Featured

Leading companies on the cutting edge of developing and delivering Internet voice communications technologies, today launched a new coalition to advance policies that enable consumers and businesses throughout Europe to enjoy the full promise and potential of Internet communications. This new coalition of companies, from Europe and around the globe, believes that with the right public policies, Internet-enabled communications, such as Voice over Internet Protocol (VoIP), can increase competition, provide a platform for innovation, drive broadband deployment, and enable economic growth.

The recent release of formal Proposals by the European Commission to amend the existing regulatory framework for communications marks the start of a wide ranging review by the Council of Ministers and European Parliament. As we enter this era of rapid and potentially far reaching regulatory change, industry leaders have come together under one roof to create an authoritative voice for the Internet-enabled communications industry.

The Voice on the Net (VON) Coalition Europe, made up of leading Internet communications and technology companies from Europe and around the world, will advocate for Internet voice innovation and the policy framework that enables it. The coalition will work to educate, inform and promote responsible government policies that enable innovation and the many benefits that Internet voice innovations can deliver.

Founding members of the VON Coalition Europe include such industry leaders as: iBasis, Intel, Google, Microsoft, Rebtel, Skype, and Voxbone.

“Internet-enabled communications are an entirely new genre of communications products, services, and applications and a new frontier in communications for individuals and businesses alike. In order to unleash their vast benefits, policymakers need to embrace forward-thinking policy approaches,” said Stephen Collins of Skype.

“If we automatically subject this new technology to legacy telephone regulation, consumers and business users could miss out on the new services, increased choices, better prices and improved features that VoIP for example, can deliver,” said Collins.

“To maximize the consumer benefit from VoIP and other exciting IP-enabled technologies, policymakers should embrace a light-handed regulatory approach that facilitates competition, innovation, and rapid deployment of IP networks,” said Peter Pitsch, Executive Director, Communications Policy, at Intel.

The group recognizes that there are important social policy obligations like emergency access that have yet to be fulfilled by some types of VoIP services, such as those that substitute for the traditional telephone in your home. The coalition hopes to educate policymakers about the vast progress that has been made, and the potential for Internet-enabled communications to further extend the reach and capabilities in an emergency. However, the Coalition is concerned, for example, that premature application of 112 rules to web sites, click-to-dial services, 1-way PSTN-out interconnected voice services, and other VoIP services that are not a replacement for traditional home/business phone services could actually harm public safety, stifle innovations critical to people with disabilities, stall competition, and limit access to innovative and evolving communication options where there is no expectation of placing a 112 call.

With VoIP, voice is now becoming just another application riding on the Internet or on data networks - and is being integrated into web sites, social networking communities, instant messaging software, blogs, mapping programs, voice recognition applications, and is likely to be used tomorrow in ways we can’t even imagine today.

“VoIP and other Internet-enabled communications technologies are transformative technologies,” said Kevin Minsky, Policy Counsel, at Microsoft. “Enlightened policy approaches will enable VoIP and other Internet-enabled devices, applications, and services to transform communications, boost business productivity, and empower consumers with more choices and capabilities never before possible.”

While promoting positive policy outcomes, the coalition said it will also work to resist the creation of regulatory barriers that could prevent consumers from enjoying the vast benefits and innovations that VoIP and Internet-enabled communications have only begun to deliver.

Hjalmar Winbladh, Rebtel co-founder and CEO said, “Reflexively applying legacy telephone regulations to new, innovative Internet communication services, applications, and devices presents the greatest potential roadblock for extending the benefits of these new and exciting technologies to more consumers.”

Outreach Planned to European Policymakers

Regulatory changes are afoot that could fundamentally reshape the European communications landscape. By launching a new European focused effort, the coalition hopes to educate policymakers throughout Europe about forward thinking policy approaches that can enable families and friends to communicate in ways never before possible, integrate voice into a variety of new web based applications, and boost business productivity by as much as 15%.1

Rodrigue Ullens de Schooten, CEO Voxbone, said “the Coalition will help educate, inform and promote forward-thinking policies that do not stifle innovations with heavy handed regulation that could potentially delay the vast benefits that VoIP can deliver.”

“We are going to engage in direct outreach to policymakers throughout Europe; work with public safety and standards bodies on advancing new policy solutions; and participate in proceedings and debates throughout the EU,” Erik De Herdt, General Counsel Voxbone, noted.

The European Commission’s proposed framework revisions signal the start of a critical phase that could determine how and when consumers benefit from the lower prices, new services, and advanced communication features that VoIP and other Internet-enabled communications can deliver. Such EC policies, if properly implemented, have the potential to unleash these services in Europe and position member countries to take a leading role of deployment of such services to consumers and businesses. To help work toward this goal, the VoIP, Internet, and information technology communities must speak with a unified voice, behind a common set of principles, and work with the EC and member states to make sure that unfounded concerns do not prevent consumers and businesses from enjoying the benefits of innovative Internet voice applications, services, and devices.

Similarly forward thinking Internet-based communication providers interested in joining the VON Coalition Europe should e-mail stephen.collins@skype.net.

{ 0 comments }

The Federal Communications Commission today addressed petitions for forbearance filed by the Verizon Telephone Companies, which sought certain forbearance relief in the Boston, New York, Philadelphia, Pittsburgh, Providence and Virginia Beach Metropolitan Statistical Areas, or MSAs.

FCC Statement: The Commission found that the current evidence of competition does not satisfy the section 10 forbearance standard with respect to any of the forbearance Verizon requests.  Accordingly, the Commission denied the requested relief in all six MSAs.

More details of this ruling:

MO&O: Word | Acrobat
News Release (12/4/07): Word | Acrobat
Martin Statement: Word | Acrobat
Copps Statement: Word | Acrobat
Adelstein Statement: Word | Acrobat

XO Communications and COVAD have both released press statements supporting the FCC’s ruling in this:

The following comments are attributable to Heather Burnett Gold, senior vice president - external affairs, at XO Communications.

“XO Communications praises Chairman Martin and each of the Commissioners for a unanimous decision denying Verizon’s petition for forbearance, and thanks Congress for its pro-consumer support of competition throughout this proceeding.”

“Today the FCC delivered a solid victory for competition and for millions of consumers. Strong bipartisan leadership from the House and Senate Commerce Committees, as well as efforts from individual Representatives and Senators, played a vital role - demonstrating the public interest in maintaining a vibrant competitive market that delivers choice, innovation and lower prices to business and residential customers.”

“The FCC made the right decision based on a thorough analysis of the evidence. This action helps ensure that competition will continue to thrive, and that markets where Verizon sought forbearance will not fall under the unchallenged rule of the single provider.”

And the statement from COVAD:

The following quote may be attributed to Charles Hoffman, Covad president and chief executive officer:
“We are very pleased that the FCC has affirmed its longstanding policies in support of facilities-based competition by companies like Covad. This decision continues the regulatory stability that has allowed Covad to invest in new and innovative services for businesses and consumers across the country.” “In particular, Covad commends Chairman Martin and the commissioners for reviewing the facts on the ground and making the right choice. We also recognize the dedicated members of Congress who stood up in favor of competition throughout this process. This decision protects competitive choice, affordable rates, and product innovation for businesses and consumers from Virginia Beach to Boston.”
In addition, the FCC voted unanimously to begin a proceeding to establish rules and procedures to govern the consideration of forbearance petitions going forward. “With many in Congress and at the FCC expressing concerns about the procedural shortcomings of forbearance, I’m pleased that the Commission has taken this
important step to establish rules of the road for future petitions,” noted Hoffman. “I’m hopeful the Commission will move quickly to finalize this rulemaking.”

{ 0 comments }

This article has been written by Law Offices of Thomas K. Crowe, P.C. Please contact them if you have any questions about the article or need their services.

Thomas K. Crowe, Principal “firm@tkcrowe.com”
Cheng Yi Liu, Staff Attorney
Law Offices of Thomas K. Crowe, P.C.
1250 24th Street, N.W.
Suite 300
Washington, D.C. 20037
(202) 263-3640 (voice)
(202) 263-3641 (fax)
www.tkcrowe.com

AW OFFICES OF THOMAS K. CROWE, P.C.

LEGAL ALERT

Clients and Interested Parties:

In its Report and Order, Declaratory Ruling, and Order on Remand (“Order”) adopted on October 31, 2007, the Federal Communications Commission (“FCC” or “Commission”) extended certain Local Number Portability (“LNP”) obligations to interconnected Voice over Internet Protocol (“VoIP”) providers.  Specifically, the Commission’s Order requires that interconnected VoIP providers ensure consumers are able port telephone numbers to and from such VoIP providers, and that such providers contribute to shared numbering administration costs.  The new rules underscore the FCC’s objective of enhancing competition between interconnected VoIP providers and providers utilizing other technologies, and further illustrate the FCC’s continuing piecemeal regulation of interconnected VoIP services.  The LNP obligations applicable to interconnected VoIP providers will become effective thirty (30) days after the publication of the FCC’s Order in the Federal Register.

In the Order, the Commission also decided that all carriers obligated to provide LNP, including interconnected VoIP providers, may not obstruct or delay the porting process by demanding information beyond the minimum needed to validate a requested port.  The FCC concluded that, for simple ports, validation information should be limited to only four alphanumeric fields.  In a Notice of Proposed Rulemaking (“NPRM”) accompanying the Order, the FCC sought comments on the possibility of imposing further LNP numbering obligations on interconnected VoIP providers and whether the FCC should adopt further rules governing the porting process.  The NPRM also tentatively concluded that a 48-hour porting interval should be adopted for certain types of simple port requests.  

LNP Obligations for Interconnected VoIP Providers 

In its Order, the FCC extended LNP obligations and numbering administration support obligations to interconnected VoIP providers.  Specifically, the Order states that an end-user customer retains the right to port-in a number to an interconnected VoIP service or to port-out the number from an interconnected VoIP service.  Since most interconnected VoIP providers will make numbers available to their customers through arrangements with other carriers (i.e., numbering partners), both the interconnected VoIP provider and its numbering partner are responsible for facilitating a customer’s request to port a number.  Thus, an interconnected VoIP provider has an affirmative legal obligation to take all steps necessary to initiate or allow the porting of a number, either through itself or through its numbering partner, on behalf of the interconnected VoIP customer (i.e., the end-user), without unreasonable delay or procedures that would deny porting of the number.

However, the FCC’s porting obligations vary depending on the type of provider (wireline or wireless) to or from which a number is to be ported.  Consequently, the porting obligations (including required porting intervals) of an interconnected VoIP provider, which obtain telephone numbers through a numbering partner, will also depend on whether its numbering partner is a wireline or wireless provider.  Wireline providers are only required to port numbers from other wireline providers in the same “rate center” (i.e., the geographic area that is used to determine whether a call is local or toll).  Porting of numbers from wireless to wireless is not limited to a wireless provider’s rate center.  For intermodal porting (i.e., porting between wireless and wireline providers), a wireline carrier is required to port a customer’s number to a wireless carrier if that wireless carrier’s coverage area overlaps with the geographic location of the customer’s wireline rate center, and wireless carriers must port a customer’s number to wireline carrier’s within the number’s originating rate center.  

The Commission also noted that interconnected VoIP providers and their numbering partners may not enter into agreements that would unreasonably prohibit or delay an end-user from porting between interconnected VoIP providers, or to or from a wireline or wireless provider.  Interconnected VoIP providers are also prohibited from contracting with a customer in a way which prevents or hinders the rights of the customer to port its number.  The FCC noted that to the extent that interconnected VoIP providers had existing contractual provisions that had the effect of unreasonably delaying or denying porting, such provisions would not supersede or affect the porting obligations outlined in the Order.  The Commission expects interconnected VoIP providers to fully inform their customers about limitations on porting between providers, especially limitations that result from the nature and use of non-geographic numbers (i.e., numbers which may be outside the rate center of a customer) by certain interconnected VoIP providers. 

LNP Contribution Obligations

The Order states that since interconnected VoIP providers benefited from LNP, they should also contribute to meet its shared costs.  Since it would be potentially costly and burdensome for interconnected VoIP providers to determine the portion of traffic and revenue attributable to each regional Local Number Portability Administration (“LNPA”),  the FCC has decided to allow interconnected VoIP providers to allocate their end-user revenues among these regions based on the percentage of subscribers the provider serves in a particular region.  Further, interconnected VoIP providers are allowed to use their billing databases to identify subscriber locations.

To implement the contribution of interconnected VoIP providers to LNP costs, the Commission will utilize annual FCC Forms 499-A filed by interconnected VoIP providers.  Interconnected VoIP providers are already required, by previous Commission orders, to file the Form 499-A to assess required contributions for the Universal Service Fund, Telecommunications Relay Service fund, and FCC regulatory fees.  In their 499-A filings for April 1, 2008, interconnected VoIP providers should include historical revenue information for the 2007 year, including all information necessary to allocate revenues across the seven LNPA regions.  After submitting their 499-A forms, interconnected VoIP providers will receive an invoice from the appropriate fund administrators for their contribution towards the shared costs of the respective support mechanism

Simple Port Validation Fields

The FCC considers simple ports to be ports that: (1) do not involve unbundled network elements; (2) involve an account only for a single line; (3) do not include complex switch translations; and (4) do not include a reseller.  To facilitate the porting process for simple ports, the FCC concluded that validation for simple ports  involving wireline-to-wireline, wireless-to-wireless, and intermodal ports should not be based on more than four customer fields: (1) the 10-digit telephone number; (2) customer account number; (3) 5 digit-zip code; and (4) pass code, if applicable.  For all porting, the Commission clarified that the porting-out provider may not require more information from the porting-in provider than is reasonable to validate the port request and accomplish the port.  While carriers may require additional information if it is required to accomplish the port, that does not encompass information that is merely required for the carrier to settle a customer’s account.  The Commission stated that a 90 day period from the release of its ruling was sufficient for carriers obligated to provide LNP to comply with its streamlined simple porting validation requirements. Therefore, all carriers with LNP obligations should be prepared to comply with this new rule for simple port validation by February 8, 2008.  

FCC Seeks Comments 

In a related NPRM accompanying the Order, the Commission sought public comment on whether additional numbering requirements (such as N11 code assignments in addition to the 911 and 711 requirements already applicable to interconnected VoIP) should be applied to interconnected VoIP providers in addition to the new LNP rules adopted in the Order.  The FCC also sought comment on general LNP process concerns, and on whether to adopt further rules regarding the LNP validation process and porting intervals, including comments on: (1) whether the Commission should issue further guidelines to ensure the efficiency and effectiveness of the porting process; (2) how the simple port validation fields will affect the validation process; (3) additional considerations for the simple port validation process; and (4)  whether it should adopt specific rules requiring carriers to identify all errors possible in a request for porting and describe the basis for rejection when rejecting a port request.  Finally, the Commission tentatively concluded that wireline-to-wireline and intermodal simple port requests should have a porting interval of 48-hours.  

Please do not hesitate to contact us should you have any questions about these new LNP rules.
——————————————————————————–

Cheng Yi Liu, Staff Attorney “firm@tkcrowe.com ”
Law Offices of Thomas K. Crowe, P.C.
1250 24th Street, N.W.
Suite 300
Washington, D.C. 20037

(202) 263-3640 (voice)
(202) 263-3641 (fax)
www.tkcrowe.com

{ 0 comments }

In a presentation today during the Third International Conference on Collaborative Computing, scientists from Avaya Labs will demonstrate how “tagging” conversations can help businesses search and retrieve interactions and access information they need to operate more effectively.

Now underway in White Plains, N.Y., the Collaborative Computing conference is jointly sponsored by the IEEE Computer Society, Create-Net and the International Communication Sciences and Technology Association.

Avaya Labs scientist Doree Seligmann, director, Collaborative Applications Research, a featured speaker at the conference, and Avaya Labs research scientists Ajita John and Shreeharsh Kelkar, will present a paper and video demonstration on the business benefits of sophisticated new algorithms they developed to “tag” key information and make voice calls searchable.

“Tagging” - which is also called “social bookmarking” or “collaborative tagging” - is an increasingly popular way to locate, classify, rank and share Internet resources through the use of shared lists of user-created Internet bookmarks. Users store lists of personally interesting Internet resources, and typically make these lists publicly accessible. They also classify their resources by the use of informally assigned, user-defined keywords or tags.

“Conversations provide a rich source of information that can be tapped to help businesses operate more efficiently and effectively,” said Seligmann. “By using sophisticated new algorithms and models that ‘reason’ about the ‘who, what, when, where and why’ of communications, we can capture and mine conversations, just as we do by searching email and other electronic documents.”

Seligmann says tagging holds the potential to help businesses readily identify subject-matter experts who can serve customers and support strategic initiatives. For example, a field technician could find individuals with the expertise needed to troubleshoot a customer problem. A marketing director could identify those familiar with an emerging market trend. Human Resources executives could determine existing pockets of company expertise, which in turn could drive staffing and training investments.

“By storing, searching and retrieving information from conversations, which are the most important resources for collaborative work of any kind, we can mine a previously untapped resource and drive intelligent communications capabilities throughout a company’s operations,” Seligmann said.

Seligmann will show examples of a pilot visualization tool the team designed to help employees archive, tag, share, search, and retrieve conversations to create a knowledge repository for the enterprise.

Since joining Avaya, Seligmann has filed more than 50 patents, most involving technologies designed to help people communicate more efficiently and effectively and to have a higher-quality experience while doing so. In addition to “tagging,” she and her team have developed a number of breakthrough collaborative technologies – including a “personalized customer relationship management” application that tells how, when and how often a caller has tried to reach someone and pops up pertinent notes for the caller to use during the conversation.

About Avaya
Avaya delivers Intelligent Communications solutions that help companies transform their businesses to achieve marketplace advantage. More than 1 million businesses worldwide, including more than 90 percent of the FORTUNE 500®, use Avaya solutions for IP Telephony, Unified Communications, Contact Centers and Communications-Enabled Business Processes. Avaya Global Services provides comprehensive service and support for companies, small to large. For more information visit the Avaya Web site: http://www.avaya.com.

{ 0 comments }