On March 31, 2010, Judge Rakoff of the Southern District of New York ruled that Manhattan Telecommunications Corp. (MTC) was entitled to compensation from Global NAPs for the termination of the Global’s VoIP-originated traffic under a theory of quantum meruit. MTC sought recovery under its federal and state access tariffs, but the court ruled them inapplicable to VoIP traffic. Yet despite finding the filed rate doctrine inapplicable to the VoIP traffic, the court held that MTC was still entitled to compensation from Global NAPs at the rates in its federal access tariff, effectively re-rating the traffic as interstate traffic. No. 1:08-cv-03829-JSR.