What is a “bona fide request” to replace a telephone in a workplace non-common area?
The person making the request must be an individual present in the normal course of the establishment’s business, legitimately on the premises as an employee or invitee of the establishment. The FCC’s “rebuttable presumption” does not give someone a right of entry onto the premises of an employer solely for the purpose of investigating and identifying whether an establishment’s telephones are HAC.