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Re: New N.Y. Law Targets Hidden Net LD Tolls

  • From: Robert Bonomi
  • Date: Thu Aug 18 08:43:36 2005

> From owner-nanog@merit.edu  Thu Aug 18 01:47:56 2005
> Date: Thu, 18 Aug 2005 02:44:59 -0400
> From: "Eric A. Hall" <ehall@ehsco.com>
> Cc: nanog@merit.edu
> Subject: Re: New N.Y. Law Targets Hidden Net LD Tolls
>
>
>
> On 8/17/2005 10:04 PM, Fergie (Paul Ferguson) wrote:
>
> > A new law that's apparently the first in the nation threatens to
> > penalize Internet service providers that fail to warn users that some
> > dial-up numbers can ring up enormous long-distance phone bills even
> > though they appear local.
>
> aka, make ISPs liable for other people's fraud. What's the thinking here,
> anybody know?

*NOT* "other people's fraud".  Just when you have 'intra-LATA' toll charges
for some numbers within a single area-code.  If the user is on one side of
the area-code, and the provider's POP is on the far side of it, you can have
a what appears to be a 'local' number, that does incur non-trivial per-minute
charges.  Without knowing _where_ a particular prefix is, you can't tell 
whether there will be toll charges for that call, or not, from any given
call origin.

Of course, this is true for *every* call in such an area -- if the new law
is actually singling out ISPs (and ISPs -only-), I expect it could be
successfully challenged as 'discriminatory'.   

The excessive 'local toll charge' situation is most visible on calls to ISPs,
because those calls tend to be somewhat lengthy -- and frequent -- thus, the
'unexpected' charges can reach significant dollar value before the phone
customer gets their first bill.

Life gets _really_ messy, when the ISP gets phone service from a CLEC, 
because there is "no telling" _where_ the ILEC uses as the 'rate point'
for handing the calls off to that CLEC.  And the CLEC bills their customers
based on distance from the caller's location to that hand-off point.  The
ISP equipment may be across the street from the caller, but the ILEC-CLEC
hand-off is on the far edge of the area-code.  and the 'local toll charges'
are applied.

The CLEC can't tell you (and thus, neither can the ISP) which prefixes are a 
'non-toll' call to their numbeers.  And trying to get an authoritative answer
from the ILEC about what charges are to the CLEC's prefix can be _very_ 
difficult.





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