• On June 10, 2011, Verizon Florida LLC filed a second motion to dismiss a complaint filed against it by Bright House Networks Information Services with the Florida Public Service Commission (FPSC). The complaint, which also names long-distance company Verizon Business Services as a defendant, includes allegations that the Verizon entities are refusing to pay intrastate access charges to Bright House for VoIP traffic. Verizon previously moved to dismiss the complaint against both Verizon entities on the ground that the Commission does not have jurisdiction over VoIP traffic. After Verizon filed that motion, Bright House and Verizon Florida, the local exchange carrier (LEC) entity, entered into an interconnection agreement (ICA), which set a rate of $0.0007 for all VoIP traffic exchanged between the two LECs.

Verizon then filed a supplemental motion to dismiss, arguing that Bright House has implicitly conceded that its complaint against Verizon is without merit, arguing that “if Bright House believed that applying a $0.0007 rate to IP-format traffic was ‘unfair and unreasonable’, Bright House would not have agreed to that rate in its agreement with Verizon Florida.” In its response, Bright House denied that the ICA represents any concession, stating that “We settled with Verizon-ILEC only because, as to Verizon-ILEC, we exchange only local and intraLATA traffic, which we think should all be rated as local in any event. That has nothing to do with Verizon Business's obligation to pay access charges on intrastate, interLATA traffic.” Docket No. 110056-TP.