ASI Worldwide v. MCI WorldCom

2002 DNH 076
CourtDistrict Court, D. New Hampshire
DecidedMarch 29, 2002
DocketCV-98-154-B
StatusPublished

This text of 2002 DNH 076 (ASI Worldwide v. MCI WorldCom) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ASI Worldwide v. MCI WorldCom, 2002 DNH 076 (D.N.H. 2002).

Opinion

ASI Worldwide v. MCI WorldCom CV-98-154-B 03/29/02

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

A .S .I . Worldwide Communications Corp.

v. Civil No. 98-154-B Opinion NO. 2002 DNH 076 MCI WorldCom Network Services, Inc.

MEMORANDUM AND ORDER

In 1994, a predecessor of defendant WorldCom Network

Services, Inc. agreed to provide long distance telephone services

to plaintiff ASI Worldwide Communications Corporation for resale

to the public. ASI did not intend to file tariffs with the

Federal Communications Commission ("FCC") or take other measures

required by federal and state law to sell the long distance

services itself. Instead, it planned to identify end users for

the long distance services through marketing efforts and contract

with an authorized reseller to service the end users.

ASI's relationship with WorldCom was plagued by difficulty

from the outset. ASI claims that WorldCom repeatedly violated the tariff under which it was providing the long distance

services by overcharging ASI and failing to provide it with

accounting information. ASI also asserts that WorldCom

improperly transferred end users controlled by ASI to WorldCom's

own account, a process known as "slamming." ASI's concerns

eventually prompted it to terminate its agreement with WorldCom

and file this action asserting claims for interference with its

contractual relationships (Count I), conversion (Count II),

violations of New Hampshire's Consumer Protection Act, N.H. Rev.

Stat. Ann. 358-A (Count III), and violations of various

provisions of the Federal Communications Act ("FCA"), 47 U.S.C.

§§ 151 _et seq. (Counts IV-VIII) .

WorldCom has responded with a motion for summary judgment.

It argues that ASI's slamming claims are defective because ASI

lacked a proprietary interest in its end users. WorldCom also

contends that ASI engaged in a pattern of illegality in its

dealings with its end users that prevents it from maintaining its

current claims. Finally, it argues that ASI cannot support its

claims with enough evidence to warrant a trial.

- 2 - I. BACKGROUND1

In March 1994, WilTel, Inc., WorldCom's predecessor, entered

into a contract to provide ASI with its "WilPlus III" long

distance telephone services for a period of three years. The

parties' business relationship, including the rates, terms and

conditions under which the services were to be provided, was

governed by a tariff WilTel filed with the FCC. ASI promised to

generate at least $100,000 in monthly long distance call volume

and furnish WilTel with certain letters of credit in exchange for

WilTel providing ASI with a 40% discount on the WilPlus III

three-year base rates set in its tariff. The contract entitled

ASI to an even more favorable rate if it generated more than

$200,000 in monthly call volume.

ASI and WilTel entered into an addendum to the contract in

May 1995, wherein (1) ASI agreed to generate at least $350,000 in

monthly long distance call volume or to pay that amount as a

minimum monthly charge if it failed to achieve that volume; (2)

1 I construe the evidence in the light most favorable to ASI, the non-moving party, and draw all reasonable inferences in its favor. See Navarro v. Pfizer Corp., 261 F.3d 90, 94 (1st Cir. 2001) (explaining the operation of Fed. R. Civ. P. 56) (citation omitted).

- 3 - ASI agreed to furnish WilTel with certain cash security deposits

and/or letters of credit; (3) WilTel agreed to provide ASI with a

40% discount on the WilPlus III three-year base rates set in the

applicable tariff; and (4) WilTel promised to provide ASI with an

annual credit equivalent in value to one month of free long

distance usage. In or around 1995, WorldCom acquired WilTel and

assumed WilTel's obligations under the agreements with ASI.

ASI developed end users for the services it acquired from

WorldCom through marketing efforts. It did not, however, file

its own tarriffs with the FCC and take other actions that were

required to become an authorized reseller. Instead, it

contracted with TWC Communications, Inc. ("TWC"), an authorized

reseller, to serve the end users listed on ASI's WorldCom

account. ASI retained control over the accounts it generated by

having customers sign Letters of Agency, authorizing ASI to place

their service with TWC. When ASI ordered service for its end

users, it provided WorldCom with the customer's name, contact

telephone number, and the address where the service was to be

installed. Pursuant to ASI's agreement with WorldCom, WorldCom

provided ASI with a record of calls made by customers listed on

- 4 - ASI's account. ASI, in turn, sent the record to TWC. TWC

generated the bills for each customer on ASI's account and

customers were instructed to send their payments to TWC.

TWC terminated its relationship with ASI in November 1996,

leaving ASI without an authorized reseller to service its

customer base. As a temporary arrangement, TWC agreed to

continue billing end users on ASI's account through December

1996. ASI then entered into an agreement with CCC Communications

Corporation ("CCC"), whom ASI understood was planning to acquire

TWC. CCC allowed ASI to bill end users on ASI's WorldCom account

using TWC's tariffs and certifications through February 1997.

In May 1997, ASI contracted with another certified reseller,

WorldTel Services, Inc. ("WorldTel"). Under its agreement with

WorldTel, ASI billed the end users on its WorldCom account in

accordance with WorldTel's filed tariffs. In return, ASI paid

WorldTel the greater of 1% of billed revenues from its end users'

telecommunications usage or $5,000 per month. The parties agreed

that the contract would operate retroactively, beginning with the

March 1997 billing period. ASI then billed its customers for

March, April, and subsequent months using WorldTel's tariffs.

- 5 - During its business relationship with WorldTel, ASI funded an

escrow account from which taxes associated with the

telecommunications services provided were paid. ASI sent its end

users bills which reflected charges for service provided by

WorldTel in conjunction with ASI. ASI also handled all customer

service issues that arose throughout its relationship with

WorldTel. ASI did not obtain authorization from any of its

customers before moving them from TWC to WorldTel.

ASI made hundreds of requests throughout its relationship

with WorldCom for accountings of charges that it believed were

erroneous. WorldCom either ignored ASI's requests, or instructed

ASI to pursue a lengthy, bureaucratic process to obtain credits.

ASI alleges that it could take months or years for credits to be

applied to ASI's account, and that even after bills were

corrected, WorldCom would reinstitute the erroneous charges on

later bills, thus causing ASI to repeat the burdensome process of

pursuing credits.

Frustrated with the process of applying for credits, ASI at

times engaged in self-help by withholding payments to WorldCom

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