On Tue, Apr 26, 2011 at 12:17 AM, Alex Balashov <abalashov at evaristesys.com> wrote:
Are you sure? The FCC was pretty firm in its 2007 clarification that ITSPs do not own numbers, but that logical end-customers own numbers I am guessing, however, that an inbound-only application provider like Efax is not considered an ITSP. ?However, there is precedent for an end-customer forcing a hosted IVR company to allow a port-out (though I don't know to what extent regulatorily enshrined).
You would need to raise the issue with the regulators, for an official determination, assuming you exhausted all options for escalation with the existing service provider, and the SP doesn't offer any additional services the customer could buy that are "obviously" subject to porting rules. The clarification the FCC made in 2007 was referring specifically to interconnected VoIP providers at the time; there was no clear mention of information service providers that utilize dedicated phone numbers to deliver other data services. The FCC could of course take action to revise the rules; they could also consider requiring e-mail service providers provide Local "E-mail address portability" again. Some fax receiving/voicemail services might not technically match the definition of interconnected VoIP provider under the 47 cfr ; if they either do not enable real-time two-way voice communication, or if they do not require a broadband internet connection, require special CPE gear, or if they don't permit the user to both originate and terminate PSTN calls. Which is a pretty strict definition. A Telco lawyer might be able to say otherwise, but it would seem that if they are not interconnected VoIP providers, and they are not telco carriers, they could at least make a very good argument that the current porting rules don't address them. -- -JH