• On June 22, 2011, a group of 34 Missouri local exchange carriers (LECs) filed a complaint against Halo Wireless, Inc. with the Missouri Public Service Commission (MPSC), alleging that Halo is illegally sending traffic to the LECs for termination. Five other Missouri LECs, Alma Communications Company, Chariton Valley Telephone Corporation, Choctaw Telephone Company, Mid-Missouri Telephone Company, and MoKAN DIAL, Inc., filed a similar complaint against Halo with the MPSC earlier this month. According to the LECs, beginning in December 2010, they began receiving traffic records indicating that Halo was sending them traffic through AT&T, but after performing a traffic study, they determined that approximately 70% of the traffic was intrastate, interexchange wireline-originated traffic. The LECs then billed Halo access charges for this traffic, but Halo claimed that it did not owe access charges because a “de facto bill and keep” arrangement existed between the carriers. The LECs further assert that Halo is in violation of its Interconnection Agreement (ICA) with AT&T, which requires Halo to negotiate agreements with other LECs prior to sending traffic for termination. Docket No. TC-2011-0404.