Request to Cancel 8-27-10.pdf

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ANGELA F. COLLINS 202-862-8930 I acoIlins(fYcgrdc.com
August 26, 2010
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83702
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Via Federal Express
Re:Notification of Consummation of Transaction between Dialaround'
Enterprises Inc. and STi Prepaid, LLC
and
Dialaround Enterprises Inc. Request to Discontinue Service and Cancel Price
List
Dear Ms. Jewell:
Dialaround Enterprises Inc. ("DEI") and STi Prepaid, LLC ("STi Prepaid"), by their
attorneys, file this letter in connection with an Asset Purchase and Contribution Agreement
between DEI and STi Prepaid and their respective individual owners and corporate parents dated
January 23 , 2007 (the "Transaction ). The parties notified the Idaho Public Utilities
Commission ("Commission ) ofthis Transaction on March 2007 Notification ). DEI and
STi Prepaid hereby notify the Commission that the Transaction was consummated on June 11
2010.
In connection with the Transaction, DEI hereby respectfully requests authority to
discontinue operations and cancel its price list for the state of Idaho effective immediately.! As
discussed in the Notification, any consumers previously using DEI's casual calling (10-, dial-
around) services will now be served by STi Prepaid, which is authorized to provide resold long
distance service in Idaho
Customer notice is not required for discontinuance of DEI's services because DEI does
not have a dedicated customer base. Dial-around services can be used by any person at any time
by dialing a specified access code prior to making a telephone call. DEI has no knowledge of the
identity of the person that may utilize its dial-around services on a day-to-day basis, and has no
established, ongoing relationship with the person utilizing the dial-around code (a third-party
Letter dated November 2002 accepting price list.
Letter dated March 29, 2007 accepting price list.
145009.
Page 2
billing and collection vendor interacts with the consumer when and if the dial-around service is
used). Cancellation of DEI's certificate will therefore be transparent to Idaho consumers.
Moreover, Idaho consumers will continue to receive the same service previously enjoyed and
likely enhanced over time due to the benefits flowing from the Transaction. Accordingly,
customer notification of the cancellation is unnecessary and would be almost impossible.
Pursuant to the Commission s filing procedures, please find enclosed an original plus two(2) copies of this letter. Please date-stamp the additional copy of this letter and return it to us in
the enclosed envelope. If you have any questions regarding this filing, please contact the
undersigned.
Respectfully submitted
dJJ.1
Counsel for Dialaround Enterprises Inc. and
STi Prepaid, LLC
See, e.g., Comments Invited on Application of Trans communications Incorporated to Discontinue Domestic
Telecommunications Services WC Docket No. 05-161 , Public Notice, DA 05-999 (reI. Apr. 4, 2005) (FCC grantingdiscontinuance of prepaid calling card services without comment based on statements that the calling card provider
could not provide customer notice because it did not know the identity and address of the consumers of its calling
cards and thus it would be effectively impossible to provide written notice of the discontinuance of service to each
affected cardholder); Notice of Domestic Section 214 Authorization Granted Public Notice, DA 07-1082 (Mar. 82007) (FCC approving transfer of prepaid calling card and dial-around assets without comment based on statements
that calling card provider could not provide customer notice because it did not know the identity and address of the
consumers using its services).
145009.