Before the Federal Communications Commission Washington, D.C. 20554
) In the Matter of ) ) Petition to Competitively Bid Toll Free ) WC Docket No. 20-174 Numbering Administrator ) ) Toll Free Assignment Modernization ) WC Docket No. 17-192 ) Toll Free Service Access Codes ) CC Docket No. 95-155 )
REPLY COMMENTS OF SOMOS, INC. ON THE PETITION OF ICONECTIV, LLC FOR COMPETITIVE PROCUREMENT OF THE TOLL FREE NUMBERING ADMINISTRATOR ROLE
Joel Bernstein Aaron M. Panner Vice President, Regulatory and Public Policy Christine A. Bonomo Somos, Inc. Kellogg, Hansen, Todd, Two Tower Center Boulevard, 20th Floor Figel & Frederick, P.L.L.C. East Brunswick, NJ 08816 1615 M Street, N.W., Suite 400 (844) HEY-JOEL, (844) 439-5635 Washington, D.C. 20036 [email protected] (202) 326-7900 [email protected] J.G. Harrington Cooley LLP 1299 Pennsylvania Avenue, N.W., Suite 700 Washington, D.C. 20004-2400 (202) 766-2818 [email protected]
Counsel for Somos, Inc.
August 13, 2020
TABLE OF CONTENTS
INTRODUCTION ...... 1
DISCUSSION ...... 2
A. The Current System of Toll-Free Number Administration Is Functioning Well ...... 2
B. If the Commission Chooses To Consider a Competitive Procurement Process, Comments to the iconectiv Petition Make Clear That It Should First Proceed Through a Notice of Inquiry ...... 7
CONCLUSION ...... 14
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INTRODUCTION AND EXECUTIVE SUMMARY
The comments filed in response to the Bureau’s Public Notice reflect overwhelming recognition that the current Toll-Free Number administration system has served the industry well and at moderate cost. A significant majority of the parties filing comments, including Resp
Orgs, users of Toll-Free Numbers, and Somos’ partners in the Toll-Free ecosystem, describe
Somos’ costs as reasonable. At the same time, they see the services it provides – in modernizing,
maintaining, and operating the SMS/800 TFN Registry; in implementing fraud prevention
programs; in providing training and customer support for Resp Orgs – as excellent. Even those
commenters who favor a competitive bidding process do not question that Somos provides
exceptional service as the Toll-Free Number Administrator (“TFNA”). There is no need for the
Commission to allocate its limited resources toward upending a system that is functioning well.
The Petition of iconectiv, LLC (the “Petition”) should therefore be denied.
In the event, however, that the Commission chooses to undertake a reevaluation of the
current regulatory structure governing Toll-Free Number administration, the record makes clear
not only that the Commission cannot act unless it first issues a Notice of Proposed Rulemaking,
but that it should not act before issuing a Notice of Inquiry (“NOI”). Commenters have made
clear that the industry and consumers have come to rely upon Somos for more than just database
administration: in particular, stakeholders highly value the customer service, technological
innovation, and fraud and spoofing prevention initiatives offered by Somos under the current
system. The Commission cannot undertake to remake the current system until it has a clear
record demonstrating how that system operates and the services it provides and on which the
Toll-Free industry relies. Furthermore, as Somos noted in its opening comments, such an NOI
should not be limited to Toll-Free Number administration but should also address the many
legacy numbering systems that are provided without competition or regulation to guarantee just
and reasonable rates and to protect the public interest across the numbering administration
ecosystem.
DISCUSSION
A. The Current System of Toll-Free Number Administration Is Functioning Well
The significant majority of commenters across the industry agree that Somos provides
Toll-Free Number administration at reasonable, moderate rates; that it operates the SMS/800
TFN Registry in an impartial manner; and that it is highly responsive to the needs of the industry.
Simply put, the current system is functioning well, and the Commission should “not break what’s
working.”1
As Somos explained, it administers the TFN Registry – which gives Resp Orgs the ability
to control Toll-Free Number assignment, Toll-Free Number routing, and Toll-Free Number
porting – at less than $1.50 per year per number.2 It also allows Resp Orgs to reserve Toll-Free
Numbers singly, not just in blocks, which helps Resp Orgs (many of which are small businesses)
control costs by avoiding payment for unused numbers.3 This pricing structure is reasonable and
relatively modest, as many commenters have observed. One Resp Org, Talkroute, for example,
writes that, “[a]s an entity that pays Somos directly, we find that $0.12 - $0.13 a month per toll
free number is not an absurd cost,” and it estimates that the fees it pays for Toll-Free Numbers
amount to just 0.015% of its revenue.4
1 Direct Results Comments at 1. 2 Somos Comments at 6-7. 3 Id. 4 Talkroute Comments at 1. See also, e.g., Vanity International Comments at 3 (noting that Toll-Free numbering is “only $1.48 per year” in contrast to similar services that it purchases which cost nearly $8 per year per number and will soon increase to $10); Jump Market Strategies
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Further, while it is true that Toll-Free rates have increased to some extent, these increases
are largely explained by Somos’ investments in modernizing its database infrastructure – necessary investments from which the entire ecosystem benefits substantially.5 Somos has
worked to minimize the impact of these costs on Resp Orgs not only by recouping the costs
gradually over several years,6 but also “by offering training and software assistance” for Resp
Orgs using the new infrastructure.7 In addition, because Somos, a not-for-profit corporation,
operates the TFN Registry at a zero percent rate of return, Resp Orgs are not paying for any
profit on the return on the capital expenses incurred for these upgrades.
The small minority of commenters who suggest that granting iconectiv’s petition may
lower costs do not criticize any of Somos’ tariff filings in particular, but instead laud the benefits
of competition in general.8 But while competition is one means of ensuring just and reasonable
rates,9 it is not the only one. As noted, Somos provides Toll-Free Number administration
services at cost, with no profit margin.10 And the tariffing process ensures that its rates are just,
Comments at 2 (“[I]n my experience the cost of a toll free number is minor in comparison to other factors that weigh on innovation on top of telecommunication services.”). 5 Somos Comments at 7-8. See also Part B, infra. 6 Somos Comments at 7. 7 FracTel Comments at 1. 8 See Sharad Kumar Comments at 1-2; USTelecom – The Broadband Association Comments at 2-3; AT&T Comments 1-2; eSignal Holdings Comments at 2. 9 See Order, Telcordia Techs., Inc. Petition to Reform Amendment 57 and to Order a Competitive Bidding Process for Number Portability Administration, 30 FCC Rcd 3082, 3173 (2015) (Statement of Commissioner Ajit Pai). 10 Somos Comments at 8. See also VIPGeek Comments at 1 (observing that Somos’ status as a nonprofit organization is important for maintaining the high level of service it provides).
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reasonable, and transparent.11 Somos files cost support with every yearly tariff filing; Resp Orgs
and other interested parties accordingly have the opportunity to scrutinize Somos’ cost
allocations and tariff rates, while the Commission staff reviews every tariff filing.12 No Resp
Org has ever objected to Somos’ published rates and the Commission has never concluded that
Somos’ cost allocations are unreasonable.13
Furthermore, far from guaranteeing cost savings, designing and running a competitive bidding process will impose costs on all parties. To start, there is no guarantee that a competitive bid process will yield lower rates, at least not while maintaining the same quality of service that
Somos currently provides. The tariffed services for Toll-Free Number administration have
always been provided on a revenue-neutral basis.14 In a competitive bid process, entities will
look to recoup not only the costs of providing TFNA services but also a profit margin. For-profit
participants in a competitive bid process, even if they promise to reduce rates, will have an
11 See Order, Toll Free Service Access Codes, Petition to Change the Composition of SMS/800, 28 FCC Rcd 15328, ¶ 38 (2013). 12 See Callfire, Inc. d/b/a EZ Texting Comments at 5 (“The TFNA has always publicly filed its pricing by tariff with the supporting information required by the Commission’s rules. Anyone, including iconectiv, has the ability to question the tariff, oppose it, or seek that the Commission investigate the charges contained therein. That iconectiv has never pursued its claims through the Commission’s established processes, highlights that it may be more concerned with its position in the industry, rather than the performance of the industry itself.”). 13 See Number Access Comments at 1 (“As far as Number Access is aware, no party has ever challenged Somos’ tariffed rates, nor has the Commission ever found a Somos rate to be inappropriate. Thus, as a matter of law and fact, Somos’ rates are and have always been just and reasonable.”). Even one of the few commenters who advocates for a competitive bid process acknowledges that the current system constrains Toll-Free rates (and also considers Somos to be an “effective and able administrator”). eSignal Holdings Comments at 2 (“Signal One wishes to make it clear that it believes the current administrator, Somos, Inc., is an effective and able administrator of the toll-free numbering system and, if anything, is itself constrained by the existing regulatory constructs.”). 14 See Report and Order, 800 Data Base Tariffs and the 800 Service Management System Tariff, 11 FCC Rcd 15227, ¶ 250 (1996).
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incentive to reduce service quality, including customer support and other services, to cut even
necessary costs and increase the profitability of the contract. Reflecting that reality, commenters
have expressed concern that even if a switch to a competitive bid process may lower rates
minimally, that reduction will come only at the expense of product quality.15 As a non-profit
corporation, Somos has no pressure from shareholders, venture capitalists, or other investors to
increase revenues or reduce service quality to boost profitability.
Moreover, in the event of a transition, Resp Orgs and other industry participants are likely to incur substantial costs to modify their systems to interact with and connect to a new
Toll-Free Number administration system. These costs include not only the potential costs associated with the likely growing pains for a new TFNA, but also the costs Resp Orgs and other
interested parties will further incur in readjusting their operations to a new administrator and
database. Any marginal price savings that a competitive bidding process might deliver – even
assuming that services are not degraded as a result – are likely to be overshadowed by the
internal costs that Resp Orgs would incur.
Beyond the reasonableness of its rates, Somos’ unique governance structure and emphasis on regular communication with industry stakeholders have allowed Somos to maintain
15 See The Alliance for Telecommunications Industry Solutions (“ATIS”) Comments at 2-3 (“[R]egardless of how the role of the TFNA is selected, ATIS SNAC urges the Commission to take steps to ensure that any changes to the TFNA will not negatively impact toll free providers and end users. In particular, ATIS . . . urges the Commission to ensure that any new rules do not significantly interfere with or require changes to the way in which providers interface with the TFNA and allows service providers to maintain existing levels of service, security, functionality, and does not require costly changes.”); EZ Texting Comments at 6 (“The apparent, but unsupported, inference of this view being that iconectiv could provide some lesser, bare bones offering ‘cheaper’ whether the industry wants it or not.”); TeleServices at 2 (“I fear that iconectiv might bid lower initially, but when faced with the huge investment they’ll need to make to do this job properly, their prices will rise, probably sooner rather than later.”).
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its impartiality while being responsive to the entire ecosystem’s needs. As explained, Somos’
independent board prevents improper influence or control by certain sectors of the industry.
Somos also engages in extensive customer outreach efforts to ensure it is serving the needs of all
Resp Orgs, large and small.16 As a result, many commenters have expressed great satisfaction
with Somos’ impartiality, outreach efforts, and customer service more generally. FracTel, for
example, observes that “from the very beginning Somos worked with all interested people in the
RespOrg industry, facilitating a neutral round table where all ideas were discussed on what was
most needed to improve our telecom backbone for all the businesses and citizens that rely on this
critical infrastructure.”17 And according to FracTel, “Somos benefits the overall
telecommunications industry by . . . helping establish an open channel of communication
through online website accessibility; surveys and in-person meet ups for a better Resp Org
community.”18 Number Access LLC, similarly highlights:
Somos is highly responsive to RespOrgs and others on a day-to-day basis. Moreover, working hand-in-hand with the 8XX provider community, Somos hosts on-going industry forums to address system updates and changes, develop and implement improved software applications, and establish methods for identifying and mitigating potential abuse and fraud in the 8XX ecosystem.19
16 Somos Comments at 9-10. 17 FracTel Comments at 1. 18 Id. at 2. 19 Number Access Comments at 1. See also, e.g., TeleServices Comments at 1 (writing that “rarely [has it] encountered a company as competent and customer-focused as is SOMOS” and further noting that “SOMOS has invested a great deal in both infrastructure and personnel and it shows”); Direct Results Comments at 1 (noting that ‘[i]t’s rare to find an organization [Somos] today that focuses on quality customer service” and observing that Somos “[e]xhibit[s] a passion and interest in their work,” “[h]andle[s] any concern/problem . . . with efficiency – Usually first time final,” does “what they say they’re going to do” and “search[es] for solutions, not excuses not to help”); RingBoost Comments at 1 (observing that the “current process” under Somos “has not only met our needs but has proven routinely to be equitable when disputes or issues have arisen”); Beta Texting Comments at 1 (“Somos has been incredibly supportive of our
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That Somos is providing such extensive customer outreach and support services further
bolsters the reasonableness of its rates under the current system. The high-quality customer service provided by Somos has substantial economic value to Resp Orgs. Efficiency in handling customer issues, for instance, translates to fewer costs for Resp Orgs that experience “first time final” solutions, rather than losing time and money having to endure delays and to request assistance again and again.20 Moreover, in many cases a high quality product means that Resp
Orgs never have to ask for assistance at all, which also lowers their costs. As the Resp Orgs are
the customers for the TFNA, this factor is important in any analysis of the true costs of the
service Somos provides.
The Commission should heed the views of the industry – in particular the entities that
most depend on Somos – and conclude that the current system is functioning well with no need
for regulatory action.
B. If the Commission Chooses To Consider a Competitive Procurement Process, Comments to the iconectiv Petition Make Clear That It Should First Proceed Through a Notice of Inquiry
For the reasons described above, there is no reason for the Commission to consider
changes to the current Toll-Free Number administration structure, given the widespread
satisfaction with the price and service provided to Resp Orgs. If the Commission chooses to
move forward nevertheless, the complexity of the issues raised by a change of structure requires
company. We have great experience with their support team and developers.”); Talkroute Comments at 2 (“Due to Somos’s easy to approach nature vs the rest of the registries, they are the only company Talkroute has registry access with.”); THE Telco Comments at 2 (“SOMOS has been leading the way with innovation and new products. They actively engage the resporg community with surveys and questionnaires requesting information on how they can provide better service, and in what areas.”). 20 Direct Results Comments at 1.
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that the process begin with a Notice of Inquiry, even before a notice of rulemaking could be
issued. In particular, the comments make clear that the services Somos provides under the
current system are multidimensional and extend beyond simply administering the SMS/800 TFN
Registry.21 Not only does Somos engage in extensive customer outreach and support, as already
discussed, but it also invests in technological innovation and partners with businesses in a variety
of industries on initiatives to prevent fraud and robocalling, among other efforts. An NOI also
would provide a framework for the Commission to undertake a comprehensive evaluation of
other legacy numbering systems, like the Local Exchange Routing Guide, that are currently
provided on an unregulated, monopoly basis.22
An NOI is the most appropriate procedural mechanism for ensuring that the Commission
gains a holistic view of the Toll-Free ecosystem, and in particular those aspects that are most
valued by participants in this ecosystem and most important to preserve. The Commission has
historically used NOIs in circumstances in which a thorough industry investigation is required.23
21 See, e.g., Unisys Comments at 2 (“The toll-free numbering system is a complex environment that provides number administration, routing, and porting capabilities; the administration of this system by Somos is equally complex. Effective management is critical to thousands of end users and, through them, millions of consumers. At a time when business services have been grossly interrupted by the pandemic and the resulting impact on operations, toll-free numbers continue to have a critical importance in providing connectivity between businesses and their current and potential customers.”). 22 See Somos Comments at 11. 23 See FCC, Rulemaking at the FCC (“The Commission releases an NOI for the purpose of gathering information about a broad subject or as a means of generating ideas on a specific issue.”), https://www.fcc.gov/general/rulemaking-fcc; see also, e.g., Notice of Inquiry, Location- Based Routing of 911 Calls, 33 FCC Rcd 3238, 3260 (2018) (Statement of Commissioner Rosenworcel, supporting an inquiry to gather data and seek recommendations from stakeholders on how to move forward); Notice of Inquiry, Promoting Telehealth for Low-Income Consumers, 33 FCC Rcd 7825, 7848 (2018) (Statement of Commissioner O’Reilly, noting that an NOI will allow a “wide-ranging presentation of many issues that need to be considered” with respect to promoting telehealth program); Notice of Inquiry, Promoting the Availability of Diverse and Independent Sources of Video Programming, 31 FCC Rcd 1610, 1626 (2016) (Statement of
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Given the complexity of Toll-Free Number administration and the administrator’s role, and the
diversity of the Toll-Free community which would be affected by any change, from sole
proprietor Resp Orgs focused on vanity numbers to the largest telecom carriers, an NOI would
provide a necessary opportunity to create a full record before the Commission proposes any
changes to the rules. As Number Access aptly notes, through an NOI “the Commission and
interested parties can fully vet all of the possible ramifications of fundamentally disrupting the
toll-free industry.”24
As explained in the comments, when Somos assumed its current role as TFNA, it
invested in developing a new, updated SMS/800 TFN Registry system, as well as investing in
strong customer support. This overhaul was required to make the system sustainable and ensure high quality service for Somos’ customers.25 The record in this proceeding also makes clear that
Somos has continued to invest in innovating and improving its service offerings. For example,
Unisys, a technology vendor, writes that Somos’ technology investments have allowed the
SMS/800 TFN Registry to achieve “high system availability, support 16 million transactions per
day (on average), and expand their network to support over 10,000 end users and more than 41
million toll-free numbers.”26 International Telecom, a Resp Org, similarly writes that Somos
“continue[s] to improve and evolve the platform so that provisioning, routing, updating, and
Commissioner Pai, supporting “giving all stakeholders the chance to provide feedback” on the diversity and availability of independent programming through an NOI). 24 Number Access Comments at 2; see also TSG Global Comments at 2 (“The FCC will require a trusted partner during this pandemic without creating a disruption to existing networks requiring time and personnel. Competition is a must but be wary to rush to a decision without inquiring from those in the industry to provide more information to make a more informed decision.”). 25 Somos Comments at 7-8. 26 Unisys Comments at 2.
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maintaining of toll-free numbers for our clients require very little manpower.”27 THE Telco,
another Resp Org, explains that Somos has “been leading the way with innovation and new
products.”28 An NOI could explore how to address technological innovation in the provision of
Toll-Free Number administration.
In addition to these technological and infrastructure development efforts, Somos has also
worked with partners across the industry on fraud prevention and other important consumer
protection initiatives. One of Somos’ partners in these efforts, Utilities United Against Scams
(“UUAS”), discusses Somos’ development of reporting mechanisms that utilities use to identify
Toll-Free Numbers used by scammers. Working with UUAS and its member organizations,
Somos has shut down over 9,000 toll-free numbers due to verified scammer use – which, in turn,
has frustrated scamming efforts of these bad actors and saved countless consumers from being
scammed.29 Companies outside of the utilities industry, such as Apple, have also begun to use
Somos’ reporting mechanisms to combat fraud.30
Similarly, Somos has worked tirelessly to ensure that the Toll-Free Number ecosystem is
included in implementing the FCC’s standards for combatting illegal caller ID spoofing – the
Secure Telephone Identity Revisited and Signature-based Handling of Asserted Information
27 International Telecom Comments at 1. 28 THE Telco Comments at 2; see also, e.g., FracTel Comments at 1-2 (explaining how Somos made a “huge upgrade to the old system” that has ultimately saved Resp Orgs money because they no longer need to send representatives to a certification class every six months); Beta Texting Comments at 1 (“Somos has helped us overcome some obstacles with our platform by adding new API’s to make our business more streamlined.”). 29 Utilities United Against Scams Comments at 2. See also Duke Energy Comments at 3- 4 (“Since Somos began working with Duke and UUAS on fighting scams in 2017, 51 utilities across the United States and Canada have reported toll free numbers associated with scammers to Somos, and Somos has worked with sellers to shut down 9,066 such scam numbers.”) 30 Duke Energy Comments at 3.
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Using toKENs standards, or STIR/SHAKEN standards31 – to block spoofed calls on toll-free numbers.32 As one Resp Org, EZ Texting, notes, “Somos has led the toll free industry in efforts
to implement the Commission’s important SHAKEN/STIR initiative to prevent spoofed
robocalls, which have plagued consumers throughout the nation for years. Fraud and abuse are
chronic concerns in the telecommunications network, and Somos should be commended for its
continuous efforts to engage with industry participants to combat these vexing problems.”33
Another Somos partner, Nomorobo, also writes that it “regularly reports illegal robocallers using
toll free number[s] to Somos. Without fail, and within minutes, they have investigated and
immediately shut them down at the highest level.”34 An NOI could address how to ensure that the TFNA continues to respond to fraud and consumer protection concerns.
In addition to allowing the commission to investigate the complexity of current Toll-Free
Number administration services, an NOI should also provide the framework for a comprehensive
review of how the systems, databases, and registries used for routing and rating calls in the U.S.
are administered. Currently, there is no consistency in how administration of numbering,
routing, and porting35 resources is managed – some services are provided under government
contract, some are provided pursuant to contracts with private pay-to-play industry consortia, and many are managed privately on a proprietary basis.36 In almost all cases, there are no
31 FCC, Combating Spoofed Robocalls with Caller ID Authentication, https://www.fcc.gov/call-authentication. 32 Number Access Comments at 1; EZ Texting Comments at 4. 33 EZ Texting Comments at 4. 34 NoMoRoBo Comments at 1. 35 The TFNA covers all three of these functions. 36 For instance, North American Numbering Plan Administration is provided through a Commission-awarded contract, Local Number Portability Administration is provided through a
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alternatives to the numbering services provided pursuant to these arrangements, even in the case
of proprietary resources like the Local Exchange Routing Guide or the LIDB Access Routing
Guide offered by iconectiv’s Telecom Routing Administration (“TRA”) business unit. TRA is
an unregulated monopoly, and carriers have to use it for routing of telecommunications traffic;
there is no alternative. LERG, BIRRDS, and LIDB Access Routing Guide (all part of TRA) are all similarly essential products for the telecom system that iconectiv inherited from the Bell
Operating Companies37 at the time of AT&T’s breakup in 1984. Those proprietary resources are
currently operated with no oversight. In fact, Somos is unaware of any occasions when the
Commission has addressed whether these proprietary monopoly resources should be subject to
oversight at all, even though they are essential to the operation of the public switched telephone
network. An NOI would offer the ideal context to evaluate and review these critical system
resources, and to determine the correct approach to ensure that each one is operated in the public
interest.
Furthermore, there is a glaring lack of transparency with respect to TRA, especially when
it comes to cost. Unlike Somos, whose costs and revenues are made public in the tariffing
process, iconectiv provides negligible information about the costs of its monopoly essential
routing products. As its catalog notes:
Pricing is not included in this catalog. TRA products follow a value based pricing model. Value based pricing is a process involving an assessment of several parameters that attempt to determine the ‘value’ of the product to the customer. Parameters include the type of company requesting the product, size of the company, etc. This pricing process is an equitable process whereby similar types of customers, relative to the assessed parameters, are charged the same price. The
contract with North American Portability Management, LLC, with supervision from the Commission, and the Local Exchange Routing Guide is a proprietary offering from iconectiv. 37 Bellcore began providing these services starting in 1984. Bellcore was renamed Telcordia and now does business as iconectiv.
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pricing process is consistent with the general TRA philosophy of providing a fair and equitable environment relative to its customers. In terms of value based pricing, this can be best understood as weighing pricing to customers in consideration that larger companies may ‘benefit’ substantially more from the data in TRA products than smaller companies.38
In other words, TRA’s pricing is not transparent, lacks oversight or competitive pressures, and
appears to be at the whim of the provider.
In addition to inadequate cost transparency, the lack of competitive pressure and oversight means that iconectiv has no incentive to modernize these monopoly systems or stay abreast of industry standards. The transition from delivery via CD to delivery via download appears to be iconectiv’s only recent system modernization effort in its TRA services.
Nevertheless, as Somos understands, the price of the service continues to climb. An NOI can explore the issues of costs, neutrality and modernization of all numbering, routing and porting resources for the entire telecommunications ecosystem, not just Toll-Free.
In any event, at a minimum, the Commission cannot proceed with further consideration of the Petition without issuing an NPRM. As explained in the Somos Comments, the steps proposed in iconectiv’s Petition are major policy changes that would affect future rights and obligations as well as require substantive amendments to the Commission’s current numbering regulations.39 The 2017 NPRM, moreover, provides an insufficient basis to move directly to a
final rule.40 Consequently, the Commission cannot adopt any of the changes the Petition seeks
without at least proposing new rules and seeking comment on them before it acts.
38 iconectiv, Catalog of Products and Services: TruOps Telecom Routing Administration, 44 (2018), https://iconectiv.com/sites/default/files/2019-11/TruOps_TRA_Catalog.pdf. 39 Somos Comments at 12-14. 40 Id. at 15.
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CONCLUSION
The record in this proceeding makes clear that the current structure of Toll-Free Number administration is functioning well, providing valuable services to the industry at reasonable rates.
As a result, the Commission should deny iconectiv’s Petition. But if the Commission chooses to consider further possible changes to the current structure, a broader investigation of the potential ramifications of those changes through an NOI is the most appropriate initial step.
Respectfully submitted,
/s/ Aaron M. Panner Joel Bernstein Aaron M. Panner Vice President, Regulatory and Public Policy Christine A. Bonomo Somos, Inc. Kellogg, Hansen, Todd, Two Tower Center Boulevard, 20th Floor Figel & Frederick, P.L.L.C. East Brunswick, NJ 08816 1615 M Street, N.W., Suite 400 (844) HEY-JOEL, (844) 439-5635 Washington, D.C. 20036 [email protected] (202) 326-7900 [email protected] J.G. Harrington Cooley LLP 1299 Pennsylvania Avenue, N.W., Suite 700 Washington, D.C. 20004-2400 (202) 766-2818 [email protected]
Counsel for Somos, Inc.
August 13, 2020
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