Written responses from Paracom, Inc. to Washington Utilities and Transportation 
Commission
regarding Docket UT-971469
concerning WAC 480-120-058 and WAC 480-120-052

The Commission’s proposed rules will affect Paracom directly, and we appreciate 
being given the opportunity to respond to the proposal. Any questions regarding 
our comments can be directed to us by e-mail at paracom@halcyon.com, or to Dan 
Agar at 206 574-0122.



WAC 480-120-052

Section (5)(a)(vi): Expiration date, if applicable. If an expiration date is 
not disclosed on the card it will be considered live indefinitely;

It is more practical for us to provide an option in the dialing menu which 
allows the customer to hear the expiration date by pressing a key on the 
telephone, and it is better for the consumer. We must print large numbers of 
cards at a time in order to achieve necessary economies of scale and keep 
prices low. The actual expiration date of those cards will vary depending on 
their date of distribution for purchase. However, when we print the expiration 
date on the cards, we must choose the earliest possible expiration date for any 
of those cards and apply it to all of them. The result is that most customers 
will buy a card which is actually valid for longer than the printed date would 
indicate. If we use a menu option rather than a printed date, customers won’t 
throw their cards out prematurely. If we must print a date, we would like to 
print something like “Good at least until January 31, 2000; press *5 for exact 
expiration date.” Can we be allowed to provide a worst-case expiration date in 
this way, and give the customer the ability to find out the true date, which 
will always be the same or later?


Section (5)(b)(i): If a company charges varying rates for intrastate, 
interstate, and international calls all applicable rates must be provided. The 
rates displayed must be no more than those approved in the tariff or price list 
of the compnay at the time of retail purchase.

Although we can provide rates for all international destinations, it is quite a 
lot of information to provide. We list 225 countries and territories in our 
price list. Retailers may object to displaying all of this information as it 
takes up space. Can it be simply available at the retailer, behind the counter 
for example, instead of being displayed?



WAC 480-120-058

Section (1)
(a) The company has a corporate debt rating, according to Standard & Poor’s of 
BBB or higher, or according to Moody’s of BAA or higher, with respect to 
outstanding debt obligation; or
(b) The company has a performance bond satisfactory to the commission 
sufficient to cover any customer prepayments; or
(c) The company has made provision for deposit of customer prepayments in a 
federally insured interest bearing trust account maintained by applicant solely 
for customer advances.

We pay our carrier for all of the long distance time associated with our cards 
before we offer them for sale. We never make only a down payment on long 
distance time and then hope that customers won’t buy the cards too quickly or 
use them up too quickly. Our carrier is a multi-billion dollar company which 
meets the standards of section (a). We would like the wording of the section to 
allow a phone card vendor such as us to avoid posting a bond if we can 
demonstrate that we have already transferred the amount of customer prepayments 
to the long distance carrier if that carrier either meets the standard of 
section (a) or posts a bond complying with section (b) which includes our 
customer prepayments as well as any the carrier might have outstanding. We pay 
in full for all of the long distance time for each group of cards before we 
make them available for sale; it is excessively onerous if we have to post a 
bond for this amount which we have already paid as well. One possible way to 
express this in a further section would be:

(1)(d) The company has transferred funds sufficient to cover all outstanding 
customer prepayments to its underlying carrier, which carrier either meets the 
requirements of section (a) or section (b), including in the case of section 
(b) a performance bond sufficient to cover any customer prepayments to the 
company.

This might be handled instead as a section 4(e), such that the company would 
petition the commission on an exception basis and give its reasons for 
requesting exemption from bonding requirements, rather than being granted a 
blanket right to proceed under a section (1)(d) as above.