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"We hired Jonathan to represent our telecommunications licensing needs. At the time we were a start-up company with only a small amount of investment revenue. Attorney costs could have been enough to rethink the business plan. Jonathan worked with us on a payment plan basis which allowed us to focus on getting customers while he worked on getting us our licenses. He provided introductions to companies we eventually hired to assist us with tax issues and other FCC requirements. When we were interested in selling our company Jonathan made introductions to other telecom companies that were in the market for our type of company. He managed the contract process at every level through the acquisition. The best recommendation I can give is that when I go to do this again I will hire Jonathan."
"Jonathan is well-versed in a broad range of telecom regulatory matters. He uses his expertise to arrive at innovative, real-world business solutions while maintaining a high degree of professionalism."
"Jonathan is extremely knowledgeable in his field. He has provided invaluable telecom expertise to us and our subsidiary company on countless occasions. We would be lost without him. I highly recommend Jonathan!"
"Jonathan['s firm] was able to provide our ISP association with fresh responses to the RBOC FCC petitions as opposed to the boilerplate comments most law firms offered. Jonathan has a good understanding of the industry and how things work at the FCC."
—COO of a leading virtual
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unit of foreign PTT
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nationwide Hosted
VoIP provider
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of US operating unit
of international multi-media
conglomerate
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regional CLEC
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international communications carrier
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provider of long distance,
wireless, point-of-sale and
carrier services
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regional CLEC
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leading provider of
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—Member, Federation of
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Contact Information

Marashlian & Donahue, LLC

The CommLaw Group
1420 Spring Hill Road
Suite 401
McLean, Virginia 22102

Telephone: (703) 714-1300
Facsimile: (703) 714-1330

E-mail: mail@commlawgroup.com
Proposed USF Contribution Factor for 4th Quarter 2010 is 12.9%
09/10/2010

The FCC recently announced that the proposed Federal Universal Service Fund ("USF") contribution factor for the Fourth Quarter of 2010 will be 0.129 or 12.9%.  This amount is a decrease from the Third Quarter 2010 contribution factor of 13.6%.

Unless otherwise notified by our firm, clients may presume the FCC approved the new rate, and that the new rate will be in effect from October 1, 2010 until l December 31, 2010.

Detailed information about the methodology the FCC used to set the new contribution factor, along with notices of past contribution factors, can be found on the FCC's website at:

http://www.fcc.gov/omd/contribution-factor.html

CLIENT ACTION ITEMS:

All contribution-eligible telecommunications carriers and interconnected VoIP providers must apply the new factor to all interstate telecommunications revenue received during the effective reporting period and contribute to the USF accordingly by filing FCC Form 499-Q. Clients who file FCC Form 499-Q with the FCC will receive invoices from the fund administrator, the Universal Service Administrative Company ("USAC"), that applies this factor to retail interstate telecommunications revenue.

Contributing telecommunications carriers are permitted to pass-through the USF contribution fee to end-users through the use of a Federal USF line-item on bills. However, under the FCC's Truth-in-Billing rules, contributing telecommunications carriers may not mark up the Federal USF line-item amounts above the current contribution factor.  Thus, clients may not, through a Federal USF line-item, recover an amount in excess of the proposed USF contribution factor from the interstate telecommunications charge on a customer's bill.

LIRE-eligible Contributors May Petition the FCC for Waiver

Since the proposed contribution factor exceeds 12 percent (the threshold for the FCC's limited international revenue exemption ("LIRE") ), international telecommunications providers who are LIRE-eligible may face contribution obligations in excess of interstate end-user telecommunications revenue. Clients who face this situation should petition the FCC for waiver of the LIRE threshold.

All LIRE-eligible contributing clients should contact Jonathan Marashlian at The Commlaw Group directly at jsm@commlawgroup.com.

Late Payment Penalties

Clients are reminded that USF contribution payments must be made promptly by the due date listed on monthly contribution invoices, or else they may face interest and penalties from both USAC and the FCC. Failure to make timely payments automatically subjects contributors to substantial interest and monetary penalties. In addition, USAC may bill clients for the cost of collecting overdue contributions and refer the matter to the FCC's Enforcement Bureau for further sanctions.

Clients who would like assistance instituting the new contribution factor for purposes of contributing to the USF, or have FCC regulatory compliance questions in general, should contact Chris Canter at cac@commlawgroup.com or Jonathan Marashlian at  jsm@commlawgroup.com.