Opinion for the Court filed by Circuit Judge RANDOLPH.
RANDOLPH, Circuit Judge.
At issue in this petition for review is the proper regulatory classification of "enhanced" prepaid calling cards, a product AT & T introduced in 1994 and no longer sells. Prepaid calling cards allow purchasers to make long-distance telephone calls without subscribing to a long-distance service or using a credit card. Instead, the purchaser buys a fixed number of minutes at...
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