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Re: [wg-b] 800 Telephone Scenario

I've just joined - am publisher of ICB Toll Free News
(http://icbtollfree.com) and pres of ICB Consultancy
(http://800consulting.com).  Also moderator of  TOLLFREE-L

I'd like to try answering some of your questions on toll free.  I've
weeded through the archives, am addressing what seems relevant.

At the time 888 was thought up at an Industry Number Committee (INC)
meeting, 800 numbers were by no means exhausted. Rather, over one third
of them were on pagers and other one-to-one PCS applications that needed
only the utility of toll free, but not the brand of 800.

The myth of "exhaust" was created by companies that did not want to wait
for a non-branded toll free utility code to be provisioned, in part
because the industry historically opposes applications-based codes
(state PUCs are now looking to this issue because of local number
exhaust), and also because waiting to roll out product, vapor or
otherwise, means not necessarily meeting quarterly projections.   888
was created of pure industry greed and steamroller management.

Not coincidentally, at the same time they created the accompanying myth
of the "broker" on whom to blame the "exhaust" at the FCC.

(To this day this works very nicely with carrier and large companies'
huge appetites for buying vanity numbers: gives them inordinate leverage
at the bargaining table.  Reverse domain name hijacking is only
800-theft's teething baby sister.)

Moving forward, 888 was to be introduced secretly and mostly
after-the-fact (how many of you have been told by your carriers to line
up for 866 and 855?), with the large carriers getting their replications
first (800 COLLECT and Co. 'own' their vanities and need replication to
'protect their consumers from confusion.'  You, do not.)

Customers got word of 888, and that their 800 brands would not be
protected in 888, and the resulting ear-boxing of carrier national
account reps, gave birth to 888 replication as a SNAC (SMS Number
Administration Committee) contribution, written by a very astute
gentleman named John Cushman at AT&T with whom it was my pleasure to

So replication become a *voluntary* industry process.  Very large
customers were notified privately and given a fair length of time (at
least three to four months) to place advance reservations to match their
existing 800's in 888.  As word leaked out of this voluntary
preferential system, angry 800 customers bombarded the FCC with
complaints, and a formal requirement to enable 888 replication for all
800 customers was issued.  When *that* was only paid lip service to, the
FCC gave 800 users unprecedented access to communicate directly with
Database Services Management Inc. (DSMI), the SMS administrator and
800's version of Internic, in order to provision their replication
requests.  If memory serves me correctly, 800 customers had a 15-day
window to get this done.

(EXPLANATION:  Unlike domain name user direct access to Internic and
Whois, 800 customers are not allowed direct access to the 800 database
and have no Whois equivalent.   Furthermore, the entities called
"RespOrgs" who by tariff are mandated to function as agents for 800
customers in the database, are usually also the carriers (AT&T, MCI,
Sprint on down ...) who also compete with customers for the best
numbers* for themselves and for their preferred customers.

These same RespOrgs also make up SNAC and INC and other industry
committees, and create behind closed doors, the products, standards and
practices of toll free numbers and service, in the guise of industry
engineering management.)

I give you this background to illustrate that the FCC has not pro-acted
on any logic or even casual consideration of customer needs or rights,
but rather, only reacted at minimum levels to keep the peace.

The 888 replication scenario was a joke that never reached most users -
its only value, that of setting some minor precedent for
rights in numbers, which the FCC keeps ignoring anyway ...

In my opinion, anything that sets the stage for using the toll free
model for domain names, is exceedingly dangerous (see EXPLANATION again
a few paragraphs up ...)

It is a vehemently anti-user system; it is dysfunctional and abusive to
all end users:  small and large businesses, resellers, service bureaus,

The only entity granted 'control' status by law (Portability) over toll
free numbers is the end user.  Toll Free Guidelines have consistently
stated throughout six years and eleven issue modifications, "The Toll
Free Service End-User Subscriber has the ultimate right to control its
Toll Free Service, and its reserved, active, or assigned Toll Free
Service numbers."

This status is ignored at every turn, at every level of the industry.
It keeps my consulting practice very busy.  This is not where I want
domain names to go.

In fact, there were plans to petition the FCC to overturn its draconian
toll free rules and system, pointing out the efficacy of the open
internet system:

1.  direct user access to Internic to acquire domain names, with no
interfering/conflicting-interest 'RespOrg'
2.  direct user access to Whois, again with no
interfering/conflicting-interest 'RespOrg'
3.  recognition of user interest in domain names
4.  unfettered freedom to buy and sell (generic, non-trademark
infringing) domain names

We were hoping to move 800 into the future ... instead it looks like the
domain name system is moving into the dark ages ... sad ...

All this said, you don't have to take my word for it.  ICB Toll Free
News contains all the documentation - news stories, FCC Rulings,
petitions (still awaiting consideration!), etc., on all of this.
Registration is required but there is a 15 day free trial.  If anyone
here is totally adverse to registering, email me
(mailto:joppenheimer@icbtollfree.com) and I will get you a temporary
user name and password to search the news stories and pick through our
Regulatory Reading Room.

Of course I'll be happy to continue this discussion on the list as well
(assuming I've not already put you to sleep), and hope I make a useful


P.S.  Milt Mueller, I believe, wrote here, "There is no evidence that
the absence of first refusal in the new space has
caused any problems."

This depends how you define a problem.  If your toll free number is used
for Johnny to call home from college, no problem.  If the toll free
number is what your business depends on for revenue - big problem.

Toll free numbers are NOT created equally.  Like .com, 800 rules, and
vanities rule above that.  The .com, the 800 and the vanity, are all,
for practical purposes, currency.  The answer to why, is branding.
Plain and simple.

Two illustrations:  a recent study, Toll Free Numbers in Radio
Advertising, found that the vanity 800 number out performed the numeric
800 number, by 14 times!  Fourteen times more people called the vanity,
than the numeric.  Which do you want your business to use?

Second illustration:  a recent ad agency mistake placed an advertiser's
877 vanity number in a radio spot instead of its 800 vanity (same
vanity).  Both numbers ring into the advertiser's call center, so no big
deal.  A percentage of misdials to the 800 was anticipated.

However, more people called the 800 vanity number than called the 877
vanity number, even though the commercial specifically said call toll
free 877 etc.   Would you want to be the 877 number advertiser without
the matching 800 number, who loses that much business to someone else
(or the ether, for that matter)?

This is one reason why one of the SBA's petitions to the FCC on
replication as well as its Toll Free Ruling against buying and selling
said, among other things, that it is discriminatory to new and small
businesses for them to be forced to use 888's and 877's, with not even
the option to try to buy the 800 ...