20220614Application.pdf

Friend, Hudak & Hanis, LLP
Attomeys at Law
Three Ravinia Drive I Suite 1700
Atlanta, GA 30346
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Enclosurecc: Jim Carpenter
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[e-mail]
June 14,2022
Via Emai!
Jan Noriyuki
Commission Secretary
ldaho Public Utilities Commission
11331 E. Chinden Blvd., Building 8, Suite 201-A
Boise, ldaho 83714 TE C- r- a-L-o I
Telrite Corporation d/b/a Life Wireless
Application for Designation as an Eligible Telecommunications Carrier
Dear Jan Noriyuki:
Enclosed please find for filing the Application of Telrite Corporation d/b/a Life Wireless for
Designation as an Eligible Telecommunications Canier in the State of ldaho.
lf you have any questions or would like to discuss this matter, please feel free to contact
me at the contact information on this letterhead. Thank you for your assistance.
Sincerely,
.. ,, il -ni/\ [lil'..r;.1i'*!*]q:j.Ul'ifrrlenci H udakHarris
rr/1N^
Re:
Susan J. Berlin
BEFORE THE
IDAHO PUBLIC UTILITIES COM1VIISSION
In the Matter of the Application of
Telrite Corporation dlbl a Life Wireless
for Designation as an Eligible
Telecommunications Carrier
cAsENo. fE (--T- 7*ol
APPLICATION OF TELRITE CORPORATION DIBIALIFE WIRELESS
FOR DESIGNATION AS AIt ELIGIBLE TELECOMMUNICATIONS CARRIER
Susan J. Berlin
Friend, Hudak & Hanis, LLP
Three Ravinia Drive, Ste. 1700
Atlanta, GA 30346
Phone: [phone]
Email: SBerl [e-mail]
Attorneys for Telrite Corporation dlblaLife
Wireless
June 14,2022
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TABLE OF CONTENTS
TNTRODUCTION
BACKGROUND.
STATUS TO TELRITE................
A. Advantages of Telrite's Lifeline Services.....
B. Benefits of Competitive Choice
C. Impact on the Universal Service Fund..........
ur. CONCLUSION...........
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.....6
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III.
IV.
A. Company Overview
THE COMMISSION HAS THE AUTHORITY TO DESIGNATE
WIRELESS ETCS FOR THE LIFELINE PROGRAM ..,..7
TELRITE SATISFIES THE REQUIREMENTS FOR DESIGNATION
AS AN ETC UNDER 47 C.F.R. $ 54.201
A. Telrite Will Provide Service via Resale Consistent with
the FCC's Forbearance of the Facilities Requirement................. ........ 9
B. Telrite Will Advertise the Availability of Its Service and Charges
in a Manner Reasonably Designed to Reach Lifeline-Eligible Consumers.......... l2
TELzuTE SATISFIES THE ADDITIONAL REQUIREMENTS
FOR ETC DESIGNATION UNDER 47 CFR $ 5a.202(a) .......... 13
A. Service Commitment throughout the Proposed Designated
Service Area..........l3
Telrite Has the Ability to Remain Functional in Emergency Situations .............. l3
Telrite Will Satisff Applicable Consumer Protection and
Service Quality Standards.. ........14
Telrite Is Financially and Technically Capable t4
t5Telrite's Proposed Lifeline Offering.....
Telrite's Processes Comply with Lifeline Verification and
Enrollment Processes, and the Company Is Committed to
Preventing Waste, Fraud, and Abuse of the Lifeline Program ... l6
VI. THE PUBLIC TNTEREST WILL BENEFIT FROM GRANTTNG ETC
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B.
C.
D.
E.
F.
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TABLE OF EXHIBITS
Exhibit A - Certificate of Authority to Transact Business in Idaho....
Exhibit C - Tclrite's Proposed Lifoline Serviee Packago for [daho......
Exhibit D - List of Current Telrite Key Oflicers and 1Vlanagement.............
Exhibit E - Officer Certilication of Veracity of Factu in Application
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of
Telrite Corporation dlb I a Life Wireless
for Designation as an Eligible
Telecommunications Carrier
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CASE NO.
APPLICATION OF TELRITE CORPORATION DIBIALIFE WIRELESS
FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER
L INTRODUCTION
Telrite Corporation dlb/aLife Wireless ("Telrite" or the "Company"), by its undersigned
counsel, and pursuant to Section zla@)Q) of the Communications Act of 1934, as amended (the
"Act"),1 sections 54.101 through 54.207 of the rules of the Federal Communications Commission
("FCC"),2 and the rules and regulations of the Idaho Public Utilities Commission ("Commission")
hereby submits this Application for Designation as an Eligible Telecommunications Carrier
("ETC") in the State of Idaho for the limited purpose of receiving universal service support to
providewireless services to low-income Idaho households as part of the Lifeline program.
Telrite does not seek access to funds from other federal Universal Service Fund
("USF") programs such as high-cost support or Tribal Link-Up. Telrite requests that its
designation as an ETC include the authority to participate in and receive reimbursement from the
Idaho Telephone Service Assistance Program QTSAP).
' 47 u.s.c. g 2la(e)(2).
2 47 c.F.R. g$ 54.lol-54.207.
4
As demonstrated herein, Telrite meets all the statutory and regulatory requirements for
designation as an ETC in Idaho, including the requirements for ETCs participating in the Lifeline
program as outlined in the various FCC Lifeline Orders.3
All correspondence, communications, pleadings, notices, orders and decisions relating to
this Application should be sent to:
Susan J. Berlin
Friend, Hudak & Harris, LLP
Three Ravinia Drive, Suite 1700
Atlanta, GA 30346
Phone: [phone] Ext. I 15
Fax: [phone]
Email: [e-mail]
with a copy to
Jim Carpenter, Division President
Telrite Holdings
I I100 Alcovy Road
Covington, GA 30014
Phone: [phone]
Fax: [phone]
Email: iim lrite.corn
3 See Lifeline and Link Up Reform and Modernization, Lifeline and Link (Jp, Federal-State Joint
Board on Universal Service, Advancing Broadband Availability Through Digital Literacy
Training, WC DocketNo. I l-42, WC DocketNo.03-109, CC DocketNo.96-45, WC DocketNo.
12-23, Report and Order and Further Notice of Proposed Rulemaking, FCC 12-l I (rel. Feb. 6,
2012) ("2012 Lifeline Reform Order"); Lifeline ond Link Up Reform and Modernization,
Telecommunications Catiers Eligiblefor Universol Service Support, Connect America Fund,WC
Docket Nos. ll-42,09-197, 10-90, Second Further Notice of Proposed Rulemaking, Order on
Reconsideration, Second Report and Order, and Memorandum Opinion and Order, FCC 15-71
(rel. June 22, 2015) (*2015 Lifeline Reform Order"); Lifeline and Link Up Reform and
Modernization, Telecommunications Carriers Eligible for Universal Service Support, Connect
America Fund, WC Docket Nos. ll-42, 09-197, 10-90, Third Report and Order, Further Report
and Order, and Order on Reconsideration, FCC 16-38 (rel. April 27,2016) (*2016 Lifeline
Modernization Order"\; Bridging the Digital Dividefor Low-Income Consumers, Lifeline and Link
Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service
Support, WC Docket Nos. 17-287, ll-42,09-197, Order on Reconsideration, Memorandum
Opinion and Order, FCC 17-155 (rel. Dec. 1,2017) ("2017 Lifeline Ordef').
5
II. BACKGROUND
Granting ETC status to Telrite will benefit the public interest by making the Company's
services available to a broad range of low-income consumers. Telrite is an established provider of
resold wireless telecommunications. In addition, Telrite has demonstrated, since it began wireless
Lifeline operations in 2010, its ability to successfully provide high-quality Lifeline services to low-
income consumers in its existing ETC-designated service areas in otherjurisdictions. Accordingly,
the Company respectfully requests that the Commission expeditiously grant this Petition.
A. Company Overview
Telrite is a Georgia corporation with its principal offices located at4l13 Monticello Street,
Covington, Georgia 30014. Documentation of Telrite's authority to transact business in Idaho as
a foreign corporation is included as ElhitritA.
Telrite is an established provider of both wireline and wireless telecommunications
services. The Company has operated as a wireline provider for over twenty years.
In October 2010, Telrite began offering wireless Lifeline services. For its Lifeline
services, Telrite operates as a reseller and uses the networks of its underlying service providers, T-
Mobile and AT&T Mobility, to provide service to its subscribers. It offers Lifeline services using
the dlbla "Life Wireless." Telrite is currently designated as a wireless ETC in the following
jurisdictions: Arizona, Arkansas, California, Colorado, Georgia, Illinois, Indiana, Iowa, Kansas,
Kentucky, Louisiana, Maine, Maryland, Michigan, Minnesota, Missouri, Nebraska, Nevada, New
York, North Dakota, Ohio, Oklahoma, Pennsylvania, Rhode Island, South Carolina, Texas, Utah,
Vermont, Washington, Wisconsin, West Virginia, Puerto Rico, and the United States Virgin
Islands.
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As described herein, Telrite meets the requirements for ETC designation. Additionally,
designation of Telrite as an ETC in Idaho serves the public interest. Telrite thereforerequests
that the Commission designate it as an ETC throughout the State of Idaho for the purposes of
providing basic Lifeline services.
m.THE COMMISSION HAS THE AUTHORITY TO DESIGNATE WIRELESS ETCS
FOR THE LIFELINE PROGRAM
Section zla@)Q) of the Act provides state public utility commissions with the "primary
responsibility" for the designation of ETCs.a Under the Act, a state public utility commission with
jurisdictional authority over ETC designations may, in the case of an area served by a rural
telephone company - and shall, in the case of all other areas - designate a common carrier as an
ETC if the carrier satisfies the requirements of Section 2la(e)(l) which states:
A common carrier designated as an eligible telecommunications carrier... shall be
eligible to receive universal service support in accordance with section 254 and
shall, throughout the service area for which the designation is received -
(A) offerthe servicesthatare supported bythe Federal universal service support
mechanism under section 254(c), either using its own facilities or a combination of
its own facilities and resale of another carrier's services (including the service
offered by another eligible telecommunications carrier); and
(B) advertise the availability of such services and the charges therefore using
media of general distribution.s
Section 2la(e)(l)(A) of the Act provides that an ETC must provide services "using its own
facilities or a combination of its own facilities and resale of another carrier's services."6 However,
pursuant to the FCC's 2012 Lifeline Reform Order, resellers have been granted blanket forbearance
4 4Z U.S.C. $ 2la(e)(2). Section zla@)$) provides for FCC designation of ETCs, but only in the
case of a common carrier'othat is not subject to the jurisdiction of a State commission..." (emphasis
added).
5 +7 U.S.C. $ 2la(e)(l) (reflected in section 54.201(d) of the FCC's rules).
6 +7 u.s.c. g 2la(e)(l)(A).
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from this facilities requirement in connection with limited ETC designation to participate in
the Lifeline program, subject to conditions.T The FCC conditioned blanket forbearance on the
reseller's compliance with certain ETC obligations, including providing 9l I and E91l service
regardless of activation status and minutes available, providing E9l l-compliant handsets, and
replacing E9l I non-compliant handsets at no charge to the Lifeline customer.8 In addition, the
reseller must adhere to an FCC-approved compliance plan that includes specific information about
the measures that the reseller will take to implement the obligations established inthe 2012 Lifeline
Reform Order.e Telrite operates as a wireless reseller and commits to compliance with all of the
conditions for ETC designation and forbearance from the facilities requirement.
Iv TELRITE SATISFIES THE REQUIREMENTS FOR DESIGNATION AS AI\ ETC
UNDER 47 C.F.R. S 54.201
Section 254(e) of the Act provides that "only an eligible telecommunications carrier
designated under section 214(e) shall be eligible to receive specific federal universal service
support." Section zla@)Q) of the Act provides that, upon request and consistent with the public
interest, convenience and necessity, the Commission may designate more than one common carrier
as an ETC in areas served by a rural telephone company and shall do so with respect to all other
areas, provided that the requesting carrier (i) offers services that are supported by Federal universal
service support mechanisms and (ii) advertises the availability of such services.lo Section
2la(e)(l) of the Act and Section 54.201(d) of the FCC's rules state that applicants for ETC
designation must be common carriers that offer all of the services throughout the designated
7 2012 Lifeline Reform Order,\368
8 Id. at11373.
e Id. atfl 363.
r0 47 U.S.C. g2la(e)(2); see also 47 C.F.R. $ 54.201(dX2).
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service area 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. Telrite satisfies all such requirements for ETC designation.
A.Telrite Will Provide Service via Resale Consistent with the FCC's
Forbearance of the Facilities Requirement
Section 2la@)Q) of the Act requires that an ETC must provide services "using its own
facilities or a combination of its own facilities and resale of another carrier's services."ll As
discussed above, although section 214 requires ETCs to provide services using their own facilities,
at least in part, the FCC has granted forbearance from enforcement of the facilities requirementto
carriers seeking Lifeline-only ETC designation. In the 2012 Lifeline Reform Order, the FCC
granted forbearance from the "own-facilities" requirement contained in Section2la(e)(l)(A)
for carriers that are, or seek to become, Lifeline-only ETCs, subject to the following conditions:12
(l) the carrier must comply with certain 9l I requirements [(a) providing its Lifeline
subscribers with 9ll and E9l1 access, regardless of activation status and availability of
minutes; (b) providing its Lifeline subscribers with E9l l-compliant handsets and replacing, at
no additional charge to the subscriber, noncompliant handsets of Lifeline-eligible subscribers
who obtain Lifeline-supported services; and (c) complying with conditions (a) and (b) starting
on the eflective date of this Order]; and
(2) the carrier must file, and the Bureau must approve, a compliance plan providing
specific information regarding the carrier's service offerings and outlining the measures
the carrier will take to implement the obligations contained in this Order as well as funher
safeguards against waste, fraud and abuse the Bureau may deem necessary.
Telrite intends to provide service in ldaho via resale of its underlying service providers, T-Mobile
and AT&T Mobility. In accordance with the forbearance requirements, Telrite submitted a
rr47 u.s.c. g 2la(e)(l)(A).
t2 See 2012 Lifeline Reform Order at flfl 368, 373, and379.
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Compliance Plan and the FCC approved it on December 26,2012.13 A copy of the FCC-Approved
Compliance Plan is attached hereto as EttribiL[. Telrite seeks limited ETC designation to permit
it to participate in the Lifeline program.
i. Telrite Is a Common Carrier
The FCC consistently has held that providers of wireless services are to be treated as
common carriers for regulatory purposes. In addition, section 332(c)(l)(A) of the Act states that
CMRS providers will be regulated as common carriers.la Telrite provides mobile
telecommunications services and, accordingly, is a common carrier.
ii. Telrite Will Provide All Supported Services by Reselling the Services of Its
Underlying Providers
Through its underlying providers, Telrite is able to provide all of the supported services
required by Section 54.101(a) of the FCC's Rules (47 C.F.R. $ 5a.l0l(a)) as follows:
a. Voice Telephony Service
As set forth in 47 C.F.R. $ 5a.l0l(a)(l), eligible Voice Telephony Services must provide
the following:
Voice Grade Access to the Public Switched Telephone Network. The FCC describes
"voice grade access" as the ability for a user to make and receive telephone calls within a specified
bandwidth.ls Telrite provides voice grade access via resale of its facilities-based underlying
network operators, T-Mobile and AT&T Mobility.
t3 See Wireline Competition Bureau Approves the Compliance Plons of Airvoice Wireless,
Amerimex Communications, Blue Jay Wireless, Millennium 2000, Nexus Communications,
PlatinumTel Communications, Sage Telecom, Telrite and Telscape Communicafrons, Public
Notice, WC Docket No. 09-197, WC Docket No. I l-42, DA 12-2063 (2012).
14 47 u.s.c. g 332(c)(l)(A).
ts See Federal-Stote Joint Board on (Jniversal Service, CC Docket No. 96-45, First Report and
Order, I2FCC Rcd 8776, 8810-l I (1997).
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Local Usage At No Additional Charge. The FCC's rules require a petitioner for ETC
designation to demonstrate that its proposed local usage plan is comparable to one offered by the
incumbent local exchange carrier ("ILEC") in the same designated service area. The determination
of comparability requires a case-by-case review, taking into account value-added capabilities and
services included within a service plan. If granted ETC designation, Telrite will provide a Lifeline
service package in Idaho as outlined in Exhibit C.
Access to Emergency Services. Telrite provides 911 and E9l I access for all of its
customers to the extent that the local government in its service area has implemented 9l I or E9l I
systems. As noted, calls to 9l I emergency services will always be free and will be available
regardless of service activation status or availability of minutes. Telrite also complies with the
FCC's regulations governing the deployment and availability of E9l I compatible handsets.
Toll Limitation. In its Lifeline Reform Order, the FCC provided that toll limitation would
no longer be deemed a supported service. Nonetheless, Telrite's offerings inherently allow Lifeline
subscribers to control their usage, as its wireless service is offered to users at no charge until they
reach their monthly allowance at which point subscribers can choose to purchase additional service
at a low cost. Telrite's service, moreover, is not offered on a distance-sensitive basis and local and
domestic long distance minutes are treated the same.
b. Broadband InternetAccess Services
Broadband Internet access service ("BIAS") is a Lifeline supported service as of December 2,
2016. The FCC has stated that BIAS consists of the ability for a user to receive "the capability to
transmit data to and receive data from all or substantially all Internet endpoints, including any
capabilities that are incidental to and enable the operation of the communications service, but
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excluding dial- up Internet access service."16 Telrite provides BIAS to low-income consumers via
resale of its underlying providers'mobile broadband networks.
Itl.Telrite Will Advertise the Availability of Its Service and Charges in a Manner
Reasonably Designed to Reach Lifeline-Eligible Consumers I 7
Telrite intends to advertise its Lifeline services using media such as the Internet, social
media, newspapers of general circulation, radio and television, as well as at its mobile enrollment
events, as a means of reaching those consumers that are likely to qualify for Lifeline services. The
Company will use these methods to advertise the availability of its services to Lifeline customers
and will expand its advertising efforts as necessary to ensure that Lifeline-eligible customers are
aware of the service offerings.ls Telrite will ensure that all of its Lifeline advertising materials
comply with section 54.405(c) of the FCC's rules.
Specifically, Telrite's advertising materials will state, in easily understood language, that:
(i) the service is a Lifeline service; (ii) Lifeline is a government assistance program; (iii) the service
may not be transferred to someone else; (iv) consumers must meet certain eligibility requirements
before enrolling in the Lifeline program; (v) the Lifeline program permits only one Lifeline
discount per household; (vi) that documentation is necessary for enrollment; and (vii) Telrite is the
provider of the services. Telrite's advertising materials will be updated, as necessary, in the event
any of the requirements change.
iv. Telrite's Requested Service Area
Sections 2la@)Q) and2l4(e)(5) of the Act provide that ETC designations shall be made
for a "service area," defined as a geographic area established by the Commission. The Company
t6 See 47 C.F.R. $ 8.2(a).
17 47 c.F.R. $ s4.405(b).
ts See id.
t2
seeks designation to operate as an ETC throughout the State of Idaho.le The public interest factors
described below justifu Telrite's designation throughout Idaho, especially because the Company
seeks ETC designation solely to utilize USF funding to provide Lifeline service to qualified low-
income consumers.
v TELRITE SATISFIES THE ADDITIONAL REQUIREMENTS FOR ETC
DESIGNATION UNDER 47 CFR $ 54.202(a)
The FCC imposes additional requirements on a carrier requesting ETC designation in
section 54.202 of its rules. As demonstrated below, Telrite satisfies these additional obligations.
A. Service Commitment throughout the Proposed Designated Service Area
Telrite will provide service in Idaho by reselling service, which it obtains from its underlying
carriers. These providers have extensive networks that are functional and ready to support service
immediately. Thus, Telrite will be able to commence offering its Lifeline service to all locations
served by its underlying carriers very soon after receiving approval from the Commission.
Pursuant to 47 C.F.R. $ 5a.202(aXlXii), a common carrier seeking designation as a Lifeline-only
ETC is not required to submit a five-year network improvement plan as part of its petition for
designation as an ETC.
B. Telrite Has the Ability to Remain Functional in Emergency Situations
As noted above, Telrite currently utilizes the networks of two underlying providers, T-
Mobile and AT&T Mobility, to provide Telrite's mobile services. The Company has access to
le Consistent with FCC holdings, there is no need for a "creamskimming" analysis in connection
with Telrite's Petition because the Company is seeking ETC designation only for purposes of
receiving Lifeline support. See, e.g., Virgin Mobile USA, L.P., Order, 24 FCC Rcd 3381, fl 39 n.
l0l (200e).
l3
these extensive and well established networks and facilities and believes that they are capable of
managing traffic spikes that may occur during emergency situations and can reroute traffic in the
event of damaged facilities. Telrite also has reason to believe that these network operators have
sufficient back-up power to ensure functionality if its external power supply is unavailable.
C Telrite Will Satis$ Applicable Consumer Protection and Service Quality
Standards
Section 5a.202(a)(3) of the FCC's rules states that a wireless applicant's commitmentto
comply with the Cellular Telecommunications and Internet Association's Consumer Code for
Wireless Service ("CTIA Consumer Code") will satisfu this consumer protection and service
quality requirement. Telrite fully complies with applicable consumer protection requirements and
commits to fully complying with the CTIA Consumer Code. For example, customers can call
customer service by dialing 6l I from their Telrite handset and no minutes will be used or
decremented for the call, or they can call I -888-5 43-3620 from any phone.
D. Telrite Is Financially and Technically Capable
As part of the 2012 Lifeline Reform Order, the FCC amended its rules to require a carrier
seeking designation as a Lifeline-only ETC to demonstrate that it is financially and technically
capable of providing the supported Lifeline service in compliance with all of the low-income
program rules.2o Telrite fully satisfies these criteria. The Company has provided general
communications services successfully for more than two decades and has access to sufficient funds
to run its business. Significantly, Telrite's business is not solely dependent on reimbursements
from the federal USF as Telrite generates non-Lifeline revenues from Telrite's affiliated
companies, Pure Talk Holdings, LLC and Locus Telecommunications, LLC, which do business as
20 See 2012Lifeline Reform Order,lT387; see also 47 C.F.R. $ 202(a)( ).
t4
PureTalkUSA and h2o@ Wireless. Attached as Elhibitr-D. is a current list of the Company's
officers and key management, along with biographical information for each, showing that the
Company's management has the expertise necessary to provide the services detailed herein
E. Telrite's Proposed Lifeline Offering
Telrite has the ability to provide all services supported by the universal service program
throughoutthe Stateof Idaho. Under its ETC designation, Telrite will meetor exceed the FCC's
minimum service standards, as currently established as well as any future updates. Telrite proposes
initially to offer the following Lifeline offerings in Idaho under its Life Wireless dba:
Idalq-Elil: 500 voice minutes and 5 GB of data per month with unlimited texting and
multimedia messaging service at lg-ge!tr to the subscriber.2l This plan, free to eligible consumers,
includes a smartphone. The plan also includes the following custom calling features: Caller ID,
Call Waiting, Call Forwarding,3-Way Calling; and Voicemail.
Life Wireless subscribers can add to this plan any month they choose by selecting
additional service, currently offered as follows: a 100 GB Data PIN for $5.00, 100 additional
minutes for $5.00, 250 additional minutes for $10.00, one day of unlimited minutes for $4.95, three
days of unlimited minutes for $7.95, one week of unlimited minutes for $12.95, two weeks of
unlimited minutes $19.95, and one month of unlimited minutes $29.95. These additional services
can be purchased on the Error! Hyperlink reference not valid.website, from Life Wireless
Customer Service or at any MoneyGram location.
2r 5 GB is contingent upon receipt of $2.50 monthly support from the Idaho Telephone Assistance Program.
Without such support, the Lifeline plan would include 4.5 GB.
l5
Telrite's Processes Comply with Lifeline Verification and Enrollment
Processes, and the Company Is Committed to Preventing Waste, Fraud, and
Abuse of the Lifeline Program
Section 54.410 of the FCC's Rules requires ETCs to certifu and veriS, a Lifeline
customer's initial and continued eligibility. Telrite has processes in place to facilitate compliance
with federal customer enrollment requirements through use of the National Verifier and the
National Lifeline Accountability Database ('NLAD"), each of which is administered by Universal
Service Administrative Company ("USAC"). Telrite is connected to both the National Verifier
and the NLAD via application programming interfaces ("APIs"), allowing it to help applicants
through the standard application form, eligibility verification, duplicate detection, identity
verification and address verification, and related resolution processes included within USAC's
systems and processes. Telrite thus complies with the disclosure, information collection and
certification requirements set forth in Section 54.410(d) ofthe FCC's rules. Forapplicants verified
as being eligible by USAC's National Verifier and NLAD, Telrite completes enrollment by
transmitting the required information into NLAD as required by Section 54.404(b)(6), by
informing the customer of his or her need to use the service at least once every thirty (30) days as
required by the 2012 Lifeline Reform Order22 and providing notice to subsoibers after 30 days of
non-usage that they must use the service within 15 days or their service will be terminated as
required by Section 5a.a05(e)(3), and by requiring the customers to activate their Lifeline service
as required by Section 5a.a07@)(l) by placing a call.
Telrite has additional processes in place to guard against waste, fraud and abuse, and to
ensure compliance with FCC rules designed to achieve that objective, including customer usage,
cure period, and de-enrollment requirements set forth in Sections 54.a07@)(2) and Section
F
22 See 2012 Lifeline Reform Order,fll257
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5a.405(e)(3), general notice and de-enrollment requirements set forth in Section 54.405(e)(l),
transmission of information to NLAD and recordkeeping requirements set fonh in Section
54.404(b)(6) and Section 54.417, annual certification and reporting requirements set forth in
Sections 54.416 and 54.420, and reimbursement claims processes established by USAC consistent
with Sections 54.403 and 54.407(a). Telrite also coordinates with USAC's National Verifier and
NLAD systems to manage additional de-enrollments related to USAC-administered benefit
transfers and annual recertification as required by Sections 54.303 and 54.405. If Telrite receives
a request for de-enrollment from a subscriber, it will process the request within two business days
in accordance with Section 54.405(e)(5). Consistent with Section 54.406(a), Telrite will require
its enrollment representatives to register with USAC before providing information directly to the
NLAD or National Verifier, and pursuant to Section 54.406(b), Telrite will not pay an enrollment
representative or his or her direct supervisor based on the number of consumers who apply for or
are enrolled in the Lifeline program with Telrite. Finally, Telrite has long been at the forefront of
developing and deploying internal controls to guard against waste, fraud and abuse. It remains
committed to be a good steward of and partner in, the Lifeline program through continued
vigilance against waste, fraud and abuse.
vI.THE PUBLIC INTEREST WILL BENEFIT FROM GRANTING ETC STATUS TO
TELRITE
The overarching purpose of the Lifeline program is to ensure that low-income consumers
have access to and can afford essential voice and broadband communications services. The
Lifeline program began with a focus upon the availability of voice services; however, as
technology has expanded and broadband has become increasingly essential to everyday living, the
Lifeline program has developed as well. Today, robust levels ofbroadband service must be offered
to eligible subscribers, as a means of effectively bridging the "Digital Divide" that separates
t7
Idaho residents on the basis of income. As regulators and policymakers have recognized since the
establishment of the Lifeline program, meeting an evolving set of essentialcommunications needs
is overwhelmingly in the public interest and, indeed, is critical to the long-term health and
prosperity of each state and to the nation as a whole. Designation of experienced ETCs such as
Telrite will directly advance the goals of the Lifeline program in ldaho.
A. Advantages of Telrite's Lifeline Services
Telrite's experience and longevity as a provider of Lifeline services in many states
demonstrates the Company's commitment and ability to provide quality Lifeline services to
eligible,low-income consumers in compliance with program requirements. Authorizing Telrite as
a Lifeline ETC in Idaho will enable it to provide eligible low-income consumers with access to
high quality mobile voice, text and data services. This will increase those consumers' choices in
service providers and service options and make essential communications services more affordable
and accessible. Importantly, it will also lead to additional competition within the Lifeline market
that should help improve the rate of program participation by eligible subscribers and spur other
ETCs to improve their own Lifeline service offerings. Telrite's combined use of online and in-
person, real-time distribution methods rely upon Internet-enabled compliance checks that, while
meeting (and often exceeding) Lifeline program requirements, have enabled the Company to bring
Lifeline service to those eligible consumers that are not easily reached by carriers relying
exclusively on one distribution method or another.
Mobile services are overwhelmingly preferred by Lifeline-eligible consumers who can
often afford only a single connection, may frequently change residences or places of employment,
may need the ability to communicate promptly and effectively with prospective employers, and
also must manage households and family responsibilities as they do so. Some of these consumers
l8
may be homeless, with their Lifeline service being the only reliable contact point they have. For all
these consumers, whatever their circumstances, Lifeline services also ensure that they always have
the ability to contact 9l I emergency services should the need arise. "Free" minutes, texts and data
are an invaluable resource for cash-strapped consumers in these circumstances.
Telrite's Lifeline service plan is an attractive option for low-income consumers because
theCompany'splansarehighlycompetitive. As set forth above and in Exhibit C,
Telrite's proposed initial Idaho Lifeline plan includes 500 minutes, unlimited texts, 5 GB of data23,
several ofthe most popular features and a smartphone, all free of charge. In addition, the Company
provides additional consumer-friendly options that enable subscribers to flexibly tailor their
wireless services to their variable needs and budgets.
Moreover, Telrite's Lifeline plans alleviate customer concerns regarding deposits, hidden
costs, varying monthly charges (including the infamous "bill shock") and long-term contract
issues. Telrite does not impose credit checks, and as such provides an alternative for those low-
income consumers unable to obtain credit as is required for post-paid services provided by
traditional carriers. Through MoneyGram, Telrite's Lifeline subscribers have nationwide retail
store access to purchase more minutes or data. This flexibility and accessibility provide a viable
option for "unbanked" and o'underbanked" consumers.
B. Benefits of Competitive Choice
The FCC recognized the interrelationship of ETC designations and competition over a
decade ago, concluding that in non-rural areas, designation of multiple ETCs, following
demonstration of compliance with eligibility requirements, was so fundamentally beneficial as to
23 5 GB is contingent upon receipt of $2.50 monthly support from the ITSAP. Without such support, the Lifeline
plan would include 4.5 GB.
t9
warrant charucterization as "consistent per se with the public interest."24 Similarly, the correlation
between increased market choice and lowering of costs, when dealing with competitive services,
has been adopted as a "given" by telecommunications industry regulators across the country. In
the Lifeline context, this equation takes on new importance, because the entry of additional
providers increases competitive choice for lower-income customers who often are less desirable
to providers focused on upscale consumer offerings.
C. Impact on the Universal Service Fund
In the past, the FCC also recognized that, in contrast to the historic designation of carriers
to receive high cost funds, the designation of Lifeline ETCs should not have an adverse effect upon
the health ofthe USF. The Lifeline benefit is provided to each eligible customerthat enrolls and, as
a result, the USF is unaffected by whether Telrite or another ETC serves that customer. Moreover,
with strict compliance to the FCC's rules concerning prevention of waste, fraud and abuse of the
USF, there is greater certainty that no customers served by Telrite or other ETCs are ineligible or
are receiving duplicative benefits.
There are still many - indeed the majority of - eligible consumers not receiving Lifeline
benefits. This is why ETC applicants highlight their ability to reach those consumers. The
presence of more Lifeline ETCs, with increasingly sophisticated ways to reach previously
unserved eligible consumers, will help to increase the overall numbers of consumers receiving
Lifeline benefits. Ensuring the availability of critical communications to Americans in desperate
need is precisely why the USF was established. And it has never been more necessary. Any
2a Federal-State Joint Board on (Iniversal Service Cellco Partnership d/b/a Bell Atlantic Mobile
(Petition for Designation as an Eligible Telecommunications Carcier), Memorandum, Opinion
and Order, l6 FCC RCD. 39,atpara.l4 (rel. Dec.26,2000).
20
increase in funding demands upon the USF will be directly proportionate to the escalated
imperative for the USF to fulfill its function.
VII. CONCLUSION
As demonstrated by the facts stated herein, and as verified in s!!!1!!p, Telrite meets all
the statutory and regulatory requirements for designation as an ETC in the State of ldaho. For the
reasons outlined above, designation of Telrite as an ETC in the State of Idaho fully satisfies the
requirements of Section zla@)Q) of the Act and is in the public interest.
WTIEREFORE, Telrite respectfully requests that the Commission promptly designate
Telrite as an ETC throughout the State of Idaho for purposes of participating in the Lifeline program
and ITSAP program to receive support and reimbursement for the provision of communications
services on a wireless basis to qualified low-income Idaho consumers.
Respectfu lly submitted,
4J^'L
June 14,2022
Susan J. Berlin
Friend, Hudak & Harris, LLP
Three Ravinia Drive, Suite 1700
Atlanta, GA 30346
Phone: [phone] Ext. I 15
Fax: [phone]
Email: [e-mail]
Attorneysfor Telrite Corporation d/b/a Life Wireless
2t
Exhibit A - Certificate of Authority to Transact Business in ldaho{ XE "Exhibit A -
Certifrcate of Authority to Transact Business in ldaho" )
22
STATE OF IDAHO
Lawerutcla DannoylWotary of SXab
Business Office
450 North 4th Street
PO Box 83720
Boise, lD 83720
June7,2O2.
Requeot Type: C€rtlf lcstg of ExistencerFl llng
R€quegtl* (XXZ3E33
R€celpt* m0671152
lsstnnceDsle: GlOlDqn
CopierRequeclad: 0
Ragarding: TELRITE CORPC,RATION
Flllng Type: Folelgn Buelnees GoDoration
Forretm0ualificdon Da!e: 04128/2003Statr: ActhoGood Standiry
DuntionTerm: Perp€tuel
File#: 4fi1200
Formation Locah: GEORGIA
lnadtue tlEb:
Certificate of Exietence
I, Lawerence Denney, Secretary of State of the State of ldaho, do hereby certify that €ffec'tive as
ofthe issuane date noted above
TELRITE CORPORATION
a Corporation furmed in the jurMiction set forth above, ie authorized to transast businasg in thie
Siate.
Denney
ldaho Secretary of State
Proceesed By: Buslnes8 Dlvblon Verlflcetlon *: 018597530
Phone: 20E-334-2301 ' Emall: [e-mail] ' Wbbslto: sosblz.ldaho.0o,
23
Exhibit B - Telrite's FCC-Approved Compliance Plan{ XE "Exhibit B - Telrite's FCC-
Approved Compliance Plan" I
24
xtw Yoi(. rY
roa Af,olL!a. cA
cttca60. t!
tTAI'OiD. CT
FAiII??AXY. XJ
aacailr!l
(202) ta?.t46r
w,tallaydryr,ccil
KELLEY DRYE & WARREN r.r.p
WASHINGTON HARBOUR, SUITE
'OO3060 K STREET, NW
wAsHtNGToN, D.c. 20007.5t08
(102) !a2-!400
ligtlE!a. ittotut
xurlat. rxorA
Dccetnber 19,2012
vI^Ectrs
Marlene H. Dortclt Secrctary
Federal Communications Commission
445 l2rh Stlecq S.W.
Washington, DC20554
Re: Tclritc Corooration Compliance Plan: WC Docket Nos. 09-197. I l-42
Dear Ms. Dortch:
On March 12,2012, Tclrite Corporation (*Telrirc") submittcd its Compliancc
Plan outlining dre mcasurc,lr it will takc to implc'nrcnt thc conditions imposed by the Commission
in its Lifeliru Reform Order.t On Apil I 0, Telrirc submitrcd a reviscd version with a minor
revision to its Model Applicatior/Ccrtific*ion Form, includod as Exhibit A to its Compliance
Plan. On April 27, July 2, July 27, Novembcr 28 and Novembcr 29 Telrite further revisd and
supplemented its Compliurce Plan.
Telrite has fur$or rpvised its Compliancc Plan (p. 14) to olariff Tolritc's process
for docnrollme,nt of customcrs that fail o respond to thc annual eligibility verification. Nothing
clse in thc C,ompliancc Plan has bcen changed.
Telrite hercby re-zubmits its complete Compliance Plan with the above rsvision.
Based on the minor nature ofthis changc, Telritc reitcrates its rcquest for expeditious approval of
its Compliance Plan.
OIRICT LlXa: (202) la2.t5aa
EIAII: lh.liilrnnOt.ll.tdry...ofr
See Lifeliw and Linh Up Reform and lttodernization, Lifeline ond Link Up, Federal.State
Joint Bood on Universal Semice, Advancing Broadband Availability Ihrough Digital
Literacy Tiaining, WC Dockot No. I l-42, WC Docket Np. 03-109, CC Docka No. 96-
45, WC Dockct No. 12-23, Report and Order and "tFurther Notice of Proposcd
Rulcmaking, FCC t2-l t (Feb.6,2012).
25
This hilt!( ond Etisd Complimoo Phn ar boiag filod cloctnonically for
iaolusim in tho ptrblic ruoord of tlo rbovo*cfcrrneod erooccAingp, Plcrso fecl fioG to coffiot
tbcudctsignod *fth my qucolions.
Marhno H. Dortch" Sconory
Dcccmbcr 19,2012
Pagc Ttwo
e9:Knn Scudino
Jonr[hent chtcr
DivFShcnoy
C{octI*Dly
KELLEY DRYE I WARRE|| ll.F
Rccpoctfully rubmiuo4
JohoJ. Ilcimann
JoehwT. Guyan
Cowtsel to Telrtte Corpraion
26
In the Matter of
Telecommunications Carriers Eligible to
Receive Universal Service Support
Lifeline and Link Up Reform and Modernization
Telrite Corporation
WC DocketNo.09-197
WC DockctNo. ll42
BEFORETEE
FEDERAL COMMI'MCATIONS COMT\flSSION
Washington, D.C.20554
TELRITE CoRPoRATIoN CoMPLIANCE PLAN
Telrite Corporation ("Tclrite" orthc "Company"),| through ir undersigred counsel,
hercby respectfully submits and requests expeditious approval of its Compliance Plan outlining
the measures it will take to implement the conditions imposed by the Commission in its Lifeline
Reform Order.z
Thc Company hereby also reports its corporatc and trade names, identifiers, and its
holding company, operating companies and affrliates as: Telrite Corporation (corporate
name), Life Wireless (rade name) and Tclritc Holdings, LLC (holding oompany). Telrite
owns l0 percent of Life Wireless Holdings, LLC, which is 50 percent owned by Puretalk
Holdings, LLC. Therefore, Puretalk Holdings, LLC is not an affiliate of Telrite,
however, Tclrite's "top-up" minutcs are sold under the Purc Unlimircd brand.
See Lifeline and Link Up Reforn and Modernizatioa L{eline and Link Up, Federal-\tate
Joint Board on Untversal Service, Ahtancing Broadband Avatlability Through Digital
Literacy Traintng, WC Docket No.ll42, WC DocketNo. 03-109, CC DocketNo. 96-
45, WC Dockct No. 12-23, Report And Order and Further Noticc Of Proposed
Rulemaking FCC 12-l I (Feb. 6, 2012) ('Lifeline Reform Order"). The Company herein
submits the information required by the Compliance Plan Public Notice. See Wireline
Competition Bweau Provides Guidancefor the Submission of Compliance Plans
Prrsuant to the Lifeline Re/orm Order, WC DocketNos. 09-197, I142, Public Notice,
DA 12-314 (rel. Feb. 29,2012).
27
The Company commends the Commission's commitnent to a nationwide
communications system that promotes the safety and welfare of all Americans, including
Lifeline customers. Telrite will comply with 9l I requirements as described below and it is
submitting this Compliance Plan in order to qualif, for blanket forbearance from the facilities
requirement of section 214(e)(l)(A) of the Communications Act and participate as an cligible
telecommunications carrier ('ETC") in the Lifcline program.3
The Company will comply fully with all conditions set forth inthe Lifeline Reform
Order, aswell as with the Commission's Lifeline rules and policies mor€ generally.a lhis
Compliance PIan dcscribes the specific measures that the Company intends to implement to
achieve these objectives. Specifically, this Compliance Plan: (l) describes the specific me.rsures
that Telrite will take to implement the obligations containcd inthe Lifeline Reform Order,
including the procedures the Company follows in enrolling a subscriber in Lifeline and
submitting for reimbursement for that subscriber from the Low-Income Fund, materials related
to initial and ongoing oertifications and sample marketing materials; and (2) provides a daailed
description ofhow Telrite offers Lifeline services, the geographic areas in which it offers
scrvices, and a detailed description ofthe Company's Lifeline service plan offerings.
See Lileline Reform Order,\368. Although the Company qualifics for and seeks to avail
itself of the Commission's grant of forbearance from the facilities requirement of section
2la(eXlXA) for purposes of the federal Lifeline program, the Company reserves the
right to demonstrate to a state public utilitics commission that it provides service using its
own facilities in a state for purposes ofstate universal service funding under state
program rules and requirements. Telrite will follow the rpquirements of the
Commission's Lifcline rules and this Compliance Plan in all states in which it provides
Lifeline service and rcceives reimbursements from the federal Low-Income Fund,
including in any state where the public utilities commission determines that Telrite
provides service using is own facilities for purposes ofa state universal service program.
In addition, this Compliance Plan is consistent with the compliance plan filcd by Global
Connection Ino. of America. See Global Connection of America Inc. Compliance Plarq
WC Docket Nos. 09- 1 97, I 142 (Apr . 30 , 2012) . The Global Connection compliance
plan was approved on May 25, 2012. See Public Notice, DA 12-828.
,,
4
28
ACCESS TO 911 AND E9I1 SERvICEt'
Pursuant to the Lifeliru Reform Order,forbarance is conditioned upon the Company: (l)
providing its Lifeline subsoribcrs with 9l I and E91l accesg regardless of activation status and
availability of minutes; and (2) providing its Lifeline subscribers with E9l l-compliant handscts
and replacing, at no additional charge to the subscriber, noncompliant handsets oflifeline-
eligible subscribers who obtain Lifeline-supported services.6 Telrite will comply with thesc
conditions starting on the effcctive date ofthe Lfeline Reform Order.
The Company will provide is Lifetinc customcrs with aocess to 9l I and E9l I serviccs
immediarcly upon activation of service. The Commission and consumers arc hereby assured that
all Telrite customers will have available access to emergency Galling services at the time that
Lifeline service is initiated, and that such 9l I and E9l I access will be available from Telrite
handsets, even if thc accourt associatcd with thc handset has no minutcs rcmaining.
The Company's existing practices currently provide access to 9l I and E9l I services for
all customers. Telrirc uses AT&T as its underlying network provider/carrier. has dircct
contracts for wircless scrvices from AT&T, as opposed to purchasing minutcs through an
intermediary, AT&T rourcs 9l I calls from the Company's customers in tlre same manner as 911
oalls from AT&T's own retail customers. To the extcnt that AT&T is certified in a given PSAP
territory, this 9l I capability will firnction the same for the Company. Telrite also currently
enabtes 9l I emergency calling services for all properly activated handsets regardless ofwhether
the account associated with the handset is active or suspended. Finally, the Company tansmits
all 9l I oalls initiated from any of its handsets even ifthc account associated with the handset has
no remaining minutcs.
See Compliance Plan Public Notice at 3.
See Lifeline ReJorm Order,\373.
J
29
E9ll-Compliant Eandse8. Telrite will cneure that all handsets used in conneotion with
the Lifeline service offering arc E9l l-compliaot In point of fact, thc Company's phones have
always bcen and will continue to bc 9l I and E9l l-compliant The Company uscs phones from
AT&T tlut havc becn through a stingort certification process with AT&T, which ensurcs that
the handsct models used mcct all 9l I and E9l I requirements. As a resulg any existing custom€r
that qualifics for and elects Lifeline service will alrcady have a 9l l/891 l-compliant handsct
wtrich will be confirmed at drc time of enrollment in the Lifeline program. Any new customer
that qualifies for and cnrolls in the Lifelinc program is assured ofrecciving a 91 1/E9l 1-
compliant handset as wcll, ftcc of charge.
CoIeIJANcEPI.AN
L PRocEDUREsToENBoLLASuBscRrBEnNLTTEUNET
A- Policy
Telritc complios with thc uniform cligibility criteria esablistrcd in new scction 54.409 of
the Commission's ruleg as wcll as any additional ccrtification and vcrification rcguirunents for
Lifeline cligibility in states where the Company is designatcd as an ETC.
Thercfore, all subscribers aro required to dcmonstratc eligibility bascd st lcast on: (l)
household income at or bclow 135% oftrc Federal Povcrty Guidelines for a houschold ofthat
size; or (2) the household's participation in one ofthe fedcral assistance pn,grams listcd in new
sections 54.409(a)(2) or 54.409(a[3) ofthc Commission's nrles. In addition, through the
certilication requircmcnts dcscribed bclow, thc Company will confirm thatthe rubscriber is not
already rccciving a Lifcline service and no one clsc in thc subscribcr's houschold is subscribcd to
a Lifclinc sorvice.
7 See Compliancc Plan Public Noticc at 3
4
30
B, Eligibility Determination
More than 99 perccnt of Tclritc's customer cnrollment is done in-person, as opposed to
over the phone or the Intemet. Event locations are schedulcd using various market or industry
data resources. Telrirc directs a team ofreprcsentatives that suwey and evaluate pote[tial event
locations across its service areas. Additionally, Telrite partrers with community organizations,
such as civic organizations, churches and food banks to host events in the communities its
serves. Representatives arc only permitted to cnroll Lifeline customers within thc borders of the
states where Telrite is desigrated as an ETC. Furtheq to €nsur€ that Telrite can track the
location of its enrollment initiatives, all representatives conducting a Telrite enrollment event are
required to clectronically check in with Telrite and provide their address before the
reprcsentatives can submit ordcrs and enroll customers in Telrite's Lifeline service.
All enrollrrnents performed in-person are complcted clectonically. The use of "paper
forms" is prohibited" however, at all times laminated copies of the Lifeline application/
certification forms arr available for customers to review. Telrite's elcctronic process uses MiFi
hotspots, laptop or net book computers, electonic signaturc pads and a bar code scsnner to
complcte enrollment in real-time. The electronic order process provides Telrite thc opportunity
to perform scveral database checks in real-time during the emollment process. Specifioally,
Telrite's systems validate and normalize addresses via "Melissa" data; perform an internal
address duplicate check (to ensure that the prospective customer or someone at that address docs
not ourrently have Lifeline service from Telrite); perform an extemal duplicate check using
CGM, LLC's C'CGM's') intercompany duplicatc database ('IDD')8; and confirm the customer's
CGM's IDD cnables participating ETCs to seed the database with subscriber lists, as wcll
as o check the database against the subscribcr lists ofparticipating ETCs. Telrite is the
Iargcst ETC participating in this important self-regulatory initiative. Fudher
5
3r
identity via Lexis Nexis (using thc prospective customer's last name, date of bitth and the last
four digits of the customer's Social Security number). ln addition, Telrite will check each
applioant's govcmment-issued photo identification for this purpose,
As discussed in furttrcr dcail in Section I.F. below all employees or rcpnssentatives
(*Company pcrsonncf') that conduct such in-person enrollmcnts are trained rcgarding the
eligibility and ccrtification requircmentsinthe Lifeline Reform Order and this Compliance Plan,
including thc one-pcr-household rcquircrncnt and told to inform potential customcrs ofthose
requirements. New Company personncl undergo an initial mandatory training session where
they are given training matcrials, a field taining manual and a compliance manual, as well as
shown visual examples of documents acceptable to demonstrate eligibility for the Lifeline
program.
IfTelrirc cannot detcrminc a prospcctivc subscriber's eligibility for Lifeline by accessing
income daabases or program eligibility darabases, Company pcrsonnel will review
documentation esablishing eligibility pursuant to the Lifeline rules.e All personnel who interact
with actual orprospcctive customers will bc trained to assist Lifeline applicants in dctermining
whether they are cligible to participatc based on the federal and s'tate-specific income-based
and/or program-based crircria. These personnel will be tained to answer questions about
Lifeline eligibility, and will rcview required documentation to determinc whether it satisfies the
Lifeline Reform Or&r and state-specific eligibility requir€ments using state-spccific checklists.
demonstating Telrirc's leadership and commitnent to defending the Lifeline program,
Telrite also has produced thrtc PSAs designed to educarc the public about the Lifeline
program. By January 2013, these PSAs will have been aired over 2,700 times
collcctively across thc following markets: Atlanta, Baltimore, Charleston (WV),
Chicago, Deluth, Lirle Rock, Minneapolis, New Orleans, Providence and St. Louis.
See L{eline Relorm Oder,'[ 100; sections 54.410(bXtXiXB), 5a.al0(cXlXiXB).
6
32
Proof of Elisibiliw. Company personnel will be trained on acceptable documentation
required to establish income-based and program-based eligibility.lo Acceptablc docum€nation of
program eligibility includes: (l) the currcnt or prior year's statement ofbenefits from a
qualiffing state, federal or Tribal program; (2) a noticc letter ofparticipation in a quatifring
state, federal or Tribal program; (3) program participation documents (e.g., the consumcr's
Supplemental Nutrition Assistance Program (SNAP) eleotronic benefit transfer card or Medicaid
participation card (or copy therco$); or (4) another official docrmrent evidencing the consumer's
participation in a quali$ing state, federal or Tribal program.rr
Acceptable documentation ofincome eligibility includes the prior ycar's state, federal, or
Tribal tax r€turn; curtent income statement from an employer or paycheck stub; a Social Security
statcment of benefits; a Veterans Administration statcment of benefits; a r€tirement/pension
statement of b€nefits; an Unemployment/Wodqnen's Compensation statement of benefis;
federal or Tribal notioe lefter ofparticipation in General Assistance; or a divorce decrec, child
support award, or other ofiicial document containing incomc information for at least three
months timc.l2
Company personnel will examine this documentation for each Lifeline applicant, and will
record the tlpe of documc.ntation used to satisfr the incomc- or program-based criteria by
checking the appropriate box on the application form.l3 In addition, Company personnel will fill
in, where available, the last four digits of an account or other identifring number on the proof
documen! ttre date ofthe proofdocument and the expiration ofthe proofdocument. The
t0 See Lifeline Reform Order,fl l0l. See also USAC Guidancc availabte at
htto://www. usac,ore/li/telecom-carriers/steo06/defau ltasox.
.Id. and soction 5a.al 0(c)(l)(i)@).
See Lifeline Reform Order, n10l ; section 54.4l0.OXlXiXB).
See Lifeltne Reform Order, \l0l ; sections 54.4 I OOX I Xiii), 54.4 I 0(cX I XiiD.
ll
12
l3
JJ
Company will not retain a copy of this documentation, except where stat€ rules require such
retention.la Where the Company personnet conclude that proffered documentation is insufficient
to establish such eligibility, the Company will dcny the associated application and inform the
appticant ofthe reason for such rejection. In the event that Company pcrsonnel cannot ascertain
whether documentation of a specific t1rye is sufiicient to establish an applicant's eligibility, the
matter will be escalated to supervisory personnel at the Company's corporate ofiices in
Covington, GA. A Telrite employee will be responsible for overseeing and finalizing every
Lifeline enrollment prior to including that customer on an FCC Form 497 for reimbursernenl
In addition, Telrite will not enroll customers at retail locations where Telrite does not
have an agency agreement with the retailer. Further, Telrite will require an agent retailer to have
any employecs involved in the enrollment process go through the standard Tclrite field
representative kaining, same as it would for any othcr agent. By establishing agency
relationships with all of its field representatives, including future retail outlets, Telrite meets the
"deal directly'' requirement adopted in the TracFone Forbearance Order.ls
Thc Commission dctermined inthe Lifellne Reform Order ilntETCs may permit agcnts
or representatives to rcview documentation ofconsumer program eligibility for Lifeline because
"the Commission has consistently found that'fl]icensees and other Commission r€gulate€s are
responsible for the acts and omissions oftheir employees and independent conEactors."'t5
Because Telrite is responsible for the actions ofall ofits employees and agents, including those
enrolling customers in any Telrite owned or afriliated retail locations, and a Telrite employee
See Lifeline Reform Oder, ll0 1; sections 54.4 I 0(bX I XiD, 54.a I 0(c)( I )(ii).
,See Petition of TracFone Wireless, Inc. for Forbcarance from 47 U.S.C. $ 2la(e)(l)(A)
and 47 C.F.R $ 54.201(D, CC Dockct no. 9645, Order, FCC 05-165, Tl9 (2005).
Lifeline Reforn Order, I I 10.
t4
I5
l5
8
34
will bc responsible for oversecing and finalizing every Lifeline eruoltnent prior to including that
customer on an FCC Form 497 for reimburscmcnt, the Company always "deals directly''with its
customers to certiS and verifr the oustomcr's Lifcline eligibility.
De-Enrollment for Inelieibility. If Telrite has a reasonablc basis to believe that one of its
Lifelinc subscribers no longo meets the eligibility criteria, the Company will notify the
subscriber of impending tcrmination in writing and in oompliancc with any applicable state
dispute resolution proccdures applicable to Lifeline trrmination, and give thc subscribcr 30 days
to dcmonshate continucd eligibility.tT A demonstration of cligibility must comply with the
annual verification proccdurcs below and found in new rule section 54.410(D, including thc
submission of a certification form. If a cuslomer contacts the Company and states that hc or she
is not eligible for Lifelinc or wishes to de-enroll for any rcason, thc Company will de+nroll the
customer within five business doys. Customers can makc this request by calling the Compan/s
customer scrvicc number and will not be required to submit any documcnts.
C. Subscriber Certifications for Enrollment
The Company will implement certification policies and procedures that enable consumers
to dernonstrate their eligibility for Lifelinc assistance to &mpany p€rsonnel as dctailcd in the
Ltletine Reforn Order,togeth*with any additional state certification rcquircments.rs Thc
Company shares thc Commission's con@rfl about abusc of &c Lifeline program and is tltus
committed to the safeguards stared herein, with thc belicf thatthcse procedures will prcvcnt the
Company's customers from engnging in such abuse ofthe program, inadvertcntly or
intentionally. Evcry applicant will be rcquired to complcte an application/certification form
t7 See Lifelirc Reform Order,'ff 143; section 5a.405(e)(l).
Lifeline Reform O&r,n61; section 54.410(a).
9
t8
35
containing disclosures, aod collccting certain information and certifications as discussed below.le
Applicants that seek to enroll based on income cligibility will be referred to a wortsheet showing
the Federal Poverty Guidelines by houschold size.2o
Applicants that do not complete the form in person will bc required to retrm the signcd
application/certification form to the Company by mail, facsimile, elcctronic mail or other
electonic tansmission. In addition, Company pcrsonnel will vcrbally explain the certifications
to consumers when they are c,nrolling in person or over the phone.2!
Disclosurcs. The Company's application and certification forms will include the
following disclosurcs: (l) Lifcline is a fcderal benefit and willfully making falsc statements to
obtain the benefit can result in fines, imprisonmeng de-enrollment or being bancd from the
program; (2) only one Lifcline servioe is available per household; (3) a household is defined, for
purposcs of the Lifeline progmm, as any individual or group of individuals who live togrther at
the same address and sharc inoome and expenses; (4) a household is not permittcd to receivc
Lifeline benefits from multiple providen; (5) violation of the one-per-household limitation
constitutes a violation ofthc Commission's rules and will result in the applicant's dc-enrollment
from thc program; and (6) Lifeline is a non-tansfcrable benefit and the applicant may not
tansfer his or her bcnefit to any other pcrson.z
Applications and ccrtification forms will also state thac (I) thc servicc is a Lifeline
servicc, (2) Lifclinc is a govemment assistance program, and (3) only eligible consumcrs may
^See Model Application/Certification Form, included as Exhibit A. See Compliance Plan
Public Notice at 3.
,See Income Eligibility Wo*sheeg included as Exhibit B.
S* Ldeline Reform Order,'ff 123.
See id.,l l2l; section 54.410(dxl).
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enroll in the program.23
ln addition, Telrite will notif the applicant that the prepaid service must be personally
activatcd by the subscriber and the scrvice will be dcaotivated and the subscriber de-cnrolled if
the subscriber does not use thc scrvice for 60 days.z
Information Collection. The Company will also collcct the following information from
the applicant in thc application/ccrtification form: (l) thc spplicant's full name; (2) the
applicant's tull rcsidentiat adrtress (P.O. Box is not sufficienfsl; (3) whaher the applicant's
rpsidcntial address is pcrmancnt or temporary; (4) the ap,plicant's billing addrcss, ifdifferent
from the applicant's residcntial address; (5) the applicant's date ofbirth; (O thc last four digits of
the applicant's Social Security number (or the applicant's Tribal identification number, ifthe
subscriber is a member ofa Tribal nation and does not havc a Social Security numbcr); (7) ifthe
applicant is secking to qualiS for Lifelinc undcrthc program-based ctiteriq the name ofthc
quali$ing assistancc program from which the applicanq his or her dcpcndents, or his or hor
houschold receives benefits; and (8) ifthe applicant is sceking to quali$ for Lifcline under the
incomc-based critcrioru the number of individuals in his or her household.26
Applicant Certification. Consistcnt with ncw rule section 54.410(d)(3), the Company
will require the applicant to certifu undcr penalty ofperjury, in writing or by electonic signature
or intcractive voice responsc pes16ing,27 the fotlowing: (l) the applicant meets the income-
based or program-based eligibiliry criteria for recciving Lifeline; (2) the ap,plicant will notifr the
See section 5a.405(c).
See Lileline Reforn Oder,n257.
See id.,\87.
.See scction 54.4 I 0(dX2).
Sce Lifeline Reform Arder,ffi 168-69; section 54.419.
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Company within 30 days if for any reason he or she no longcr satislics the criteria for rcceiving
Lifclinc including, as r€lcyant, if the applioant no longer mcets the income-based or progr.m-
based criteria for receiving Lifcline supporl the applicant is receiving more than onc Lifeline
bencfit, or another mcrnber ofthe applicant's houschold is rccciving a Lifclinc bencfiq (3) ifthc
applicant is sccking to qua[ry for Lifcline as an eligiblc residcnt ofTribal lands, he or she lives
on Tribal lands; (4) if the applicant movcs to a new addrcss, he or shc will providc that new
address to fie Company within 30 days; (5) if the applicant provided a temporary residcntial
address to the Company, ttrc applicant will be rcquired to vcd! his or her tcmporury rcsidential
ad&ess cvery 90 days; (6) thc applicant's houschold will reccive only onc Lifeline sewice and,
to thc best ofthc applicant's knowledge, the applicant's household is not already rcceiving a
Lifelinc sen ice; (4 the information contained in thc applicant's certification fomt is tme and
correct to the h ofthe applicant's knowlcdgc; (8) the applicant acknowledges that prcviding
falsc or fraudulcnt infomration to rcceive Lifeline bcarcfits is punishable by law; and (9) the
applicant acknowledges that the applicant may be requircd to re-oerti! his or her continued
cligibility for Lifcline at any timc, and thc applicad's failure to re<erti$ as to thc applicant' s
continucd eligibility will rcsult in de-cnrollment and the tcrmination of the applicant's Lifeline
bencfits pursuant to thc de+nrollmcnt policy included below and in the Commission's rules.
In addition, the applicurt will be required to authorizc thc Company to access ury rccords
rcquired to verifr thc applicant's statemcnts on the application/certification form and to confirm
the applicant's eligibility for thc Company Lifeline credit The applicant must also authorize thc
Company to releasc any records rcquircd for the adminisfiation of thc Company Lifcline credit
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program, including to USAC to be used in a Lifeline program database.2t
D. Annual Verification Procedurcs
Telrirc will annually re-certi$ all subscribers by querying the apprcpriatc eligibility
databascs or obtaining a signod certification from cach subscriber oonsistent with thc
certification requircments above and new section 54.410(d) of thc Commission's nrles. This
ccrtification will includc a confirmation that the applicant's houschold will receivc only one
Lifeline servioc and, to fte best ofthc subscribcr's knowledge, thc subscriber's household is
rcceiving no more than one Lifeline servioc.2e Thc Company will notify each participating
Lifeline customer annuelly that he or she must confirm his or her continued eligibility in
accordancc with thc applicablc requiremcnts. Further, the verification matcrials will inform the
subsoriber that he or she is being conacted to re-certiff his or her continuing eligibility for
Lifeline and if thc subscribcr fails to respond, he or she will be de-enrolled in thc program.3o
2012 Vcrification. Telritc will re-ccrti$ thc eligibility of each of its cxisting subscribers
as of Jrmc 1,2012 on a rolling besis by the end of 2012 and rcport the results to USAC by
January 31, 2013.31 The Company will contast its subscribers via tc:rt message to their Lifclinc
supported tclephone, or by mail, phone, email or othcr lnternet communication. Thc notic,e will
explain the actions the customer must take to retain Lifelinc benefits, when Lifcline benefits may
be terminated and how to oontact the Company.
28 See Section S+.+O+(b)(9). The application/ccrtification form will also describe the
information that will bc transmittcd, that the information is being transmitted to USAC to
cnsure the proper adminisnation oftlre Lifeline program and 0rat failure to provide
oonsent will result in the applicant being denicd thc Lifeline *wicc, See id.2e See Lifettne Reform Order,\120.30 See id.,.fi 145.3t See id.,'[ l3O.
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Verification De-Enrollment. Telrite will de-enroll subscribers that do not respond to the
annual verification or fail to provide the required ocrtification.32 The Company will send a single
written notice explaining that failure to rcspond to the re-certification request within 30 days will
rcsult in the subscribcr's de+nrollment from thc Lifeline program. If the subscribcr does not
rcspond within the 30 days, the Company will de-enroll the subscriber within five busincss days.
E. Activation and Non-Usage
Telrite will not considcr a prepaid subscriber activatcd and will not scek reimbursement
for Lifeline for that subscriber, until the subscriber activates the Company's prcpaid servicc by a
method established by Telrite. For activation ofa handset provided to a new customer at an
event or "in the field", succcssful applicants are provided a functioning handset and instructed to
dial 770-200-1000 to complete the activation process. Such calls are free ofchargc to the
applicant. To activatc a handset provided to a successful applicant by mail, upon rcceipt ofthe
handseg the applicant must contact Telrite customer senrice at 888-543-3620 or 888-543-36it0 to
activate the servicc. The customer must veriS their last name, date ofbirth and last four digits
oftheir Social Security number. The customer must also veri$ that he or she ordercd the
Lifeline service. The phone is activatcd only aftcr tha vcrification process has bccn completed.
In addition, after servicc activation, the Company will provide a de-enrollmcnt notice to
subscribers that havc not used thcir servicc for 60 days. After 60 days ofnon-use, Telrite will
provide notice to the subscriber that failurc to use the Lifeline service within a 30day notice
period will result in de-cnrollment 33 Subscribers can "usc" thc scrvice by: (l) complcting an
outbomd call; (2) purchasing minurcs from the Company to add to the subscriber's plan; (3)
See id.,fl I42; scction 5a.54.a05(e)(a).
See Lifeline Reform Order, ![ 257; section 54.405(eX3).
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answering an incoming call from a party other than thc Company; or (4) responding to a direct
contact ftom the Company and confirming that the subscriber wants to continue rrc€iving the
service.r
Ifthe subscriber docs not rcspond to the notice, thc subscriber will be dc-cnrolled and
Tclrirc will not requcst furttrer Lifeline reimbunemcnt for the subsctiber. Thc Company will
report annually to the Commission thc number of zubscribcrs de-enrolled for non-usage by
month,35
F. Additional Meesures to Prevent Westg Fraud ond Abuse
To supplement its verification and certification procedurcs, and to bettcr ensurc that
customcrs understand the Lifeline service restictions with rcspect to duplicetes, the Company
will implement measurcs and procedures to prevent duplicaa Lifeline bcnefits being awarded o
the same houschold. Thcsc measures entail additional emphasis in unittcn disclosures as well as
live due diligcnce.
In addition to checking the database whcn it becomcs availablg Company personnel will
emphasize thc "one Lifeline phonc per houschold" restriction in their dircct sales contacts with
potcntial customers. Training materials include a discussion of the limitation to one Lifcline
phone per household, and tho needto ensurc that the customer is informed ofthis rcsEiction.36
Telrite conducts backgound chccks on all Company pcnlonnol intcracting with existing and
potential Lifeline customers and they must pass a complete onboarding proccss that includes I
photo idcntification chcck. All such Company personncl also mdergo training rcgarding the
See Lifeline Reforn Order,l26l; section 54.40(c)(2).
See Lifeline Reform Order,l257: sestion 54.a05(e)(3).
See id.
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eligibility and certification requircments ilntlrc Lifeline Reform Order andthis Compliance Plan.
New Company personncl complete an initial mandatory three-hour taining scssion conducted by
corporate traincrs that arc employees of Telrite wherc they are givcn taining materials, a field
training manual and a compliancc manual, as well as shown visual cxamples of documents
scceptable to demonstratc eligibility for the Lifeline program. These taining documents are
regularly updated to reflect the requirements of the Lifeliw Reform Order ufithis Compliance
Plan, and they arc provided to existing Company pcrsonncl. All Company personnel must have
these manuals with them when conducting enrollment or othcr activities for Telrirc. Fu(her,
Telrite holds weekly compliance udat€s and weekly reAesher/continuing cducation confcrence
calls and all Company personnel have access to a Telrite portal with a largc resource section
containing policies, tips and procedures for Lifcline enrollment.
Telritc also has Compliance and Field Operations teams that invcstigate possible waste,
fraud and abuse by Company personnel or reprcsentatives and either resolve the issues or
escalate them. Solutions can include additional training, deactivation ofcrcdentials, temrination
and possible legal action. To discover potcntial waste, fraud and abuse, the Compliance
Dcpartrnent is rcsponsiblc for tracking and monitoring data entry, orders and bchavior of
Company pcrsonnel engaging in Lifcline enrollments, as well as conducting data audits (tracking
statistics on orders to look for inegularities), customer quality calls, sccret shopping, no-notice
field audits and photo audits (random audits requiring the representative to take a photo ofthe
event set-up). Telrite's Compliance Departnent is itself subject to outside audits by CGM.
Finally, on or before May 4,2012, all Tclrite agents and representatives received a
Training Bulletin and Fraud Policy, whioh Telrirc also filed with the Commission, designed to
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42
remind all Company personnel engaged in enrollment of Lifeline applicants regarding their
obligations to explain the one-per-household restriction to Lifeline applicants.
Database. When the National Lifelinc Accountability Databasc (National Database")
becomes available, Telrite will comply with the requirements of new rule section 54.4M. The
Company will query the National Database to determine whether a prospective subscriber is
cuntntly receiving a Lifeline scrvice from another ETC and whether anyone else living at the
prospective subscribcr's residential address is currently rcceiving Lifeline service.3T
One-Per-Houschold. Telrite will implement the requirements of the Lifelirc Reforn
Order to ensure that it provides only one Lifeline benefit per household38 through the use of its
application and certification forms discussed above, database checks and its marketing materials
discussed below. Upon receiving an application for the Company's Lifeline service, Telrite
validatcs and normalizes the address provided via the MELISSA database and then the namc,
address, date ofbir& and last four digits ofthe Social Security numbcr are entered into Telrite's
intomal duplicate database to ensur€ that it does not already provide Lifeline-supportcd service
37 See Lifeline Reform Order,l203. Company will also transmit to the National Database
the information rcquired for each new and existing Lifeline subscriber, ^See ld.,'l[ 189-
195; section 54.404OX6). Further, Company will updarc each subscriber's information
in the National Database within ten business days ofany change, except for de-
enrollmen! which will be tansmitted within onc business day. See section
54.404(bX8),(r0).
A "household" is any individual or group of individuals who arc living togothcr at the
same address as one economic unit. A household may include relatcd and unrelated
persons. An "economic unit" consists ofall adult individuals contributing to and sharing
in the income and expenses ofa household. An adult is any pcrson eightccn years or
older. If an adult has no or minimal income, and lives with someone who provides
financial support to him/trer, both people shall be considered part ofthe same household.
Children under the age ofeighteen living with their parents or guardians are considered to
be part ofthc same household as their parcnts or guardians. See Lifeline Rcform Order,\
74; section 54.400(h).
17
43
to that indMdual or anothcr person at thc same addrcas.3e If so, and the applicant livcs at an
address with multiple houscholds, the Company will requirc the applicant to completc and
submit a written USAC document containing the following: (l ) an orplanation of the
Commission's onc-per-household rule; (2) a chock box that an applicant can mark to indica&
that he or she tives at an address occupied by multiplo houscholds; (3) a space for the applicant
to oertiry that he or she shares an address with other adults who do not contributc incomc to the
applicant's household and sharc in the houschold's o(pcnscs or bcncfit fiom the applicant's
income, pursuant to tle Commission's dcfinition; and (4) thc penalty for a consmrer's failurc to
make the rcquired one-pcr-houschold cprtification (d,e,, de-enrollment)jo Further, if a subscribcr
pnovides a t8mporary address on his or her application/ccrtification form collected as described
abovc, thc Company will veri$ with the subscriber every 90 days that the subscribcr continues
to r€ly on that addr€ss.4l
In addition, Company pcrsonncl will inform each Lifcline applicant that he or shc may bc
receiving Lifeline support unda anothcr namc, and facilitatc ttre applicant's undcrstanding of
what constitutcs "Lifelinc-supportcd sctrviccs," and ability o detcrminc wtrcther hc or shc is
already bcnefiting from Lifelinc support by informing thc consumer that all Lifelinc services
may not be currently marketod under thc namc Lifclinc. Tclritc elso asks each customcr whethcr
they arc rrceiving Lifeline service from onc of the other major Lifclinc providers in the statc
(e.g:., Safelinh Assunncc). Further, at the timc of c,luollmcnt, Tclritc checks cach applicant
against an int€rnd databosc, as wcll as a poolcd duplicates database established by CGlvL
See Lifelite Reform Order,l78.
&e id. The USAC wortsheet is available at
http /Arww.usac.ore/liltoolVnews/defautrasox#5 82.
tu Lifeliw Reforn Ortur,li9.
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Finally, Telrite will continue to participatc in the In-Depttr Validation process with the
Commission and USAC to locate and address duplicates bcfween ETCs ia various states until the
national database is in place.
Marketinq Materials. Within the deadline provided inthc Lifelbu Reform Order,firc
Company will include thc following infonnation regarding its Lifeline servicc on all marketing
materials describing the service: (l) it is a Lifeline scnice, (2) Lifeline is a govemmcnt
assistance program, (3) the sewice is non-transfcrable, (4) only eligible consumers may enroll in
the prcgram, (5) the pogram is limitod to one discount per houschold; (6) that documenation is
neccssary for cnrollmenB and (7) Tetritc's name (the ETC).42 Thesc statcmenB will be included
in all print" audio video and web matcrials (including social networking mcdia) used to describe
or enroll customqr in thc Company's Lifeline service offering as well as the Company's
application forms and ccrtification forms.43 This specifically includes thc Company's website
(www.lifewiretess.com) ard outdoor signage.44 A sample of the Company's marketing materiats
is included as Exhibit C. In addition, the Company's application/ccrtification form will statc tlut
consumcrs who willfully makc a falsc statoment in order to obtain the Lifeline benefit can bc
punishcd by fnc or imprisonment or can bc barrcd from the program.
G. Company Reimburrcments From the Fund
To ensure that the Company does not scck reimbursement &om the Fund without a
subscribcr's consent, Telrite will ccrtifr, as part of cach reimbursement r€quest, that it is in
complianoe with all of the Commission's Lifeline nrles and, to thc cxtcnt rcquircd, has obtaincd
See Lifeline Relorm O&r,1275; scction 54.405(c).
Id.
Id.
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valid certification and verification forms from each ofthc subscribers for whom it is seeking
reimbursementas Further, thc Company will transition the submission of its FCC Forms 497 to
the cighth day of cach month in ordcr to be reimburscd the sarc month, and inform USAC, to
the odent nec€ssary, to transition its rcimburscment procegs to actual claims rathcr than
projcctcd claims ovcr the couse of morc than one month.6 In addition, the Company will kcep
accuratc rccords as dircctcd by USAC and as requfued by ncw section 54.417 of thc
Commission's rulcs.
H. Annual Company Cortificetionr
Telritc will submit an annual ccrtification to USAC, signcd by a Compeny ofticcr under
pcnalty of pcrjury, that the Company: (l) has policies and procedurcs in placc to rcvicw
consumers' documentation of incom+ and program-based eligibility and cnsurp that its Lifeline
subscribers arc cligible to reccive Lifctine sen ices;a8 121 is in compliurcc with all fcdaal
Lifclinc certifrcation proccdurus;4e and (3) has obtaincd a valid certification form for each
subscribcr for whom thc carricr seeks Lifelinc reimburssrnenls
In addition, thc Company will providc the rcsults of its annual re-
certificationVverifications on an annual basis to the Commission, USAC, thc applicablc state
commission and thc rptcvant Tribal govcmmcnts (for zubscribers residing on Tribal lands).5!
See Lifeline Reform Ot&r,n 128; scction 54.407(d).
&e Lifeliw Relorn Or&r, ffi 302-306.
See id.
See id.,\ 126; section 5a.al5(aXl).
See Lifeliw Refom Order,l|27; scction 54.aK@)(2).
&e scction 54.41 6(a)(3).
See Lilelilu Reform Order,fl13\148: section 54.416@).
20
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Further, as discussed above, the Company will report annuatly to tho Commission the number of
subscribers dc-enrollod for non-usage by month.s2
The Company will also annually report to the Commission, USAC, and r€levant statc
commissions and the r€levant authority in a U.S. tcnitory or Tribal government as appropriatc,s3
the company name, namcs of the company's holding oompmn opcrating oompanics and
affiliates, and any branding (such as a "dba" or brand designation) as wcll as relevant universal
service identifiers for each entity by Study Arca Code.sa The Company will report annually
information regarding the terms and conditions of its Lifeline plans for voice telephony scrvice
offered specifically for low income consumers during the previous year, including the number of
minutcs provided and whether there arc additional charges to the consumcr for scrvice, inctuding
minutes of usc and/or toll catls.5s Finally, t[re Company will annually providc deailed
information rcgarding scrvice outagcs in the prcvious year, the number of complaints received
and ccrtificetion ofcompliance with applicable scrvice quality standards and consum€r
protcction rules, as well as a ccrtification that the Company is able to function in cmaganoy
situations.s
L Cooperation wlth State and Federol Reguhtorc
The Company has cooperaEd and will continue to coopcrato with fedcral and statc
regulators to prcvcnt waste, fraud and abusc. More specifically, thc Company will:
See Lifeltne Reforn Order,n257; section 54.405(c)(3).
See Ltfeltte Reform Order, section 54.422(c).
See Lifeliru Reform Order,ffi296,390; section 54.422(a).
See Lifeltw Reform Order,n390; scction 54.422(b)(5).
See Lilehne Reform Order, I 389 ; s*rton 54.422(bX I X4).
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54
55
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r Make available, upon r€quesq statc-spccific subscribcr dat4 including the names
and addrcsses ofLifeline subscribcrs, to USAC and to each state public utilitics
commission where the Company opcrates for the purpose of determining whether
an existing Lifetine subscribcr rcceives Lifeline service from another carrier;"
. Assist the Commission, USAC, ststc commissiong and othcr ETCs in rtsolving
instances ofduplicativc cnrollmcnt by Lifcline subscriberq including by
providing to USAC and/or any state commission, upon request, the neccssary
information to detcct and rcsolve duplicative Lifeline claims;
o Promptly investigate any notification that it receives from the Commission,
USAC, or a state commission to the effcct 0rat one of its customerc already
receives Lifeline services from another cerrier; and
. Immediately de-enroll any subscriber whom the Company has a reasonable basis
to believest is reoeiving Lifeline-supported service from another ETC or is no
longer eligible - whether or not such information is provided by the Commission,
USAC, or a state commission.
U. Description of Lifeline Senice Olferingsse
Tclrite will offer its Lifcline service in the states where it is desigrratcd as an ETC60 and
throughout the coverage area of its underlfng provider AT&T. The Company's Lifcline
offering in each state where tlre Company has been dcsigrated as an ETC providcs customcrs
with their choice of 125 or 250 anlime prcpaid minutcs per month at no charge. Minutes do not
expire for the 125 minute plan and unused minutes are rolled over to the next month. Unused
minutes for the 250 minute plan do not roll over. Text messaging is available at the rate of:
125 Minute Plan: l/3 minute (i.e., 3 SMS texts pcr voice minutQa
a 250 Minute Plan 1/3 minute (i.a., 3 SMS texts per voice minute)
Thc Company anticipates that the need to providc such information will sunset following
thc implementation of the national duplicatcs database.
See section 54.a05GX1 ).
,See Compliance Plan Public Notice at 3.
Thc Company is currcntly designtcd as an ETC in Arkansas, Illinois, Louisiana, Wcst
Virginia, Rhode Island, Pucrto Rico, Missouri, Maryland, Georgia & Minncsota.
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Lifeline customers can purchase additional bundles of minutes in denominations of
$10.00, $25.00, $4.95, $7.95, $12.95, $2149 and $29.95.6r Airtime, when used for standard
celtular calls, is valued at and will bc decrementcd at thc following rates:
l) $10.00 denomination - $0.099 pcr minute of use;2) S25.00 denomination - $0.0708 per minutc of use;3) $4.95 denomination - I day Unlimited Talk and SMS;4) $7.95 denomination - 3 day Unlimited Talk and SMS;5) $12.95 denomination - I week Unlimited Talk and SMS;6) S21.95 denomination - 2 weeks Unlimited Talk and SMS;7) $29.95 denomination - I month Ualimited Talk and SMS;
Airtime "top-up" minutcs ane available for purchase at the Company's rctail locations, through
any Money C:ranr location and on thc Company's website.62 Additional information regarding
the Company's plans, rates and scrvices can be found on its website: www.lifewiroless.com.
In addition to A,ee voice services, Telrite's Lifeline plan will includo a frec handset and
custom calling fcanlres et no chargc, including Caller ID, Call Waiting, Call Forwarding 3-Way
Calling; Voice Mail, No Roaming chargcs and free access to Customer Care by dialing 6l I from
oustomerc' Life Wireless handsct or by dialing l-888-543-3620 from any wircline phone. All
plans includc domestic long{istanoe at no extra per minute charge. Calls to 9l I cmergency
services are alwaya free, regardless of servicc activation or availability of minurcs.
5t The $29.95 rate for unlimitcd talk and tcxt is available only to Lifc Wtrless customers
that purchasc online or by calling Telrite customcr service. The rctail rate availablc in
stores is $42.95, which is set to be reduced to a yct undet€nnined rate.
Top-up minutes are provided using the PureTalk USA and Pure Unlimited brands, by
Purctalk Holdings, LLC, a sister mmpany of Telrite with common ownerchip, though not
technically an aftiliatc.
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IIL Demonctrstion of Financial and Technicel Capabilities and Cefiifications Required
forETC Designation63
Financial and Technical Capabilitics. Rcvised Commission rule 5a.202(a)(9,a7 C.F.R.
54.202(a)(4), requires carriers petitioning for ETC designation to demonstratc financial and
technical capability to comply with the Commission's Lifcline service requirements.s Thc
Compliancc Plan Public Notioe rcquires that cariers' compliance plan include this
dernonshation. Among the factors the Commission wilt consider are: a carrier's prior offering of
servicc to non-Lifcline subscrib€rs, the length oftimc the carrier has been in business, wiether
the carricr rclies cxclusively on Lifelinc reimbursemcnt to operate, whcthcr the carrier reccives
revcnuos from othcr sources and whsthcr the carricr has becn the subject ofan cnforccrncnt
action or ETC revocation proceeding,
Telritc has bccn offering Lifcline servicc to customcrc since fuober, 2010. Tclrite also
offers scveral other t€leoommunication sewiccs in addition to its Lifeline servicc. In 201 I , thc
wirclinc scrvices offered by Telritc p,roduced subsuntial net income. This rcvonuc was
gcnerated from morc tran 30,000 customcrs ofTelritc's local and long distance servicc, which
Telritc has bccn providing for over l0 ycars. In sum, Telritc has access to suffioient firnds to nrn
its busincss urd is not solcly dependart on rcimbursemcnts ftom the Fund, Tclrite reccntly
entered into a conscnt decree with the Enforconent Bureau relating to an investigation begun in
2004.6s Thc Company has not bcen subject to cnforcemcnt sanctions or ETC revocation
procecdings in any state.
.Sea Compliancc Plan Public Noticc at 3.
See Lifeline Rcform Order,$fr387-388 (rcvising Commission rulc 54202(aX4).
See Tclrite Corporation, File No. EB-05-lH-2348, Ordcr and Consent Dcorec, DA l2-
612 (rcl. Apr. 18,2012).
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63
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SeNice Reouircmen6 Aoplicsble to thc Company's Suoport. The Compliancc Plan
Public Notice requircs carriers to include *certifications required undcr ncwly amended scction
54.202 of thc Commission's rulcs.'ff Telrirc ccrtifics that it will comply with the scnice
rcquirements applicabtc to thc support the Company rcccivcs.6T Telritc provides all ofthe
telecommunications senice supported by the Lifeline program and will make the services
available to all qualifiod consumers throughout the states in which it is designated as an ETC.
The Company's serviccs includc voicc telcphony services that provide voice grade access to the
publio switchcd network or its functional equivalcnt. Furthcr, the Companyls servicc oflerings
provide its customen with minutes of use for local scrvicc at no charge to the customer. The
Company will ofrcr a sct number of minutes of local orchange scrvice fres of charge to is
subscribers. Telrite's cunent Lifcline offerings include packages in Scction II sr,pra that can be
uscd for local and domestic toll service.
The Company also will provide acccss to emorgcrtrcy scrviccs provided by local
govemment or public safety officials, including 9l I and E9l I where available and will oomply
with any Commission requircments regarding E9l l-compatible handsets. As discusscd above,
the Compny will comply with the Commission's fortearance gnnt conditio$ r€lating to the
provision of9l I and E9l I serviccs and handscts.
Finally, Telritc will not provide toll limitation servicc (*TLS"), which allows low income
consumcrs to avoid unexpccted toll charges. Howevcr, since thc Company is a prepaid servicc
providcr, customcrs cannot be disconnectcd for failurc to pay toll chargcs, nor are there
additional charges for excceding their minutes. Furtho, the Company, like most wireless
carriers, does not difrercntiate domestic long distance toll usage from local usage urd all usage is
Compliance Plan Public Notice at 3.
47 C.F.R $ s4.202(axl).
25
6
67
5l
poidfchadvanco. PrrsuattodrclffallruRfurror&r,cubscribcmusuclrecrvioosrrcnot
considcrcd to havsvotrrrtarily otoctod o rpcclvo TIS.fl
IV. C-oucbrion
Tohirc submits fut its Cotrrplirrro Plan fully sdisficc fu oonditiom sot foilh in trc
Commission'e trflUer R&Tt Mp,b Compliancc Phn Public Natoo d fu Ufclirc rulcs.
Accordingly, frc Compy rcryomUy roquctcs ttd ttc Commissio opcditi,oucly ryprovc iu
ComplirocePlan.
Rocpcc,tfully sbmiuod,
JohJ. ttroittann
JosbtuT. Gtt1,m
ItultcyDryc & Warrcn IIF
3050K tucoANlY
Suitc 400
W6hingtoqD.C. 2000?
w)34,24s4
CwwlnTclttu@rytalon
Dcocmbcr 19,2012
6t tuLWrrcRcfu1,rfu,12:lo.
25
52
Life Wireless
Georgia wirelcss Ufelhe Service Applkatlon and CertlflGtion
Tdrtb Corporudon / lr. Wlrchrr
FO Bd 2t'il1 Coftlrd, GA 30015
FAL I-t6rG5110 / EMAILT tlde@el@irtlfi5el[
A complete and signed Lifeline Servlce Application and Certilication ('Certification') is requlred to enroll you in Telrite
Corporation / Life Wireless' Lifeline service program in your state. This Cenification is only for the purpose of verifolng your
ellgibility for Lifeline service and will not be used for any other purpose. Service requests will not be processed untll this
Form has been received and verlfied by company.
One Lif:line sellce per houschold disclosures: Lifellre is a Sovernm.nt assistance progam and wlllfully making f"ls!
st€tements to obtain a Lifeline bencflt can result ln fines, lmprisonmen! de-enrollment ol being barred from the program.
Lif.llnebenefltsarellmitedtoasinglelineofserviceperhousehold. Ahouseholdlsdefined,forpwposesofthetlfelinepro€ram,
as any indlvldual or group of lndlvlduals who lfue together at the same address end share lncome and expenses. A household may
not recelve multiple Lffeline dlscounts. You may apply your Llfeline discount to etther one landllne or one wireless
number, but you cannot have the discount on both and you cannot recelve Lffellne beneflts from multiplc providers. Note
that not all Lifeline services are currently markcted under the name Llfellne. Lifeline is a noFtransfc6ble benefit and you
mey not tmnsfer your bcnefrt to any other person. including another ellglble b$.income consumer, Vlolatlon of the one.per-
household Iimltation constltutes a violadon of the Federal Communicstlons @mmlssion's rules and wlll resuh in your deenrollment
from the program, and potentlalv prosecution by the Unlted Stat6 Gorr€rnment.
O I hlreby certlry that I havc read and undlrstood the dlsclosures listed .bove and that, to the best of my knowledSe,
my household is aot already receMng a Llfeline scrvlce beneflt.
Customer eligiblllty cenlllcatioi: I hcreby certlfy that I partlclpate in at least one ol the followinE protiams (chrd( oncl:
o Supplemental Nutritlon Asslstancc Program (SNAP! O lncomc at or below 135% of FedeEl Poverty Guldellnes
o Sectlon 8 federal Publlc Houslng Assistance (FPHA) o Food Distrlbution Program on lndian R$ervations
O Medicaid (not Medicare) (FOPIR)
o Supplemental Security lncome (ssl) o Bureau of lndlan Affalrs General Asslstance (BlAl
B Temporary Assistance for Needy Fa mllles (TAN F) o Tribally Admlnistercd TANF IrATNF]o Low lncome Home Energy Assistance Program (LIHEAP) o Head Start (meetlnS Income qualifylng standards)
o National School Lunch Program's free lunch program o Senior Citi2en Low lncome Oiscount Offarcd by Loc.l
Gas or Power Company
Trlbel cllgiblllty:o I hereby certtty that I reslde on Federally-recognlzed Trlbal lands.
Customer Application lnformatlon:
Frn Mlddh Name:_ L.st Name:
-
Date of Birth: Month:
-
Dsy:
-
Yerr:
-
Last Four Diglts of Sodal s€curity Number (or Ttlbsl lD Number!:
-
lf QualtfyinS foi lifelin€ by lncome, numb€r of lndMduals ln Housahold: _
Home T.lephone ilumber (ff avallable):
-
Resldenthl Address (P.O. Bor NOT sufncicnt)
Numbcr: _ Apt: _ Strlet_ City
SEte:
-Zlp
Code: _
Address ls (choce one): o Permancnt o TBmporary
Billint Addres (if dlfferent from Residertial Addr.sEl (P.O, Eor lS sufficicntl
Numb€r: _ ADtr _ gtre€t- Clty-
St ta:-Ap
Multlpla households sharlng and address:
o I hereby certify that I reslde at an .ddress occupled by multlple households, lncludlng sdults who do not
contrlbute income to my housrhold and/or share ln my household's expensas, and I will complete a sepatstG
eddltlonal form.
Actlvat,on and usage requlremcnt dlsclosurcs: This servlce is a prepaid scrvlce and you must pcrsonally actlrate it by calling
TlG200-r,[o. To keep your account active, Wu iluct ute your Ltdlnc servla at leo6t onc. durhv ony 80 day Ftod by
@mpletloE an outbound qll putclnslrq odditionol mlnutls fiom @mpany, arcucrlng an lnSound all frcm sonode other thon
53
@mPdnh u oy rasponomg to o otrua Mwcs rfom @mPony aoryrm,ng mot you wnt to conunue ruQtyrng Lrreilnc s"M2 rm
C;ompony. lf your servic€ goes un$ed for 50 days, you will no longer bc eligible for Ufeline benefits and your service will be
suspended (allowin8 only 9U calls and calls to the Compan)r's customer care center) subject to a 30 day cure period during which
you may use the Servic! (as described above) or contact the Company to confirm that you want to continua receiving Ufeline service
from Company.
o I hGreby certlfy that I have read and undcrstood the dlsclosures llst.d aboye retardlng activatlon and usagc
tcqulrcnrGnts.
Authorizationsi
O I hereby authorize the Company to access any records required to verify my statements on this form and to confim my
eliSibility for the Lifeline program. I atso authorize the Compeny to releasc any records rcquired for the administration of th!
Ufeline program (e.9,, name, t€lephone number and address), includinS to the Universal Service Administrative Company, to be
uscd in a Lifeline database and to ensure the proper administratlon ofthe Lifeline Program. Failure to consent will result in
denlal ofservice.
Addltaonal ccrtflcationt: I hereby ceftifu, under penalty of perjury, that (check cach box):
o I meet the income-baed or program-based cliglbillty critcria for receiving Lifeline service and havc provided docum.ntatlon
of €liglbllity if required
o I will notify the Company within 30 days if for any rcason I no lonter satisfy the criteria for receiving Lif.line includlng, as
relevant, if I no longer meet the income-based or program-based eliglbllity criteria, I begln receiving more than one Lifellne
benefit, or another member of my household Is rccelving a Lifcllne benefit, I understand that I may be subject to penalties
if I tail to follow this requlrement
o I am not listed as a dependent on another person's tax return (unless over the a8e of 60)
o The address llsted below is my primary residence, not a second home or business
o lf I move to a ncw address, I will provlde that new address to th€ Company within 30 days
O lf I provlded a temporary r€sldential address to the Company, I will verw my temporary residential address every 90 days
O I acknowled8e that providing false or fraudulent informatlon to receivc Llfeline benefits is punishable by law
O I acknowledt€ that I may be required to re-ceftit my continued eliglblllty for lffeline at any time, and my failure to re-
certifo as to my continued eliglbility within 30 days will result in de-enrollment and the termlnation of my t ifeline benefits
o The lnformation contain€d ln thls certilicatlon form lstrue and correct to the best of my knowledge
AppllcanfssEnatu,es Dttr:
54
Life Wireless Lifeline Service Applicafion
Income Eligibility Worksheet
Individuals in all statcs arc ablc to eololl in thc Ufcline program by demonstrating that tbcir household's annual
incomcisatorbclowl35o/ooftheFederalPovcrtyGuidelines. Thistablcshouldbeusedtodctcmrinewhether
a Lifeline applicant is eligible for Lifclinc service bascd otr the number of individuals in the applicarr's
houschold and thc applicant's household annual incomc:
HOUSEH )LD S1ZE INCOME LEVEL
$ r 5.080
2 s20.426
5 s2s-772
4 s3l^lt8
s16-454
6 $41.810
7 s47.156
s52-502
For each additioml
mmon
Add $5,346
Aopllcante must list t}e number of lndlvlduels In the aoolic.at'r household oo tbe Lifeline eoolication
form. Applicants secking to qualiS for Lifclinc scrvice based on their household income must prcsent one of
the followiog documents in ordcr to prove cligibility:
. thcprioryear's statc, fedcral, orTribal tax r€tum. c1llrent bcome stuernent from an employer orpaycheck stubr a Social Security statcment ofbcnefitso a Vetcraos Adminishtion statcmcnt of bcocfitso a rctircment/pcnsion statemcnt of bcoefitse an Unemployment/Workmen's Compensation statement of beuefitsr Federal or Tribal noticc letter ofparticipation io Gcocnl Assistance. a divorce decrcc, child suppon award, or other official docrunent coDtaining income information
for at lcast thrcc months time
Thls is c Lifdlne gervicc provldcd Telrltc Corponton. LlfdiDc lt s govemmclt $rbt.ncc progr.m. Only otre
Ufelitre servlce is evdl.ble per houscbold, Households rre rot permlfied to rccolve multiplc Ufdlnc benefitr
whethcr they ere fron oue or multiplc companics, wirelers or wlreline. Proof of elBibiltty is rcguirtd for
snroltmcnt rnd only sligiblc cDrtomeB mry enroll in Llfcline service- Congumers who wi[itlgy make falsc
stateEents to obtrlD the betrcfit crn bc punished by llne or rnprfuonment or can be brrcd from the progr.m"
Lifcllne ls a non-trancferable bencfit llfcllne cBtomcrr mry Dot trrnsfer thelr bcnetitr to rny otler pcrson,
55
Ltfe Wreles Customer )ou wlll recefue FREE Mlnutg each
month on your annlvasary date Unused minutes will
rolFoler to the ns<t month and never e<pire as long as
your account remains acti\re Must make at hast one call
each 60 days to keep )rour servlce activer
Life Wireless Features:
B Nationwide Calllng
" Text Messaglng
" Caller lD
* Voicemail
" Rollover Minutes
" Affordable Recharge Plans
. Free 91 I Service
LifeWreless ls a Lifellne supported service, a governm€nt
asslstance progrdm. Only eligible cu5torners may enroll ln
the program. See if yo.r qualiff for a free phone with free
monthly s€rvie! Service ls limited to orE discount per
household consisting d elther wlreline or wireless service.
Forms of documentation necessary for enrollment are llsted
on reverse. Service h non-transftrable.
Welcome!
lfyou n€ed mor€ than the a[otted free minutes each
month, Lifewirel€ss has partnered with Purc Unlimited to
offer you recharge cards in the followlng denomlnatlons.
$10 and $25 Recharge Cards Also Arrallable
at 9.9C per minute and 5Q per text.
recharge ords are amilable in many reoll
oronline at
www.lifewireless.com
$/'ss $12'ss $)1'ts $!2ss
I,'t*rffigdg
RRdECodc7924
We Accept
Purc Unlimited
ectrblishments
56
Things to know:
; Lifdlne benefits are llmited to a single line of seMce per
household.You may not recelve muldple Llfellne or Link
Up discounts You may applypur Lifeline discount to
elther one landllne or onewlreless number, but you
canrxlt have the dlscount on both.
r Customers must present Photo lD and Proof of Beneft to
obtain service.
" To <omplete the aGiyrtlon prfiess you must power
on your phonc and place a call to T7(F2qFl 0O0.
o lf you have further qucstions or concemt Uft Wireless
Customer Service is ready to help. Agcnts are available
7 daysa weekfrom SO0amtoMldnight ESTat
r-888-543-3520
IMPORTANT: consumers who wil]fully rnake a false
statement in orde, to obtain the Ufeline benefit can be
punished byfine or imprisonment or can be baned from
the program.
Gldtc Cdporatlon ls an Bl8lble T.{6communlcaton3
Canbr Erc), dolng busln€ss es Lllo Wrdess.
r*w.ffigdgffi
'B[c' bm&!att'on h ffilotm ara ffirrt.l lilc i*r& pbd otsh lo}mffi
57
Life Wireless is a Lifeline supported swice, a go^/emment assistance program. Only eli-
$ble customers may enroll in the program. See if you quali! for a fiee ptone with free
monthly seruice! SeMce is limfted to one disclurt per household, corsisting of either
wireline or wireless seMc€, Forns of documentation necessary for enrollment are listed
belorr/. Seryice is non-transferable.
Ufe Wreless Features:
' Nationwide Calling
,. Text Messagng
Caller lD
. Voicemail
. Rolloler Minutes
' Affordable Recharge Plans
WITH FREE
MONTHLY
SERVICE!
FREE
PHONE
IMPORTANT: clnsumers
wtro willtully make a false
statement in order to
obtaln the Lifeline benefit
can be punlshed byfine or
amprisonment or can be
baned tom the program.
$10 and $25 Recharge Cards Also Available!
1-888-54{I-3620
,,&- H ffi H @ & ffi
$f2'ss $)1'+s $[2'ss
+l $7'e5
58
9,IIG+,oE'
oLo
E
Loq-
?
-+,oocroolrlJlrl
E,
=EIlrIJ
o?
-+,
o+t
o
Eoo
59
Exhibit C - Telrite's Proposed Lifeline Service Package for Idaho{ XE "Exhibit C -
Telrite's Proposed Lifeline Service Package for Idaho" )
60
Modbly:
o 5(X) voice mimtes
o Unlimited texts od multimodia messaging sorvioe
o 5 GB ofdatar
o SmarQhoae
o Cugtom sallirg feafiuts: Caller ID, Call Waiting Call Forwrding 3-lVay
Calling; and Voicemail.
o Freto eligibbcutmners
Lifeline subscribGrs can add to -' i* basic plan oo a ono-timo basis in my monlh they chooee and
as ofteo as thry wish by solecting additional servic{r). Crnrcnt selectionr incltde:
Trllt: I 0 0 additional minrtres oftalk for $5.00
250 additiood mitrutes oftalkfor $10.fi)
orre day of rmlimited talk for $4.95
Thec days of unlimitedmiiltes for $7.95
One wook ofrmlimitod minutos for $12.95
Tlryo weelc of rmlimited mimrtes $19.95
One mmth ofunlimitod minrt€s $29.95
Drh: 100 GB Data PIN for $5.fi)
These additional scf,rricos can be pur&ased on the www.lifewirslcss.com weboite, froo Lifo
Wireless Customer Service or at any MoneyGrmt locdion,
I 5 CIB is cqrtLgcnt rryon rccoipt of $2.50 nonthly nrypct frorr th, Idatro Tolcphotc Scrvicc
Asist8t c€ Progren. Withow such oryport, tho Lifclino plen would includ€ 4.5 OB.
6l
Exhibit D - List of Current Telrite Key Officers and Management{ XE "Exhibit D - List of
Current Telrite Key Officers and Management" I
62
Msnegement Experienc€
All aspects of Telrite's Liftline operations are directed by a scasoned management teano led by
the following individuals :
RP.McForlcnqCEO
Formed Statacom Telecounnrmications in 2fi)l; merged with Telrite Corporation in 2fl)5
Served as Vice President and Presidetrt ofNetwo* Operations oflecStaruntil 2001
Founded IntraLec Telecomounications in 1999; mergcd with LecStar Corporatiou in 2000
Served as Senior Vice President Network Operations with ILD until 1999
Founded Interlink Communications; merged with ILD Corporation in 1997
Over 10 years with AT&T in various uunagemetrt positions
United States Miliary Veterao
Jim Carpenter, Presldent
President, Life Wireless
Over l0 years' experience with Telrite
Brten Rathman, Vice President of Network Operations
Director of Operations, Telrit€ Corporation
Director of Network Operations, Lectstar Communications
Network Engine€r, LecStar Commrmications
Graduatc ofthe Masters Program ofthe School of Electrical and Computu
Fngrnecrrng at the Georgia Instihrt€ of Techrclogy Q002)
KellyJesel" CFIO
Contoller, Telritc Corporation
Accounting Assistan! ILD Corporation
SeniorAccormtant, Emst and Youog
Graduate of the Masters of Accountancy Program at the University of Georgia (2001)
63
Exhibit E - Officer Certification of Veracity of Facts in Application{ XE "Exhibit E -
Officer Certification of Veracity of Facts in Application" )
64
Exhibit E
Ccrtlllcatlor
STATE OFGEORG]A
COUNTY OF NEIVTON
I, Jirn Curpenter. stat€ lhal I am the President of Telrite Corporation d/b/a Life
Wirelcsr ("Telrits"): that I am authorizcd to makc this Vcrification on bchalf of Tclritq that
I have read the fb,regoing document; and that lhe slatements in the lhrcgoing docun:cnl with
rerpect to l'elrite are trust acsurEle and correct lo the best rrf rny knowledge, inforn:ation and
belief, I declare under pcnalry of pefiury thot the tbregoing is true ord correct,
vision Pruident
Tclrirc Corporation rVb/a Life Wirelcss
4l l3 Monticello $treet
Cor.inglorl Gargia 30014
$
$
$
Subscribed and
Cr,*4.w
sworn lo beforc me lhis
My conrmission enpircs: al n I aU
ofJune 2O22.
65