Initial Comments continue to provide evidence for further action against cramming on wireline, wireless, and VoIP services. As the expert agency, the Commission has had ample experience with cramming and how cramming has developed in the traditional landline industry. The Commission now has evidence of consumers being victims of wireless cramming, and from a caller’s perspective, a VoIP service acts the same as a traditional landline telephone service.

In this proceeding, several states and public interest groups have provided the necessary facts for why the Commission should act to impose restrictions not just on traditional wireline services, but also wireless and VoIP services. It is logical for the Commission to rely on its expertise to determine that these predatory practices will continue to explode on wireless and VoIP services and should use its predictive judgment to impose cramming restrictions on all carriers.