As a reminder to our premium rate clients, the following verbiage and disclaimers are required on your compliant websites. There has been a recent increase in audits around these requirements. We recommend reviewing your website as soon as possible to avoid an audit in the near future.

• The disclaimer “All purchases must be authorized by the account holder” must be visible above the fold on the compliance website. We are starting to see audits around this issue, so be proactive and add it to your website today to avoid an audit in the near future.
• For WebRegistration/Web opt-ins, pricing must appear directly above or below the phone # and PIN # entry field. (Cannot be diagonal or beside)

Please contact your Account Manager or 3Ci Support for more website requirements and compliance information.

This is reminder of the carrier provisioning schedules for this holiday season. Be sure to submit your programs by the dates listed below in order to start the process in 2011. Please note that provisioning delays may occur with the mobile operators due to staffing shortages during these timeframes. 3Cinteractive’s offices will be closed Friday, December 24, 2010, in observance of the Christmas holiday and on Friday, December 31, 2010 in observance of New Year’s. Please also be reminded that mobile operator provisioning schedules are subject to change at any time.

AT&T has a provisioning freeze as of Sunday, November 21, 2010 at 12:00 PM EST (noon). Please keep in mind that programs submitted after this date will not begin the provisioning process until January 3, 2011.

All campaigns were to have been submitted to Sprint by 12:00 PM EST (noon) on Monday, November 22, 2010 (this is for the provisioning cycle occurring on Thursday, December 9, 2010).

There are no provisioning freezes scheduled at this time.

There are no provisioning freezes scheduled at this time.

In observance of the remaining 2010 holidays, Verizon Wireless will not review, approve, or provision any Short Code Programs on the following dates:

• Friday, December 24, 2010
• Friday, December 31, 2010

There are no provisioning freezes scheduled at this time.

For any questions, please contact your account manager or 3Ci Support via telephone at 561.443.5505 or via email at support@3cinteractive.com.

As a reminder to our standard rate clients who may be running a contest or a sweepstakes, following is the verbiage required on a “Contest Rules” or “Sweepstakes Rules” page linked to from the mobile program page of your website:

• The dates of the contest/sweepstakes must appear
• The date of drawing must be indicated
• The method of entry needs to be specified
• Eligibility should be detailed
• The age of the contestants and any age restrictions must be noted
• A description of the prizes.

Note: be sure to confer with your legal team or sweepstakes administrator regarding the complete legal requirements for your mobile program.

Please note that Revol is no longer supporting Premium-rated programs. This includes all existing and new premium programs. It’s not anticipated that this will not have a serious impact as Revol primarily services parts of the Midwest and the Northeast.

Please contact your Account Manager or 3Ci Support for more website requirements and compliance information.

As a reminder to our standard rate clients, following is the verbiage and font styles / formats required on the “Terms and Conditions” page, linked to from the mobile program page of your website. At a minimum the Terms and Conditions page must include:

• Terms and conditions for mobile program must appear at the top of the page
• Program Sponsor information, defined as the program name, company name, or brand associated with the campaign
• Program pricing (Msg&Data Rates May Apply)
• Customer service support information
• Help information in bold (For help at any time text HELP to XXXXX)
• Opt-out information in bold (To stop messages at any time text STOP to XXXXX)
• Frequency of program services
• Carriers supported on the program

Note: be sure to confer with your legal team regarding the complete content requirements for your mobile program.

Please contact your Account Manager or 3Ci Support for more website requirements and compliance information.

As a reminder to our standard rate clients, following is a partial list of verbiage and font styles / formats that are required on the mobile program page of your website:

• A two to three (2-3) sentence description of the service including all program types on file with the carriers
• The frequency of alerts if offered (in monthly terms, e.g. Max 5 msgs/month)
• The verbiage Message and Data Rates May Apply must appear within one line of any call-to-action or cell phone submit field (Msg&Data Rates May Apply). Please note that the following formats are not allowed:
       · Msg & Data rates may apply
       · Msg+data rates may apply
       · Message & data rates may apply
       · Msg and data rates may apply
• Opt-out information must appear in bold type (e.g. To stop messages at any time text STOP to XXXXX)

Please contact your Account Manager or 3Ci Support for more website requirements and compliance information.

AT&T recently made auditing and monitoring policy changes to standard and premium campaigns.

Effective May 3, 2010, AT&T is implementing the following changes to its audit process:

• The scoring system that AT&T has used in the past for auditing will no longer be used. Instead a PASS/FAIL indication will be shown
• There will no longer be a “three strikes” process with regard to audits
• An audit will receive a FAIL if a customer-affecting or AT&T brand-affecting issue has been found during the audit, or if the issue breaks any of the MMA CBP guidelines. (A PDF copy of the guidelines is available for download here. Please note that you will need Adobe® Reader® in order to view the document)
• Root cause analysis (RCA) will be required for all failed audits. RCA will also be required for programs that generate over 25% refund rate
• Please be advised that IQ Quiz type-content will continue to follow the IQ Quiz Policy, dated December 2009

AT&T will continue to send feedback forms summarizing the failed audit; however, the following changes will occur:

• A failure in one or more criteria will result in a failed audit which will be considered an “escalation”
• All failed criteria must be resolved within five (5) business days
• AT&T will automatically check for compliance following Day 5
• Any escalation / failed audit not completely resolved will result in closure of the campaign. If a campaign is closed for failure, the customer will have 14 days to fix the issue or risk having the short code de-provisioned
• AT&T will indicate the reason for closure and change the campaign status
• No new subscriptions will be allowed immediately; however, existing customers will be able to retain their service
• AT&T will monitor activity for closed campaigns
• When a program failure is ‘resolved’, it can be stated within the RCA delivered to AT&T, which in turn will be reviewed for re-activation
• Failure to comply with this new policy will result in de-provisioning of the entire short code

Please contact your Account Manager or 3Ci Support if you should have any questions regarding AT&T’s changes to its audit process.

3Cinteractive, along with Neustar, was proud to sponsor the Mobile Marketing Association’s (MMA) 2010 Consumer Best Practices (CBP) Public Forum event. The forum, held at the Boca Raton Resort and Club in Boca Raton, Florida, discussed the CBP Guidelines, which are produced by the MMA’s CBP Committee (of which 3Cinteractive is a member). The guidelines provide measures of acceptable and unacceptable practices. Updated regularly, these guidelines set the industry standard for cross- carrier mobile content services, such as short messaging service (SMS), multimedia messaging service (MMS), shortcode programs, interactive voice response (IVR), and mobile web.

Pictured, left to right: Vic Shroff, 3Cinteractive; Alykahn Govani, MX Telecom;
and Jeremy Martin, 3Cinteractive

Here are some of our insights from the industry forum, which continues its charge of shaping the mobile industry as a viable, profitable market place that provides value to the end user.

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