HomeMy WebLinkAboutEx. 1 to SJ Recon Ruling4/19/2021 Gmail - Re: In re TracFone Wireless, Inc.
https://mail.google.com/mail/u/0?ik=bf094191aa&view=pt&search=all&permthid=thread-f%3A1696420081300613181%7Cmsg-a%3Ar8818110666074…1/2
Phil Olbrechts <olbrechtslaw@gmail.com>
Re: In re TracFone Wireless, Inc.
1 message
Phil Olbrechts <olbrechtslaw@gmail.com>Wed, Apr 7, 2021 at 8:18 PM
To: "Craig, Angela" <CraigA@lanepowell.com>
Cc: CityClerk <CityClerk@rentonwa.gov>, Cynthia Moya <CMoya@rentonwa.gov>, "ksand@omwlaw.com"
<ksand@omwlaw.com>, "Kenya C. Owens" <kowens@omwlaw.com>, "Edwards, Scott M." <EdwardsS@lanepowell.com>,
"Degginger, Grant" <DeggingerG@lanepowell.com>, Docketing <Docketing@lanepowell.com>, "Tsuboi, Norma"
<TsuboiN@lanepowell.com>
Supplementing my prior email, I neglected to mention that I didn't find Mr. Malone's Fred Meyer purchase very illuminating
on the issue, since I understood him to be just adding airtime to a handset that already had its own minutes. I don't
believe there was anything from the description of that event that would preclude that understanding.
On Wed, Apr 7, 2021 at 8:06 PM Phil Olbrechts <olbrechtslaw@gmail.com> wrote:
Thank you for the reconsidera on briefing. I will likely need at least a week to carefully go through the arguments
presented by the par es. In the mean me, in lieu of oral argument, I’m hoping we can resolve the ambigui es of
the handset issue by email.
In clarifying the handset issue in my reconsidera on decision, I would like to give the par es an opportunity to
iden fy where in the administra ve record it is established that the handsets are sold and charged separately from
air me.
My understanding of the handsets sales was that Tracfone handsets include Tracfone air me rights to the same
extent as air me cards, in a sense being “preloaded” with air me in the same fashion as air me cards. In this
scenario the phones simply serve as a more expensive and func onal version of plas c air me cards. It was also
my understanding that the handsets were sold to the consumer via one charge. This is why I found the Ac vate
case per nent. In its reconsidera on request, Tracfone argued that the handset sales are not subject to the u lity
tax because handset sales qualify as compe ve telephone service. The Ac vate court held that sales of handsets
do not qualify as compe ve telephone service if they are not charged separately from network telephone service.
The evidence presented by the City le a very strong impression that the handsets were “loaded” with air me in
the same fashion as the air me cards. The most detailed rendi on of how handsets are sold and ac vated was in
the 1/29/21 Ashpaugh declara on. Paragraph 10 of his declara on states that both air me cards and handsets will
be referenced as “equipment.” Paragraph 12 states that when “equipment” (which includes handsets) is scanned
for purchase by a consumer, Tracfone is no fied electronically. Mr. Ashpaugh goes on to declare that once the
“equipment ” (which includes handsets) is purchased, it (the handset, without an air me card) doesn’t become
ac vated un l the consumer contacts TracFone via website or phone number.
So from the Ashpaugh declara on, it was reasonable to conclude that a handset could be purchased without an
air me card and then ac vated for use. Under such a scenario there would be no basis for concluding that any
air me “loaded” into the handset would be charged separately from the phone itself. Indeed, my one me
experience with prepaid air me was the purchase of a disposable phone when I forgot to pack my cell phone on a
business trip. As best as I can recall, there was only one charge for that phone.
The City’s request for summary judgment relief also made no dis nc on between air me card sales and handset
sales. In its Statement of Facts, the City iden fied that Tracfone sells wireless services and handsets directly and to
retail agents. The City then framed its second ques on presented as “Is TracFone’s gross income from its retail
agents properly included within the City’s tax base…” Nowhere in its summary judgment argument did the City
dis nguish between gross income generated from handset sales and that generated from air me cards.
A er being presented with the record and arguments described above, I’m now told that the City’s sj mo on was
only advoca ng for applica on of the u lity tax to air me card sales and also that handsets are not “ac vated” in
the fashion described in the Ashpaugh declara on. I am happy to accommodate the par es’ request on this issue
since both par es are in agreement. However, it would be helpful to be able to iden fy something in the record
and/or briefing that clearly iden fies that all handsets are sold separately from air me and also that the City had
limited is sj request to gross sales of air me. On the la er issue, simply sta ng that the City was only asking for
u lity tax on network telephone service doesn’t resolve the situa on, since handsets that serve as glorified air me
cards arguably qualify as network telephone service if the air me is not separately charged.
4/19/2021 Gmail - Re: In re TracFone Wireless, Inc.
https://mail.google.com/mail/u/0?ik=bf094191aa&view=pt&search=all&permthid=thread-f%3A1696420081300613181%7Cmsg-a%3Ar8818110666074…2/2
If the par es have any references they ’d like to make to the record to clarify the handset issue, please do so by
email by next Tuesday. I’ll try to get my ruling out shortly therea er.
On Wed, Apr 7, 2021 at 2:51 PM Craig, Angela <CraigA@lanepowell.com> wrote:
Good afternoon. Attached for filing in the above matter, please find the following:
Reply in Support of TracFone’s Motion for Reconsideration
Please confirm receipt. Thank you.
ANGELA CRAIG
Legal Assistant
craiga@lanepowell.com
D 206.223.6138
LANEPOWELL.COM
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