RE: [Enum] Subject: I-DACTION:draft-ranalli-peek-walter-enum-t1roles-00.txt

["Judith Oppenheimer" <[e-mail]>]

> That number has been delegated to that "subscriber" under the
> normal terms
> and conditions of 800 service ..so the "controlling party" is
> known to the
> 800 SMS and can be verified.  The key to ENUM authority is that this
> verification can be successfully accomplished and that proper
> authorization
> can be delegated from the T1 to the T2 entity that actually holds the
> Resource Records that provision real service.

The subscriber -- the "controlling party" -- is *not* known to the SMS800.

In most instances this information is considered to be proprietary to the
RespOrg or RespOrg/TSP and not housed in any external data base.

> The key to ENUM authority is that this
> verification can be successfully accomplished and that proper
> authorization
> can be delegated

Most RespOrg/carriers (versus RespOrgs that aren't TSP's) simply don’t know
who a fair portion of their subscribers are. With operational origins in
pre-portability provisioning, RespOrg/carrier records are maintained based
on who pays the bill -- not who the authorized subscriber is.

For example, subscriber identity is not included in RespOrg/carrier
reseller-sold records, because RespOrg/carriers consider the reseller to be
the customer, even though FCC regulations stipulate that the end user is
the legally-recognized subscriber of record.

In April '98 the FCC order the RespOrgs to identify and notify the toll
free customers affected by the right-of-first-refusal process for 888
replications -- ** a simple verification process. **   Only 370,000 toll
free numbers were involved.

In December '98 the FCC published that only 34 of 179 RespOrgs complied
fully, and 52 did not comply at all.

(AT&T had a 36.1% compliance rate; MCI, 40%, and Sprint, 35.1%.)

The FCC charged the carriers were "warehousing set-aside 888 numbers or the
corresponding 800 numbers, or ... falsely indicating ... identified
subscribers for those numbers."  These suspicions had some legitimacy, but
I can tell you firsthand that at SNAC meetings throughout that period, all
I heard from harried carrier execs, especially from the largest carriers,
was "we just don't know who the subscribers are."

They begged the FCC for more time to find their subscribers - and were
turned down, resulting in a full two thirds of the original 370,000
set-aside 888 numbers, ultimately going unclaimed.  (see p.s. below)

So the "key to ENUM authority" may not so easily fit the U.S. 800 master
locks.

J

P.S.  On April 5, 1999 the unclaimed set-aside 888 toll free numbers were
released to spare (available) status, by order of the FCC.  In its March 23
press statement announcing the release, the FCC advised the public that
there would be 140,000 vanity 888 numbers made available to the public, on
a first come first serve basis. Anna Gomez of the FCC's Common Carrier
Bureau, advised that the 140,000 figure was supplied to the agency by
Database Services Management Inc. (DSMI.)

But the actual amount of 888 numbers released on April 5 was over twice the
published figure: 289,943, per the April 12, 1999 SMS/800 weekly report,
which is printed by DSMI. A DSMI executive also confirmed that the 289,943
figure was accurate, noting that a full two thirds of the original 370,000
set-aside 888 numbers, ultimately went unclaimed and were released on April
5.

Asked by a different reporter to explain the discrepancy between the two
figures, another DSMI representative maintained that there was none, and
that only 140,000 numbers were released.

Judith Oppenheimer, 212 684-7210, 1 800 The Expert
Publisher, http://www.ICBTollFreeNews.com
President, http://www.1800TheExpert.com
FREE 800/Domain Classifieds, http://ICBclassifieds.com
Domain Name & 800 News, Intelligence, Analysis


> -----Original Message-----
> From: [e-mail] [mailto:[e-mail]]On Behalf Of
> Richard Shockey
> Sent: Monday, November 27, 2000 9:44 PM
> To: Judith Oppenheimer
> Cc: [e-mail]
> Subject: RE: [Enum] Subject:
> I-DACTION:draft-ranalli-peek-walter-enum-t1roles-00.txt
>
>
> At 05:56 PM 11/27/2000 -0500, Judith Oppenheimer wrote:
> >I do not see where this draft anticipates that the "service
> provider" for a
> >toll free number may not be a TSP, but rather a so-called
> "RespOrg" (stands
> >for Responsible Organization.)  For that matter, the calls
> may not resolve
> >to the end user subscriber either.
> >
> >One or more TSPs (programmed to be used at varying times of day for
> >cheapest rates, for example) can simply be used as a
> provisioning tool,
> >sending calls to one or multiple locations, none of which are the
> >controlling party of the toll free number.
> >
> >Judith
>
> Hello Judith..
>
> Let me try and clear up a few things here. You are right that
> many of the
> drafts discussed here do not adequately or address the specific
> requirements and functions of the Toll Free System but I can
> assure you
> that those needs are are understood and being met.
>
> The "controlling party" of the Toll Free number is just as
> important .. as
> any telephone number.
>
> If there is a problem it is one of semantics and
> understanding the new
> service logic of Internet Telephony.
>
> Assume the case of 1 800 DOG-BONES that wishes to provision
> ENUM services
> to accept calls using SIP.
>
> That number has been delegated to that "subscriber" under the
> normal terms
> and conditions of 800 service ..so the "controlling party" is
> known to the
> 800 SMS and can be verified.  The key to ENUM authority is that this
> verification can be successfully accomplished and that proper
> authorization
> can be delegated from the T1 to the T2 entity that actually holds the
> Resource Records that provision real service.
>
> Once this is accomplished we can assume that 1 800 DOG-BONES
> resolves to a
> SIP URL either under the direct control of the "controlling
> party", to use
> your terms, or to a T2 ENUM service provider that maintains
> these records
> under contract for this service under various SLA's etc.
>
> The SIP proxy that ENUM resolves to will maintain the real
> service logic of
> call routing necessary to complete the call based on the numbers
> "controlling party" requirements.[ time of day etc]  And the
> syntax of that
> service logic is defined by the IPTEL WG as Call Progress Language.
>
> http://www.ietf.org/internet-drafts/draft-ietf-iptel-cpl-04.txt
>
> The CPL is the real provisioning tool for Call Progress and
> routing as you
> outline. And the promise of this whole exercise in standards
> development is
> that  service logic now resides within the complete control
> of the 1 800
> number holder ..and not the carrier from whom service was delivered.
>
> ENUM is very simple in its abstraction. Number In ..URL Out.
> Its the URL
> that really controls the call and what that URL is. It is the
> URL that must
> be controlled by the number holder.
>
> Is this a touch clearer?
>
>
> > >
> > > At 05:18 PM 11/27/2000 -0500, you wrote:
> > > >Is this system meant to accomodate U.S. toll free numbers?
> > > >
> > > >Judith
> > >
> > > Any national ENUM system has to accommodate toll free
> > > numbers. 800 - 877
> > > etc, numbers in the US are E.164 numbers. Its just that the
> > > authority for
> > > authorization ( record holder ) is different.
> > >
> > >
>
>
>
>
>  >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>
>
> Richard Shockey
> Senior Technical Industry Liaison
> NeuStar Inc.
> 1120 Vermont Avenue N.W.
> Suite 550
> Washington DC. 20005
> Voice 202.533.2811
> Fax to EMail 815.333.1237 (Preferred for Fax)
> Cell : 314.503.0640
> INTERNET Mail & IFAX : [e-mail]
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>
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