SOCIAL MEDIA GUIDEBOOK:
A guide for the use of social media sites
by local governments.
March 2010
Prepared for GMTC by
Kenneth S. Fellman
Nancy Cornish Rodgers
Kissinger & Fellman, P.C.
Copyright © 2010. Great Metro Telecommunications Consortium and Kissinger & Fellman, P.C. All rights
reserved. No reproduction without prior permission.
TABLE OF CONTENTS
PAGE
Introduction
Disclaimer
Section I
Section II
Section III
Section IV
Section V
Section VI
Section VII
Section VIII
Section IX
..................................................................................................................................1
..................................................................................................................................1
Background - Social Media .....................................................................................2
Evaluating Social Media Use in the Local Government Context ............................2
First Amendment Issues – Employment ..................................................................4
First Amendment Issues – Free Speech from the Public Perspective......................7
Colorado Open Records Act (CORA) .....................................................................9
Colorado Open Meetings Laws .............................................................................10
Copyright ...............................................................................................................11
American with Disabilities Act..............................................................................11
Special Considerations for Elected Officials .........................................................11
Appendix
A
B
C
GMTC Communities’ Social Media Site Use Chart as of March 2010
Examples of Social Media Use Employee Policies
Examples of Social Media Use Government Site Policies
The Greater Metro Telecommunications Consortium
The Greater Metro Telecommunications Consortium (GMTC) is an intergovernmental
agency comprised of local government representatives who work together on
telecommunications issues. Originally formed in 1992 to facilitate franchise agreements with the
local cable television operator, the GMTC has since realized benefits of sharing expertise and
pooling resources in addressing multiple areas of local government communications. Members
share information and resources pertaining to technologies; laws, ordinances, and policies that
govern the impact and implementation of services; and business transactions and regulatory
oversight involving telecommunication related industries.
The GMTC has opened doors to new levels of regional cooperation, with members
working together to represent their counties, municipalities, and ultimately, their citizens in
council chambers, with legislative and regulatory bodies, and directly with those companies that
provide services.
Introduction
Local governments that use social media sites are engaging their citizens in new and
different ways in order to provide services, address local concerns and create a variety of
opportunities for citizens to interact with their government. The use of social media sites is
breaking new ground and setting new standards. However, because social media technology and
local governments’ use of it is relatively new, there are many unknowns related to the results,
consequences and liability for its use. Further, with so many social media tools currently
available and more on the way, it can be overwhelming and impractical to evaluate and have a
presence on each site. This guide was created to assist local governments in evaluating the use,
or potential use, of social media sites and to provide options and recommendations for how local
governments may address the legal and oversight issues that arise from social media site usage.
Disclaimer
This guide provides general information about legal topics but it is not a complete
discussion of all legal issues that arise in relation to social media nor is it a substitute for legal
advice. This guide attempts to provide an overview of how the law is likely to treat many of the
issues that arise in relation to social media use by local government. As discussed herein, the
law on this topic is evolving. It is anticipated that this guidebook will be updated periodically.
GMTC members with specific questions should consult with their legal counsel or with GMTC’s
legal counsel.
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I. Background - Social Media
Social media includes a broad range of Internet- and mobile-based tools for obtaining and
discussing information. These tools include social networking sites (Facebook, MySpace,
LinkedIn), blogs and micro-blogs (Blogger, Twitter, Nixle), video and photograph sharing sites
(YouTube, Flickr, Flixster), and Wikis (shared encyclopedias). There are already numerous
social media sites operating, with more sites likely to launch in the near future. Below is a list of
some of the more popular sites available to date:
Facebook
My Space
Twitter
Nixle (govt micro-blog)
Plaxo (address book)
LinkedIn
YouTube
Wikipedia
Flickr (photos)
Flixster (video)
Last.FM (music)
XING (social network)
FriendFeed (website
sharing)
GovLoop (social network)
Social media is transforming the way people interact, work, and communicate. It has
impacted almost every aspect of how local governments interact with their citizens and the
broader world at large. The effect, and potential impact, on
Review this article from The Denver
local government operations is only now beginning to be
Channel (7 News) on the way social
understood as local governments consider if and how to use
networking sites are changing the way
these sites to benefit from the social media revolution.
disaster situations are handled.
Researchers: Social Networking Sites
Currently, local governments are using social media
Critical in Disaster Situations.
sites to provide information about upcoming events,
March 11, 2009.
neighborhood and traffic alerts, news announcements, and
government programs. They also use social media sites to notify citizens of emergencies and
provide immediate service information. Some use the sites to allow the open exchange of ideas
and comments on political issues. Citizens seem responsive to the new technology. Some
GMTC communities have hundreds of citizens following them on their official social media
pages. See Appendix A for a chart of social media site use by GMTC communities.
II. Evaluating Social Media Use in the Local Government Context
Different from a website, a social media site is generally an interactive tool where
citizens, elected officials and public employees can participate on an individual level. In
addition to communicating official messages from the local government, social media sites may
contain posts, often unrestricted, from individuals related to local government issues. The
interactive and immediate nature of the social media sites makes it a less formal method of
communication that the traditional website.
The use of social media sites is a policy decision. In addition to considering the legal
issues addressed later in this guide, the following questions should be considered by local
governments that already have a presence on a social media site, as well as those considering
using social media sites:
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Do we want this site to be an official voice of the local government?
If you plan on communicating local government business through a social media site, it is
important to consider it as an official voice of the local government because that is how it will be
perceived by the public. Alternatively, if you wish to have a site for your community where
official local government business is not being presented or communicated, but citizens (and not
elected officials and staff) have an opportunity to speak about local issues (a virtual soap box in
the middle of your virtual town center), then care should be taken to identify that the site is not
an official voice of the local government. Even still, the management of the site by the local
government connects it to the local government enough that certain precautions should be made
related to content control and employee/elected official use.
How should we use social media?
Local government staff and elected officials must consider how they wish to use their
social media sites. Use of social media sites could be limited by topic: council/board meetings,
emergencies, event postings, elections; by time: daily, monthly, bi-monthly; or by department:
parks and recreation, police, streets and maintenance. Maintaining and managing a social media
site (or multiple sites) takes staff time and energy. In considering how to use a site, you should
consider what need the site is filling in your community and what benefits will accrue from using
the site. Those factors should be weighed with or against the staff time, energy and social media
know-how required to manage the site(s). Representatives of different facets of the local
government’s management (legal, city/county manager, IT/CIO, individual departments with
jurisdiction over issues to be addressed on social media sites, etc.) should be involved in the
discussions and decisions relating to these issues.
What social media tools should we use?
It is impractical for many local governments to use all available social media tools
because of the staff time involved in proper management. Facebook, MySpace, and Twitter are
the most commonly used social media sites by local governments. See Appendix A. Depending
on your demographics and resources, you may find that the combination of Facebook and
YouTube meets your needs and your community’s expectations. Alternatively, your existing
government website combined with Twitter updates may satisfy your social media goals. New
social media tools are emerging, and it may be that in five years there will be an entirely new set
of the most popular sites. In addition to the goals and needs of the community, the number of
staff available to manage the sites may impact which sites and how many you use. Finally,
increased use of social media sites will involve increased legal issues for a community to
continually monitor and address (the various legal issues are addressed in more detail below).
Therefore, it is important for the local government to weigh the risks and benefits associated with
such use.
Should our social media site use be decentralized or centralized?
Decentralized use of a social media sites means that multiple people/departments have
access to the site’s control. An advantage of decentralized use is the department with the
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knowledge about the information is charged with communicating that information through the
social media site. However, decentralization means less control over the message and increased
challenges in management of the social media site(s). Centralized use means that one
person/department is charged with the management of social media sites. The control and site
management is increased, but delays may occur in disseminating the information because of the
internal steps one has to go through to get the information to the key person or department.
Whether you use the decentralized or centralized approach, it is important that there are one or
two people in the department (decentralized) or in the entire organization (centralized) which
have ultimate responsibility for the local government’s information place on the social media
site. Other factors to consider are staff time and ability and the existence of a communications
department or public information office, which could handle social media site management
issues.
How will social media help or improve our current communication methods?
Depending on broadband availability and adoption rate usage in your community, social
media sites may not be the best way to communicate with your community. Some citizens may
lack the knowledge and/or the resources to access social media sites. Local governments should
evaluate the effectiveness of their current communication tools and consider how social media
can compliment them now and in the future. A slow introduction of social media over a
specified time frame may be needed in order to increase the effectiveness of social media site
use. Alternatively, your citizens may be ready for social media sites right now and (impatiently)
waiting for their local government to get on board.
How will we manage the social media use and the data that is created?
As explained in more detail below, social media use triggers certain constitutional issues,
employment laws, and open records laws. Local governments must be prepared and have the
technology to manage and, if applicable, save the data that is created on a social media site in
order to treat it with the appropriate constitutional deference and comply with open records laws.
A local government’s ability or inability to do so may impact the decision on whether to use a
particular social media site.
III. First Amendment Issues - Employment
Similar to other employment management issues, local governments must consider their
employees’ use of social media sites from an employer’s perspective. Many local governments
allow their employees to post on the government’s social media site(s). Further, many local
governments do not restrict an employee’s ability to have a personal social media site where the
employee publicly acknowledges their employment with the local government and comments on
local issues.
An Employee’s Right to Free Speech:
Courts have yet to address employee speech on social media sites. However, we can rely
on the well established law from other employee free speech cases, which states that speech
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related to an employee’s job duties is not protected under the First Amendment. This applies to
oral or written speech. Written speech includes electronic speech. Therefore, speech may be
restricted by the local government in the form of policies addressing social media use and
discipline, including termination, for violating such policies.
Monitoring Employee’s Use of Social Media Sites:
According to a 2009 survey conducted by Deloitte LLP, 45% of employees visit social
networking sites between one and five times a week and 20% admit to visiting social networking
sites at work. During work hours and/or on the employer’s equipment, employers can monitor
and direct the activities of their employees. During off-work hours, employers can monitor and
direct the activities of employees as long as it is related to the function of the organization. For
example, if the employee “advertises” that he/she is the “X Department Director for Y City” on
his/her personal site, then the tie to the functioning of the organization is closer and the employer
may have more reason and authority to monitor the employee’s use of the social media site.
Suggested Employer Policies and Practices for the Organization:
First, many of the current policies a local government should already have in place can be
applied to employee activity related to social media site use. A local government should
integrate a social media site use policy into other applicable policies in the workplace, such as
harassment, discrimination, workplace conduct, and confidentiality. The policies should be
expanded so that an employee’s post, comment, or other use of a social media site is identified as
an activity that is subject to oversight pursuant to these policies. The key is that local
governments inform employees that employee comments and posts to social media sites must
conform to the organization’s long standing policies as stated in its personnel rules.
Second, the local government should implement a policy specifically addressing the local
government’s social media use and its expectations for its employees. This policy should notify
employees that social media site use conducted on governmental sites or from governmental
equipment will be monitored. In addition, social media site use will be monitored when the
employee openly advertises his/her position on a site and make remarks about organizational
events, policies, or functions. The policy should include provisions on:









The intended purpose and use of the social media sites by the local government
Definitions
Standards of conduct and baseline expectations
Restrictions of conduct
Organizational chart of permissible speakers and managers for the sites
Consequences for violations
Level of privacy staff has in conducting government or personal business on the local
government’s computer system or on its sites (the answer should be “none”)
How personal and business use of the local government’s site(s) will be monitored
Intention that the policy be applicable to social
media sites as they currently exist and may exist in You can also visit a clearinghouse of
social media policies at
the future.
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http://www.compliancebuilding.com/abou
t/publications/social-media-policies/
You should review and, if needed, revise your policies annually. Examples of policies are
attached as Appendix B.
Limiting who speaks for the local government:
It is very important that the local government identify employee(s) authorized to speak
for the organization and discourage or restrict other employees from doing so without permission
from the communications department, city/county manager, department head, or appropriate
official. If you are following the centralized model, up to two employees or one office should be
in charge of the social media site(s) for the entire organization. If you are following the
decentralized model, up to two employees in the department should be in charge of the social
media site for the entire department. All messages should go through this filter. Although a
decentralized approach offers the advantage of each department having control and access to
postings regarding its subject area, we believe that the better practice is the centralized approach
where very few people are in charge of the site for the entire organization. This way, the
organization has greater control over the consistency of the message communicated via the social
media site.
In addition, a local government should restrict employees from creating a social
networking presence for the organization unless they have obtained specific instruction or
permission from the office in charge of social networking sites or their supervisor.
Addressing misuse and disciplining employees:
Similar to other employee behavior, local governments should address mistakes and
misstatements made by employees on social media sites, and take appropriate action consistent
with their policies and procedures.
In addition, local governments should have
crisis plans in place for such misstatements, from
minor to major announcements. Such crisis plans
may be similar to plans currently in place for oral
or written misstatements by elected officials or
employees.
Consider the situation in Montgomery Township New
Jersey when a false Internet rumor spread over social
media sites that the Township’s animal shelter was
closing and all the animals would be euthanized. The
rumor resulted in the Township needing to quickly
mobilize to address the fast-spreading rumor.
Codes of Conduct for Volunteers and Elected Officials
A local government may consider adopting a code of conduct (or amending its existing
code of conduct) that addresses the social media site use of its volunteers and elected officials.
Similar to the employee policy, the code or conduct would address expectations for use and
explain any consequences for violating those expectations. An existing code of conduct may
only need to be modified slightly to put the volunteer/elected official on notice that social media
site use will fall under the purview of the code of conduct. (See below for the section on Special
Considerations for Elected Officials).
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IV. First Amendment Issues – Free Speech from the Public Perspective
The application of free speech principles to social media use by the general public is an
emerging area of the law. Presumably, courts will rely on traditional free speech case law,
including law derived from cases involving other forms of electronic communications, in
establishing the application of free speech principals to social media site use.
Type of forum:
There are two types of forums in the free speech context: public forums and nonpublic/private forums.
Public forums include traditional or designated forums, and limited forums. A traditional
or designated forum is similar to a local park. It is a place established and recognized as a place
for free speech. It is also a space that has become a place for free speech over the years, such as
the front steps of the town hall. In general, the government does not restrict access to traditional
or designated public forums. A limited forum is similar to a classroom. It is a place where
speech is allowed, but the topics can be limited by the controlling government entity.
A non-public or private forum is, in essence, closed to free speech. Common examples
include a jail or a military base where free speech is restricted.
Limiting Public Speech on a Social Media Site:
Initially, a local government can decide what type of forum it wants its social media
sites to be: a non-public forum or a public forum. As mentioned above, there are no court cases
establishing the law on social networking sites and the type of forum. Factors to consider
include:
 Whether the site is generally available to a class of speakers or whether users
must gain permission.
 The level of permission or exclusion the organization exercises with regard to the
site.
 Whether exclusion of certain content is properly designed to limit the speech on
the site to that which is compatible with the site’s purpose.
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With regard to the level of permission, the organization must consider the type of access
it allows. In an open public forum, the organization does not restrict access at all and allows
open access to anyone.
In a designated public forum, the organization has restrictions on who can and who
cannot post comments or information to the site AND the restrictions are tied to the site’s
purpose. Restrictions can include access limitations, such as restricted access to citizens and
certain advertisers. If the restrictions and exclusions are not tied to the site’s purpose, then the
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A local government may not be able to control the type of forum for YouTube, whose content is decided by
YouTube. However, a local government may be able to control the content of its own video sharing site, if it
decided to create one.
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restrictions on speech will be deemed unconstitutional. Any restrictions will be examined very
closely to determine whether they are adequately related to the purpose of the site.
In a closed non-public forum, the organization establishes restrictions on who can and
who cannot post comments or information to this site that are stricter than those in a designated
public forum and generally do not include access to people not in the organization. The only
people who can post are members of the organization assigned to communicate via the social
networking site. Further, only “government communication” is allowed. The site, in general, is
not open to public posts or comments. The restrictions (both permission and exclusion) must
still be tied to the site’s purpose, and will be permissible as long as they are reasonable and are
not user viewpoint restrictions. If the restrictions and exclusions are not tied to the site’s
purpose, then the restrictions on speech will be deemed unconstitutional. As with the designated
public forum, any restrictions will be examined very closely.
Commercial Speech
Commercial speech is speech made with the intent of making a profit, such as
advertisements or sale pitches. The First Amendment provides little protection to commercial
speech and, as a result, it may be regulated more than other speech. False, deceptive, or
misleading commercial speech may be banned outright. Other restrictions are permissible as
long as the restriction advances a government interest and the restriction is no more extensive
than necessary to advance that interest.
Suggested Policies and Procedures
Regardless of whether the site is completely open to comments or limited by certain
restrictions, the local government can still require public comments to be respectful and not
offensive, degrading, or obscene. Similar policies can be found in those addressing public
comment periods during public meetings.
If the site is a designated public forum, the organization can also require that comments
be relevant to the purpose of the social networking site. For example, the recreation center can
have a policy that it will remove posts not relevant to recreation center’s operations. Any
restriction must be drafted specifically to put users on notice of topics which are acceptable for
the site. The restrictions need to be applied equally to all comments and posts.
Restrictions for any site should be viewpoint neutral, meaning that both proponents and
opponents on a particular topic would be restricted from posting if the topic was not related to
the site’s purpose. Relevant comments and posts that are critical of the organization, its policies,
procedures, or personnel should not be removed just because they are critical. Policies should
include provisions on:




The purpose and mission of the pages
Definitions and scope of policy
Disclaimer related to comments and disclaimers related to links
Links and permissible attachments
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

Editorial policy explaining the local government’s restrictions related to
o Access
o Content
o Commercial speech
o Political speech
Explanation of open records implications (that all posts are public records)
Examples of policies are attached as Appendix C.
V. Colorado Open Records Act (CORA)
CORA states that “[a]ll public records are open for inspection by any person at
reasonable times.” Public records include all writings made, maintained, or kept for use in the
exercise of functions required or authorized by law or administrative rule. The inquiry of
whether a record falls under CORA must be content driven.
Writings include “other documentary materials, regardless of physical form or
characteristic.” The statute specifically includes digitally stored data. The custodian is the
officer or employee who is responsible for the keeping of public records, regardless of whether
such records are in his or her actual custody or control. A social networking site manager can be
a custodian for social networking records.
When running an organization-sponsored social
networking site (eg: the city’s Facebook page), be prepared to
treat the comments, posts, pictures, and lists of individuals
connected to the site as open records. Further, you should treat
each post, comment, friend request, etc. as a separate record.
Personal sites kept by employees or even elected officials of the
organization are not subject to CORA unless the writings on the
site are made, maintained, or kept for the use in the exercise of
the functions of the organization. You should periodically save
an electronic copy of the page to a server and archive the
comments and posts sent to the site. One way to do this is to set
up a forwarding system whereby posts, friend requests,
notifications of people joining the site, and comments are sent to
an organizational email account. These emails can be archived
for the purpose of record retention. The responsibility to retain
these records includes saving any comments and posts that are
subsequently removed from the site.
In a discussion with a representative of
the state archivist’s office, we learned
that the State of Colorado has not yet
established best practices for how to
archive social media site information.
The representative suggests that local
governments keep the records created on
social media sites “the best way you
can.” The archivist’s office met with
federal officials for guidance and will be
meeting with industry representatives in
June. If a policy or best practices are
created, it will be shared with the
municipal and county clerks.
Read the State Archivist’s 2003
Recommended Storage and Handling
Guidelines for the Maintenance of
Electronic Records of Long-Term or
Enduring Value.
When an elected official has a social networking site that he/she utilizes in the exercise of
the function of their position, some or all of the posts and comments to the site may be subject to
the CORA. Procedures similar to those stated above should be followed. Further, the elected
official must be able to respond to a records request in a timely and efficient manner as required
by statute.
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Similar to elected officials, when posts and comments to an employee’s social
networking site make it an avenue for communication from the organization, then such posts and
comments are likely considered public records and must be retained. Procedures similar to those
stated above should be followed. As mentioned in the employee-free speech section above, the
employee should be advised that their site will be monitored by the organization and that
comments and posts, to the extent they are related to the function of the organization, may be
retained by the organization.
VI. Colorado Open Meetings Laws
A “meeting” means “[a]ny kind of gathering, convened to discuss public business, in
person, by telephone, electronically, or by other means of communication.” C.R.S. §24-6402(1)(b). There must be a link between the meeting and the policy-making powers of the
organization holding the meeting. Therefore, a meeting occurs when discussion involves a rule,
regulation, ordinance, policy or formal action. Merely discussing matters of public importance
does not necessarily mean it’s a “meeting.” A quorum, or three or more members of a local
public body (whichever is fewer) discussing public business or taking formal action constitutes a
meeting that must be open to the public.
Meetings under Colorado’s open meetings laws require “full and timely notice” of the
meeting. This typically means 24 hours notice of the meeting posted in a designated public
place. The local government should keep minutes of the meeting when a proposed policy,
position, resolution, rule, regulation, or formal action occurs. If there is no formal action, no
minutes are required. Failure to adhere by the open meetings laws can result in any action taken
being void. Further, the complaining citizen is awarded costs and attorneys’ fees in a suit where
the citizen prevails.
As applied to social media sites, a quorum, or three or more local governmental officials
commenting on a proposed ordinance or annexation or budget change may likely be considered a
meeting. If a local government wanted to have an online discussion of a specific issue, it could
“notice” the meeting. If the organization wants to avoid any chance of a meeting taking place on
a social networking site, it should restrict elected officials from commenting on the social
networking sites when the topics are addressed in a manner that can be considered discussion of
public business. Elected officials’ use should be limited to first-run comments and
announcements, and replies specifically in response to the citizen’s comments. Special care
should be taken to avoid cross-comments between elected officials and avoid any official action
taken on a matter (or even the appearance of any official action). For quasi-judicial matters,
elected officials should respond to inquiries on social media sites the same as they would to a
telephone call or email message – inform the person contacting them that the matter cannot be
discussed outside of the public hearing.
If the organization would like to host an e-meeting through its social networking site, it
should treat the meeting as any meeting held in person, by providing sufficient notice to the
public that the meeting will occur. Further, the organization should be prepared to keep minutes
of the meeting, which should include all of the comments and posts.
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VII.
Copyright
State entities are immune from a suit for copyright infringement under the 11th
Amendment. Cities and counties do not enjoy 11th Amendment immunity. In Colorado,
governmental entities, including local governments, have immunity under the Colorado
Governmental Immunity Act. The Act establishes governmental immunity for most legal actions
against a public entity and protects against lawsuits for copyright infringement. Despite
immunity, governmental entities should still be aware of copyright restrictions to avoid legal
action that tie up the organization and cause defense costs to be incurred, even if the action may
eventually be dismissed.
In order to address copyright issues, local governments that post links should have those
linked websites open in external pages, which are separate and distinct from the organizational
websites. Any sites, including external media sites, should include a disclaimer addressing the
content of sites that are linked from the organization’s site, specifically disclaiming liability for
any illegal or infringing content. The organization should also adopt policies addressing
copyright issues for employees and those responsible for posting information on the social
networking site. These would be similar to website policies on the same issue.
Sample disclaimer language:
You are now leaving an official [local government’s name] website. The [local
government’s name] is not responsible for the content, nor endorses or supports any
advertising that may be contained on this site.
You are now leaving the [local government’s name] website. You may find value in
reading the contents of this linked website which, to the best of our knowledge and belief,
is of legitimate interest. However, the [local government’s name] has no control over the
content nor the ownership of the domain name and we do not endorse, control, or take
responsibility for this organization, its views, or the accuracy of the information
contained on the link you have chosen.
VIII. Americans with Disabilities Act
The ADA, as amended, requires that disabled individuals be given an equal opportunity
to benefit from the programs, services, and activities offered by the
See the Department of
government. The Department of Justice has taken the position that
Justice’s 2003 guidance
ADA accessibility requirements apply to web sites, telephone access
on Accessibility of State
systems,
and other “communication modalities of public
and Local Government
accommodations.”
Websites to People with
Disabilities.
The organization must take steps to ensure the site is
accessible. Site design and layout must be in a manner that is easily understood and allows for
easy enlargement. The site should not contain problematic links and graphics. Further, the
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organization should provide a method for a person with a disability to request the site
information directly from the organization in another format.
IX. Special Considerations for Elected Officials
Elected officials should consider their use of official, personal, and campaign sites.
Campaign activities should be kept separate from any site a person maintains in his or her elected
official capacity. Personal sites and campaign sites may provide a link to the organization’s
official site, but should take care to note that the organization’s site does not endorse any
candidate or any individual elected official’s position. However, elected officials can be open
about the positions they hold for the organization. Elected officials should work with the
person/office designated to handle social networking site issues in order to avoid missteps and
misstatements (similar to working with a communications team before being interviewed by the
media). The elected official should be aware of the possible implications of CORA and Open
Meetings Law (addressed above). Local government organizations should integrate social
networking site policies into their current policies, practices, and codes for elected officials,
specifically those related to communication with the media, ethics, and confidential information.
Copyright © 2010. Great Metro Telecommunication Consortium and Kissinger & Fellman, P.C. All rights reserved.
No reproduction without prior permission.
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