INTRODUCTION .gov

? ASK Initials "Enter your initials in all CAPS (e.g. ATTY)" [/d "ATTY"]Initials \* MERGEFORMAT Decision 21-09-019September 9, 2021 ASK AgendaNo "Enter the agenda item number (e.g. CA-4)" [/d "Agenda Item No."] \* MERGEFORMAT BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIAPacific Bell Telephone Co. d/b/a AT&TCalifornia (U1001C), Complainant,vs.TruConnect Communications, Inc. f/k/aTelscape Communications, Inc. (U4380C)and Blue Casa Telephone, LLC (U7222C),LLC (U7222C), defendants.Case 17-08-003And related matter.Case 18-01-005ORDER DENYING REHEARING OF Decision 21-06-007INTRODUCTIONIn this Order, we deny the Application for Rehearing of Decision (D.) 21-06-007, filed by TruConnect Communications, Inc. (TruConnect). On June 8, 2021, we issued D.21-06-007 which resolves Case (C.) 17-08-003 filed by Pacific Bell Telephone, doing business as AT&T California (AT&T), seeking to recover from TruConnect and/or Blue Casa Telephone (Blue Casa) charges for collocation, intrastate access, resale service and wholesale services rendered through July 31, 2016, under an approved Interconnection Agreement (ICA) between AT&T and TruConnect. D.21-06-007 finds that the Commission has jurisdiction over the complaint filed by AT&T, C.17-08-003, on the grounds that it involves an ICA approved and adopted by the Commission. The decision finds in favor of AT&T and orders TruConnect to pay all AT&T’s charges, plus applicable late fees, for services rendered pursuant to the ICA through March 31, 2016.The decision further finds that the related case filed by Blue Casa, C.18-01-005, seeking a refund for alleged overpayments it made to AT&T for facilities and services used to serve its customers, is a private contract which the Commission did not approve or adopt, and disputes arising under it are beyond the Commission’s subject matter jurisdiction to resolve. As a result, the decision dismisses C.18-01-005. TruConnect’s Application for Rehearing challenges D.21-06-007 on the grounds that the Commission acted inconsistently by asserting jurisdiction over the ICA but not the private agreement between AT&T, TruConnect, and Blue Casa. Specifically, TruConnect argues: 1) the Commission acted outside of its jurisdiction; 2) the Commission failed to act in a manner required by law; 3) the decision is not supported by the findings; 4) the findings in the decision are not supported by substantial evidence in light of the whole record; 5) the decision is an abuse of discretion; 6) the decision violates TruConnect’s due process. In addition, TruConnect requests oral argument. For the reasons stated herein, we affirm D.21-06-007 and deny the application for rehearing and request for oral argument.FACTUAL BACKGROUNDPrior to 2016, AT&T and TruConnect were parties to a Commission-approved ICA that contained provisions relating to terms and rates for intrastate access services provided by AT&T to TruConnect, unbundled network elements (UNEs), resale services, collocation space and arrangements, delegation of responsibilities, and late charges. In 2015, TruConnect and Blue Casa entered into a private asset purchase agreement (APA) that provided for the migration of TruConnect’s customers from TruConnect to Blue Casa. The APA provided that Blue Casa would acquire TruConnect’s California residential customer base. As Blue Casa and TruConnect were preparing to close the APA, Blue Casa discovered that AT&T had filed a lien on TruConnect’s assets. In order to satisfy the lien and enable the closing to take place, Blue Casa, TruConnect and AT&T entered into a three-way “Transfer Agreement” pursuant to which, among other things, Blue Casa would pay TruConnect’s AT&T bills for the UNE loops and resale services that TruConnect would continue to use to serve the affected customers while they were being migrated to Blue Casa’s underlying carrier. The Transfer Agreement established a “Cutover Date” of August 31, 2015, as the date after which Blue Casa would assume this responsibility.AT&T continued to bill TruConnect for the UNE loops and wholesale services after the Cutover Date. Blue Casa paid some of the bills but stopped paying them after a certain point. TruConnect did not pay any of the bills as of the Cutover Date. AT&T started sending collection letters to TruConnect in December 2015 and to Blue Casa in April 2016.The Transfer Agreement was to remain in effect for nine months, at which time any wholesale services not migrated and any remaining access services and collocation facilities would be disconnected, and the ICA would be terminated. On March 31, 2016, TruConnect notified AT&T that the migration was complete and the ICA was terminated.Early in the migration process, TruConnect and Blue Casa found themselves in a dispute regarding the amounts payable under the APA that led to Blue Casa filing, on October 29, 2015, Case (C.) 15-10-010 seeking injunctive relief to prevent TruConnect from disconnecting service to customers who had not yet migrated to Blue Casa’s underlying carrier. By motion dated November 13, 2015, Blue Casa moved to add AT&T as a party to the complaint, which was granted. On March 25, 2016, TruConnect and Blue Casa filed a joint status report stating that the migration was completed, which was served on AT&T. The complaint was thereupon dismissed upon joint written request of the parties on April 4, 2016. A modified presiding officer’s decision was adopted by the Commission and issued on June 8, 2021. TruConnect filed a timely application for rehearing and request for oral argument. AT&T filed a timely response opposing the application for rehearing.The factual background recited in D.21-06-007 is generally not in dispute by TruConnect. However, TruConnect requests that the Commission include two additional facts that it alleges were improperly omitted from the decision, discussed in more detail below. DISCUSSIONTruConnect argues that D.21-06-007 commits legal error in several ways. Specifically, TruConnect argues that: 1) the Commission lacks jurisdiction over the dispute between AT&T and TruConnect; 2) the Commission abused its discretion by imposing liability on TruConnect for receiving AT&T’s services over TruConnect’s objections; 3) TruConnect cannot be held liable for amounts AT&T expressly waived the right to seek from TruConnect in the Transfer Agreement; 4) the decision is unconstitutionally vague and violates due process because it could be read to include liability for services billed in advance, but not provided after March 31, 2016; 5) the ICA was terminated on March 31, 2016, so there is no contractual basis to allow recovery of late charges accrued after that date; and 6) the Commission’s jurisdiction is unsupported by the record.We address these arguments, TruConnect’s request to mention two additional facts, and TruConnect’s request for oral argument below.The Commission Has Jurisdiction Over ICAsThe Commission approved and adopted the ICA between AT&T and TruConnect, and thus has jurisdiction to resolve disputes arising out of the ICA. TruConnect does not challenge the Commission’s authority to approve and adopt ICAs. Instead, TruConnect argues that the Commission lacks subject matter jurisdiction over AT&T’s claims because in reality the liabilities arise under the Transfer Agreement, not the ICA, and the Transfer Agreement is a private contract over which the Commission lacks jurisdiction. As a result, TruConnect argues that AT&T’s complaint should be dismissed. However, the record shows that AT&T and TruConnect entered into a Commission-approved ICA for AT&T to provide various wholesale products and services to TruConnect to serve TruConnect’s customers. The record further shows that AT&T seeks to recover the amounts due to AT&T under the ICA for services provided to TruConnect, which TruConnect does not dispute that it did not pay for. Although the ICA permitted delegation to a third party of obligations under the ICA, it did not relieve TruConnect from liability for nonpayment. TruConnect does not dispute that it continued to receive interconnection services but stopped paying AT&T’s bills for services after the Cutover Date. Thus, TruConnect fails to show that it was not in violation of the ICA.Further, in C.17-08-003 AT&T seeks payment of unpaid bills for services provided under the ICA which TruConnect continued to receive and not pay for. Therefore, we disagree with TruConnect that the record shows that AT&T’s claims are for nonpayment under the Transfer Agreement, not the ICA.TruConnect alleges the “unpaid balances [are] related to the obligations that appear in the Transfer Agreement, not the Interconnection Agreement.” TruConnect argues that the Transfer Agreement is the governing contract here because the Transfer Agreement differs from the ICA in several ways, in that: 1) it required Blue Casa to pay for the “wholesale services” from AT&T; 2) it contains a different start and end date than the ICA; 3) it contained a clause for early termination upon completion of the migration of customers; and 4) it contains a clause that states that the Transfer Agreement supersedes all other contracts. However, these differences do not establish that the Transfer Agreement should supersede the ICA. Instead, they show that the Transfer Agreement was different than, and potentially in conflict with, the ICA. Enforcing the Transfer Agreement as the governing contract between AT&T and TruConnect would effectively alter or amend the terms contained in the Commission-approved ICA, which is prohibited by the filed-rate doctrine (discussed below). Further, the record shows that AT&T provided and billed TruConnect for services under the ICA, not the Transfer Agreement. The ICA contained provisions relating to terms and rates for services including for collocation space and arrangements, late charges, unbundled network elements (UNEs), resale services, and intrastate access service to TruConnect. TruConnect appears to argue that payment for provision of these services falls under the Transfer Agreement, not the ICA. However, the record shows that these services are covered by the ICA.Under the filed-rate doctrine, which applies to ICAs, a carrier cannot change or amend the rates for services contained in the ICA. Thus, to the extent the Transfer Agreement changed or conflicted with the terms and rates contained in the ICA, it is unenforceable. Under the filed-rate doctrine, the Commission can only enforce recovery of nonpayment for the services provided pursuant to the ICA under the terms and conditions in the ICA. Essentially, TruConnect argues that AT&T is perpetuating a subterfuge by claiming to be enforcing the ICA, but actually is attempting to enforce the Transfer Agreement. However, AT&T has maintained throughout this proceeding that it seeks payment under the ICA, so TruConnect’s argument is unpersuasive. Also, the record does not support the allegation that AT&T is concealing its true intention to seek payment under the Transfer Agreement rather than the ICA. D.21-06-007 thus correctly requires TruConnect to pay for services provided by AT&T under the terms set forth in the ICA (i.e., intrastate access service, collocation space and arrangements, resale services, unbundled network elements, and late charges). We disagree with TruConnect that the Transfer Agreement governs provision of these services, or that AT&T allegedly seeks to enforce the terms of the Transfer Agreement. We thus affirm D.21-06-007 regarding our jurisdiction to enforce the ICA against TruConnect.TruConnect Must Pay for Services That It Continued To Receive Pursuant To The ICATruConnect argues that D.21-06-007 runs afoul of the law by ordering TruConnect “to pay for services the Commission compelled TruConnect to maintain” over TruConnect’s objections. TruConnect claims that in November 2015 it attempted to raise objections about its ICA with AT&T and possibly discontinue service, and that it was prevented from doing so. TruConnect argues that it is an abuse of discretion for the Commission to compel TruConnect to continue to pay for and receive services over its objections. At this juncture, we note here it is unclear to what record evidence TruConnect is citing for its claim that it was compelled to continue to provide service by the assigned Administrative Law Judge (ALJ) in November 2015. TruConnect fails to provide record citations for its contention that the ALJ ordered TruConnect, over its objections, to continue to provide services to customers who had not yet migrated to Blue Casa. D.21-06-007 characterizes the ALJ’s comments at the November 2015 prehearing conference as a request, not as a directive, and points out that at the time, there was no basis to assume TruConnect had a right to disconnect. Since C.15-10-010 was dismissed after TruConnect gave written notice of the termination of the ICA to AT&T, it was proper for the ALJ in November 2015 to request TruConnect not to disconnect customers who had not yet migrated to Blue Casa. Further, the record shows that TruConnect attempted to raise objections regarding service to Blue Casa due to Blue Casa’s alleged failure to pay AT&T’s bills for services, but did not object continuing to provide service to its own customers. The ALJ’s request related to protecting TruConnect’s end-user customers who had not yet been migrated, not to the customers of its successor carrier Blue Casa, and TruConnect conflates the two.However, the important fact here is the date when TruConnect provided written notice to AT&T of its intent to terminate the ICA. The record does not show that TruConnect conveyed to AT&T its intent to terminate the ICA in November 2015.The ICA is clear that billing disputes must be clearly communicated to the other party. Specifically, Section 29.13.3 of the Terms and Conditions of the ICA provide that the disputing party must provide written notice of a controversy or claim on the other party. D.21-06-007 finds that TruConnect notified AT&T that the ICA was to terminate, and products and services under the ICA were to be disconnected, upon the completion of the migration of customers from TruConnect to Blue Casa under the APA. TruConnect states that “TruConnect and Blue Casa advised AT&T in January 2016 that they wanted the disconnection to occur on the then-threatened date because they were confident all live customers would be migrated by that time.” However, it was not until March 31, 2016, that TruConnect notified AT&T in writing that migration was complete and that it wished to terminate the ICA. In fact, in January 2016 TruConnect filed a motion to prevent wholesale providers, like AT&T, from discontinuing services to TruConnect. (See Motion By TruConnect Communications, Inc. (U6589c) For Emergency Order To Compel Payment Of All Payments Owed And Prevent Discontinuation Of Services (C.15-10-010), filed January 27, 2016.) Thus, the record of TruConnect’s actions in late 2015 and early 2016 does not demonstrate that TruConnect intended to terminate the ICA prior to March 31, 2016. Although TruConnect may have raised concerns during the November 2015 prehearing conference in C.15-10-010 regarding services to Blue Casa, TruConnect did not inform AT&T at that time that it wished to terminate the ICA. TruConnect states that in 2015 it “sought permission to disconnect Blue Casa pursuant to these [involuntary exit] guidelines.” But D.21-06-007 notes that “TruConnect’s threat to disconnect its service to Blue Casa does not constitute notice to AT&T that TruConnect was terminating its ICA with AT&T.” The ICA provided that TruConnect remains liable for services it receives pursuant to the ICA until the ICA is terminated, regardless of whether it delegates its rights and obligations to a third party. Proper written notice under the ICA was not delivered to AT&T until March 31, 2016. TruConnect further argues that “the Commission has discretion and should apply equitable principles to determine the fairest and most reasonable date to end liability for AT&T services.” TruConnect argues that the Commission “unfairly” imposes liability for services that Blue Casa received under the APA, and if anyone should bear the cost it should be Blue Casa. We disagree, on the grounds that the Commission does not have discretion to alter the terms and conditions of the ICA due to the filed-rate doctrine explained above. If we apply equitable principles and relieve TruConnect of liability on the grounds that Blue Casa did not pay AT&T’s bills pursuant to the APA, we are in effect changing the terms of the ICA. While the ICA permits TruConnect to elect to delegate its ICA obligations to a third party (i.e., Blue Casa), TruConnect remains fully liable for nonperformance under the terms and conditions set forth in the ICA. Whether Blue Casa should be held jointly liable under the Transfer Agreement is not at issue here because the Commission does not have jurisdiction to adjudicate these types of private contracts. Under the terms of the ICA, despite migrating customers to Blue Casa, TruConnect remains liable for nonperformance of the terms and conditions of service as set forth in the ICA.Furthermore, the issue of whether TruConnect had a right to disconnect its customers prior to the termination date of the ICA as a result of Blue Casa’s failure to pay was raised in C.15-10-010, but not resolved. TruConnect claims the ALJ in C.15-10-010 allegedly “directed” TruConnect to continue to provide service to the customers that were to be migrated to Blue Casa but had not yet done so, despite Blue Casa’s alleged failure to pay its bills and over TruConnect’s objections. However, C.15-01-010 was dismissed by the parties’ joint request without resolving whether TruConnect was required to continue to provide service up to March 31, 2016, thus no order existed. TruConnect continued to receive services from AT&T under the ICA without providing the required written termination notice to AT&T until March 31, 2016, thus D.21-06-007 correctly finds that TruConnect must pay for those services up to that time.The Commission Did Not Abuse its Discretion by Imposing Liability Under the ICATruConnect argues that the Commission abused its discretion by imposing liability on TruConnect because in the Transfer Agreement AT&T allegedly waived its right to seek payment from TruConnect for provision of “wholesale services.” TruConnect alleges that the Transfer Agreement required Blue Casa to pay for “wholesale services,” and that AT&T agreed to not seek payment from TruConnect for any wholesale services. TruConnect argues that allowing “AT&T to escape this binding waiver and release” for wholesale services provided to TruConnect is “illegal and inequitable.” However, as discussed above, TruConnect failed to establish that the Commission has jurisdiction to enforce this type of private agreement (the Transfer Agreement). TruConnect’s allegation that AT&T waived the right to seek payment from TruConnect for wholesale services is based on an interpretation of the Transfer Agreement, not the ICA. D.21-06-007 correctly finds that the Commission does not have jurisdiction over the Transfer Agreement, thus we need not decide whether AT&T waived its rights to seek recovery of wholesale services in the Transfer Agreement. We affirm D.21-06-007 regarding dismissal of the dispute regarding the Transfer Agreement, which is a private contract over which we do not have jurisdiction. TruConnect Is Liable for Services Provided By AT&T Pursuant To The ICA Up To March 31, 2021TruConnect argues that D.21-06-007 errs because it orders TruConnect to pay for services that were billed in advance but not yet provided as of March 31, 2016. Reviewing the ordering paragraphs of D.21-06-007, we are not persuaded that TruConnect is being ordered to pay for services that were billed in advance but not yet provided. Ordering Paragraph #1 of D.21-06-007 states:TruConnect Communications shall pay Pacific Bell Telephone, doing business as AT&T California, all of the amounts billed under the applicable Interconnection Agreement for services provided (i.e., collocation space and arrangements, unbundled network elements, resale services, and intrastate access service) through March 31, 2016, including late charges, within 30 days of the effective date of this order.TruConnect emphasizes that the decision requires it to pay “all of the amounts billed…through March 31, 2016” (emphasis in TruConnect’s Application for Rehearing). TruConnect argues that this phrase requires them to pay bills for services provided after March 31, 2016, but billed in advance. However, the order states that TruConnect must pay “for services provided … through March 31, 2016.”The “amounts billed” is modified by “for services provided.” Thus, a reasonable understanding is that TruConnect must pay for services provided up to March 31, 2016, but not after. AT&T’s Response to TruConnect’s Application for Rehearing states that this is its understanding as well. We are not persuaded that Ordering Paragraph #1 is unconstitutionally vague to the extent that it violates TruConnect’s due process and needs to be modified. We decline to make the changes suggested by TruConnect. TruConnect is Liable for Late Payment Charges for Nonpayment of Services Provided by AT&TTruConnect argues that it should not be required to pay any late charges accrued after March 31, 2016. TruConnect asserts that the payment of late charges is based on the ICA, which is a contract. TruConnect argues that after a contract like the ICA terminates, the contract no longer exists and thus “there is no contractual basis to allow [late charges] for amounts deemed owed but not yet paid after that date.” We disagree with this line of reasoning. As discussed above, the filed-rate doctrine prevents us from changing the terms of the ICA. It is undisputed that the ICA provides for late-payment charges of 1.5% of the amount that is past due, accruing monthly. The ICA contains no provision of which we are aware, and TruConnect points to none, that relieves TruConnect of the obligation to pay late charges that continue to accrue after the termination date.In effect, TruConnect asks us to modify the terms of the ICA in order to limit late charges for nonpayment of services that were provided prior to March 31, 2016. As discussed above, the filed-rate doctrine prevents us from modifying the terms of the ICA in this way. There is no provision of the ICA that limits late charges from accruing for nonpayment for services provided before the termination date that continue to not be paid, and the filed-rate doctrine prohibits us from changing the ICA to limit liability for late charges as requested by TruConnect.TruConnect further argues that AT&T “sat on its hands” by filing a complaint in August 2017 for nonpayment of services beginning in 2015. However, the record shows that AT&T sent demand letters requesting payment on December 7, 2015, January 18, 2016, April 11, 2016, April 14, 2016, and May 18, 2016. The delay between the last collection letter and the filing of C.17-08-003 does not appear to be an unreasonable amount of time, especially in light of C.15-10-010, in which billing disputes between Blue Casa, TruConnect and AT&T were being litigated. Thus, we are not persuaded that AT&T “sat on its hands” and took too long to file its complaint.Therefore, we deny TruConnect’s request to apply equitable principles and limit the late charges that continue to accrue for TruConnect’s nonpayment of AT&T’s services provided prior to March 31, 2016.The Commission’s Jurisdiction Over The ICA Is Supported By The RecordTruConnect argues that asserting jurisdiction over the ICA but not the Transfer Agreement is unsupported by the record and an abuse of discretion. TruConnect argues that it is “logically inconsistent” and an abuse of discretion to impose liability on TruConnect but not Blue Casa when the complaint involves the “same transactions.” We do not agree that resolving one complaint (C.17-08-003) but not the other (C.18-01-005) is an abuse of discretion, because the two are different in nature.In support of the argument that the two complaints involve the same transactions, TruConnect states that when it provided notice to Blue Casa that it was terminating the ICA, AT&T either knew or should have known about it because AT&T was a party to the Transfer Agreement. However, this alone does not prove that the two complaints arise out of the “same transactions.” The decision reasonably concludes that notice to Blue Casa does not necessarily provide notice to AT&T. The ICA contained specific termination notice requirements which were not met until March 31, 2016. As discussed above, the Transfer Agreement was set to terminate after nine months, or after the migration of TruConnect’s customers was complete.Although C.17-08-003 and C.18-01-005 involve related and overlapping circumstances, they do not involve the “same transaction.” In C.17-08-003, AT&T alleges that TruConnect violated the ICA by failing to pay for services that AT&T provided to TruConnect to support its customers, which TruConnect then transferred to Blue Casa. In C.18-01-005, Blue Casa alleges that after the Cutover Date it discovered that AT&T had been inappropriately billing Blue Casa for services either unrelated to the migration of TruConnect’s customers, or that should have been terminated as of the Cutover Date.The transaction at issue in C.17-08-003 is the ICA, but the transaction at issue in C.18-01-005 is the Transfer Agreement. Blue Casa was not a party to the ICA. AT&T was not initially a party to the transfer of TruConnect’s customers to Blue Casa. AT&T’s rights and obligations under the Transfer Agreement, joined only after the AT&T lien on TruConnect was discovered, were different from the ICA. The Commission approved and adopted the ICA pursuant to its jurisdiction, but not the Transfer Agreement, a private agreement over which the Commission has no jurisdiction. The ICA did not contain terms for migration of TruConnect’s customers to Blue Casa. The Transfer Agreement did not govern the provision of interconnection services by AT&T to TruConnect. Thus, the two cases involve different contracts with different parties and different rights and obligations and are thus different transactions. We do not find any inconsistency between resolving C.17-08-003 and dismissing C.18-01-005. TruConnect’s argument that the record does not support the Commission’s assertion of jurisdiction over the ICA is without merit. TruConnect’s Request To Modify D.21-06-007’s Factual Background To Include Additional Facts Is DeniedThe factual background is not disputed by TruConnect, although TruConnect requests that the Commission mention two additional facts that it alleges should be included in the factual background section of D.21-06-007. First, TruConnect does not dispute that it stopped making payments to AT&T as of August 31, 2015, the Cutover Date, but argues that the decision errs by omitting that Blue Casa was responsible for all of AT&T’s charges after that date. However, the decision notes that as of the Cutover Date, Blue Casa would assume the responsibility of paying AT&T’s bills to TruConnect for, among other things, the UNE loops and resale services that TruConnect would continue to use to serve the affected customers while they were being migrated to Blue Casa’s underlying carrier. Thus, the decision adequately includes the fact that the Transfer Agreement provides that Blue Casa was responsible for paying AT&T’s bills after the Cutover Date, and does not need to be amended in that regard.Second, TruConnect argues that it should not be liable after November 2015 for AT&T’s unpaid bills for services because in C.15-10-010 the “assigned Administrative Law Judge directed TruConnect to cease the disconnections” of customers who had not yet migrated to Blue Casa. However, on April 6, 2016, C.15-10-010 was dismissed at the parties’ request without being resolved. As discussed in more detail above, there was no order in C.15-10-010 requiring TruConnect to continue to provide service to Blue Casa over its objections. In any event, the dispute between TruConnect and Blue Casa over who should be required to pay AT&T’s bills is outside the Commission’s jurisdiction to resolve. The record shows that TruConnect continued to receive interconnection services under the ICA, without paying for them and without notifying AT&T that the ICA was terminated, until March 31, 2016. The background facts described in the decision provide an adequate record to support ordering TruConnect to pay all AT&T’s charges, plus applicable late fees, for services rendered under the ICA between AT&T and TruConnect through March 31, 2016. The factual background need not be amended as requested by TruConnect.Request For Oral Argument DeniedTruConnect requests oral argument pursuant to Rule 16.3 on the grounds that the decision presents issues of “major significance”, “novel legal issues of first impression,” and “important policy issues.” However, TruConnect fails to explain or elaborate. Commission Rule 16.3 gives the Commission discretion to determine whether oral argument is necessary during the rehearing stage. As discussed above, this decision resolves a routine ICA dispute and does not change Commission decisions or orders and does not adopt new precedent. The decision orders TruConnect to pay for services it received under an ICA with AT&T and declines to decide a dispute over which it lacks jurisdiction. TruConnect has failed to justify its request for oral argument. CONCLUSIONFor the reasons stated above, we deny TruConnect’s Application for Rehearing of D.21-06-007 and request for oral argument.THEREFORE, IT IS ORDERED that: 1.TruConnect’s Application for Rehearing of Decision 21-06-007 is denied.2.TruConnect’s request for oral argument is denied. 3.This proceeding is closed.This order is effective today.Dated September 9, 2021 at San Francisco, California.MARYBEL BATJER PresidentMARTHA GUZMAN ACEVESCLIFFORD RECHTSCHAFFENGENEVIEVE SHIROMADARCIE L. HOUCK Commissioners ................
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