Pay-Per-Call Rule Review: 900 Number #19

Submission Number:
Jerusa Carl Wilson, Jr.
MCI Telecommunications Corporation
Initiative Name:
Pay-Per-Call Rule Review: 900 Number
Matter Number:


Before the
Washington, D.C. 20580

In the Matter of

900-Number Rule Review; Request for Comment Regarding Possible Modification of Definition of "Pay-Per-Call Services" Pursuant to the Telecommunications Act of 1996

FTC File No. R611016


MCI Telecommunications Corporation (MCI), by its attorneys, hereby submits the following comments in response to the Federal Trade Commission's (the Commission) above-captioned 900-Number Rule Review and Request for Comment (Rule Review), released on March 12, 1997. In this Rule Review, the Commission proposes several modifications to its definition of "pay-per-call" services, pursuant to the Telecommunications Act of 1996 (the Act).


Congress enacted the Telephone Disclosure and Dispute Resolution Act of 1992 (TDDRA) (1) to curtail unfair and deceptive practices perpetrated by some pay-per-call businesses, and to encourage the growth of the legitimate pay-per-call industry. Titles II and III of TDDRA required the Commission to prescribe regulations governing pay-per-call services. TDDRA also required the Commission to initiate a rulemeking review proceeding to evaluate the Commission's 900-Number Rule operation no later than four (4) years after its effective date of November 1, 1993. Additionally, the Act granted the Commission the authority to expand the scope of its 900-Number Rule by broadening the definition of pay-per-call services. The above-captioned proceeding was initiated pursuant to this authority.


It is MCI's hope that the comments submitted in this proceeding will facilitate a productive review of the Commission's 900-Number Rule, and MCI looks forward to working with the Commission and its staff in this regard. (2) In this Rule Review proceeding, the Commission has posed 48 questions concerning both 900 and non-900 audiotext services. One of the parties that has responded to these inquiries is the Interactive Services Association (ISA). MCI is an active member of ISA and has been integrally involved in the development of the comments submitted by ISA in this proceeding. Accordingly, MCI supports the recommendations made by ISA in its comments and urges the Commission to implement ISA's recommendations. Implementation of ISA's recommendations will strengthen consumer protection and ensure continued strong growth of the audiotext industry.


For the foregoing reasons, MCI respectfully requests that the Commission consider the above comments when fashioning amended rules in this proceeding.

Respectfully submitted,


Jerusa Carl Wilson, Jr.
1801 Pennsylvania Ave., N.W.
Washington, D.C. 20006
(202) 887-2666

May 12, 1997

Its Attorneys

1. The Telephone Disclosure and Dispute Resolution Act of 1992, which added Section 228 to the Communications Act of 1934, Pub. L. No. 102-556, 106 Stat. 4181 (1992)(codified at 47 U.S.C. § 228).

2. See MCI's Notification of Interest regarding participation in the Commission's June 19-20, 1997 900-Number Rule workshop-conference. This formal Notification is appended hereto and incorporated herein.