On Wednesday evening the FCC announced another round of proposed fines totaling nearly $44 million against three Lifeline ETCs for alleged intra-company duplicates, which involve the same subscriber receiving Lifeline support from the same ETC.  These three Notices of Apparent Liability (“NALs”) follow five others issued on September 30 (proposing $14.4 million in fines) and three issued on November 1 (proposing almost $33 million in fines).  The new NALs were issued to Global Connection (d/b/a Stand Up), Cintex, and Telrite.  The ETCs have 30 days to respond or, alternatively, pay the proposed fines.

This brings the total amount of proposed fines against Lifeline ETCs to $90 million in the past 75 days.  Some of the cited ETCs have begun to engage with FCC staff, including TracFone, which filed a summary  of a recent meeting in which the company asserted that its overall rate of alleged duplicates was a tiny 0.03% of its customer base and that approximately 21% of the subscribers at issue were incorrectly flagged by the Enforcement Bureau as duplicates.  Industry observers are interested in the extent to which the forthcoming National Lifeline Accountability Database, to be launched in 2014, will exhibit the same level of perfection as that sought in these NALs.