20130506Application.pdf

RE CE I ‘F
Also Admitted in New York
Email:[e-mail]
Lance J.M.Steinhart,P.C.
Attorneys At Law
1725 Windward Concourse
Suite 150
Alpharetta,Georgia 30005
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Telephone:[phone]
Facsimile:[phone]
May3,2013
VIA OVERNIGHT DELIVERY
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise,Idaho 83702
NEW CASE
L-T l3-
Re:Q LINK WIRELESS LLC
Application for Limited Designation as an Eligible Telecommunications Carrier
Dear Ms.Jewell:
Enclosed please find for filing an original and seven (7)copies of Q LINK WIRELESS
LLCs Application for Limited 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 returned 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.Thank you.
Enclosures
cc:Issa Asad
KaseyC.
Associate at J.M.Steinhart,P.C.
Attorneys for Q LINK WIRELESS LLC
Respectfully submitted,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
V3 1M
In the Matter of the Application of )
)
CASENO.
__________
QLINKWIRELESSLLCFOR LIMITED L\kJ —-
3-O)
DESIGNATION AS AN ELIGIBLE )
TELECOMMUNICATIONS CARRIER )
NEW CASE
APPLICATION OF Q LINK WERELESS LLC FOR LIMITED DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS CARRIER
Lance J.M.Steinhart
Lance J.M.Steinhart,P.C.
Attorneys at Law
1725 Windward Concourse,Suite 150
Aipharetta,Georgia 30005
[phone] (Phone)
[phone] (fax)
E-Mail:[e-mail]
Attorneysfor Q LINK WIRELES$LLC
May 3,2013
TABLE OF CONTENTS
INTRODUCTION I
II.BACKGROUND 2
A.Company Overview 2
B.Proposed Lifeline Offering 4
C.Plan Enrollment 6
D.Prevention of Waste,Fraud and Abuse 7
III.THE COMMISSION HAS JURISDICTION TO DESIGNATE WIRELESS
ETCS $
A.The ETC Designation Request Is Consistent with Recent Commission
Precedent 9
IV.Q LINK SATISFIES THE REQUIREMENTS FOR DESIGNATION AS
ANETC 10
A.Q LINK Will Provide Service Consistent With the FCC’s Grant of
Forbearance from Section 2 14’s Facilities Requirements 10
B.Q LINK Is a Common Carrier 11
C.Q LINK Will Provide All Required Supported Services 11
1.Voice Grade Access to the Public Switched Telephone
Network 12
2.Local Usage 12
3.Access to Emergency Services 12
4.Toll Limitation for Qualified Low-Income Customers 12
5.Other Services 13
D.Q LINK Will Advertise the Availability of Supported Services 13
E.Q LINK Requests Designation Throughout its Service Area in Idaho 14
F.Service Commitment Throughout the Proposed Designated Service
Area 15
G.Five-Year Network Improvement Plan 15
H.Ability to Remain Functional in Emergency Situations 15
I.Commitment to Consumer Protection and Service Quality 16
I.Local Usage Requirement 16
K.Equal Access Requirement 17
L.Financial and Technical Capability 17
M.Q LINK Will Comply with Certification and Verification
Requirements 17
N.Q Lll’JK Will Comply With All Regulations Imposed By The
Commission 18
V.DESIGNATION OF Q liNK AS AN ETC WOULD PROMOTE THE
PUBLIC INTEREST 18
A.Advantages of Q LINK’s Service Offering 19
B.The Benefits of Competitive Choice 21
C.Impact on the Universal Service Fund 21
VI.ANTI-DRUG ABUSE CERTIFICATION 22
VII.CONCLUSION 23
TABLE OF EXHIBITS
Exhibit
Certification of Issa Asad,CEO of Q LINK WIRELESS LLC 1
Proposed Lifeline Offering 2
Lifeline Certification Form 3
Q LiNK’s FCC Compliance Plan 4
2010 Lifeline Participation Rates by State 5
Wire Centers and Coverage Maps 6
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter ofthe Application of )
)CASE NO.
_________
Q LTNK WIRELESS LLC FOR LIMITED
DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER )
____________________________________________________________________________________________
)
)
APPLICATION OF Q LINK WIRELESS LLC FOR LIMITED DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS CARRIER
I.INTRODUCTION
Q LINK WIRELESS LLC (“Q LINK”or the “Company”),by its undersigned counsel,
and pursuant to Section 21 4(e)(2)of the Communications Act of 1934,as amended (the “Act”)1,
Sections 54.101 through 54.207 of the Rules of the Federal Communications Commission
(“FCC”),2 and the Idaho Public Utilities Commission’s (“Commission”)rules and regulations3,
hereby submits this Application for Designation as an Eligible Telecommunications Carrier
(“ETC”)in the State of Idaho.Q LINK seeks ETC designation solely to provide Lifeline service
to qualifying Idaho consumers;it will not seek access to funds from the federal Universal
Service Fund (“USF”)for the purpose of participating in the Link-Up program or providing
service to high cost areas.4 As demonstrated herein,and as certified in Exhibit 1 to this
Application,Q LINK meets all the statutory and regulatory requirements for designation as an
47 U.S.C.§214(e)(2)
2 C.f.R.§54.10 1-54.207.
See In the Matter of the Application of WWC Holding Co.,Inc.d/b/a Cellular-one Seeking Designation as an
Eligible Telecommunications Carrier that may Receive Federal Universal Service Support,Order No.29841
(August 4,2005)(“Commission Order No.29841”).
Given that Q LINK only seeks 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.
1
ETC in the State of Idaho,including the new requirements outlined in the FCC’s U$f/ICC
Transformation Order5 and Lfeline and Link Up Reform Order.6 Rapid grant of Q LINK’s
request,moreover,would advance the public interest because it would enable the Company to
commence much needed Lifeline service 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 I.M.Steinhart
Lance J.M.Steinhart,P.C.
Attorney for Q LINK WIRELESS LLC
1725 Windward Concourse,Suite 150
Aipharetta,Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail:[e-mail]
II.BACKGROUND
A.Company Overview
Q LINK is a Delaware Limited Liability Company.7 Its principal office is located at 499
East Sheridan Street,Suite 300.Dania,Florida 33004.Q LINK is a provider of commercial
mobile radio service (“CMRS”)throughout the United States,and provides prepaid wireless
telecommunications services to consumers by using the Sprint Spectrum,L.P.(“Sprint”)network
In the Matter of Connect America Fund,A National Broadband Plan for Our future,Establishing Just and
Reasonable Rates for Local Exchange Carriers,High-Cost Universal Service Support,Developing a Un!fled
Intercarrier Compensation Regime,Federal-State Joint Board on Universal Service,Lifeline and Link-Up,
Universal Service Reform —Mobility Fund,WC Docket No.10-90,GN Docket No.09-5 1,WC Docket No.07-135,
WC Docket No.05-337,CC Docket No.96-45,WC Docket No.03-109,WT Docket No.10-208,Report and Order
and Further Notice of Proposed Rulemakhig,FCC 11-161 (rel.Nov.18,2011)(“USF/ICC Transformation Order”).
6 In the Matter ofLifeline and Link Up Reform and Modernization,Lifeline and Link Up,federal-State Joint Board
on Universal Service,Advancing Broadband Availability Through Digital Literacy Training,WC Docket No.11-42,
WC Docket No.03-109,CC Docket No.96-45,WC Docket No.12-23,Report and Order and Further Notice of
Proposed Rulemaking,FCC 12-11 (rel.Feb.6,2012)(“Lifeline andLink Up Reform Order”).
Q LiNK was organized in the State ofDelaware on August 25,2011.
2
on a wholesale basis to offer nationwide service.Q LiNK obtains from Sprint Nextel (“Sprint”)
the network infrastructure and wireless transmission facilities to allow the Company to operate as a
Mobile Virtual Network Operator (“MVNO”),similar to Tracfone Wireless,Inc.(“Tracfone”)
and Virgin Mobile USA,L.P.(“Virgin Mobile”),who have been granted ETC status by the
Commission.As of the date of filing,Q fiNK has been designated as an ETC in Arizona,
Colorado,Kansas,Kentucky,Maine,Maryland,Michigan,Minnesota,Missouri,Nevada,Ohio,
Oklahoma,Pennsylvania,Texas,Utah,West Virginia,and Wisconsin.As of the date of filing.Q
LiNK currently has applications for ETC designation pending with Arkansas,California,
Georgia,Illinois,Indiana,Iowa,Louisiana,Massachusetts,Mississippi,New Jersey,New
Mexico,South Carolina,and Vermont;no such petitions have been denied.
Q LINK’s prepaid wireless services are affordable,easy to use,and attractive to low-
income 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,as well as for contacting prospective employers.Q LINK offers consumers a variety of
simple and affordable prepaid calling plans,easy-to-use handsets,and high-quality customer
service.Given its pricing and marketing strategy and the demographics of other,similar MYNOs’
customers,Q LINK 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.Q LINK 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 were previously ignored by traditional carriers,Q LINK will
3
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
Q LINK has the ability to provide all services and functionalities 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.Q LINK intends to be a leader in the prepaid marketplace by
offering consumers exceptional value and competitive amounts of voice usage at all price points.
The Company’s Lifeline service offering will provide customers with the same features and
flinctionalities enjoyed by all other Q LINK prepaid customers,with one notable exception:
prepaid Lifeline services will not require payment of an out-of-pocket fee by subscribers,but
instead,Q LINK will receive support from the Lifeline program as compensation for providing
those services.Q LINK’s Lifeline service offering proposes to give eligible tribal and non-tribal
customers the following Lifeline Plan choices:
1.Plan 1:6$Monthly Minutes (Non-Tribal).Under Plan 1,non-tribal eligible Lifeline
customers enjoy 6$anytime minutes that rollover and free international long
distance.8 Text messaging is at the rate of one-third of one minute (3 incoming or
outgoing texts =1 minute of voice).
2.Plan 2:125 Monthly Minutes (Non-Tribal).Under Plan 2,non-tribal eligible Lifeline
customers enjoy 125 anytime minutes that rollover.Text messaging is at the rate of
one minute (1 incoming or outgoing text =1 minute of voice).
$If you are on Plan I,there is no additional charge for international long distance to counfries designated at
www.glinkwireless.com.
4
3.Plan 3:250 Monthly Minutes (Non-Tribal).Under Plan 3,non-tribal eligible Lifeline
customers enjoy 250 anytime minutes.Minutes do not rollover.Text messaging is at
the rate of one minute (1 incoming or outgoing text =1 minute of voice).
4.Tribal Plan:1 000 Monthly Minutes.Under the Tribal Plan,Tribal eligible Lifeline
customers enjoy 1,000 anytime minutes.Minutes do not rollover.Text messaging is
at the rate of one minute (1 incoming or outgoing text =1 minute of voice).
Customers can purchase additional bundles of minutes in denominations as low as $10,
$20,$30,$35,$50,and $60.Airtime replenishment cards will be made available at retail
outlets frequented by low-income customers throughout the Company’s Service Area.
Customers can also add minutes by calling Customer Service or online via the Company’s
website.In addition to wholly supported voice services,all of Q Link’s Lifeline plans will
include a free handset and the following Custom Calling features:Caller ID,Call Waiting,and
Voicemail.Q LINK does not impose burdensome credit checks or long-term service contracts
on its Lifeline customers.Customers are not bound by a local calling area requirement;all Q
LINK plans come with domestic long distance at no extra per minute charge and exceptional
nationwide digital coverage on the Nationwide Sprint Network.Given this nationwide coverage,
there is minimal need for roaming.So that customers will not incur unexpected roaming
charges,Q LINK blocks roaming ability on its Lifeline handsets.Calls to 911 emergency
services are always free,regardless of service activation or availability of minutes.Calls to Q
Link customer service are also free with no deduction of minutes for services related issues.
$10 =50 minutes for 30 service days;$20 =100 minutes for 30 service days;$30 =150 minutes for 30 service
days;$35 =200 minutes for 60 service days;$50 =500 minutes for 60 service days;and $60 =unlimited minutes
for 30 service days.
Attached hereto as Exhibit 2 is a summary table of the Company’s proposed Lifeline
service offering10.As Exhibit 2 demonstrates,the Company’s Lifeline offering will not only
allow feature-rich mobile connectivity for qualifying subscribers at no cost to the subscriber,but
also will bring a variety of rate plans into the reach of eligible customers that are comparable in
minutes and features to those available to post-paid wireless subscribers —but at low rates and
without a the burden of credit checks or service contracts.Q IJNK’s prepaid offering will be an
attractive alternative for consumers who need the mobility,security,and convenience of a
wireless phone,but who are concerned about usage charges or long-term contracts.
C.Plan 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 detailed description of the program
and state-specific eligibility criteria.Customers may then request that an enrollment form be
mailed to them,or they can download a form from the internet or retrieve a form in person at Q
LINK kiosks.The certification forms,a sample of which is attached as Exhibit 3,will explain in
clear,easily understandable language that:
(i)Lifeline is a federal benefit;
(ii)Lifeline service is available for only one line per household;
(iii)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;
(iv)households are not permitted to receive benefits from multiple providers;
(v)that violation of the one-per-household requirement would constitute a violation of
the FCC’s rules and would result in the consumer’s de-enroilment from the program.and
potentially,prosecution by the United States government;and
(vi)a Lifeline subscriber may not transfer his or her service to any other individual,
including another eligible low-income consumer.
The Company’s Lifeline terms and conditions can be found at www.qlinkwfreless.com.
6
Q LINK’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
revised CfR §54.4 10(d).’1 See Exhibit 4 for more detailed enrollment information.Q LINK
will annually re-certify the continued eligibility of all of its subscribers.
U.Prevention of Waste,Fraud and Abuse
Q LINK recognizes the importance of safeguarding the USF.Therefore,the Company
has implemented the following 60-day non-usage policy in an effort to avoid waste,fraud,and
abuse of the program.Q LINK will not seek reimbursement from the U$f for inactive
subscribers who have not used the service for a consecutive 60-day period.12 Q LINK will notify
its subscribers at service initiation about the non-transferability of the phone service,its usage
requirements,and the de-enrollment and deactivation that will result following non-usage in any
60-day period of time.’3 An account will be considered active if during any 60-day period the
authorized subscriber does at least one of the following:makes a monthly payment;purchases
minutes from the Company to add to an existing pre-paid Lifeline account;completes an
outbound call;answers an incoming call from anyone other than the Company,its representative,
or agent:or affirmatively responds to a direct contact from the Company confirming that he or
she wants to continue.14 Q LINK will provide the subscriber 30 days’notice,using clear,easily
understood language,that the subscriber’s failure to use the Lifeline service within the 30-day
notice period will result in service termination for non-usage;such notice may be given after 30
“See Lfe1ine andLink Up Reform Order page 227-29.
12 See Lfetine and Link Up Reform Order at ¶257.
13 See Id.
14 See Lfeline andLink Up Reform Order at ¶261.
7
days of non-usage.Customers that have been deactivated may participate in the Company’s
Lifeline service in the future by reapplying and re-establishing eligibility.
To further protect the integrity of the USf,Q LINK 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:(1)Duplicate Same-Month Lifeline
Subsidies (Double Dip):any name/address that is already receiving a lifeline subsidy from the
Company will be automatically prevented from receiving a second lifeline subsidy in that same
month;and (2)Inactive lines receiving subsidy:CGM’s systems compare all subsidy requests to
underlying network status to ensure that subsidies are requested only for active lines.Through
the processes described above,Q LINK ensures that it does not over-request from support funds.
III.THE COMMISSION HAS JURISDICTION TO DESIGNATE WIRELESS ETCS
Section 214(e)(2)of the Act (47 U.S.C.§214(e)(2))provides state public utility
commissions with the “primary responsibility”for the designation of ETCs.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)’Therefore,the Commission has the authority
to designate Q LINK as an ETC.Pursuant to this authority,the Commission has designated
numerous carriers as ETCs in the State of Idaho,including many wireless carriers.16
Under the Act,a state public utility commission with jurisdictional authority over ETC
designations must designate a common carrier as an ETC if the carrier satisfies the requirements
of Section 214(e)(l).Q LINK recognizes that Section 214(e)(l)(A)of the Act states that ETCs
15 See federal-State Joint Board on Universal Service,first Report and Order,12 FCC Rcd 8776,8858-59,¶145
(1997)(“USf Order”).
16 See e.g.,Tracfone ETC Order and Virgin Mobile ETC Order.
8
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 recently granted forbearance from enforcement of this facilities
requirement to carriers seeking Lifeline-only ETC designation.17 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 10(e)to act in accordance with the FCC’s grant of forbearance,and therefore,may
not apply the facilities-based requirement to Q LINK.Therefore,the Commission has the
authority to act under Section 214(e)(2)of the Act and to grant Q LINK’s request for designation
as an ETC throughout the State of Idaho.
A.The ETC Designation Request Is Consistent with Recent Commission
Precedent
Q LINK’s request for ETC designation to participate in the Lifeline program is consistent
with the Commission’s recent decision designating TracFone and Virgin Mobile as ETCs.’8 In
its decisions,the Commission determined that designation of a prepaid wireless provider as an
ETC would serve the public interest.Q LINK requests that the Commission expeditiously
process its ETC Application so that it can quickly commence providing qualifying low-income
Idaho customers with affordable USF-supported wireless services during these challenging
economic times for all state residents.Designation of Q LINK as an ETC would further
competition for wireless Lifeline services and would offer eligible consumers an additional
17 See Lfe1ine and Link Up Reform Order at ¶36$.
See Tracfone ETC Order,see also Virgin Mobile ETC Order
9
choice of providers for accessing telecommunications services,representing a significant step
towards ensuring that all low-income consumers share in the many benefits associated with
access to wireless services.
IV.Q LINK SATISFIES THE 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 214(e)(2)of the Act authorizes state commissions,such as the Commission,to
designate ETC status for federal universal service purposes and authorizes the Commission to
designate wireless ETCs.’9 Section 214(e)(1)of the Act and Section 54.201(d)of the FCC’s
rules provide that applicants for ETC designation must be common carriers that 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.20 As detailed below,Q LINK satisfies each of the above-
listed requirements.
A.Q LINK 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 Q LINK.lii the
Lifeline and Link Up Reform Order,the FCC granted forbearance from the “own-facilities”
19 See USf Order at 8858-59,¶145.
20 See 47 U.S.C.§214(e)(1)and 47 C.F.R.§54.201(d)(2).
10
requirement contained in Section 214(e)(1)(A)for carriers that are,or seek to become,Lifeline-only
ETCs,subject to the following conditions:2’
(1)the carrier must comply with certain 911 requirements [(a)providing its Lifeline
subscribers with 911 and E911 access,regardless of activation status and availability of
minutes;(b)providing its Lifeline subscribers with E9 11-compliant handsets and replacing,
at no additional charge to the subscriber,noncompliant handsets of Lifeline-eligible
subscribers who obtain Lifeline-supported services;and (c)complying with conditions (a)
and (b)starting on the effective date ofthis 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.”
Q LTNK has availed itself of the FCC’s grant of blanket forbearance.In accordance with the
Lifeline and Link Liv Reform Order,Q LINK filed its Compliance Plan with the FCC.which the
FCC approved on August 8,2012.A copy of the FCC’s Public Notice of Approval and a copy
of the Company’s FCC-Approved Compliance Plan are attached hereto as Exhibit 4.Q LINK
commits to providing Lifeline service in Idaho in accordance with the Compliance Plan and
requests expeditious ETC designation in Idaho.
B.Q LINK Is a Common Carrier
CMRS providers like Q LINK are treated as common carriers.22
C.Q LINK Will Provide All Required Supported Services
Through its wholesale arrangements with Sprint,Q LINK is able to provide all of the
services and functionalities required by Section 54.10 1(a)and Section 54.202(a)of the FCC’s
21 See Lifeline and Link Up Reform Order at ¶J 368,373 and 379.
22 Implementation ofSections 3(n)and 332 of the Communications Act,Regulatoiy Treatment ofMobile Services,
GN Docket No.93-252,Second Report and Order,9 fCC Rcd 1411,1425 37,1454-55 ¶102 (1994)(wireless
resellers are included in the statutory “mobile services”category,and providers of cellular service are common
carriers and CMRS providers);47 U.S.C.§332(c)(1)(A)(“mobile services”providers are common carriers);see
also PCIA Petitionfor forbearancefor Broadband PC’S,WT Docket No.98-100,Memorandum Opinion and Order
and Notice of Proposed Rulemaking,13 FCC Rcd 16857,16911 ¶111 (1998)(“We concluded [in the Second
Report and Order]that CMRS also includes the following common carrier services:cellular service,...all mobile
telephone services and resellers of such services.”)
11
Rules (47 C.f.R.§54.101(a)and 47 C.f.R.§54.202(a)),including the following:
1.Voice Grade Access to the Public Switched Telephone Network
Q LiNK provides voice grade access to the public switched telephone network (“PSTN”)
through the purchase of wholesale CMRS services from Sprint.
2.Local Usage
As part of the voice grade access to the PSIN,an ETC must provide minutes of use for
local service at no additional charge to end-users.The FCC has not specified a minimum
amount of local usage that an ETC must offer.23 Q LINK offers a variety of rate plans that
provide its customers with minutes of use for local service at no additional charge.
3.Access to Emergency Services
Q LINK provides 911 and E9 11 access for all of its customers to the extent the local
government in its service area has implemented 911 or E91 1 systems.Q LINK also complies
with the FCC’s regulations governing the deployment and availability of E91 1 compatible
handsets.
4.ToIl Limitation for Qualified Low-Income Customers
In its Lfeline and Link Up Reform Order,the FCC stated that toll limitation would no
longer be deemed a supported service.24 “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.2D Nonetheless,Q LINK’s offerings inherently allow
Lifeline subscribers to control their usage,as its wireless service is offered on a prepaid,or pay
23 See e.g.,In the Matter of Federal-State Joint Board on Universal Service,Recommended Decision 15 fCC Rcd
7331 (2002).
24 See Lifeline and Link Up Reform Order at ¶367.
25 See Lifeline and Link Up Reform Order at ¶49.
12
as-you-go,basis.Q LINK’s service,moreover,is not offered on a distance-sensitive basis and
local and domestic long distance minutes are treated the same.Q LINK will not seek
reimbursement for toll lhriitation service.
5.Other Services
While no longer required by 47 C.f.R.§54.101(a),Q LINK provides dual tone multi-
frequency (“DTMf”)signaling to expedite the transmission of call set up and call detail
information throughout the network,single party service for the duration of each telephone call
and not multi-party (or “party-line”)services,access to operator services,the ability to make
interexchange,or long distance,telephone calls,and access to directory assistance services by
dialing “411”from the provided wireless handsets.
D.Q LINK Will Advertise the Availability of Supported Services
Q LINK will broadly advertise the availability and rates for the services described above
using media of general distribution as required by 47 C.F.R.§54.201(d)(2)of the FCC’s
regulations.Q LiNK’s advertising will comply with the requirements set forth in the Lifeline and
Link Up Reform Order,as outlined in the Company’s Compliance Plan26 The Company will
advertise its services in a manner reasonably designed to reach those likely to qualify for Lifeline
service,using many mediums for outreach internet marketing,television and radio spots,print
advertising,direct mailing,and local kiosks in retail outlets.The Company will engage in
advertising campaigns specifically targeted to reach those likely to qualify for Lifeline service,
promoting the availability of cost-effective wireless services to this neglected consumer segment.
Q LINK may also promote the availability of its Lifeline offering by distributing brochures at
26 See Exhibit 4,section I1I.D.3.See also Lifeline and Link Up Reform Order at Section Vll.f.
13
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,Q LINK intends to utilize its network of retail partners to help promote the
availability of its Lifeline plans,especially those retail outlets that are frequented by low income
consumers.Q LiNK will provide retail vendors with signage to be displayed where Company
products are sold,and with printed materials describing the Company’s Lifeline program.27
Statistics suggest there are many eligible customers who are not yet aware of the
programs.According to the best data available to the Company,as of December 31,2010,only
between 10-20%of consumers eligible for Lifeline Services in the State of Idaho were being
provided such services.26 Q LINK believes that its advertising and outreach efforts detailed
above will inform consumers of the availability of Lifeline service in a manner that will result in
significantly higher participation by qualified consumers than has been the case in the past.
E.Q LINK Requests Designation Throughout Its Service Area in Idaho
Q LINK is not a rural telephone company as defined in Section 153(37)of the Act (47
U.S.C.§153(37)).Accordingly,the Company is required to describe the geographic area(s)
within which it requests designation as an ETC.Q LINK requests designation as an ETC that is
statewide in scope,subject to the existence of its underlying carrier’s facilities and corresponding
coverage.29 Q LINK understands that its service area may overlap with rural carriers in Idaho,
but maintains that the public interest factors described below justify its designation in these
27 See attached Exhibit B of Exhibit 4,the Company’s Compliance Plan,for a sample advertisement.
29 See attached Exhibit 5,2010 Lifeline Participation Rates by State,which was obtained from the Universal Service
Administrative Company (“USAC”),an independent not-for-profit corporation designated as the administrator of
the federal Universal Service fund by the FCC.USAC administers Universal Service fund (USF)programs for
high cost companies serving rural areas,low-income consumers,rural health care providers,and schools and
libraries.
29 A list of wire centers and coverage maps in which the Company requests ETC designation are attached hereto as
Exhibit 6.
14
carriers’service areas,especially because it seeks ETC designation solely to utilize USF funding
to provide Lifeline service to qualified low-income consumers.It does not seek and will not
accept Link-Up or high cost support.
F.Service Commitment Throughout the Proposed Designated Service Area
Q LiNK provides service in Idaho by reselling service which it obtains from its
underlying facilities-based provider.The provider’s network is operational and largely built out.
Thus,Q LINK will be able to commence offering its Lifeline service to all locations served by its
underlying carrier very soon after receiving approval from the Commission.Q LINK commits to
comply with the service requirements applicable to the support that it receives.30
G.Five-Year Network Improvement Plan
As set forth in the Lifeline and Link Up Reform Order,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.3’
H.Ability to Remain Functional in Emergency Situations
In accordance with 47 CfR §54.202(a)(2),Q LINK has the ability to remain functional in
emergency situations.Through its agreement with its underlying carrier,Q LINK provides to its
customers the same ability to remain functional in emergency situations as currently provided by
the ILECs to their own customers,including access to a reasonable amount of back-up power to
ensure functionality without an external power source,the ability to reroute traffic around
damaged facilities,and the capability of managing traffic spikes resulting from emergency
situations.
°See Lifeline and Link Up Reform Order at page 208,revised §54.202(a)(1)(i).
31 See Lifeline and Link Up Reform Order at ¶386.
15
I.Commitment to Consumer Protection and Service Quality
Under FCC guidelines,an ETC applicant must demonstrate that it will satisfy applicable
3)consumer protection and service quality standards.The Company commits to satisfying all
such applicable state and federal requirements related to consumer protection and service quality
standards.Specifically,Q LiNK commits to comply with the Cellular Telecommunications and
Internet Association’s (CTIA)Consumer Code for Wireless Service.
J.Local Usage Requirement
An applicant for ETC designation is no longer required to demonstrate that it offers a
local usage plan that is “comparable”to the plan offered by the ILEC in the relevant service
territory.33 Nevertheless,not only will the Company’s offering be comparable to the underlying
ILEC plans,but it also will exceed them in several respects.Q LINK will offer customers a
certain amount of service free of charge.In contrast to the ILEC plans,which contain relatively
small local calling areas,Q LINK customers can use these free minutes to place calls statewide
(and even nationwide)because Q LINK does not constrict customers’use by imposing a local
calling area requirement.Q LINK will also provide Lifeline customers with E91 1 capabilities
and access to voice mail,caller I.D.,and call waiting services at no cost.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.
32 See 47 C.F.R.§54.202(a)(3).
See Lfellne and Link Up Reform Order at page 208,revised §54.202(a).
16
K.Equal Access Requirement
FCC Rules no longer require an applicant for ETC status to provide a certification that it
acknowledges that the FCC may require it to provide equal access to long distance carriers in the
event that no other ETC is providing equal access within the service area.34
L.Q LINK is financially and Technically Capable
Q LINK is financially and technically capable of providing Lifeline-supported services.35
Q LINK will provide service to both Lifeline and non-Lifeline customers.Q LINK intends to
launch its retail and Lifeline wireless service simultaneously.Q LINK is already designated as
an ETC in 17 states and provides retail and Lifeline wireless services in these states.Q LINK
has not been subject to enforcement action or ETC revocation proceedings in any state.Q LINK
is financially able to provide Lifeline-supported services;the Company does not,and does not
intend to,offer exclusively Lifeline-supported services—and is therefore not exclusively
dependent on USAC for its revenue.Q LINK is fully capable of honoring all its service
obligations to customers and regulatory obligations to state and federal regulators.Furthermore,
the senior management of Q LINK has great depth in the telecommunications industry with over
80 years of combined experience and offers extensive telecommunications business technical
and managerial expertise to the Company.36 Q LINK will be providing resold wireless service,
and therefore will also rely upon the managerial and technical expertise of its underlying carrier.
M.Q LINK Will Comply with Certification and Verification Requirements
Section 54.4 10 of the FCC’s Rules requires ETCs to certify and verify a Lifeline
customer’s initial and continued eligibility.Q LINK will certify and verify consumer eligibility
See Id.
See Lfe1ine and Link Lip Reform Order at ¶387.
See Exhibit D of Exhibit 3,the Company’s FCC-Approved Compliance Plan,for key management resumes.
17
in accordance with the FCC’s requirements and in accordance with its Compliance Plan,which
outlines how the Company will comply with the requirements set forth in the Lfetine and Link
Up Reform Order,and with Commission Order No.2984].
N.Q LINK Will Comply With All Regu]ations Imposed By The Commission
By this Application,Q LiNK 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,to the extent such provisions apply to a
prepaid wireless provider.Upon Commission request,the Company is prepared to answer
questions or present additional testimony or other evidence about its services within the state.Q
LINK commits that 100%of federal universal service funds will flow through directly to Lifeline
customers.The Company commits to comply with the reporting requirements adopted by the
Commission.’8
As the Company is not seeking high-cost support for its wireless service,it hereby
requests a waiver of the following Commission Rules:Commission Order No.2984]Section B.1
(two-year network improvement and maintenance plan based on high-cost support)and
Commission Order No.2984]Section C.1 (annual report of certain information based on high-
cost support).Because the Company is not seeking high-cost support,these rules are not
applicable and,therefore,should be waived.
V.DESIGNATION OF Q LINK 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
See Commission Order No.29841 at Appendix,Section D.
38 See Commission Order No.29841 at Appendix,Section C.
1$
consumers and encourage the rapid deployment of new telecommunications technologies”to all
citizens,regardless of geographic location or income.39 There is no question that designation of
Q LINK as an ETC in Idaho will further the public interest by providing Idaho consumers,
especially low-income consumers,with lower prices and higher quality services.Many low
income customers in Idaho have yet to reap the full benefits of the intensely competitive wireless
market.Whether because of financial constraints,poor credit history or intermittent
employment,these consumers often lack the countless choices available to most consumers.
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
Q LINK as an ETC would significantly benefit low-income consumers eligible for Lifeline
service in the State of Idaho —the intended beneficiaries of universal service.
A.Advantages of Q LINK’s Service Offering
The public interest benefits of the Company’s wireless service include larger local calling
areas (as compared to traditional wireline carriers),the convenience and security afforded by
mobile telephone service,the opportunity for customers to control cost by receiving a preset
amount of monthly airtime at no charge,the ability to purchase additional usage at flexible and
affordable amounts in the event that included usage has been exhausted,911 service and,where
available,E91 1 service in accordance with current FCC requirements.The Company’s Lifeline
customers will receive the same high-quality wireless services and exceptional customer service
provided to all Company customers.Q LiNK’s Lifeline rate plans will not only allow feature-
Telecommunications Act of1996,Pub.L.No.104-1 04,110 Stat.56.
19
rich mobile connectivity for qualifying subscribers at no cost to the subscriber,but also will
bring a variety of rate plans into the reach of Lifeline customers that are comparable in minutes
and features to those available to post-paid wireless subscribers —but at low Lifeline rates and
without the burden of credit checks or contracts.
Q LiNK’s Lifeline program will provide low-income Idaho residents with the convenience
and security offered by wireless services—even if their financial position deteriorates.The
economic circumstances indicate that low-income individuals,now more than ever,can greatly
benefit from the advantages offered by the Company’s Lifeline service,thus allowing those
adversely impacted by the failing economy or job loss to have access to a free wireless service to
assist in emergency situations,facilitate job search efforts,and to maintain contact with family
members.
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.Providing Q LiNK with the authority necessary to offer discounted Lifeline service to
those most in danger of losing wireless service altogether undoubtedly promotes the public
interest.
Moreover,grant of Q LiNK’s Application will serve the public interest in increasing the
number of ETCs in Idaho.By granting ETC status to Q LINK,the Commission will enable Q
LINK to increase the number of Idaho residents receiving Lifeline support,thereby increasing the
amount of USf money flowing into Idaho.In sum,ETC designation in the State of Idaho would
20
enable Q LINK to provide all of the public benefits cited by the FCC in its analysis in the Virgin
Mobile Order.Namely,Q LINK would provide “increased consumer choice,high-quality service
offerings,and mobility,”40 as well as the safety and security of effective 911 and E9l 1 services.41
B.The Benefits of Competitive Choice
The benefits to consumers of being able to choose from among a variety of
telecommunications service providers have been acknowledged by the FCC for more than three
decades.42 Designation of Q LINK as an ETC will promote competition and innovation,and spur
other carriers to target low-income consumers with service offerings tailored to their needs and
to improve their existing networks to remain competitive,resulting in improved services to
consumers.Designation of Q LINK as an ETC will help assure that quality services are available
at ‘just,reasonable,and affordable rates”as envisioned in the Act.43 Introducing Q LINK into
the market as an additional wireless ETC provider will afford low-income Idaho residents a
wider choice of providers and available services while enhancing 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 P SIN.
C.Impact on the Universal Service Fund
Q LINK’s request for designation as an ETC solely for Lifeline purposes 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
40 See Virgin Mobile Order,24 FCC Rcd at 3395 ¶3$.
41 See Ii at 3391 ¶23.
42 See,e.g.,Specialized Common Carrier Services,29 FCC Rcd $70 (1971).
See 47 U.S.C.§254(b)(1).
21
company such as Q LINK or the Incumbent LEC operating in the same service area.Q LINK
will oniy increase the amount of USF Lifeline funding in situations where it obtains Lifeline
customers not enrolled in another ETC’s Lifeline program.By implementing the safeguards set
forth in the Lifeline and Link-up Reform Order,Q LINK will minimize the likelihood that its
customers are not eligible or are receiving duplicative support either individually or within their
household.Significantly,the Company’s designation as an ETC will not increase the number of
persons eligible for Lifeline support.Q LINK’s ability to increase the Lifeline participation rate
of qualified low-income individuals will further the goal of Congress to provide all individuals
with affordable access to telecommunications service,and thus any incremental increases in
Lifeline expenditures are far outweighed by the significant public interest benefits of expanding
the availability of affordable wireless services to low-income consumers.According to the FCC,
“the additional choice and service options of another wireless reseller offering 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.”44
VI.ANTI-DRUG ABUSE CERTIFICATION
Q LINK certifies that no party to this Application is subject to denial of federal benefits,
including FCC benefits,pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988.
See Petition ofi-wireless,LLC for forbearance from 47 U.s.c §214(e,)(1)(A,),Order,FCC 10-117 (rel.June 25,
2010)atf 19.
22
VII.CONCLUSION
Based on the foregoing,designation of Q LiNK as an ETC in the State of Idaho accords
with the requirements of Section 214(e)(2)of the Act and is in the public interest.
WHEREFORE,Q LINK respectfully requests that the Commission promptly designate Q
LINK as an ETC in the State of Idaho.
Respectfully su ifted,
Lance I..teinhart
Lance J.M.Steinhart,P.C.
Attorneys at Law
1725 Windward Concourse,Suite 150
Alpharetta,Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail:[e-mail]
Attorneys for Q LINK WIRELESS LLC
May 3,2013
23
EXHIBIT 1
Certification of Issa Asad,CEO of Q LINK WIRELESS EEC
)State of Florida
)County of Broward
Certification
Personally appeared before the undersigned,an officer duly authorized to administer oaths.I,tssa Asad,tIrst being duly sworn,depose and state that I am the CEO of Q LINK WIRELESSLLC,Petitioner in this Petition,and have read the same and knows the contents thereof,andconfirmthatthestatementsmadehereinaretrueandcorrecttothebestofandwithinmypersonalknowledge.
Dated:1
--—-
Issa Asad
CEO
Q LINK WIRELESS LLC
Subscribed and sworn to before me this 5day of )ri /2013.
_______
/(Signu of pecan au orized to administer oath)
—SOPHtAEN
MYCOMMSSIONEE 14436
YXPIiRES:Novembef7215
(rnPub Unj
My Commission Expires:(t 7 Z
EXHIBIT 2
Proposed Lifeline Offering
Plan 1:68 Monthly Minutes Plan (NonTribal)*
6$anytime minutes per month
(texts are one-third of one minute,i.e.3 texts =1 minute)
Net cost to non-Tribal Lifeline customer:SO (free)
*Tls package includes:
•free handset
•Free calls to Customer Service
•free calls to 911 emergency services
•free Voicemail,Caller-ID,and Call Waiting
•6$anytime minutes (unused minutes rollover)
•free Domestic Long Distance
•Free International Long Distance to countries designated at www.glinkwireless.com
Plan 2:125 Monthly Minutes Plan (NonTribafl*
125 anytime minutes per month
(texts are one minute,i.e.1 text 1 minute)
Net cost to non-Tribal Lifeline customer:SO (free)
*This package includes:
•Free handset
•free calls to Customer Service
•Free calls to 911 emergency services
•Free Voicemail,Caller-ID,and Call Waiting
•125 anytime minutes (unused minutes rollover)
•free Domestic Long Distance
Plan 3:250 Monthly Minutes Plan (NonTribaI)*
250 anytime minutes per month
(texts are one minute,i.e.1 text =1 minute)
Net cost to non-Tribal Lifeline customer:SO (free)
*This package includes:
•free handset
•free calls to Customer Service
•free calls to 911 emergency services
•Free Voicemail,Caller-ID,and Call Waiting
•250 anytime minutes (unused minutes do not rollover)
•Free Domestic Long Distance
Tribal Plan:1,000 Monthly Minutes PJan*
1.000 anytime minutes per month
(texts are one minute,i.e.1 text 1 minute)
Net cost to Tribal Lifeline customer:SO (free)
*This package includes:
•Free handset
•Free calls to Customer Service
•Free calls to 911 emergency services
•Free Voicemail,Caller-ID,and Call Waiting
•1,000 anytime minutes (unused minutes do not rollover)
•Free Domestic Long Distance
Additional Minutes*
50 minutes =$10 150 minutes =$30 500 minutes $50
100 minutes =$20 200 minutes =$35 unlimited minutes =$60
*terms and conditions of additional minutes available at www.glinkwireless.com/add-rninutes.aspx
International Long Distance
Free International Calling Destinations on the 68 Monthly Minutes Plan
(Certain special or off-network locations may be excluded from the free international Long
Distance.Calls to cellular phones are not included unless the word ‘Cellular is specifically
listed next to the country name.Numbers in parentheses Q indicate the Country Code.)
Albania-Tirana (355)France (33)Mexico (52)
Andorra (376)french Antilles (594)Monaco (377)
Argentina (54)french Guiana-Cellular Netherlands (31)
Australia (61)(594)New Zealand (64)
Austria (43)french Guiana (594)Norway (47)
Bahamas-Cellular (1)Georgia (995)Panama (507)
Bahamas (1)Germany (49)Paraguay (595)
Bangladesh-Cellular (880)Gibraltar (350)Peru (51)
Bangladesh-Chittagong Greece (30)Poland (48)
($80)Guadeloupe (590)Portugal (351)
Bangladesh-Dhaka ($80)Guatemala-Telgua (502)Romania (40)
Bangladesh-Sylhet ($80)Hong Kong-Cellular (852)Russia-Cellular (7)
Belgium (32)Hong Kong ($52)Russia (7)
Bermuda-Cellular (1)Hungary (36)San Marino-Cellular (378)
Bermuda (1)Iceland (354)San Marino (37$)
Bolivia-La Paz (591)India-Cellular (91)Saudi Arabia-Riyadh (966)
Bolivia-Santa Cruz (591)India (91)Singapore-Cellular (65)
Brazil (55)Indonesia-Cellular (62)Singapore (65)
Brunei-Cellular (673)Indonesia-Jakarta (62)Slovakia (421)
Brnnei (673)Indonesia-Surabaya (62)Slovenia (386)
Bulgaria (359)Iraq-Baghdad (964)South Korea-Cellular ($2)
Canada-Cellular (1)Ireland (353)South Korea (82)
Canada (1)Israel (972)Spain (34)
Chile (56)Italy (39)Sweden (46)
China-Cellular (86)Japan ($1)Switzerland (41)
China ($6)Jordan (962)Taiwan-Cellular ($86)
Columbia-Cellular (57)Kazakhstan (7)Taiwan ($66)
Columbia (57)Kenya-Nairobi (254)Thailand (66)
Costa Rica (506)Lithuania (370)Turkey (90)
Croatia (585)Luxembourg-Cellular United Kingdom (44)
Cyprus-Cellular (357)(352)Uzbekistan (7)
Cyprus (357)Luxembourg (352)Venezuela (5$)
Czech Republic (420)Macao-Cellular (853)Vietnam-Ho Chi Minh
Denmark (45)Macao (853)City (84)
Dominican Republic (1)Malaysia-Cellular (60)Zambia (260)
Estonia (372)Malaysia (60)
Finland (358)Malta (356)
EXHIBIT 3
Lifeline Certification Form
(i 1k1LfJLIINi’e
I S t I F S S
CONNECTING AMERICA
Enrollment ID:
Must be Eligible to Enroll
IDAHO LIFELINE ASSISTANCE PROGRAM
Things to know about the Lifeline Assistance Program:(1)Lifeline is a federal non-transferable benefit.(2)Lifeline Assistance is available for only one line per household.A household cannot receive benefits from multiple providers;and(3)A household is defined,for purposes of the Lifeline Program,as any individual or individuals who live together at the same address and share income and expenses.
0 Personal Information
Please read all instructions before completing.Information will be validated.Discrepancies could result in delays.PLEASE PRINT.
-Last Name:
___________
Address:
City:
(No RO.Buses,Must be your prrrctpai address)
State:
_________
Zip Code:
Apt:
This address is 121 Permanent El Temporary U Multi-Household
Home Number:(-Cell Number:Other Number:f_
E-mail Address:
o Supplemental Security Income (551)
o Low-Income Energy Assistance Program (LIHEAP)
o Tribal Administration )TANF)
o Head Start (Income Qualifying /Residents of Tribal Lands Only)
First Name:
MI:
Birth Date (Month/Day/Year):_/,_J,_.Last 4 Digits of Social Security Number:EJE EJECompletethispartONLYifyourchildordependentisthebeneficiaryofthequalifyingprogram.
First Name:
__________________________
Last Name:
__________________________
./_._J________
Birth Date (r1M/DD/YYYY)Last 4 Digits of Social Security NumberQSelectYourFreePlanBelowMostPopularPlan!
Li 250 FREE MJNUTE$-I EE I’.i’Ui’E 68 FREt MINUTESLocalCallsLocalCallsLocalCallsNationalLongDistancetNationalLongDistanceNationalLongDistanceVoicemailVoiCemailVoiCemailNationvideText1Iminutepertext)Nationwide Text i minute per texl Nationwide Text (0.3 m nutes per text)Roaming ‘/Roaming RoamingFren911Free911‘Free911‘iu Carry Over Minutes el CarrYOver Minutes Carry-Over Minutes
0 Enclose Accepted Proof of Identity such as:
Driver’s License,State ID,Passport,Voter’s Registration Card,Birth Certificate,Marriage License,Military ID,or Other Government Issued ID.
0 To Apply For Service Choose One of the Qualification Options Below:The program is limited to one benefit per household and only eligible consumers may enroll.Consumers who willfully make falsestatementsinordertoobtainthebenefitcanbepunishedbyfineorimprisonmentorcanbebarredfromtheprogram.
Option 1 QUALIFY BASED ON PARTICIPATION IN A GOVERNMENT PROGRAM (Mostly Popular Option)To qualify you must attach proof of participation in one of the programs listed below.I hereby certify that I participate in ONE or more of the public assistance programs listed below (Check all that apply):O Food Stamps I SNAP (Supplemental Nutrition Assistance Program)Q National School Lunch Program (Free Program Only)O Medicaid (Not the same as Medicare)
O Federal Public Housing Assistance!Section 8
O Temporary Assistance for Needy Families (TAME)
O Bureau of Indian Affairs General Assistance
Food Distribution Program on Indian Reservation (FDPIR)
--YOU MUST PROVIDE PROOF OF PARTICIPATION IN A GOVERNMENT PROGRAM.This could be a copy of your benefits card,a copy of an eligibility letter from an authorized agency,or statement of benefits.THE MOST COMMON TYPES OF GOVERNMENT PROGRAM PROOF YOU CAN SUBMIT:•Food Stamps/EBT Card or Award Letter •National School Lunch Program•Medicaid Card •Low Income Energy Assistance Program•Supplemental Security Income (SSI)Award Letter •Section 8 or Federal Public Housing Assistance -
SECUOII rPleaseseeothersidefor
Option 2 INCOME-BASED ELIGIBILITY
Qualify by certifying your income is at or below 135%of the Federal Poverty Guidelines.(If you selected OPTION I skip this section and continue to SECTION C)Calculate TOTAL household income by reporting the income of all adult persons residing in your home in the appropriate category.REMINDER:YOU MUST PROVIDE PROOF OF INCOME (DO NOT SEND ORIGINAL DOCUMENTS).
How many people live in your household?Number of children under the age of 18:Number of people receiving income:
What is your total monthly/yearly household income?/monthly yearly
Income Guidelines Proof of income reported:Choose an item from the list below and include it with your application.Household Maximum Three consecutive months of one of these OR One of these documentsSizeYearlyIncomestatements(from the previous 12 months):
Prior year’s State or Federal income tax returno1$15,512 •Your Pay Stubs
•Income statement from employerO2$20,939 •Social Security benefits statement •Federal letter of participation in General AssistanceC)3 $26,366 .Veterans Administration benefits statement •Divorce decree or child support documento4$31,793 .Retirement/Pension benefits statement •Workers’Compensation benefits statement()$•Unemployment benefits statement
9f you have more than 4 people In your household,write thenumberandadd$5,427 (Oreachadditional person on top of the $31,793,
0 Penalty of Perjury:
Under title 18 U.S.C.§1621,whoever Willfully states as true any material matter which he does not believe to be true in a statementunderpenaltyofperjury,is guilty of perjury and shall,except as otherwise expressly provided by law,be fined or imprisoned notmorethanfiveyears,or both.I certify,under penalty of perjury:(Intial by Each Certification)
--I understand that Lifeline Is a federal benefit program and that willfully making a false statement or providing fraudulent documentation In order to obtainthisgovernmentbenefitmayresultinfines,Imprisonment,tie-enrollment or permanent removal from the program.
-——I understand that only one Lifeline discounted service flandline or wireless)is available per household.A household is defined,for purposes of the Lifelineprogram,as any individual or group of individuals who live together at the same address and share income and expenses.A household is not permitted toreceiveLifelinebenefitsfrommultipleproviders.I understand that violation of the one-per-household rule constitutes a violation of federal rules and willresuitinde-enroliment from the Lifeline program and potential prosecution by the United States Government.
I understand Lifeline is a non-transferable benefit.I will not transfer to any third party,including another eligible Individual,any of the rights or benefitsreceivedundertheservice.
--I understand I may be required to recertify my continued eligibility for Lifeline benefit at any time,and failure to do so may result in termination of Lifelinebenefits.t understand that If my service goes unused for sIxty (60)days,my service will be suspended,subject to a thIrty (30)day period which I mayusetheserviceorcontactQLinkWirelesstoconfirmthatIwanttocontinuereceivingtheirservice.
I certify that I participate in a qualIfying federai program or meet the Income qualifications to establish eligibility for Lifeline and I will providedocumentationofeiigibiiityifrequiredtodoso.
—I certify that my household will receive only one Lifeline benefit.To the best of my knowledge,fi)my household is not already receiving a Lifeline benefit,or (ii)If I currently have Lifeline service with a different service provider,and I am approved for Q Link Wireless service,I will notify my current providerthatIamreceivingafederalLifelineAssistancebenefitfromQLinkWirelessandherebycancelmyservicewithotherproviderinfavorofQLinkWireless.I certify that if I have provided a temporary address:Q Link Wireless will attempt to verify every 90 days that I continue to reside at that address,and ImustnotifyQLInkWirelesswithin30daysofanychangeofaddress.It I do not respond to Q Link Wireless’address verification attempts within 30 days,I may be tie-enrolled.
I certify that I will inform Q Link Wireless within 30 days of any of the following,and may be sub)ect to penalties if I fail to do so:-I move to a new address.
-I no longer participate in a Lifeline qualifying program or my annual household Income exceeds l3S/n of the Federal Poverty Guidelines.-I become aware that my household is receiving more than one Lifeline benefit,-For any other reason,I no longer meet the criteria for federal Lifeiine support.
I authorize Q Link Wireless or its agent to access and release any records (Including financial records)required to verify my statements herein and toconfirmeligibilityforQLinkWireless’service.I authorize state or federal agency representatives to discuss with,and/or provide Information to,Q LinkWirelessverifyingmypartIcipationinpublicassistanceprogramsthatqualifymeforQLinkWireless’service.
I understand that my name,telephone number,date of birth,last four digits of my social security number,and address will be divulged to the UniversalServiceAdministrativeCompany(USAC)and/or its agents for the purpose of verifying that I do not receive more than one Lifeline subsidy.I understandthatifuSACidentflesIamreceivingmorethatoneLifelinesubsidy,all carriers involved may be notified so that I may select one service provider and bede-enrolled from the other(s).
—-I authorize Q Link Wireless to provide access to or release any records required for the administration of Q Link Wireless’service.
—--I understand that the completion of this application does not constitute Immediate approval for Q Link Wireless’service.
APPLICANT’S SIGNATURE______________________________DATE_______________
Submit your completed application using any of the methods below:
Mail application:Q Link Wireless,LLC Fax application Toll-Free to:1-855-837-5465499ESheridanSt.Suite 300 ORDania,FL 33004 Email application to:documents©qlinkwireless.com
For questions,please call Q Link Wireless Toll-Free at 1-855-754-6543.
uiqjaOufl!IdWOJJJJSjflJflO
t’iiarnx
PUBLIC NOTICE
Federal Communications Commission News Media Information 2021 418-0500
12 St.,S.w.Internet:http:Ilwww.fcc.gov
TrY:1-888-835-5322Washington,D.C.20554
BA 12-1286
Release Date:August 8,2012
WIRELINE COMPETITION BUREAU APPROVES THE COMPLIANCE PLANS OF BIRCH
COMMUNICATIONS,BOOMERANG WIRELESS,IM TELECOM,Q LINK WIRELESS AND
TAG MOBILE
WC Docket Nos.09-197 and 11-42
The Wireline Competition Bureau (Bureau)approves the compliance plans of five carriers:Birch
Communications,Inc.(Birch);Boomerang Wireless,LLC (Boomerang);TM Telecom,LLC (TM);Q Link
Wireless,LLC (Q Link);and TAG Mobile,LLC (TAG).The compliance plans were filed pursuant to the
Lifeline Reform Order as a condition of obtaining forbearance from the facilities requirement of the
Communications Act of 1934,as amended (the Act),for the provision of Lifeline service.’
The Act provides that in order to be designated as an eligible telecommunications carrier for the
purpose of universal service support,a carrier must “offer the services that are supported by Federal
universal service support mechanisms...either using its own facilities or a combination of its own
facilities and resale of another carrier’s services .“The Commission recently amended its rules to
define voice telephony as the supported service and removed directory assistance and operator services,
among other things,from the list of supported services.3 As a result of these amendments,many Lifeline-
only ETCs that previously met the facilities requirement by providing operator services,directory
assistance or other previously supported services no longer meet the facilities requirement of the Act.4 Tn
the Lifeline Reform Order,the Commission found that a grant of blanket forbearance of the facilities
requirement,subject to certain public safety and compliance obligations,is appropriate for carriers
‘See Lifeline andLink Up Reform and Modernization eta?,WC Docket No.11-42 et aL,Report and Order and
Further Notice ofProposed Rulemaking,27 FCC Rcd 6656,6816-17 at paras.379-380 (2012)(Lifeline Reform
Order).A list of the compliance plans approved through this Public Notice can be found in the Appendix to this
Public Notice.
247 U.S.C.§2l4(e)(l)(A).
See Connect America Fund,WC Docket No.10-90 eta?.,Report and Order and Further Notice of Proposed
Rulemaking,26 FCC Rcd 17663,17692-93,paras.77-78,80 (2011);pets.for reviewpending sub nom.In re:FCC
11-161,No.11-9900 (10th Cir.filed Dec.8,2011);Connect America Fund,WC Docket No.10-90 et a?.,Order on
Reconsideration,26 FCC Rcd 17633,17634-35,para.4 (2011)(USF/ICC Transformation Order on
Reconsideration).
See Lifeline Reform Order,27 FCC Rcd 6812,at para.366,App.A;USF/ICC Transformation Order on
Reconsideration at para.4.Some ETCs have included language in their compliance plans indicating that they have
facilities or plan to acquire facilities in the future.See,e.g.,Blanket Forbearance Compliance Plan,WC Docket
Nos.09-197 and 11-42,Q Link Wireless,LLC’s Third Amended Compliance Plan at 4 n.2 (filed July 30,2012).
To the extent ETCs seek to avail themselves of the conditional forbearance relief established in the Lifeline Refol7n
Order,we presume they lack facilities to provide the supported service under section 54.101 and 54.401 of the
Commission’s rules.See 47 C.F.R.§54.101 and 54.401.Such ETCs must comply with the compliance plan
approved herein in each state or territory where they are designated as an ETC,regardless of their claim of facilities
for other purposes,such as eligibility for state universal service funding.
seeking to provide Lifeline-only service.3 Therefore,in the Lfeline Reform Order,the Commission
conditionally granted forbearance from the Act’s facilities requirement to all telecommunications carriers
seeking Lifeline-only ETC designation,subject to the following conditions:(1)compliance with certain
911 and enhanced 911 (E911)public safety requirements;and (2)Bureau approval of a compliance plan
providing specific information regarding the carrier and its service offerings and outlining the measures
the carrier will take to implement the obligations contained in the Order.6
The Bureau has reviewed the five plans listed in the Appendix for compliance with the conditions
of the Lifeline Reform Order,and now approves those five compliance plans.7
Filings,including the Compliance Plans identified in the Appendix,and comments are available
for public inspection and copying during regular business hours at the FCC Reference Information
Center,Portals II 445 12th Street,S.W.,Room CY-A257,Washington,D.C.20554.They may also be
purchased from the Commission’s duplicating contractor,Best Copy and Printing,Inc.,Portals II,445
12th Street,S.W.,Room CY-B402,Washington,D.C.20554,telephone:[phone],fax:(202)448-
5563,or via email www.bcpiweb.com.
People with Disabilities:To request materials in accessible formats for people with disabilities
(Braille,large print,electronic files,audio format),send an email to [e-mail] or call the
Consumer &Governmental Affairs Bureau at [phone] or TTY [phone].
For further information,please contact Divya Shenoy,Telecommunications Access Policy
Division,Wireline Competition Bureau at [phone] or TTY [phone].
-FCC-
SeeLifelineReforin Order,27 FCC Rcd 6813-6817 atparas.368-381.
6 See id.at paras.373 and 389.Subsequently,the Bureau provided guidance for carriers submitting compliance
plans pursuant to the Lifeline Reform Order.Wire/me Competition Bureau Provides Guidancefor the Submission of
‘ompliance Plans Pursuant to the Lfeline Reform Order,WC Docket Nos.09-197 and 11-42,Public Notice,27
FCC Rcd 2186 (Wireline Comp.Bur.2012).
The Commission has not acted on any pending ETC petitions filed by these carriers,and this Public Notice only
approves the compliance plans of the carriers listed above.While these compliance plans contain information on
each carrier’s Lifeline offering,we leave it to the designating authority to determine whether or not the carrier’s
Lifeline offerings are sufficient to serve consumers.See Lfelmne Reform Order,27 fCC Rcd 6679-80,68 18-19 at
paras.50 and 387.
2
APPENDIX
Petitioner Compliance Plans Date of filing Docket
As Captioned by Petitioner Numbers
Birch Communications,Further Amended Compliance Plan of July 2,2012 09-197;11-42
Inc.Birch Communications,Inc.
Boomerang Wireless,Boomerang Wireless,LLC Revised July 26,2012 09-197;11-42
LLC Compliance Plan
IM Telecom,LLC TM Telecom,LLC d/b/a Infiniti Mobile July 5,2012 09-197;11-42
Compliance_Plan
Q Link Wireless,LLC Q Link Wireless,LLC’s Third July 30,2012 09-197;1 1-42
Amended_Compliance_Plan
TAG Mobile,LLC TAG Mobile,LLC Compliance Plan July 26,2012 09-197;11-42
3
Before the
Federal Communications Commission
Washington,D.C.20554
In the Mailer ofthe )
)
Telecommunications Carriers Eligible for )WC Docket No.09-197
Universal Service Support )
)WCDocketNo.11-42
Lifeline and Link Up Reform and Modernization )
)
Blanket Forbearance Compliance Plan )
p LINK WIRELESS LLC’S TifiRD AMENDED COMPLIANCE PLAN
Lance J.M.Steinhart
Lance J.M.Steinhart,P.C.
1725 Windward Concourse,Suite 150
Aipharetta,Georgia 30005
[phone] (Phone)
[phone] (Fax)
E-Mail:[e-mail]
Attorneyfor Q LINK WIRELESS LLC
July 30,2012
TABLE OF CONTENTS
INTRODUCTION 4
II.BACKGROU1SD 5
III.Q LINK WILL COMPLY WITH THE REQUIREMENTS SET FORTH IN THE
ORDER 5
A.Accessto9ll andE9ll Services 6
B.E911-Compliant Handsets 6
C.Consumer Eligibility and Enrollment 6
1.One-Per-Household 7
2.Initial and Annual Certification $
3.Annual Re-Certification 11
D.Additional Reforms to Eliminate Waste,Fraud and Abuse 13
1.National Lifeline Accountability Database 15
2.Subscriber Usage 16
3.Marketing &Outreach 17
4.Audits 1$
E.De-Enrollment 18
F.Additional Rule Amendments 20
1.Reporting Requirements 20
2.Reimbursement from USAC 20
3.Section 54.202 Certifications 21
IV.COMPANY INFORMATION 21
A.Names and Identifiers 21
B.Financial and Technical CapabiLity 22
C.Lifeline Offering 22
V.CONCLUSION 24
2
TABLE OF EXHIBITS
Exhibit
Sample Lifeline Certification Form A
Sample Marketing Materials B
Financial Statements C
Key Management Resumes D
Proposed Lifeline Rates E
Terms and Conditions F
3
Before the
Federal Communications Commission
Washington,D.C.20554
In the Matter of the )
)
Telecommunications Carriers Eligible for )WC Docket No.09-197
Universat Service Support )
)WCDocketNo.11-42
Lifeline and Link Up Reform and Modernization )
)
Blanket forbearance Compliance Plan )
p LINK WIRELESS LLC’S TifiRD AMENDED COMPLIANCE PLAN
I.INTRODUCTION
Q LiNK WIRELESS LLC (“Q LINK”or the “Company”)is a prepaid wireless
telecommunications carrier seeking designation as an Eligible Telecommunications Carrier (“ETC”)
solely for the purpose of participating in the Lifeline program.Although Section 214(e)(1)(A)of
the Act requires an ETC to offer USF-supported services to some extent over its own facilities,the
federal Communications Commission (“FCC”or “Commission”)has forborne from that
requirement for carriers that are,or seek to become,Lifeline-only ETCs.’Q LINK will avail itself
of the FCC’s conditional grant of forbearance and,by its attorney,hereby files its Third Amended
Compliance Plan outlining the measures it will take to implement the conditions of forbearance
outlined in the Order.2 This Third Amended Compliance Plan replaces in its entirety Q LINK’s
Second Amended Compliance Plan filed on April 12,2012,and all other Compliance Plans
In the Matter ofLifeline and Link Up Reform and Modernization,Lifeline and Link Up,federal-State Joint Board
on Universal Service,Advancing BroadbandAvailability Through Digital Literacy Training,WC Docket No.11-42,
WC Docket No.03-109,CC Docket No.96-45,WC Docket No.12-23,Report and Order and Further Notice of
Proposed Rulemaking,FCC 12-11 (rel.Feb.6,2012)(Order’).
2 Although the Company qualifies for and seeks to avail itself ofthe Commission’s grant of forbearance from the
facilities requirement of section 214(e)(1)(A)for purposes of the federal Lifeline program,the Company reserves
the right to demonstrate to a state public utilities commission that it provides service using its own facilities in a
state for purposes of state universal service funding under state program rules and requirements.The Company will
follow the requirements ofthe Commission’s Lifeline rules and this Compliance Plan in all states in which it
provides Lifeline service and receives reimbursements from the federal Low-Income fund.
4
previously filed by the Company.Given the severe economic environment that is forcing many
low-income customers to forego wireless service,Q LINK respectfully requests expeditious
approval of this plan so that the Company,upon designation as an FTC,may quickly deploy much-
needed Lifeline services to qualified low-income customers.
II.BACKGROUND
In the Order,the Commission granted forbearance from the “own-facilities”requirement
contained in Section 214(e)(1)(A)for carriers that are,or seek to become,Lifeline-only ETCs,
subject to the following conditions:3
(1)the carrier must comply with certain 911 requirements [(a)providing its Lifeline
subscribers with 911 and E91 1 access.regardless of activation status and availability of
minutes:(b)providing its Lifeline subscribers with E91 1-compliant handsets and replacing,
at no additional charge to the subscriber,noncompliant handsets of Lifeline-eligible
subscribers who obtain Lifeline-supported services;and (c)complying with conditions (a)
and (b)starting on the effective date of this Order];and
(2)the carrier must file,and the Bureau must approve,a compliance plan that:(a)outlines
the measures the carrier will take to implement the obligations contained in this Order,
including but not limited to the procedures the ETC follows in enrolling a subscriber in
Lifeline and submitting for reimbursement for that subscriber from the Fund,materials
related to initial and ongoing certifications and sample marketing materials,as well as
further safeguards against waste,fraud and abuse the Bureau may deem necessary;and (b)
provides a detailed description of how the carrier offers service,the geographic areas in
which it offers service,and a description of the carrier’s various Lifeline service plan
offerings,including subscriber rates,number of minutes included and types of plans
available.
III.Q LINK WILL COMPLY WITH THE REQUIREMENTS SET FORTH IN THE
ORDER
Q LiNK will comply with all conditions set forth in the Order,the provisions of this
Compliance Plan,and all laws and regulations governing its provision of Lifeline-supported prepaid
wireless service to customers throughout the United States.
See Order at ¶T 368,373 and 379.
5
A.Access to 911 and E911 Services
In the Order,the Commission requires Q LINK to provide its Lifeline customers with
access to 911 and E911 services,regardless of activation status and availability of minutes.4 The
Commission and consumers are hereby assured that all Q LINK customers will have available
access to emergency calling services at the time that Lifeline service is initiated,and that such 911
and E91 1 access will be available from Q LINK handsets even if the account associated with the
handset has no minutes remaining.
B.E911-Compliant Handsets
The Commission also conditioned its grant of forbearance detennination on Q LINK
providing only E91 1-compliant handsets to its Lifeline customers.5 Q LINK will ensure that all
handsets used in connection with the Company’s Lifeline service offering are E91 1-compliant.In
the event that an existing Q LINK customer does not have an E91 1-compliant handset,the
Company will replace it with a new 91 1/E91 1-compliant handset at no charge to the customer.Any
new customer that qualifies for and enrolls in the Lifeline program is assured of receiving a
91 1/E9 11-compliant handset as weLl,free of charge.
C.Consumer Eligibility and Enrollment
Q LINK will certify and verify consumer eligibiLity for Lifeline in accordance with the
requirements set forth in the Order.In instances where a state agency or third-party administrator
is responsible for the initial determination and annual recertification of consumer eligibility,Q
LINK will rely on the state identification or database.6 In instances where Q LINK is responsible
for the initial determination and annual recertification of consumer eligibility,the Company will
follow the procedures set forth below.
See Order at ¶373.
See Id.
6 See Order at ¶98.
6
1.One-Per-Household
Q LINK understands that Lifeline is limited to a single subscription per household.and
that the Commission has defined household as “any individual or group of individuals who are
living together at the same address as one economic unit.”7 Upon receiving an application for
Lifeline support,Q LINK will check the duplicates database.once in place,to determine whether
an individual at the applicant’s residential address is currently receiving Lifeline-supported
service.Q LINK will also search its own internal database of active customers,real-time,pre
sale,to ensure that it does not already provide Lifeline-supported service to someone at that
residential address.
If Q LINK determines that an individual at the applicant’s address is currently receiving
Lifeline-supported service,Q LINK will take an additional step to ensure that the applicant and
the current subscriber are part of different households.To enable applicants to make this
demonstration,Q LINK will require applicants to complete and submit to the Company USAC’s
one-per-household template,which will contain the following:(1)an explanation of the
Commission’s one-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 certify 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;and (4)the penalty for a consumer’s failure to make the required one-per-household
certification (i.e.,de-enrollment).8 Q LINK will deny the Lifeline application of any individual
residing at the same address as a current Lifeline subscriber who is part of the same household,and
will advise the applicant of the basis for the denial.
See Order at ¶74.
8 See Order at ¶7$.
7
On its application certification forms,a sample of which is attached as Exhibit A,9 Q
LINK will obtain a consumer’s permanent residential address (which cannot be a P.O.Box or
General Delivery address),unless they only have a temporary address,and,if different.a billing
address for the service (which may include a P.O Box or General Delivery address).’°Q LTNK
will inquire on its certification forms whether or not the address provided is temporary.11 If so,
Q LINK will notify the consumer that the Company will contact the consumer every 90 days,by
phone or text,to verify that he or she continues to rely on that address,and that if the consumer
fails to respond within 30 days of Q LINK’s attempt to verify the temporary address,he or she
will be de-enrolled from the Lifeline program.Also on its certification forms,Q LINK will
explain that if the subscriber moves,they must provide their new address to the Company within
30 days of moving.12 If the subscriber has moved,Q LINK will update the duplicates database,
once in place,with the information within 10 business days of receipt of the information.13
As detailed below,Q LiNK’s certification form will clearly explain the one-per-
household requirement and all consumers must certify that they receive Lifeline support for a
single subscription per household.
2.Initial and Annual Certification
Consumers will be signed up in person or directed,via company literature or advertising,to
a toll-free telephone number and to the Company website,which will provide information regarding
the Company’s Lifeline service plans,including a detailed description of the program and state-
specific eligibility criteria.Q LINK’s application form will identify that it is a “Lifeline”
See Exhibit A.The sample certification form remains subject to change,but substantially reflects the content of
the Company’s application.
10 See Order at ¶85.
See Order at ¶89.
12 See Order at ¶85.
13 See Id.
8
application.Q LFNK will provide Lifeline-specific training to all personnel,whether employees,
agents or representatives,that interacts with actual or prospective customers with respect to
obtaining,changing,or terminating Lifeline services.
Q UNK’s initial and annual certification forms will conform to the list of requirements
provided in the Order,Appendix C and with C.f.R.§54.410(d),as amended.Q LINK’s Lifeline
certification forms will require each prospective subscriber to provide the following information:
(i)The subscriber’s full name;
(ii)The subscriber’s full residential address;
(iii)Whether the subscriber’s residential address is permanent or temporary;
(iv)The subscriber’s billing address,if different from the subscriber’s residential address;
(v)The subscriber’s date of birth;
(vi)The last four digits of the subscriber’s social security number,or the subscriber’s
Tribal identification number,if the subscriber is a member of a Tribal nation and does not
have a social security number;
(vii)If the subscriber is seeking to qualify for Lifeline under the program-based criteria,
as set forth in §54.409,the name of the qualifying assistance program from which the
subscriber,his or her dependents,or his or her household receives benefits;and
(viii)If the subscriber is seeking to qualify for Lifeline under the income-based criterion,
as set forth in §54.409,the number of individuals in his or her household.
The certification forms will also explain in clear,easily understandable language that:
(i)Lifeline is a federal government benefit;
(ii)Lifeline service is available for only one line per household;
(iii)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;
(iv)households are not permitted to receive benefits from multiple providers;
(v)that violation of the one-per-household requirement would constitute a violation of
the Commission’s rules and would result in the consumer’s de-enroliment from the
program,and potentially,prosecution by the United States government;and
(vi)a Lifeline subscriber may not transfer his or her service to any other individual,
including another eligible low-income consumer.
Q LINK will require all consumers,at sign up and annually thereafter,to certify under penalty of
perjury that:
(i)The subscriber meets the income-based or program-based eligibility criteria for
receiving Lifeline,provided in §54.409;
9
(ii)The subscriber will notify the carrier within 30 days if for any reason he or she no
longer satisfies the criteria for receiving Lifeline including,as relevant,if the subscriber
no longer meets the income-based or program-based criteria for receiving Lifeline
support,the subscriber is receiving more than one Lifeline benefit,or another member of
the subscriber’s household is receiving a Lifeline benefit.
(iii)If the subscriber is seeking to qualify for Lifeline as an eligible resident of Tribal
lands,he or she lives on Tribal lands,as defined in 54.400(e);
(iv)If the subscriber moves to a new address,he or she will provide that new address to
the eligible telecommunications carrier within 30 days;
(v)If the subscriber provided a temporary residential address,he or she will be required
to verify his or her temporary residential address every 90 days;
(vi)The subscriber’s household will receive only one Lifeline service and,to the best of
his or her knowledge,the subscriber’s household is not already receiving a Lifeline
service;
(vii)The information contained in the subscriber’s certification form is true and correct to
the best of his or her knowledge,
(viii)The subscriber acknowledges that providing false or fraudulent information to
receive Lifeline benefits is punishable by law;and
(ix)The subscriber acknowledges that the subscriber may be required to re-certify his or
her continued eligibility for Lifeline at any time,and the subscriber’s failure to re-certify
as to his or her continued eligibility will result in de-enrollment and the termination of the
subscriber’s Lifeline benefits pursuant to §54.405(e)(4).
Applicants will also be required to initial a number of disclosure statements intended to
ensure that the applicant understands applicable eligibility requirements.Q LINK will verbally
explain the certifications to consumers.With respect to those enrolling via the Internet,Q LINK
will highlight the certifications that are required,for example,by requiring consumers to
acknowledge each certification before moving on to the next field.14 Consumers must return a
signed application and support documentation to the Company by mail,fax,email,kiosk scan,or
other electronic transmission.The Company will accept electronic signatures,including Interactive
Voice Response (IVR)recordings,which meet the requirements of the Electronic Signatures in
Global and National Commerce Act,15 USC 70017O06.13
Q LINK will determine eligibility,at a minimum,utilizing the income and program
criteria currently utilized by federal default states (47 C.f.R.§54.409(a),(b)),as well as any
‘4See Order at ¶123.
5 See Order at ¶1 168.
10
additional state-specific criteria.Prior to enrolling a new subscriber,Q LINK will check the
eligibility of applicants first by accessing state or federal social services electronic eligibility
databases,where available.’6 If a database is used to establish eligibility,Q LINK will not
require documentation of the applicant’s participation in a qualifying federal program;instead,Q
LINK or its representative will note in its records what specific data was relied upon to confirm
the applicant’s initial eligibility for Lifeline.’7 However,in states where there is no state
administrator,the state commission or other state agency is not making eligibility
determinations,and there is no automated means for Q LINK to check electronic databases for
eligibility,Q LINK will review documentation to determine eligibility for new subscribers until
such time as a qualifying eligibility database is available.’8 Q LINK will require acceptable
documentation both for income eligibility and program eligibility.The Company will not retain
copies of the documentation but rather will establish policies and procedures to review such
documentation and keep accurate records detailing how the applicant demonstrated his or her
eligibility.’9 Q LINK understands that it may permit agents or representatives to review
documentation of consumer program eligibility for Lifeline,and in such cases Q LINK remains
liable for ensuring the agent or representative’s compliance with the Lifeline program rules.2°
3.Annual Re-Certification
Q LINK understands that it must re-certify the eligibility of its entire Lifeline subscriber
base as of June 1,2012 by the end of 2012 and report the results to USAC by January 31,2013,
and the Company may elect to perform this re-certification on a rolling basis throughout the
16 See Order at ¶97.
17 See Order at ¶9$.
185ee Order at ¶99.
I9 See Order atajj 101.
20See Order at ¶110.
11
year.2’By December 31,2012,Q LINK will re-certify the continued eligibility of all of its
subscribers by contacting them —either in person,in writing,by phone,by text message,by
email,or otherwise through the Internet —to confirm their continued eligibility.22 The re
certification notice witt exptain the actions the customer must take to retain Lifeline benefits.
when Lifeline benefits may be terminated,and how to contact Q LiNK.Q LINK will obtain a
signed certification from the subscriber that meets the certification requirements of 47 C.F.R.§
54.410(d),as amended,as detailed in section C.2 above.The Company will provide written
notice of impending service termination to subscribers who do not respond to the annual re
certification within 30 days.Q LINK understands that such certifications may be obtained
through a written format,an WR system,or a text message,and will use one or more of such
options for its certifications.23
Alternatively,where a database containing consumer eligibility data is available,Q LINK
(or state agency or third-party,where applicable)will instead query the database by the end of
2012 and maintain a record of what specific data was used to re-certify eligibility and the date of
re-certification.If a subscriber’s address cannot be verified through the state data,Q LiNK will
contact the subscriber during the annual certification process to obtain a valid address.24 After
2012.Q LINK will continue to annually certify the continued eLigibility of its entire subscriber
base,either by accessing a qualifying database,or by electing to have USAC administer the self-
certification process on the Company’s beha1f.2
Q LINK will certify its compliance with Commission ruLes on an annual Lifeline eligible
telecommunications carrier certification form and when submitting FCC Forms 497 to USAC for
21 See Order at ¶130.
22See Id
See Order at ¶132.
24 See Order at 131.
25 See Order at ¶133.
12
reimbursement.As part of Q LINK’s submission of re-certification data pursuant to 47 C.f.R.§
54.4 16,an officer of the Company will certify annually to USAC:
(1)that the Company has procedures in place to review consumers’documentation of
income-and program-based eligibility.In instances where the Company confirms
consumer eligibility by relying on official program eligibility data,such as a state or
federal database,an officer of the Company will attest to what data the Company uses to
confirm consumer eligibility in each state;and
(2)that the Company is in compliance with all federal Lifeline certification procedures.26
In addition,Q LINK will certify when seeking reimbursement that the Company has obtained a
valid certification form for each customer for whom the Company seeks Lifeline
reimbursement.27
D.Additional Reforms to Eliminate Waste,Fraud and Abuse
Q LINK shares the Commission’s concern about abuse of the Lifeline program and is thus
committed to the safeguards stated herein,with the belief that the procedures it will implement will
prevent Company customers from engaging in such abuse of the program,inadvertently or
intentionally.In an effort to prevent waste,fraud,and abuse,Q LINK has implemented procedures
to identifSj and prevent fraud.The goals are to ensure integrity both in Q LINK,but also in the
Lifeline program as a whole.
Q LINK 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:(1)Duplicate Same-Month Lifeline Subsidies (Double Dip):any name/address that is
already receiving a lifeline subsidy from the Company will be automatically prevented from
26 See Order at ¶I 26-27.
27 See Order at ¶12$.
13
receiving a second lifeline subsidy in that same month;and (2)Inactive lines receiving subsidy:
CGMs systems compare all subsidy requests to underlying network status to ensure that
subsidies are requested only for active lines.Through the processes described herein,Q LINK
ensures that it does not over-request from support funds.
For each applicant,Q LINK first validates the applicant’s identity via a government issued
ID card,passport,etc.Additionally,as mentioned above,Q LiNK requires the applicant provide
their date of birth (DOB)and last four digits of their social security number (SSN).Requiring DOB
and SSN ensures that neither the applicant nor the Company representative can forge certification
forms based on false names and addresses.Once the applicant’s identity is confirmed,Q LINK
verifies that the applicant is eligible to receive the Lifeline subsidy.To do this,Q LINK checks any
available eligibility database.If one is not available,the applicant is required to provide proof of
participation in one of the Lifeline eligible programs or proof that their annual household income is
at or below 135%of the federal poverty guidelines.This prevents ineligible applicants from
receiving the Lifeline subsidy.
The address of the applicant is then verified via a USPS/Melissa Database to ensure the
address is correct.Simultaneously,the name/address combination is dipped into CGM’s aggregate
duplicate database to confirm that the applicant is not already receiving a Lifeline subsidy from Q
LINK or any other CGM client.This is done through an API connection between Q LINK’s
provisioning platform and GCM.This allows the Company to ensure the applicant is not receiving
a duplicate subsidy,as well as identify those who share an address with current Q LiNK customers.
This then prompts the representative to detail the one-per-household rule with the applicant,
allowing the applicant to then certify they are head of household.Should Q LINK confirm that a
household is receiving more than one subsidy,whether by information obtained from an applicant,
14
USAC’s IDRP process,or a national database.the customer will be immediately de-etwolled from
the Lifeline program.
If and when Q LINK determines that an applicant is indeed eligible for the Lifeline
program,the Company will ship a new or refurbished handset,dependent only upon availability,to
the qualifying Lifeline customer along with materials explaining the use of the handset,Q LiNK’s
terms and conditions.and disclosures regarding the Lifeline program.Handsets will not be shipped
pre-activated.Qualifying Lifeline customers,upon receipt of the handset,must personally activate
the handset by contacting Q LINK Customer Service either over the phone or via Internet.
1.National Lifeline Accountability Database
Q LINK will participate in the National Lifeline Accountability Database,once it is
established.As required by the Order,Q LINK will provide to the database subscriber name,
address,phone number,the last four digits of Social Security number,date of birth,Lifeline service
initiation and de-enrollment date (when applicable),and amount of federal Lifeline support being
sought for that subscriber.28 Q LINK will provide the information listed above for existing
subscribers within 60 days of Commission notice that the database is capable of accepting
subscriber information.29
Furthermore,Q LINK will obtain acknowledgement and consent from each of its
subscribers that is written in clear,easily understandable language that the subscriber’s name,
telephone number,and address will be disclosed to USAC and/or its agents for the purpose of
verifying that the subscriber does not receive more than one Lifeline benefit.3°
Within 30 days following Commission notice that the database is capable of accepting
queries,Q LTNK will query the database to check if a prospective subscriber is already receiving
28See Order at ¶189.
2 See Order at ¶190.
30 See Order,Appendix C.
15
service from another ETC prior to seeking reimbursement from the fund.3’
2.Subscriber Usage
Q LINK will not seek reimbursement from the USf for new subscribers until they have
personally activated the service,either by initiation and/or actual use of the service by the
subscriber.furthermore,Q LINK will not seek reimbursement from the USF for inactive
subscribers who have not used the service for a consecutive 60-day period.32 LINK will notify
its subscribers at service initiation about the non-transferability of the phone service,its usage
requirements,and the de-enrollrnent and deactivation that will result following non-usage in any
60-day period of time.33 An account will be considered active if during any 60-day period the
authorized subscriber does at least one of the following:makes a monthly payment;purchases
minutes from the Company to add to an existing pre-paid Lifeline account;completes an
outbound call;answers an incoming call from anyone other than the Company,its representative,
or agent;or affirmatively responds to a direct contact from the Company confirming that he or
she wants to continue.34 Q LINK utilizes tracking software to notify the customer if the
customer has not used their service for more than 30 or 60 consecutive days.furthermore,a
third party contractor validates the Company’s subsidy data to prevent a subsidy request for
customers that are inactive under the Company’s non-usage policy.After notification.if the
customer fails to use their service,the customer is automatically de-enrolled pursuant to the
procedures outlined in section E below.Q LINK will continue to comply with applicable public
safety,including transmitting 911 calls to the appropriate PSAP even if the Company is no
31 See Order at ¶203.
32 See Order at ¶257.
See icL
345ee Order at ¶261.
CGM,LLC is currently the Company’s third party contractor.
16
longer providing Lifeline service to a consumer.36
3.Marketing &Outreach
Q LiNK will implement the measures outlined herein to help ensure that oniy eligible
consumers enroll in the program and that those consumers are fully informed of the limitations
of the program,so as to prevent dup]icative or otherwise ineligible service as well as other forms
of waste,fraud,and abuse.Q LINK will explain in clear,easily understood language the
following disclosures in all marketing materials related to the supported service:37 (1)that only
eligible consumers may enroll in the program;(2)that the program is limited to one benefit per
household,consisting of either wireline or wireless service;(3)a household is defined,for
purposes of the Lifeline program,as any individual or group of individuals who live together at
the same address and share income and expenses;and (4)that Lifeline is a government benefit
program.Q LINK will prepare printed material that will explain the documentation necessary
for enrotlment.and the details of the Company’s plans.and will provide such information on its
website.Such material and website information,as well as its application,will make clear that
consumers who willfully make false statements in order to obtain the benefit can be punished by
fine or imprisonment or can be barred from the program.38 For broadcast advertisements and
outdoor signage,such as billboards,and any other situation in which inclusion of documentation
information and warnings against willful false statements are impractical,Q LINK,will provide
the URL link for the information disclosure page on its website.Additionally,Q LINK will
36 See Order at 262.91 1 transmissions will actually be performed by the Company’s underlying facilities-based
CMRS provider.
‘See Exhibit B for sample marketing materials.The Company understands the term “marketing materials”includes
materials in all media,including but not limited to print,audio,video,Internet (including email,web,and social
networking media),and outdoor signage,that describe the Lifeline-supported service offering,including application
and certification forms.See Order at ¶275.
38 See Order at ¶275.
17
disclose the company name under which it does business.39 In order to reinforce the limitation of
one Lifeline phone per household,the following statement,or words to the same effect,will
appear in the Company’s marketing materials and website (www.qlinkwireless.com)in a
conspicuous place,in bold font and in an offsetting color to ensure it is not overlooked:
Lifetine support is limited to one per household on wireline or wireless
service.
4.Audits
If Q LINK draws $5 million or more in the aggregate on an annual basis from the low
income program,as determined on a holding company basis taking into account all operating
companies and affiliates,the Company will hire an independent licensed certified public
accounting firm to conduct a biennial audit according to government accounting standards to
assess Q LINK’s overall compliance with the program’s requirements.4°Q LINK will comply
with applicable rules regarding the dissemination of audit findings to the Commission,USAC.
and relevant state and Tribal governments within 30 days upon issuance.41
E.De-Enroilment
If at any time a Q LINK Lifeline customer wishes to de-enroll from the Company’s
Lifeline program,Company customer service representatives will handle such elective de
enrollment requests.Q LINK Lifeline customers simply call the Company’s toll-free customer
service number and they can speak to a live operator to de-enroll from Q LiNK’s Lifeline
program.Q LiNK will de-enroll consumers from the Company’s Lifeline program in the
following instances,according to C.f.R.§54.405(e):
39See Id.
40See Order atJ 291.
See Order at ¶294.
18
Ineligibility.Any subscriber who indicates that he or she is receiving more than one
Lifeline-supported service per household,or neglects to make the required one-per-household
certification on his or her certification form,will be de-enrolled from Lifeline pursuant to the
process for resolving duplicative Lifeline subscriptions described in section 54.405(e)(2).42
If a customer does not respond to the Company’s annual verification survey within 30 days,or if
Q LINK has reasonable basis to believe that the subscriber no longer meets the Lifeline-
qualifying criteria (including instances where a subscriber informs the Company or the state that
he or she is ineligible for Lifeline),Q LINK will provide a written notice of impending service
termination to the subscriber and then give the subscriber 30 days after the date of the letter to
demonstrate that his or her Lifeline service should not be terminated.43 Similarly,Q LiNK will
de-enroll a subscriber if they fail to respond to the Company’s attempt to verify a temporary
address within 30 days.44
Duplicative Support.Subject to USAC’s Duplicate Resolution Process and anticipated
Duplicate Scrubbing Process,4 Q LINK will de-enroll a subscriber within 5 business days if the
Company is informed by USAC that the subscriber is receiving Lifeline service from another
ETC or that more than one member of a subscriber’s household is receiving Lifeline service.
Non-Usage.Q LINK will monitor all customers to ensure that they in fact have usage on
their account within a 60-day period.Q LINK will de-enroll any subscriber that has not used the
Company’s Lifeline service for 60 consecutive days.as discussed in section W.B above.Q
LINK will send the subscriber a 30-day termination letter,using clear,easily understood
language,notifying the subscriber that failure to use the Lifeline service within the 30-day cure
42 See Order at ¶122.
See id.In states that have dispute resolution procedures applicable to Lifeline termination,the Company will
comply with the state requirements.
See Order at ¶89.
See Order at ¶214-16.
19
period will result in service termination for non-usage.The subscriber will be able to confirm
that they want to continue receiving their Lifeline service.Q LINK will update the national
database,once in place,within one business day of de-enrolling a subscriber for non-use and will
submit a non-usage de-enroliment report annually to USAC.46 Q LINK will not seek
reimbursement from the USf during the 30-day cure period unless the subscriber confirms they
want to continue service.
F.Additional Rule Amendments
1.Reporting Requirements
Q LINK will report all information required by section 54.422,as it may heretofore be
amended.This includes the names of the Company’s holding company,operating companies
and affiliates,and any branding (“doing-business-as company”or brand designation),and
provide to the Commission and USAC general information regarding the terms and conditions of
the Lifeline plans for voice telephony service offered specifically for low income consumers
through the program offered during the previous year,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.47
2.Reimbursements from USAC
In seeking reimbursement for Lifeline,Q LINK will comply with the requirements of
C.F.R §54.407,as revised by the Order.48 Q LINK will certify when seeking reimbursement that
the Company has obtained a valid certification fonn for each consumer for whom the Company
46 See Order at ¶257.
See Order at ¶296,390.Section 153 ofthe Communications Act defines “affiliate”as “a person that (directly or
indirectly)owns or controls,is owned or controlled by,or is under common ownership or control with,another
person.
485ee Order page 221.
20
seeks Lifeline reimbursement;49 and the Company will seek reimbursement for actual lines
served,not projected lines.50
3.Section 54.202 Certifications
Q LINK certifies the following in accordance with newly amended C.f.R.§54.202:(1)Q
LINK will comply with the service requirements applicable to the support that it receives;(2)Q
LINK is able to remain functional in emergency situations;and (3)Q LINK will satisf applicable
consumer protection and service quality standards.
IV.COMPANY INFORMATION
Q LINK is a Limited Liability Company organized in the State of Delaware on August 25,
2011.Q LINK will provide prepaid wireless telecommunications services by using the Sprint
Nextel (“Sprint”)network on a wholesale basis to offer nationwide service.Sprint is a nationwide
carrier that provides wholesale capacity on its wireless network to wireless providers like Q LINK.
Q LINK will obtain from Sprint the network infrastructure and wireless transmission facilities to
allow Q LINK to operate as a Mobile Virtual Network Operator (“MVNO”).Q LINK was
designated as an ETC in Maryland on December 21,2011.Q LINK does not currently provide
service in any state.
A.Names and Identifiers
The Company’s legal name is Q LINK WIRELESS LLC.Q LINK’s holding company is
QUADRANT HOLDINGS GROUP LLC.The Company does not have any operating companies
and it identifies itself as Q LINK or Q LINK WIRELESS on its marketing and advertising
materials.
See Order at ¶128.
50See Order at ¶302.
21
B.Financial and Technical Capability
Q LINK is financially and technically capable of providing Lifeline-supported services.1 Q
LINK will provide service to both Lifeline and non-Lifeline customers.Q LINK intends to launch
its retail and Lifeline wireless service simultaneously.Q LINK has not been subject to
enforcement action or ETC revocation proceedings in any state.Q LINK is financially able to
provide Lifeline-supported services and will not rely exclusively on USf disbursements to
operate.52 furthermore,the senior management of Q LINK has great depth in the
telecommunications industry and offers extensive telecommunications business technical and
managerial expertise to the Company.3 Q LINK will also rely upon the managerial and technical
expertise of its underlying carrier Sprint.
C.Lifeline Offering
Q LINK will offer its Lifeline service in the states where it is designated as an ETC and
throughout the coverage area of its underlying carrier Sprint.As summarized in Exhibit E attached
hereto,the Company’s Lifeline offering will provide customers with the option to choose between
three (3)Lifeline Plans4 that best meets their needs:
1.Plan 1:68 Monthly Minutes.Under Plan 1,eligible customers enjoy 6$anytime
minutes that rollover and free international long distance.55 Text messaging is at the
rate of one-third of one minute (3 texts =1 minute).
See Order at 387.
See Exhibit C for QUADRANT HOLDfNGS GROUP LLC’S financial Statements.This information is
CONFIDENTIAL AND PROPRIETARY and is being filed under seal as such.
See Exhibit D for key management resumes.
Q LINK’s Lifeline Plans vary from state to state in accordance with state requirements or Tribal offerings;the
three Lifeline plans outlined in this compliance plan are the offerings available in most states.Please see the
Company’s website (www.glinkwireless.com)for more detailed information regarding plans available in each state.
If you are on Plan 1,there is no additional charge for international long distance to countries designated at
www.glinkwireless.com.
22
2.Plan 2:125 Monthly Minutes.Under Plan 2,eligible customers enjoy 125 anytime
minutes that rollover.Text messaging is at the rate of one minute (1 text =1 minute).
3.Plan 3:250 Monthly Minutes.Under Plan 3,eligible customers enjoy 250 anytime
minutes.Minutes do not rollover.Text messaging is at the rate of one minute (1 text
=1 minute).
Customers have the capability of purchasing additional bundles of minutes in
denominations as low as $9.99.$19.99,$29.99,and $59•99•36 Airtime replenishment cards will
be made available at retail outlets frequented by low-income customers throughout the
Company’s Service Area.In addition to free voice services,all of Q LINK’s Lifeline plans will
include a free handset and the following Custom Calling features:Caller ID,Call Waiting,and
Voicemail.Q LINK does not impose burdensome credit checks or long-term service contracts
on its prepaid customers.Customers are not bound by a local calling area requirement;all Q
LINK plans come with domestic long distance at no extra per minute charge and exceptional
nationwide digital coverage on the Nationwide Sprint PCS Network.Calls to 911 emergency
services are always free,regardless of service activation or availability of minutes.Calls to Q
Link customer service are also free.Q LINK has attached as Exhibit F its Lifeline terms and
conditions of service.The terms and conditions of the Company’s plans can also be found at
www.qlinkwireless.com.
$9.99 =50 minutes,$19.99 =120 minutes,$29.99 =200 minutes.and $59.99 =450 minutes.
23
V.CONCLUSION
Q LINK submits that its Compliance Plan fully satisfies the conditions of forbearance set
forth in the Commission’s Order.Implementation of the procedures described herein will promote
public safety and should ensure that Lifeline customers have access to 911 and E91 I services while
safeguarding against misuse of the Company’s Lifeline services.Accordingly,Q LINK
respectfully requests that the Commission expeditiously approve its Compliance Plan so that the
Company may begin providing the benefits of much-needed Lifeline service to qualifying low
income consumers as quickly as possible.
Respectfully submitted,
Q LINK WIRELESS LLC
Is!LANCE STETNHART
Lance J.M.Steinhart
Lance J.M.Steithart,P.C.
1725 Windward Concourse
Suite 150
Aipharetta,Georgia 30005
[phone]
Its Counsel
Dated July 30,2012
24
EXHIBIT A
Sample Lifeline Certification Form
I I k I if APPUCATION FOR GOVERNMENT
I I N IN.LIFELINE ASSISTANCE PROGRAM
VI I fl S L E 5 S
Things to know about the Lifeline Program:
(1)Lifeline is a federal non-transferable benefit.
(2)Lifeline Service is available for only one line per household.A household cannot receive benefits from multiple providers;and
(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.
Please read all instructions before completing.Information will be validated.Discrepancies could result in delays.
___________________________________________
I I
_________
Ml B:rth Date (MonthlDayffear)Lest Four Digits of SSS
Hone Phone Number cell Phone Number contea Phone Number Email Address
This address is LPermanent TemporaryF Multi-Household
Residence Address (No P.O.Boxes,Must be your principal address(Apartment No.State
Plan Features
Choose your SIan (check one(
Local Calls
National Long Distance
VoIce Mail
Nationwide Text
Roaming at no additional Cost
Free 911
411 Directory Assistance
Carry-Over minutes from month to month
1 OO+lntemational Long Distance destinations
‘Minutes can be usedfor 411 calling at no additiona cml
5’°“Long ostance charges wit appiy
‘2.To apply for 0 Link you may choose ONE of the two options below:
The program is limited to one benefit per household and only eligible Consumers may enroll in the program.Consumers who willfully make false statements in
order to obtain the benefit can be punished by tine or imprisonment or can be barred from the program.
To qualify you must attach proofof participation in one of the
programs listed below.
I hereby certify that I participate In at least ONE ofthefottowing pubtic
assistance programs (Check alt that applyl:
Total monthly household income L I
ec$h°Total yearly household income I__________
__________
£
PENALTY OF PERJURY:undertitle 18 U.S.C.§1621,whoever willfully states as true any material matterwhich he does not believe to be true in a statement under penalty of
perjury,is guilty of perjury and shall,except as otherwise expressly provided by law,be fined or imprisoned not more than five years,orboth.
I certify,under penalty of perjury:Ilnitial by Each Certification)
(1)The information contained in my application remains true and correctto the best of my knowledge and I acknowledge that willfully providing false or fraudulent informatiornto receive Lifeline benefits is
punishable by law and may result in me being barred from the program.
(2)lam a current recipient ofthe program chocked above,or have an annual household income at or below 135 percent ofthe Federal Poverty Guidelines
(3)1 have provided documentation of eligibility if required to do so.
(4)t understand that I and my household can only have one Lifeline-supported telephone service.0 Link Wireless has eoptained the one-perhousehold requirement.I understand that violation ofthe one-
per-household requirement constitutes a violation of the FCC’s rules and will result in my de-enrolimentfrom the Lifeline program,and could result in criminal prosecution by the US Government.
(5)I attest to the best ofmy knowledge,that I and no one in my household is mceiving a Lifeline service from any other tand line or wireless company such as Safelink,Assurance,or ReachoutWireless.
(6)I understand my 0 Link tMmless Lifeline service is a non-transferable.I may not transfer my serviceto any individual,including anothereligible low-income consumer.
(7)I understand that if my service goes unused for sixty (60)days,my service will be suspended,subject to a thirty (3D)day period which I may use the service or contact 0 Link fMreles to confirm that I
want to conhnue receivingtheir service.
(8)I will notify 0 Link Wireless within thirty(30)days if I no longer quality for Lifeline.I understand this requirement and may be subject to penalties it (fail to notify 0 Link Wireless if:
(1)1 cease to participate in the above federal or state program,ormy annual household income exceeds 135%FPG.
(2)kiy household to receiving more than one Cifettne supported device.
13)1 no longersatisfythe critena for receiving Lifeline support.
(9)I will notify a Link Wirelesswithin thirty (30)days of moving.Additionally,ifmy address listed above is a temporary address,I understand that I must verify my address with 0 Link Wireless every ninety
(90)days.If I tail to respond to 0 Link Wireless’address verification attempts within thirty (30)days,my 0 Link Wireteos Lifeline service may be terminated.
(10)0 LinkWireless has expluined that I’m required each yearto re-certify my eligibility for Lifeline,If I tail to do so within thirty (30)days,t will result in thetermination ofmy 0 LinkWireless service.
(11)1 authorize and understand that the 0 Link Wireless may provide to state and Federal agencies,as required by law,for the purposes ofcomplying with the Lifeline program all the information related to my
account including but not limited to my name,date of birth,social security,usage history,address and phone number.
(1211 understand that my name,telephone number,date of birth,last four digitsofmy social security number,and address will be divulged to the Universal Service Administrative Company (USAC)and/orits
agentsforthe purpose of verifying that I do not receive more than one Lifeline subsidy,
(13)1 understand that if USAC identifies I am receiving more than one Lifeline subsidy,all camera involved maybe notified so that I may select one service and be de-enrolled from the other.
PRIVACY LAW
I authorize 0 Link Wireless or its duly appointed representativeto (1)access any records required to verify my statements herein:(2)to confirm my continued eligibility for Lifeline assistance:13)to update my
address to a proper mailing address format;and (4)authorize social service agency representatives to discuss with and/or provide information to 0 Link Wireless verifying my participation in benefit programs
that qualifyme for Lifeline assistance I understand that completion of this form does not constitute immediate approval for Lifeline.
Please checkthis boa if you would like toreceive pre.re:orded special offers and promotions for 0 Link Cuslomersal the Home Telephone number provided In the Contact Information.
SIGN &
Applicant Signature__________________________________________Date
__________________________________________
OATS
HERE
Mail application to:13 Link Wireless LLC
499 East Sheridan Street Suite 300
Danla Beach,FL 33004
Last Name First Name
../(03nrinuleu per teen
if
if
if
city
LI
a)Ii minute per teotl
ifif
Zip Code
4-a)4-,.
if
4-11 minute per teot(
if
4-x
4,
Qualify by certifying your income is at or below 135%of the Fedural Pos’etty Gudelines.
HouSEHoLD INCOME:
Please cheek heushnid persons and income level that applies.Eligibility may appiy If poor total
household income is at or below the lollewlee guidelines.E Medicaid (Not the same as Medicare)
D Supplemental Nutrition Assistance Program (Food Stamps)[ees in Fasdl or Heusoliutx4enr,aut inanme Munntle in(To goal ly by roams you mustanuch yruct of
[j Temporary Assistance to Needy Families )TANF)
,°r’
s nio
You ‘5 0 u’r S t t t m
—I 2 I Li 022 0th Slash .Pm yearn Son,e’Frocrx ,eruoncoo rein’
Li Supplemental Security Income SSI (Not the same as Social Security Benefits)(“j 0 fl27,$2 316 ‘TOme aensemsse monthsvi yrormnot ascent airystubS
E National School Lunch Programs Free Lunch Program “
d
‘
U 933 525 _,C0nidpy “n rrd’5omn’tb5o f’5
5 u:140,0 C .Rshieze,,UPovconbnnehlssmatei000t
E Low-Income Home Energy Assistance Program (LIHEAP)-i -,
‘Smiai besanixtenimons ha,.,ndatwioo tennehis nrawmo,rt
-
5.-_‘Sir c “.“Ionoemnenlahon You Suhost Wdl Not an Retumnedi
Federal Public Housing Assistancel Section 8 Namber atpeople receiving income I
__________
Numbnr of chidren underage of it I
Fax application to:1-855-83QLINK (855-837-54651
For questions please call i-8s5-QLINK43 (855-7546543)
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_
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f
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a
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Sc
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Lu
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c
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Pr
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s
Fr
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Pr
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m
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En
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!
Se
c
t
i
o
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8
To
t
a
l
mo
n
t
h
l
y
ho
u
s
e
h
o
l
d
in
c
o
m
e
I_
_
_
_
_
_
_
_
_
_
To
t
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l
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ho
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s
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h
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d
in
c
o
m
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BO
T
T
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M
SE
C
T
I
O
N
PE
N
A
L
T
Y
OF
PE
R
J
U
R
Y
Un
d
e
r
ti
t
l
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18
U
S
C
16
2
1
,
wh
o
e
v
e
r
wi
l
l
f
u
l
l
y
st
a
t
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s
as
tr
u
e
an
y
ma
t
e
r
i
a
l
ma
t
t
e
r
wh
i
c
h
he
do
e
s
no
t
be
l
i
e
v
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to
be
tr
u
e
In
a
st
a
t
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m
e
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t
un
d
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r
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a
l
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of
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r
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,
Is
gu
i
l
t
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of
pe
r
j
u
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an
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sh
a
l
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,
ex
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p
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as
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ex
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s
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l
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pr
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v
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by
la
w
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be
fi
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d
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im
p
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o
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d
no
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mo
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fi
v
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t
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t
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,
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d
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by
Ea
c
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r
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c
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Th
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In
f
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m
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co
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In
my
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pu
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me
be
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ba
r
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d
fr
o
m
th
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pr
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g
r
a
m
.
(2
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I
am
a
cu
r
r
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n
t
re
c
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p
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n
t
of
th
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pr
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g
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a
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ch
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,
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a
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s
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h
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in
c
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at
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13
5
pe
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c
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n
t
of
th
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Fe
d
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r
a
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Po
v
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t
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Gu
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d
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l
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s
.
__
_
_
_
_
(3
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I
ha
v
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pr
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do
c
u
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t
a
t
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of
el
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b
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f
l
t
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if
re
q
u
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r
e
d
to
do
so
.
(4
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1
un
d
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th
a
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I
an
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my
ho
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h
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ca
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on
l
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ha
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of
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FC
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s
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In
my
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fr
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f
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pr
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,
an
d
co
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in
cr
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pr
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c
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I
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by
th
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US
Go
v
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r
n
m
e
n
t
.
(5
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I
at
t
e
s
t
to
th
e
be
s
t
o
f
my
kn
o
w
l
e
d
g
e
,
th
a
t
I
an
d
no
on
e
in
my
ho
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s
e
h
o
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d
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re
c
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v
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rv
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fr
o
m
an
y
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h
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r
la
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d
li
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or
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s
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co
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p
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su
c
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Sa
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Re
a
c
h
o
u
t
Wi
f
e
l
e
s
s
.
(6
)
I
un
d
e
r
s
t
a
n
d
my
0
li
n
k
WI
r
e
l
e
s
s
LI
f
e
l
i
n
e
se
r
v
i
c
e
is
a
no
n
tr
a
n
s
f
e
r
a
b
l
e
I
ma
y
no
t
tr
a
n
s
f
e
r
my
se
r
v
i
c
e
to
an
y
ln
d
M
d
u
a
l
in
c
l
u
d
i
n
g
an
o
t
h
e
r
el
i
g
i
b
l
e
lo
w
in
c
o
m
e
co
n
s
u
m
e
r
(7
)
I
un
d
e
r
s
t
a
n
d
th
a
t
If
my
se
r
v
i
c
e
go
e
s
un
u
s
e
d
fo
r
si
x
t
y
(6
0
)
da
y
s
,
my
se
r
v
i
c
e
wil
l
be
su
s
p
e
n
d
e
d
,
su
b
j
e
c
t
to
a
th
i
r
t
y
(3
0
)
da
y
pe
r
i
o
d
wh
i
c
h
I
ma
y
us
e
th
e
se
r
v
i
c
e
or
co
n
t
a
c
t
0
Li
n
k
Wh
a
l
e
s
to
co
n
f
i
r
m
th
a
t
I
wa
n
t
to
co
n
t
i
n
u
e
re
c
e
i
v
i
n
g
th
e
i
r
se
r
v
i
c
e
.
—
(8
)
I
wi
l
l
no
t
i
f
y
0
Li
n
k
Wi
r
e
l
e
s
s
wi
t
h
i
n
th
i
r
t
y
(3
0
)
da
y
s
If
I
no
lo
n
g
e
r
qu
a
l
i
f
y
fo
r
Li
f
e
l
I
n
e
I
un
d
e
r
s
t
a
n
d
th
i
s
re
q
u
i
r
e
m
e
n
t
an
d
ma
y
be
su
b
j
e
c
t
to
pe
n
a
l
t
i
e
s
if
l
fa
i
l
to
no
t
i
f
y
0
Li
n
k
Wi
r
e
l
e
s
s
if
(1
)
1
ce
a
s
e
to
pa
r
t
i
c
i
p
a
t
e
in
th
e
ab
o
v
e
fe
d
e
r
a
l
or
st
a
t
e
pr
o
g
r
a
m
or
my
an
n
u
a
l
ho
u
s
e
h
o
l
d
In
c
o
m
e
ex
c
e
e
d
s
13
5
%
FP
G
(2
)
M
y
ho
u
s
e
h
o
l
d
Is
re
c
e
I
v
i
n
g
mo
r
e
th
a
n
on
e
Li
f
e
l
i
n
e
su
p
p
o
r
t
e
d
de
v
i
c
e
(3
)
1
no
lo
n
g
e
r
sa
t
i
s
f
y
th
e
cr
i
t
e
r
i
a
fo
r
re
c
e
i
v
i
n
g
Li
f
e
l
i
n
e
su
p
p
o
r
t
(9
)
I
wi
l
l
no
t
i
f
y
0
Li
n
k
Wi
r
e
l
e
s
s
wi
t
h
i
n
th
i
r
t
y
(3
0
)
da
y
s
of
mo
v
i
n
g
Ad
d
i
t
i
o
n
a
l
l
y
if
y
ad
d
r
e
s
s
li
s
t
e
d
ab
o
v
e
is
a
te
m
p
o
r
a
r
y
ad
d
r
e
s
s
I
un
d
e
r
s
t
a
n
d
th
a
t
I
mu
s
t
ve
r
i
f
y
my
ad
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r
e
s
s
wi
t
h
0
Li
n
k
Wi
r
e
l
e
s
s
ev
e
r
y
ni
n
e
t
y
(9
0
)
da
y
s
If
I
fa
i
l
to
re
s
p
o
n
d
to
O
Li
n
k
Wi
r
e
l
e
s
s
ad
d
r
e
s
s
ve
n
f
i
c
a
t
i
o
n
at
t
e
m
p
t
s
wi
t
h
i
n
th
i
r
t
y
(3
0
)
da
y
s
my
0
Li
n
k
Wi
r
e
l
e
s
s
Li
f
e
l
i
n
e
se
r
v
I
c
e
ma
y
be
te
r
m
i
n
a
t
e
d
__
_
_
_
_
(1
0
)
Q
Li
n
k
Wi
r
e
l
e
s
s
ha
s
ex
p
l
a
i
n
e
d
th
a
t
I
m
re
q
u
i
r
e
d
ea
c
h
ye
a
r
to
re
ce
r
t
i
f
y
my
el
i
g
i
b
i
l
i
t
y
fo
r
LI
f
e
l
i
n
e
If
I
fa
l
l
to
do
so
wi
t
h
i
r
t
th
i
r
t
y
(3
0
)
da
y
s
It
wi
l
l
re
s
u
l
t
in
th
e
te
r
m
I
n
a
t
i
o
n
of
my
0
Li
n
k
Wi
r
e
l
e
s
s
se
r
v
I
c
e
-
(1
1
)
1
au
t
h
o
r
i
z
e
an
d
un
d
e
r
s
t
a
n
d
th
a
t
th
e
0
Li
n
k
Wi
r
e
l
e
s
s
ma
y
pr
o
v
i
d
e
to
st
a
t
e
an
d
Fe
d
e
r
a
l
ag
e
n
c
i
e
s
as
re
q
u
i
r
e
d
by
la
w
,
fo
r
th
e
pu
r
p
o
s
e
s
of
co
m
p
l
y
i
n
g
wI
t
h
th
e
Li
f
e
l
i
n
e
pr
o
g
r
a
m
al
l
th
e
in
f
o
r
m
a
t
i
o
n
re
l
a
t
e
d
to
my
ac
c
o
u
n
t
In
c
l
u
d
i
n
g
bu
t
no
t
li
m
i
t
e
d
to
my
na
m
e
da
t
e
of
bi
r
t
h
so
c
i
a
l
se
c
u
r
i
t
y
us
a
g
e
hi
s
t
o
r
y
ad
d
r
e
s
s
an
d
ph
o
n
e
nu
m
b
e
r
(1
2
)
1
un
d
e
r
s
t
a
n
d
th
a
t
my
na
m
e
te
l
e
p
h
o
n
e
nu
m
b
e
r
da
t
e
Of
bi
r
t
h
la
s
t
to
u
t
di
g
i
t
s
of
my
so
c
i
a
l
se
c
u
n
t
y
nu
m
b
e
r
an
d
ad
d
r
e
s
s
wi
l
l
be
di
v
u
l
g
e
d
to
th
e
Un
i
v
e
r
s
a
l
Se
r
v
i
c
e
Ad
m
i
n
i
s
t
r
a
t
i
v
e
Co
m
p
a
n
y
(U
S
A
C
)
an
d
/
o
r
it
s
ag
e
n
t
s
fo
r
th
e
pu
r
p
o
s
e
of
ve
r
i
f
y
i
n
g
th
a
t
I
do
no
t
re
c
e
i
v
e
mo
r
e
th
a
n
on
e
Li
f
e
l
i
n
e
su
b
s
i
d
y
.
(1
3
)
I
un
d
e
r
s
t
a
n
d
th
a
t
if
US
A
C
id
e
n
t
i
f
i
e
s
I
am
re
c
e
i
v
i
n
g
mo
r
e
th
a
n
on
e
Li
f
e
l
i
n
e
su
b
s
i
d
y
al
l
ca
m
e
r
s
in
v
o
l
v
e
d
ma
y
be
no
t
i
f
i
e
d
so
th
a
t
I
ma
y
se
l
e
c
t
on
e
se
r
v
i
c
e
an
d
be
do
-
e
n
r
o
l
l
e
d
fr
o
m
th
e
ot
h
e
r
PR
I
V
A
C
Y
LA
W
I
au
t
h
o
r
i
z
e
0
Li
n
k
Wi
r
e
l
e
s
s
or
it
s
du
l
y
ap
p
o
i
n
t
e
d
re
p
r
e
s
e
n
t
a
t
i
v
e
to
(1
)
ac
c
e
s
s
an
y
re
c
o
r
d
s
re
q
u
i
r
e
d
to
ve
r
I
f
y
my
st
a
t
e
m
e
n
t
s
he
r
o
i
n
(2
)
to
co
n
f
i
r
m
my
co
n
t
i
n
u
e
d
el
i
g
i
b
i
l
i
t
y
fo
r
Li
f
e
l
i
n
e
as
s
i
s
t
a
n
c
e
(3
)
to
up
d
a
t
e
my
ad
d
r
e
s
s
to
a
pr
o
p
e
r
ma
i
l
i
n
g
ad
d
r
e
s
s
fo
r
m
a
t
an
d
(4
)
au
t
h
o
r
i
z
e
so
c
i
a
l
se
r
v
i
c
e
ag
e
n
c
y
re
p
r
e
s
e
n
t
a
t
i
v
e
s
to
di
s
c
u
s
s
wi
t
h
an
d
/
o
r
pr
o
v
i
d
e
in
f
o
r
m
a
t
i
o
n
to
Q
Li
n
k
Wi
r
e
l
e
s
s
ve
r
i
f
y
I
n
g
my
pa
r
t
i
c
i
p
a
t
i
o
n
in
be
n
e
f
i
t
pr
o
g
r
a
m
s
th
a
t
qu
a
l
i
f
y
me
fo
r
Li
f
e
l
i
n
e
as
s
i
s
t
a
n
c
e
.
I
un
d
e
r
s
t
a
n
d
th
a
t
co
m
p
l
e
t
i
o
n
of
th
i
s
fo
r
m
do
e
s
no
t
co
n
s
t
i
t
u
t
e
im
m
e
d
i
a
t
e
ap
p
r
o
v
a
l
fo
r
Li
f
e
l
i
n
e
,
Pl
e
a
s
e
ch
e
c
k
th
i
s
bo
x
if
yo
u
wo
u
l
d
li
k
e
to
re
c
e
i
v
e
pr
e
-
r
e
c
o
r
d
e
d
sp
e
c
i
a
l
of
f
e
r
s
an
d
pr
o
m
o
t
i
o
n
s
fo
r
0
Li
n
k
Cu
s
t
o
m
e
r
s
.
at
th
e
Ho
m
e
Te
l
e
p
h
o
n
e
nu
m
b
e
r
pr
o
v
i
d
e
d
in
th
e
Co
n
t
a
c
t
In
f
o
r
m
a
t
i
o
n
.
SI
G
N
&
Ap
p
l
i
c
a
n
t
Si
g
n
a
t
u
r
e
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
Da
t
e
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
_
DA
T
E
HE
R
E
Ma
l
i
ap
p
l
i
c
a
t
i
o
n
to
:
Q
Li
n
k
Wi
r
e
l
e
s
s
LL
C
Fa
x
ap
p
l
i
c
a
t
i
o
n
to
:
14
5
5
4
3
0
U
N
K
(8
5
5
-
8
3
7
-
5
4
6
5
)
49
9
Ea
s
t
S
h
e
r
i
d
a
n
St
r
e
e
t
Su
I
t
e
30
0
Fo
r
qu
e
s
t
i
o
n
s
pl
e
a
s
e
ca
l
l
1-
8
5
5
-
Q
L
I
N
K
4
3
(8
5
5
.
7
5
4
-
6
5
4
3
)
Da
n
i
a
Be
a
c
h
,
FL
33
0
0
4
EXHIBIT B
Sample Marketing Materials
1.Internet/Email Banner Ad 600x474
2.Poster/flyer Ad 8.5x1 1
GE
T
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el
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in
d
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?
Yo
u
——
_
_
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ma
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qu
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in
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4
No
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4
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lifeline support is limited to one per house9oid on wireline or wireless service.Consumers who willfully
make false statements in order to obtain the benefit can be punished by fine or imprisonment or can be
barred from the program.Proof of pa.rticiptin in eligible programs/annual household income required for
en roi,l ment
Q Link Wireless provides FREE cell phone service and FREE Monthly Minutes through the Governwentrs Lifeline
prôran to qualirin fanilies and individualc,Visit wwwqlln1reles.on or call 1-855-QLINK43 to see If you
qualify.
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QUADRANT HOLDINGS CORP
BALANCE SHEET
As of Sept 30,2011
ASSETS
Current Assets
Cash &Cash Equivalents
Q Link Wierless Investment
Trade Accounts Receivable
Inventory
Prepaid Expenses and Deposits
Deferred Costs
Other Current Liabilities
Total Current Assents
I
Total Fixed Assets
Total Assets
FiXED ASSETS
Property and Equipment
Right of Access
Goodwill
LIABILITIES AND SHAREHOLDER’S EQUITY
Current Liabilities
Accounts Payable
Customer Deposits
Deferred Revenue
Current Portion of Deferred Lease Inducements
Current Portion of Obligations Under Capital Lease
Deferred Lease Inducements
Total Liabilities
Shareholder’s Equity
Share Capital
Contributed Surplus
Net Income or Loss
Total Liabilities &Capital $
QUADRANT HOLDINGS CORP
STATEMENT OF OPERATIONS,PROFIT &lOSS
As of Sept 30,2011
Revenues
Cost of Sales
Gross Profit
Expenses
Sales and Marketing
General Administrative
Amortization
Interest Expense
Other Expense
Total Expenses
I I
Net Income
EXHIBIT D
Key Management Resumes
Issa Asad
Issa Asad is the President &CEO or Managing Member of Various Companies (Quadrant Holdings Group LLC,Q Link
Wireless,NCOM Networks,RTN Networks,Reliable Telecard),these are some of the nation’s premier
telecommunications providers in the United States today,representing VoIP,wireless and prepaid service providers,
manufacturers and suppliers in the new world of Internet-based and wireless communications and entertainment.
A respected Telecom veteran with more than 15 years’experience in telecommunications,Mr.Asadjoined the
Telecommunications industiy in 1996 and has led the organization’s growth into the top telecommunications providers in
the nation.Intelecard News magazine has profiled Mr.Asad as a telecommunications executive with “real vision.”The
Prepaid Press newspaper has featured Mr.Asad as a “Telecom Mover of the Month”and labeled him as a ‘playmaker”-
one of the “top telecommunications executives”in United States.He has been recognized by Whos Who in Telecom.
Prior to establishing his footprint in the Prepaid Telecommunications industry,Mr.Asad served as President &CEO of
the South Florida Grocers Network.
Companies and their owners who endure in the prepaid industry are worthy of recognition because they are rare.As CEO
and owner of Reliable Telecard and I-Prepay Inc.Issa Asad began in retail as an owner operator and developer of
convenience stores and gas stations in New York and Florida.
Considered a pioneer he was the first station owner to implement fast food into service offerings,beginning with Fine
Foods.Asad also led the grocers industry to incorporate A TMs,convenience stores and Check Cashing stores into
groce,y’s and stations.
In 1996,he realized the potential of phone cards to the immigrant market and began offering phone cards from his stores.
By the late 90s,prepaid wireless was emerging and with his retail background Asad knew the long-term play was
electronic delivery.In the spring of 2000,he teamed with Reliable Telecard and I-Prepay Inc and developed a real-time
PIN delivery system for the electronic delivery ofprepaid products.
There he led a broad market restructuring that resulted in record sales and revenues,increased stature for the industry,
and significant telecom marketing victories.
ISSA ASAD
E—mail:[e-mail]
499 East Sheridan St Suite 301
Dania FL 33004
SENIOR EXECUTIVE SUMMARY
Entrepreneur and senior sales executive with 15 year accomplished track known throughout the prepaid and telecom
industry for delivering and sustaining revenue and profit gains within highly competitive domestic and international
prepaid products,including domestic and international prepaid telephone and wireless calling cards and national
distribution channels markets.By age 30,had pioneered what is now a multi-hundred million dollar a year Prepaid
industry.Practical experience in and solid understanding of a diverse range of business management applications,
including market analysis,sales and marketing,team-building and quality assurance.Demonstrated ability to select,train
and retain self-motivated customer-oriented employees.Exceptional problem-solving skills,keen client needs assessment
aptitude,high-caliber presentation,negotiation and closing skills.
Strategic &Tactical Planning Business Expansion &Startups
Mergers &Acquisition Staff Management &Development
Strategic Partnerships &Alliance Sales Presentations /Closing
Broker /Vendor Relations Account Development /Acquisition
PROFESSIONAL EXPERIENCE
QUADRANT HOLDINGS GROUP LLC -DANIA FL
Managing Member,January 201 1 —present
Quadrant Holdings is a holding company that serves as the Managing Member entity ofQ LINK WIRELESS LLC.
Q LINK WIRELESS LLC -DANIA,FL
Co-Founder,January 2011 —present
Q LINK WIRELESS LLC provides a government assisted wireless service.Q LINK offers a discount benefit to low
income families al?d individuals via wireless services in place ofolder technologies like landline phone service.
•Develop and evolve the sales model including strategy,process,partnerships,organization,and execution
to deliver financial and market share goals
•Design,architect and implement an optimized sales model that enables the company to achieve sustained
profitable growth
•Recruit,train and manage results-orientated staff of professional managers to oversee sales and marketing
efforts
IPREPAY,INC.-MIAMI,FL
VP of Sales &Co-Founder,January 2000 —2008
Provides wholesale long distance,prepaidpoint ofsale services including,prepaid wireless,prepaid calling
cards,billpay,FTD flowers and an array ofstored value products and services to carriers and end-users.Its
point-of-sale technology and services are a sensible alternative to paying the increasingly recurrent
infrastructure expenses necessaiy in the world of exponentially-improving telecom networks.The company 170W
serves as a one-stop-shopfor all prepaidproducts.
•Develop and evolve the sales model including strategy,process,partnerships,organization,and execution
to deliver financial and market share goals
•Design,architect and implement an optimized sales model that enables the company to achieve sustained
profitable growth
•Recruit,train and manage results-orientated staff of professional managers to oversee sales and marketing
efforts
•Increased 2004 gross revenues from $_M to 2005 run-rate of 575M.
X CHANGE COMMUNICATIONS -MIAMI,FL
Strategic Business Partner,2000 —2008
This company is apowerho use,with over 150 employees in a 40,000 squarefoot office campus in Miami,Florida.
X Change has the capacity to handle 8 billion calling minutes per month through a system that is beyond state of
the art.Evemi more amazing,that system was completely designed and developed by strategic partners and own
in-house software engineers.
•facilitated partnership with top carriers
•1St year partnership Revenues exceeded $85M
RELIABLE TELECARD -MIAMI,FL
CEO,President and Founder,2000 -Present
A leadingprovider ofwholesale and retail telecommunications services.Reliable Telecard uses its own network
infrastructure to route calls worldwide.The company’s prepaid retail cards (‘currentl)’topping 100 brw?ds,are
m’ai]able at over 250,000 points ofsale nationwide.
•Grew and maintain client base of 9,000 agents and 300 worldwide outlets
•Manage a staff of 150 employees
•Gross annual profits exceeding $50 M
PREPAID TECHNOLOGIES -MIAMI,FL
CEO,President and Founder,1996-2001
Prepaid Technologies is aligned with quaifled national processors and has issued cards through a variety of
national banks.113repaid Technologies provides host-based stored value cards that are packaged al?d marketed as
many diverse products such as a gi card,travel card,payroll card,incentive reward card,student card,e-card,
vendor payment card and expense card.
•Responsible for securing national prepaid distribution channels
•1St year profits exceeding $600K
WORLDCOM -MIAMI,FL
Director of Sales 1995 -1996
Facilities-based network operator managing one ofthe world’s largest communications network systems.One of
the largest carriers ofinternational voice traffic operating a leading Internet protocol backbone system.
•Secured exclusive prepaid phone card deal with Michael Jordon generating over $JB in gross revenues
with over $350 Million in profits during the 151 year
FINE FOODS SUPERMARKETS -MIAMI,FL
CEO,President and Founder,199 1-1999
•Designed,developed,opened and maintain 12 retail chain grocery stores
INDUSTRY PUBLICATIONS AND ACKNOWLEDGEMENTS
Intele-Card News Magazine:Acknowledged and interviewed in 48 issues since 2000.
Phone Plus:Acknowledged and interviewed in 10 issues since 2002.
Convenience Store Decisions:Acknowledged and interviewed in both 1997 and 1998.
Convenience Store News:Acknowledged and interviewed in both 1997 and 1998.
Vending Times:Acknowledged and interviewed in 1995.
EDUCATION
FLORIDA INTERNATIONAL UNWERSITY -MIAMI,FL
B.A..Business,May 1995
A.A..Science,May 1995
EXHIBIT E
Proposed Lifeline Rate Plans
Plan 1:68 Monthly Minutes Plan*
6$anytime minutes per month
(texts are one-third of one minute,i.e.3 texts =1 minute)
Net cost to Lifeline customer:$0 (free)
*This package includes:
•Free handset
•Free calls to Customer Service
•Free calls to 911 emergency services
•Free Voicemail,Caller-ID,and Call Waiting
•68 anytime minutes (unused minutes rollover)
•Free Domestic Long Distance
•Free International Long Distance to countries designated at www.glinkwireless.com
(listed below)
Plan 2:125 Monthly Minutes Plan*
125 anytime minutes per month
(texts are one minute,i.e.1 text 1 minute)
Net cost to Lifeline customer:$0 (free)
*This package includes:
•Free handset
•Free calls to Customer Service
•Free calls to 911 emergency services
•Free Voicemail,Caller-ID,and Call Waiting
•125 anytime minutes (unused minutes rollover)
•Free Domestic Long Distance
Plan 3:250 Monthly Minutes Plan*
250 anytime minutes per month
(texts are one minute,i.e.1 text 1 minute)
Net cost to Lifeline customer:$0 (free)
*Tlis package includes:
•Free handset
•free calls to Customer Service
•Free calls to 911 emergency services
•Free Voicemail,Caller-ID,and Call Waiting
•250 anytime minutes (unused minutes do not rollover)
•free Domestic Long Distance
International Long Distance
Free International Calling Destinations on the 68 Monthly Minutes Plan
(Certain special or off-network locations may be excluded from the Free International Long
Distance.Calls to cellular phones are not included unless the word “Cellular”is specifically
listed next to the country name.Numbers in parentheses Q indicate the Country Code.)
Albania-Tirana (355)france (33)Mexico (52)
Andorra (376)french Antilles (594)Monaco (377)
Argentina (54)French Guiana-Cellular Netherlands (31)
Australia (61)(594)New Zealand (64)
Austria (43)French Guiana (594)Norway (47)
Bahamas-Cellular (1)Georgia (995)Panama (507)
Bahamas (1)Germany (49)Paraguay (595)
Bangladesh-Cellular (880)Gibraltar (350)Peru (51)
Bangladesh-Chittagong Greece (30)Poland (48)
(880)Guadeloupe (590)Portugal (351)
Bang]adesh-Dhaka (880)Guatemala-Telgua (502)Romania (40)
Bangladesh-Sylhet ($80)Hong Kong-Cellular ($52)Russia-Cellular (7)
Belgium (32)Hong Kong (852)Russia (7)
Bermuda-Cellular (1)Hungary (36)San Marino-Cellular (378)
Bermuda (1)Iceland (354)San Marino (378)
Bolivia-La Paz (591)India-Cellular (91)Saudi Arabia-Riyadh (966)
Bolivia-Santa Cruz (591)India (91)Singapore-Cellular (65)
Brazil (55)Indonesia-Cellular (62)Singapore (65)
Brunei-Cellular (673)Indonesia-Jakarta (62)Slovakia (421)
Brunei (673)Indonesia-Surabaya (62)Slovenia (386)
Bulgaria (359)Iraq-Baghdad (964)South Korea-Cellular (82)
Canada-Cellular (1)Ireland (353)South Korea ($2)
Canada (1)Israel (972)Spain (34)
Chile (56)Italy (39)Sweden (46)
China-Cellular (86)Japan (81)Switzerland (41)
China (86)Jordan (962)Taiwan-Cellular (886)
Columbia-Cellular (57)Kazakhstan (7)Taiwan (866)
Columbia (57)Kenya-Nairobi (254)Thailand (66)
Costa Rica (506)Lithuania (370)Turkey (90)
Croatia (585)Luxembourg-Cellular United Kingdom (44)
Cyprus-Cellular (357)(352)Uzbekistan (7)
Cyprus (357)Luxembourg (352)Venezuela (58)
Czech Republic (420)Macao-Cellular ($53)Vietnam-Ho Chi Minh
Denmark (45)Macao (853)City ($4)
Dominican Republic (1)Malaysia-Cellular (60)Zambia (260)
Estonia (372)Malaysia (60)
Finland (35$)Malta (356)
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Q LINK WIRELESS LifeLine Terms and Conditions of Service
Please read these Q LINK WIRELESS LLC Lifeline Terms and Conditions of Service carefully.These 0
LINK WIRELESS LLC Lifeline Terms and Conditions of Service are a legally binding agreement between
you and Q LINK WIRELESS LLC.They contain important information about your legal rights and require
that certain disputes be resolved through Arbitration instead of a court trial.0 LINK WIRELESS LLC
reserves the right to change or modify any of these 0 LINK WIRELESS LLC Lifeline Terms and
Conditions of Service at any time and at its sole discretion.Any changes or modifications to these 0 LINK
WIRELESS LLC Lifeline Terms and Conditions of Service will be binding upon you once posted on the Q
LINK WIRELESS LLC website.You should check the 0 LINK WIRELESS LLC website regularly for
updates to these terms.
By enrolling in the 0 LINK WIRELESS Lifeline Program (the “0 LINK WIRELESS Lifeline Program”or “Q
LINK Lifeline Program”)and by using the Q LINK WIRELESS Lifeline service (the 0 LINK WIRELESS
Lifeline Service”or “0 LINK Lifeline Service”),you (‘You”),the participant,acknowledge and agree to the
following terms and conditions:
1.Q LINK WIRELESS LIFELINE PROGRAM DESCRIPTION
0 LINK WIRELESS Lifeline Service is funded by the Universal Service Fund Lifeline program and
administered by the Universal Service Administrative Company.In order to qualify for enrollment in the Q
LINK WIRELESS Lifeline Program,a person must meet certain eligibility requirements set by each state
where the Q LINK Lifeline Program is offered.These requirements are based on a person’s participation
in a state or federal support program(s)or by meeting certain income requirements based upon the
Income Poverty Guidelines as defined by the US Government.Federal law limits the availability of the Q
LINK Lifeline Program.The 0 LINK Lifeline Program allows one (1)enrollment per “household’.The 0
LINK Lifeline Program permits only one Lifeline benefit per household,therefore,no person currently
living in the household may receive Lifeline benefits from any other Lifeline program offered by another
carrier.Applicants for the 0 LINK Lifeline Program must complete an application form,provide supporting
documentation that they meet the eligibility requirements and certify,under penalty of perjury,that they:
•Are eligible for and currently receive benefits from the public assistance program(s)identified in the
application form.
•Do not currently receive Lifeline support for a telephone line serving their residential address and no
other resident in their household participates in a Lifeline program.
•lf the applicant is already participating in a Lifeline program from another provider,then the applicant
agrees to cancel their current household Lifeline program with the other provider in order to enroll in the 0
LINK Lifeline Program.
Will notify 0 LINK WIRELESS by calling 1-855-QLINK43 (1-855-754-6543)-if and when they no longer
qualify for any of the public assistance programs identified in their application form.
•Will notify 0 LINK WIRELESS of any change of address by calling 1-855-QLJNK43 (1-855-754-6543).
‘Reviewed the information contained in their application and certify that it is true and correct to the best of
their knowledge and belief.
Applicants who do not meet the eligibility requirements will receive written notification,via US Mail,of the
reason for their non-eligibility f in Colorado,DHS will determine and notify applicants if they do not meet
the eligibility requirements).Upon enrollment in the Q LINK Lifeline Program.you will be qualified to
participate for up to one (1)year unless you no longer qualify as an eligible subscriber.To continue your
enrollment in the Q LINK Lifeline Program after the initial year,you must verify annually that you are
qualified for continued enrollment in the Q LINK Lifeline Program as required by your state Public Service
Commission,Public Utility Commission or other agency administering the Q LINK Lifeline Program in your
state.Q LINK WIRELESS will also conduct verification drives according to each state’s rules.If Q LINK
WIRELESS determines during its verification drive,or at any other time,that a customer fails to continue
to qualify for the 0 LINK Lifeline Program,such customer will immediately be deemed ineligible to
participate in the 0 LINK Lifeline Program,will be de-enrolled from the 0 LINK Lifeline Program and will
no longer receive the free monthly minutes.Q LINK Customers who are no longer eligible (for any
reason)for enrollment in the 0 LINK Lifeline Program must immediately notify 0 LINK WIRELESS that
they no longer meet the eligibility requirements for enrollment.A 0 LINK customer’s enrollment may also
be cancelled upon the request of a state and/or federal authority.
0 LINK WIRELESS reserve the right to cancel the enrollment of any customer and/or permanently
deactivate any customer’s 0 LINK WIRELESS phone for fraud,misrepresentation or other misconduct as
determined solely by Q LINK WIRELESS.While participating in the 0 LINK Lifeline Program,a customer
shall not be permitted to sell,rent,give away or in any way allow another person to use the cellular phone
or 0 LINK Lifeline Service provided to him/her by 0 LINK WIRELESS.IT IS A VIOLATION OF FEDERAL
AND STATE LAW TO SELL OR GIVE AWAY THE 0 LINK CELLULAR PHONE OR 0 LINK SERVICE
PROVIDED TO YOU BY 0 LINK WIRELESS.Any violation of this prohibition will be reported to the
appropriate legal authorities for prosecution.In addition,if 0 LINK determines,in its sole discretion,that a
0 LINK WIRELESS customer has violated these prohibitions,0 LINK WIRELESS will then permanently
de-enroll the customer from the Q LINK Lifeline Program,their phone will be permanently deactivated and
the customer’s personal information will be permanently flagged so that the customer may not re-enroll in
the 0 LINK Lifeline Program in the future.If you have any questions,concerns,comments or complaints
regarding the Q LINK Lifeline Program or Lifeline Service,offerings or products,please call 0 LINK
WIRELESS Customer Care at 1-855-QLINK43 (1-855-754-6543).You may also contact your state’s
Public Service Commission/Public Utility Commission.
2.ACTIVATION AND USE OF YOUR 0 LINK WIRELESS PHONE
Upon enrollment in the 0 LINK Lifeline Program,you will receive a pre-activated Q LINK WIRELESS
phone delivered to your home address noted in the application.You must accept the 0 LINK WIRELESS
telephone number assigned to your 0 LINK WIRELESS phone at the time of activation and you will
acquire no proprietary interest in any number assigned to you.The WIRELESS telecommunications
networks used to transmit calls for the 0 LINK WIRELESS Lifeline Service are owned and operated by
various licensed commercial mobile radio service providers (‘Carriers”).The number assigned to your Q
LINK WIRELESS phone at the time of activation will not be changed for any reason unless required by a
Carrier or if the number is lost following the deactivation of your phone.You may not select a number to
be assigned to your 0 LINK WIRELESS phone.Your Q LINK WIRELESS phone can only be used
through 0 LINK WIRELESS,and cannot be activated with any other WIRELESS or cellular service.Q
LINK WIRELESS Lifeline Services are provided at 0 LINK WIRELESS’discretion.Some functions and
features referenced in the Manufacturer’s manual provided with your 0 LINK WIRELESS phone may not
be available on your 0 LINK WIRELESS handset.0 LINK WIRELESS may modify or cancel any 0 LINK
Lifeline Service or take corrective action at any time without prior notice and for any reason,including but
not limited to your violation of these terms and conditions of service.
3.MINUTE RATES,USAGE AND INCLUDED MONTHLY MINUTES.
While you are enrolled in the Q LINK Lifeline Program,you will receive a free monthly allotment of
minutes as provided for the Q LINK Lifeline Program approved in your state and the minute Plan that you
select.The monthly minutes provided by the Q LINK Lifeline Program will vary from state to state.Please
call Q LINK WIRELESS at 1-855-QLINK43(1-855-754-6543)or visit our website for further information.Q
LINK WIRELESS Minute is issued in minute (or unit)increments.Units are deducted from the Q LINK
WIRELESS phone at a rate of one (1)unit per minute or partial minute of use.There is no additional
charge for nationwide long distance.If you are on Plan 1 there is no additional charge for international
long distance to countries designated on our website.In most states,Q LINK offers three plans that are
currently available to all new and existing Q LINK customers.Each of these three plans offers different
benefits,features and carryover options.Again,the monthly minutes provided by the Q LINK Lifeline
Program will vary from state to state.Please call Q LINK WIRELESS or visit www.qlinkwireless.com for
more information on the plans available in your state.
The three plans currently available in most states are:
VoicemailFreeMonthlyUnusedminutesTextMessageFreeInternationalCallerIDminutesIncludedinCarryoverEachCharge**Long Distance Call
Plan Month ***Waiting
Plan 1 68”‘es 3 Texts/i Minute Yes Yes
Plan 2 125”Yes 1 Text/i Minute No Yes
Plan 3 250*No***1 Text/i Minute No Yes
“Plans i and 2 are not available in Colorado.Plans i,2 and 3 are not available in Oklahoma.Please call
Q LINK WIRELESS or visit the Companys website for information on the plans available in your state.
““These text-messaging rates will apply even if a different text-messaging rate is stated on minute cards.
***With Plan 3,your phone will reset to 250 minutes each month when your monthly minutes are
delivered.Unused minutes will not automatically carry over to the next month.You may carry over unused
minutes on this plan for up to three consecutive months if you purchase and add minutes from a Q LINK
Minute Card.By purchasing and adding a Q LINK Minute Card your unused minutes (including your free
monthly allotment and any additional Q LINK Minute Cards)will carry over for three consecutive months
from the date of your last 0 LINK Minute Card redemption.Adding more than one Minute Card at the
same time will NOT extend your minute carry over for more than the three consecutive months.The 3
month carry over is effective from the date of redemption of the last Minute Card redeemed to your
phone.
New 0 LINK customers must choose a plan upon enrollment.Existing 0 LINK customers who wish to
switch plans may do so online or by calling i-855-QLINK43 (i-855-754-6543).If you switch plans before
the 25th day of any given month,the change will be effective the following month.If you switch plans on
or after the 25th day of the month,the change will be effective in the second month following your request
to switch plans.You may use your free monthly allotment of minutes to place or receive calls,to send or
read text messages or multi-media messages and to access the internet (with certain models of phones).
In order to receive your monthly allotment of minutes,you will need to leave your Q LINK WIRELESS
phone powered “ON”during the first few days of each month.If you DO NOT receive your monthly
allotment of minutes because your phone was not “ON”at the beginning of the month or your phone does
not automatically retrieve minutes when powered “ON”you may self-retrieve by following the instructions
below.If for any reason these instructions do not work on your handset,please call us.
Minutes will be deducted for all time during which your 0 LINK WIRELESS phone is connected to,or
using,the wireless system of any Carrier.Use of a wireless system typically begins when you press the
send,’call’or other key to initiate or answer a call and does not end until you press the “end”key or the
call is otherwise terminated.Minutes are deducted for all incoming and outgoing calls,including incoming
call waiting calls,simultaneous calls,calls to toll free numbers,411 611,Customer Care,and to access
your voice mail.For simultaneous calls,such as incoming call waiting and 3-way calling (where available)
minutes will be deducted for each call.Minutes are not deducted for calls to 911,and all handsets will be
able to call 911 even if they have no minutes remaining.Customers in the State of Washington will not be
charged for calls to Customer Care if they dial 611 directly from their handset.For outbound calls,you
may be charged Minutes for incomplete and/or busy-no answer calls.Minutes will be deducted for use of
other services such as text messaging and accessing the 0 LINK WIRELESS Mobile Web (“WAP”).No
credit or refund is given for dropped calls.
4.TEXT MESSAGING.
You may use your free monthly allotment of minutes to send and/or open text messages.Text messages
sent to you by 0 LINK WIRELESS are free of charge.The charge to send or open an incoming text
message using your 0 LINK WIRELESS phone will vary depending upon your plan.Under Plan 1,you
will be charged 0.3 minute per text message for sending and 0.3 minute per text message for opening a
received text message.Under Plans 2 and 3,you will be charged 1 minute per text message for sending
and 1 minute per text message for opening a received text message.If you have exhausted your free
monthly allotment of minutes,you will need to purchase and redeem additional minutes in order to
continue to send text messages and open incoming text messages and to place and receive voice calls.If
you do not want minutes deducted from your Q LINK WIRELESS phone for text messaging,then do not
send text messages or open incoming text messages.Q LINK WIRELESS does not allow international
text messages.Attempting to send international messages could result in service deactivation and de
enrollment from the Q LINK Lifeline Program.Please note that 0 LINK WIRELESS does not generally
participate in Premium SMS services or campaigns.Premium SMS campaigns include activities such as
casting a vote,expressing your opinion,playing a game,subscribing to a service,or interactive television
programs.You should not attempt to participate in Premium SMS campaigns unless it is a 0 LINK
WIRELESS authorized campaign.Any text message you send to a ‘short code”will in all likelihood not go
through.Any charges you may incur because of any attempts to participate in Premium SMS services or
campaigns not authorized by Q LINK WIRELESS are not refundable whether you incur charges as
deductions from your 0 LINK WIRELESS phone or from your credit card.You may purchase from 0 LINK
WIRELESS ring tones,graphics and certain information services.You may utilize multi-media services
with certain 0 LINK WIRELESS models of phones.See 0 LINK WIRELESS Data Services below for
more information.
5.INTERNATIONAL CALLING.
International calling is available.If you selected an International Plan,You may use your Q LINK
WIRELESS phone to make international calls to landlines and some cellular phones in some countries at
no additional charge (see website for available countries and details).The countries where international
calling is available are subject to change at any time without prior notice.In order to place an international
call,you will need to dial the International Long Distance (9LD”)access number and follow the
instructions.Minute deductions for international calls begin the moment the ILD access number is dialed
and apply to dropped calls,misdialed numbers and busy destination numbers.When placing international
calls,you may experience connection failures more frequently than calls made within the United States.Q
LINK WIRELESS will not credit minutes deducted for unsuccessful calls.You will not be able to make or
receive calls on your Q LINK WIRELESS phone when you are located outside of the United States,
Puerto Rico or the U.S.Virgin Islands (the “Coverage Area”).Any attempt to make or receive calls when
you are located outside of the Coverage Area could result in service deactivation and de-enrollment from
the Q LINK Lifeline Program.
6.MINUTE CARDS.
Your Q LINK WIRELESS phone will only operate when you have minutes available on the 0 LINK
WIRELESS phone.If you run out of your free monthly allotment of airtime,you may purchase and add
additional Minute to your phone.See the instructions above for adding airtime.0 LINK WIRELESS
customers may purchase and use any 0 LINK WIRELESS Minute cards,including unlimited minutes for a
specified time period Minute cards,for their 0 LINK WIRELESS phone.Each Q LINK WIRELESS Minute
card includes a set number of minutes and service days that begin to run from the date you add the
Minutes to your 0 LINK WIRELESS phone.Bonus and promotional minutes will not increase with any 0
LINK WIRELESS Unlimited Minute cards.0 LINK reserves the right to modify,adjust and/or eliminate the
extra Bonus minutes at any time in its discretion.Q LINK customers may purchase Minutes at the rate of
100 or less per unit.0 LINK reserves the right to adjust its Minute rates at any time in its sole discretion.
For each 0 LINK WIRELESS airtime,card or PIN purchased at our regular price and added to a 0 LINK
phone,the 0 LINK customer will receive the following:
-
•Minutes on Face of Q Link Card Service Days Price of Card Rate Per Minute
50 30 $9.99 .20
I——
120 30 $19.99 .17
200 30 $29.99 .15
450 30 $59.99 .13
------
One WEEK UNLIMITED Service Card 7 $15.99 N/A
Two WEEK UNLIMITED Service Card 14 $25.99 N/A
7.SERVICE END DATE,DEACTIVATION AND REACTIVATION.
As a Q LINK WiRELESS customer,you will receive 365 service days upon your enrollment and activation
in the 0 LINK Lifeline Program and another 365 service days following each successful annual
verification for your continued program eligibility in the 0 LINK Lifeline Program.If you fail to complete
your annual verification within 90 days of the requited verification date,you will be de-enrolled from the 0
LINK Lifeline Program.Upon de-enrollment from the 0 LINK Lifeline Program,you will cease receiving
the free monthly allotment of airtime.If you are de-enrolled,your phone will remain active and you may
continue to use your phone so long as you have available minutes and service days remaining on your
phone.You may purchase Minute and service days to keep your phone service active.If you are de
enrolled from the 0 LINK Lifeline Program and you allow your remaining service days to expire or go
“past due,”your phone service will be deactivated,you may lose your unused minutes and you will lose
your wireless telephone number.If you choose to reactivate your phone by completing the annual
verification within 60 days after your verification due date,you will be re-enrolled in the program and
continue receiving the free monthly allotment of airtime.
If your service is deactivated,you may reactivate your service by either re-enrolling in the Q LINK Lifeline
Program (if eligible)or purchasing and redeeming a 0 LINK WIRELESS Minute card with service days.
Upon reactivation of your phone,you may be assigned a new telephone number.Any minutes remaining
on your handset at the time of deactivation will be reinstated if your phone is reactivated within 60 days
from the deactivation date.If your phone remains inactive for more than 60 days,you will lose any
remaining airtime.If you have been de-enrolled from the 0 LINK Lifeline Program and are not eligible to
re-enroll but you wish to keep your service active,you must purchase and redeem additional Minute and
service days before the “Service End Date”displayed on your phone.To prevent any interruption in your
phone service.please keep your handset service active by timely completing your annual verification as
required by the 0 LINK Lifeline Program or,if no longer eligible,by purchasing and adding 0 LINK Minute
cards before your Service End Date.
“No Usage”De-Enrollment and Deactivation of Lifeline Service:Regardless of the Service End Date
displayed on your handset,if you exceed 2 months without any Usage (as defined in this section),you will
be de-enrolled from the Q LINK Lifeline Program.“Usage”is defined as any transaction including,but not
limited to,making or receiving a call,sending or opening a text message,downloading data content,
adding Minutes or receiving your free monthly airtime.Upon de-enrollment for non-Usage,you will have
up to a 30-day grace period to reenroll in the 0 LINK Lifeline Program by calling 1-855-QLINK43 (1-855-
754-6543).If you do not re-enroll,use your phone or call Q LINK Customer Care within 30 days of your
de-enrollment,your phone service will be deactivated.In order to reactivate your Q LINK phone and re
enroll in the 0 LINK Lifeline Program,you will need to call 0 LINK Customer Care.Upon successful re
enrollment,you will receive the monthly minutes that you were entitled to receive through the date your
enrollment was cancelled.You will not,however,receive any minutes for the period of time you were not
enrolled in the 0 LINK Lifeline Program.In addition,you will be assigned the service days displayed on
your handset,which are the days you were granted when first enrolled in the program.
8.OUR RIGHT TO TERMINATE YOUR Q LINK WIRELESS LIFELINE SERVICE.
You agree not to give away,resell or offer to resell the 0 LINK Phone or Service provided by the 0 LINK
Lifeline Program.You also agree your 0 LINK Phone will not be used for any other purpose that is not
allowed by this agreement or that is illegal.WE CAN,WITHOUT NOTICE,LIMIT,SUSPEND,OR END
YOUR SERVICE AND DE-ENROLL YOU FROM THE Q LINK PROGRAM FOR VIOLATING THIS
PROVISION OR FOR ANY OTHER GOOD CAUSE,including,but not limited to,if you:(a)violate any of
the terms and conditions of service;(b)lie to us or attempt to defraud us;(c)allow anyone to tamper with
your 0 LINK Phone;(d)threaten or commit violence against any of our employees or customer service
representatives;(e)use vulgar and/or inappropriate language when interacting with our representatives;
(f)steal from us;(g)harass our representatives;(h)interfere with our operations;(i)engage in abusive
messaging,emailing or calling;(j)modify your device from its manufacturer’s specification;or (k)use the
service in a way that adversely affects our network or the service available to our other customers.We
reserve the right to,without notice,limit,suspend or end your service for any other operational or
governmental reason.In addition to permanently terminating your Service,criminal offenses (i.e.,selling
or giving away your Service;threatening violence,etc.)will be reported to the appropriate legal authorities
for prosecution.
9.UNAUTHORIZED USAGE;TAMPERING.
The Q LINK WIRELESS handset is provided exclusively for use by you,the end consumer with the Q
LINK WIRELESS Lifeline Service available solely in the United States,Puerto Rico and the U.S.Virgin
Islands.Any other use of your Q LINK WIRELESS handset,including without limitation,any resale,
unlocking and/or re-flashing of the handset is unauthorized and constitutes a violation of your agreement
with Q LINK WIRELESS.You agree not to unlock,re-flash,tamper with or alter your Q LINK WIRELESS
phone or its software,enter unauthorized PIN’s,engage in any other unauthorized or illegal use of your Q
LINK WIRELESS phone or the Service,or assist others in such acts,or to sell and/or export Q LINK
WIRELESS handsets outside of the United States.These acts violate 0 LINK WIRELESS’rights and
state and federal laws.Improper,illegal or unauthorized use of your Q LINK WIRELESS phone is a
violation of this agreement and may result in immediate discontinuance of Services and legal action
against you.Q LINK WIRELESS will prosecute violators fully of the law.You agree that any violation of
this agreement through your improper,illegal or unauthorized use or sale of your 0 LINK WIRELESS
phone shall entitle Q LINK WIRELESS to recover liquidated damages from you in an amount of not less
than $5,000 per 0 LINK WIRELESS handset purchased,sold,acquired or used in violation of this
agreement.
Some Q LINK WIRELESS handsets have SIM cards.If your 0 LINK WIRELESS phone has a SIM card,
then you agree to safeguard your SIM card and not to allow any unauthorized person to use your SIM
card.You agree not to allow any other person to,directly or indirectly alter,bypass,copy,deactivate,
remove,reverse-engineer or otherwise circumvent or reproduce the encoded information stored on.or
the encryption mechanisms of,your SIM card.You may not remove your SIM Card from your phone nor
place the SIM Card in any other phone.Doing so could result in the immediate termination of your service
and de-enrollment from the Q LINK Lifeline Program.The Carriers,0 LINK WIRELESS,or its service
providers,may,from time to time,remotely update or change the encoded information on your SIM card.
Your 0 LINK WIRELESS phone is restricted from operating when you are located anywhere outside of
the United States,Puerto Rico or the U.S.Virgin Islands,including offshore or in international waters.In
the event of suspension for this or any other unauthorized usage,you will not be entitled to receive any
refunds for unused airtime.
10.COVERAGE MAPS AND ROAMING.
You will find coverage maps on our website.These maps are for general informational purposes only.
Actual coverage and service areas may vary from the maps and may change without notice.0 LINK
WIRELESS does not guarantee coverage or service availability.Even within a coverage area,factors
such as terrain,weather,structures,foliage,signal strength.traffic volumes,service outages,network
changes,technical limitations,and your equipment may interfere with actual service,quality and
availability.“Roaming”occurs when a subscriber of one wireless service provider uses the facilities of
another wireless service provider.Roaming most often occurs when you make and receive calls outside
of the network coverage area of your service provider.When your 0 LINK WIRELESS phone is roaming,
an indicator light on your handset may display the word “Roam”or “RM”on the screen while the phone is
not in use.There are no additional charges for domestic roaming calls for the Q LINK WIRELESS phone
you were provided.Availability,quality of coverage and Services while roaming are not guaranteed.
11.LIMITATIONS OF SERVICE AND USE OF EQUIPMENT.
Service is subject to transmission limitations caused by certain equipment and compatibility issues,
atmospheric,topographical and other conditions.Further,service may be temporarily refused,limited,
interrupted or curtailed due to system capacity limitations,technology migration or limitations imposed by
the Carrier,or because of equipment modifications,upgrades,repairs or relocations or other similar
activities necessary or proper for the operation or improvement of the Carrier’s radio telephone system.At
any time.Q LINK WIRELESS reserves the right to substitute and/or replace any Q LINK WIRELESS
equipment (including handsets)with other 0 LINK WIRELESS equipment including handsets of
comparable quality.Some functions and features referenced in the Manufacturer’s manual for a particular
Q LINK WIRELESS handset may not be available on your phone.Q LINK WIRELESS does not warrant
or guarantee availability of network or of any Services at any specific time or geographic location or that
the Services will be provided without interruption.Neither 0 LINK WIRELESS,nor any Carrier,shall have
any liability for service failures,outages or limitations of Service.Because of the risk of being struck by
lightning,you should not use your 0 LINK WIRELESS phone outside during a lightning storm.You should
also unplug the 0 LINK WIRELESS phone power cord and charger to avoid electrical shock and/or fire
during a lightning storm.
12.WARRANTY EXCHANGE AND LOST OR STOLEN PHONE POLICY.
Limited Warranty Exchange Policy:0 LINK WIRELESS customers shall have up to one year from the
activation date of their phone to return any defective phone to 0 LINK WIRELESS.0 LINK WIRELESS
will exchange a defective phone for a new or refurbished phone,at Q LINK’s discretion,during this period
only pursuant to the terms of the Limited Warranty set forth below.For a defective phone replacement,
call 0 LINK WIRELESS Technical Customer Service.
13.LOST OR STOLEN PHONE POLICY:
For any lost or stolen 0 LINK WIRELESS phone,you may request and receive only one replacement
phone per customer.The replacement phone will be a refurbished phone.All reported lost and stolen
phones will be permanently deactivated.The replacement phone will include only 10 minutes of lost
airtime.Any additional Minutes that you may have had on your lost phone will not be replaced.In the
event you lose your replacement phone or it is stolen,you will need to purchase an additional phone.If a
phone is lost or stolen while in transit to the customer before the customer receives the phone,the lost
phone and minutes may be replaced as a onetime courtesy in 0 LINK’s sole discretion.
14.DISCLAIMER OF WARRANTIES.
EXCEPT FOR THE LIMITED WARRANTY SET FORTH IN THESE TERMS AND CONDITIONS,AND TO
THE EXTENT PERMITTED BY LAW,THE SERVICES AND DEVICES ARE PROVIDED ON AN “AS IS”
AND ‘WITH ALL FAULTS”BASIS AND WITHOUT WARRANTIES OF ANY KIND.WE MAKE NO
REPRESENTATIONS OR WARRANTIES,EXPRESS OR IMPLIED,INCLUDING ANY IMPLIED
WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CONCERNING
YOUR SERVICE OR YOUR DEVICE.WE CANNOT PROMISE UNINTERRUPTED OR ERROR-FREE
SERVICE AND DO NOT AUTHORIZE ANYONE TO MAKE ANY WARRANTIES ON OUR BEHALF.WE
DO NOT GUARANTEE THAT YOUR COMMUNICATIONS WILL BE PRIVATE OR SECURE;IT IS
ILLEGAL FOR UNAUTHORIZED PEOPLE TO INTERCEPT YOUR COMMUNICATIONS,BUT SUCH
INTERCEPTIONS CAN OCCUR.
15.HEARING,VISUAL OR SPEECH IMPAIRED ACCOMMODATIONS.
Any hearing,visual or speech impaired persons interested in applying for a specially equipped 0 LINK
WIRELESS must call Q LINK WIRELESS and specify the need(s)to an agent and 0 LINK WIRELESS
will make every effort to assist such customer in obtaining a handset that is in compliance with all
applicable laws,rules,and regulations.
16.EMERGENCY CALLS.
Q LINK WIRELESS customers have access to 911.Occasionally,however,callers may attempt to call
911 in areas where there is no wireless coverage.If there is no wireless coverage,your call to 91 1 may
not go though and you should dial 911 from the nearest landline phone.
17.DATA SERVICES.
With certain Q LINK WIRELESS phone models,you can download ring tones,graphics,access
information services such as news,weather and sports (Information Services’)and utilize multi-media
messaging services (“MMS”)(ringtones,graphics,Information Services and MMS are collectively referred
to as “Data Services”)through our wireless Mobile Web (‘WAP’).Data Services are additional Services
offered by us at an additional charge in the form of a debit of minutes for your use of such services.
Accessing and Purchasing Data Services.In order to purchase,download or access Data Services,your
handset must have active service and sufficient available Minutes.Your handset will not let you open the
WAP browser without a remaining minute balance of at least 10 minutes.Each time you access our
wireless WAP with your handset’s browser,0.5 units per minute will be deducted from your handset
(“Access Charges”).Access Charges are deducted in full minute increments.WAP access of less than 60
seconds is rounded up to the next full minute.Access Charges begin when your handset makes a data
connection.This should occur shortly after you open your browser,send or receive a multi-media
message (e.g.,a picture),initiate a content download,view subscribed Information Services or if WAP
access is initiated for any other purpose.Access Charges end when the data connection terminates.This
should occur shortly after you close your browser,successfully receive or send a multi-media message
(e.g.,a picture),after a successful content download or after any other closure of a WAP session.The
WAP access duration and the related Access Charges are NOT determined from the exact moment you
press a button on your handset to open or close the browser.
In addition to the Access Charges,there will be an additional one-time charge for any content you select
to download (“Content Charge”).The Content Charges vary depending on the type of content.You will be
advised of the Content Charges prior to finalizing your purchase.The Data Services you purchase and
download may only be used or viewed on the handset for which they were purchased and cannot be
transferred to any other device,including a new or replacement handset.
Modifications,Interruptions,or Discontinuation of Data Service.Q LINK WIRELESS does not guarantee
the availability of Data Services on all of its phone models nor does it guarantee the availability of Data
Services at all times.Q LINK WIRELESS reserves the right to modify,suspend,interrupt,discontinue or
permanently cancel Data Services,or portions thereof,without notice.Data Services are not available in
certain areas.0 LINK WIRELESS is not responsible and will not be liable for any modifications,
interruptions or discontinuation of the Data Services or for any failure in receipt of the purchased Data
Services.If the Data Services,or any part thereof,for which you subscribe,are modified,interrupted,
discontinued or canceled,you will not receive a refund or credit from Q LINK WIRELESS for any
remaining used or unused subscription time.If you cancel or attempt to cancel a Data Service download,
a subscription purchase or a multi-media message in progress,or if this process is otherwise interrupted
through no action on your part,you may nevertheless be charged in accordance with the terms and
conditions set forth herein.
18.LIMITATION OF LIABILITY.
0 LINK and Q LINK WIRELESS are not liable to you for any direct or indirect,special,incidental,
consequential,exemplary or punitive damages of any kind,including lost profits (regardless of whether it
has been notified such loss may occur)by reason of any act or omission in its provision of equipment
and/or Services.Q LINK and 0 LINK WIRELESS will not be liable for any act or omission of any other
company furnishing a part of our Services or any equipment or for any damages that result from any
service or equipment provided by or manufactured by third parties.When your Q LINK WIRELESS phone
is returned to Q LINK WIRELESS for any reason.0 LINK WIRELESS is not responsible and shall not be
liable to you or anyone else for any personal information such as user names,passwords,contacts,
pictures,SMS,MMS and/or additional downloads you may have stored on your phone or which may
remain on your phone.
19.INDEMINIFICATION.
You agree to indemnify and hold harmless 0 LINK WIRELESS and All Affiliated or related companies
from any and all liabilities,penalties,claims,causes of action,and demands brought by third parties
(including the costs,expenses,and attorneys’fees on account thereof)resulting from your use of a Q
LINK WIRELESS phone and/or use of the Q LINK WIRELESS Lifeline Services,whether based in
contract or tort (including strict liability)and regardless of the form of action.
20.BINDING ARBITRATION.PLEASE READ THIS SECTION CAREFULLY AS IT AFFECTS RIGHTS
THAT YOU MAY OTHERWISE HAVE.IT PROVIDES FOR RESOLUTION OF ALL DISPUTES AND
CLAIMS (INCLUDING ONES THAT ALREADY ARE THE SUBJECT OF LITIGATION),EXCEPT FOR
CLAIMS CONCERNING THE UNAUTHORIZED RESALE,EXPORT,ALTERATION,AND/OR
TAMPERING OF YOUR Q LINK WIRELESS PHONE,ITS SOFTWARE,THE SERVICE AND/OR PIN
NUMBERS,THROUGH ARBITRATION INSTEAD OF SUING IN COURT IN THE EVENT THE PARTIES
ARE UNABLE TO RESOLVE A DISPUTE OR CLAIM.ARBITRATION IS BINDING AND SUBJECT TO
ONLY A VERY LIMITED REVIEW BY A COURT.THIS ARBITRATION CLAUSE SHALL SURVIVE
TERMINATION OF Q LINK WIRELESSTM AGREEMENT WITH YOU.
This provision is intended to encompass all disputes or claims arising out of your relationship with 0 LINK
WIRELESS,arising out of or relating to the Q LINK Lifeline Service or any equipment used in connection
with the 0 LINK Lifeline Service (whether based in contract,tort.statute,fraud,misrepresentation or any
other legal theory).Nothing contained in this arbitration provision shall preclude Q LINK WIRELESS from
bringing claims concerning the unauthorized resale,export,alteration,and/or tampering of your Q LINK
WIRELESS phone,its software,the 0 LINK Lifeline Service and/or PIN numbers,in state or federal court.
References to you and Q LINK WIRELESS include our respective subsidiaries,affiliates,predecessors in
interest,successors,and assigns.All claims,except those excluded above,will be resolved by binding
arbitration where permitted by law.You must first present any claim or dispute to Q LINK WIRELESS by
contacting Customer Care to allow an opportunity to resolve the dispute prior to initiating arbitration.The
arbitration of any dispute or claim shall be conducted in accordance with the American Arbitration
Association (“AAA”)under the Commercial Dispute Resolution Procedures and the Supplementary
Procedures for Consumer Related Disputes (collectively,“AAA Rules’),as modified by this agreement.
You and Q LINK WIRELESS agree that use of the Q LINK Lifeline Service evidences a transaction in
interstate commerce and this arbitration provision will be interpreted and enforced in accordance with the
Federal Arbitration Act and federal arbitration law.All issues are for the arbitrator to decide,including the
scope of this arbitration clause,but the arbitrator is bound by the terms of this agreement.You and Q
LINK WIRELESS agree that any arbitration will be conducted on an individual basis and not on a
consolidated,class wide or representative basis.Further,you agree that the arbitrator may not
consolidate proceedings or more than one person’s claims,and may not otherwise preside over any form
of a representative or class proceeding,and if this preclusion of consolidated,class wide or
representative proceedings is found to be unenforceable,then this entire arbitration clause shall be null
and void.All fees and expenses of arbitration will be divided between you and Q LINK WIRELESS in
accordance with the AAA Rules,except that Q LINK WIRELESS will reimburse you for the filing fee in the
event you prevail in the arbitration.Each party will bear the expenses of its own counsel,experts,
witnesses,and preparation and presentation of evidence.If for any reason this arbitration provision is
deemed inapplicable or invalid,otto the extent this arbitration provision allows for litigation of disputes in
court,you waive to the fullest extent permitted by law,(i)the right to a trial by jury and (ii)any claims for
punitive or exemplary damages.Unless Q LINK WIRELESS and you agree otherwise,the location of any
arbitration shall be Dania,Florida.Except where prohibited by law,Q LINK WIRELESS and you agree
that no arbitrator has the authority to award punitive damages or any other damages not measured by the
prevailing party’s actual damages.Neither you not Q LINK WIRELESS shall disclose the existence,
contents,or results of any arbitration,except to the extent required by law.Judgment on the award
rendered may be entered by any court of competent jurisdiction.
This Agreement shall be construed under the laws of Florida,without regard to its choice of law rules,
except for the arbitration provision contained in these Terms and Conditions,which will be governed by
the Federal Arbitration Act.This governing law provision applies no matter where you reside,or where
you use or pay for the Services.
21.PRIVACY POLICY.
To view the 0 LINK WIRELESS Privacy Policy please refer to the 0 LINK WIRELESS website.
22.LIMITED WARRANTY.
Your 0 LINK phone is covered by a one year limited warranty,set forth below,administered by 0 LINK.A
reconditioned 0 LINK phone also has a one year limited warranty provided by 0 LINK and all 0 LINK
accessories have a 90-day limited warranty against defects in materials and workmanship under normal
use by the purchaser.You may obtain warranty service directly from Q LINK.
How to obtain Warranty Service.To obtain warranty service from 0 LINK on a new or reconditioned
phone or 0 LINK accessories,please contact Technical Support from a landline or another phone in
order to avoid using up your minutes.If your problem cannot be resolved over the phone,our 0 LINK
technicians will provide you with a Ticket Number,which you will use to send your phone and/or
accessories to the designated Q LINK Lifeline Service Center for repair or replacement,at Q LINK ‘s
discretion.
Terms of Limited Warranty .Q LINK warrants to you,the Customer,that your Q LINK cellular phone
(“Product”)is free from defects in material and workmanship that result in Product failure during normal
usage,according to the following terms and conditions:
1.The limited warranty for the Product extends for ninety (90)days beginning on the first date of
activation of your phone.
2.The limited warranty extends only to the original customer (“Consumer”)of the Product.
3.The limited warranty is not assignable or transferable to any subsequent end-user.
4.During the limited warranty period,Q LINK will replace or repair,at Q LINK’s sole option,any defective
Products or parts (except as excluded below),or any Products or parts that will not properly operate for
their intended use (except as excluded below)with new or refurbished replacement Products or parts if
such replacement or repair is needed because of Product malfunction or failure during normal usage.Q
LINK may,at its sole discretion,replace the Product with a refurbished phone of the same model if
available,or if not available,of a comparable model of phone.The limited warranty does not cover loss of
personal information,passwords,contacts,music,ringtones,pictures,videos,applications or other
content,memory cards,software,defects in appearance,cosmetic,decorative or structural items,
including framing,and any non-operative parts.Q LINK’s limit of liability under this limited warranty is the
actual cash value of the Product at the time the Consumer returns the Product to Q LINK for repair,
determined by the price paid by the Consumer for the Product less a reasonable amount for usage.Q
LINK shall not be liable for any other losses or damages.These remedies are the Consumer’s exclusive
remedies for breach of warranty.
5.The Consumer shall have no coverage or benefits under this limited warranty if any of the following
conditions are applicable:
a.The Product has been subjected to abnormal use,abnormal conditions,improper storage,exposure to
moisture or dampness,unauthorized modifications,unauthorized connections,unauthorized repair,
misuse,neglect,abuse.accident,alteration,improper installation,or other acts which are not the fault of
Q LINK,including damage caused by shipping.
b.The Product has been damaged from external causes such as collision with an object,or from fire,
flooding,sand,dirt,windstorm,lightning,earthquake or damage from exposure to weather conditions,an
Act of God,or battery leakage,theft,blown fuse,or improper use of any electrical source.
c.Q LINK was not advised in writing by the Consumer of the alleged defect or malfunction of the Product
within ten (10)days after the expiration of the applicable limited warranty period.
d.The Product serial number plate or the enhancement data code has been removed,defaced or altered.
e.The defect or damage was caused by the defective function of the cellular system or by inadequate
signal reception by the external antenna,or viruses or other software problems introduced into the
Product.
f.The Product is outside of the Limited Warranty period.
6.Q LINK does not warrant uninterrupted or error-free operation of the Product or service.Q LINK cannot
and does not guarantee that your communications will be private or secure;it is illegal for unauthorized
people to intercept your communications,but such interceptions can occur.
7.If a problem develops during the limited warranty period,the Consumer shall contact Q LINK Customer
Care for repair or replacement processing of the Product.0 LINK shall,at its discretion,provide a
replacement product that may consist of a refurbished phone of the same model if available,or of a
comparable model.
8.You (the Consumer)understand that the product may consist of refurbished equipment that contains
used components,some of which have been reprocessed.The used components comply with Product
performance and reliability specifications.
9.0 LINK EXPRESSLY DISCLAIMS ANY IMPLIED WARRANTY OF MERCHANTABILITY,OR FITNESS
FOR A PARTICULAR PURPOSE OR USE.THE FOREGOING LIMITED WARRANTY IS THE
CONSUMER’S SOLE AND EXCLUSIVE REMEDY AND IS IN LIEU OF ALL OTHER WARRANTIES.
EXPRESS OR IMPLIED.Q LINK SHALL NOT BE LIABLE FOR SPECIAL,INCIDENTAL,PUNITIVE OR
CONSEQUENTIAL DAMAGES,INCLUDING BUT NOT LIMITED TO LOSS OF ANTICIPATED
BENEFITS OR PROFITS,LOSS OF SAVINGS OR REVENUE,LOSS OF DATA,PUNITIVE DAMAGES,
LOSS OF USE OF THE PRODUCT OR ANY ASSOCIATED EQUIPMENT,COST OF CAPITAL,COST
OF ANY SUBSTITUTE EQUIPMENT OR FACILITIES,DOWNTIME.THE CLAIMS OF ANY THIRD
PARTIES,INCLUDING CUSTOMERS,AND INJURY TO PROPERTY,RESULTING FROM THE
PURCHASE OR USE OF THE PRODUCT OR ARISING FROM BREACH OF THE WARRANTY,
BREACH OF CONTRACT,NEGLIGENCE,STRICT TORT,OR ANY OTHER LEGAL OR EQUITABLE
THEORY,EVEN IF 0 LINK KNEW OF THE LIKELIHOOD OF SUCH DAMAGES.0 LINK SHALL NOT
BE LIABLE FOR DELAY IN RENDERING SERVICE UNDER THE LIMITED WARRANTY,LOSS OF USE
DURING THE PERIOD THAT THE PRODUCT IS RETURNED FOR REPLACEMENT OR WARRANTY
SERVICE OR FOR THE LOSS OR UNAUTHORIZED USE OF CUSTOMER PASSWORDS,PERSONAL
INFORMATION,CONTACTS.PICTURES,VIDEOS,APPLICATIONS,MUSIC.RINGTONES OR OTHER
CONTENT.
10.Some states do not allow the exclusion or limitation of incidental and consequential damages,so
certain of the above limitations or exclusions may not apply to you (the Consumer).This limited warranty
gives the Consumer specific legal rights and the Consumer may have other rights,which vary from state
to state.
11.Q LINK neither assumes nor authorizes any authorized service center or any other person or entity to
assume for it any other obligation or liability beyond that which is expressly provided for in this limited
warranty including the provider or seller of any extended warranty or service agreement.
12.This is the entire warranty between 0 LINK and the Consumer,and supersedes all prior and
contemporaneous agreements or understandings,oral or written,relating to the Product,and no
representation,promise or condition not contained herein shall modify these terms.
13.This limited warranty allocates the risk of failure of the Product between the Consumer and Q LINK.
The allocation is recognized by the Consumer and is reflected in the purchase price.
Certain mobile phone features may not be available throughout the entire network or their functionality
may be limited.All plan rates,features,functionality and other product specifications are subject to
change without notice or obligation.Color of phones may vary.All talk and standby times are quoted in
Digital Mode and are approximate.
O LINK and Q LINK WIRELESS are registered trademarks of Q LINK WIRELESS,LLC.A subsidiary of
Quadrant Holdings Group LLC.
EXHIBIT 5
2010 Lifeline Participation Rates by State
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2—
1
5
-
1
1
EXHIBIT 6
Wire Centers and Coverage Maps
WC_Code
BWWI DXX
CLFKI DXX
CRALI DXX
FRFDWAXA
FRTNWAXX
GRFDWAXX
HOPE IDXX
H RSNI DXA
HYLKIDXX
NWPTWAXX
PLMRIDXX
PN H RI DXA
PRRVIDXX
PSFLIDXX
RCFRWAXB
RTHDIDXX
SNPNIDXX
SPLKIDXX
ALBNIDXC
AMFLIDMA
B LSSI DMA
BOISIDMA
BOISIDNW
BOISIDSW
BOISIDWE
BRLYI DMA
BRUNIDXC
BUHLIDMA
CLWLI DMA
CNCLIDXC
CRGMIDO1
CSCDIDXC
CSFRI DMA
DECLIDMA
DNLYIDXC
EAGLIDNM
EDHZIDMA
EMMTIDMA
FILRIDAA
FRLDIDXX
GDNGIDMA
GENSIDXX
GLFYIDCO
GLFYIDMA
HALYI DMA
HGMNIDMA
HLSTIDXC
HMDLIDXC
HRBNIDXC
]ERMIDNM
KMBRIDMA
KTCH ID MA
KUNAIDMA
LAPWIDO1
LENRIDXA
LSTNIDSH
MCCLIDXC
M DTN DMA
MDVAIDXC
MELBIDMA
MNDKIDXC
MRDNIDMA
MRNGIDXC
M RTGID MA
MSCWIDXX
MTHOIDMA
MTHOIDSO
NMPAIDMA
NPMOIDMA
NRLDtDXC
NUARIDXC
NWMDIDXC
OKLYIDXC
PARMIDXC
PAULIDXC
PECKIDXX
PYHIDMA
RFRVIDXC
RKLDIDXC
RP RTI DXC
SHSHIDMA
SOMTIDXC
STARIDNM
SWETI DXC
TROYIDXX
TWFLI DMA
UNTWWAXA
WESRTDMA
WLDRIDXC
WNDLIDMA
MALTI DXC
RCFDIDXC
ABRDIDXC
ARCOIDXC
BLFTIDMA
FRTHIDMA
HAM RDXC
HOWEIDXC
IDFLIDMA
INKMIDMA
LS MN IDMA
PCTLIDMA
PCTLIDNO
RB RTI DMA
RGBYIDMA
RIRIIDMA
RVSDIDMA
RXBGIDMA
S H LYIDMA
SPFDIDXC
STATIDMA
STNLIDXC
TRTNIDXC
DWNYIDMA
DYTNIDMA
FKLNIDMA
LHSPIDMA
MCCMIDMA
MLCYIDXC
MTPLIDMA
PARSIDXC
PSTNIDMA
DRGSIDMA
0
R
I
0
0
N
M0
N
I
A
4
A
Ri
q
t
a
r
a
W
V
0
M
I
N
(
Wy
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Co
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,
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?
P
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f
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II
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VA
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A
--
)r
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g
o
n
0
It
I
I.
0
II
W
V
0
M
I
It
C
:
Wy
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m
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g
CI
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V
A
Mo
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tna
Wy
o
m
i
n
g