<br><font size=2 face="sans-serif">There is a regulatory battle going on
about this between State Public Service Commisions and the FCC. I
have not found the FCC to state specifically what you are doing with your
DID's is wrong but your State Public Service Commision may say something
different. Minnesota PSC sued Vonage about this typeof issue but they lost.
The court ruled that the feds have jusridiction. The Feds are concerned
primarilly with 911 and CALEA wich is basically law enforcements ability
to wire tap. If your legal dept can point to specific laws saying what
you are doing with the did's is wrong I would like to see that and if they
are state laws or Federal. </font>
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<br>
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<td width=40%><font size=1 face="sans-serif"><b>"Mark Holloway"
<mh@markholloway.com></b> </font>
<br><font size=1 face="sans-serif">Sent by: cisco-voip-bounces@puck.nether.net</font>
<p><font size=1 face="sans-serif">08/02/2007 04:52 PM</font>
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<div align=right><font size=1 face="sans-serif">To</font></div>
<td><font size=1 face="sans-serif">"'Dark Fiber'" <d4rkf1ber@gmail.com></font>
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<div align=right><font size=1 face="sans-serif">cc</font></div>
<td><font size=1 face="sans-serif">cisco-voip@puck.nether.net</font>
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<div align=right><font size=1 face="sans-serif">Subject</font></div>
<td><font size=1 face="sans-serif">Re: [cisco-voip] Need some facts regarding
DID's, Enterprise VoIP and LATAs</font></table>
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<br><font size=2 color=#1f497d face="sans-serif">Out of rate center numbers
are considered “dirty” and if your phone company that you’re getting
the TN’s from knew, they might make a big deal about it. </font>
<br><font size=2 color=#1f497d face="sans-serif"> </font>
<br><font size=2 face="Tahoma"><b>From:</b> techguy@gmail.com [mailto:techguy@gmail.com]
<b>On Behalf Of </b>Dark Fiber<b><br>
Sent:</b> Thursday, August 02, 2007 2:34 PM<b><br>
To:</b> Mark Holloway<b><br>
Cc:</b> cisco-voip@puck.nether.net<b><br>
Subject:</b> Re: [cisco-voip] Need some facts regarding DID's, Enterprise
VoIP and LATAs</font>
<br><font size=3 face="Times New Roman"> </font>
<br><font size=3 face="Times New Roman">Actually 911 is not the issue,
we do have local gateways with a couple of pstn lines at each location
strictly for 911. So if someone in Houston calls 911 it routes out
the local gateway to reach the right psap.</font>
<br><font size=3 face="Times New Roman"> </font>
<br><font size=3 face="Times New Roman">Appreciate the response though.<br>
<br>
</font>
<br><font size=3 face="Times New Roman">On 8/2/07, <b>Mark Holloway</b>
<</font><a href=mailto:mh@markholloway.com><font size=3 color=blue face="Times New Roman"><u>mh@markholloway.com</u></font></a><font size=3 face="Times New Roman">>
wrote: </font>
<p><font size=2 color=#1f497d face="Times New Roman">Hey man, had to skim
through this one quick (busy day at work) but let me see if I'm getting
this right. You are assigning DID's from Dallas to users in Houston
and San Antonio? Yikes! How are you handling 911 for Houston/San
Antonio users? You should have an FXO on Houston's router and San
Antonio's router with a 911 dial peer that displays a Houston or San Antonio
TN to their local PSAP. You are in major FCC violation for not providing
local 911 access. If Houston dials 911 and goes to a Dallas PSAP,
that person is screwed. That's a major law suit and a major FCC violation.
The reason Vonage can do it is they have the ability to give you
a DID anywhere, but route 911 to your local PSAP. You definitely
need some FXO cards and 911 dial peers in each of your remote locations.
</font>
<p><font size=2 color=#1f497d face="Times New Roman"> </font>
<p><font size=2 color=#1f497d face="Times New Roman"> </font>
<p><font size=2 color=#1f497d face="Times New Roman"> </font>
<p><font size=2 face="Times New Roman"><b>From:</b> </font><a href="mailto:cisco-voip-bounces@puck.nether.net" target=_blank><font size=2 color=blue face="Times New Roman"><u>cisco-voip-bounces@puck.nether.net
</u></font></a><font size=2 face="Times New Roman">[mailto:</font><a href="mailto:cisco-voip-bounces@puck.nether.net" target=_blank><font size=2 color=blue face="Times New Roman"><u>cisco-voip-bounces@puck.nether.net</u></font></a><font size=2 face="Times New Roman">]
<b>On Behalf Of </b>Dark Fiber<b><br>
Sent:</b> Thursday, August 02, 2007 11:38 AM<b><br>
To:</b> </font><a href="mailto:cisco-voip@puck.nether.net" target=_blank><font size=2 color=blue face="Times New Roman"><u>cisco-voip@puck.nether.net</u></font></a><font size=2 face="Times New Roman"><b><br>
Subject:</b> [cisco-voip] Need some facts regarding DID's, Enterprise VoIP
and LATAs </font>
<p><font size=3 face="Times New Roman"> </font>
<p><font size=3 face="Times New Roman">In the last couple of weeks I have
been dealing with e911/911 issues internally at work. In trying to
resolve and provide the best possible solution for 911 calling to all employees
throughout the region I ended having to pull in our legal and regulatory
folks to address some of these issues and what they felt we needed to provide
at a minimum to our employees, so that we make sure we are completely covered.
</font>
<p><font size=3 face="Times New Roman"> </font>
<p><font size=3 face="Times New Roman">In doing so I begin to layout the
network and phone system for them explaining what we have and where we
are going and such. Upon seeing this the regulatory folk begin telling
me that this is wrong / illegal. Basically saying that the way we
have deployed phones and Call Manager and such is wrong and needs to be
corrected. I was seriously taken aback by this, never did I question
our phone deployment if you will, I mean heck this meeting was about 911
you know. </font>
<p><font size=3 face="Times New Roman"> </font>
<p><font size=3 face="Times New Roman">The first thing they tell me is
that DID's are for internal calling / usage, and not meant for external
or incoming calling? I was like blown away, this is completely OPPOSITE
of what I have always thought and known. DID's are direct inward
dialing, you can 100 DID's if you will on a PRI from your service provider
and assign them to individuals internally so that users can have a direct
inward number from the outside. Heck even wikipedia "which I
know is not the end all source of all knowledge" but fairly reliable
states exactly what I have always known DID's as. </font>
<p><font size=3 face="Times New Roman"> </font>
<p><font size=3 face="Times New Roman">Next they begin telling me I have
to get circuits and DID's / numbers that correspond to each of my physical
locations!</font>
<p><font size=3 face="Times New Roman"> </font>
<p><font size=3 face="Times New Roman">Basically, right now we have various
small locations spread out in different cities. Say as an example
Houston, Dallas and San Antonio. Main office say is Dallas, my call
managers and gateways are there in Dallas. I get PRI's to terminate
there and I have a large block of DID's all for Dallas. </font>
<p><font size=3 face="Times New Roman"> </font>
<p><font size=3 face="Times New Roman">All ip phones are setup with four
digit extension, and are tied to a DID from Dallas even though the phone
and user may be in Houston or something. User in Houston places a
call it goes out of Dallas, and incoming calls obviously go into Dallas
then over our fiber to Houston. Blah blah, nothing new there I know
alot of places that do the same thing. </font>
<p><font size=3 face="Times New Roman"> </font>
<p><font size=3 face="Times New Roman">Anyway, so they tell me I can't
do this. That legally I have to get circuits in each market, and
provide those users numbers in that market. </font>
<p><font size=3 face="Times New Roman"> </font>
<p><font size=3 face="Times New Roman">I just don't buy this. I mean
the past three employees I have been at and managed the call managers they
all had similar setups and I am not the one who set them up so I know I
was not the only one who believed it was perfectly acceptable to do things
this way. </font>
<p><font size=3 face="Times New Roman"> </font>
<p><font size=3 face="Times New Roman">I would love some facts to use to
show that it is perfectly acceptable to do this. I can't find anything
from a legal perspective to substantiate what they said or what I believe.</font>
<p><font size=3 face="Times New Roman"> </font>
<p><font size=3 face="Times New Roman">I even pointed out VoIP providers
like Vonage and stuff, and said if it was illegal to do then don't you
think these companies that base their business on just that sort of thing
would exist? That's one of the main selling points you can get a
number from any market in the US pretty much no matter where you live.
Of course their answer was they are regulated differently. And
who knows maybe so. </font>
<p><font size=3 face="Times New Roman"> </font>
<p><font size=3 face="Times New Roman">Any thoughts or arguments out there
on this? Would love to be able to point to some law or case or something
regarding this rather then just thoughts and examples since they would
have more weight for me to prove my point. But I would love to hear
anything at this point. </font>
<p><font size=3 face="Times New Roman"> </font>
<p><font size=3 face="Times New Roman"> </font>
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