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Abstract
NECA continued, "AT&T's second offering simply merges AT&T's ordinary prepaid caUing card service with Internet Protocol (JP) transport. The FCC has previously determined that AT&T's calling card service is a telecommunications service. The Commission has also determined that AT&T's ??-in-the-middle' services are telecommunications services. Bundling the two together does not in any way transform AT&T's caUing card service variant into an information service."
SBC Communications, Inc., said the FCC itself has acknowledged "the urgent need to reform the current intercarrier compensation rules," which Commissioner Michael J. Copps has described as "Byzantine and broken." SBC added, "The Commission simply cannot afford to expend its scarce resources on less pressing intercarrier compensation issues - such as the creation of new rules for prepaid calling card services - until after it has finished the job of comprehensively reforming its existing intercarrier compensation rules, which it began almost four years ago."
MCI, Inc., said that the regulatory uncertainty facing the industry "is not unique to prepaid calling cards and cannot be resolved in an inquiry concerning only enhanced prepaid services. To the contrary, the uncertainty stems from conflicting statements the Commission has made concerning the Communications Act's definitional terms 'telecommunications services' and 'information services,' and beyond that, from longstanding confusion about the appUcation of the Commission's definitions of 'basic' and 'enhanced' services when they are applied to enhanced service providers who use their own transmission faculties."
In its own comments, AT&T argued that the FCC "plainly" should classify some calling-card services as information services. "In AT&T's new offering, for example, the end user affirmatively interacts with AT&T's computer platform by actively choosing the information she wants and otherwise manipulating stored information, which is precisely the type of service the Commission has consistently found to be an information service," AT&T wrote.