Rule Radiophone Service, Inc. 2232 Dell Range Boulevard Cheyenne, WY 82009 !99! "30#$ %3!

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February 28, 2014 Marlene H. Dortch, Secretary Federal Communications Commission 445 12th Street, S. ., Suite ! "#$25 ashin%ton, D.C. 20554 &'# (lectronic Filin% )e* Certi+ication o+ C,-' Filin% (. Doc/et -o. 00"$0 F)-* 000$"1088"01 Form 422 Filer 'D* 815202 Dear Ms. Dortch* !ransmitted electronically, in accordance 3ith the Commission4s (n+orcement #d5isory 2014"02 6D# 14"1$87, and Section 04.20026e7 o+ the Commission4s )ules, is the certi+icate o+ com8liance and statement +or the year 3hich ended on December $1, 201$ +rom )ule )adio8hone Ser5ice, 'nc.

9ours truly,

Robert R. Rule, pres.

)obert ). )ule, 8resident, ):;( )#D'<,H<-( S()&'C(, '-C.

#nnual 41 C.F.). = 04.20026e7 C,-' Certi+ication (. Doc/et 00"$0

#nnual 04.20026e7 C,-' Certi+ication +or 201$ 6Filed in 20147 Date +iled* February 28, 2014 -ame o+ com8any co5ered by this certi+ication* )ule )adio8hone Ser5ice, 'nc. Form 422 Filer 'D* 815202 -ame o+ si%natory* )obert ). )ule !itle o+ si%natory* ,resident ', )obert ). )ule, certi+y that ' am an o++icer o+ the com8any named abo5e, and actin% as an a%ent o+ the com8any, that ' ha5e 8ersonal /no3led%e that the com8any has established o8eratin% 8rocedures that are ade>uate to ensure com8liance 3ith the Commission4s C,-' rules. See 41 C.F.). = 04.2001 et seq. #ttached to this certi+ication is an accom8anyin% statement e?8lainin% ho3 the com8any4s 8rocedures ensure that the com8any is in com8liance 3ith the re>uirements 6includin% those mandatin% the ado8tion o+ C,-' 8rocedures, trainin%, record/ee8in%, and su8er5isory re5ie37 set +orth in section 04.2001 et seq. o+ the Commission4s rules. !he com8any has not ta/en any actions 6i.e., 8roceedin%s instituted or 8etitions +iled by a com8any at either state commissions, the court system, or at the Commission a%ainst data bro/ers7 a%ainst data bro/ers in the 8ast year. !he com8any has not recei5ed any customer com8laints in the 8ast year concernin% the unauthori@ed release o+ C,-'. !he com8any re8resents and 3arrants that the abo5e certi+ication is consistent 3ith 41. C.F.). = 1.11 3hich re>uires truth+ul and accurate statements to the Commission. !he com8any also ac/no3led%es that +alse statements and misre8resentations to the Commission are 8unishable under !itle 18 o+ the :. S. Code and may subAect it to en+orcement action. Si%ned*

Robert R. Rule, pres.

)obert ). )ule, ,resident, )ule )adio8hone Ser5ice, 'nc.

#ttachment* #ccom8anyin% Statement e?8lainin% C,-' 8rocedures S'(')*)+'

)ule )adio8hone Ser5ice, 'nc., 6BCarrierC7 has established o8eratin% 8rocedures that ensure com8liance 3ith the Federal Communication Commission 6BCommissionC7 re%ulations re%ardin% the 8rotection o+ consumer 8ro8rietary net3or/ in+ormation 6BC,-'C7. Carrier has im8lemented a system 3hereby the status o+ a customer4s C,-' a88ro5al can be determined 8rior to the use o+ C,-'. Carrier continually educates and trains its em8loyees re%ardin% the a88ro8riate use o+ C,-'. Carrier has established the re>uired disci8linary 8rocedures should an em8loyee be +ound to be in 5iolation o+ the C,-' 8roducers established by Carrier. Carrier maintains a record o+ its a++iliates4 sales and mar/etin% cam8ai%ns that use its customer4s C,-'. Carrier also maintains a record o+ any and all instances 3here C,-' 3as disclosed or 8ro5ided to third 8arties, or 3here their 8arties 3ere allo3ed access to C,-', should this e5er ha88en in the +uture. !he record 3ill include a descri8tion o+ each cam8in%, the s8eci+ic C,-' that as used in the cam8ai%n, and 3hat 8roducts and ser5ices 3ere o++ered as a 8art o+ the cam8ai%n. !o date, no such cam8ai%ns ha5e been used. Carrier has established a su8er5isory re5ie3 8rocess re%ardin% com8liance 3ith the C,-' rules 3ith res8ect to outbound mar/etin% situations and maintains records o+ carrier com8liance +or a minimum o+ one year. Carrier4s sales 8ersonnel 3ill obtain su8er5isory a88ro5al o+ any 8ro8osed outbound mar/etin% re>uest +or customer a88ro5al re%ardin% its C,-'. .ut, +rom a 8ractical 5ie3 8oint, Carrier does not use outside mar/etin% e++orts, and thus, most o+ this does not a88ly. B#88ro8riate authentication o+ customers 3here Carrier 8ro5ides online access to account in+ormationC is mootD no account in+ormation is on line. B#uthentication o+ customers in retail locationsC is mostly moot, as 3e ha5e only one o++ice em8loyee, and she /no3s all o+ the customers 8ersonally. Should this chan%e, 3e 3ill re>uire ne3 em8loyees to chec/ customer 'Ds. B# re>uirement to establish a 8ass3ord 8rotection 3hen Carrier 8ro5ides online access to account in+ormation is moot, as account in+ormation is not 8osted online. )e%ardin% any actions ta/en a%ainst data bro/ers, includin% a summary o+ all customer com8laints recei5ed in the 8ast year concernin% the unauthori@ed release o+ C,-', this is all moot, as none o+ this has ha88ened.

Robert R. Rule, pres.

)obert ). )ule, ,resident, ):;( )#D'<,H<-( S()&'C(, '-C.

February 28, 2014 (''(C,*)+' 3 !# C.-.R. . %!.2009 Sa/eguard0 re1uired /or u0e o/ cu02o3er proprie2ary ne24or5 in/or3a2ion.
6a7 !elecommunications carriers must im8lement a system by 3hich the status o+ a customerEs C,-' a88ro5al can be clearly established 8rior to the use o+ C,-'. 6b7 !elecommunications carriers must train their 8ersonnel as to 3hen they are and are not authori@ed to use C,-', and carriers must ha5e an e?8ress disci8linary 8rocess in 8lace. 6c7 #ll carriers shall maintain a record, electronically or in some other manner, o+ their o3n and their a++iliatesE sales and mar/etin% cam8ai%ns that use their customersE C,-'. #ll carriers shall maintain a record o+ all instances 3here C,-' 3as disclosed or 8ro5ided to third 8arties, or 3here third 8arties 3ere allo3ed access to C,-'. !he record must include a descri8tion o+ each cam8ai%n, the s8eci+ic C,-' that 3as used in the cam8ai%n, and 3hat 8roducts and ser5ices 3ere o++ered as a 8art o+ the cam8ai%n. Carriers shall retain the record +or a minimum o+ one year. 6d7 !elecommunications carriers must establish a su8er5isory re5ie3 8rocess re%ardin% carrier com8liance 3ith the rules in this sub8art +or outbound mar/etin% situations and maintain records o+ carrier com8liance +or a minimum 8eriod o+ one year. S8eci+ically, sales 8ersonnel must obtain su8er5isory a88ro5al o+ any 8ro8osed outbound mar/etin% re>uest +or customer a88ro5al. 6e7 # telecommunications carrier must ha5e an o++icer, as an a%ent o+ the carrier, si%n and +ile 3ith the Commission a com8liance certi+icate on an annual basis. !he o++icer must state in the certi+ication that he or she has 8ersonal /no3led%e that the com8any has established o8eratin% 8rocedures that are ade>uate to ensure com8liance 3ith the rules in this sub8art. !he carrier must 8ro5ide a statement accom8anyin% the certi+icate e?8lainin% ho3 its o8eratin% 8rocedures ensure that it is or is not in com8liance 3ith the rules in this sub8art. 'n addition, the carrier must include an e?8lanation o+ any actions ta/en a%ainst data bro/ers and a summary o+ all customer com8laints recei5ed in the 8ast year concernin% the unauthori@ed release o+ C,-'. !his +ilin% must be made annually 3ith the (n+orcement .ureau on or be+ore March 1 in (. Doc/et -o. 00"$0, +or data 8ertainin% to the 8re5ious calendar year. 6+7 Carriers must 8ro5ide 3ritten notice 3ithin +i5e business days to the Commission o+ any instance 3here the o8t"out mechanisms do not 3or/ 8ro8erly, to such a de%ree that consumersE inability to o8t"out is more than an anomaly. 617 !he notice shall be in the +orm o+ a letter, and shall include the carrierEs name, a descri8tion o+ the o8t"out mechanism6s7 used, the 8roblem6s7 e?8erienced, the remedy 8ro8osed and 3hen it 3ill beF3as im8lemented, 3hether the rele5ant state commission6s7 has been noti+ied and 3hether it has ta/en any action, a co8y o+ the notice 8ro5ided to customers, and contact in+ormation. 627 Such notice must be submitted e5en i+ the carrier o++ers other methods by 3hich consumers may o8t"out.