Verizon Wireless has announced a new $50 unlimited talk, text, and web prepaid plan for price sensitive new customers who don’t mind being stuck with a lower-end feature phone.

The new Verizon Unleashed unlimited plan has been test-marketed since April to prepaid customers in southern California and Florida, but will now be available nationwide from Verizon stores, Best Buy, Wal-Mart and Target.

Although existing Verizon Wireless prepaid customers may be able to sign up for the plan on their existing phones, new customers in test markets were limited to a selection of just a handful of “feature phones” that make web use and texting cumbersome:

• LG Cosmos™ 2 — Now into its second generation, this basic feature phone slightly improved its slide-out keyboard.  The phone was rated “adequate” for an entry-level feature phone, but CNET’s detailed review notes it lacks 3G EV-DO service.  That means you will be web browsing on Verizon’s painfully slow 1xRTT data network.  Verizon has no worries customers using this phone will chew up a lot of wireless data.  Customers rated the build quality as adequate, but found the keys on the first generation of this phone did tend to wear out with a lot of use.  It’s a true “throwaway” phone once the warranty expires.  Repairs always cost more than buying a new phone.  Verizon’s website prices the phone at a stiff $189.99 for month-to-month customers, but it will probably remain priced at around $99.99 for prepaid customers choosing the Unleashed plan.
• LG Accolade™ — A real workhorse basic phone for Verizon Wireless, the Accolade is much better for making and receiving calls than doing anything with texting or web use.  The phone has no QWERTY keyboard to type on, and no 3G service either, so its usefulness for data and texting is extremely limited.  But it is cheap, routinely selling for under $40.  CNET has a video review.  We suspect this phone will not be major part of the nationwide rollout of Unleashed, as Verizon appears to have discontinued it recently.
• Pantech Caper — A front facing tiny keyboard features prominently on this phone, which would have been considered cutting edge five years ago.  Now, it’s considered a ho-hum “feature phone” for the non-smartphone crowd.  It received a fair rating from most reviewers, with the biggest complaints coming from unintentional pocket dialing and button pressing, and a lousy built-in camera.  No 3G service.  The Caper also won’t win any awards for its ergonomics.  Verizon Wireless had been selling this phone in test markets for $80 earlier this year.  CNET’s video review is here.

There is a good chance a few different, more current feature phones will be introduced for the Unleashed plan later this week.  But they will all likely dispense with support for 3G service and lack features many customers increasingly seek on smartphones.

Verizon Wireless has traditionally done poorly in the prepaid market, because its plans are considerably more expensive that those offered by competitors, especially T-Mobile and Sprint.  Verizon Wireless had been charging $95 a month for unlimited talk/text prepaid service plus $0.99 per day for web use.  At those prices, Verizon has been losing prepaid customers, now down to 4.4 million.  Many of those customers fled to providers like Sprint’s Virgin Mobile, which saw a 23 percent increase in its customers, which now number 13.8 million.

Verizon’s $50 unlimited plan matches AT&T’s $50 prepaid unlimited GoPhone plan.  Analysts suggest both companies have set prices (and limitations on the phones that work with the plans) at a level that allows them to compete with lower-priced rivals, but does not encourage their contract customers to switch to a cheaper prepaid plan.

For data-hungry smartphone users, there is little here to persuade anyone to downgrade to a $50 prepaid plan.

When broadband customers sign up for service under a “price protection agreement,” also known as a “term contract,” “minimum commitment,” or “price-lock guarantee,” few consumers realize their broadband provider will typically renew the contract for an additional one to three year term automatically “for your convenience.”

These Automatically Renewable Contracts (ARCs) require customers to notify their ISP, typically in writing, at least 30 days before their term commitment expires to prevent the provider from renewing the agreement, subjecting customers to stiff early cancellation fees if they want to change providers.

Now the independent UK regulator and competition authority Ofcom has ruled those agreements deliver few benefits to the consumers locked into them and plans to ban them effective Dec. 31.

Richards

Ofcom’s chief executive Ed Richards said: “ARCs raise barriers to effective competition by locking customers into long-term deals with little additional benefit.”

At least 15 percent of British broadband consumers are currently signed to renewable contracts, which have been used by BT, Adept Telecom, Axis Telecom, Eze Talk and iTalk.

“Our research, in particular the econometric analysis that we commissioned on the switching behaviour of BT customers, indicates a clear causal link between ARCs and reduced levels of consumer switching,” Ofcom said in a statement. “We believe this effect stems from the opt-out nature of the process for contract renewal and that any example of such a contract is likely to be harmful to consumers and to effective competition.”

Providers love the auto-renewing contract because most customers long forget about them until they call to cancel service, at which point they face a stiff cancellation fee that can run into the hundreds of dollars.  Faced with that kind of exit fee, many consumers opt to stay with their existing provider, despite better offers from a competitor.

The contracts are also popular in North America, particularly with telephone companies who face increased competition from cable providers.  If a telephone company DSL product loses the speed war with an area cable competitor, holding customers in place with term contracts assures phone companies consumers will stay put.  The more services bundled into a customer contract, the higher the termination fee, especially if a signup bonus was provided.  Phone companies have tried offering free netbook computers, free satellite television, and free HD televisions as part of contract bundles that can last as long as three years.  Some have cancellation fees of up to $500 if a customer leaves early.

Ofcom hopes the retirement of these contracts will encourage consumers to shop around for the best possible broadband and landline deals that serve their specific needs.

Shamrock Museum

The city of Shamrock, Okla. may not be a city for much longer, facing unincorporation and liquidation of its remaining assets, which include the abandoned police cars that used to earn the city enough ticket revenue to keep the doors open.  But fast (and free at the local community center) Internet prevails (with competition, too) in a city with fewer than 100 remaining citizens.  It’s all thanks to a federal broadband grant and an existing Wireless ISP.

Shamrock’s unlucky predicament comes at the expense of the boom-and-bust oil business that launched dozens of small towns in rural Oklahoma, only to leave them largely abandoned when the oil dried up, or the cost to access it becomes too prohibitive.  Once a community numbering 10,000, Shamrock, located nearly halfway between Oklahoma City and Tulsa, had recently been surviving on revenue earned from writing traffic tickets in infamous speed traps set up along Highway 16.  Shamrock, along with Big Cabin, Caney, Moffett, and Stringtown, became so notorious for their dependence on traffic ticket revenue to keep the towns afloat, at one point the state government publicly designated them “speed trap towns” and banned them from writing tickets on state and federal highways. When Creek County officials learned the city was using non-commissioned officers to write tickets, they shut down the whole operation.

Soon after, residents found the city hall padlocked, with coffee cups still on the desks and police evidence lockers still stuffed with property from active criminal cases (although seized marijuana and beer has since disappeared.)

In fact, the only service now in operation at the city hall, now converted into a “community center,” is Internet access on 10 computers made possible by @Link Services LLC, an Oklahoma City-based Wireless Internet Service Provider (WISP) that provides service in rural areas, with the help of a broadband grant from the U.S. Dept. of Agriculture.

The broadband grant, amounting to $536,000, with matching funds of $134,000 kicked in by @Link, covers the costs of running the community center for two years and extending wireless access with the construction of a new wireless radio tower in Stillwater, which allows the company to reach Shamrock residents.

In addition to providing free access at the former city hall, @Link also sells Internet access to area residents (the only remaining business in town is a diner):

“This is going to be the last place anyone would provide Internet without government funding because there is no chance of turning a profit,” Kerry Conn, chief financial officer of @Link Services told The Oklahoman. “But if you don’t have Internet services, your town is going to die.”

@Link CEO Samual Curtis says their wireless Internet access sells itself.

“Broadband is a very easy sell where there is no broadband,” Curtis told the newspaper.

The only problem with that is Shamrock currently does receive service from another Wireless ISP — OnALot, a service of HDR Internet Services, Inc.  OnALot operates from 70 systems in more than 25 cities and communities across rural Oklahoma.  @Link’s arrival in town, with the assistance of a federal broadband grant, came as a surprise to some Shamrock residents who already had Internet service from OnALot.  Now those customers have two choices — both wireless — for Internet service.  OnALot, the incumbent, is often cheaper, too:

OnALot does not sell traditional speed tiers.  Instead customers share access points rated at speeds of 11 and 54Mbps.  Customers do not actually see anything close to those speeds, because they are theoretical maximums and each access point is shared by several users.  But since many residential customers do not have a firm understanding of what different speed levels represent, it has proven workable for HDR Internet to sell services based on price, not speed.

OnALot does sell dedicated, private wireless circuits to customers who don’t want to share, but they are comparatively expensive:

OnALot.com operates both standard Line-of-Sight and Near-Line-of-Sight systems on the 80' tall water tower on the west side of Shamrock.

One Oklahoman reader, Bobbi, wondered why @Link received federal grant money to provide Internet service in a community that already had access.

“Why this company didn’t do their homework before they used government money to provide a service to a town that had that service,” Bobbi asked. “Wouldn’t that be a misuse of the grant money?”

Broadband grant funding has come under criticism at times for funding projects that incumbent providers accuse of duplicating services.  A study funded by the National Cable & Telecommunications Association, the cable industry’s top lobbyist, found several instances of grants that would deliver broadband service to areas already served by other providers.

“While it may be too early for a comprehensive assessment of the [government]’s broadband programs, it is not too early to conclude that, at least in some cases, millions of dollars in grants and loans have been made in areas where a significant majority of households already have broadband coverage, and the costs per incremental home passed are therefore far higher than existing evidence suggests should be necessary,” the study says.

Thus far, much of the funding for rural Oklahoma seems to be directed towards wireless Internet access projects, which typically serve sparsely populated areas cable and phone companies have traditionally ignored.

The NCTA’s criticism, in particular, was directed against its would-be competitors.  The lobbying group suggests the price of competition was too high.

Based on the cost of the direct grants and subsidizing the loans, the NCTA study estimated that the cost per incremental home passed would be $30,104 if existing coverage by mobile broadband providers was ignored, and $349,234 if mobile broadband coverage was taken into account.

Wireless ISP operators have told Stop the Cap! many of their projects are self-financed and do not receive government assistance.  Some WISP operators have accused the government of making broadband grants to wireless operators a cumbersome, if not impossible prospect because incumbent telephone companies are often most likely to meet the government’s grant criteria.

For Shamrock residents, one piece of good news: @Link Services and OnALot both have no Internet Overcharging schemes like usage caps.  However, OnALot prohibits the use of peer-to-peer software (torrents) and @Link Services maintains the right to curtail speeds for those who create problems for other users on their shared wireless network.

OnALot’s usage policies are among the most frank (and common sense) we’ve seen, because they are up front with customers about the impact certain traffic can have on their wireless network:

1. You are paying us to download from the Internet. We do not limit you on that. You can download anything you want 24/7. Games, email, web pages, radio stations, and so on – we don’t care, downloading is what you are paying us for. That said, we would prefer that you do not leave an active game un-attended, or run a radio station continuously, as these eat up bandwidth that others could be using. When you’re done with your game, please turn it off.
2. We do have restrictions when it comes to uploading TO the Internet. P2P or Peer-to-Peer programs are NOT allowed. These limitations apply primarily to file sharing programs. We do NOT allow music or video sharing programs, bit torrent programs or other programs where outside users can extract files from your computer with or without your express consent. And seriously, do you actually WANT others to have full access to your computer? That’s what you’re giving to file sharing programs! Please call us if you are unsure if the program you are using is a file sharing program.
3. Yes, you can upload to your favorite website, send big emails, and transfer any size files that are under your control. That’s OK with us – these are intermittent in nature and under your full control. It’s the unattended uploading that sharing programs do that we do not allow.
4. If your computer has a virus and is “spewing” out onto the Internet, we expect you to have it cleaned. Causing others to become infected is wrong, and we may take steps to disable your Internet connection. We will call you first, explain what is going on and ask that you have your machine cleaned. If you decide not to do this, we will then cut you off until you do.

Not satisfied with relying on the U.S. Department of Justice to protect the competitive marketplace for cell phone service, Sprint Nextel today brought suit against AT&T, Inc., AT&T Mobility, Deutsche Telekom and T-Mobile seeking to block the proposed acquisition as a violation of Section 7 of the Clayton Act. The lawsuit was filed in federal court in the District of Columbia as a related case to the Department of Justice’s (DOJ) suit against the proposed acquisition.  It has been assigned to the same judge handling the Justice Department’s own lawsuit — Judge Ellen S. Huvelle.

“Sprint opposes AT&T’s proposed takeover of T-Mobile,” said Susan Z. Haller, vice president-Litigation, Sprint. “With today’s legal action, we are continuing that advocacy on behalf of consumers and competition, and expect to contribute our expertise and resources in proving that the proposed transaction is illegal.”

Sprint’s lawsuit focuses on the competitive and consumer harms which would result from a takeover of T-Mobile by AT&T. The proposed takeover would:

• Harm retail consumers and corporate customers by causing higher prices and less innovation;
• Entrench the duopoly control of AT&T and Verizon, the two “Ma Bell” descendants, of the almost one-quarter of a trillion dollar wireless market. As a result of the transaction, AT&T and Verizon would control more than three-quarters of that market and 90 percent of the profits;
• Harm Sprint and the other independent wireless carriers. If the transaction were to be allowed, a combined AT&T and T-Mobile would have the ability to use its control over backhaul, roaming and spectrum, and its increased market position to exclude competitors, raise their costs, restrict their access to handsets, damage their businesses and ultimately to lessen competition.

Sprint believes that in a marketplace dominated by AT&T and Verizon Wireless, the two largest players would likely collude on pricing and terms of service rather than compete heavily against one-another.  Sprint’s assumptions may already be true, considering both companies largely charge near-identical prices for service.

While Sprint proceeds with its own legal action, squabbling has broken out over whether or not AT&T so carefully crafted the terms and conditions of their $6 billion “breakup fee,” payable to T-Mobile USA if the merger fails, that it almost guarantees AT&T will never have to pay it.

“Under its agreement with Deutsche Telekom, the deal is only valid if the acquisition receives regulatory approval within a certain time frame,” an anonymous source told Reuters. “Also, the agreement could become invalid if regulatory conditions for the sale push the value of T-Mobile USA below a certain level.”

T-Mobile, unsurprisingly, disagrees with that characterization.

A Deutsche Telekom spokesman said Tuesday that AT&T could retreat from the transaction if the concessions necessary to get approval amount to more than $7.8 billion, but added Deutsche Telekom would still be entitled to receive the break-up fee package, which includes cash and wireless spectrum.

News Release

Justice Department Files Antitrust Lawsuit to Block AT&T’s Acquisition of T-Mobile

Transaction Would Reduce Competition in Mobile Wireless Telecommunications Services, Resulting in Higher Prices, Poorer Quality Services, Fewer Choices and Fewer Innovative Products for Millions of American Consumers

WASHINGTON – The Department of Justice today filed a civil antitrust lawsuit to block AT&T Inc.’s proposed acquisition of T-Mobile USA Inc.   The department said that the proposed $39 billion transaction would substantially lessen competition for mobile wireless telecommunications services across the United States, resulting in higher prices, poorer quality services, fewer choices and fewer innovative products for the millions of American consumers who rely on mobile wireless services in their everyday lives.

The department’s lawsuit, filed in U.S. District Court for the District of Columbia, seeks to prevent AT&T from acquiring T-Mobile from Deutsche Telekom AG.

“The combination of AT&T and T-Mobile would result in tens of millions of consumers all across the United States facing higher prices, fewer choices and lower quality products for mobile wireless services,” said Deputy Attorney General James M. Cole.   “Consumers across the country, including those in rural areas and those with lower incomes, benefit from competition among the nation’s wireless carriers, particularly the four remaining national carriers.   This lawsuit seeks to ensure that everyone can continue to receive the benefits of that competition.”

“T-Mobile has been an important source of competition among the national carriers, including through innovation and quality enhancements such as the roll-out of the first nationwide high-speed data network,” said Sharis A. Pozen, Acting Assistant Attorney General in charge of the Department of Justice’s Antitrust Division.   “Unless this merger is blocked, competition and innovation will be reduced, and consumers will suffer.”

Mobile wireless telecommunications services play a critical role in the way Americans live and work, with more than 300 million feature phones, smart phones, data cards, tablets and other mobile wireless devices in service today.   Four nationwide providers of these services – AT&T, T-Mobile, Sprint and Verizon – account for more than 90 percent of mobile wireless connections.   The proposed acquisition would combine two of those four, eliminating from the market T-Mobile, a firm that historically has been a value provider, offering particularly aggressive pricing.

According to the complaint, AT&T and T-Mobile compete head to head nationwide, including in 97 of the nation’s largest 100 cellular marketing areas.   They also compete nationwide to attract business and government customers.  AT&T’s acquisition of T-Mobile would eliminate a company that has been a disruptive force through low pricing and innovation by competing aggressively in the mobile wireless telecommunications services marketplace.

The complaint cites a T-Mobile document in which T-Mobile explains that it has been responsible for a number of significant “firsts” in the U.S. mobile wireless industry, including the first handset using the Android operating system, Blackberry wireless email, the Sidekick, national Wi-Fi “hotspot” access, and a variety of unlimited service plans.   T-Mobile was also the first company to roll out a nationwide high-speed data network based on advanced HSPA+ (High-Speed Packet Access) technology.  The complaint states that by January 2011, an AT&T employee was observing that “[T-Mobile] was first to have HSPA+ devices in their portfolio…we added them in reaction to potential loss of speed claims.”

The complaint details other ways that AT&T felt competitive pressure from T-Mobile.   The complaint quotes T-Mobile documents describing the company’s important role in the market:

• T-Mobile sees itself as “the No. 1 value challenger of the established big guys in the market and as well positioned in a consolidated 4-player national market”; and
• T-Mobile’s strategy is to “attack incumbents and find innovative ways to overcome scale disadvantages.   [T-Mobile] will be faster, more agile, and scrappy, with diligence on decisions and costs both big and small.   Our approach to market will not be conventional, and we will push to the boundaries where possible. . . . [T-Mobile] will champion the customer and break down industry barriers with innovations. . . .”

The complaint also states that regional providers face significant competitive limitations, largely stemming from their lack of national networks, and are therefore limited in their ability to compete with the four national carriers.   And, the department said that any potential entry from a new mobile wireless telecommunications services provider would be unable to offset the transaction’s anticompetitive effects because it would be difficult, time-consuming and expensive, requiring spectrum licenses and the construction of a network.

The department said that it gave serious consideration to the efficiencies that the merging parties claim would result from the transaction.   The department concluded AT&T had not demonstrated that the proposed transaction promised any efficiencies that would be sufficient to outweigh the transaction’s substantial adverse impact on competition and consumers.   Moreover, the department said that AT&T could obtain substantially the same network enhancements that it claims will come from the transaction if it simply invested in its own network without eliminating a close competitor.

AT&T is a Delaware corporation headquartered in Dallas.   AT&T is one of the world’s largest providers of communications services, and is the second largest mobile wireless telecommunications services provider in the United States as measured by subscribers.   It serves approximately 98.6 million connections to wireless devices.   In 2010, AT&T earned mobile wireless telecommunications services revenues of $53.5 billion, and its total revenues were in excess of $124 billion.

T-Mobile, is a Delaware corporation headquartered in Bellevue, Wash.   T-Mobile is the fourth-largest mobile wireless telecommunications services provider in the United States as measured by subscribers, and serves approximately 33.6 million wireless connections to wireless devices.   In 2010, T-Mobile earned mobile wireless telecommunications services revenues of $18.7 billion.   T-Mobile is a wholly-owned subsidiary of Deutsche Telekom AG.

Deutsche Telekom AG is a German corporation headquartered in Bonn, Germany.   It is the largest telecommunications operator in Europe with wireline and wireless interests in numerous countries and total annual revenues in 2010 of €62.4 billion.

Download a copy of the Complaint (PDF)

 

Deputy Attorney General James M. Cole Speaks at the AT&T/T-Mobile Press Conference

Washington, D.C. ~ Wednesday, August 31, 2011

[flv]http://www.phillipdampier.com/video/CNBC Cole Comments on Merger Opposition 8-31-11.flv[/flv]

Good morning.   Millions of Americans rely on mobile wireless telecommunications services in their everyday lives.   Whether you are a parent using a cell phone to check up on your teenager or a working professional using a laptop or smart phone to conduct business or surf the web, mobile wireless communications plays a vital – and increasing – role in our daily lives.

We all reap the benefits of this incredible technology because there has been fierce competition in this industry, which has brought all of us innovative and affordable products and services.

Cole

In order to ensure that competition remains and that everyone – including consumers, businesses and the government – continues to receive high quality, competitively priced mobile wireless products and services, the Department of Justice today filed an antitrust lawsuit in U.S. District Court in Washington, D.C. to block AT&T’s acquisition of T-Mobile.

The Department filed its lawsuit because we believe the combination of AT&T and T-Mobile would result in tens of millions of consumers all across the United States facing higher prices, fewer choices and lower quality products for their mobile wireless services.

Consumers across the country, including those in rural areas and those with lower incomes, have benefitted from competition among the nation’s wireless carriers, particularly the four remaining national carriers.   This lawsuit seeks to ensure that everyone can continue to reap the benefits of that competition.

Right now, four nationwide providers account for more than 90 percent of the mobile wireless connections in America, and preserving competition among them is crucial.   For instance, AT&T and T-Mobile currently compete head-to-head in 97 of the nation’s largest 100 cellular marketing areas.   They also compete nationwide to attract business and government customers.   Were the merger to proceed, there would only be three providers with 90 percent of the market, and competition among the remaining competitors on all dimensions—including price, quality, and innovation—would be diminished.

As can be seen in the Department’s complaint, AT&T felt competitive pressure from T-Mobile.   One example cites an AT&T employee observing that “[T-Mobile] was first to have HSPA+ devices in their portfolio…we added them in reaction to potential loss of speed claims.”

So as you can see, a merged AT&T and T-Mobile would combine two of the four largest competitors in the marketplace, and would eliminate T-Mobile, an aggressive competitor, from the market.

Although there has been a leadership change in the Antitrust Division, one thing has not changed – the Division will remain steadfast in its mission to vigorously enforce the antitrust laws.

And that’s what the Department has done today.   The leadership transition has been seamless and the right decision was reached in this case.

We are seeking to block this deal in order to maintain a vibrant and competitive marketplace that allows everyone to benefit from lower prices and better quality and innovative products.

I want to express my own deep gratitude for the efforts of so many members of the Antitrust Division staff who have tremendous expertise in this important industry.   And Sharis, I want to thank you for your leadership in this effort.   You and your team have done the right thing for consumers.

And now, Acting Assistant Attorney General Sharis Pozen will say a few words.

 

Acting Assistant Attorney General Sharis A. Pozen Speaks at the AT&T/T-Mobile Press Conference

Washington, D.C. ~ Wednesday, August 31, 2011

Thank you, Jim.   And thank you for your leadership and support on this case.

As the Deputy Attorney General mentioned, this is an extremely vital industry with more than 300 million feature phones, smart phones, data cards, tablets, and other mobile wireless devices in service today.   As you are well aware, the Department of Justice has significant experience in this industry going as far back as the original breakup of AT&T.   We know this industry well—inside and out.

Here, the Antitrust Division conducted an exhaustive investigation.   We conducted dozens of interviews of customers and competitors, and we reviewed more than 1 million AT&T and T-Mobile documents.   The conclusion we reached was clear.   Any way you look at this transaction, it is anticompetitive.   Our action today seeks to ensure that our nation enjoys the competitive wireless industry it deserves.

Sharis (Courtesy: Main Justice)

T-Mobile has been an important source of competition among the national carriers through innovation and quality enhancements.   For example, T-Mobile rolled-out the first nationwide high-speed data network using advanced HSPA+ technology and the first handset using the Android operating system.   It has also been an important source of price competition in the industry.   Unless this merger is blocked, competition and innovation in the mobile wireless market, in the form of low prices and innovative wireless handsets, operating systems, and calling plans, will be diminished—and consumers will suffer.

T-Mobile competes with the other three national providers to attract individual consumers, businesses, and government customers for mobile wireless telecommunications services. They compete on price, plan structure, network coverage, quality, speed, devices, and operating systems.   A combination of AT&T and T-Mobile would eliminate this price competition and innovation.   It would reduce the number of nationwide competitors in the marketplace from four to three.   Eliminating this aggressive competitor, which offers low pricing and innovative products, would hurt consumers, businesses, and government customers that rely on a competitive marketplace to provide them with the best products at the best possible price.

It is important to move expeditiously to preserve the lower prices and innovation resulting from T-Mobile’s competitive presence in this market.   That’s why we filed a lawsuit to block this transaction—our goal is to preserve price competition and innovation in this important industry.

I want to thank the Division’s Deputies for their expertise and counsel.   And I want to especially recognize the Telecommunications staff led by Chief Laury Bobbish and the many others in the Division for their tireless work on this important matter.   Consumers and businesses around the country owe you a great deal of thanks.   We also want to thank our partners in law enforcement, including the Federal Communications Commission and the state Attorneys General who have assisted and partnered with us in our investigation.