
We have been trying to port out an efax number for one of customers but efax says they do not have to comply as they are not a phone company. XO is the underlying carrier, but they will not accept a Port Out form from our end user, which is not XO's end user. Any experience with this, ideas, or suggestions? Thanks, Eric

Efax and other endpoint services like those call forwarding and receptionist services are not bound by porting rules. I've had success in paying extort(COUGH) fees to get the numbers out, but they don't have to allow it. -- Sent from my iPad On Apr 25, 2011, at 9:08 PM, "Eric Hiller" <clec at cygnustel.com> wrote:
We have been trying to port out an efax number for one of customers but efax says they do not have to comply as they are not a phone company. XO is the underlying carrier, but they will not accept a Port Out form from our end user, which is not XO's end user. Any experience with this, ideas, or suggestions?
Thanks, Eric
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

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 (even if the ITSP spent money to acquire the numbers on an end-customer's behalf or has had that number in inventory for a long time), and that ITSPs must allow and assist with port-outs, even if there are outstanding balances due or other unresolved billing disputes. 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). -- Alex Balashov - Principal Evariste Systems LLC 260 Peachtree Street NW Suite 2200 Atlanta, GA 30303 Tel: +1-678-954-0670 Fax: +1-404-961-1892 Web: http://www.evaristesys.com/ On Apr 26, 2011, at 12:11 AM, Carlos Alvarez <carlos at televolve.com> wrote:
Efax and other endpoint services like those call forwarding and receptionist services are not bound by porting rules. I've had success in paying extort(COUGH) fees to get the numbers out, but they don't have to allow it.
-- Sent from my iPad
On Apr 25, 2011, at 9:08 PM, "Eric Hiller" <clec at cygnustel.com> wrote:
We have been trying to port out an efax number for one of customers but efax says they do not have to comply as they are not a phone company. XO is the underlying carrier, but they will not accept a Port Out form from our end user, which is not XO's end user. Any experience with this, ideas, or suggestions?
Thanks, Eric
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

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

On 04/26/2011 09:20 AM, Jimmy Hess wrote:
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.
The clarification was just that, a clarification of a long standing rule, in the FCC's opinion. What eFax and others are doing is providing a service to an end user, and refusing to allow a number dedicated to the use of an end user to be ported out. FCC's opinion made it clear that the CLEC's obligation to port out was not avoidable just because the CLEC's customer wasn't the end user. They also made it clear that the ITSP was bound directly by LNP rules and could be subjected to penalties just like a CLEC could. Seems like one could make up any number of "excuses" why they're not a phone carrier, or why they really own the number even though it's for someone else's exclusive use, but at the end of the day I strongly doubt any of these rationales would do anything more than antagonize the FCC, and I look forward eagerly to the test cases. -Paul

So what should the next step be, go back to XO and say all of this to them and see if they budge? -Eric On Tue, April 26, 2011 9:07 am, Paul Timmins wrote:
On 04/26/2011 09:20 AM, Jimmy Hess wrote:
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.
The clarification was just that, a clarification of a long standing rule, in the FCC's opinion. What eFax and others are doing is providing a service to an end user, and refusing to allow a number dedicated to the use of an end user to be ported out.
FCC's opinion made it clear that the CLEC's obligation to port out was not avoidable just because the CLEC's customer wasn't the end user. They also made it clear that the ITSP was bound directly by LNP rules and could be subjected to penalties just like a CLEC could.
Seems like one could make up any number of "excuses" why they're not a phone carrier, or why they really own the number even though it's for someone else's exclusive use, but at the end of the day I strongly doubt any of these rationales would do anything more than antagonize the FCC, and I look forward eagerly to the test cases.
-Paul
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

On Tue, Apr 26, 2011 at 11:19 AM, Eric Hiller <clec at cygnustel.com> wrote:
So what should the next step be, go back to XO and say all of this to them and see if they budge?
Good luck. The last time I tried this, XO (and the provider) asserted: - Information Service - Person asserting end-user status not customer of record The FCC indicated that to pursue the complaint a fee would be required - and it wasn't worth it to anyone involved. -jbn

Here's an additional complication I forgot to mention: These services all seem to include "you can't port" into their TOS. At least Efax and Answer Phoenix, the two I researched, do. So not only is our position with the FCC tenuous at best, the customer effectively signed a contract acknowledging that they don't own the numbers. Justin B Newman wrote:
On Tue, Apr 26, 2011 at 11:19 AM, Eric Hiller<clec at cygnustel.com> wrote:
So what should the next step be, go back to XO and say all of this to them and see if they budge?
Good luck. The last time I tried this, XO (and the provider) asserted:
- Information Service - Person asserting end-user status not customer of record
The FCC indicated that to pursue the complaint a fee would be required - and it wasn't worth it to anyone involved.
-jbn _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
-- Carlos Alvarez TelEvolve 602-889-3003

VoicePulse had similar language in their contracts, and it didn't do a thing for them. On 04/26/2011 11:45 AM, Carlos Alvarez wrote:
Here's an additional complication I forgot to mention: These services all seem to include "you can't port" into their TOS. At least Efax and Answer Phoenix, the two I researched, do. So not only is our position with the FCC tenuous at best, the customer effectively signed a contract acknowledging that they don't own the numbers.
Justin B Newman wrote:
On Tue, Apr 26, 2011 at 11:19 AM, Eric Hiller<clec at cygnustel.com> wrote:
So what should the next step be, go back to XO and say all of this to them and see if they budge?
Good luck. The last time I tried this, XO (and the provider) asserted:
- Information Service - Person asserting end-user status not customer of record
The FCC indicated that to pursue the complaint a fee would be required - and it wasn't worth it to anyone involved.
-jbn _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

They are an ITSP, and the FCC ruling trumps the contract. What I'm saying is that there is nothing clear on these non-carrier services, so the contract still has weight. It's clear that Efax and the others are not ITSPs. Last I heard you couldn't port from Google Voice, and they are big enough to make this an issue. Paul Timmins wrote:
VoicePulse had similar language in their contracts, and it didn't do a thing for them.
On 04/26/2011 11:45 AM, Carlos Alvarez wrote:
Here's an additional complication I forgot to mention: These services all seem to include "you can't port" into their TOS. At least Efax and Answer Phoenix, the two I researched, do. So not only is our position with the FCC tenuous at best, the customer effectively signed a contract acknowledging that they don't own the numbers.
Justin B Newman wrote:
On Tue, Apr 26, 2011 at 11:19 AM, Eric Hiller<clec at cygnustel.com> wrote:
So what should the next step be, go back to XO and say all of this to them and see if they budge?
Good luck. The last time I tried this, XO (and the provider) asserted:
- Information Service - Person asserting end-user status not customer of record
The FCC indicated that to pursue the complaint a fee would be required - and it wasn't worth it to anyone involved.
-jbn _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
-- Carlos Alvarez TelEvolve 602-889-3003

What would be interesting would be to have a cooperating carrier do a portout without concurrence, and then let them file a slamming complaint and try to justify that they are the end user. Of course, it'd have to be someone with some big stones. On 04/26/2011 12:28 PM, Carlos Alvarez wrote:
They are an ITSP, and the FCC ruling trumps the contract. What I'm saying is that there is nothing clear on these non-carrier services, so the contract still has weight. It's clear that Efax and the others are not ITSPs. Last I heard you couldn't port from Google Voice, and they are big enough to make this an issue.
Paul Timmins wrote:
VoicePulse had similar language in their contracts, and it didn't do a thing for them.
On 04/26/2011 11:45 AM, Carlos Alvarez wrote:
Here's an additional complication I forgot to mention: These services all seem to include "you can't port" into their TOS. At least Efax and Answer Phoenix, the two I researched, do. So not only is our position with the FCC tenuous at best, the customer effectively signed a contract acknowledging that they don't own the numbers.
Justin B Newman wrote:
On Tue, Apr 26, 2011 at 11:19 AM, Eric Hiller<clec at cygnustel.com> wrote:
So what should the next step be, go back to XO and say all of this to them and see if they budge?
Good luck. The last time I tried this, XO (and the provider) asserted:
- Information Service - Person asserting end-user status not customer of record
The FCC indicated that to pursue the complaint a fee would be required - and it wasn't worth it to anyone involved.
-jbn _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

Porting is a two party process. If the owning carrier does not release the number the port will not go through. On Apr 26, 2011, at 9:58 AM, Paul Timmins wrote:
What would be interesting would be to have a cooperating carrier do a portout without concurrence, and then let them file a slamming complaint and try to justify that they are the end user. Of course, it'd have to be someone with some big stones.
On 04/26/2011 12:28 PM, Carlos Alvarez wrote:
They are an ITSP, and the FCC ruling trumps the contract. What I'm saying is that there is nothing clear on these non-carrier services, so the contract still has weight. It's clear that Efax and the others are not ITSPs. Last I heard you couldn't port from Google Voice, and they are big enough to make this an issue.
Paul Timmins wrote:
VoicePulse had similar language in their contracts, and it didn't do a thing for them.
On 04/26/2011 11:45 AM, Carlos Alvarez wrote:
Here's an additional complication I forgot to mention: These services all seem to include "you can't port" into their TOS. At least Efax and Answer Phoenix, the two I researched, do. So not only is our position with the FCC tenuous at best, the customer effectively signed a contract acknowledging that they don't own the numbers.
Justin B Newman wrote:
On Tue, Apr 26, 2011 at 11:19 AM, Eric Hiller<clec at cygnustel.com> wrote:
So what should the next step be, go back to XO and say all of this to them and see if they budge?
Good luck. The last time I tried this, XO (and the provider) asserted:
- Information Service - Person asserting end-user status not customer of record
The FCC indicated that to pursue the complaint a fee would be required - and it wasn't worth it to anyone involved.
-jbn _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

I don't know the entire porting process from the inside, however, I have been on the receiving side of what seemed like a forced port. I believe a CLEC/ILEC can actually do this, and I agree, it would be awesome to see the results. In my case I had requested a port from one CLEC to another (Cox to Time Warner, PRI to PRI) with about 70 days notice. Cox basically ignored it, and come move time, they had not acted upon it (normal with them, they suck when you try to leave). Around midnight I had a TW NOC tech on the phone and he asked things like "do you own these numbers" and "do you authorize me to do this port without concurrence from your old carrier?" Then he did it instantly. Jed Stafford wrote:
Porting is a two party process. If the owning carrier does not release the number the port will not go through.
On Apr 26, 2011, at 9:58 AM, Paul Timmins wrote:
What would be interesting would be to have a cooperating carrier do a portout without concurrence, and then let them file a slamming complaint and try to justify that they are the end user. Of course, it'd have to be someone with some big stones.
On 04/26/2011 12:28 PM, Carlos Alvarez wrote:
They are an ITSP, and the FCC ruling trumps the contract. What I'm saying is that there is nothing clear on these non-carrier services, so the contract still has weight. It's clear that Efax and the others are not ITSPs. Last I heard you couldn't port from Google Voice, and they are big enough to make this an issue.
Paul Timmins wrote:
VoicePulse had similar language in their contracts, and it didn't do a thing for them.
On 04/26/2011 11:45 AM, Carlos Alvarez wrote:
Here's an additional complication I forgot to mention: These services all seem to include "you can't port" into their TOS. At least Efax and Answer Phoenix, the two I researched, do. So not only is our position with the FCC tenuous at best, the customer effectively signed a contract acknowledging that they don't own the numbers.
Justin B Newman wrote:
On Tue, Apr 26, 2011 at 11:19 AM, Eric Hiller<clec at cygnustel.com> wrote: > So what should the next step be, go back to XO and say all of this > to them > and see if they budge? > Good luck. The last time I tried this, XO (and the provider) asserted:
- Information Service - Person asserting end-user status not customer of record
The FCC indicated that to pursue the complaint a fee would be required - and it wasn't worth it to anyone involved.
-jbn _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
-- Carlos Alvarez TelEvolve 602-889-3003

On 4/26/11 10:10 AM, Carlos Alvarez wrote:
In my case I had requested a port from one CLEC to another (Cox to Time Warner, PRI to PRI) with about 70 days notice. Cox basically ignored it, and come move time, they had not acted upon it (normal with them, they suck when you try to leave). Around midnight I had a TW NOC tech on the phone and he asked things like "do you own these numbers" and "do you authorize me to do this port without concurrence from your old carrier?" Then he did it instantly.
This will almost certainly break calls coming from the old carrier at least temporarily, which may or may not be a big deal. And Cox may take their sweet time routing to the ported numbers if ever. Even when doing a normal port from the ILEC we very frequently run into a situation where they don't pull the numbers from the local switch. Everyone can call the target number except for anyone in the same town who uses the old carrier. -- Jay Hennigan - CCIE #7880 - Network Engineering - jay at impulse.net Impulse Internet Service - http://www.impulse.net/ Your local telephone and internet company - 805 884-6323 - WB6RDV

That's interesting what they did for you. Regarding Google Voice, I believe that we were able to port a number from them about 1.5 years ago. I would have to search the records. They also published back then that they will support LNP. Now that they port cell phone numbers to their service, they should be also releasing numbers as well. I am going to test that soon and let you know.. Oren On Tue, Apr 26, 2011 at 1:10 PM, Carlos Alvarez <carlos at televolve.com> wrote:
I don't know the entire porting process from the inside, however, I have been on the receiving side of what seemed like a forced port. ?I believe a CLEC/ILEC can actually do this, and I agree, it would be awesome to see the results.
In my case I had requested a port from one CLEC to another (Cox to Time Warner, PRI to PRI) with about 70 days notice. ?Cox basically ignored it, and come move time, they had not acted upon it (normal with them, they suck when you try to leave). ?Around midnight I had a TW NOC tech on the phone and he asked things like "do you own these numbers" and "do you authorize me to do this port without concurrence from your old carrier?" ?Then he did it instantly.
Jed Stafford wrote:
Porting is a two party process. If the owning carrier does not release the number the port will not go through.
On Apr 26, 2011, at 9:58 AM, Paul Timmins wrote:
What would be interesting would be to have a cooperating carrier do a portout without concurrence, and then let them file a slamming complaint and try to justify that they are the end user. Of course, it'd have to be someone with some big stones.
On 04/26/2011 12:28 PM, Carlos Alvarez wrote:
They are an ITSP, and the FCC ruling trumps the contract. ?What I'm saying is that there is nothing clear on these non-carrier services, so the contract still has weight. ?It's clear that Efax and the others are not ITSPs. ?Last I heard you couldn't port from Google Voice, and they are big enough to make this an issue.
Paul Timmins wrote:
VoicePulse had similar language in their contracts, and it didn't do a thing for them.
On 04/26/2011 11:45 AM, Carlos Alvarez wrote:
Here's an additional complication I forgot to mention: These services all seem to include "you can't port" into their TOS. At least Efax and Answer Phoenix, the two I researched, do. So not only is our position with the FCC tenuous at best, the customer effectively signed a contract acknowledging that they don't own the numbers.
Justin B Newman wrote: > > On Tue, Apr 26, 2011 at 11:19 AM, Eric Hiller<clec at cygnustel.com> > ?wrote: >> >> So what should the next step be, go back to XO and say all of this >> to them >> and see if they budge? >> > Good luck. The last time I tried this, XO (and the provider) > asserted: > > - Information Service > - Person asserting end-user status not customer of record > > The FCC indicated that to pursue the complaint a fee would be > required > - and it wasn't worth it to anyone involved. > > -jbn > _______________________________________________ > VoiceOps mailing list > VoiceOps at voiceops.org > https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
-- Carlos Alvarez TelEvolve 602-889-3003
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

Per the FCC 1 day port order, the medium timer in NPAC is set to 24 hours, at least according to my memory (my computer's misbehaving so I can't get in to verify that). If you create the SV, and it is not put in conflict within 24 hours by the losing carrier, you can port without concurrence. There's nothing illegal, or immoral about doing it, it's just bypassing the industry process, and in general if you're going to do that, you'd better be right. Otherwise you're looking for trouble, and your customer might still get bills from their old carrier because they won't realize they've been ported out. Of course, if the losing carrier has their OSS systems integrated with the NPAC, their system will likely place the order in conflict as soon as you create it (hi, AT&T) unless you have a valid FOC on an LSR with a matching due date. But even carriers like XO aren't integrated this way typically, so you can take numbers away rather simply. -Paul On 04/26/2011 01:10 PM, Carlos Alvarez wrote:
I don't know the entire porting process from the inside, however, I have been on the receiving side of what seemed like a forced port. I believe a CLEC/ILEC can actually do this, and I agree, it would be awesome to see the results.
In my case I had requested a port from one CLEC to another (Cox to Time Warner, PRI to PRI) with about 70 days notice. Cox basically ignored it, and come move time, they had not acted upon it (normal with them, they suck when you try to leave). Around midnight I had a TW NOC tech on the phone and he asked things like "do you own these numbers" and "do you authorize me to do this port without concurrence from your old carrier?" Then he did it instantly.
Jed Stafford wrote:
Porting is a two party process. If the owning carrier does not release the number the port will not go through.
On Apr 26, 2011, at 9:58 AM, Paul Timmins wrote:
What would be interesting would be to have a cooperating carrier do a portout without concurrence, and then let them file a slamming complaint and try to justify that they are the end user. Of course, it'd have to be someone with some big stones.
On 04/26/2011 12:28 PM, Carlos Alvarez wrote:
They are an ITSP, and the FCC ruling trumps the contract. What I'm saying is that there is nothing clear on these non-carrier services, so the contract still has weight. It's clear that Efax and the others are not ITSPs. Last I heard you couldn't port from Google Voice, and they are big enough to make this an issue.
Paul Timmins wrote:
VoicePulse had similar language in their contracts, and it didn't do a thing for them.
On 04/26/2011 11:45 AM, Carlos Alvarez wrote:
Here's an additional complication I forgot to mention: These services all seem to include "you can't port" into their TOS. At least Efax and Answer Phoenix, the two I researched, do. So not only is our position with the FCC tenuous at best, the customer effectively signed a contract acknowledging that they don't own the numbers.
Justin B Newman wrote: > On Tue, Apr 26, 2011 at 11:19 AM, Eric > Hiller<clec at cygnustel.com> wrote: >> So what should the next step be, go back to XO and say all of this >> to them >> and see if they budge? >> > Good luck. The last time I tried this, XO (and the provider) > asserted: > > - Information Service > - Person asserting end-user status not customer of record > > The FCC indicated that to pursue the complaint a fee would be > required > - and it wasn't worth it to anyone involved. > > -jbn > _______________________________________________ > VoiceOps mailing list > VoiceOps at voiceops.org > https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

Hahaha, 24 hour LNP, where fantasy fails to meet reality. But anyway another problem of the losing carrier not realizing they lost the number is that they keep routing it internally. That means anyone on that carrier can no longer call the number. This is getting bad, to where we run into it at least once a month. Paul Timmins wrote:
Per the FCC 1 day port order, the medium timer in NPAC is set to 24 hours, at least according to my memory (my computer's misbehaving so I can't get in to verify that).
If you create the SV, and it is not put in conflict within 24 hours by the losing carrier, you can port without concurrence.
There's nothing illegal, or immoral about doing it, it's just bypassing the industry process, and in general if you're going to do that, you'd better be right. Otherwise you're looking for trouble, and your customer might still get bills from their old carrier because they won't realize they've been ported out.
Of course, if the losing carrier has their OSS systems integrated with the NPAC, their system will likely place the order in conflict as soon as you create it (hi, AT&T) unless you have a valid FOC on an LSR with a matching due date. But even carriers like XO aren't integrated this way typically, so you can take numbers away rather simply.
-Paul
On 04/26/2011 01:10 PM, Carlos Alvarez wrote:
I don't know the entire porting process from the inside, however, I have been on the receiving side of what seemed like a forced port. I believe a CLEC/ILEC can actually do this, and I agree, it would be awesome to see the results.
In my case I had requested a port from one CLEC to another (Cox to Time Warner, PRI to PRI) with about 70 days notice. Cox basically ignored it, and come move time, they had not acted upon it (normal with them, they suck when you try to leave). Around midnight I had a TW NOC tech on the phone and he asked things like "do you own these numbers" and "do you authorize me to do this port without concurrence from your old carrier?" Then he did it instantly.
Jed Stafford wrote:
Porting is a two party process. If the owning carrier does not release the number the port will not go through.
On Apr 26, 2011, at 9:58 AM, Paul Timmins wrote:
What would be interesting would be to have a cooperating carrier do a portout without concurrence, and then let them file a slamming complaint and try to justify that they are the end user. Of course, it'd have to be someone with some big stones.
On 04/26/2011 12:28 PM, Carlos Alvarez wrote:
They are an ITSP, and the FCC ruling trumps the contract. What I'm saying is that there is nothing clear on these non-carrier services, so the contract still has weight. It's clear that Efax and the others are not ITSPs. Last I heard you couldn't port from Google Voice, and they are big enough to make this an issue.
Paul Timmins wrote:
VoicePulse had similar language in their contracts, and it didn't do a thing for them.
On 04/26/2011 11:45 AM, Carlos Alvarez wrote: > Here's an additional complication I forgot to mention: These > services > all seem to include "you can't port" into their TOS. At least > Efax and > Answer Phoenix, the two I researched, do. So not only is our > position > with the FCC tenuous at best, the customer effectively signed a > contract acknowledging that they don't own the numbers. > > > Justin B Newman wrote: >> On Tue, Apr 26, 2011 at 11:19 AM, Eric >> Hiller<clec at cygnustel.com> wrote: >>> So what should the next step be, go back to XO and say all of this >>> to them >>> and see if they budge? >>> >> Good luck. The last time I tried this, XO (and the provider) >> asserted: >> >> - Information Service >> - Person asserting end-user status not customer of record >> >> The FCC indicated that to pursue the complaint a fee would be >> required >> - and it wasn't worth it to anyone involved. >> >> -jbn >> _______________________________________________ >> VoiceOps mailing list >> VoiceOps at voiceops.org >> https://puck.nether.net/mailman/listinfo/voiceops >
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
-- Carlos Alvarez TelEvolve 602-889-3003

On 04/26/2011 01:35 PM, Carlos Alvarez wrote:
Hahaha, 24 hour LNP, where fantasy fails to meet reality.
But anyway another problem of the losing carrier not realizing they lost the number is that they keep routing it internally. That means anyone on that carrier can no longer call the number. This is getting bad, to where we run into it at least once a month.
The proper solution would be for them to do LRN dips on every outgoing call regardless of whether the number is presumably on-net, but it's understandable that they may not want to do that for cost reasons. And without the OSS+NPAC integration Paul referenced, it's pretty hard to stay on top of the on-net routing table fastidiously enough to not let port-outs--let alone stealth port-outs--slip through the cracks. -- Alex Balashov - Principal Evariste Systems LLC 260 Peachtree Street NW Suite 2200 Atlanta, GA 30303 Tel: +1-678-954-0670 Fax: +1-404-961-1892 Web: http://www.evaristesys.com/

On 04/26/2011 01:06 PM, Jed Stafford wrote:
Porting is a two party process. If the owning carrier does not release the number the port will not go through.
No, that's not true. There is a concurrence window in which the donor carrier can deny the port, but without an explicit response, the port can still go through. It's just that in many cases this is considered poor form without a heads up, and porting people at various carriers generally have a system for dealing with these issues. -- Alex Balashov - Principal Evariste Systems LLC 260 Peachtree Street NW Suite 2200 Atlanta, GA 30303 Tel: +1-678-954-0670 Fax: +1-404-961-1892 Web: http://www.evaristesys.com/

"Sure" is difficult with these gray and changing topics. The company trying to port to us was a law firm, so they researched it. They are not a telecom-specific firm, but I assume they know how to research law in general. They brought up the ITSP rule and the company holding the number (a local answering/forwarding company similar to Google Voice) said they are not an ITSP nor transporting calls, they are the end user. The lawyers could find no clear way around that. A test case is probably needed. Speaking of all this, what's the port-out situation with Google Voice? Alex Balashov 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 (even if the ITSP spent money to acquire the numbers on an end-customer's behalf or has had that number in inventory for a long time), and that ITSPs must allow and assist with port-outs, even if there are outstanding balances due or other unresolved billing disputes.
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).
-- Alex Balashov - Principal Evariste Systems LLC 260 Peachtree Street NW Suite 2200 Atlanta, GA 30303 Tel: +1-678-954-0670 Fax: +1-404-961-1892 Web: http://www.evaristesys.com/
On Apr 26, 2011, at 12:11 AM, Carlos Alvarez<carlos at televolve.com> wrote:
Efax and other endpoint services like those call forwarding and receptionist services are not bound by porting rules. I've had success in paying extort(COUGH) fees to get the numbers out, but they don't have to allow it.
-- Sent from my iPad
On Apr 25, 2011, at 9:08 PM, "Eric Hiller"<clec at cygnustel.com> wrote:
We have been trying to port out an efax number for one of customers but efax says they do not have to comply as they are not a phone company. XO is the underlying carrier, but they will not accept a Port Out form from our end user, which is not XO's end user. Any experience with this, ideas, or suggestions?
Thanks, Eric
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participants (9)
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abalashov@evaristesys.com
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carlos@televolve.com
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clec@cygnustel.com
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jay@west.net
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jedsta@gmail.com
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justin@ejtown.org
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mysidia@gmail.com
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orenyny@gmail.com
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paul@timmins.net