PR Tel. Co., Inc. v. Sprintcom, Inc.

PRTC, telecommunications local exchange carrier under the jurisdiction of the Telecommunications Regulatory Board of Puerto Rico and the FCC, entered into an interconnection agreement with Sprint. In a dispute concerning compensation, the Board held that under the agreement''s change-of-law provision PRTC and Sprint were to reciprocally compensate each other for internet-service-provider bound traffic in accordance with an interim compensation order set forth by the FCC in its ISP Remand Order. The Board dismissed Sprint's claim that PRTC had overcharged for termination of transit traffic. The district court upheld the Board. The First Circuit reversed in part. The ISP Remand Order did not alter existing contractual obligations and, therefore, did not trigger the change-of-law provision. The court affirmed dismissal of the overbilling claim.