Further Guidance Regarding Prepaid Calling Card Marketing/Disclosure Guidelines


Last week, our firm distributed to all clients engaged in the prepaid calling card services industry a Client Advisory detailing the implications of recent federal and state law enforcement actions on the marketing activities and trade practices of the industry. As described in the Client Advisory, our firm sought to identify marketing, disclosure and practice “Guidelines” which our clients could review, evaluate and, to the extent applicable and practical, implement in their respective businesses to safeguard against allegations of deceptive marketing and/or unfair trade practices by law enforcement, the general public and competitors. A copy of this Client Advisory is attached to this Memo for ease of reference. As we continue our on-going effort to comprehend and predict the “end game” of law enforcement agents, such as the Federal Trade Commission (“FTC”), State Attorneys General Offices (“SAGOs”) and state legislatures, with respect to “cleaning up” the calling card industry, our firm will share our evaluations and guidance with affected clients.

ATTORNEY ADVERTISING DISCLAIMER: This information may be considered advertising in some jurisdictions under the applicable law and ethical rules. The determination of the need for legal services and the choice of a lawyer are extremely important decisions and should not be based solely upon advertisements or self-proclaimed expertise. No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers

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