1. Still Cramming after all these Years? Chris Witteman California Public Utilities Commission* wit@cpuc.ca.gov NASUCA Presentation *for identification purposes only

2. What We’re Talking About

3. System Architecture

4. Confusing Bills

5. Confusing Bills -- No Service Provider Listed

6. Complaint Tracking Issues

7. Consumer Rage –www.consumeraffairs. comwww.consumeraffairs. com –www.ripoffreport.comwww.ripoffreport.com –www.complaintsboard. comwww.complaintsboard. com –www.classactionconne ct.comwww.classactionconne ct.com

8. Charles YoungCharles Young says: I have landline phone service and DSL with AT&T. I pay for my long distance service on a separate bill. My AT&T bill this month included $8.44 for ILD Teleservices. I called AT&T and informed them that I did not order or want any services from or through AT&T other than DSL and landline phone. I asked them to remove the charges and block all future third party charges. The customer rep replied that I have to call ILD Teleservices to cancel my service, and that AT&T is unable to block third party services. As I explained to the rep, I did not order anything from ILD Teleservices, I do not know what ILD Teleservices is, and I should not have to call some unknown third party to correct my AT&T bill. The Run-Around

9. Brenda of Fairfield, CA June 10, 2010 Upon receiving this month's AT&T billing, we are again charged 13.21 for May. After you credited the account for the previous 25.90 for March and April to cancel the unwanted service. I'm not sure of what part of we did not ask for or request this service you understand. PLEASE DISCONTINUE THIS SERVICE IMMEDIATELY AND CREDIT FOR THE MONTH OF MAY FOREVER. I don't want to do this each month. I am also again contacting Consumer Affairs and AT&T of this unfair business practice via this e-mail. I do not understand why consumers must go through this each month to cancel a service we did not request. Repeat request to agent

10. Cal PU Code 2890 (a) A telephone bill may only contain charges for products or services, the purchase of which the subscriber has authorized…. (d) (1) A billing telephone company shall clearly identify, and use a separate billing section for, each person, corporation, or billing agent that generates a charge on a subscriber's telephone bill.

11. CPUC Cramming Actions –ATN – D 98 03 039 –USP&C – D.01-04-036 - aggregator, later Mafia indictment –ASI DSL – D.02-10-073 – unauthorized DSL charges - $27 million settlement –MCI settlement – approved in D.06-04-035 –Americatel Investigation – I.10-02-003

12. Enforcement problems/defenses Counting problems – how many victims? Consumer confusion about responsible parties “call detail record” defense Blame-it-on-the-telemarketer defense Anyone-in-house-can-authorize defense Conflict of interest – billing telcos, aggregators

13. Solutions **Third-party bill block** Hold billing telcos responsible Clean up reporting –Audit, Enforce, (Clarify?) Remove presumption that CDR = authorizn More TPVs, Better TPVs (whole sales pitch) More Enforcement

14. Network Architecture network architecture Service/content provider ↔ Aggregator ↔ Billing Telco ↔ Customer $$ flow right to left  re tracking credits and debits through the foodchain