1. Piracy on the Cyberseas Dianne E. Dusman Senior Assistant Consumer Advocate Pennsylvania Office of Consumer Advocate 555 Walnut Street, Fifth Floor, Forum Place Harrisburg PA 17101-1923 000142639.doc November 16, 2006

4. HOW DOES CRAMMING HAPPEN? “iffy” websites inadequate disclosures small print e-mails from scammers unscrupulous telemarketers

5. I ACCEPT You accept that you will be charged and you will pay $2.99 per minute, along with a $1.99 charge for the actual long distance connection on your local phone bill by Telliss Billing. You will incur charges by accessing this pay-per-view internet service from the international long distance charge of $2.99 per minute, with a $1.99 connect fee. This amount will be billed by Telliss Billing on your local phone bill. These charges are accurate for the connection. NO SLAMMING or CRAMMING for these telephone charges have occurred.

6. Pennsylvania Regulations, 52 Pa. Code 64.23: Unauthorized charges must be removed from the customer’s bill upon request. One contact to the Local Exchange Carrier should resolve the cramming dispute!

7. Negotiated Settlements between PaOCA, Verizon & Aggregators led to Approximately $702,500 in refunds and credits to PA customers alone.

8. How does it happen? Is there sufficient vigilance on the part of local exchange carriers and aggregators? Is there sufficient vigilance on the part of local exchange carriers and aggregators? Are carriers and aggregators respecting the FCC anti-cramming best practice guidelines? [http://www.fcc.gov/Bureaus/Common_Carrier/Other/cramming.html] Are carriers and aggregators respecting the FCC anti-cramming best practice guidelines? [http://www.fcc.gov/Bureaus/Common_Carrier/Other/cramming.html] Initial screening, complaint thresholds, fees for unauthorized charge disputes? Initial screening, complaint thresholds, fees for unauthorized charge disputes? Disclosure of crams to enforcement agencies? Disclosure of crams to enforcement agencies?

9. Possible Innovations? Early Warning Systems? Aberrant charge kick-outs, OR Aberrant charge kick-outs, OR Calls by Customer Service Reps to consumers to confirm purchases if new charges appear Calls by Customer Service Reps to consumers to confirm purchases if new charges appear

10. 2010-11 PA complaints allege cramming by Rask Network/Transition Clearing; International Satellite Comm.; Rocket Comm.; USBI, OAN, ILD Teleservices, Pamentone; Fetch Unlimited; Payment One/Pathway Profits; ESBI, Comlink Direct, Voice Express, AOS, Select Options, PBI, adigitalvillage.com, USA Voicemail, Streaming Flix, Meteline Tech… among others

11. Factors in 2010 - 2011 PA complaints Charges: $6.31 to $16.95 per month Charges: $6.31 to $16.95 per month Appeared on up to six months’ bills Appeared on up to six months’ bills Often involved 2 to 3 companies Often involved 2 to 3 companies (other than LEC) (other than LEC) Appeared to involve Internet use or telemarketing Appeared to involve Internet use or telemarketing

12. Multiple Potential Approaches to Eliminating Cramming Prevention by carriers/aggregators using best anti-cramming practices and innovative technology Prevention by carriers/aggregators using best anti-cramming practices and innovative technology Consumer education by carriers, govt. agencies, consumer groups Consumer education by carriers, govt. agencies, consumer groups Enforcement /Injunctions against initiators and non-compliance carriers Enforcement /Injunctions against initiators and non-compliance carriers –State, federal, administrative agencies all play a role.

13. Thanks for your kind attention!