In August 2004, AT&T discovered it may have overcharged the government for services and equipment the company provided to schools through the Federal Communications Commission-administered E-Rate program. AT&T voluntarily reported the billing irregularities to the FCC, which investigated, and by December of that year the matter was settled, with AT&T agreeing to pay $500,000 and enter a corporate compliance program. Case closed.

But the business records the FCC amassed from AT&T during that investigation may still become an open book–they include invoices, internal e-mails giving pricing and billing information, responses to FCC questions, names of employees involved in the billing irregularities, and AT&T’s self-assessment of whether and to what extent employees involved may have violated the company’s internal code of conduct. In April 2005, CompTel, a trade group representing some of AT&T’s competitors, submitted a Freedom of Information Act (FOIA) request to the FCC’s Enforcement Bureau for “all pleadings and correspondence contained in” the AT&T E-Rate investigation file.