Earlier this month, the Federal Communications Commission took drastic and quite draconian actions in its enforcement of the Universal Service Fund reporting and contribution requirements by releasing Notices of Apparent Liability against three companies – Global Crossing, Compass Global and Telrite Corporation. According to the FCC allegations in the respective NAL Orders, these companies “willfully and repeatedly” violated the FCC’s reporting and contribution rules related to the USF, Telecommunications Relay Services and other FCC programs.