Pursuant to Federal Communications Commission (“FCC” or “Commission”) requirements, all prepaid calling card providers must report percentage of interstate usage (“PIU”) factors and call volumes on which these factors were calculated to those carriers from which they purchase transport services by the 45th day of each calendar quarter. In addition, prepaid calling card providers must file quarterly certifications with the FCC (“FCC Certification”) attesting to their compliance with certain PIU and Universal Service Fund (“USF”) reporting requirements.