20230807Application_Redacted.pdf

Lance J.M. Steinhart, P.C.
Attorneys At Law 1725 Windward Concourse Suite 150 Alpharetta, Georgia 30005

Also Admitted in New York Telephone: [phone]
Email: [e-mail] Facsimile: [phone] August 7, 2023
VIA EMAIL DELIVERY TO [e-mail]
Jan Noriyuki Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, Suite 201-A Boise, ID 83714 [phone]
Re: TEMPO TELECOM, LLC
Application for Designation as an Eligible Telecommunications Carrier for the Limited Purpose of Offering Lifeline Service to Qualified Households Dear Ms. Noriyuki:
Please find for filing TEMPO TELECOM, LLC’s Application for Designation as an Eligible Telecommunications Carrier for the Limited Purpose of Offering Lifeline Service to Qualified Households in the State of Idaho.
Please note that Exhibit 7 is marked “CONFIDENTIAL” and contains confidential and proprietary information. Applicant hereby respectfully requests confidential treatment of such information. If you have any questions, or if I may provide you with additional information, please do not hesitate to contact me at [e-mail] or by phone at 770-232-9200. Respectfully submitted,
Lance J.M. Steinhart, Esq.
Managing Attorney Lance J.M. Steinhart, P.C. Attorneys for TEMPO TELECOM, LLC
Attachments
RECEIVED
Monday, August 7, 2023 3:11:41 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CASE NO. TEM-T-23-01
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
TEMPO TELECOM, LLC
Application for Designation as an Eligible Telecommunications Carrier for the Limited Purposes of Offering Lifeline Services to Qualified Households ____________________________________
) )))))))
Case No. ____
APPLICATION

Lance J.M. Steinhart, Esq. Managing Attorney Lance J.M. Steinhart, P.C. 1725 Windward Concourse, Suite 150
Alpharetta, Georgia 30005 [phone] (Phone) [phone] (Fax) E-Mail: [e-mail]

Attorneys for TEMPO TELECOM, LLC

August 7, 2023
TABLE OF CONTENTS I. INTRODUCTION ...............................................................................................................1
II. COMPANY OVERVIEW ...................................................................................................3
III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF WIRELESS ETCS ...............................................................................................................6
IV. TEMPO SATISFIES THE REQUIREMENTS FOR DESIGNATION AS AN ETC UNDER 47 C.F.R. § 54.201 ........................................................................................7
V. TEMPO SATISFIES THE ADDITIONAL REQUIREMENTS FOR ETC
DESIGNATION UNDER 47 C.F.R. § 54.202(a) ..............................................................13
VI. DESIGNATION OF TEMPO AS AN ETC WOULD PROMOTE THE PUBLIC INTEREST .........................................................................................................25
VII. CONCLUSION ..................................................................................................................29

TABLE OF EXHIBITS
Exhibit
Certification ...............................................................................................................1 FCC Compliance Plan................................................................................................2

Coverage Area ...........................................................................................................3 Sample Advertisement ...............................................................................................4
Key Management Bios ...............................................................................................5
Proposed Lifeline Offering ........................................................................................6 Financial Statements ..................................................................................................7

Certificate of Service .................................................................................................8

1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
TEMPO TELECOM, LLC
Application for Designation as an Eligible Telecommunications Carrier for the Limited Purposes of Offering Lifeline Services to Qualified Households ____________________________________
) )))))))
Case No. ____
APPLICATION
I. INTRODUCTION
TEMPO TELECOM, LLC (“TEMPO” or the “Company”), by its undersigned counsel, and
pursuant to Section 214(e)(2) of the Communications Act of 1934, as amended (the “Act”),1
Sections 54.101 through 54.207 of the Rules of the Federal Communications Commission
(“FCC”),2 and the rules and regulations of the Idaho Public Utilities Commission (the
“Commission”), including the Idaho Telecommunications Act of 1988, hereby submits this
Application for Designation as an Eligible Telecommunications Carrier (“ETC”) in the State of
Idaho (this “Application”).

1 47 U.S.C. § 214(e)(2)
2 47 C.F.R. §§ 54.101-54.207.
2
TEMPO seeks ETC designation solely to provide Lifeline service to qualifying Idaho
consumers; it will not (and is not eligible to) seek access to funds from the federal Universal
Service Fund (“USF”) for the purpose of participating in the Link-Up program or high cost
program.3 TEMPO requests that its designation as an ETC include the authority to participate in
and receive reimbursement from the Idaho Telephone Service Assistance Program (ITSAP).
As demonstrated herein, and as certified in Exhibit 1 attached hereto, TEMPO meets all
the statutory and regulatory requirements for designation as an ETC in the State of Idaho, including
the requirements outlined in the FCC’s Lifeline Reform Order,4 Lifeline Modernization Order,5
and Fifth Report and Order.6 Furthermore, TEMPO is positioned to reach unserved and
underserved Lifeline-eligible consumers. Rapid grant of TEMPO’s request, therefore, would
advance the public interest because it would enable the Company to commence much needed
Lifeline services to a wide array of low-income Idaho residents as soon as possible. Accordingly,
the Company respectfully requests that the Commission expeditiously approve this Application.

3 Given that the Company only seeks Lifeline support from the low-income program and does not seek any high-cost support, ETC certification requirements for the high-cost program are not applicable to the Company.
4 In the Matter of Lifeline and Link Up Reform and Modernization, Lifeline and Link Up, Federal-State Joint Board
on Universal Service, Advancing Broadband Availability Through Digital Literacy Training, WC Docket No. 11-42, WC Docket No. 03-109, CC Docket No. 96-45, WC Docket No. 12-23, Report and Order and Further Notice of
Proposed Rulemaking, FCC 12-11 (rel. Feb. 6, 2012) (“Lifeline Reform Order”).
5 In the Matter of Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for
Universal Service Support, Connect America Fund, WC Docket No. 11-42, WC Docket No. 09-197, WC Docket No. 10-90, Third Report and Order, Further Report and Order, and Order on Reconsideration, FCC 16-38 (rel. Apr. 27,
2016) (hereinafter, “Third Report and Order” or “Lifeline Modernization Order”).
6 In the Matter of Bridging the Digital Divide for Low-Income Consumers, Lifeline and Link Up Reform and
Modernization, Telecommunications Carriers Eligible for Universal Service Support, WC Docket No. 17-287, WC Docket No. 11-42, WC Docket No. 09-197, Fifth Report and Order, Memorandum Opinion and Order and Order on Reconsideration, and Further Notice of Proposed Rulemaking, FCC 19-111 (rel. Nov. 14, 2019) (hereinafter, “Fifth Report and Order”).
3
All correspondence, communications, pleadings, notices, orders and decisions relating to
this Application should be addressed to:
Lance J.M. Steinhart, Esq. Managing Attorney Lance J.M. Steinhart, P.C.
Attorneys for TEMPO TELECOM, LLC
1725 Windward Concourse, Suite 150 Alpharetta, Georgia 30005 [phone] (Phone) [phone] (Fax)
E-Mail: [e-mail]
II. COMPANY OVERVIEW
TEMPO is a Georgia limited liability company and provider of commercial mobile radio
service (“CMRS”). TEMPO provides prepaid wireless services throughout the United States, and
prepaid wireless Lifeline services in 21 states,7 by using the underlying wireless networks of Tier
1 carriers (“Underlying Carrier”), currently T Mobile USA, Inc. (“T-Mobile”), on a wholesale
basis. T-Mobile provides TEMPO with the underlying network infrastructure and wireless
transmission facilities needed for TEMPO to offer service as a Mobile Virtual Network Operator
(“MVNO”). TEMPO operates under the “Tempo” or “Tempo Telecom” name throughout the
United States.
TEMPO is a wholly-owned subsidiary of Lingo Management, LLC (“Lingo
Management”), a Delaware limited liability company with a principal office at 25925 Telegraph
Rd., Suite 210, Southfield, Michigan 48033. Lingo Management is a holding company and does
not provide any telecommunications services or hold authorizations from any state authority for

7 These states are: Colorado, Georgia, Hawaii, Indiana, Iowa, Kansas, Kentucky, Maryland, Michigan, Minnesota, Missouri, Nebraska, Nevada, North Dakota, Ohio, Rhode Island, South Carolina, Utah, West Virginia, Wisconsin, and Wyoming.
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the provision of telecommunications services. Lingo Management holds international Section 214
authority on behalf of its operating subsidiaries, but does not provide any services.
B. Riley Principal Investments, LLC (“BRPI”), a Delaware limited liability company, holds
100 percent of Lingo Management.8 BRPI is a holding company with a principal office at 30870
Russell Ranch Road, Suite 250, Westlake Village, CA 91362. BRPI is owned by B. Riley
Financial, Inc., a publicly traded Delaware corporation (NASDAQ: RILY) and diversified
financial services company that takes a collaborative approach to the capital raising and financial
advisory needs of public and private companies and high net worth individuals. Bryant R. Riley,
a U.S. citizen, beneficially owns approximately 20.8 percent of the shares of B. Riley outstanding
as of March 28, 2022. BRPI does not provide telecommunications services or hold authorizations
from any state or federal authority for the provision of telecommunications services.
Lingo Management also is the holding company for the following telecommunications
carriers (the “Lingo Carriers”): Lingo Telecom, LLC (f/k/a Matrix Telecom, LLC); Lingo Telecom
of Virginia, LLC (f/k/a Matrix Telecom of Virginia, LLC); Lingo Telecom of the West, LLC;9
Lingo Communications of Kentucky, LLC; and BullsEye Telecom, Inc. Separate and apart from
its holdings in Lingo Management, BRPI also holds ownership interests in: United Online, Inc.;
YMax Communications Corp.; and magicJack SMB, Inc.
After a proposed transaction described further herein, TEMPO will be 100 percent owned
by Insight Mobile, Inc. (“Insight Mobile”), a Delaware corporation with principal offices located

8 In the Updated Compliance Plan approved on September 21, 2022, BRPI held an 80 percent interest in Lingo
Management and Lingo Communications, LLC (“Lingo”), a Georgia limited liability company held a 20 percent interest in Lingo Management. On February 24, 2023, BRPI acquired Lingo’s 20 percent interest in Lingo
Management, thereby becoming its sole owner. Given that BRPI already held a controlling interest in BRPI, there was not transfer of control.
9 In connection with an internal corporate reorganization expected to occur in the next few months, this entity will be dissolved and its California customers will continue to be served by Lingo Telecom, LLC.
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at 12301 Wilshire Boulevard, Suite 303, Los Angeles, California 90025. Insight Mobile is not
currently providing telecommunications services. Shadi Aslemand, a United States citizen, owns
100 percent of Insight Mobile. Ms. Aslemand is also a 50 percent owner of Excess Telecom, Inc.
(Excess Telecom), a California corporation which operates as a Mobile Virtual Network Operator
(MVNO) and delivers domestic wireless voice services and broadband services to qualified low-
income households nationwide and participates in the Affordable Connectivity Program (“ACP”).
TEMPO will provide affordable prepaid mobile phone service, including calling, text
messaging, and broadband access, along with user-friendly handsets, tablet or hotspot devices.
The Company will not require service contracts from its customers and it will always ensure
competitively low pricing for its services and products. TEMPO will manage all aspects of the
customer experience, including setting service pricing, handset selection, marketing materials, and
customer service. The Company’s prepaid, budget-friendly pricing will give many low-income
consumers the option of having mobile phone service and broadband access without the burden of
hidden costs, varying monthly charges, or contractual commitments. Customers will be able to
customize their TEMPO service to suit their needs with TEMPO’s available bundles of minutes,
broadband data, and text packages to supplement their monthly plan.
TEMPO’s Lifeline customers will depend on, and benefit greatly from, TEMPO’s
inexpensive and flexible pricing plans. TEMPO will not impose credit checks nor will it require
any deposits or contractual commitments. Many Lifeline customers turn to carriers like TEMPO
because they cannot afford the postpaid services provided by traditional wireless carriers. TEMPO
will affirmatively reach out to the low-income sector of the consumer base to offer attractive and
affordable communications options. As such, TEMPO will contribute to the expansion of mobile
wireless and broadband services for low-income consumers in Idaho.
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III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF WIRELESS ETCS
Section 214(e)(2) of the Act provides state public utility commissions with the “primary
responsibility” for the designation of ETCs.10 Although Section 332(c)(3)(A) of the Act prohibits
states from regulating the entry of or the rates charged by any provider of commercial mobile
service or any private mobile service, this prohibition does not allow states to deny wireless carriers
ETC status.11 Under the Act, a state public utility commission with jurisdictional authority over
ETC designations must designate a common carrier as an ETC if the carrier satisfies the
requirements of Section 214(e)(1).
TEMPO recognizes that Section 214(e)(1)(A) of the Act states that ETCs shall offer
services, at least in part, over their own facilities and that Section 54.201(i) of the FCC’s Rules (47
C.F.R. § 54.201(i)) prohibits state commissions from designating as an ETC a telecommunications
carrier that offers services exclusively through the resale of another carrier’s services. However,
the FCC has granted forbearance from enforcement of this facilities requirement to carriers seeking
Lifeline-only ETC designation.12 Section 10(e) of the Act (47 U.S.C. § 160(e)) provides: “[a]
State commission may not continue to apply or enforce any provision of this chapter that the
[Federal Communications] Commission has determined to forbear from applying under subsection
(a) of this section.” As such, the Commission is required by Section 10(e) to act in accordance
with the FCC’s grant of forbearance, and therefore, may not apply the facilities-based requirement
to TEMPO. Therefore, the Commission has the authority under Section 214(e)(2) of the Act to
grant TEMPO’s request for designation as an ETC throughout the State of Idaho.

10 47 U.S.C. § 214(e)(2).
11 USF Order, at 8858–59, ¶ 145.
12 See Lifeline Reform Order at ¶ 368.
7
IV. TEMPO SATISFIES THE REQUIREMENTS FOR DESIGNATION AS AN ETC UNDER 47 C.F.R. § 54.201
Section 254(e) of the Act provides that, “only an eligible telecommunications carrier
designated under section 214(e) shall be eligible to receive specific federal universal service
support.” Section 214(e)(2) of the Act authorizes state commissions, such as the Commission, to
designate ETC status for federal universal service purposes and authorizes the Commission to
designate wireless ETCs.13 Section 214(e)(1) of the Act and Section 54.201(d) of the FCC’s rules
provide that applicants for ETC designation must be common carriers that shall, throughout the
designated service area, offer all of the services supported by universal service, either using their
own facilities or a combination of their own facilities and the resale of another carrier’s services,
except where the FCC has forborne from the “own facilities” requirement. Applicants also must
commit to advertise the availability and rates of such services.14 As detailed below, TEMPO
satisfies each of the above-listed requirements.
A. TEMPO Will Provide Service Consistent with the FCC’s Grant of Forbearance from Section 214’s Facilities Requirements
Although Section 214 requires ETCs to provide services using their facilities, at least in
part, the FCC has forborne from that requirement with respect to carriers such as TEMPO. In the
Lifeline Reform Order, the FCC granted forbearance from the “own-facilities” requirement contained
in Section 214(e)(1)(A) for carriers that are, or seek to become, Lifeline-only ETCs, subject to the
following conditions:15
(1) the carrier must comply with certain 911 requirements [(a) providing its Lifeline
subscribers with 911 and E911 access, regardless of activation status and availability of
minutes; (b) providing its Lifeline subscribers with E911-compliant handsets and replacing,

13 See Federal-State Joint Board on Universal Service, First Report and Order, 12 FCC Rcd 8776, 8858-59, ¶ 145 (1997) (“USF Order”).
14 See 47 U.S.C. § 214(e)(1) and 47 C.F.R. § 54.201(d)(2).
15 See Lifeline Reform Order at ¶¶ 368, 373, and 379.
8
at no additional charge to the subscriber, noncompliant handsets of Lifeline-eligible subscribers who obtain Lifeline-supported services; and (c) complying with conditions (a) and
(b) starting on the effective date of this Order]; and
(2) the carrier must file, and the Bureau must approve, a compliance plan providing specific information regarding the carrier’s service offerings and outlining the measures the carrier will take to implement the obligations contained in this Order as well as further safeguards
against waste, fraud and abuse the Bureau may deem necessary.
TEMPO’s original Compliance Plan, which the FCC approved on August 8, 2012,16 was
filed under the name of Birch Communications, Inc. (“Birch”). Via letter dated December 18,
2012, Birch notified the FCC that the prepaid wireless Lifeline service at issue in the Compliance
Plan would be provided by a separate legal entity known as Now Communications, LLC (“Now
Comm”). The FCC acknowledged these changes in corporate structure in a December 20, 2012
public notice, and confirmed that the previously-approved Compliance Plan applied to Now
Comm.17 After the December 2012 filing, Now Comm changed its name to Tempo Telecom,
LLC. Via letter dated September 17, 2013, TEMPO notified the FCC it would implement and
comply with the previously-approved Compliance Plan and adopt the Compliance Plan as its own.
On July 25, 2022, TEMPO filed its Updated Compliance Plan which the FCC approved on
September 21, 2022.18
TEMPO filed its Second Updated Compliance Plan on April 28, 2023, a copy of which is
attached hereto as Exhibit 2, identifying the transfer of control described herein. TEMPO commits

16 Wireline Competition Bureau Approves the Compliance Plans of Birch Communications, Boomerang Wireless,
IM Telecom, Q Link Wireless, and TAG Mobile, WC Docket Nos. 09-197, 11-42, Public Notice, DA 12-1286 (WCB Aug. 8, 2012).
17 Wireline Competition Bureau Seeks Comment on Petitions for Designation as a Low-Income Eligible Telecommunications Carrier filed by Now Comm, Zing PCS, LTS, Odin Wireless, and TX Mobile, WC Docket No.
09-197, Public Notice (WCB Dec. 20, 2012) (“The Wireline Competition Bureau has approved Birch’s compliance plan, which will also apply to Now Comm.”)
18 Wireline Competition Bureau Approves the Updated Compliance Plan of Tempo Telecom, LLC, WC Docket Nos. 09-197, 11-42, Public Notice, DA 22-991, at 1 (WCB Sept. 21, 2022). See Updated Compliance Plan of Tempo Telecom, LLC, WC Docket Nos. 09-197, 11-42 (filed July 25, 2022), https://www.fcc.gov/ecfs/search/search-filings/filing/107250467828034.
9
to providing Lifeline service in Idaho in accordance with its approved Compliance Plan, including
as it continues to be updated, and in compliance with applicable state and federal regulations, to
the extent amendments thereto may supersede commitments made in the Compliance Plan.
B. TEMPO Is a Common Carrier
CMRS providers like TEMPO are treated as common carriers.19
C. TEMPO Will Provide All Supported Services
Through its Underlying Carrier, TEMPO is able to provide all of the supported services
required by Section 54.101(a) of the FCC’s Rules (47 C.F.R. § 54.101(a)) as follows:
1. Voice Telephony Service
As set forth in 47 C.F.R. § 54.101(a)(1), eligible Voice Telephony Services must provide
the following:
Voice Grade Access to the Public Switched Telephone Network. TEMPO provides
voice grade access to the public switched telephone network (“PSTN”) through the purchase of
wholesale CMRS services from its facilities-based underlying carriers.
Local Usage At No Additional Charge. TEMPO offers rate plans that provide its customers
with minutes of use for local service at no additional charge.
Access to Emergency Services. TEMPO provides 911 and E911 access for all of its
customers to the extent the local government in its service area has implemented 911 or E911
systems. As noted, calls to 911 emergency services will always be free and will be available

19 Implementation of Sections 3(n) and 332 of the Communications Act, Regulatory Treatment of Mobile Services, GN Docket No. 93-252, Second Report and Order, 9 FCC Rcd 1411, 1425 ¶ 37, 1454-55 ¶ 102 (1994) (wireless resellers
are included in the statutory “mobile services” category, and providers of cellular service are common carriers and CMRS providers); 47 U.S.C. § 332(c)(1)(A) (“mobile services” providers are common carriers); see also PCIA
Petition for Forbearance for Broadband PCS, WT Docket No. 98-100, (Memorandum Opinion and Order and Notice of Proposed Rulemaking, 13 FCC Rcd 16857, 16911 ¶ 111 (1998) ("We concluded [in the Second Report and Order] that CMRS also includes the following common carrier services: cellular service, … all mobile telephone services and resellers of such services.") (emphasis added).
10
regardless of service activation status or availability of minutes. TEMPO also complies with the
FCC’s regulations governing the deployment and availability of E911 compatible handsets.
Toll Limitation. In its Lifeline Reform Order, the FCC provided that toll limitation would
no longer be deemed a supported service.20 “ETCs are not required to offer toll limitation service
to low-income consumers if the Lifeline offering provides a set amount of minutes that do not
distinguish between toll and non-toll calls.”21 Nonetheless, TEMPO’s offerings inherently allow
Lifeline subscribers to control their usage, as its wireless service is offered on a prepaid, or pay-
as-you-go, basis. TEMPO’s service, moreover, is not offered on a distance-sensitive basis and
local and domestic long distance minutes are treated the same.
2. Broadband Internet Access Services
So that its Lifeline customers have access to the full amount of Lifeline support, TEMPO
provides broadband Internet access service (“BIAS”) which the FCC has stated consists of the
ability for a user to receive “the capability to transmit data to and receive data from all or
substantially all Internet endpoints, including any capabilities that are incidental to and enable the
operation of the communications service, but excluding dial-up Internet access service.”22
TEMPO provides BIAS to low-income consumers via resale of its Underlying Carrier’s mobile
services.
D. TEMPO Requests Designation Throughout Its Service Area
TEMPO is not a rural telephone company as defined in Section 153(37) of the Act (47
U.S.C. § 153(37)). Accordingly, TEMPO is required to describe the geographic area(s) within
which it requests designation as an ETC. TEMPO requests ETC designation that is statewide in

20 See Lifeline Reform Order at ¶ 367.
21 See id. at ¶ 49.
22 See 47 C.F.R. § 8.2(a).
11
scope to allow the Company to provide Lifeline service wherever its underlying, facilities-based
provider(s) have wireless coverage, including federally recognized tribal lands.23 A current
coverage map is attached hereto as Exhibit 3. TEMPO understands that its service area overlaps
with rural carriers in Idaho, but maintains that the public interest factors described below justify
its designation in these carriers’ service areas, especially because it seeks ETC designation solely
to utilize USF funding to provide Lifeline service to qualified low-income consumers. TEMPO is
not eligible for and does not seek Link-Up or high-cost support.
Therefore, designation of TEMPO as an ETC will cause no growth in the high-cost portions
of the USF and will not erode high-cost support from any rural telephone company. In fact, the
FCC has determined that “[d]esignation of competitive ETCs promotes competition and benefits
consumers in rural and high-cost areas by increasing customer choice, innovative services, and
new technologies.”24 While federal rules (47 U.S.C. §§ 160, 214(e)(5) and 47 C.F.R. § 54.207(b))
require that the service area of an ETC conform to the service area of any rural telephone company
serving the same area (the “service area conformance” requirement), the FCC has authorized
forbearance from the service area conformance requirements with respect to carriers seeking to
provide Lifeline-only service.25 In light of this forbearance, the Commission has the authority to
designate ETCs such as TEMPO in rural areas without concern for the service area conformance
requirement.26

23 The Company requests that the Commission expressly indicate in the ETC designation order that such designation includes federally recognized tribal lands. In accordance with Commission requirements, a copy of this Application
is being sent concurrent with this filing to the tribes identified on the attached Certificate of Service.
24 See Western Wireless Corporation Petition for Designation as an Eligible Telecommunications Carrier in the State
of Wyoming, Memorandum Opinion and Order, 16 FCC Rcd 48, 55 (2000).
25 See In the Matter of Telecommunications Carriers Eligible for Support, Lifeline and Link Up Reform, WC Docket No. 09-197, WC Docket No. 11-42, Memorandum Opinion and Order, FCC 13-44 (rel. April 15, 2013).
26 See 47 C.F.R. § 54.207(c).
12
E. TEMPO Will Advertise the Availability of Supported Services
TEMPO will advertise the availability and rates for the services described above using
media of general distribution as required by 47 C.F.R. § 54.201(d)(2). TEMPO will comply with
the FCC’s rules regarding information to be included in marketing materials, including FCC rule
section 54.405(c).27 TEMPO includes the following information regarding its Lifeline service on
all relevant marketing materials: (1) it is a Lifeline-supported service; (2) Lifeline is a government
assistance program; (3) the service is non-transferable; (4) only eligible consumers may enroll in
the Lifeline program; (5) the Lifeline program is limited to one discount per household; and (6)
documentation is necessary for enrollment in the Lifeline program.28 TEMPO ensures the FCC-
required disclosures, any DBA names it uses, and details of the prepaid wireless Lifeline service
offering are contained in all marketing materials.29 This information is included in all print, audio,
video, website, and electronic materials (including social networking) used to describe or enroll
subscribers in Lifeline service. In addition, the standard application/certification forms developed
by USAC state that consumers who willfully make a false statement in order to obtain the Lifeline
benefit can be punished by fine or imprisonment or can be barred from the program.30
TEMPO publicizes the availability of its prepaid wireless Lifeline service offering in a
manner reasonably designed to reach those likely to qualify the service.31 Specifically, TEMPO
utilizes outreach materials and methods designed to reach households that currently do not have

27 See attached Exhibit 4 for a sample advertisement.
28 47 C.F.R. § 54.405(c).
29 Lifeline Reform Order, ¶¶ 274-282.
30 47 C.F.R. § 54.410(d)(1).
31 47 C.F.R. § 54.405(b).
13
telephone service, has developed advertising materials for non-English speaking populations
within its service area, and coordinates its outreach efforts with relevant government agencies.
TEMPO’s advertising strategy for its prepaid wireless Lifeline service offering builds on
its expertise in advertising its prepaid wireless service, and the advertising used by TEMPO’s
telecommunications carrier affiliates. TEMPO’s advertising for its prepaid wireless Lifeline
service offering includes, but is not limited to, targeted direct mail, advertisements in daily and
weekly print periodicals, billboards, event sponsorship, bus advertising, radio advertising, and
online search engines.
TEMPO intends to coordinate with relevant state agencies, community outreach
organizations, and non-profit organizations to make information available regarding TEMPO’s
prepaid wireless Lifeline service offering in resource guides and other printed materials produced
by those organizations, as well as in their offices or other locations visited by potential Lifeline-
eligible subscribers. In addition, TEMPO intends to market its prepaid wireless Lifeline services
through state, county, municipal and non-profit community action agencies, associations, and
networks. These agencies support Lifeline-eligible individuals and families in obtaining support
services, employment, employment training, life skills training, and other services. TEMPO will
helps raise awareness of Lifeline services through the inclusion of TEMPO Lifeline information
in resource guides and other support materials (online and in printed materials issued by the
agency) that are provided to Lifeline-eligible prospective customers. TEMPO may also raise
awareness of its Lifeline services through sponsoring events held by these agencies.
V. TEMPO SATISFIES THE ADDITIONAL REQUIREMENTS FOR ETC DESIGNATION UNDER 47 C.F.R. § 54.202(a)
TEMPO hereby provides the additional information and certifications required for carriers
seeking ETC designation as set forth in 47 C.F.R. § 54.202(a).
14
A. Service Commitment Throughout the Proposed Designated Service Area
TEMPO will provide service in Idaho by reselling service which it obtains from its
Underlying Carrier whose network is operational and largely built out. Thus, TEMPO will be able
to commence offering its Lifeline service to all locations served by its Underlying Carrier very
soon after receiving approval from the Commission.
In accordance with 47 C.F.R. § 54.202(a)(1)(i), and by the certification attached in Exhibit
1, TEMPO commits to comply with the service requirements applicable to the low-income support
that it receives. Pursuant to 47 C.F.R. § 54.202(a)(1)(ii), a common carrier seeking designation as
a Lifeline-only ETC is not required to submit a five-year network improvement plan as part of its
Application for designation as an ETC.
B. Ability to Remain Functional in Emergency Situations
In accordance with 47 C.F.R. § 54.202(a)(2), TEMPO has the ability to remain functional
in emergency situations. TEMPO has been offering telecommunications services since 2012, and
its affiliates have been offering telecommunications services since at least 1996. Thus, TEMPO
and its affiliated telecommunications carriers have significant experience with remaining
functional in emergency situations. TEMPO has disaster recovery contingency plans that include
diverse/alternate routing, electronics redundancy, dual data centers geographically separated, and
environmental controls for data and switching centers. TEMPO’s MVNO contract arrangements
with T-Mobile also impose certain obligations on T-Mobile to ensure TEMPO’s prepaid wireless
Lifeline service offering remains functional during emergency situations. As a large, nationwide
wireless carrier, T-Mobile is subject to regulatory requirements to remain functional during
15
emergency situations.32 TEMPO’s MVNO agreements also contain certain quality of service
guarantees.
C. Commitment to Consumer Protection and Service Quality
In accordance with 47 C.F.R. § 54.202(a)(3), an ETC applicant must demonstrate that it
will satisfy applicable consumer protection and service quality standards, and wireless applicants
may satisfy this requirement with a commitment to comply with the Cellular Telecommunications
and Internet Association’s (“CTIA”) Consumer Code for Wireless Service. TEMPO hereby
commits to comply with the CTIA Consumer Code for Wireless Service.
D. TEMPO is Financially and Technically Capable
In accordance with 47 C.F.R. § 54.202(a)(4), TEMPO is financially and technically capable
of providing Lifeline-supported services. TEMPO has successfully operated as a wireless reseller
since 2012 and has been providing Lifeline services since 2013. TEMPO’s affiliates have been
operating as nationwide competitive local exchange carriers since at least 1996. TEMPO has
never been subject to an ETC revocation proceeding in any state.
With respect to technical expertise, TEMPO has demonstrated its technical capabilities
over the past 10 years of successful operation. Further, TEMPO’s partnerships with nationwide
wireless carriers such as T-Mobile demonstrates TEMPO is technically capable of providing
prepaid wireless Lifeline service.
Pursuant to a Membership Interest Purchase Agreement dated January 24, 2023, Lingo
Management and Insight Mobile have agreed that, subject to regulatory approval, Lingo
Management will transfer 100 percent of the outstanding membership interests in TEMPO to

32 TEMPO is also familiar with the continuity and disaster response program T-Mobile has implemented, which addresses the need to remain functional during emergency situations.
16
Insight Mobile (the “Transaction”). Financial support for TEMPO’s continued operations will be
enhanced by the Transaction. Following the proposed change in TEMPO’s ownership, the
Company’s corporate and trade names and identifiers initially will remain unchanged, and any
future changes to the Company’s name will comply with relevant laws governing customer
notices. The Transaction will not result in any loss or impairment of service for any customer, and
customers will continue to receive their existing services at the same rates, terms and conditions
currently in effect.
Upon approval of the change in ownership, Insight Mobile’s management team will be
responsible for day-to-day oversight of TEMPO’s operations. However, the parties contemplate
that TEMPO’s employees who are currently responsible for the Company’s Lifeline service
business will maintain their positions under Insight Mobile’s ownership. Insight Mobile’s
management team has extensive experience in the telecommunications and technology industries,
as well as in the Lifeline services market. Their collective expertise will guide the Company’s
decisions going forward.33 As a result, the Transaction will bring together the full strength of
TEMPO’s and Insight Mobile’s experience in the telecommunications industry and business
expertise. The resulting synergies will enable TEMPO to achieve measurable growth at the same
time as it develops improved operating efficiencies, both necessary components for the Company
to thrive. Moreover, with access to Insight Mobile’s financial and technical resources, TEMPO
will be able to offer enhanced service offerings to all current and future end users, including those
who are enrolled in the Lifeline program.

33 See Exhibit 5 for key management bios.
17
E. Terms and Conditions of Proposed Lifeline Offering
TEMPO has the ability to provide all services supported by the universal service program,
as detailed in 47 C.F.R. § 54.101(a), throughout Idaho. TEMPO commits that its Lifeline-
supported voice services will meet or exceed the minimum service standards set forth in 47 C.F.R.
§ 54.408, including as such standards are updated going forward. TEMPO’S Lifeline-supported
broadband services will also meet the minimum service standards set forth in 47 C.F.R. § 54.408
for mobile broadband internet access services, including for service speed and data usage
allowance, as such standards are updated going forward. To the extent TEMPO provides devices
for use with Lifeline-supported broadband service, such devices will meet the equipment
requirements set forth in 47 C.F.R. § 54.408(f), and TEMPO will not impose an additional or
separate tethering charge for mobile data usage below the minimum standard.
Attached hereto as Exhibit 6 is a summary table of the Company’s “Lifeline Data Bundle”
plan, which offers unlimited nationwide voice minutes, voicemail, unlimited nationwide text
messages, and 4.5 gigabytes (“GB”) of data each month (15 GB data for Tribal residents) at no
charge to an eligible consumer after application of Lifeline and ITSAP support. In addition,
TEMPO offers consumers the ability to purchase additional data at reduced rates (plus applicable
taxes and fees).
In addition to wholly-supported or discounted wireless services, prepaid Lifeline customers
will receive access to voicemail, caller ID and call waiting features at no additional charge. All
plans will include nationwide domestic long-distance at no extra per-minute charge, and TEMPO
will not assess any usage for access to its free customer services (611). Emergency (911) calls
will be free, regardless of service activation or availability of minutes, and will not count against
the customer’s airtime. The Company’s Lifeline offering will provide feature-rich mobile
connectivity for qualifying subscribers without the burden of credit checks or service contracts.
18
TEMPO’s prepaid offering will be an attractive alternative for consumers who need the mobility,
security, and convenience of a wireless phone, but who are concerned about usage charges or long-
term contracts.
F. TEMPO Will Comply with the Lifeline Certification and Verification
Requirements
TEMPO has been offering Lifeline services for nearly 10 years, and is therefore intimately
familiar with the procedures for confirming consumer eligibility, enrolling eligible customers,
recertification, activation, and usage.
Consumer Eligibility
TEMPO has implemented detailed policies and procedures to ensure its Lifeline customers
are eligible to receive Lifeline service. TEMPO does not provide Lifeline service – and does not
provide an activated device – to any consumer until TEMPO has confirmed the consumer meets
the eligibility requirements established by the FCC for receipt of Lifeline services.34 Specifically,
a consumer must meet one of the following requirements to be eligible for Lifeline service: (1) the
consumer’s household income is at or below 135 percent of the Federal Poverty Guidelines
currently in effect for a household of that size; or (2) the consumer (or the consumer’s dependents
or household) receives benefits from certain federal assistance programs.35 TEMPO relies solely
on the National Lifeline Eligibility Verifier (“Lifeline National Verifier”) for establishing a
prospective customer’s eligibility for Lifeline service.36

34 47 C.F.R. § 54.409.
35 47 C.F.R. § 54.409(a). TEMPO also complies with any state-specific eligibility requirements.
36 The Lifeline National Verifier also collects any needed documentation from the prospective customer.
19
Enrollment
Prospective Lifeline customers can contact TEMPO via its website or toll-free customer
service number to start the process of receiving Lifeline services from TEMPO.37 TEMPO relies
on the USAC-standard application and certification form, and thus TEMPO’s processes comply
with FCC rules for subscriber eligibility determinations and certifications.38 If the customer has
not pre-qualified via the Lifeline National Verifier, TEMPO first directs the customer to the
Lifeline National Verifier so the customer can confirm its eligibility for Lifeline service and obtain
an approved application ID from the Lifeline National Verifier.
Once the customer’s eligibility has been confirmed by the Lifeline National Verifier (and
the customer has obtained an approved application ID), TEMPO takes two additional steps to
prevent duplicate Lifeline subsidies. First, TEMPO reviews its own service records to ensure the
potential customer is not currently receiving Lifeline service from TEMPO. Second, TEMPO
checks the National Lifeline Accountability Database (“NLAD”) to ensure the potential customer
is not currently receiving a Lifeline service from any other carrier.39 When applicable, TEMPO
requires the prospective customer to complete the Independent Economic Household Worksheet
via the Lifeline National Verifier. This USAC-developed form contains the following: (1) an
explanation of the FCC’s one-per-household rule; (2) a check box that an applicant can mark to
indicate that he or she lives at an address occupied by multiple households; (3) a space for the
applicant to certify that he or she shares an address with other adults who do not contribute income

37 At this time, TEMPO is not using third-party dealer locations to sign-up prospective Lifeline customers. In the
future, prospective customers may be able to begin the process of receiving Lifeline services from TEMPO via a third-party dealer location.
38 47 C.F.R. § 54.410. TEMPO representatives also orally explain the application and certification form to potential Lifeline customers if they choose to enroll over the phone.
39 TEMPO also commits to promptly investigate any notification it receives from a state, the FCC, or USAC that one of its Lifeline customers is improperly receiving service.
20
to the applicant’s household and share in the household’s expenses or benefit from the applicant’s
income, pursuant to the FCC’s definition; and (4) the penalty for a consumer’s failure to make the
one-per-household certification when required.
Once TEMPO has confirmed there is no duplicate service, TEMPO enrolls the customer
in the Lifeline program using NLAD’s real-time interface (API), and submits all required
information regarding the customer to NLAD.40 TEMPO does not enroll or claim reimbursement
for a prospective customer if NLAD or the Lifeline National Verifier cannot verify the identity of
the prospective customer or the prospective customer’s status as non-deceased.41
Any TEMPO representatives involved in the Lifeline enrollment process (both in-house
and third-party)42 are required to engage in initial and ongoing training regarding Lifeline rules
and must be registered with USAC prior to enrolling any customer in NLAD.43 TEMPO also
conducts periodic audits and random checks of its Lifeline representatives to ensure compliance
with FCC rules. TEMPO does not offer or provide any commission or other compensation to
enrollment representatives based on the number of consumers that apply for or are enrolled in the
Lifeline program.44
Annual Verification
TEMPO’s systems are capable of tracking and flagging the anniversary of a Lifeline
customer’s start date. TEMPO uses the anniversary date to ensure its Lifeline customers re-certify

40 In addition, TEMPO updates each subscriber’s information in NLAD within ten (10) business days of any change,
except for de-enrollment, which is updated within one (1) business day. See 47 C.F.R. § 54.404(b)(8), (10).
41 47 C.F.R. § 54.404(b).
42 At this time, TEMPO does not utilize third-party dealers to enroll prospective customers in the Lifeline program, but could do so in the future.
43 47 C.F.R. § 54.406.
44 47 C.F.R. § 54.406(b).
21
their eligibility to participate in the Lifeline program once a year. TEMPO Lifeline customers are
re-certified within 12 months after the subscriber’s service initiation date and within every 12
months thereafter by the Lifeline National Verifier as required under FCC rules.45 The annual re-
certification materials inform the subscriber it is being contacted to re-certify continuing eligibility
for Lifeline, and if the subscriber fails to respond, it will be de-enrolled from the program as
discussed below.
Activation and Usage
Once all eligibility determinations and documentation requirements are complete, TEMPO
ships the free SIM card or purchased handset, whichever is applicable, to the customer at the
address listed on the enrollment form.46 TEMPO requires the customer to take affirmative steps
to “personally activate” the service by requiring the customer to complete an outgoing call.47 If
service is not initiated, TEMPO does not consider the consumer to be enrolled in the Lifeline
program and TEMPO does not request Lifeline reimbursement until the subscriber personally
activates its service.48 After service activation, TEMPO does not seek reimbursement for any
Lifeline subscriber who has not used the service consistent with FCC usage requirements.49
G. Prevention of Waste, Fraud and Abuse
TEMPO has procedures in place to prevent waste, fraud, and abuse. As discussed above,
TEMPO prevents waste, fraud, and abuse by relying upon the Lifeline National Verifier and
NLAD to ensure applicants are eligible and not duplicative. Further, TEMPO de-enrolls Lifeline

45 47 C.F.R. § 54.410(f).
46 If TEMPO were to use third-party dealers in the future, the third-party representative may provide the handset or
SIM card to the customer during an in-person enrollment depending on availability.
47 Lifeline Reform Order ¶ 260.
48 Lifeline Reform Order ¶ 257.
49 47 C.F.R. § 54.407(c)(2).
22
customers in accordance with FCC rules for: no longer qualifying for Lifeline service; duplicative
support; non-usage; failure to re-certify; and when requested by the Lifeline subscriber. As
required by the FCC’s rules, TEMPO updates NLAD with de-enrollment information within one
(1) business day of de-enrollment.50
De-Enrollment for Ineligibility
If TEMPO has a reasonable basis to believe that one of its Lifeline customers no longer
meets the eligibility criteria (either based on TEMPO’s own knowledge or information supplied
by a third-party), TEMPO notifies the subscriber of the impending de-enrollment in writing and
gives the subscriber thirty (30) days to demonstrate continued eligibility.51 Any demonstration of
eligibility from the subscriber must comply with the annual re-certification procedures set forth in
the FCC’s rules, including the submission of the USAC-created enrollment/certification form. A
subscriber’s failure to provide the requested documentation will result in de-enrollment within five
(5) business days after the expiration of the subscriber’s time to respond.
De-enrollment for duplicative support
TEMPO understands that duplicative claims are wasteful and burden universal service and
takes all necessary steps to swiftly de-enroll consumers found to be receiving duplicative federal
Lifeline discounts. Upon notification from the FCC, a state, or USAC that a subscriber is receiving
Lifeline service from another carrier, or more than one member of a household is receiving Lifeline
service, TEMPO de-enrolls the subscriber within five (5) business days.52

50 47 C.F.R. § 54.404(b)(10).
51 47 C.F.R. § 54.405(e)(1).
52 47 C.F.R. § 54.405(e)(2).
23
De-enrollment for non-usage
TEMPO de-enrolls any Lifeline customer whose service is inactive for a consecutive 30-
day period after providing the customer with notice and a 15-day “cure” period.53 After 30
consecutive days of non-usage (as defined in FCC rules), TEMPO provides subscribers notice,
using clear, easily understood language, to inform the subscriber that its failure to use the Lifeline
service within the next 15 days will result in service termination on the 46th day (30 days of non-
usage plus the 15-day “cure” period).54 TEMPO will continue to comply with its existing public
safety obligations to transmit all 911/E911 calls regardless of subscriber inactivity even if TEMPO
is no longer providing Lifeline service to that consumer.55 TEMPO understands that it can only
seek reimbursement for any subscriber that has used its Lifeline service within the last 30 days or
who has cured its non-usage as described above.56
De-enrollment for failure to re-certify
TEMPO de-enrolls subscribers who do not respond to an annual re-certification request or
fail to provide the required certification to the Lifeline National Verifier,57 which is the entity
responsible for annual re-certification of a subscriber’s Lifeline eligibility. Prior to de-enrolling a
subscriber for failure to re-certify, subscribers receive written notice explaining that failure to
respond to the re-certification request within sixty (60) days will result in the subscriber’s de-

53 47 C.F.R. § 54.405(e)(3). TEMPO provides the customer with notice via text message on day 7, day 14, and day 28 that failure to use the Lifeline service may result in service termination.
54 TEMPO provides the customer with notice via text message on day 30, day 35, and days 40-44 that failure to use the Lifeline service may result in service termination. TEMPO then provides the customer with notice via text message
on day 45 that the service will be disconnected for non-usage.
55 Lifeline Reform Order, ¶ 262.
56 47 C.F.R. § 54.407(c)(2).
57 47 C.F.R. § 54.405(e)(4).
24
enrollment. TEMPO de-enrolls the subscriber within five (5) business days after the expiration of
the subscriber’s time to respond.
De-Enrollment by Subscriber
If a subscriber contacts TEMPO and states the subscriber is no longer eligible for Lifeline
or wishes to de-enroll for any reason, TEMPO de-enrolls the subscriber within two (2) business
days.58 Subscribers can make this request either via customer service or online.
H. TEMPO Will Comply With Reporting Requirements
TEMPO will provide the Commission a copy of its annual reports and certifications
pursuant to 47 C.F.R. § 54.416 (i.e., FCC Form 555) and 47 C.F.R. § 54.422 (i.e., FCC Form 481),
and will comply with applicable Commission reporting requirements for Lifeline ETCs.
I. TEMPO Will Comply With Regulations Imposed By The Commission By this Application, TEMPO hereby asserts its willingness and ability to comply with all
the rules and regulations that the Commission may lawfully impose upon the Company’s provision
of service contemplated by this Application. TEMPO commits to comply with applicable ITSAP
regulations, including but not limited to required monthly reporting, as well as execution of a
Memorandum of Understanding with the Department of Health and Welfare. TEMPO further
commits to remit required ITSAP funds to the ITSAP Administrator. Upon Commission request,
TEMPO is prepared to answer questions or present additional testimony or other evidence about
its services within the state.
As the Company is not seeking high-cost support for its wireless service, it hereby requests
a waiver of the Commission Rules, Commission Order No. 29841 Section B.1 (two-year network

58 47 C.F.R. § 54.405(e)(5).
25
improvement and maintenance plan based on high-cost support). Because the Company is not
seeking high-cost support, this rule is not applicable and therefore should be waived.
TEMPO commits that 100% of federal universal service funds will flow through directly
to Lifeline customers.
VI. DESIGNATION OF TEMPO AS AN ETC WOULD PROMOTE THE PUBLIC INTEREST
One of the principal goals of the Act, as amended by the Telecommunications Act of 1996,
is “to secure lower prices and higher quality services for American telecommunications consumers
and encourage the rapid deployment of new telecommunications technologies” to all citizens,
regardless of geographic location or income.59 Designation of TEMPO as an ETC in Idaho will
further that public interest. Whether because of financial constraints, poor credit history, or
intermittent employment, many low-income consumers often lack the countless choices available
to most consumers and thus have yet to reap the full benefits of the intensely competitive wireless
market.
The instant request for ETC designation must be examined in light of the Act’s goal of
providing low-income consumers with access to telecommunications services. The primary
purpose of universal service is to ensure that consumers—particularly low-income consumers—
receive affordable and comparable telecommunications services. The FCC has in recent years
expanded the Lifeline program to cover broadband services, noting that “Only half of all
households in the lowest income tier subscribe to a broadband service and 43 percent say the
biggest reason for not subscribing is the cost of the service,” and “Of the low income consumers
who have subscribed to mobile broadband, over 40 percent have to cancel or suspend their service

59 Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56.
26
due to financial constraints.”60 Given this context, designating TEMPO as an ETC would
significantly benefit low-income consumers eligible for Lifeline services in Idaho—the intended
beneficiaries of universal service.
A. Advantages of TEMPO’s Service Offering
TEMPO offers an easy to use, competitive, and highly affordable wireless
telecommunications service, which benefits qualified consumers who either have no other service
alternatives or who choose a wireless prepaid solution in lieu of more traditional service. The
public interest benefits of TEMPO’s wireless service include larger calling areas (as compared to
traditional wireline carriers), the convenience and security afforded by mobile service, and a
generous amount of voice and broadband access included without cost (after application of the
Lifeline and ITSAP support), as well as free access to caller ID, call waiting, and Voicemail
features, and access to 911 services regardless of the number of voice minutes remaining on the
Lifeline consumer’s plan. These no cost to consumer services and low-cost minutes are an
invaluable resource for cash-strapped consumers, and the prepaid nature of the service also
provides an alternative for “unbanked” consumers. TEMPO’s prepaid wireless service is likely to
be an especially attractive option for low-income consumers because it alleviates customer
concerns regarding hidden costs, varying monthly charges and long-term contract issues.
In today’s market, consumers, including qualified Lifeline customers, view the portability
and convenience of wireless service not as a luxury, but as a necessity. Mobile service allows
children to reach their parents wherever they may be, allows a person seeking employment greater
ability to be contacted by potential employers, and provides end users with the ability to contact
emergency service providers regardless of location. Mobile service often also serves as a key

60 See Lifeline Modernization Order ¶ 2.
27
bridge in closing the homework gap for students who live in rural areas with limited access to
broadband.
Without question, prepaid wireless services have become essential for low-income
customers, providing them with value for their money, access to emergency services on wireless
devices, and a reliable means of contact for prospective employers, social service agencies or
dependents. Providing TEMPO with the authority necessary to offer discounted Lifeline service
to those without wireless service—or most in danger of losing service altogether—undoubtedly
promotes the public interest.
B. The Benefits of Competitive Choice
The FCC has acknowledged the benefits to consumers of being able to choose from among
a variety of telecommunications service providers for more than three decades.61 Increasing
customer choice promotes promote competition and innovation, thus spurring other carriers to
target low-income consumers with service offerings tailored to their needs, ultimately resulting in
improved services to consumers. Designation of TEMPO as an ETC will help ensure that quality
services are available at “just, reasonable, and affordable rates” as envisioned in the Act.62
Introducing TEMPO into the market as an additional wireless ETC provider will afford low-
income Idaho residents a wider choice of providers and available services while creating a
competitive marketplace as ETCs compete for a finite number of Lifeline-eligible customers.
Increasing the competitive marketplace of providers has the potential to effectively increase the
penetration rate and reduce the number of individuals not connected to the PSTN.

61 See, e.g., Specialized Common Carrier Services, 29 FCC Rcd 870 (1971).
62 See 47 U.S.C. § 254(b)(1).
28
C. Impact on the Universal Service Fund
With Lifeline, ETCs only receive support for customers they obtain. The amount of
support available to an eligible subscriber is exactly the same whether the support is given through
a company such as TEMPO or the Incumbent LEC operating in the same service area. The number
of persons eligible for Lifeline support is the same regardless of the number of ETCs; thus, TEMPO
will only increase the amount of USF Lifeline funding in situations where it obtains Lifeline
customers not already enrolled in another ETC’s Lifeline program. By implementing the
safeguards set forth in the Lifeline Reform Order and utilizing the NLAD and National Verifier,
the likelihood that TEMPO’s customers are not eligible or are receiving duplicative support either
individually or within their household is greatly minimized. TEMPO’s ability to increase the
Lifeline participation rate of qualified low-income individuals will further the goal of Congress to
provide all individuals with affordable access to telecommunications service, and thus any
incremental increases in Lifeline expenditures are far outweighed by the significant public interest
benefits of expanding the availability of affordable wireless services to low-income consumers.

29
VII. CONCLUSION
Based on the foregoing, designation of TEMPO as an ETC in the State of Idaho accords
with the requirements of Section 214(e)(2) of the Act and is in the public interest.
WHEREFORE, TEMPO respectfully requests that the Commission promptly designate
TEMPO as an ETC in the State of Idaho for the purpose of participating in the Lifeline and ITSAP
programs.
Respectfully submitted,
/s/Lance J.M. Steinhart ______________________________
Lance J.M. Steinhart, Esq.
Managing Attorney Lance J.M. Steinhart, P.C. 1725 Windward Concourse, Suite 150 Alpharetta, Georgia 30005
[phone] (Phone)
[phone] (Fax) E-Mail: [e-mail]
Attorneys for TEMPO TELECOM, LLC
August 7, 2023

EXHIBIT 1

Certification

STATE OF TEXAS )
)
COUNTY OF DALLAS )

I, Alex Valencia, Chief Compliance Officer of TEMPO TELECOM, LLC, hereby state upon
oath and affirmation of belief and personal knowledge that the matters, facts and statements set
forth in the foregoing Application are true to the best of my knowledge and belief.

__________________________________
Alex Valencia, Chief Compliance Officer
TEMPO TELECOM, LLC

EXHIBIT 2
FCC Compliance Plan

April 28, 2023
Via ECFS
Marlene H. Dortch
Secretary
Federal Communications Commission
Office of the Secretary
45 L Street, NE
Washington, DC 20554
RE: Tempo Telecom, LLC Second Updated Compliance Plan - Acquisition by Insight
Mobile, Inc.; WC Docket Nos. 09-197, 11-42
Dear Ms. Dortch:
On July 25, 2022, Tempo Telecom, LLC (“Tempo” or the “Company”) filed its Updated
Compliance Plan for wireless Lifeline services, outlining the measures it would take to comply
with the Federal Communications Commission’s (“Commission’s”) Lifeline rules. The Wireline
Competition Bureau (“Bureau”) approved the plan on September 21, 2022.1 Enclosed, on behalf
of Tempo and Insight Mobile, Inc. (“Insight Mobile”), is Tempo’s Second Updated Compliance
Plan. Tempo is revising its approved Updated Compliance Plan to reflect a transaction,
described in more detail in the Second Updated Compliance Plan, whereby Insight will acquire
100 percent ownership and control of Tempo. Tempo and Insight Mobile respectfully request
that the Bureau expeditiously approve the Second Updated Compliance Plan.

1 Wireline Competition Bureau Approves the Updated Compliance Plan of Tempo Telecom, LLC,
WC Docket Nos. 09-197, 11-42, Public Notice, DA 22-991 (Sept. 21, 2022). Tempo’s
Compliance Plan originally was filed in 2012 under the name of Birch Communications, Inc.
(“Birch”) in support of Birch’s request to be designated as an ETC by the Commission. The
Commission approved the Compliance Plan on August 8, 2012. See Wireline Competition
Bureau Approves the Compliance Plans of Birch Communications, Boomerang Wireless, IM
Telecom, Q Link Wireless, and TAG Mobile, Public Notice, DA 12-1286 (Aug. 8, 2012).

Marlene H. Dortch
April 28, 2023
Page 2

Current Tempo Operations

As discussed in the Second Updated Compliance Plan, Tempo operates, or is authorized
to operate (insofar as required), as a Mobile Virtual Network Operator in 21 states, providing
prepaid commercial mobile radio services to consumers utilizing the wireless networks of its
underlying facilities-based providers. The Company is designated as an eligible
telecommunications carrier (“ETC”) to provide Lifeline services to low-income consumers on a
wireless basis in 21 states, and does not have ETC applications pending in any states.

Insight Mobile Transaction

Tempo is currently 100 percent owned by Lingo Management, LLC (“Lingo
Management”). Pursuant to a Membership Interest Purchase Agreement (the “Agreement”),
dated January 24, 2023, Lingo Management and Insight Mobile have agreed that Lingo
Management will transfer 100 percent of the outstanding membership interests in Tempo to
Insight Mobile (the “Transaction”).2 The Transaction will be closed as soon as required
regulatory approvals are obtained and other pre-closing conditions satisfied or waived.
Following the consummation of the Transaction, Tempo will be a direct wholly-owned
subsidiary of Insight Mobile.

Insight Mobile is a Delaware corporation with principal offices located at 12301 Wilshire
Boulevard, Suite 303, Los Angeles, California 90025. Insight Mobile holds international Section
214 authority from the Commission to provide global facilities-based and resale service, but is
not currently providing telecommunications services. The acquisition of Tempo by Insight
Mobile, as contemplated by the Agreement, will benefit consumers throughout Tempo’s current
and future operating territories. Insight Mobile is financially strong and is directly managed by a
hands-on team which brings significant experience in the telecommunications and technology
industries, as well as in the Lifeline services market. Insight Mobile’s extensive
telecommunications experience and financial resources will be available to Tempo as it
continues to grow and develop its business. This will facilitate improvements to Tempo’s
operating efficiency, financial management, and strategic decision-making. As a result, Tempo
will be able to compete more effectively in the wireless and broadband market sectors. At the
same time, the Transaction holds no adverse effects for consumers as it will not lead to any loss
of or reduction in services to Tempo’s customers, nor will it result in any change to the rates,
terms and conditions associated with those services.3

2 The January 24, 2023 Agreement was entered between Lingo Management and another
company. However, pursuant to an assignment and assumption agreement between that
company and Insight Mobile dated April 5, 2023, Insight Mobile is now the purchaser.
3 Future changes to Tempo’s service offerings and/or the rates, terms and conditions applicable
to those offerings will be implemented consistent with applicable regulatory requirements.

Marlene H. Dortch
April 28, 2023
Page 3

This letter and attached Second Updated Compliance Plan are being filed electronically
for inclusion in the public record of the above-referenced proceedings. Please contact the
undersigned should you have any questions.

Respectfully submitted,

/s/ Alex Valencia
Alex Valencia
Chief Compliance Officer
Tempo Telecom, LLC
25925 Telegraph Road
Suite 210
Southfield, MI 48033
972-910-1720
[e-mail]

/s/ John J. Heitmann
John J. Heitmann
Debra McGuire Mercer
Nelson Mullins Riley & Scarborough LLP
101 Constitution Avenue, NW
Suite 900
Washington, DC 20001
[phone]
[e-mail]
[e-mail]

Counsel for Insight Mobile, Inc.

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of )
)
TEMPO TELECOM, LLC ) WC Docket No. 09-197
)
Compliance Plan for Lifeline Service ) WC Docket No. 11-42
)

SECOND UPDATED COMPLIANCE PLAN OF TEMPO TELECOM, LLC
Tempo Telecom, LLC (“Tempo” or the “Company”) and Insight Mobile, Inc. (“Insight
Mobile”), through their undersigned counsel, hereby respectfully submit and request expeditious
approval of Tempo’s Second Updated Compliance Plan outlining the measures it will take to
implement the conditions imposed by the Federal Communications Commission
(“Commission”) in its Lifeline Rules and Orders1 and reflecting both immaterial and material
changes in ownership of Tempo.2

1 See Lifeline and Link Up Reform and Modernization, Lifeline and Link Up, Federal-State Joint
Board on Universal Service, Advancing Broadband Availability Through Digital Literacy
Training, WC Docket No. 11-42, WC Docket No. 03-109, CC Docket No. 96-45, WC Docket
No. 12-23, Report And Order and Further Notice Of Proposed Rulemaking, FCC 12-11 (Feb. 6,
2012) (2012 Lifeline Reform Order); Lifeline and Link Up Reform and Modernization et al., WC
Docket No. 11-42, et al., Second Further Notice of Proposed Rulemaking, Order on
Reconsideration, Second Report and Order, and Memorandum Opinion and Order, FCC 15-71
(2015); Lifeline and Link Up Reform and Modernization, et al., WC Docket No. 11-42, et al.,
Third Report and Order, Further Report and Order, and Order on Reconsideration, FCC 16-38
(2016) (“2016 Lifeline Reform Order”); Bridging the Digital Divide for Low-Income Consumers,
Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for
Universal Service Support, WC Docket Nos. 17-287, 11-42, and 09-197, Fifth Report and Order,
Memorandum Opinion and Order and Order on Reconsideration, and Further Notice of Proposed
Rulemaking, FCC 19-111 (rel. Nov. 14, 2019) (collectively, with 47 C.F.R. Part 54 (including
but not limited to sections 54.101, 54.202 and 54.400-54.423), “Lifeline Rules and Orders”).
2 After the transaction described herein, Tempo will be 100 percent owned by Insight Mobile.
This Second Updated Compliance Plan is submitted in accordance Commission’s guidance
regarding compliance plans. See Wireline Competition Bureau Provides Guidance for the
Submission of Compliance Plans Pursuant to the 2012 Lifeline Reform Order, WC Docket Nos.
09-197, 11-42, Public Notice, DA 12-314 (WCB Feb. 29, 2012) (“2012 Public Notice”).

2

INTRODUCTION
Both the Communications Act of 1934, as amended (the “Act”), and the Commission’s
rules require a carrier seeking designation as an eligible telecommunications carrier (“ETC”) to
offer the supported services using its own facilities or a combination of its own facilities and
resale of another carrier’s services.3 In the 2012 Lifeline Reform Order, however, the
Commission decided to conditionally forbear from application of the Act’s facilities requirement
for telecommunications carriers that seek limited ETC designation to participate in the Lifeline
program.4 Specifically, the Commission determined that conditional forbearance from the
facilities requirement would apply if the carrier: (1) complied with certain 911 requirements and
(2) filed and received approval of a compliance plan providing specific information regarding the
carrier’s service offerings and outlining the measures the carrier will take to implement the
Commission’s requirements as well as safeguard against waste, fraud, and abuse.5
To continue to avail itself of the Commission’s conditional grant of forbearance from the
facilities requirement, Tempo provides this Second Updated Compliance Plan. Specifically,
Tempo’s Second Updated Compliance Plan provides information regarding Tempo’s current
Lifeline service offerings and outlines the measures Tempo takes to implement the
Commission’s Lifeline requirements as well as safeguard against waste, fraud, and abuse.

3 47 U.S.C. § 214(e)(1); 47 C.F.R. § 54.201(d)(1).
4 See 2012 Lifeline Reform Order, ¶ 368.
5 See id.. Subsequently, the Commission provided guidance for carriers submitting compliance
plans pursuant to the 2012 Lifeline Reform Order. See 2012 Public Notice.

3

HISTORY OF TEMPO’S COMPLIANCE PLAN
Tempo’s Compliance Plan originally was filed in 2012 under the name of Birch
Communications, Inc. (“Birch”) in support of Birch’s request to be designated as an ETC by the
Commission. The Commission approved the Compliance Plan on August 8, 2012.6
Via letter dated December 18, 2012, Birch notified the Commission that the prepaid
wireless Lifeline service at issue in the Compliance Plan would be provided by a separate legal
entity known as Now Communications, LLC (“Now Comm”). Now Comm committed to
implement and comply with the previously-approved Compliance Plan, and notified the
Commission that it adopted the Compliance Plan as its own. The Commission acknowledged
these changes in corporate structure in a December 20, 2012 public notice, and confirmed that
the previously-approved Compliance Plan applied to Now Comm.7
After the December 2012 filing, Now Comm changed its name to Tempo Telecom, LLC.
Via letter dated September 17, 2013, Tempo notified the Commission it would implement and
comply with the previously-approved Compliance Plan and adopt the Compliance Plan as its
own. Tempo committed to using the same procedures and policies set forth in the approved
Compliance Plan for its provision of prepaid wireless Lifeline service.8 Via letter dated January
9, 2014, Tempo re-confirmed that the previously-approved Compliance Plan applied to all

6 Wireline Competition Bureau Approves the Compliance Plans of Birch Communications,
Boomerang Wireless, IM Telecom, Q Link Wireless, and TAG Mobile, WC Docket Nos. 09-197,
11-42, Public Notice, DA 12-1286 (WCB Aug. 8, 2012).
7 Wireline Competition Bureau Seeks Comment on Petitions for Designation as a Low-Income
Eligible Telecommunications Carrier filed by Now Comm, Zing PCS, LTS, Odin Wireless, and
TX Mobile, WC Docket No. 09-197, Public Notice (WCB Dec. 20, 2012) (“The Wireline
Competition Bureau has approved Birch’s compliance plan, which will also apply to Now
Comm.”)
8 WC Docket Nos. 09-197, 11-42, Letter from Tempo Telecom, LLC (Sept. 17, 2013).

4

jurisdictions in which Tempo sought designation as an ETC.9 On July 25, 2022, Tempo filed its
Updated Compliance Plan. The Commission approved the plan on September 21, 2022.10
COMPLIANCE PLAN
(1) Information about the carrier and the Lifeline plans it intends to offer:
(a) Names and identifiers used by the carrier, its holding company, operating
company and all affiliates

Tempo is a Georgia limited liability company and wireless reseller that offers prepaid
wireless services throughout the United States, and prepaid wireless Lifeline services in 21
states.11 Tempo operates under the “Tempo” or “Tempo Telecom” name throughout the United
States.
Tempo is a wholly-owned subsidiary of Lingo Management, LLC (“Lingo
Management”), a Delaware limited liability company with a principal office at 3475 Piedmont
Road NE, 12th Floor, Suite 1260, Atlanta, GA 30305. Lingo Management is a holding company
and does not provide any telecommunications services or hold authorizations from any state
authority for the provision of telecommunications services. Lingo Management holds
international Section 214 authority from the Commission on behalf of its operating subsidiaries,
but does not provide any services.

9 WC Docket Nos. 09-197, 11-42, Letter from Tempo Telecom, LLC (Jan. 9, 2014).
10 Wireline Competition Bureau Approves the Updated Compliance Plan of Tempo Telecom,
LLC, WC Docket Nos. 09-197, 11-42, Public Notice, DA 22-991, at 1 (WCB Sept. 21, 2022).
Tempo is filing this Second Updated Compliance Plan to advise the Commission of a transaction
whereby Insight Mobile will acquire Tempo.
11 These states are: Colorado, Georgia, Hawaii, Indiana, Iowa, Kansas, Kentucky, Maryland,
Michigan, Minnesota, Missouri, Nebraska, Nevada, North Dakota, Ohio, Rhode Island, South
Carolina, Utah, West Virginia, Wisconsin, and Wyoming.

5

B. Riley Principal Investments, LLC (“BRPI”), a Delaware limited liability company,
holds 100 percent of Lingo Management.12 BRPI is a holding company with a principal office at
30870 Russell Ranch Road, Suite 250, Westlake Village, CA 91362. BRPI is owned by B. Riley
Financial, Inc., a publicly traded Delaware corporation (NASDAQ: RILY) and diversified
financial services company that takes a collaborative approach to the capital raising and financial
advisory needs of public and private companies and high net worth individuals. Bryant R. Riley,
a U.S. citizen, beneficially owns approximately 20.8 percent of the shares of B. Riley
outstanding as of March 28, 2022. BRPI does not provide telecommunications services or hold
authorizations from any state or federal authority for the provision of telecommunications
services.
In 2021, the Commission approved a transaction to increase BRPI’s ownership interest
in Lingo Management to 80 percent (with Lingo holding the remaining 20 percent) (the “BR
Transaction”).13 Prior to the BR Transaction, BRPI held a 40 percent interest in Lingo
Management and Lingo held a 60 percent interest in Lingo Management. The BR Transaction
closed on May 31, 2022.
Lingo Management also is the holding company for the following telecommunications
carriers (the “Lingo Carriers”):
 Lingo Telecom, LLC (f/k/a Matrix Telecom, LLC): A Texas limited liability company
providing local exchange, intrastate interexchange, interconnected Voice over Internet

12 In the Updated Compliance Plan approved on September 21, 2022, BRPI held an 80 percent
interest in Lingo Management and Lingo Communications, LLC (“Lingo”), a Georgia limited
liability company held a 20 percent interest in Lingo Management. On February 24, 2023, BRPI
acquired Lingo’s 20 percent interest in Lingo Management, thereby becoming its sole owner.
Given that BRPI already held a controlling interest in BRPI, there was not transfer of control.
13 See Notice of Domestic Section 214 Authorization Granted, WC Docket No. 21-21, Public
Notice Da 21-280 (WCB Mar. 8, 2021).

6

Protocol (“VoIP”), interstate, international, and/or broadband Internet access services to
residential and small business customers in 49 states and the District of Columbia.
 Lingo Telecom of Virginia, LLC (f/k/a Matrix Telecom of Virginia, LLC): A Virginia
limited liability company providing local exchange, intrastate interexchange,
interconnected VoIP, interstate, and/or broadband Internet access services to residential
and small business customers in Virginia.
 Lingo Telecom of the West, LLC: A Delaware limited liability company providing local
exchange, intrastate interexchange, interconnected VoIP, and/or broadband Internet
access services in the state of California. In connection with an internal corporate
reorganization expected to occur in the next few months, this entity will be dissolved and
its California customers will continue to be served by Lingo Telecom, LLC.
 Lingo Communications of Kentucky, LLC (“Lingo Kentucky”): A Georgia limited
liability company providing local exchange, intrastate interexchange, interstate, and/or
international services in certain areas of Kentucky.14
 BullsEye Telecom, Inc. (“BullsEye”), a Michigan corporation with a principal office at
25925 Telegraph Road, Suite 210, Southfield, MI 48033. BullsEye is a competitive
provider of communications solutions, including traditional telephone, interconnected

14 Lingo Kentucky is a rural competitive local exchange carrier operating only in certain rural
areas of Kentucky. See, e.g., Lingo Communications of Kentucky, LLC Tariff F.C.C. No. 1, WC
Docket No. 20-245, Order (WCB Dec. 16, 2020).

7

VoIP, interstate, international, and/or broadband Internet access services, to business
customers in the lower 48 states and the District of Columbia.15
Separate and apart from its holdings in Lingo Management, BRPI also holds ownership
interests in:
 United Online, Inc.: A Delaware corporation that offers Internet access services to
consumers under the NetZero and Juno brands, as well as email, Internet security, web
hosting services, and other communications-related services in the District of Columbia
and all 50 states.
 YMax Communications Corp.: A Delaware corporation that offers competitive local
exchange and/or interexchange services in the District of Columbia and all 50 states
except for Alaska and New Hampshire.
 magicJack SMB, Inc.: A Florida corporation that offers interconnected VoIP services in
the District of Columbia and all 50 states except for Alaska.
As noted above, Tempo is currently 100 percent owned by Lingo Management. Pursuant
to a Membership Interest Purchase Agreement (the “Agreement”), dated January 24, 2023, Lingo
Management and Insight Mobile have agreed that Lingo Management will transfer 100 percent

15 The Commission approved the acquisition of BullsEye on June 14, 2022. See generally,
Domestic 214 Application Granted for the Transfer of BullsEye Telecom, Inc. to the Lingo
Entities, WC Docket No. 22-249, Public Notice, DA 22-632 (WCB June 14, 2022). BullsEye
Telecom of Virginia, LLC, a wholly-owned subsidiary of BullsEye, is authorized to provide
intrastate services in Virginia.

8

of the outstanding membership interests in Tempo to Insight Mobile (the “Transaction”). 16 Pre-
and post-close corporate structure diagrams are included as Exhibit A.
(b) Detailed information demonstrating the carrier is financially and technically
capable of providing the supported Lifeline service in compliance with the
Commission’s rules

Commission rules require ETCs to demonstrate financial and technical capability to
comply with Lifeline service requirements,17 and the Commission has requested such
demonstrations also be included in compliance plans.18 The Commission has stated the “relevant
considerations” for demonstrating that a carrier is financially and technically capable would be
whether the carrier previously offered services to non-Lifeline consumers, how long the carrier
has been in business, whether the carrier intends to rely exclusively on universal service fund
disbursements to operate, whether the carrier receives funds from other sources, and whether the
carrier has been subject to enforcement action or ETC revocation proceedings in other states.19
Tempo has successfully operated as a wireless reseller since 2012 and has been
providing Lifeline services since 2013. Tempo’s affiliates have been operating as nationwide
competitive local exchange carriers since at least 1996. Tempo has not been subject to an
abnormal number of enforcement proceedings in the past ten years, and such proceedings
generally have focused on a missed/late filing or payment. Tempo has never been subject to an
ETC revocation proceeding in any state. Tempo’s Lifeline operations also have been audited by

16 The January 24, 2023 Agreement was entered between Lingo Management and another
company. However, pursuant to an assignment and assumption agreement between that
company and Insight Mobile dated April 5, 2023, Insight Mobile has taken the place of that
company and is now the purchaser.
17 Public Notice, at 3.
18 47 C.F.R. § 54.202(a)(4).
19 2012 Lifeline Reform Order, ¶ 388.

9

the Universal Service Administrative Company (“USAC”) and several states, and those audits
have not disclosed any material non-compliance with Commission Lifeline requirements.
Financial support for Tempo’s continued operations will be enhanced by the Transaction
whereby, subject to regulatory approval, Insight Mobile will acquire 100 percent of the
membership interest in Tempo. Following the proposed change in Tempo’s ownership, the
Company’s corporate and trade names and identifiers initially will remain unchanged, and any
future changes to the Company’s name will comply with relevant laws governing customer
notices. The Transaction will not result in any loss or impairment of service for any customer,
and customers will continue to receive their existing services at the same rates, terms and
conditions currently in effect. Moreover, the Transaction will neither eliminate any Lifeline
market participants nor reduce the service choices available to Lifeline-eligible consumers.
Insight Mobile is a Delaware corporation with principal offices located at 12301 Wilshire
Boulevard, Suite 303, Los Angeles, California 90025. Insight Mobile holds international Section
214 authority from the Commission to provide global facilities-based and resale service.20
Insight Mobile is not currently providing telecommunications services. Shadi Aslemand, a
United States citizen, owns 100 percent of Insight Mobile. Ms. Aslemand is also a 50 percent
owner of Excess Telecom, Inc. (Excess Telecom), a California corporation that holds
international Section 214 authority from the Commission to provide global facilities-based and
resale services.21 Upon closing of the Transaction, Tempo will be affiliated with Excess
Telecom which operates as a Mobile Virtual Network Operator (MVNO) and delivers domestic

20 File No. ITC-214-20220314-00037, granted April 8, 2022.
21 File No. ITC-214-20150218-00049, granted March 13, 2015.

10

wireless voice services and broadband services to qualified low-income households nationwide
and participates in the Affordable Connectivity Program.
With respect to technical expertise, Tempo has demonstrated its technical capabilities
over the past 10 years of successful operation. Further, Tempo’s partnerships with nationwide
wireless carriers demonstrate Tempo is technically capable of providing prepaid wireless
Lifeline service throughout its 21-state service territory. Initially, Tempo resold the wireless
services of Sprint, and later added T-Mobile as an additional underlying carrier (Sprint and T-
Mobile have since merged, and thus Tempo refers only to T-Mobile herein). T-Mobile provides
Tempo with the underlying network infrastructure and wireless transmission facilities needed
for Tempo to offer service as a MVNO.
Upon approval of the change in ownership, Insight Mobile’s management team will be
responsible for day-to-day oversight of Tempo’s operations. However, the parties contemplate
that Tempo’s employees who are currently responsible for the Company’s Lifeline service
business will maintain their positions under Insight Mobile’s ownership. Information about the
key members of Insight Mobile’s management team is attached as Exhibit B. Insight Mobile’s
management team has extensive experience in the telecommunications and technology
industries, as well as in the Lifeline services market. Their collective expertise will guide the
Company’s decisions going forward and its adherence to this Second Updated Compliance
Plan.22 As a result, the Transaction will bring together the full strength of Tempo’s and Insight
Mobile’s experience in the telecommunications industry and business expertise. The resulting

22 Insight Mobile’s management team currently hold dual roles at both Insight Mobile and
Excess Telecom. Upon the closing of the Transaction, members of the management team will
transition to full-time employment with Insight Mobile.

11

synergies will enable Tempo to achieve measurable growth at the same time as it develops
improved operating efficiencies, both necessary components for the Company to thrive.
Moreover, with access to Insight Mobile’s financial and technical resources, Tempo will be able
to offer enhanced service offerings to all current and future end users, including those who are
enrolled in the Lifeline program.
(c) Detailed information, including geographic locations, of the carrier’s current
service offerings if the carrier currently offers service

Tempo currently offers prepaid wireless services on a nationwide basis. Tempo
currently provides prepaid wireless Lifeline service in certain designated portions of the
following 21 states: (1) Colorado; (2) Georgia; (3) Hawaii; (4) Indiana; (5) Iowa; (6) Kansas; (7)
Kentucky; (8) Maryland; (9) Michigan; (10) Minnesota; (11) Missouri; (12) Nebraska; (13)
Nevada; (14) North Dakota; (15) Ohio; (16) Rhode Island; (17) South Carolina; (18) Utah; (19)
West Virginia; (20) Wisconsin; and (21) Wyoming.
(d) The terms and conditions of each Lifeline service plan offering, including
rates, the number of minutes provided, and additional charges, if any, for toll
calls

Tempo currently offers a “Lifeline Data Bundle” plan, which offers unlimited nationwide
voice minutes, voicemail, unlimited nationwide text messages, and 4.5 GBs of data each month
at no charge to an eligible consumer.23 In addition, Tempo offers consumers the ability to
purchase additional MBs or additional GBs of data at reduced rates (plus applicable taxes and
fees). The Lifeline Data Bundle also provides an option to add international calling with per-

23 Tempo’s Lifeline plan components may differ in some states in accordance with state-
mandated requirements for Lifeline services, but all plans comply with the Commission’s
minimum service standards for wireless Lifeline services.

12

minute pricing based on the country to be called, which is provided to the consumer when opting
for this capability.
(e) All other certifications required under section 54.202 of the Commission’s
rules

Commission Rule 54.202 requires a common carrier seeking ETC designation to make
certain certifications, and the Commission has requested such certifications be included in
compliance plans.24 Specifically, Rule 54.202 requires: (1) certification that the carrier will
comply with the service requirements applicable to the support it receives;25 (2) submission of a
five-year plan for proposed improvements or upgrades to the carrier’s network unless the carrier
seeks Lifeline support only;26 (3) demonstration of the carrier’s ability to remain functional in
emergency situations, including a demonstration that it has a reasonable amount of back-up
power to ensure functionality without an external power source, is able to reroute traffic around
damaged facilities, and is capable of managing traffic spikes resulting from emergency
situations;27 (4) demonstration the carrier will satisfy applicable consumer protection and service
quality standards;28 (5) demonstration the carrier is financially and technically capable of
providing Lifeline service in compliance with the Commission’s rules;29 (6) submission of
information describing the terms and conditions of the voice telephony plans offered to Lifeline

24 2012 Public Notice, at 3.
25 47 C.F.R. § 54.202(a)(1)(i).
26 47 C.F.R. § 54.202(a)(1)(ii).
27 47 C.F.R. § 54.202(a)(2).
28 47 C.F.R. § 54.202(a)(3).
29 47 C.F.R. § 54.202(a)(4).

13

subscribers;30 and (7) submission of information describing the terms and conditions of
broadband Internet access service plans offered to Lifeline subscribers.31
With respect to (1) above, Tempo provides Lifeline service only, and therefore certifies
that it complies with the service requirements applicable to Lifeline support. Eligible voice
telephony services must provide voice grade access to the public switched telephone network
(“PSTN”) or its functional equivalent, minutes of use for local service provided at no additional
charge, access to emergency 911 and enhanced 911 service in locations where implemented, and
for qualifying low-income consumers, toll limitation service.32 Eligible broadband Internet
access services must provide the capability to transmit and receive data by wire or radio from all
or substantially all Internet endpoints, including any capabilities that are incidental to and enable
the operation of the communications service, but excluding dial-up service.
Tempo’s Lifeline offering provides voice grade access to the PSTN, and includes
unlimited local calling. In addition, Tempo’s Lifeline offering provides consumers with access
to 911 and enhanced 911 to the extent local governments have implemented such services as
explained further below. With respect to toll limitation service, the Commission eliminated the
requirement to provide toll limitation services if the Lifeline offering provides a set amount of
minutes that do not distinguish between toll and non-toll calls.33 Thus, Tempo is not required to
provide toll limitation service in connection with its Lifeline service offering because Tempo’s
Lifeline plan offers unlimited voice calling within the United States. Similarly, Tempo’s
Lifeline service offering provides consumers with the capability to transmit data to and receive

30 47 C.F.R. § 54.202(a)(5).
31 47 C.F.R. § 54.202(a)(6).
32 47 C.F.R. § 54.101(a)(1).
33 2012 Lifeline Reform Order, ¶ 49.

14

data from all or substantially all Internet endpoints, and meets the minimum service standards for
broadband Internet access service required by Commission rules.34
With respect to (2) above, Tempo provides Lifeline-only service, and a five-year plan
is not required for carriers offering supported services only under the Lifeline program.35
With respect to (3) above, Tempo has the ability to remain functional in emergency
situations. Tempo has been offering telecommunications services since 2012, and its affiliates
have been offering telecommunications services since at least 1996. Thus, Tempo and its
affiliated telecommunications carriers have significant experience with remaining functional in
emergency situations. Tempo has disaster recovery contingency plans that include
diverse/alternate routing, electronics redundancy, dual data centers geographically separated, and
environmental controls for data and switching centers. Tempo’s MVNO contract arrangements
with T-Mobile also impose certain obligations on T-Mobile to ensure Tempo’s prepaid wireless
Lifeline service offering remains functional during emergency situations. As a large, nationwide
wireless carrier, T-Mobile is subject to regulatory requirements to remain functional during
emergency situations.36 Tempo’s MVNO agreements also contain certain quality of service
guarantees.
With respect to (4) above, Tempo satisfies applicable consumer protection and service
quality standards. Tempo complies with the Cellular Telecommunications and Internet

34 47 C.F.R. § 54.408(b). The current minimum service standards for mobile broadband is speed
3G or better and usage of 4.5 GB per month.
35 47 C.F.R. § 54.202(a)(1)(ii); see also 2012 Lifeline Reform Order, ¶ 386.
36 Tempo is also familiar with the continuity and disaster response program T-Mobile has
implemented, which addresses the need to remain functional during emergency situations.

15

Association’s Consumer Code for Wireless Service to satisfy this requirement as permitted by
the Commission’s rules.37
With respect to (5) above, Tempo is financially and technically capable of providing
Lifeline service in compliance with the Commission’s rules as explained in 1(b) above.
With respect to (6) and (7) above, information regarding Tempo’s Lifeline service plan is
set forth in (1)(d) above. Commission rules also allow a carrier to provide a link to a public
Website outlining the Lifeline service plan.38 Information regarding Tempo’s Lifeline service
plan is available at: https://mytempo.com/lifeline-wireless/.
(2) A detailed explanation of how the carrier will comply with the Commission’s rules
relating to determinations of subscriber eligibility for Lifeline services, including all
of the consumer eligibility, consumer enrollment, and re-certification procedures

Tempo has been offering Lifeline services for nearly 10 years, and is therefore intimately
familiar with the Commission’s procedures for confirming consumer eligibility, enrolling
eligible customers, recertification, activation, and usage.
Consumer Eligibility
Tempo has implemented detailed policies and procedures to ensure its Lifeline customers
are eligible to receive Lifeline service under the Commission’s rules. Tempo does not provide
Lifeline service – and does not provide an activated device – to any consumer until Tempo has
confirmed the consumer meets the eligibility requirements established by the Commission for
receipt of Lifeline services.39 Specifically, a consumer must meet one of the following
requirements to be eligible for Lifeline service: (1) the consumer’s household income is at or

37 47 C.F.R. § 54.202(a)(3).
38 47 C.F.R. § 54.202(5), (6).
39 47 C.F.R. § 54.409.

16

below 135 percent of the Federal Poverty Guidelines currently in effect for a household of that
size; or (2) the consumer (or the consumer’s dependents or household) receives benefits from
certain federal assistance programs.40 Tempo relies solely on the Lifeline National Verifier for
establishing a prospective customer’s eligibility for Lifeline service.41
Enrollment
Prospective Lifeline customers can contact Tempo via its website or toll-free customer
service number to start the process of receiving Lifeline services from Tempo.42 Tempo relies on
the USAC-standard application and certification form, and thus Tempo’s processes comply with
Commission rules for subscriber eligibility determinations and certifications.43 If the customer
has not pre-qualified via the Lifeline National Verifier, Tempo first directs the customer to the
Lifeline National Verifier so the customer can confirm its eligibility for Lifeline service and
obtain an approved application ID from the Lifeline National Verifier.
Once the customer’s eligibility has been confirmed by the Lifeline National Verifier (and
the customer has obtained an approved application ID), Tempo takes two additional steps to
prevent duplicate Lifeline subsidies. First, Tempo reviews its own service records to ensure the
potential customer is not currently receiving Lifeline service from Tempo. Second, Tempo
checks the National Lifeline Accountability Database (“NLAD”) to ensure the potential

40 47 C.F.R. § 54.409(a). Tempo also complies with any state-specific eligibility requirements
applicable in its 21-state Lifeline service territory.
41 The Lifeline National Verifier also collects any needed documentation from the prospective
customer.
42 At this time, Tempo is not using third-party dealer locations to sign-up prospective Lifeline
customers. In the future, prospective customers may be able to begin the process of receiving
Lifeline services from Tempo via a third-party dealer location.
43 47 C.F.R. § 54.410. Tempo representatives also orally explain the application and certification
form to potential Lifeline customers if they choose to enroll over the phone.

17

customer is not currently receiving a Lifeline service from any other carrier.44 When applicable,
Tempo requires the prospective customer to complete the Independent Economic Household
Worksheet via the Lifeline National Verifier. This USAC-developed form contains the
following: (1) an explanation of the Commission’s one-per-household rule; (2) a check box that
an applicant can mark to indicate that he or she lives at an address occupied by multiple
households; (3) a space for the applicant to certify that he or she shares an address with other
adults who do not contribute income to the applicant’s household and share in the household’s
expenses or benefit from the applicant’s income, pursuant to the Commission’s definition; and
(4) the penalty for a consumer’s failure to make the one-per-household certification when
required.
Once Tempo has confirmed there is no duplicate service, Tempo enrolls the customer in
the Lifeline program using NLAD’s real-time interface (API), and submits all required
information regarding the customer to NLAD.45 Tempo does not enroll or claim reimbursement
for a prospective customer if NLAD or the Lifeline National Verifier cannot verify the identity
of the prospective customer or the prospective customer’s status as non-deceased.46
All Tempo representatives involved in the Lifeline enrollment process (both in-house and
third-party)47 are required to take a training course regarding the Commission’s Lifeline rules

44 Tempo also commits to promptly investigate any notification it receives from a state, the
Commission, or USAC that one of its Lifeline customers is improperly receiving service.
45 In addition, Tempo updates each subscriber’s information in NLAD within ten (10) business
days of any change, except for de-enrollment, which is updated within one (1) business day. See
47 C.F.R. § 54.404(b)(8), (10).
46 47 C.F.R. § 54.404(b).
47 At this time, Tempo does not utilize third-party dealers to enroll prospective customers in the
Lifeline program, but could do so in the future. Tempo includes information regarding third-
party representatives herein in the event Tempo uses such representatives in the future.

18

and to be registered with USAC prior to enrolling any customer in NLAD.48 Tempo also
conducts periodic audits and random checks of its Lifeline representatives to ensure compliance
with Commission rules. Tempo does not offer or provide any commission or other
compensation to enrollment representatives based on the number of consumers that apply for or
are enrolled in the Lifeline program.49
Annual Verification
Tempo’s systems are capable of tracking and flagging the anniversary of a Lifeline
customer’s start date. Tempo uses the anniversary date to ensure its Lifeline customers re-certify
their eligibility to participate in the Lifeline program once a year. Tempo Lifeline customers are
re-certified within 12 months after the subscriber’s service initiation date and within every 12
months thereafter by the Lifeline National Verifier as required under Commission rules.50 The
annual re-certification materials inform the subscriber it is being contacted to re-certify
continuing eligibility for Lifeline, and if the subscriber fails to respond, it will be de-enrolled
from the program as discussed below.
Activation and Usage
Once all eligibility determinations and documentation requirements are complete, Tempo
ships the handset to the customer at the address listed on the enrollment form.51 Tempo requires
the customer to take affirmative steps to “personally activate” the service by requiring the

48 47 C.F.R. § 54.406. Tempo also requires its representatives to engage in routine, ongoing
training regarding Commission compliance requirements for Lifeline services.
49 47 C.F.R. § 54.406(b).
50 47 C.F.R. § 54.410(f).
51 If Tempo were to use third-party dealers in the future, the third-party representative may
provide the handset to the customer during an in-person enrollment depending on handset
availability.

19

customer to complete an outgoing call.52 If service is not initiated, Tempo does not consider the
consumer to be enrolled in the Lifeline program and Tempo does not request Lifeline
reimbursement until the subscriber personally activates its service.53 After service activation,
Tempo does not seek reimbursement for any Lifeline subscriber who has not used the service
consistent with Commission usage requirements.54
(3) A detailed explanation of how the carrier will comply with the forbearance
conditions relating to public safety and 911/E911 access

Pursuant to the 2012 Lifeline Reform Order, forbearance for non-facilities based ETCs is
conditioned upon the ETC providing its Lifeline voice subscribers with 911/E911 access,
regardless of activation status and availability of minutes, and providing its Lifeline voice
subscribers with E911-compliant handsets and replacing, at no additional charge to the
subscriber, any non-compliant handsets.55 Tempo’s prepaid wireless Lifeline service offering
complies with the 911 requirements necessary for application of conditional forbearance.
Tempo provides access to 911/E911 services for all its customers, including its Lifeline
customers. Tempo uses T-Mobile as its underlying network provider, which routes 911/E911
calls from Tempo’s customers in the same manner as 911/E911 calls from T-Mobile’s own
customers.56 To the extent that T-Mobile delivers 911/E911 calls in a given public safety
answering point territory, this capability functions the same for Tempo and its customers.

52 2012 Lifeline Reform Order, ¶ 260.
53 2012 Lifeline Reform Order, ¶ 257.
54 47 C.F.R. § 54.407(c)(2).
55 2012 Lifeline Reform Order, ¶ 373.
56 Tempo understands that it has an independent obligation to provide 911/E911 services as a
wireless reseller, and utilizes its underlying contractual arrangements to meet that obligation.
See 2012 Lifeline Reform Order, n.989.

20

Tempo enables 911/E911 emergency calling services for all properly activated handsets
regardless of whether the account associated with the handset is active or suspended. Further, all
911/E911 calls initiated from any Tempo handset are transmitted even if the account associated
with the handset has no remaining minutes (which would not occur given Tempo’s current
Lifeline service plan offers unlimited voice minutes).
Tempo provides its Lifeline subscribers with E911-complianct handsets, and replaces, at
no additional charge to the subscriber, any non-compliant handset. Tempo relies on underlying
contractual arrangements with third-parties to provide handsets to consumers, and those
contractual arrangements require the third-party to supply handsets that satisfy all Commission
requirements. Thus, any Lifeline customer that obtains a handset from Tempo has an E911-
compliant handset.
(4) A detailed explanation of how the carrier will comply with the Commission’s
marketing and disclosure requirements for participation in the Lifeline program

Tempo includes the following information regarding its Lifeline service on all relevant
marketing materials: (1) it is a Lifeline-supported service; (2) Lifeline is a government assistance
program; (3) the service is non-transferable; (4) only eligible consumers may enroll in the
Lifeline program; (5) the Lifeline program is limited to one discount per household; and (6)
documentation is necessary for enrollment in the Lifeline program.57 Tempo ensures the
Commission-required disclosures, any DBA names it uses, and details of the prepaid wireless
Lifeline service offering are contained in all marketing materials.58 This information is included
in all print, audio, video, website, and electronic materials (including social networking) used to
describe or enroll subscribers in Lifeline service. In addition, the standard

57 47 C.F.R. § 54.405(c).
58 2012 Lifeline Reform Order, ¶¶ 274-282.

21

application/certification forms developed by USAC state that consumers who willfully make a
false statement in order to obtain the Lifeline benefit can be punished by fine or imprisonment or
can be barred from the program.59
Tempo publicizes the availability of its prepaid wireless Lifeline service offering in a
manner reasonably designed to reach those likely to qualify the service.60 Tempo utilizes the
Commission’s 2004 outreach guidelines for advertising its prepaid wireless Lifeline service
offering.61 Specifically, Tempo utilizes outreach materials and methods designed to reach
households that currently do not have telephone service, has developed advertising materials for
non-English speaking populations within its service area, and coordinates its outreach efforts
with relevant government agencies.
Tempo’s advertising strategy for its prepaid wireless Lifeline service offering builds on
its expertise in advertising its prepaid wireless service, and the advertising used by Tempo’s
telecommunications carrier affiliates. Tempo’s advertising for its prepaid wireless Lifeline
service offering includes, but is not limited to, targeted direct mail, advertisements in daily and
weekly print periodicals, billboards, event sponsorship, bus advertising, radio advertising, and
online search engines.
Tempo also coordinates with relevant state agencies, community outreach organizations,
and non-profit organizations to make information available regarding Tempo’s prepaid wireless
Lifeline service offering in resource guides and other printed materials produced by those
organizations, as well as in their offices or other locations visited by potential Lifeline-eligible

59 47 C.F.R. § 54.410(d)(1).
60 47 C.F.R. § 54.405(b).
61 Lifeline and Link Up, 19 FCC Rcd 8302, ¶¶ 45-48 (2004).

22

subscribers. In addition, Tempo markets its prepaid wireless Lifeline services through state,
county, municipal and non-profit community action agencies, associations, and networks. These
agencies support Lifeline-eligible individuals and families in obtaining support services,
employment, employment training, life skills training, and other services. Tempo helps raise
awareness of Lifeline services through the inclusion of Tempo Lifeline information in resource
guides and other support materials (online and in printed materials issued by the agency) that are
provided to Lifeline-eligible prospective customers. Tempo also raises awareness of its Lifeline
services through sponsoring events held by these agencies.
(5) A detailed explanation of the carrier’s procedures and efforts to prevent waste,
fraud and abuse in connection with Lifeline funds, including but not limited to,
procedures the carrier has in place to prevent duplicate Lifeline subsidies within its
own subscriber base, procedures the carrier undertakes to de-enroll subscribers
receiving more than one Lifeline subsidy per household, information regarding the
carrier’s toll limitation service, if applicable, and the carrier’s non-usage policy, if
applicable

Throughout this Second Updated Compliance Plan, Tempo explains its procedures and
efforts to prevent waste, fraud, and abuse. This section focuses on Tempo’s de-enrollment
procedures, and how they prevent waste, fraud, and abuse. Tempo de-enrolls Lifeline customers
for: no longer qualifying for Lifeline service; duplicative support; non-usage; failure to re-
certify; and when requested by the Lifeline subscriber. As required by the Commission’s rules,
Tempo updates NLAD with de-enrollment information within one (1) business day of de-
enrollment.62
De-Enrollment for Ineligibility
If Tempo has a reasonable basis to believe that one of its Lifeline customers no longer
meets the eligibility criteria (either based on Tempo’s own knowledge or information supplied

62 47 C.F.R. § 54.404(b)(10).

23

by a third-party), Tempo notifies the subscriber of the impending de-enrollment in writing and
gives the subscriber thirty (30) days to demonstrate continued eligibility.63 Any demonstration
of eligibility from the subscriber must comply with the annual re-certification procedures set
forth in the Commission’s rules, including the submission of the USAC-created
enrollment/certification form. A subscriber’s failure to provide the requested documentation will
result in de-enrollment within five (5) business days after the expiration of the subscriber’s time
to respond.
De-enrollment for duplicative support
Tempo understands that duplicative claims are wasteful and burden universal service and
takes all necessary steps to swiftly de-enroll consumers found to be receiving duplicative federal
Lifeline discounts. Upon notification from the Commission, a state, or USAC that a subscriber is
receiving Lifeline service from another carrier, or more than one member of a household is
receiving Lifeline service, Tempo de-enrolls the subscriber within five (5) business days.64
De-enrollment for non-usage
Tempo de-enrolls any Lifeline customer whose service is inactive for a consecutive 30-
day period after providing the customer with notice and a 15-day “cure” period.65 After 30
consecutive days of non-usage (as defined in Commission rules), Tempo provides subscribers
notice, using clear, easily understood language, to inform the subscriber that its failure to use the
Lifeline service within the next 15 days will result in service termination on the 46th day (30

63 47 C.F.R. § 54.405(e)(1).
64 47 C.F.R. § 54.405(e)(2); see also Lifeline and Link Up Reform and Modernization, 26 FCC
Rcd 9022, ¶ 15 (2011).
65 47 C.F.R. § 54.405(e)(3). Tempo provides the customer with notice via text message on day 7,
day 14, and day 28 that failure to use the Lifeline service may result in service termination.

24

days of non-usage plus the 15-day “cure” period).66 Despite a consumer’s “usage” (as defined in
Commission rules), Tempo will continue to comply with its existing public safety obligations to
transmit all 911/E911 calls regardless of subscriber inactivity even if Tempo is no longer
providing Lifeline service to that consumer.67 Tempo includes any subscribers de-enrolled for
non-usage in its annual non-usage de-enrollment reports. Tempo also understands that it can
only seek reimbursement for any subscriber that has used its Lifeline service within the last 30
days or who has cured its non-usage as described above.68
De-enrollment for failure to re-certify
Tempo de-enrolls subscribers who do not respond to an annual re-certification request or
fail to provide the required certification to the Lifeline National Verifier,69 which is the entity
responsible for annual re-certification of a subscriber’s Lifeline eligibility. Prior to de-enrolling
a subscriber for failure to re-certify, subscribers receive written notice explaining that failure to
respond to the re-certification request within sixty (60) days will result in the subscriber’s de-
enrollment. Tempo de-enrolls the subscriber within five (5) business days after the expiration of
the subscriber’s time to respond.

66 Tempo provides the customer with notice via text message on day 30, day 35, and days 40-44
that failure to use the Lifeline service may result in service termination. Tempo then provides
the customer with notice via text message on day 45 that the service will be disconnected for
non-usage.
67 2012 Lifeline Reform Order, ¶ 262.
68 47 C.F.R. § 54.407(c)(2).
69 47 C.F.R. § 54.405(e)(4).

25

De-Enrollment by Subscriber
If a subscriber contacts Tempo and states the subscriber is no longer eligible for Lifeline
or wishes to de-enroll for any reason, Tempo de-enrolls the subscriber within two (2) business
days.70 Subscribers can make this request either via customer service or online.
(6) Other requirements applicable to wireless Lifeline providers
Tempo complies with all current Commission rules governing the provision of prepaid
wireless Lifeline services.
Handset Requirements
In the 2016 Lifeline Reform Order, the Commission required providers of Lifeline-
supported services offering both mobile broadband services and devices to provide their
customers with handset devices that are Wi-Fi enabled.71 Lifeline customers also are entitled to
a choice of at least one (1) device that is capable of being used as a hotspot.72 All handsets
offered by Tempo to Lifeline customers are Wi-Fi enabled and at least 55 percent of Tempo’s
handsets offered to Lifeline customers are capable of being used as a hotspot as required under
the rules.73
Annual Reports and Certifications
Tempo submits its required annual reports and certifications to the Commission,
including FCC Form 481 and FCC Form 555, as well as any other reports the Commission
directs ETCs to file on a one-time or periodic basis.

70 47 C.F.R. § 54.405(e)(5).
71 2016 Lifeline Reform Order, ¶¶ 366-67.
72 47 C.F.R. § 54.408(f)(3).
73 47 C.F.R. § 54.408(f)(3)(v) (requiring at least 45 percent of devices to be capable of being used
as a hotspot from December 1, 2021 to November 30, 2022). Tempo will ensure that it meets the
appropriate percentages required by the rules for December 1, 2022 going forward.

26

Reimbursement and Recordkeeping
Tempo ensures it has valid certification and recertification forms for each of the Lifeline
subscribers for whom it seeks reimbursement.74 Further, Tempo complies with the
Commission’s requirement to use the number of eligible Lifeline subscribers as of the snapshot
date indicated by NLAD data to request reimbursement for its provision of Lifeline service.75
Finally, Tempo maintains accurate records as directed by USAC and as required by
Commission’s rules.76

74 47 C.F.R. § 54.407(d). Tempo relies upon the Lifeline National Verifier and/or its website to
obtain initial certification and enrollment information. In addition, Tempo relies on USAC
and/or the Lifeline National Verifier to recertify customers and obtain the necessary
documentation associated with recertification. Tempo provides notice to its customers to assist
them in the recertification process.
75 47 C.F.R. § 54.407(a).
76 47 C.F.R. § 54.417.

27

CONCLUSION
WHEREFORE, for the forgoing reasons, Tempo and Insight Mobile respectfully
request that the Commission expeditiously approve Tempo’s updated Compliance Plan.
Respectfully submitted,

TEMPO TELECOM, LLC

/s/ Alex Valencia
Alex Valencia
Chief Compliance Officer
25925 Telegraph Road
Suite 210
Southfield, MI 48033
972-910-1720
[e-mail]

INSIGHT MOBILE, INC.

/s/ John J. Heitmann
John J. Heitmann
Debra McGuire Mercer
Nelson Mullins Riley & Scarborough LLP
101 Constitution Avenue, NW
Suite 900
Washington, DC 20001
[phone]
[e-mail]
[e-mail]

Counsel for Insight Mobile, Inc.

April 28, 2023
Pre-Transaction
EXHIBIT A
Impact
Acquisition, LLC.
(DE)
Lingo Management, LLC
(DE)
Lingo Telecom,
LLC
(TX)
Lingo Telecom of
Virginia , LLC
(VA)
Vancouver
Telephone
Company Limited
(Canada)
B. Riley Principal Investments, LLC
(DE)
Lingo
Communications
of Kentucky, LLC
(GA)
Tempo Telecom,
LLC
(GA)
Impact Telecom,
LLC.
(NV)
Bullseye Telecom,
Inc.
(MI)
Bullseye Business
Solutions
Holdings, Inc.
(MI)
Bullseye Business
Solutions ULC
(Canada)
Bullseye Telecom
of Virginia , LLC
(VA)
Bandwave
Systems, LLC.
(PA)
Lingo Telecom
of the West, LLC.
(DE)
B. Riley Financial, Inc.
(DE)
Post-Transaction
EXHIBIT A
Shadi Aslemand
Tempo Telecom, LLC
(GA)
Insight Mobile, Inc.
(DE)
EXHIBIT B

Officer and Key Management Bios

John Ripley (Chief Operations Officer - Excess Telecom, Inc. and Insight Mobile, Inc.)
For the past 25 years John Ripley has worked with companies to build and execute high growth
strategies that revolve around profitable, sustainable and efficient growth. As Excess Telecom’s
Chief Operations Officer (“COO”), John oversees strategic execution while managing all
customer operations, field operations, compliance, legal, corporate operations, finance and
accounting. John will have the same role at Insight Mobile.
After starting his career in finance and accounting with big tech companies such as Oracle and
Microsoft, John pivoted to work with start-up and growth stage companies in the
telecommunications, healthcare, technology and services industries. Prior to joining Excess
Telecom as Chief Operations Officer in April 2022, John held executive leadership roles in the
Lifeline and Emergency Broadband Benefit Program space since 2013 when he served as COO
and Chief Financial Officer for IMMERGE, LLC. At IMMERGE, John managed a field
operations and compliance team that oversaw the activities of more than 3,000 field agents
spread across the United States. Under John’s guidance, IMMERGE successfully launched,
grew and managed one of the largest lifeline enrollment companies in the nation in a compliant-
centric manner.
John also has worked extensively with companies and regulators to develop and execute growth
strategies in other highly regulated industries including healthcare, energy and banking. This
broad set of experience provides John with the skillset needed to manage both Excess and Insight
toward a compliance-centric, customer focused path of sustainable, profitable growth.
Andrew Whitelock (Chief Compliance Officer – Excess Telecom, Inc. and Insight Mobile,
Inc.)
Over the past 25 years, Andrew Whitelock has developed and led compliance and risk
management programs in a variety of for-profit and non-profit companies. As Excess Telecom’s
Chief Compliance Officer, Andrew directs the activities of the company’s compliance program,
manages regulatory compliance and overseas risk management practices. Andrew will have the
same role at Insight Mobile.
Andrew began his career contracting with medical providers and hospitals to build a
comprehensive healthcare delivery network serving low-income and disadvantaged populations
in Los Angeles. He joined L.A. Care Health Plan in 1998 and progressed from provider
contracting to regulatory compliance, and then account executive managing two key corporate
partnerships. In 2005, Andrew became the Director of Government Contracts with Molina
Healthcare of California and was the Associate Vice President of Government Contracts when he
departed in 2012 to become the Compliance Officer at SCAN Health Plan. Prior to joining
Excess Telecom, Andrew was SCAN’s Chief Risk Executive. Andrew has experience managing
2

diverse teams with a wide scope of responsibilities. As the Chief Risk Executive at SCAN, he
managed four departments with sixty-five staff members and an annual budget of $11M.
Andrew has broad experience identifying and mitigating enterprise risks. He has worked
extensively with state and federal regulators to manage monitoring and auditing activities;
review proposed regulations and policies; and demonstrate compliance with program
requirements. Proactively managing enterprise risks is core to Andrew’s leadership role with
both Excess Telecom and Insight Mobile.
Andrew is a graduate of the University of Southern California (“USC”) with Bachelor of Arts
degrees in history and biological sciences. He also holds a Master of Science in international
development and non-profit management from USC, and a Master of Business Administration
from Pepperdine University.
Ryan Moxom (Vice President, Operations – Excess Telecom, Inc. and Insight Mobile, Inc.)
Ryan Moxom is Excess Telecom’s Vice President Operations. In this role, Ryan oversees all
field operations for the company, including agent training and onboarding, customer support and
customer engagement programs. Ryan will have the same role at Insight Mobile.
Ryan’s telecommunications experience includes being a Program Manager at the Universal
Service Administrative Company for the Lifeline program, managing Lifeline compliance
matters for Verizon, and Director of Regulatory Compliance for StandUp Wireless, a Lifeline and
Affordable Connectivity Program provider. In his most recent role, Ryan was a Lead Product
Marketing Manager with AT&T Inc.
Ryan is a graduate of the University of Florida with a Bachelor of Arts degree in Economics. He
also holds a Juris Doctor degree from the University of Georgia School of Law. Ryan has been a
member of the Georgia Bar since 2014.

EXHIBIT 3
Coverage Area
T-Mobile

EXHIBIT 4
Sample Advertisement

EXHIBIT 5
Key Management Bios
Ananth Veluppillai
Chief Executive Officer
Ananth Veluppillai serves as Tempo Telecom’s Chief Executive Officer, in addition to being CEO of Lingo
Management and a member of its Board. Ananth also serves as the Chief Operating Officer of B. Riley
Principal Investments (an owner of Lingo). Ananth has over 28 years of experience in
telecommunications and held various leadership positions, including serving as the COO of Global
Operations for Tech Mahindra’s Network Services unit and COO of LCC International, Inc., that provided
consulting services in Wireless and Wireline telecommunication networks around the world. Ananth
holds B.S. in Electrical Engineering from the University of Maryland at College Park.

Christine Tarrago
Chief Financial Officer
Christine Tarrago is the Chief Financial Officer at Tempo Telecom and Lingo Management with more
than +25 years of global financial executive leadership. Prior to joining BullsEye, Christine Tarrago served
among others as CFO of private equity backed organizations. Before that, she had leadership positions
at Siemens and Alstom. Originally from Europe, she graduated with a BA and MBA from the University of
Augsburg, Germany, started her career in Europe where she worked in public accounting on large
international publicly listed companies in Germany, France, and Spain. She is fluent in four languages
and is a registered CPA in the State of Illinois.

Alex Valencia
Chief Compliance Officer
Alex Valencia serves as Chief Compliance Officer for Tempo Telecom and Lingo Management and is a
20+ year veteran of the telecom industry. Alex oversees the Company’s government and legal affairs,
including corporate governance and directs all regulatory policies. Prior to joining Lingo, Alex served as
VP of Regulatory Affairs for Impact Telecom. He holds an LLM in International and Comparative Law
from Notre Dame Law School, a Juris Doctorate from Gonzaga University School of Law, and Bachelor
of Arts degrees in Political Science and Latin America Studies from Southern Methodist University.
John Ripley (Chief Operations Officer - Excess Telecom, Inc. and Insight Mobile, Inc.)
For the past 25 years John Ripley has worked with companies to build and execute high growth
strategies that revolve around profitable, sustainable and efficient growth. As Excess Telecom’s
Chief Operations Officer (“COO”), John oversees strategic execution while managing all customer
operations, field operations, compliance, legal, corporate operations, finance and accounting. John
will have the same role at Insight Mobile.
After starting his career in finance and accounting with big tech companies such as Oracle and
Microsoft, John pivoted to work with start-up and growth stage companies in the
telecommunications, healthcare, technology and services industries. Prior to joining Excess
Telecom as Chief Operations Officer in April 2022, John held executive leadership roles in the
Lifeline and Emergency Broadband Benefit Program space since 2013 when he served as COO and
Chief Financial Officer for IMMERGE, LLC. At IMMERGE, John managed a field operations and
compliance team that oversaw the activities of more than 3,000 field agents spread across the
United States. Under John’s guidance, IMMERGE successfully launched, grew and managed one
of the largest lifeline enrollment companies in the nation in a compliant-centric manner.
John also has worked extensively with companies and regulators to develop and execute growth
strategies in other highly regulated industries including healthcare, energy and banking. This broad
set of experience provides John with the skillset needed to manage both Excess and Insight toward a
compliance-centric, customer focused path of sustainable, profitable growth.

Andrew Whitelock (Chief Compliance Officer – Excess Telecom, Inc. and Insight Mobile, Inc.)
Over the past 25 years, Andrew Whitelock has developed and led compliance and risk management
programs in a variety of for-profit and non-profit companies. As Excess Telecom’s Chief
Compliance Officer, Andrew directs the activities of the company’s compliance program, manages
regulatory compliance and overseas risk management practices. Andrew will have the same role at
Insight Mobile.
Andrew began his career contracting with medical providers and hospitals to build a comprehensive
healthcare delivery network serving low-income and disadvantaged populations in Los Angeles. He
joined L.A. Care Health Plan in 1998 and progressed from provider contracting to regulatory
compliance, and then account executive managing two key corporate partnerships. In 2005,
Andrew became the Director of Government Contracts with Molina Healthcare of California and
was the Associate Vice President of Government Contracts when he departed in 2012 to become the
Compliance Officer at SCAN Health Plan. Prior to joining Excess Telecom, Andrew was SCAN’s
Chief Risk Executive. Andrew has experience managing diverse teams with a wide scope of
responsibilities. As the Chief Risk Executive at SCAN, he managed four departments with sixty-
five staff members and an annual budget of $11M.
Andrew has broad experience identifying and mitigating enterprise risks. He has worked
extensively with state and federal regulators to manage monitoring and auditing activities; review
proposed regulations and policies; and demonstrate compliance with program requirements.
Proactively managing enterprise risks is core to Andrew’s leadership role with both Excess Telecom
and Insight Mobile.
Andrew is a graduate of the University of Southern California (“USC”) with Bachelor of Arts
degrees in history and biological sciences. He also holds a Master of Science in international
development and non-profit management from USC, and a Master of Business Administration from
Pepperdine University.

Ryan Moxom (Vice President, Operations – Excess Telecom, Inc. and Insight Mobile, Inc.)
Ryan Moxom is Excess Telecom’s Vice President Operations. In this role, Ryan oversees all field
operations for the company, including agent training and onboarding, customer support and
customer engagement programs. Ryan will have the same role at Insight Mobile.
Ryan’s telecommunications experience includes being a Program Manager at the Universal Service
Administrative Company for the Lifeline program, managing Lifeline compliance matters for
Verizon, and Director of Regulatory Compliance for StandUp Wireless, a Lifeline and Affordable
Connectivity Program provider. In his most recent role, Ryan was a Lead Product Marketing
Manager with AT&T Inc.
Ryan is a graduate of the University of Florida with a Bachelor of Arts degree in Economics. He
also holds a Juris Doctor degree from the University of Georgia School of Law. Ryan has been a
member of the Georgia Bar since 2014.

EXHIBIT 6
Proposed Lifeline Offering
LIFELINE DATA BUNDLE Unlimited Voice anytime minutes per month
Unlimited Nationwide text messages
4.5 GB data per month
Data does not rollover Net cost to Lifeline customer: $0
TRIBAL LIFELINE BUNDLE Unlimited Voice anytime minutes per month Unlimited Nationwide text messages
15 GB data per month
Data does not rollover Net cost to Tribal Lifeline customer: $0
Information regarding TEMPO’s Lifeline service plan including additional airtime is available
at: https://mytempo.com/lifeline-wireless/

All packages include:
• Free calls to TEMPO Customer Service
• Free calls to 911 emergency services
• Free access to Voicemail, Caller-ID, and Call Waiting features
• Voice minutes may be used for Domestic Long Distance at no extra cost

EXHIBIT 7
PUBLIC DISCLOSURE DOCUMENT Financial Statements
CONFIDENTIAL IN ENTIRETY

EXHIBIT 7
TRADE SECRET Financial Statements

EXHIBIT 8
CERTIFICATE OF SERVICE I HEREBY CERTIFY that I caused a true and correct copy of TEMPO TELECOM,
LLC’s Application for Designation as an Eligible Telecommunications Carrier for the Limited
Purpose of Offering Lifeline Service to Qualified Households to be mailed, by USPS Tracking, to
the Tribes listed below:

Coeur d’ Alene Tribe 850 A Street Plummer, ID 83851
Kootenai Tribe of Idaho 142 County Road 38A, Bonners Ferry, ID 83805
Nez Perce Tribe of Idaho 120 Bever Grade Rd, Lapwai, ID 83540
Shoshone-BannockTribe of Idaho Mission Rd, Fort Hall, ID 83203

DATED THIS _7th_ day of August 2023.
____________________________ Lance J.M. Steinhart, Esq. Lance J.M. Steinhart, P.C. Attorneys at Law 1725 Windward Concourse, Ste. 150
Alpharetta, GA 30005 [phone] (Phone) [phone] (Facsimile) [e-mail] (Email)
Attorneys for TEMPO TELECOM, LLC