements of Section 21a@)Q) of the Act and is in the public interest.
WHEREFORE, StandUP Wireless respectfully requests that the Commission promptly
designate StandUP Wireless as an ETC in the State of Idaho for the purpose of participating in
the Lifeline program.
Respectfully submitted,
Lance J.M. Steinhart
Managing Attorney
Lance J.M. Steinhart, P.C.
1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail : [e-mail]
Attorneys /br Global Connection Inc of
America dba STAND UP II4RELESS
June I 8, 2018
30
EX}TIBIT I
Certification
STATE OT GEORGIA
(..(-OI" i NTY OF G WINNETT
Personally appeared hefore the undersigned. an ollcer duly authorized to administer oaths. Eric
Schimpf. rvho tirst duly sworn upon oath. deposes iud states that he is the Chief Operating
Otficer (COO) ul'Clohal Clonnection lnc. of AmErica d/bla StandUP Wireless. and has rcad the
tbregoing Petition and knows the contents thereof. and confirms that the statements made therein
arc lru$ to thc best of his knowledge and beliel.
Eric Schim Operating 0flicer
)
)
)
Subscribed and sworn to bcfon me this a I day of ll4c.,r ,2018.I
Public
My Commission expires:ft
?
It
Irlt
o o
4.gv
&rrt\o
-l
EXHIBIT 2
Proposed Lifeline Offering
Global Connection Inc. of America dlbla StandUP Wireless
Lifeline Offering
Terms & Conditions maintained at www.StandUpWireless.com
Includes:
o Handset
. Access to Voicemail, Caller-ID, call waiting, three-way calling, & call forwarding
features
o Free calls to 911 and StandUP Wireless customer service
o Domestic Long Distance at no extra cost
o Data at 3G+ speeds
Additional Minutes Additional Data:
Price Minutes
$5.00 200
$ 10.00 450
$20.00 I 000
$30.00 1 500
$50.00 2s00
PLAN DESCRIPTION VOICE TEXT DATA LIFELINE
PRICE
Voice Plan 750 Unlimited IOO MB $0.00
Broadband Plan 500 Unlimited lcB $0.00
Price Data
$3.9s 250 MB
$7.95 5OO MB
$ l s.9s IGB
EXHIBIT 3
StandUP Wireless' FCC-Approved Compliance Plan
NEW YORK, NY
LOS ANGELES, CA
CHICAGO, IL
STAMFORO, CT
PARSIPPANY. NJ
FACSIMILE
12021 312-8151
www. k e lle y d ry e . c o m
KELLEY DRYE & WARREN ur-p
A LIMITEO LIABILIIY PARTNERSHIP
WASHINGTON HARBOUR, SUITE 4OO
3050 K STREET, NW
WASHtNGTON, D.C. 20007-5108
(202) 3,{2-8400
BRUSSELS. BELGIUM DIRECT LINE: (2O2) 342-4544
EMAIL: [e-mail]
AFFILIAIE OFFICES
MUMBAI, INOIA
April30,2012
Vu ECFS
Marlene H. Dortch, Secretary
Federal Communications Commission
445 l2th Street, S.W.
Washington , DC 20554
Re: Global Connection Inc. of America Compliance Plan: WC Docket Nos.
09-197. t1-42
Dear Ms. Dortch:
On March 8,2012, Global Connection Inc. of America ("Global Connection")
submitted its Compliance Plan outlining the measures it will take to implement the conditions
imposed by the Commission in its Lifeline Re/brm Order.t On April 10,2012, Global
Connection submitted a revised version with a minor revision to its Model
Application/Certification Form, included as Exhibit A to its Compliance Plan. Based on a
meeting with Commission staff, Global Connection has further revised and supplemented its
compliance plan.
Global Connection has revised its Compliance Plan to: l) confirm in footnote 3
that Global Connection will follow the requirements of its Compliance Plan in all states where it
provides Lifeline service and receives reimbursements from the federal Low-Income fund; 2)
provide additional detail regarding Global Connection's enrollment process, Company personnel
training and potential fraud detection in Sections l.B. and LF.; 4) provide additional detail
regarding Global Connection's handset activation policy in Section I.E.; and 5) revise the agent
use box in the Application/Certification Form in Exhibit A.
See Lifeline ancl Link Up Reform ond Modernizalion, Lifeline ond Link Up, Federal-State
Joint Board on Universal Service, Advancing Broadband Availability T'hrough Digital
Literacy Training, WC Docket No. I l-42, WC Docket No. 03-109, CC Docket No. 96-
45, WC Docket No. 12-23, Report And Order and Further Notice Of Proposed
Rulemaking, FCC 12-l I (Feb. 6,2012).
KELLEY DRYE & WARREN r-r-p
Marlene H. Dortch, Secretary
April 30,2012
Page Two
Global Connection hereby re-submits its complete Compliance Plan with the
above revisions. Based on the minor nature of these changes, Global Connection reiterates its
request for expeditious approval of its Compliance Plan.
This letter and revised Compliance Plan is being filed electronically for inclusion
in the public record ofthe above-referenced proceedings. Please feel free to contact the
undersigned with any questions.
John J. Heitmann
Joshua T. Guyan
Counsel to Global Connection Inc. of America
cc Kim Scardino
Divya Shenoy
Charles Tyler
Garnet Hanly
Alex Minard
Respectfully submitted,
BEFORE THE
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
GLoSIL CoNNocTToN INC. oF AMERICA CoMPLIANCE PLAN
Global Connection Inc. of America ( "Global Connection" or the "Compahy"),1
through its undersigned counsel, hereby respectfully submits and requests expeditious
approval of its Compliance Plan outlining the measures it will take to implement the
conditions imposed by the Commission in its Lifeline Reform Order.z
The Company commends the Commission's commitment to a nationwide
communications system that promotes the safety and welfare of allAmericans, including
The Company hereby also reports its corporate and trade names, identifiers, and
its holding company, operating companies and affiliates as: Stand Up Wireless
(dba), and Global Connection Holdings Corporation (holding company). This
Compliance Plan applies only to Global Connection's wireless Lifeline service
offerings.
See Lifeline and Link Up ReJbrm and Modernization, Lifeline and Link Up,
Federal-State Joint Board on Universal Service, Advancing Broadband
Availability Through Digital Literacy Training, WC Docket No. ll-42, WC
Docket No. 03-109, CC Docket No. 96-45, WC Docket No. 12-23,Report And
Order and Further Notice Of Proposed Rulemaking, FCC l2-l I (Feb. 6,2012)
("Lifeline Reform Order"). The Company herein submits the information
required by the Compliance Plan Public Notice. See ll'ireline Competition
Bureau Provides Guidance.for lhe Submission of Compliance Plans Pursuanl to
the Lifeline Reform Order, WC Docket Nos. 09-197,11-42, Public Notice, DA
12-314 (rel. Feb. 29,2012).
2
In the Matter of
Telecommunications Carriers Eligible to
Receive Universal Service Support
Lifeline and Link Up Reform and Modernization
Global Connection [nc. of America
WC Docket No. 09-197
WC Docket No. I l-42
Lifeline customers. Global Connection will comply with 9l I requirements as described
below and it is submitting this Compliance Plan in order to qualify for blanket
forbearance from the facilities requirement of section 2la(eXlXA) of the
Communications Act and participate as an eligible telecommunications carrier ("ETC")
in the Lifeline p.og.a-.3
GlobalConnection willcomply fully with all conditions set forth in the Lifeline
Reform Order, as well as with the Commission's Lifeline rules and policies more
generally.a This Compliance Plan describes the specific measures that the Company
intends to implement to achieve these objectives. Specifically, this Compliance Plan: (l)
describes the specific measures that the Global Connection will take to implement the
obligations contained inthe LiJbline Reform Order, including the procedures the
Company follows in enrolling a subscriber in Lifeline and submitting for reimbursement
for that subscriber from the low income fund, materials related to initial and ongoing
certifications and sample marketing materials; and (2) provides a detailed description of
how Global Connection offers Lifeline services, the geographic areas in which it offers
services, and a detailed description of the Company's Lif'eline service plan offerings.
See Lifeline Reform Order, fl 368. Although Global Connection qualifies for and
seeks to avail itself of the Commission's grant of forbearance from the facilities
requirement of section 2la(e)(l)(A) forpurposes of the federalLifeline program,
the Company reserves the right to demonstrate to a state public utilities
commission that it provides service using its own facilities in a state for purposes
of state universal service funding under state program rules and requirements.
Global Connection will follow the requirements of the Commission's Lifeline
rules and this Compliance Plan in all states in which it provides Lifeline service
and receives reimbursements from the federal Low-lncome fund.
In addition, this Compliance Plan is consistent with the compliance plan filed by
Cricket Communications, Inc. See Notice of Ex Porte Communication of Cricket
Communications, Inc., WC Docket No. 09-197 (Sept. 23,201l) ("Cricket
Compliance Plan"). The Wireline Competition Bureau approved the Cricket
Compliance Plan on February 7 ,2012. See Telecommunications Carriers Eligible
.for Universal Service Srytport, Cricket Communications, lnc. Petitionfor
Forbearance, WC Docket No. 09-197, Order, DA l2-158 (Feb. 7, 2012).
4
2
l
Accpss ro 911 aNn E91l Senvrcnss
Pursuant to the Lifeline Reform Order, forbearance is conditioned upon the
Company: (l) providing its Lifeline subscribers *'ith 9l I and E91l access, regardless of
activation status and availability of minutes; and (2) providing its Lifeline subscribers
with E9l I -compliant handsets and replacing, at no additional charge to the subscriber,
noncompliant handsets of Lifeline-eligible subscribers who obtain Lifeline-supported
services.6 The Company will comply with these conditions starting on the effective date
of the Lifeline Reform Order.
The Company will provide its Lif€line customers with access to 911 and E9l l
services immediately upon activation of service. The Commission and consumers are
hereby assured that all Company customers will have available access to emergency
calling services at the time that Lifeline service is initiated, and that such 9l I and E9l I
access will be available from Company handsets, even if the account associated with the
handset has no minutes remaining.
Global Connection's existing practices currently provide access to 9l I and E9l I
services for all customers. The Company uses Sprint and Verizon Wireless as its
underlying network provider/carrier. Sprint and Verizon Wireless route 911 calls from
the Company's customers in the same manner as 9l I calls from their own retail
customers. To the extent that Sprint or Verizon Wireless is certified in a given PSAP
territory, this 9l I capability will function the same for the Company. Global Connection
also currently enables 9l I cmergency calling services for all properly activated handsets
regardless of whether the account associated with the handset is active or suspended.
See Compliance Plan Public Notice at 3
See Lifeline Reform Order,n373.
5
6
J
Finally, Global Connection transmits all 9l I calls initiated from any of its handsets even
if the account associated with the handset has no remaining minutes.
E911-Compliant Handsets. Global Connection will ensure that all
handsets used in connection with the Lifeline service offering are E9l I -
compliant. ln point of fact, the Company's phones have always been and will
continue to be 9l I and E9l l-compliant. The Company uses phones from BDI
Logistics LLC that have been through a stringent certification process, which
ensures that the handset models used meet all 9l I and E9l I requirements. As a
result, any existing customer that qualifies for and elects Lifeline service will
already have a 9lllBql I -compliant handset, which will be confirmed at the time
of enrollment in the I.ifeline program. Any new customer that qualifies for and
enrolls in the Lifeline program is assured of receiving a911/E9l l-compliant
handset as well, free of charge.
CouplnNCE Pr,AN
I. PRocrnuRES To Er,,lRor-r- A SusscnrBER rN LrrnlnrT
A. Policy
Global Connection will comply with the uniform eligibility criteria established in
new section 54.409 of the Commission's rules (when it becomes effective on June 1,
2012), as well as any additional certification and verification requirements for Lifeline
eligibility in states where the Company is designated as an ETC.
Therefore, all subscribers will be required to demonstrate eligibility based at least
on: (1) household income at or below 135%o of the Federal Poverty Guidelines for a
7 See Compliance Plan Public Notice at 3
4
household of that size; or (2) the household's participation in one of the federal assistance
programs listed in new sections 54.409(a)(2) or 5a.a09(a)(3) of the Commission's rules.
In addition, through the certification requirements described below. the Company will
confirm that the subscriber is not already receiving a Lifeline service and no one else in
the subscriber's household is subscribed to a Lifeline service.
B. Eligibility Determination
More than 90 percent of Global Connection's customer enrollment is done in-
person at events hosted by the Company, as opposed to over the phone or the Internet. At
such events, Global Connection requires all prospective customers to show a valid
government-issued photo identification, which is electronically scanned to detect
alterations. Each prospective customer is checked against Global Connection's internal
database in real-time to ensure that the customer does not already receive a Lifeline
benefit from the Company before the customer is enrolled.
As discussed in further detail in Section I.F. below, all employees or agents
("Company personnel") that conduct such in-person enrollments are lrained regarding the
eligibility and certification requirements in the Lifeline Reform Order and this
Compliance Plan, including the one-per-household requirement, and told to inform
potential customers of those requirements. New Company personnel undergo an initial
mandatory training session where they are given training materials, as well as shown
visual examples of documents acceptable to demonstrate eligibility for the Lifeline
program.
If Global Connection cannot determine a prospective subscriber's eligibility for
Lifeline by accessing income databases or program eligibility databases, Company
5
personnel will review documentation establishing eligibility pursuant to the Lifeline
rules.8 All personnel who interact with current or prospective customers will be trained
to assist I-ifeline applicants in determining whether they are eligible to participate based
on the federal and state-specific income-based and/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 the Lifeline Reform Order and
state-specifi c eligibility requirements using state-specific checklists.e
Proof of Elisibility. Company personnel will be trained on acceptable
documentation required to establish income-based and program-based eligibility. l0
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, fuderal or Tribal program; (3) program participation
documents (e.9., 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 p.og.a*. "
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 retiremenUpension statement of benefits;an Unemployment/Workmen's
See Lifeline Reform Order, 'lJ 100; section 54.41O(bXl)(iXB), 5a.al0(c)(l)(iXB);
Cricket Compliance PIan at 4.
See Cricket Compliance Plan at 6.
See Lifeline Reform Order, fl l0l.
Id. and section 54.al0(c)(lXiXB).
8
9
l0
ll
6
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.r2
Company personnel will examine this documentation for each Lifeline applicant,
and will record the type of documentation used to satisfy the income- or program-based
criteria by checking the appropriate box on the application form.l3 The Company witl
not retain a copy of this documentation.la Where the Company personnel conclude that
proffered documentation is insufficient to establish such eligibility, Global Connection
will deny the associated application and inform the applicant of the reason for such
rejection.ls ln the event that Company personnel cannot ascertain whether
documentation of a specitic type is sufficient to establish an applicant's eligibility, the
matter will be escalated to supervisory personnel.l6
,nrollment for lneli If Global Connection 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.lT A
demonstration of eligibility must comply with the annual verification procedures below
and found in new rule section 54.410(0, including the submission of a certification form
t2
l3
t4
l5
l6
t7
See Lifbline Reform Order, fll0l; section 54.41O.(bXlXiXB).
See Ldbline Reform Order, til01; sections 54.410(bXtXiii), 5a. l0(c)(1)(iii).
See LiJbline Reform Order,fll01;sections 54.410(bXlXii),5a.a10(c)(1)(ii).
See Cricket Compliance Plan at 6.
See id.
See Li/bline Reform Order,\ la3; section 5a.a05(e)(l).
7
C. Subscriber Certifications for Enrollment
Global Connection will implement certification policies and procedures that
enablc consumers to demonstrate their eligibility for Lifeline assistance to Companl,
personnel as detailed in the Lifeline Reform Order, together with any additional state
certification requirements.l8 The Company shares the Commission's concern about
abuse of the Lifeline program and is thus committed to the safeguards stated herein, with
the belief that these procedures will prevent the Company's customers from engaging in
such abuse of the program, inadvertently or intentionally.re Every applicant will be
required to complete an application/certification form containing disclosures, and
collecting certain information and certifications as discussed below.20 Applicants that do
not complete the form in person will be required to return the signed
application/certification to the Company by mail, facsimile, electronic mail or other
electronic transmission. In addition, Company personnel will verbally explain the
certifications to consumers when they are enrolling in person or over the phone.2l
Disclosures. The Company's application and certification forms will include the
following disclosures: (l ) Lifeline is a federal benefit and willfully making false
statements to obtain the benefit can result in fines, imprisonment, de-enrollment or being
barred from the program; (2) only one Lifeline service is available per household; (3) a
household is defined, for purposes of the Lifeline program, as any individual or group of
individuals who live together at the same address and share income and expenses; (4) a
l8
19
20
Lifeline Re.form Order, fl 6l; section 54.410(a).
^See Cricket Compliance Plan at 3.
See Model Application/Certification Form, included as Exhibit A. See
Compliance Plan Public Notice at 3.
Sce Lifeline Reform Order,n ln.2l
8
household is not permitted to receive Lifeline benefits from multiple providers; (5)
violation of the one-per-household limitation constitutes a violation of the Commission's
rules and will result in the applicant's de-enrollment from the program; and (6) Lifeline is
a non-transferable benefit and the applicant may not transfer his or her benefit to any
other person.22
Applications and certification forms will also state that: (l) the service is a
Lifeline service, (2) Lifeline is a government assistance program, and (3) only eligible
consumers may enroll in the program.23
In addition, the Company will notify the applicant that the prepaid service must be
personally activated by the subscriber and the service will be deactivated and the
subscriber de-enrolled if the subscriber does not use the service for 60 days.2a
Information Collection. The Company will also collect the following information
from the applicant in the application/certification form: (l) the applicant's full na-";"
(2) the applicant's full residential address (P.O. Box is not sufficient26); (3) whether the
applicant's residential address is permanent or temporary; (4) the applicant's billing
address, ifdifferent from the applicant's residential address; (5) the applicant's date of
birlh; (6) the last four digits of the applicant's Social Security number (or the applicant's
Tribal identification number, if the subscriber is a member of a Tribal nation and does not
have a Social Security number); (7) if the applicant is seeking to qualify for Lifeline
under the program-based criteria, the name of the qualifying assistance program from
See id.,\ l2l; section 54.410(dXl)
See section 54.405(c).
See Lifeline Reform Order, fl 114.
See Cricket Compliance Plan at 4.
See Lfbline Reform Ortler,l87 .
22
23
24
25
26
9
which the applicant, his or her dependents, or his or her household receives benefits;27
and (8) if the applicant is seeking to qualify for Lifeline under the income-based criterion,
the number of individuals in his or her household.2s
Applicant Certification. Consistent with new rule section 54.410(dX3), the
Company will require the applicant to certify, under penalty of perjury, in writing or by
electronic signature or interactive voice response recording,2e the following: (l) the
applicant meets the income-based or program-based eligibility criteria for receiving
Lifeline; (2) the applicant will notify the Company within 30 days if for any reason he or
she no longer satisfies the criteria for receiving Lifeline including, as relevant, if the
applicant no longer meets the income-based or program-based criteria for receiving
Lifeline support, the applicant is receiving more than one Lifeline benefit, or another
member of the applicant's household is receiving a Lifeline benefit; (3) if the applicant is
seeking to qualify for Lifeline as an eligible resident of Tribal lands, he or she lives on
Tribal lands; (4) if the applicant moves to a new address, he or she will provide that new
address to the Company within 30 days; (5) if the applicant provided a temporary
residential address to the Company, the applicant will be required to verify his or her
temporary residential address every 90 days; (6) the applicant's household will receive
only one Lifeline service and, to the best of the applicant's knowledge, the applicant's
household is not already receiving a Lifeline service;30 (7) the information contained in
the applicant's certification form is true and correct to the best of the applicant's
See Cricket Compliance Plan at 4.
See section 54.410(d)(2). See Cricket Compliance Plan at 4.
See Lifeline Reform Order. flu 168-69; section 54.419.
.lee Cricket Compliance PIan at 4.
27
28
29
30
r0
knowledge;'' 18; the applicant acknowledges that providing false or fraudulent
information to receive Lifeline benefits is punishable by law; and (9) the applicant
acknowledges that the applicant may be required to re-certify his or her continued
eligibility for Lifeline at any time, and the applicant's failure to re-certify as to the
applicant' s continued eligibility will result in de-enrollment and the termination of the
applicant's Lifeline benefits pursuant to the de-enrollment policy included below and in
the Commission's rules.
In addition, the applicant will be required to authorize Global Connection to
access any records required to verify the applicant's statements on the
application/certification form and to confirm the applicant's eligibility for the Company
Lifeline credit.32 The applicant must also authorize the Company to release any records
required for the administration of the Company Lifeline credit program, including to
USAC to be used in a Lifeline program database.33
D. Annual Verification Procedures
Global Connection will annually re-certify all subscribers by querying the
appropriate eligibility databases or obtaining a signed certification from each subscriber
consistent with the certification requirements above and new section 54.410(d) of the
Commission's rules. This certification will include a confirmation that the applicant's
household will receive only one Lifeline service and, to the best of the subscriber's
3l
32
l3
See id. at 5.
See id.
See Section 54.404(bX9). The application/certification form will also describe the
information that will be transmitted, that the information is being transmitted to
USAC to ensure the proper administration of the Lifeline program and that failure
to provide consent wilI result in the applicant being denied the Lifeline service.
See id. See also Cricket Compliance Plan at 5.
ll
knowledge, the subscriber's household is receiving no more than one Lifeline service.3a
Further, the verification materials will inform the subscriber that he or she is being
contacted to re-certify his or her continuing eligibility for Lifeline and if the subscriber
fails to respond, he or she will be de-enrolled in the program.35
2012 Verification. Global Connection will re-certify the eligibility of each of its
existing subscribers as of June 1 ,2012 on a rolling basis by the end of 2012 and report
the results to USAC by January 3l ,2013.36 The Company will contact its subscribers via
text message to their Lifeline supported telephone, or by mail, phone, email or other
Intemet communication. The notice will explain the actions the customer must take to
retain Lifeline benefits, when Lif'eline benefits may be terminated, and how to contact the
Company.
Verification De-Enrollment. Global Connection will de-enroll subscribers that do
not respond to the annual verification or fail to provide the required certification.3' Th"
Company will give subscribers 30 days to respond to the annual verification inquiry. lf
the subscriber does not respond, the Company will send a separate written notice
explaining that failure to respond within 30 days will result in the subscriber's de-
enrollment from the Lifeline program. If the subscriber does not respond within 30 days,
the Company will de-enroll the subscriber within five business days.
34
35
36
37
See Lifeline Reform Order, fl 120 and Cricket Compliance Plan at 8.
See Lifbline Reform Order, fl 145.
See id, fl 130.
See Lfeline Re/brm Order,l142; section 5a.5a.a05(e)(a).
l2
B. Activation and Non-Usage
Global Connection will not consider a prepaid subscriber activated, and will not
seek reimbursement for Lifelinc for that subscriber, until the subscriber activates the
Company's prepaid service by dialing a specified dedicated number from their Clobal
Connection-issued handset.38 For enrollments at in-person events, the Lifeline
application and certifications are tied to a phone number for the handset that is provided
to the new Lifeline customer. The customer activates the phone in-person with the
Company personnel on site. For enrollments that are over the phone or through the
Intemet, the phones are shipped directly to the eligible customer. The customer must
sign for the phone and then use it to call the dedicated Global Connection number
provided to activate the phone.
In addition, after service activation, the Company will provide a de-enrollment
notice to subscribers that have not used their service for 60 days. After 60 days of non-
use, the Company will provide notice to the subscriber that failure to use the Lifeline
service within a 30-day notice period will result in de-enrollment.3e Subscribers can
"use" the service by: (1) completing an outbound call; (2) purchasing minutes from the
Company to add to the subscriber's plan; (3) answering an incoming call from a party
other than the Company; or (4) responding to a direct contact from the Company and
confirming that the subscriber wants to continue receiving the service.a0
See Ldbline Reform Order,\257; section 5a.407(c)(l).
See Lifeline Reform Order,\257; section 5a.a05(e)(3). See Cricket Compliance
Plan at 2 (stating that it did not need to implement a non-usage policy because it
offered only plans with unlimited local and long distance calling).
See Lifeline Reform Order,l26l; section 5a.a07@)(2).
38
39
40
l3
If the subscriber does not respond to the notice, the subscriber will be de-enrolled
and the Company will not request further Lifeline reimbursement for the subscriber.
Global Connection will report annually to the Commission the number of subscribers de-
enrolled for non-usage by month.al
F. Additional Measures to Prevent Waste, Fraud and Abuse
To supplement its verification and certification procedures, and to better ensure
that customers understand the Lifeline service restrictions with respect to duplicates,
Global Connection will implement measures and procedures to prevent duplicate Lifeline
benefits being awarded to the same household. These measures entail additional
emphasis in written disclosures as well as live due diligence.a2
In addition to checking the database when it becomes available, Company
personnel emphasize the "one Lifeline phone per household" restriction in their direct
sales contacts with potential customers.43 Training materials include a discussion of the
limitation to one Lifeline phone per household, and the need to ensure that the customer
is informed of this restriction.aa All customer-facing employees and agents must
demonstrate understanding of the Commission's and Global Connection's rules and
policies by completing the Company's Lifeline training and pass a Company issued
exam. The training will be updated as needed, but at least every 90 days. Further, Global
Connection employs a dedicated compliance officer to oversee training and compliance
matters.
4l
42
43
44
See Lifeline Reform Order,\257; section 5a.a05(e)(3)
See Cricket Compliance Plan at 9.
See id. at 6,9.
See id.
t4
Database. When the National Lifeline Accountability Database ("National
Database") becomes available, the Company will comply with the requirements of new
rule section 54.404. The Company will query the National Database to determine
whether a prospective subscriber is currently receiving a Lifeline service from another
ETC and whether anyone else living at the prospective subscriber's residential address is
currently receiving Lifeline service.a5
One-Per-Household. Global Connection will implement the requirements of the
Lifeline Reform Oder to ensure that it provides only one Lifeline benefit per householda6
through the use of its application and certification forms discussed above, internal
database checks and its marketing materials discussed below. Upon receiving an
application for the Company's Lifeline service, the Company will search its own internal
records to ensure that it does not already provide Lifeline-supported service to someone
at the same residential address.aT If so, and the applicant lives at an address with multiple
households, the Company will require the applicant to complete and submit a written
USAC document containing the following: (l ) an explanation of the Commission's one-
45 See Lifeline Reform Order,11203. Company will also transmit to the National
Database the information required for each new and existing Lifeline subscriber.
See id., flfl 189-195; section 54.404(bX6). Further, Companywillupdate each
subscriber's information in the National Database within ten business days of any
change, except for de-enrollment, which will be transmitted within one business
day. See section 54.404(bX8),(10).
A "household" is any individual or group of individuals who are living together at
the same address as one economic unit. A household may include related and
unrelated persons. An "economic unit" consists of all adult individuals
contributing to and sharing in the income and expenses of a household. An adult
is any person eighteen years or older. lf an adult has no or minimal income, and
Iives with someone who provides financial support to himiher, both people shall
be considered part of the same household. Children under the age of eighteen
living with their parents or guardians are considered to be part of the same
household as their parents or guardians. See Lifeline Reform Order, fl 74; section
s4.400(h).
See Lifeline Reform Order, fl 78 and Cricket Compliance Plan at7.
46
t5
47
per-household rule; (2) a check box that an applicant can mark to indicate that he or she
lives at an address occupied by multiple households; (3) a space for the applicant to
certifl, that he or she shares an address with other adults who do not contribute income to
the applicant's household and share in the household's expenses or benefit from the
applicant's income, pursuant to the Commission's definition; and (4) the penalty for a
consumer's failure to make the required one-per-household certification (i.e., de-
enrollment).48 Further, if a subscriber provides a temporary address on his or her
application/certification form collected as described above, Global Connection will verify
with the subscriber every 90 days that the subscriber continues to rely on that address.ae
Finally, Company personnel 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 services," and ability to determine
whether he or she is already benefiting from Lifeline support, by informing the consumer
that not all Lifeline services are currently marketed under the name Lifeline.
Marketin Materials. Within the deadline provided inthe Lifeline Reform Order,
the Company will include the following information regarding its Lifeline service on all
marketing materials describing the service: (l) it is a Lifeline service,so (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) what documentation is necessary for enrollment; (7) Global Connection's
name (the ETC); and (8) consumers who willfully make a false statement in order to
rd.
See Lifeline Reform Order,\ 89.
See Cricket Compliance Plan at 4
48
49
50
16
obtain the Lifeline benefit can be punished by fine or imprisonment or can be barred from
the program.s' Th"re statements will be included in all print, audio video and web
materials (including social networking media) used to describe or enroll customers in the
Company's Lifeline service offering, as well as the Company's application forms and
certification forms.s2 This specifically includes the Company's website
(www.StanOUpWirele ) and outdoor signage.s3 A sample of the Company's
marketing materials is included as Exhibit B.
G. Company Reimbursements From the Fund
To ensure that the Global Connection does not seek reimbursement from the Fund
without a subscriber's consent, the Company will certify, as part of each reimbursement
request, that it is in compliance with all of the Commission's Lifeline rules and, to the
extent required, has obtained valid certification and verification forms from each of the
subscribers for whom it is seeking reimbursement.sa Further, the Company will transition
the submission of its FCC Forms 497 to the eighth day of each month in order to be
reimbursed the same month, and inform USAC, to the extent it deems necessary, to
transition its reimbursement process to actual claims rather than projected claims over the
course of more than one month.55 In addition, the Company will keep accurate records as
directed by USAC56 and as required by new section 54.417 of the Commission's rules.
5l
52
53
54
55
56
See Lifeline Reform Order,fl275; section 5a.405(c).
Id.
Id.
See Lifeline Reform Order, fl 128; section 54.407(d).
See Lifeline Reform Order,lTfl 302-306.
See section 54.407@).
t1
H. Annual Company Certifications
The Company will submit an annual certification to USAC, signed by a Global
Conncction officcr under pcnaltl'of pcrjurl', that the Company: (l) has policics and
procedures in place to review consumers' documentation of income- and program-based
eligibility and ensure that its Lifeline subscribers are eligible to receive Lifeline
services;s7 (2) is in compliance with all federal Lifeline certification procedures;58 and (3)
has obtained a valid certification form for each subscriber for whom the carrier seeks
Lifel ine reimbursement.se
In addition, the Company will provide the results of its annual re-
certifications/verifications on an annual basis to the Commission, USAC, the applicable
state commission and the relevant Tribal governments (for subscribers residing on Tribal
lands).60 Further, as discussed above, Global Connection will report annually to the
Commission the number of subscribers de-enrolled for non-usage by month.6r
The Company will also annually report to the Commission, USAC, and relevant
state commissions and the relevant authority in a U.S. territory or Tribal government as
appropriate,62 the company name, names of the company's holding company, operating
companies and affiliates, and any branding (such as a "dba" or brand designation) as well
as relevant universal service identifiers for each entity by Study Area Code.u' The
57
58
59
60
6l
62
63
See Lifeline Reform Order,n D6: section 5a.al6(a)(l).
See Lifeline Reform Order,l127; section 5a.al6@)(2).
See section 5a.al6@)(3).
See Lifeline Reform Order,ll 132,148; section 54.416(b).
See Lifeline Reform Order,n257; section 5a.a05(e)(3).
See section 5a.a22@).
See Lifeline Reform Order,fln296,390; section 54.422(a).
r8
Company will report annually information regarding the terms and conditions of its
Lifeline plans for voice telephony service offered specifically for low income consumers
during the previous vear. including the number of minutes provided and whether there are
additional charges to the consumer for service, including minutes of use and/or toll
calls.6a Finally, Global Connection will annually provide detailed information regarding
service outages in the previous year, the number of complaints received and certification
of compliance with applicable service quality standards and consumer protection rules, as
well as a certification that the Company is able to function in emergency situations.6s
I. Cooperation with State and Federal Regulators
Global Connection has cooperated and will continue to cooperate with federal and
state regulators to prevent waste, fraud and abuse. More specifically, the Company will:
Make available state-specific subscriber data, including the names and
addresses of Lifeline subscribers, to USAC and to each state public
utilities commission where the Company operates for the purpose of
determining whether an existing Lifeline subscriber receives Lifeline
service from another carrier,66
a
a Assist the Commission, USAC, state commissions, and other ETCs in
resolving instances of duplicative enrollment by Lifeline subscribers,
including by providing to USAC and/or any state commission, upon
request, the necessary information to detect and resolve duplicative
Lifeline claims;
64
65
66
Promptly investigate any notification that it receives from the
Commission, USAC, or a state commission to the effect that one of its
customers already receives Lifeline services from another carrier; and
See LiJbline Reform Order, fl 390; section 54.422(b)(5).
See Lifeline Reform Order, fl 389; section 54.422(b)(1)-(4).
The Company anticipates that the need to provide such information will sunset
following the implementation of the national duplicates database.
l9
a
II.
. Immediately de-enroll any _subscriber whom the Company has a
reasonable basis to believe6/ is receiving Lifeline-supported service from
another ETC or is no longer eligible - whether or not such information is
provided by the Commission, USAC, or a state commission.6s
Description of Lifeline Service Offerings6e
Global Connection will offer its wireless Lifeline service in the states where it is
designated as an ETC70 and throughout the coverage area of its underlying provider(s)
Sprint and Verizon Wireless. The Company's Lifeline offering will provide customers
with 100 anytime prepaid minutes per month, plus 100 anytime text messages, with
rollover, at no charge. Additionally, the Company will offer a 250 anytime talk and text
plan without rollover (one minute of talk time for each text). Lifeline customers can
purchase additional bundles of minutes in denominations of 55 (40 minutes), $10 (100
minutes), $20 (250 minutes), $30 (500 minutes) and $50 (1000 minutes). Airtime "top-
up" minutes are available for purchase at the Company's retail locations, through
customer service and on its website. Text messaging is available at the rate of one
minute of talk time per text message. Additional information regarding the Company's
plans, rates and services can be found on its website www.StandUpWireless.com.
In addition to free voice services, Global Connection's Lifeline plan will include a
free handset and custom calling features at no charge, including Caller lD, Call Waiting,
and Voicemail. All plans include domestic long-distance at no extra per minute charge.
See section 54.405(e)(l ).
&e Cricket Compliance Plan at 10.
See Compliance Plan Public Notice at 3.
Global Connection is currently designated as an ETC in Arkansas, Louisiana,
Maryland, Missouri and West Virginia.
67
68
69
'70
20
Calls to 9l I emergency services are always free, regardless of service activation or
availabi Iity of minutes.
III. Demonstration of Financial and Techrrical Capabilities and Certifications
Required for ETC DesignationTl
Financial and Technical Capabilities. Revised Commission rule 54.202(a)(4),47
C.F.R. 5a.202(a)(4), requires carriers petitioning for ETC designation to demonstrate
financial and technical capability to comply with the Commission's Lifeline service
requirements.T2 The Compliance Plan Public Notice requires that carriers' compliance
plan include this demonstration. Among the factors the Commission will consider are: a
carrier's prior offering of service to non-Lifeline subscribers, the length of time the
carrier has been in business, whether the carrier relies exclusively on Lifeline
reimbursement to operate; whether the carrier receives revenues from other sources and
whether the carrier has been the subject of an enforcement action or ETC revocation
proceeding in any state.
Global Connection has been offering non-Lifeline and Lifeline wireline service
since 1998 and began providing non-Lifeline and Lifeline-supported wireless service in
April, 201l. The Company generates substantial revenues from non-Lifeline services
and has access to capital from its investors. The majority owner of Global Connection is
Milestone Partners, a Pennsylvania private equity firm. Consequently, Global
Connection has not relied, and will not be relying exclusively on Lifeline reimbursement
for the Company's operating revenues. The Company has not been subject to
enforcement sanctions or ETC revocation proceedings in any state.
7t See Compliance Plan Public Notice at 3.
See Lifeline Reform Order, flfl 387-388 (revising Commission rule 5a.202(a)$)).
21
72
Service Requirements Applic pany's Suppo4. The Compliance
Plan Public Notice requires carriers to include "certifications required under newly
amended section 54.202 of the Commission's rules."73 Globul Connection certifies that it
will comply with the service requirements applicable to the support the Company
receives.T4 The Company provides all of the telecommunications service supported by
the Lifeline program and will make the services available to all qualified consumers
throughout the states in which it is designated as an ETC. The Company's services
include voice telephony services that provide voice grade access to the public switched
network or its functional equivalent. Further, the Company's service offerings provide its
customers with a set number of minutes of use for Iocal service at no charge to the
customer. The Company's current Lifeline offerings include packages in Section II
supra that can be used for local and domestic toll service.
The Company also will provide access to emergency services provided by local
government or public safety officials, including 9l 1 and E9l 1 where available and will
comply with any Commission requirements regarding E9l1-compatible handsets. As
discussed above, the Company will comply with the Commission's forbearance grant
conditions relating to the provision of 911 and E91 I services and handsets.
Finally, Global Connection will not provide toll limitation service ("TLS"), which
allows low income consumers to avoid unexpected toll charges. However, since the
Company is a prepaid service provider, customers cannot be disconnected for failure to
pay toll charges, nor are there additional charges for exceeding their minutes. Further,
the Company, like most wireless carriers, does not differentiate domestic long distance
Compliance Plan Public Notice at 3
47 C.F.R. $ sa.202(a)(l).
73
74
22
toll usage from local usage and all usage is paid for in advance. Pursuant to the Lifeline
Reform Order, subscribers to such services are not considered to have voluntarily elected
to receive TLS.75
IV. Conclusion
Global Connection submits that its Compliance Plan fully satisfies the conditions
set forth in the Commission's LiJbline Reform Order, the Compliance Plan Public Notice
and the Lifeline rules. Accordingly, the Company respectfully requests that the
Commission expeditiously approve its Compliance Plan.
Respectful ly subm itted,
.f ohn J. Heitmann
Joshua T. Guyan
Kelley Drye & Warren LLP
3050 K Street, NW
Suite 400
Washington, D.C. 20007
(202) 342-8s44
Coun.sel to Global Connection lnc. o.f
America
April30,20l2
15 See Lifeline Re./brm Order,nn0.
Z)
E,XHIBIT A
Global Connection lnc. of America D/B/A StandUP Wireless
State Wireless Lifeline Service Application and Certification
WIRELESSH"Mail or fax form completed and signed form to:
Fax [phone] I Customer Service: 7.800.544.4447Global Connection lnc. of America
A complete and signed Lifeline Service Application and Certification ("Certification") is required to enroll you in Global
Connection lnc. of America D/B/A StandUP Wireless ("the Company's") Lifeline service program in your state. This
Certification is only for the purpose of verifying your eligibility for Lifeline service and will not be used for any other
purpose. Service requests will not be processed until this Form has been received and verified by Company.
One Lifeline service per household disclosures: Lifeline is a government assistance program and willfully making false
statements to obtain a Lifeline benefit can result in fines, imprisonment, de-enrollment or being barred from the program.
Lifeline benefits are limited to a single line of service 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 may not receive multiple Lifeline discounts. You may apply your Lifeline discount to either one landline or
one wireless number, but you cannot have the discount on both and you cannot receive Lifeline benefits from multiple
providers. Note that not all Lifeline services are currently marketed under the name Lifeline. Lifeline is a non-
transferable benefit and you may not transfer your benefit to any other person, including another eligible low-income
consumer. 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 potentially prosecution by the United States Government.
u I hereby certify that I have read and understood the disclosures listed above and that, to the best of my
knowledge, my household is not already receiving a Lifeline service benefit.
Customer eligibility certification: lhereby certify that I participate in at least one of the following programs
(check one):
O Supplemental Nutrition Assistance Program (SNAP) O TemporaryAssistance for Needy Families (TANF)
tr Section 8 Federal Public Housing Assistance (FPHA) o Low lncome Home EnergyAssistance Program (LIHEAP)
o Medicaid (not Medicare) tr National School Lunch Program's free lunch program
o Supplemental Security lncome (SSl) o lncome at or below 135% of Federal Poverty Guidelines
Customer Application lnformation:
First Middle Name:Last Name
Date of Birth: Month: _ Day: _ Year: Last Four Digits of Social Security Number:
lf Qualifying for Lifeline by lncome, number of lndividuals in Household:
Home Telephone Number (if available)
Residential Address (P.O. Box NOT sufficient)
Number:Apt: _ Street_ City
State: _ Zip Code:
Address is (choose one): n Permanent o Temporary
Billing Address (if different from Residential Address) (P.O. Box lS sufficient)
Number:
Fi
StandUP I
Apt: _ Street_ City
State: _ Zip Code:
Multiple households sharing and address:
o lhereby certify that lreside at an address occupied by multiple households, including adults who do not
contribute income to my household andfor share in my household's expenses, and lwill complete a separate
additional form.
Activation and usage requirement disclosures: This service is a prepaid service and you must personally activate it by
calling 1.877.283.3890. To keep your account active, you must use your Lifeline service at least once during any 6O day period by
completing an outbound call, purchasing additional minutes from Company, answering an in-bound call from someone other
than Company, or by responding to a direct contact from Company confirming that you want to continue receiving Lifeline
service from Company. lf your service goes unused for 50 days, you will no longer be eligible for Lifeline benefits and your
service will be suspended (allowing only 911 calls and calls to the Company's customer care center) subject to a 30 day cure
period during which you may use the service (as described above) or contact the Company to confirm that you want to continue
receiving Lifeline service from Company.
o I hereby certify that I have read and understood the disclosures listed above regarding activation and usage
requirements.
Authorizations:
o I hereby authorize the Company to access any records required to verify my statements on this form and to confirm my
eligibility for the Lifeline program. I also authorize the Company to release any records required for the administration of the
Lifeline program (e.9., name, telephone number and address), including to the Universal Service Administrative Company, to
be used in a Lifeline database and to ensure the proper administration of the Lifeline Program. Failure to consent will result in
denial of service.
Additional certifications: I hereby certify, under penalty of perjury, that (Check the box next to each line):
o I meet the income-based or program-based eligibility criteria for receiving Lifeline service and have provided documentation
of eligibility if required
o I will notify the Company within 30 days if for any reason I no longer satisfy the criteria for receiving Lifeline including, as
relevant, if I no longer meet the income-based or program-based eligibility criteria, I begin receiving more than one Lifeline
benefit, or another member of my household is receiving a Lifeline benefit. I understand that I may be subject to penalties if I
fail to follow this requirement
o I am not listed as a dependent on another person's tax return (unless over the age of 60)
o The address listed below is my primary residence, not a second home or business
o lf I move to a new address, I will provide that new address to the Company within 30 days
o lf I provided a temporary residential address to the Company, I will verify my temporary residential address every 90 days
o I acknowledge that providing false or fraudulent information to receive Lifeline benefits is punishable by law
o I acknowledge that I may be required to re-certify my continued eligibility for Lifeline at any time, and my failure to re-certify
as to my continued eligibility within 30 days will result in de-enrollment and the termination of my Lifeline benefits
n The information contained in this certification form is true and correct to the best of my knowledge
Applicant's Signature:Date
For Agent Use Only (check the appropriate boxes for the proof of eligibility viewed; do not copy or retain documentation):
Documents Acceptable Proof for lncome-Eligibility (check 1):
E The prlor year's state, federal, or Tribal tax return,
Section 8 Federal Public Housing Assistance (FPHA)
Supplemental Security lncome (SSl)
Temporary Assistance for Needy Families (TANF)
Low lncome Home Energy Assistance Program (LIHEAP)
National School Lunch Program's free lunch program
Food Distribution Program on lndian Reservations (FDPIR)
Bureau of lndian Affairs General Assistance (BlA)
Tribally Administered TANF (TATNF)
Head Start (meeting income qualifying standards)
State Program 1
State Program 2
ListB-Choose1:
I Program participation card/document
I Prioryear's statement of benefits
I Notice letter of participation
! Other official document evidencing participation
!tr
Dtrtr!!
I Supplemental Nutrition Assista
! vedicaid
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,
I An Unemployment/Workmen's Compensation statement of benefits,
I Federal orTribal notice letter of participation in General Assistance, or
I A divorce decree, child support award, or other official document
containing income information for at least three months time.
Documents Acceptable Proof for Program-Eligibility (choose 1 from
each list A and B below):
ListA-ChooseL
nce Program (SNAP)
Applicant Account Number Agent/Dealer Number
E,XHIBIT B
StandUP Wireless - Current Zip Code Coverage in ldaho
83201
83202
83204
83209
83210
83211
83211
83220
83221
83226
83228
83232
83236
83237
83241
8324s
83246
83250
83251
83254
83255
83262
83263
8321r
83272
83274
83216
83271
83283
83286
83287
83301
83313
83314
83316
83318
83320
83323
83324
83325
83330
83333
83334
8333s
83338
83340
83341
83342
83346
83348
83349
833s0
833s2
83355
83401
83402
83404
83406
83420
83423
83427
83428
83429
83440
83442
83443
83445
83448
83449
83450
83452
83455
83464
83461
83s01
8360s
83607
83610
83612
83677
83619
83622
83627
83628
83629
83633
83534
83638
83639
83642
83643
83546
83641
83648
83651
83660
83561
83672
83676
83686
83687
83702
83703
83704
83705
83706
83709
83712
83713
837t4
83716
83725
8380s
83814
83815
83835
83843
838s2
838s4
83858
83860
83864
.i t2 P€
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1OO o/o
95.9 %
67%6.44 yo
14 06 0k 12.35 %
1OO Yo
1 Percentages shown above the level of Global Connection Holdings Corporation reflect actual interests (not adjusted for
application of attribution rule) in immediate subsidiary and not indirect ownership interest in GCIOA.
2 Milestone Partners holds a total indirect interest in GCIOA of 70 .64% by direct catculation and 100% applying the
attribution rule. These interests are held through several funds. Direct inlerests in MP Global Holdings, LLC are held by
Milestone Partners lll,L.P. (72.5o/o) and Milestone Partners lll, L.P 2 (27.sok). The general partner of both funds is
Milestone Partners lll G.P., L.P. The general partner of Milestone Partners lll G.P., L.P is Milestone Partners lll, LLC.
Voting or investment control over securities that the Milestone Partners Funds own are acted upon by vole of Mileslone
Partners lll, LLC whose current members (all U.S. citizens) are W. Scott Warren, John P, Shoemaker, Brooke B. Hayes,
and Robert G. Levine.
Global Connection tnc. of America
Pre-Close Corporate Structu re
(lnterests > 10%)1
Milestone Partners2
(Delaware limited liability company)
MP GlobalHoldings, LLC
L6-GlobalLLC
Global Connection Holdings Corporation
Global Connection lnc. of America
Banyan lnvestments
99 Yo
Odin Mobile, LLC
Pre-Close Corporate Structure
(lnterests 210%)1
Paul Greene
Odin Mobile, LLC
6.441o
100 %
95.9%
67 Yo 99%
25%750h
1 Percentages shown above the level of GCIOA reflect actual interests (not adjusted for application
of attribution rule) in immediate subsidiary and not indirect ownership interest in GCIOA.
Globa! Connection lnc. of America
Post-Close Corporate Structure
(lnterests >-1|o/ol1
Milestone Partners
(Delaware limited liability company)
MP Global Holdings, LLC
L6-Global LLC Paul Greene
Global Connection Holdings Corporation Odin Mobile, LLC
Global Connection lnc. of America