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.