Over the past two years prepaid calling card providers have witnessed the rapid and, for many, painful evolution of the Federal Communications Commission’s (“FCC”) regulatory oversight of their industry segment. It began in February 2005 when the FCC issued an Order declaring AT&T’s “enhanced” calling card services nothing more than a plain old telephone service. AT&T was ordered to make retroactive contributions to the Universal Service Fund (“USF”) to make up for its prior failure to contribute on its “enhanced” card revenue. Then, in June 2006, the FCC used the AT&T ruling as a springboard for a broader order affecting the entire prepaid industry, entitled, In the Matter of Regulation of Prepaid Calling Card Services, WC Docket No. 05-68 (“Calling Card Order”).