COMMENTS OF THE PUBLIC COUNSEL SECTION
OFFICE OF ATTORNEY GENERAL
NOTICE OF PROPOSED RULEMAKING
TELECOMMUNICATIONS FAIR PRACTICES
DOCKET NO. UT-960942

June 19, 1997


I. INTRODUCTION

 The office of Public Counsel, Washington Attorney General, submits the 
following comments in response to the Commission's Notice of Proposed 
Rulemaking dated May 21, 1997.

 Public Counsel filed comments in the CR 101 phase of this proceeding, and 
refers to the Commission to those, as well as to the following comments.

 Public Counsel strongly supports the Commission's efforts to address consumer 
protection issues raised by the emergence of competition in 
telecommunications.  These proposed rules begin the process of addressing this 
important topic.  As Public Counsel has argued in its earlier comments, there 
are additional areas which the Commission should also address as implementation 
of competition continues.  The topics contained in the notice are a reasonable 
start, but they should be viewed as the beginning of a multi-stage process to 
adopt necessary consumer protections. Our comments below are intended to 
suggest alternative and expanded provisions to address the topics that are 
proposed for the current rulemaking.

II. PROPOSED RULES

 While Public Counsel generally concurs with the general direction of the draft 
rules attached to the NPRM, we suggest a number of changes and additions. These 
changes and additions are designed to clarify the proposed rules, add important 
provisions that relate to enforcement and prevention of unfair practices, and 
more clearly state the Commission’s overall policy with regard to a consumer’s 
right to privacy with regard to information obtained by telephone companies.  
Our proposed rule language is attached to these comments as Appendix B. 

A.  PRIVACY

 The Commission’s proposed rules, in WAC 480-120-139 (2)-Business Practices,  
contain several provisions that address consumer privacy concerns.  Although 
not labeled as relating to privacy concerns, subsections 2(a)-(c) establish a 
set of rules designed to address a carrier’s use of “customer specific 
information.”  Public Counsel agrees with the intent of the proposed rules, but 
suggests that it would be more appropriate to address customer privacy concerns 
directly and separately from any regulation designed to prevent a carrier from 
using customer-specific information in an unfair and competitive manner to the 
detriment of similarly situated competitors.  These are two sets of distinct 
policies and with two separate directives in the Telecommunications Act of 
1996. 

 Section 222    47 U.S.C. §222. of the federal Act mandates that all 
telecommunication carriers abide by certain requirements affecting the use and 
release of customer proprietary network information (CPNI).  As such, this 
provision requires the FCC to take privacy concerns into account in its 
establishment of policies to expand and encourage competition.  This directive 
must be viewed in the context of the prior FCC regulation of CPNI.  The FCC’s 
existing regulatory regime focuses on the ability of some carriers to use CPNI 
for marketing enhanced services and customer premises equipment, confirming 
that the FCC was primarily motivated to address concerns with competition 
policy, not privacy.   The FCC has initiated a new rulemaking proceeding    
Telecommunications Carriers’ Use of Customer Proprietary Network Information 
and Other Customer Information, Notice of Proposed Rulemaking, CC Docket No. 
96-115, FCC No. 96-221, 11 FCC Rcd 12513 (1996). to explore the implications of 
the Act’s elevation of privacy to a concern equal to competition and has 
solicited comments on how and whether the existing regulations should be 
expanded and strengthened.  

 This privacy concern must be coordinated with the competition rules contained 
in Sections 271 and 272 of the Act. (A copy of Section 271 was attached to the 
Commission’s CR 102 notice.)  These sections are designed to regulate the Bell 
Operating Companies’ entry into long distance competition, and are not, 
therefore, applicable to other telephone companies, such as GTE or MCI.  While 
these sections impose some restrictions on the BOC’s use of CPNI in their 
possession, those restrictions are designed primarily to prevent the BOCs from 
obtaining an unfair advantage, based on their local exchange monopoly, through 
the use of such information as they enter into the long distance market.
 
 Public Counsel supports the development of Washington-based rules that can be 
enforced by the WUTC to implement both of these provisions.  Privacy issues are 
historically a matter of state concern.  Washington telephone customers should 
be able to look to local enforcement authorities for these important issues. 
There is nothing in the federal law that suggests that the states should not or 
cannot enact their own privacy protection rules. Furthermore, we believe that 
the privacy issues should be addressed separately and not as part of a 
provision (as proposed by the WUTC draft rules at issue here) that is primarily 
related to the prevention of slamming or business practices designed to prevent 
unfair competition.  

 The FCC has not taken any action to finalize the NOPR on CPNI issued in 1996. 
We are about to enter local competition without any significant control over or 
customer safeguards with respect to the use telephone companies may make of the 
private (and valuable, from a marketing perspective) information many telephone 
companies receive from their customers.  

 Our proposal rests on two basic principles.  First, customer-specific 
information should not be used by a carrier for anything other than billing, 
collecting and providing the telecommunication services requested by the 
customer, without the customer’s express written permission.  Second, customers 
should be informed of their privacy rights periodically.  We have drawn upon 
the statutes and regulations in effect in California, Oregon and Ohio for our 
proposal.  The citations to these and other state telecommunications statutes 
and rules that we have consulted for Public Counsel’s draft rules are set out 
in Appendix A to our comments.

 Our proposal contains two of the three proposals (subsections (2)(a) and (b)) 
found in the WUTC draft rule.  The third, relating to a carrier’s ability to 
telemarket its services to customers with unlisted or unpublished numbers is 
discussed below as well, although not adopted in our proposal.

 Subsection 1. General duty.  It is important to state the overall objective 
and purpose served by regulating a carrier’s use of customer specific 
information.  This subsection establishes the duty to protect the privacy of 
customer proprietary network information, other personal information in the 
possession of the carriers and the records of a customer’s transactions for 
both local exchange and toll services.  The following provisions then establish 
key definitions, specific practices, and describe when and how a carrier can 
use a customer’s specific information.

 Subsection 2: CPNI.  This subsection addresses the use of CPNI, defined in 
paragraph (f) as individual subscriber data which a carrier obtains in the 
course of providing services to a subscriber.  The term refers to information 
obtained about a telecommunications service and is based on the definition of 
CPNI in Section 222 of the federal Act.  The specific prohibitions contained in 
this section are directed to the use of CPNI that may occur because of the 
transmittal of such information between carriers to effectuate the customer’s 
ordering of a telecommunications service.  In other words, the proposed rules 
are needed because of the transmittal of CPNI between and among carriers.  In 
general, a carrier should not be allowed to transmit CPNI to another carrier 
(except for specific purposes that are identified in the rule) without the 
express written consent of the subscriber.

 Subsection 3: Subscriber personal information.  This subsection addresses 
customer specific information other than CPNI that is in the possession of a 
carrier, such as personal identifying information, calling pattern, financial 
information, household income, employment and other personal information that 
carriers may gather to determine credit worthiness, collect an outstanding bill 
or provide advice and services to customers who cannot pay their bill in full.  
This information is broader than that typically defined as CPNI in subsection 
2, and will probably encompass information that is technically not regulated by 
the federal Act because of its reliance on the term CPNI.  Again, the overall 
objective is to prohibit the transmittal of such information to any person or 
organization (not limited to other carriers) without the customer’s consent.

 Subsection 4: Exceptions.  Public Counsel’s proposal recognizes the 
traditional and proper exceptions to the transfer of CPNI or other customer 
specific information: directory information; directory assistance services 
(except unlisted or non-published numbers); information provided to an 
emergency assistance agency; information provided to a law enforcement agency 
in response to a lawful process; information required by regulatory agencies; 
and information released to credit reporting agencies and debt collection 
agencies in conformance with state and federal law.

 Subsection 5: Annual Notice.  It is vital that subscribers understand the type 
of information retained by carriers, what their rights are with respect to the 
use and release of this information and how to give and rescind a written 
authorization. Our proposal requires all telephone companies to provide an 
annual notice to their subscribers of their privacy rights.  This information 
could be contained in telephone directories or included as an annual bill 
insert.  We also propose that customers with unlisted or non-published numbers 
be notified that their listing restrictions do not protect them from 
telemarketing by their own company or third parties (see discussion below).  

 Subsection 6: Equal access to aggregate CPNI.  This provision is directly 
related to the unfair use of CPNI to gain a competitive advantage.  Public 
Counsel suggests that companies that make aggregate (that is, non-customer 
specific) CPNI available to its affiliate must also make such information 
available to other companies under the same rates, terms and conditions.  
Should the Commission determine that a set of fair business practice rules or 
code of conduct will be necessary to govern the activities of a 
telecommunications company and its affiliates, this provision could best be 
included in that general approach.  However, since that approach has not been 
proposed in these draft rules, it does make sense to include all aspects of a 
carrier’s use of CPNI in one location. 

 Telemarketing to unlisted and non-published subscribers.  

 The WUTC draft prohibits a carrier from telemarketing its own services to 
customers who have bought a non-published or unlisted telephone number.  This 
would presumably not prohibit marketing to such customers altogether, merely 
the use of telemarketing.  Although Public Counsel is sympathetic to the 
objective of the proposed rule and would not object to including it in a final 
rule, there are some balancing considerations which should be taken into 
account.  

 Customers have perhaps mistakenly assumed that they have bought privacy from 
such marketing approaches with the purchase of a non-published or unpublished 
number.  Unfortunately, this is not the case.  When customers provide their 
telephone number to any provider of a service to them, such as in an 
application for a credit card, magazine subscription, purchase a car or 
register their appliance purchase, those telephone numbers are often included 
in the sale of an organization’s lists to marketers for similar products.  
Customers with unlisted or non-published numbers are subject to telemarketing 
in the normal course and have the same (but no greater) rights as other 
consumers when responding to what are admittedly often annoying invasions of 
our homes at dinner time.  

 The Telephone Consumer Protection Act of 1991 (47 U.S.C. §227) establishes a 
procedure which allows customers to remove their telephone numbers from 
telemarketing lists.  Telephone customers who have purchased an unlisted or 
non-published number have obtained only a telephone service, that is, the 
removal of their name and number from directories and the blocking of others to 
their telephone number through directory assistance.  This service does not 
assure them of privacy or freedom from telemarketing.  Other steps are 
necessary to obtain this protection.  We propose rule language that would 
require, as part of the annual notice of rights, that customers with unlisted 
or nonpublished numbers be told that they are not automatically protected from 
telemarketing.

B. CHANGE OF CARRIER ("SLAMMING”)

 No issue has resulted in greater customer dissatisfaction with telephone 
competition than slamming, the practice of changing a customer’s long distance 
telephone company without their permission.  At both the federal and state 
level, this has been the number one complaint and has resulted in unprecedented 
calling levels to both state and federal complaint centers. Public Counsel 
strongly endorses the general principles contained in the WUTC draft rule, WAC 
480-120-139.  The draft rules adopt the current FCC rules    47 CFR §64.1100., 
which are applicable to the change of a long distance service provider.  The 
adoption of WUTC rules on this issue will allow the Commission to enforce these 
provisions against any carrier for any improper change order submitted for 
local exchange service and intraLATA toll service.

 New York has proposed to adopt anti-slamming policies that will require a 
company that relies on a Letter of Agency (as opposed to oral third party 
verification) to obtain the customer’s written authorization    In the Matter 
of the Unauthorized Switching of Telephone Customers from One Telephone Carrier 
to Another Through the
Practice Known as “Slamming”(NY P.S.C., December 13, 1996) (Case 95-C-0806).. 
New York thus rejected the FCC approach which allows a company that relies on a 
Letter of Agency for confirmation to impose a "negative option" on customers. 
Under a negative option approach a customer is changed to the new service 
unless they notify the company in writing otherwise after receipt of the LOA.  
Both the FCC and the WUTC proposed rule follow this approach.  

 Ohio has adopted an anti-slamming policy that, like New York's, also rejects 
the use of the negative option and requires the telephone company to confirm 
the change either by electronic authorization (the customer electronically 
records the agreement to change carrier), use of an independent third party for 
verification, or written confirmation when the company relies on the use of a 
LOA to confirm the change.    In re Establishment of Local Exchange Competition 
(Ohio P.U.C. November 7, 1996) (NO. 95-845-TP-COI), at 88.
 
 Several states, including Ohio and California, have also adopted much stricter 
enforcement approaches to slamming compared to the FCC.  Both states put the 
customer back in the position that existed prior to the slam, that is, the 
customer is returned to his original telephone company and does not owe any 
charges to the company that did the slamming.  If the customer did not in fact 
have a contract with the company that slammed him, he owes nothing for services 
provided without authorization.  This is unlike the FCC rule which requires the 
customer to pay up to the amount that would have been charged by his or her 
original telephone company.    Policies and Rules Concerning Unauthorized 
Changes of Consumers’ Long Distance Carriers, 10 FCC Rcd 9560 (1995).  This 
approach has been supplemented recently with a Notice of Apparent Liability for 
Forfeiture issued by the Common Carrier Bureau, relying on the authority in 47 
U.S.C. §503(b)(2)(B)to assess a forfeiture of up to $100,000 for each violation 
up to a statutory maximum of $1,000,000 for a single act or failure to act. 
See, e.g., In the Matter of Long Distance Services, Inc., Notice of Apparent 
Liability for Forfeiture, DA 96-2102, December 17, 1996.
 
 Any state anti-slamming rule must balance the need to prevent fraud, which 
suggests the need for written authorization for any switch, with the equally 
important need to stimulate the development of competition in the face of the 
significant market power of the incumbent, thus suggesting the need for 
allowing oral confirmation.  

 Whatever the merits of the more liberal approach, i.e., relying on oral 
confirmation, the history of slamming in the interstate long distance industry 
suggests that some additional constraints are necessary.  Therefore, Public 
Counsel recommends the use of oral confirmation when a customer initiates the 
contact with the telephone provider, and allows the use of oral confirmation by 
an independent third party when the provider initiates the contract via 
telemarketing. 

 If oral confirmation is not obtained with these options, the provider must 
obtain the customer’s written authorization on an approved Letter of Agency.  
No negative option is allowed in these circumstances.  Furthermore, the use of 
a check as an LOA is prohibited.   Of course, no approach can work if a 
provider is intent on fraudulent conduct, such as forgery. Any instance of this 
conduct should result in a severe penalty, preferably, certificate cancellation.
 
 Public Counsel’s proposed amendments to the WUTC draft are modeled on the 
state regulations in California, Ohio and proposed rules pending in New York.  
Our approach differs from the WUTC draft rules by clarifying when a customer 
can obtain a change in provider by orally contacting their local service 
provider to request a change; specifying the form and content of a Letter of 
Agency and requiring that the new provider provide the customer with certain 
written disclosures to confirm the change in carrier; prohibiting the use of a 
check to operate as a LOA; and specifying enhanced enforcement tools for the 
Commission to respond to violations of the change of provider rules.

 Neither our draft nor the WUTC proposal address the issue of a PIC freeze, 
that is, a request by a customer to their local exchange provider to halt any 
change in their long distance service provider without their express written 
permission.  This service has the effect of prohibiting the local exchange 
provider from responding to a change order submitted by a new provider who has 
complied with the options for change orders set forth in this rule.  When a 
state moves to either intra-LATA presubcription or local exchange competition, 
this service has the effect of preventing the customer from easily entering the 
competitive market and choosing a new in-state toll or local exchange provider 
even though the customer requested this service to respond to unwanted provider 
changes for interstate long distance.  Public Counsel recommends that the 
Commission investigate the extent of the use of PIC freezes in Washington prior 
to addressing this matter. At the very least, those companies who have 
instituted this service option should be required to inform the affected 
customers how to change (and then freeze if desired) their service 
provider.                               

 Our further comments are organized by our draft rule attached to these 
comments:

 Subsection 1: General duty.  While the WUTC draft contains a general 
obligation not to submit a change order unless confirmed according to several 
optional procedures, our draft in effect defines the term “change order” and 
establishes an affirmative obligation on all carriers to establish internal 
procedures and monitor its employees and agents to prevent an authorized change 
of a company by a consumer.

 Subsection 2: Subscriber-initiated inbound call.  Public Counsel’s proposed 
rule allows a customer to initiate a change in provider by calling the new 
carrier to make the change.  The new carrier should be able to notify the 
customer’s old carrier of this change (or, in the case of a toll carrier, 
notify the customer’ local exchange carrier) without further authorization. 
 Subsection 3: Telecommunication company-initiated sales. Both the WUTC draft 
and Public Counsel’s allow the use of an electronic verification or third-party 
verification as options to demonstrate the customer’s assent to the change in 
provider. However, our draft combines the form of the written authorization 
from the customer (Section 139(1)(a) of the WUTC draft) and the Letter of 
Agency approach (Section 139(1)(d) of the WUTC draft. The main difference is 
that the Public Counsel’s proposal does not allow a provider to issue a 
customer a written package of information which operates as a negative option, 
that is, changes the customer’s carrier unless the customer returns the 
postcard. This approach, authorized by the current FCC rule, is the cause of 
much mischief because it requires the customer to take action to halt a change 
in service provider he or she may never have ordered.  Furthermore, our draft 
prohibits the use of a check as a form of written authorization when signed or 
cashed by the customer.  

 The Public Counsel’s draft requires that if the new provider has initiated the 
contact with the customer (whether by telemarketing or direct mail), the 
customer must approve the change by a written authorization.  A failure to 
return the written authorization (which could be in the form of a postcard, but 
not a check, prize or other money order) would mean that the customer’s 
provider would not change.  

 In addition, we propose in subsection 3(d) of our slamming rule draft that all 
customers whose provider is changed as a result of either direct contact by the 
customer; electronic verification; or third-party authorization must receive an 
information package with key disclosures within three business days.  A 
customer whose written authorization is obtained from a LOA will have already 
received similar information.  

 Subsection 4: Disputes. There must be no doubt that the telecommunications 
company who disputes the customer’s authorization to change carriers bears the 
burden of providing the evidence to demonstrate compliance with the provisions 
of the state regulation.

 Subsection 5: Remedies.  While the WUTC has the authority to impose fines and 
revoke a license of a carrier that violates its rules, the Public Counsel’s 
draft contains specific remedies relating to the violation of the anti-slamming 
rules.  The current FCC rules are inadequate in this regard and do not prevent 
continued violations.  Our proposal will allow the Commission to order a 
violator to pay the customer’s previous service provider an amount equal to the 
charges paid by the subscriber to the violator or owed to the violator.  
Furthermore, a subscriber should not have to pay one dime to a company that 
violates these rules and payments made should be promptly refunded.  Our rules 
also allow the Commission to order a company to rely solely on a written 
authorization from new customers prior to any switch if there is a demonstrated 
pattern or practice of noncompliance.  Any documentation of forgery by a 
carrier should immediately cause that carrier’s license to do business in 
Washington to be revoked.  There can be no tolerance for this outrageous 
conduct.

C. DIRECTORY LISTINGS

 The WUTC draft rule contains one provision relating to directory listings.  
The amendment requires directory listings by incumbent local exchange carriers 
or competitive LECs to include the name and address of all exchange carriers 
registered to provide service in the geographic area covered by the directory. 
Public Counsel agrees with this proposal.  

 Our draft rule on this topic incorporates the WUTC proposal and adds the 
requirement that the listing should be placed in a prominent location near the 
front of the directory.  It will not achieve the purpose of the proposed rule 
to place this list of competitors in a location unlikely to be viewed by most 
customers.  Our proposal also requires the local exchange company’s directory 
service to offer registered exchange providers the ability to purchase a larger 
space, up to 1/8 of a page, to more clearly describe their proposed services.

 In addition to the requirement that directories include a listing of all 
registered exchange providers, Public Counsel also proposes that all 
directories contain a listing of subscribers served by competitors in the 
geographic area served by the directory.  The telephone directory service will 
soon lose its value as a source of comprehensive information on customers, 
addresses and telephone numbers if it does not contain all customers served by 
the local exchange companies offering service within that geographic area.

III. CONCLUSION

 Public Counsel supports the Commission's efforts to address these important 
areas.  We respectfully urge the Commission to consider and adopt the changes 
and additions proposed in our comments in order to clarify and enhance the 
Commission's efforts in this area.

       Respectfully submitted,



       Simon J. ffitch
       Assistant Attorney General
       Public Counsel Section


F:\CASES\UT\UT960942\COMMENT2.DOC




APPENDIX A
COMMENTS OF PUBLIC COUNSEL
UT 960942

STATE RULES REGARDING TELEPHONE COMPETITION

California: Re Order Instituting Rulemaking on the Commission’s own Motion into 
Competition for Local Exchange Services (Cal.P.U.C., July 24, 1995 (Docket No. 
R. 95-04-043, I. 95-04-044) Appendix B.  See also Cal. Public Utility Code 
§§2891, 2891.1, and 2893.

Ohio:  Re Local Service Guidelines, Appendix A (Ohio P.U.C., November 7, 1996 
(Case No. 95-845-TP-COI).

Oregon:  Oregon Administrative Rules, Chapter 860, Division 35 (PUC), §860-
35-090: Access to CPNI.

New York:  Re Transition to Competition in the Local Exchange Market (N.Y. 
P.S.C., May 22, 1996) (Case No. 94-C-0095, Opinion No. 96-13); In the Matter of 
the Unauthorized Switching of Telephone Customers from One Telephone Carrier to 
Another Through the Practice Known as “Slamming", Notice Soliciting Comments, 
Case No. 95-C-0806, December 13, 1996.

Minnesota: Minnesota Statutes 1996, §237.66, Disclosure of local service 
options.

F:\CASES\UT\UT960942\COMMENT2.DOC

APPENDIX B

PUBLIC COUNSEL DRAFT PROPOSED RULES
(6/19/97)
WUTC DOCKET No. UT-960942


WAC 480-120-xxx  Privacy.
(1) General duty.  Every telecommunications company shall have a duty to 
preserve the privacy of customer proprietary network information, other 
personal information in the possession of the telecommunications company, and 
the record of subscriber transactions involving local exchange service and toll 
service.  Every telecommunications company shall protect such information and 
transaction records from commercial abuse and unauthorized disclosure.  
(2) Customer Proprietary Network Information (CPNI).  
(a)  A telecommunications company that receives or obtains CPNI from another 
telecommunications company to provide a telecommunications service to its own 
subscriber shall use that information only for the provision of that specific 
service. A telecommunications company shall not use the information for its own 
marketing efforts unless the information is accessed in response to a call 
initiated by the subscriber and the subscriber orally approves of the use of 
such information for marketing services to the subscriber.
(b)  No telecommunications company shall access or use the CPNI obtained from 
an interconnecting telecommunications company for the purpose of marketing its 
services to the subscribers of the interconnecting telecommunications company.
(c) No telecommunications company shall solicit another telecommunications 
company’s subscriber or applicant where the interconnecting telecommunications 
company is in the Draft Rules, WUTC Docket No. UT-960942
Page 1
process of waiting for the telecommunications company to provide facilities 
necessary to serve that same subscriber or applicant.
(d)  A telecommunications company may only make CPNI available to another 
telecommunications company after it obtains prior written authorization from 
the subscriber for the provision of subscriber-specific CPNI to the other 
telecommunications company.
(e)  A telecommunications company or its affiliate shall not provide CPNI to 
any telecommunications equipment manufacturer or telecommunications company for 
use with or in connection with the manufacturing of telecommunications 
equipment or the provision of local exchange, interLATA, information, enhanced, 
or video services that are disseminated by means of such local exchange company’
s or any of its affiliates’ facilities without the prior affirmative and 
written consent of the subscriber.
(f) “Customer Proprietary Network Information” is defined as individual 
subscriber data which a telecommunications company obtains in the course of 
providing services to a subscriber.  CPNI means information that relates to the 
quantity, technical configuration type, destination, and amount of use of a 
telecommunications service obtained by the subscriber, and that is made 
available to the company by the subscriber solely by virtue of the subscriber 
relationship.  CPNI includes information contained in the bills pertaining to 
telecommunications services received by a subscriber, except that this term 
does not include subscriber list information. 
(g)  The term “subscriber list information” means information identifying the 
listed names of subscribers of a telecommunications company and the 
subscribers’ telephone numbers, addresses and primary advertising 
classifications or any combination of such listed names, numbers, addresses or 
classifications, if such information has been published or caused to be 
published by the telecommunications company or its affiliate in any directory 
format.
(3)  Subscriber personal information.  Unless the telecommunications company 
has obtained the subscriber’s prior affirmative and written consent , no 
telecommunications company shall make available to any other person or 
organization, any of the following personal information:
(a) The subscriber’s personal calling pattern, including any listing of the 
telephone or other access numbers called by the subscriber, except for the 
purposes of billing information provided to the person who makes the call and 
also except for the identification of the telephone number from which the call 
was placed pursuant to a Commission-approved subscriber call identification 
service;
(b) The subscriber’s credit or other personal financial information, except to 
a credit reporting agency for lawful purposes or a debt collection agency for 
the collection of unpaid debts owed to the telecommunications 
company,                         
(c)  The services which the subscriber purchases from the telecommunicatio