Thread Subject: Re: Background on what is covered by Sec. 255 Rules
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From: Gregg Vanderheiden
Date: Wed, Dec 12 2007 11:05 PM
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Here is my crack at it. Karen may have a more authoritative knowledge on
this but here is my understanding.
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Peter Korn
> This suggests that a computer-to-computer free service like
> Skype wouldn't be considered a "Telecommunications Service"
> by the 1996 Telecom Act, although the Skype-Out service
> (which they charge for) would be considered a
> "Telecommunications Service".
Actually, the FCC declared anything over Internet as info service and not
telecom (even though the Internet - the whole Internet - would otherwise
meet the definition of telecom).
So Skype and all other internet based systems are not telecom
However, the FCC has now ruled that VoIP systems that are interconnected
with the PSTN are to follow telecom access rules.
So it is complicated. The VoIP systems aren't telecom but they are
covered by telecom regs.
PS don't use Skype as an example because for some reason I don't think they
are covered (yet) even thought they connect to PSTN through Skype out.
> > 2. Any manufacturer of telecommunications equipment or customer
> > premises equipment ( 47 CFR 6.1)
> > - Definition of Telecommunications equipment-
> > equip is equipment used by a carrier to provide telecommunication
> > service
> > - CPE - equipment employed on the premises of a person
> other than
> > a carrier to originate, route or terminate telecommunications.
> I don't see a definition of "carrier" (unless it is someone
> who provides a "Telecommunications Service", so it isn't
> clear to me whether I should consider software like Skype
> "telecommunications equipment"/"CPE" or not. Also, said
> software can be used (as I noted) for free calls as well as
> for paid calls (SkypeOut), with the only change being whether
> the use has become a customer or not, and of course server
> Thoughts on this anyone?
See above. Use a different provider than Skype. It is confusing right
> > 3. Any telecommunications carrier (47 CFR 6.1)
> > 4. Any provider of interconnected VOIP service (47 CFR 6.1)
> > 5. Any manufacturer of equipment or CPE specifically
> designed to
> > provide VOIP (47 CFR 6.1)
> Again, does it matter here whether said VOIP is
> interconnected or not?
> If I design VOIP software that does not interconnect with
> POTS, then am I still a "manufacturer" under this?
You would not be "interconnected VoIP". But you couldn't make any phone
calls to PSTN phones either.
Also - when PSTN goes away they will have to redefine all this again.
> > 6. Any provider of voicemail or interactive menu service (part
> > 7.1)
> > 7. Any manufacturer of telecommunications equipment or
> CPE which
> > performs a voicemail or interactive menu function (part 7.1)
> Again for #6 and #7, does it matter if this is interconnected
> to POTS or not?
No - these are definitions of telecom. So VoIP that is interconnected is
not telecom but is covered.
And if it isn't interconnected it would not be covered by the current FCC
ruling. But may be under future rulings as things change.
And of course these are all covered under 508 and maybe even under ADA for
> > II. Covered Functions
> > 1. Part 6.11 and 7.11 Information, documentation and training
> > - "Manufacturers and service providers shall ensure access to
> > information and documentation it provides to its customers,
> if readily
> > achievable. Such information and documentation included
> user guides,
> > bills, installation guides for end-user installable devices, and
> > product support communications, regarding both the product
> in general
> > and the accessibility features.."
> > 2. "An entity that provides both
> > telecommunications services and
> > non-telecommunications services, however, is subject to section 255
> > only to the extent that it provides a telecommunications service"
> > (September 1999 255 Order, paragraph 80.)
> > 3. "In connection with multipurpose equipment, we adopt our
> > tentative conclusion that CPE is covered by section 255 only to the
> > extent that it provides a telecommunications function." (September
> > 1999 255 Order, paragraph 87)
> OK, this seems to help in the Skype canonical case (assuming
> that "telecommunications function" mirrors
> "telecommunications service" and only kicks in when a fee to
> the public is involved) - suggesting that
> 255 only applies only at that point to CPE.
> I'm using Skype as the well-known example, but there are
> plenty of other software voice products/offerings (e.g.
> GoogleTalk, Windows Messenger, Apple's video conferencing,
> Ekiga) - all of which are computer to computer and generally free.
I don't think it is the FREE part that triggers it. It is the
'interconnected to PSTN' part.
> Peter Korn
> Accessibility Architect,
> Sun Microsystems, Inc.
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