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Notes: VoIP |
In order to formulate an informed, consistent regulatory policy, the
Commission would like to obtain information about VOIP activity in Michigan
. The Commission, therefore, requests comments on VOIP activity in Michigan
on the following topics that may be affected by both state and federal
law:
...
e. Whether VOIP providers may participate in, and have access to, the
federal Universal Service Fund (USF) to provide service to rural areas,
hospitals, and schools; the ability of VOIP carriers to provide low-cost
service similar to Lifeline and Link-up for low-income end users; and the
need for VOIP end-users to contribute to the federal USF.
-- -- U-14073 - Commission's Own Motion (investigation of VOIP) - (MI
PUC 3/16/2004 ) HTML
| PDF
Should VoIP providers and their subscribers contribute to the Universal
Service Fund that assists low income consumers, schools and libraries with
obtaining affordable telephone services? If not, will migration of customers
from traditional telephone services to VoIP providers either reduce the
funds available for USF programs or increase the burden on non-VoIP customers?
Should VoIP providers and their subscribers contribute to similar state-operated
programs, such as New York’s Targeted Accessibility Fund (which
assists consumers with hearing and other physical disabilities)... Should
VoIP providers contribute to state funds that support telephone regulatory
agencies or pay state and local taxes on intrastate services provided to
subscribers? How should jurisdictional allocation of VoIP services be identified
and reported?
---In Re Vonage Holding Company Petition
for a Declaratory Ruling Concerning the Order of the Minnesota PUC, WC
Docket No. 03-211, Comments
of the NY AG (Nov. 21, 2003)
1. an accelerated consumer transition from services subject to access charges, such as toll services, to VoIP services.-- Order instituting investigation on the Commission's own motion to determine the extent to which the public utility telephone service known as Voice over Internet Protocol should be exempted from regulatory requirements, CA PUC February 11, 2004 http://www.cpuc.ca.gov/published/agenda_decision/33960.htm
2. a diminution of access and toll revenues, thereby reducing regulated revenues.
3. increases in regulated service prices, such as basic service, to offset regulated revenue reductions.
4. steep increases in public program surcharges to ensure basic telephone service is affordable in rural, high-cost areas of the state, because these customers cannot afford broadband connectivity or are currently beyond the reach of broadband networks.
10. One final word on this subject: now that this commission has backed
off on regulating VoIP - at least until the FCC acts - VoIP providers should
seek free market solutions to intercarrier compensation and 911 service
issues. When a VoIP call touches the Publicly Switched Telephone
Network, there should be compensation to the network owner - at a rate
agreed to by willing market participants. Resolving the 911-service
issue is even more important. VoIP providers should not have to worry
that agreeing to contract with a Basic Emergency Service Provider (in Colorado,
Qwest) to offer customary 911 services will somehow suck it into regulation,
at least in this state. I strongly encourage VoIP providers to work
out 911-service and intercarrier compensation agreements, to show that
they are good corporate citizens. And to show that traditional regulation
is not necessary.
--In The Matter Of The Investigation Into Voice Over Internet Protocol
(Voip) Services, Docket No. 03M-220T, Order
Closing Docket ¶ 8 ( Colorado PUC Dec. 17, 2003) (Chairman Gregory
E. Sopkin Specially Concurring)
In order to formulate an informed, consistent regulatory policy, the
Commission would like to obtain information about VOIP activity in Michigan
. The Commission, therefore, requests comments on VOIP activity in Michigan
on the following topics that may be affected by both state and federal
law:
...
f. VOIP services' effect on the current access charge structure.
-- -- U-14073 - Commission's Own Motion (investigation of VOIP) - (MI
PUC 3/16/2004 ) HTML
| PDF
See also FCC 911 solution Summit March 28, 2004 real audio | Powerpoint Presentation of Prof. Henning Schulzrinne, Department of Computer Science, Columbia University, New York.
42. As discussed above, we preempt the Minnesota Vonage Order because it imposes entry and other requirements on Vonage that impermissibly interfere with this Commission’s valid exercise of authority. As Vonage indicates in its Petition, Minnesota includes as one of its entry conditions the approval of a 911 service plan “comparable to the provision of 911 service by the [incumbent] local exchange carrier.” 145 In the Minnesota Vonage Order, the Minnesota Commission specifically subjected Vonage to this requirement. 146 Because Minnesota inextricably links pre-approval of a 911 plan to becoming certificated to offer service in the state, the application of its 911 requirements operates as an entry regulation. Vonage explains that there is no practicable way for it to comply with this requirement: it cannot today identify with sufficient accuracy the geographic location of a caller, and it has not obtained access in all cases to incumbent LEC E911 trunks that carry calls to specialized operators at public safety answering points (PSAPs). 147 Under the Minnesota “telephone company” rules, therefore, this requirement bars Vonage from entry in Minnesota . To that extent, this requirement is preempted along with all other entry requirements contained in Minnesota ’s “telephone company” regulations as applied to DigitalVoice. 148 Although we preempt Minnesota from imposing its 911 requirements on Vonage as a condition of entry, this does not mean that Vonage should cease the efforts it has undertaken to date and we understand is continuing to take both to develop a workable public safety solution for its DigitalVoice service and to offer its customers equivalent access to emergency services.
43. There is no question that innovative services like DigitalVoice are having a profound and beneficial impact on American consumers.149 While we do not agree with unnecessary economic regulation of DigitalVoice designed for different services, we do believe that important social policy issues surrounding services like DigitalVoice should be considered and resolved.150 Access to emergency services, a critically important public safety matter, is one of these important social policy issues. In this proceeding, Vonage has indicated that it is devoting substantial resources toward the development of standards and technology necessary to facilitate some type of 911 service, working cooperatively with Minnesota agencies and other state commissions, public safety officials and PSAPs, the National Emergency Number Association (NENA), and the Association of Public-Safety Communications Officials (APCO).151 Moreover, it has demonstrated that it is offering its version of 911 capability to all its customers, including those in Minnesota, and has provided us information indicating what actions its customers must take to activate this 911 capability.152 We are also aware that Vonage recently announced the successful completion of an E911 trial in Rhode Island, a state that has not, to our knowledge, attempted to regulate DigitalVoice. In collaboration with the State of Rhode Island, Vonage has developed a technical solution to deliver a caller’s location and call back number to emergency service personnel for 911 calls placed in that state by DigitalVoice users.153 We fully expect Vonage to continue its 911 development efforts and to continue to offer some type of public safety capability during the pendency of our IP-Enabled Services Proceeding.154
44. We emphasize that while we have decided the jurisdictional question for Vonage’s DigitalVoice here, we have yet to determine final rules for the variety of issues discussed in the IP-Enabled Services Proceeding. While we intend to address the 911 issue as soon as possible, perhaps even separately, we anticipate addressing other critical issues such as universal service, intercarrier compensation, section 251 rights and obligations,155 numbering, disability access, and consumer protection in that proceeding. 156
45. Furthermore, we acknowledge that a U.S. District Court in New York has recently ordered Vonage “to continue to provide the same emergency 911 calling services currently available to Vonage customers” within that state157 and to “make reasonable good faith efforts to participate on a voluntary basis” in workshops pertaining to the development of VoIP 911 calling capabilities.158 Because DigitalVoice is a national service for which Vonage cannot single out New York “intrastate” calls (any more than it can Minnesota “intrastate” calls), as a practical matter, the District Court’s order reaches DigitalVoice wherever it is used.159 Thus, we need not be concerned that as a result of our action today, Vonage will cease its efforts to continue developing and offering a public safety capability in Minnesota. The District Court order ensures that these efforts must continue while we work cooperatively with our state colleagues and industry to determine how best to address 911/E911-type capabilities for IP-enabled services in a comprehensive manner in the context of our IP-Enabled Services Proceeding.160
145See Vonage Petition at 25 (citing Minn. Rule § 7812.0550 subp. 1).
146See Minnesota Vonage Order at 8.
147See Vonage Petition at 8-9, 24-25.
148See supra paras. 20- 22 (explaining preemption of entry requirements). Indeed, Vonage notes in its petition that “[I]f the Commission preempts Minnesota’s certificate requirement . . . this issue [911 comparability to an incumbent LEC] will be moot.” See Vonage Petition at 25. Similarly, to the extent the Minnesota Commission demands payment of 911 fees as a condition of entry, that requirement is preempted.
149See VON Coalition Aug. 19 Ex Parte Letter at 4.
150 As explained above, these issues are currently being considered in pending proceedings before this Commission. See supra note 46. See also, e.g., Minnesota Commission Comments at 4; Surewest Comments at 12; Texas 911 Agencies Comments at 2-3 (urging the Commission to consider public safety issues related to VoIP services).
151 See NENA Reply at 1-2; Vonage Aug. 13 Ex Parte Letter at 1-2; Minnesota Statewide 911 Program Comments at 4.
152 In offering its “911” capability to its customers, Vonage has provided the Commission information regarding how and what it tells its customers about its limited 911 capabilities such that its customers are fully aware of those limitations when they subscribe to the service and clearly understand that it is not a comparable emergency service to the 911 capability they obtain with local exchange service. We fully expect Vonage to continue providing customers information such as this about its “911” capability. See Vonage Oct. 1 Ex Parte Letter at 3-4 & Exhibit 10.
153 See Letter from William B. Wilhelm, Jr. and Ronald W. Del Sesto, Jr., Counsel for Vonage, to Marlene H. Dortch, Secretary, FCC, WC Docket Nos. 03-211, 04-36, at 1 (filed Oct. 14, 2004).
154 We look beyond Vonage’s efforts of today, however, toward work that remains to be done in the area of 911 and the opportunities that this new technology presents for public safety. To that end, we are aware of the six principles NENA has advanced: (1) establish a national E911 VoIP policy; (2) encourage vendor and technology neutral solutions and innovation; (3) retain consumer service quality expectations; (4) support dynamic, flexible, open architecture system design process for 911; (5) develop policies for 911 compatible with the commercial environment for IP communications; and (6) promote a fully funded 911 system. See National Emergency Number Association, E9-1-1, Internet Protocol & Emergency Communications, Press Release ( Mar. 22, 2004). We applaud NENA’s vision in establishing these principles to support a process to “promote a fully functional 9-1-1 system that responds any time, anywhere from every device.” See id.. We endorse these principles because they provide a sound blueprint for the development of a national 911 solution for VoIP services and we encourage all VoIP providers and industry participants to work toward their realization.
155 We note that nothing in this Order addressing the Commission’s jurisdictional determination of or regulatory treatment of particular retail IP-enabled services impacts competitive LEC access to the underlying facilities on which such retail services ride. See Letter from Jason D. Oxman, General Counsel, Association for Local Telecommunications Services, to Marlene Dortch, Secretary, FCC, WC Docket Nos. 04-29, 04-36 (filed Nov. 2, 2004).
156 See supra note 46.
157 See New York Preliminary Injunction at 3. We note that Vonage’s “emergency 911 calling service” is not a service that is provided pursuant to the New York Commission’s rules or any other state commission’s rules. This is a service Vonage has voluntarily undertaken in response to consumer demand.
158 See New York Preliminary Injunction at 4.
159 We recognize that Vonage’s 911 capability relies on the cooperation of its customers in accurately registering and re-registering their user location when they move about with the service.
160 See IP-Enabled Services Proceeding, 19 FCC Rcd at 4897-901, paras. 51-57.
Vonage Holdings Corporation Petition for Declaratory Ruling Concerning an Order of the Minnesota Public Utilities Commission, WC Docket No. 03-211, Memorandum Opinion and Order (FCC Nov. 12, 2004)
Impact of IP Telephony on Public Safety: In California, years of state funded improvements have been made to 911 service to enable telecommunications providers and first responders to ensure the safety of California customers. In addition, law enforcement utilizes its right under federal law to monitor telecommunications services to combat criminal activity. Exempting VoIP providers from regulation raises concerns about public safety and law enforcement activities in local communities. On the other hand, VoIP technologies offer the possibility to provide more detailed emergency information about some user locations, e.g. PBX users, than available with current technology.
-- Order instituting investigation on the Commission's own motion to determine the extent to which the public utility telephone service known as Voice over Internet Protocol should be exempted from regulatory requirements, CA PUC February 11, 2004
10. One final word on this subject: now that this commission has backed off on regulating VoIP - at least until the FCC acts - VoIP providers should seek free market solutions to intercarrier compensation and 911 service issues. When a VoIP call touches the Publicly Switched Telephone Network, there should be compensation to the network owner - at a rate agreed to by willing market participants. Resolving the 911-service issue is even more important. VoIP providers should not have to worry that agreeing to contract with a Basic Emergency Service Provider (in Colorado, Qwest) to offer customary 911 services will somehow suck it into regulation, at least in this state. I strongly encourage VoIP providers to work out 911-service and intercarrier compensation agreements, to show that they are good corporate citizens. And to show that traditional regulation is not necessary.
--In The Matter Of The Investigation Into Voice Over Internet Protocol (Voip) Services, Docket No. 03M-220T, Order Closing Docket ¶ 8 ( Colorado PUC Dec. 17, 2003) (Chairman Gregory E. Sopkin Specially Concurring)
In order to formulate an informed, consistent regulatory policy, the Commission would like to obtain information about VOIP activity in Michigan . The Commission, therefore, requests comments on VOIP activity in Michigan on the following topics that may be affected by both state and federal law:
. . .
d. Access to emergency calling, including VOIP end users' unrestricted access to 9-1-1 , non-carrier charges for 9-1-1 access, and public safety answering points costs to geographically locate VOIP callers and provide a call back number.
. . .
g. The ability of VOIP services to provide abbreviated dialing (2-1-1, 3-1-1, 4-1-1, 7-1-1) programs and toll-free dialing (1+800) to end users.
-- -- U-14073 - Commission's Own Motion (investigation of VOIP) - (MI PUC 3/16/2004 ) HTML | PDF
Should VoIP subscribers pay state and local emergency 911/E-911 surcharges since they make use of emergency response services.... Can VoIP providers provide subscribers with E911/911emergency service that is equivalent to that provided by traditional local exchange carriers? If not, what level of E911/911 emergency service is adequate to protect the health and safety of VoIP subscribers and others 22 who may use their telephones in an emergency?
-- In Re Vonage Holding Company Petition for a Declaratory Ruling Concerning the Order of the Minnesota PUC, WC Docket No. 03-211, Comments of the NY AG (Nov. 21, 2003)
In order to formulate an informed, consistent regulatory policy, the
Commission would like to obtain information about VOIP activity in Michigan
. The Commission, therefore, requests comments on VOIP activity in Michigan
on the following topics that may be affected by both state and federal
law:
...
h. Other technical issues, such as internet virus potential, power
outage risks, consumer protections including privacy, quality of service,
and accessibility by local, state and federal law enforcement.
-- -- U-14073 - Commission's Own Motion (investigation of VOIP) - (MI
PUC 3/16/2004 ) HTML
| PDF
"12. . . . Section 102(8)(C) of the definition specifically excludes information services, and the legislative history makes clear that CALEA does not apply to private network services:
"Telecommunications Services that support the transport or switching of commmunications for private networks or for the sole purpose of interconnecting telecommunications carriers . . . need not meet any wiretap standards. PBXs are excluded. So are automated teller machine (ATM) networks and other closed networks. Also excluded from coverage are all information services, such as Internet service providers or services such as prodigy or America Online."
13. We also conclude that CALEA's definitions of "telecommunications carriers" and "information services" were not modified by the 1996 Act, and that the CALEA definitions therefore remain in force for purposes of CALEA.
. . .
27. Where facilities are used solely to provide an information service, whether offered by an exclusively-IS provider or a common carrier that has established a dedicated IS-system apart from the telecommunications system, we find that such facilities are not subject to CALEA. Where facilities are used to provide both telecommunications and information services, however, such joint-use facilities are subject to CALEA in order to ensure the ability to surveil the telecommunications services.
-- In the matter of Communications Assistance for Law Enforcement Act, CC Docket 97-213, Second Report and Order, (August 31, 1999)
In order to formulate an informed, consistent regulatory policy, the
Commission would like to obtain information about VOIP activity in Michigan
. The Commission, therefore, requests comments on VOIP activity in Michigan
on the following topics that may be affected by both state and federal
law:
...
h. Other technical issues, such as internet virus potential, power
outage risks, consumer protections including privacy, quality of service,
and accessibility by local, state and federal law enforcement.
-- -- U-14073 - Commission's Own Motion (investigation of VOIP) - (MI
PUC 3/16/2004 ) HTML
| PDF
C. State and Federal Law Enforcement Needs Must Be Safeguarded
The implications of Vonage’s and other VoIP offerings for
federal agencies’ law enforcement and national security activities
were well presented in the DOJ-FBI joint filing. Carrier compliance with
statutory requirements for telecommunications providers to cooperate
with lawful governmental investigatory efforts to monitor calls and
capture relevant call routing and other data is also critically important
to investigations conducted by state and local prosecutors and police.
For example, the NYSAG’s Organized Crime Task Force has devoted
substantial effort and capital to access facilities of numerous local
exchange carriers and wireless carriers to effect its investigations of
major crimes. State and local law enforcement activities would be compromised
if the FCC does not require Vonage and other VoIP providers to comply with
the Communications Assistance for Law Enforcement Act.
--In Re Vonage Holding Company Petition
for a Declaratory Ruling Concerning the Order of the Minnesota PUC, WC
Docket No. 03-211, Comments
of the NY AG (Nov. 21, 2003)
E.g., New York requires carriers to participate in the Public Service
Commission's customer dispute resolution programs, and to suspend termination
of service for nonpayment of amounts in dispute until the matter is resolved.
16 New York Code Rules and Regulations ("NYCRR") § 633.16 and Part
12. Vonage's customer agreement denies subscribers such protections, and
instead requires binding commercial arbitration which may cost consumers
more than the amount in dispute. Vonage Customer Agreement ¶ 6.1.
Vonage's Customer Agreement asserts the provider's right to terminate service
at any time if its charges are not paid in full.
Vonage Customer Agreement ¶ 4.3. New York also requires carriers
to provide consumers a minimum suspension/termination notice period and
prevents termination of service to customers with medical emergencies.
16 NYCRR §§ 633.4 - 633.8.
-- In re Vonage Holdings Corporation Petition for Declaratory Ruling
Concerning an Order of the Minnesota Public Utilities Commission, WC Docket
No. 03-211, Reply Comments Of Eliot Spitzer Attorney General Of The State
Of New York n. 21 (November 21, 2003) http://www.oag.state.ny.us/telecommunications/filings/fcc_vonage_voip_petition.pdf
In order to formulate an informed, consistent regulatory policy, the
Commission would like to obtain information about VOIP activity in Michigan
. The Commission, therefore, requests comments on VOIP activity in Michigan
on the following topics that may be affected by both state and federal
law:
...
h. Other technical issues, such as internet virus potential, power
outage risks, consumer protections including privacy, quality of service,
and accessibility by local, state and federal law enforcement.
-- -- U-14073 - Commission's Own Motion (investigation of VOIP) - (MI
PUC 3/16/2004 ) HTML
| PDF
Although Vonage presents its DigitalSmart S M service as a substitute
for traditional local and long distance telephone service, 18 there are
a number of significant differences between the service Vonage provides
and the service local exchange carriers are required to provide in New
York and other states. If VoIP providers are classified as information
services or otherwise exempted by the FCC from state regulatory requirements,
then their VoIP subscribers may be denied some or all of the following
list of customer protections.
Should VoIP providers be required to facilitate communications with
consumers having hearing or other physical disabilities that require use
of telephone relay or other special services?
Should VoIP providers be required to provide subscribers optional blocking
of pay-per- call services 19 and non-telecommunications services to prevent
such charges from being incurred
Should VoIP providers be required to provide subscribers optional blocking
of caller-ID service to restrict access to their telephone numbers as some
states’ regulations require of other providers? 20
How would classification of VoIP as either a telecommunications service
or an information service affect VoIP providers’ obligation to
comply with various state statutory and regulatory consumer protection
policies?
. . .
What level of minimum telephone service quality standards should be
applied to VoIPWhat level of minimum telephone service quality standards
should be applied to VoIP providers given the differing technologies among
VoIP providers and their distinctions from
traditional switched telephone services? 23
What procedures should VoIP providers be required to follow to facilitate
smooth migration of customers between VoIP and non-VoIP providers to ensure
that customers do not lose dial tone in the process? 24
Furthermore, where a VoIP carrier goes out of business or leaves a
particular market, what protections should apply to facilitate transfer
of all its subscribers to new providers without service interruption? 2
-- In Re Vonage Holding Company Petition
for a Declaratory Ruling Concerning the Order of the Minnesota PUC, WC
Docket No. 03-211, Comments
of the NY AG (Nov. 21, 2003)
78. We decline to expand the meaning
of "telecommunications services" to include information services for purposes
of section 255, as urged by some commenters. In the NPRM, we recognized
that under our interpretation of these terms, some important and widely
used services, such as voicemail and electronic mail, would fall outside
the scope of section 255 because they are considered information services.
We conclude, however, that we may not reinterpret the definition of telecommunications
services, either for purposes of section 255 only or for all Title II regulation.
First, we emphasize that the term "information services" is defined separately
in the Act. As we noted in the NPRM, there was no indication in
the legislative history of the 1996 Act that Congress intended these terms
to have any different, specialized meaning for purposes of accessibility.
79. Furthermore, in a Report
to Congress that was released subsequent to the NPRM, we reiterated
the distinction between information services and telecommunications services.
Specifically, we found that "Congress intended [that] the categories of
`telecommunications service' and `information service' to be mutually exclusive,
like the definitions of 'basic service' and 'enhanced service' developed
in our Computer II proceeding, and the definitions of 'telecommunications'
and 'information service' developed in the Modification of Final Judgment
that divested the Bell Operating Companies from AT&T." While we decline
here to redefine the meaning of telecommunications services, either for
purposes of section 255 or more broadly, we do think it is appropriate,
as we discuss below, to use ofur ancillary jurisdiction to extend to certain
non-telecommunications services accessibility obligations that mirror those
under section 255 in order to effectuate Congress' intent that we make
telecommunications services accessible.
107. On this same basis, however,
we decline to extend accessibility obligations to any other information
services. While some commenters have argued that there is an overwhelming
need for all information services to be accessible to people with disabilities,
we assess the record differently, and use our discretion to reach only
those services we find essential to making telecommunications services
accessible. Unlike voicemail and interactive menus, other information services
discussed by commenters do not have the potential to render telecommunications
services themselves inaccessible. Therefore, we decline to exercise our
ancillary jurisdiction over those additional services. Many of these other
services are alternatives to telecommunications services, but not essential
to their effective use. For example, e-mail, electronic information services,
and web pages are alternative ways to receive information which can also
be received over the phone using telecommunications services. In contrast,
inaccessible and unusable voicemail and interactive menus operate in a
manner that can render the telecommunications service itself inaccessible
and unusable.
108. Our assertion of ancillary
jurisdiction is thus discrete and limited. Consequently, we dismiss the
contention that including even a single information service under our accessibility
and usability rules could lead to the full-scale regulation of entities
providing information services, such as Internet Service Providers. Nor
can we credit the argument that extension of these provisions through ancillary
jurisdiction will chill innovation, resulting in less accessibility not
more. We do emphasize, however, that our decision to apply these accessibility
obligations to two discrete information services does not alter the regulatory
classification afforded these services. Nor is it our intent by this action
to apply any additional provisions of the Act to providers and manufacturers
of voicemail and interactive menu services and equipment. Thus, as a general
matter, we are not altering our past or current treatment of information
services.
-- In the matter of the Implementation
of Sections 255 and 251(a)(2) of the Communications Act of 1934, as Enacted
by the Telecommunications Act of 1996, WT Docket No. 96-198, Report And
Order And Further Notice Of Inquiry (September 29, 1999) (footnote numbering
off).
Should VoIP providers be required to facilitate communications with
consumers having hearing or other physical disabilities that require use
of telephone relay or other special services?
-- In Re Vonage Holding Company Petition
for a Declaratory Ruling Concerning the Order of the Minnesota PUC, WC
Docket No. 03-211, Comments
of the NY AG (Nov. 21, 2003)
In order to formulate an informed, consistent regulatory policy, the
Commission would like to obtain information about VOIP activity in Michigan
. The Commission, therefore, requests comments on VOIP activity in Michigan
on the following topics that may be affected by both state and federal
law:
. . .
c. Information regarding the effect of VOIP on telephone numbering
resources, including non-licensed VOIP providers' access to numbering resources
through licensed telecommunication carriers and VOIP end users' ability
to port their current landline or wireless telephone number to their VOIP
equipment.
-- U-14073 - Commission's Own Motion (investigation of VOIP) - (MI
PUC 3/16/2004 ) HTML
| PDF
In order to formulate an informed, consistent regulatory policy, the Commission would like to obtain information about VOIP activity in Michigan . The Commission, therefore, requests comments on VOIP activity in Michigan on the following topics that may be affected by both state and federal law:Security
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