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App Cram possible?

On my new phone/account, I got a charge on my ATT bill with the following details.


Content Provider: c_jamdat
Product Name: EA Games:This is a test offer created for testing
Type: C:GA
Payment Method: Bill to Phone
Price: $4.99

With the online dispute process, my dispute got approved immediately.

Is it possible for developers to cram (charge w/o authorization)?
 
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