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SMT ADDRESSES USE OF SMS/800 DATA IN ENUM

New York, NY September 10, 2003 (ICB TOLL FREE NEWS) In an ENUM Forum contribution titled Use of Non-Proprietary SMS/800 Information in ENUM, the SMS/800 Management Team Representative wrote: This document outlines several concerns that the SMT would like to communicate to the ENUM Forum regarding the use of SMS/800 non-proprietary data in ENUM.

Overview of SMS/800 Data

SMS/800 is the centralized system used for toll-free number administration and provisioning. Organizations that have met specific registration requirements for obtaining access to SMS/800 are referred to as Responsible Organizations (Resp Orgs). As stated in a previous contribution, a Resp Org is defined in the Industry Guidelines for Toll Free Number Administration as the “entity identified by the Toll Free Service Customer that assumes the duty of managing and administering the appropriate records in the 800 Service Management System (SMS/800).” In other words, Resp Orgs utilize SMS/800 to search for, reserve, and provision toll-free numbers in SMS/800 on behalf of a customer. The customer can be an end consumer or a re-seller of telecommunication services which uses the Resp Org to process their toll-free number requests.

SMS/800 maintains information needed for the administration, provisioning, and maintenance of toll-free numbers by the Resp Orgs. The information includes but is not limited to the status of toll-free numbers, call routing information, and Resp Org information for each toll-free number in the system. Most of the information is considered proprietary and is only accessible by the Resp Org for a specific number. Some information is considered proprietary and is accessible only by the Resp Org and the involved network carriers for a specific number. A small portion of the data stored in SMS/800 is considered non-proprietary and can be viewed by Resp Org or network operators with access to SMS/800.

Non-proprietary SMS/800 Information in ENUM

In Penn Pfautz’s (AT&T) contribution, GEN0080RO “Provisioning and Authentication/Authorization for Toll-Free Numbers” Dated June 23, 2003, a suggestion is made that a request be submitted to the Order & Billing Forum’s (OBF) SMS/800 Number Administration Committee (SNAC) to make Resp Org information and assignment status for toll free numbers generally available via IVR or web access.

The SMS/800 tariff (FCC Tariff #1) provides that Resp Orgs may access SMS/800 only to the extent required by, and incident to, the administration and management of their toll-free subscriber's telecommunications services. Providing query access via IVR or web access to the SMS/800 to non-Resp Orgs who are not subject to the FCC tariff, would not be permitted under the rules outlined in the tariff. To implement Penn Pfautz’s request would be tantamount to a disregard of the FCC #1 Tariff and the provisions that govern this service, which the BOCs are not prepared to do.

In addition, downloading information to an IVR, web access, or other system on a set time interval other than real-time, would mean that ENUM is utilizing SMS/800 data that is not current and is potentially inaccurate.

Finally, litigation exists in the industry at the present time whereby a marketing firm has used Resp Org non-proprietary data (allegedly provided by a Resp Org) on toll free numbers to target another Resp Org's subscribers. Providing non-proprietary data through a website or an IVR may generate additional litigation. Furthermore, all Resp Orgs would have to consent to the creation of access to this information for it to even be considered, aside from the legal outcome of the pending litigation.

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