• On July 11, 2011, the United States District Court for the Western District of Michigan, on its own motion, stayed the access charge litigation between Lucre, Inc., a local exchange carrier, and Qwest’s long-distance entity, rather than address Qwest’s motion to dismiss several claims in Lucre’s complaint. Lucre sued Qwest for unpaid access charges, but Qwest maintains that Lucre’s provision of services to free conferencing service providers renders the calls non-compensable. Qwest moved to dismiss most claims in Lucre’s complaint, arguing that the filed tariff doctrine precludes Lucre’s claims for equitable relief and declaratory judgment. The court identified numerous other cases raising similar issues that have been referred to the FCC or stayed pending FCC action on the pending Notice of Proposed Rulemaking on intercarrier compensation reform. The court held that on “the basis of the primary jurisdiction doctrine, the need for FCC expertise on these issues, and the substantial risk of inconsistent rulings, this Court will issue a stay to afford the FCC the opportunity to resolve the issues referred to it by the courts in several of the cases cited above ... .” The court denied Qwest’s motion to dismiss without prejudice as premature. Lucre, Inc. v. Qwest Commc’ns Co., No. 1:09-cv-902 (W.D. Mich.).