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I. INTRODUCTION. II. MOBILE THIRD-PARTY BILLING. A. Uses of Mobile Carrier Billing. B. Types of Carrier Billing Arrangements. C. Market Participants. III. THE MOBILE CRAMMING PROBLEM. A. What is Cramming?. 1. FTC Actions Addressing Mobile Cramming. 2. Other Federal and State Initiatives Addressing Mobile Cramming. B. Prevalence of Mobile Cramming. 1. Carrier Refund Rates. 2. Complaint Information. 3. Other Efforts to Estimate the Extent of Cramming. 4. Unreported Consumer Injury. C. International Views. IV. STRATEGIES TO REDUCE MOBILE CRAMMING. A. Allowing Consumers to Avoid Third-Party Charges to Mobile Accounts . 1. Current Industry Practices. 2. FTC Staff Recommendations. B. Strategies to Detect and Prevent Mobile Cramming. 1. Avoiding Deceptive Practices That Lead to Unauthorized Mobile Charges. a. Industry Practices. b. Staff Recommendations. 2. Obtaining Consumers’ Express, Informed Consent. a. Current Industry Practices. b. Staff Recommendations. C. Adequate Disclosures of Third-Party Charges. 1. Current Industry Practices. 2. Staff Recommendations. D. Consumer Dispute Protections and Refunds. 1. Current Industry Practices. 2. Staff Recommendations. CONCLUSION.