Before the

FEDERAL COMMUNICATIONS COMMISSION

45 L Street NE
Washington, D.C. 20554

In the Matter of )
)
Default Sending of Wideband Audio to )
Domestic and International Telephone )
Destinations )

PETITION FOR DECLARATION OF DEFAULT SENDING OF WIDEBAND AUDIO
TO DOMESTIC AND INTERNATIONAL TELEPHONE DESTINATIONS
NOW Comes [Insert Your Full Name], Petitioner, and files this Petition for Declaration of
Default Sending of Wideband Audio to Domestic and International Telephone Destinations, and
for cause would show this Honorable Commission.

A. PARTIES

1. [Insert Your Full Name] is a law-abiding adult citizen and a resident of [Insert Full
Address]. He is the Petitioner in this matter.
2. This Petition has been filed to seek orders of specific performance against all mobile
carries within the United States.

B. JURISDICTION AND VENUE

3. Jurisdiction exists before this Commission pursuant to Title I of the Telecommunications
Act of 1996.
4. Venue is proper in Washington, D.C. as it is the address of the Commission to
Petitioner’s best knowledge.

C. STATEMENT OF FACTS

5. Mobile carriers currently operate in a manner which they are allowed to continue sending
narrowband audio to domestic and international telephone destinations. For instance, a
user with a wideband (“HD audio” typically G.722.2 AMR-WB codec) phone will get
very clear reception when calling someone on their carrier network.
6. On the other hand, if such a user calls someone on a competitor carrier’s network, the
user will not be able to differentiate between /f/ and sounds.
7. The current situation has led to a scenario in which competitors receive no benefit from
sending or receiving bandwith audio to other carriers.
8. For competitors to receive benefit from sending and receiving bandwith audio to other
carriers, mobile carriers should be required to send wideband audio to domestic and
international telephone destinations, except under the following circumstances: (1) in the
event that the callee (the person being called) cannot or will not accept the call; and (2) in
the event that a local mobile transceiver base station bandwith is limited, for instance, in
a packed sports event stadium. Under such circumstances, carriers should be allowed to
fall back to the use of narrowband audio.

D. PRAYER FOR RELIEF

REASONS WHEREFORE, PREMISES CONSIDERED, Petitioner respectfully requests this
Honorable Commission to grant the following reliefs:
a. GRANT this Petition;

b. ISSUE a Declaration that mobile carriers shall send wideband audio only to domestic and
international telephone destinations, except under the following circumstances: (1) in the
event that the callee (the person being called) cannot or will not accept the call; and (2) in
the event that a local mobile transceiver base station bandwith is limited, for instance, in
a packed sports event stadium. Under such circumstances, carriers shall be allowed to fall
back to the use of narrowband audio.
c. AWARD Petitioner such equitable and further relief as this Honorable Commission
deems fair, proper and necessary.

Dated this ___ day of August, 2022.

Respectfully Submitted,
___________________________________
[Insert Your Full Name],
Petitioner in pro per

VERIFICATION

I, [Insert Your Full Name], do swear and state under penalty of perjury that I have read the
foregoing Petition for Declaration of Default Sending of Wideband Audio to Domestic and
International Telephone Destinations, and know the contents thereof. That the same is true of my
own knowledge except as to those matters and things stated upon information and belief, and as
to those things, I believe them to be true.

_________________________________
(Sign in the presence of a Notary Public)

Sworn to and subscribed before me this ___ day of August, 2022.

_____________________________________
Notary Public

______________________________________
(Printed Name of Notary Public)

My Commission Expires: ________________

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