In American Telephone & Telegraph Co. v. Central Office Telephone, Inc., 524 U.S. 214 (1998), the Supreme Court articulated that the filed rate doctrine binds telecommunications carriers and customers to the rates and tariffs filed pursuant to section 203, and preempts any state law claim that directly or indirectly, either in the form of damages, restitution or otherwise, has the effect of imposing any rate for services other than that reflected in the filed tariff (id. at 223, 229). Thus, the rate filed by the carrier was to be enforced, irrespective of whether the carrier misrepresented rates to a customer, or if the customer was unaware of the carrier's rates (id. at 223). The Court noted that although the rule is "undeniably strict and it obviously may work hardship in some cases . . . it embodies the policy which has been adopted by Congress in the regulation of interstate commerce to prevent unjust discrimination," which is violated "when similarly situated customers pay different rates for the same services" (id. at 222-223).