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service and hence the rates that IXCs [interexchange or
long-distance carriers] must charge their interstate
customers. Moreover, * * * DNP [disconnection for
nonpayment] is integral to the billing and collection
service that C&P provides to interstate carriers. * * *
Finally, * * * AT&T must rely on the LECs to
perform recording of call detail information * * *.
* * * IXCs cannot, as a practical matter, offer
interstate telephone service without obtaining recorded
call detail information sufficient to collect payment
from customers * * * .
Besides "affecting" interstate communications, the
billing and collection service that C&P provides for
AT&T are also "closely related to the provision of
[such] services," since billing and collection must
occur accurately and efficiently for an interstate
carrier to offer its services on an economically sound
basis. From a technical perspective, DNP and the call
detail recording function are two integral components
of the billing and collection services that C&P
provides to interstate carriers that are closely
related to the interstate communication services of
those carriers. DNP and recording are each performed
as a function of the LECs' provision of interstate
communications service * * * that other, non-carrier
vendors of billing and collection services cannot
provide.
* * * When one interstate carrier is performing
billing and collection for the interstate services of
another interstate carrier under circumstances like
those involved in C&P's relationship with AT&T the
billing and collection service is incidental to
interstate communications and subject to our Title I
jurisdiction. [Fn. ref. omitted; emphasis supplied.]
4 FCC Rcd at 4005.
Finally, in 1992, the FCC formally reversed the position it
had taken in the 1986 Detariffing Order. In In the Matter of
Policies and Rule Concerning Local Exchange Carrier Validation
and Billing Information for Joint Use Calling Cards, 7 FCC Rcd
3528 (1992) (1992 FCC Decision), the FCC stated affirmatively
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