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Federal Internet Law & Policy
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Notes: VoIP: Definition Dont be a FOOL; The Law is Not DIY
- VoIP
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Telecom Issues
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- ACTA Petition
- Blocking
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- Stevens Report
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- Time Warner Petition
- Vonage
Social Issues
- 911
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Notes
- ESPs / Info Service
- History
- Notes
- - Classification
- - definition
- - Jurisdiction
- Statistics
Related Issues
- Intercarrier Comp
- ENUM
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Notes > Applications > VoIP These notes are not complete and there is no guarantee that they are accurate. They are presented simply as notes. Feel free to use them but as with all material on the Internet Telecom Project, you should consider them a beginning to your research and not an end.

Definitions

  VoIP Caselaw

"VoIP is an internet application used to transmit voice communication over a broadband internet connection." Vonage v Nebraska PSC, No. 08-1764, slip at 3 (8th Cir. May 1, 2009)

Voice communication using the Internet has been called Internet Protocol ("IP") telephony, and rather than using circuit switching, it utilizes "packet switching," a process of breaking down data into packets of digital bits and transmitting them over the Internet. Id. at 21.
-- Vonage v. Minnesota PUC, Civil No. 03-5287, Sec. III (MJD/JGL) (DMN October 16, 2003)

 VoIP - FCC

Although the Commission has adopted no formal definition of “VoIP,” we use the term generally to include any IP‑enabled services offering real-time, multidirectional voice functionality, including, but not limited to, services that mimic traditional telephony. See IP-Enabled Services Proceeding, 19 FCC at 4866, para. 3 n.7. VoIP services are available in a number of different forms. See, e.g., Minnesota Commission Reply at 3 (“[VoIP] is a technology that has many current applications and potentially many more future applications.”); see also Availability of Advanced Telecommunications Capability in the United States, GN Docket No. 04-54, Fourth Report to Congress, FCC 04-208, at 24-26 (rel. Sept. 9, 2004) (Fourth Section 706 Report) (describing VoIP services generally).
-- 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, n. 9 (FCC Nov. 12, 2004 )


3. VoIP technologies, including those used to facilitate IP telephony, enable real-time delivery of voice and voice-based applications.  When VoIP is used, a voice communication traverses at least a portion of its communications path in an IP packet format using IP technology and IP networks.  VoIP can be provided over the public Internet or over private IP networks.  VoIP can be transmitted over a variety of media (e.g., copper, cable, fiber, wireless).  Unlike traditional circuit-switched telephony, which establishes a dedicated circuit between the parties to a voice transmission, VoIP relies on packet-switching, which divides the voice transmission into packets and sends them over the fastest available route.  Thus, VoIP uses available bandwidth more efficiently than circuit-switched telephony and allows providers to maintain a single IP network for both voice and data.
-- In re Petition for Declaratory Ruling that AT&T's Phone-to-Phone IP Telephony Services are Exempt from Access Charges, WC Docket No. 02-361, Order para 3  (April 21, 2004)


177. Internet Protocol telephony ("Internet" or "IP" telephony) services enable real-time voice transmission using the Internet Protocol (IP), a packet-switched communications protocol. The services can be provided in two basic ways: computer-to-computer IP telephony conducted through special software and hardware at an end user's premises; or phone-to-phone IP telephony conducted through "gateways" that enable applications originating and/or terminating on the public switched network. Phone-to-phone IP telephony is provided through computer gateways that allow end users to make and receive calls using their traditional telephones. Gateways translate the circuit-switched voice signal into IP packets, and vice versa, and perform associated signalling, control, and address translation functions. The voice communications can then be transmitted along with other data on the "public" Internet, or can be routed through intranets or other private data networks for improved performance.
--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, ¶ 177 (September 29, 1999).

Although we conclude that Internet access is not a "telecommunications service," we acknowledge that there may be telecommunications services that can be provisioned through the Internet. We have singled out IP telephony services for discussion in this Report.[213] As discussed above, users of certain forms of phone-to-phone IP telephony appear to pay fees for the sole purpose of obtaining transmission of information without change in form or content. Indeed, from the end-user perspective, these types of phone-to-phone IP telephony service providers seem virtually identical to traditional circuit-switched carriers. The record currently before us suggests that these services lack the characteristics that would render them Ainformation services@ within the meaning of the statute, and instead bear the characteristics of Atelecommunications services.@[214]

[213] See supra Section IV.D.3.

[214] As discussed above, however, we do not believe that it is appropriate to make any definitive pronouncements in the absence of a more complete record focused on individual service offerings.

In re Federal-State Joint Board on Universal Service, Report to Congress, FCC 98-67 ¶ 101 (April 10, 1998).
See pending FCC proceeding seeking to amend definition of "interconnected VoIP"
See FCC Regulations that apply to Interconnected VoIP Services

VoIP Definition :: FCC :: Interconnected VoIP :: CFR

47 CFR § 9.3   Definitions.

Interconnected VoIP service. An interconnected Voice over Internet protocol (VoIP) service is a service that:

(1) Enables real-time, two-way voice communications;

(2) Requires a broadband connection from the user's location;

(3) Requires Internet protocol-compatible customer premises equipment (CPE); and

(4) Permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network.

NOTE:

Other Definitions

47 CFR § 9.3   Definitions.

ANI. Automatic Number Identification, as such term is defined in §20.3 of this chapter.

Appropriate local emergency authority. An emergency answering point that has not been officially designated as a Public Safety Answering Point (PSAP), but has the capability of receiving 911 calls and either dispatching emergency services personnel or, if necessary, relaying the call to another emergency service provider. An appropriate local emergency authority may include, but is not limited to, an existing local law enforcement authority, such as the police, county sheriff, local emergency medical services provider, or fire department.

PSAP. Public Safety Answering Point, as such term is defined in §20.3 of this chapter.

Pseudo Automatic Number Identification (Pseudo-ANI). A number, consisting of the same number of digits as ANI, that is not a North American Numbering Plan telephone directory number and may be used in place of an ANI to convey special meaning. The special meaning assigned to the pseudo-ANI is determined by agreements, as necessary, between the system originating the call, intermediate systems handling and routing the call, and the destination system.

Registered Location. The most recent information obtained by an interconnected VoIP service provider that identifies the physical location of an end user.

Statewide default answering point. An emergency answering point designated by the State to receive 911 calls for either the entire State or those portions of the State not otherwise served by a local PSAP.

Wireline E911 Network. A dedicated wireline network that:

(1) Is interconnected with but largely separate from the public switched telephone network;

(2) Includes a selective router; and

(3) Is utilized to route emergency calls and related information to PSAPs, designated statewide default answering points, appropriate local emergency authorities or other emergency answering points.

 VoIP - State

Newton’s Telecom Dictionary, 19th edition (2003), defines VoIP as “The technology used to transmit voice conversations over a data network using the Internet Protocol. Such data network may be the Internet or a corporate Intranet.”
-- Washington Exchange Carriers Association v. LocalDial Corporation, Docket UT-031472, Order (WUTC June 11, 2004) 


Voice over Internet Protocol (VoIP) is a technology developed to enable voice communication over networks, including the public Internet, that utilize the Internet Protocol (IP). VoIP converts voice conversations into digital packets that are transmitted over IP networks.
-- Complaint of Frontier Telephone of Rochester, Inc. Against Vonage Holdings Corporation Concerning Provision of Local Exchange and InterExchange Telephone Service in New York State in Violation of the Public Service Law, CASE 03-C-1285, Order Establishing Balanced Regulatory Framework for Vonage Holding Corporation, p. 3 (May 21, 2004) 


VoIP is an emerging technology that allows real-time audio (i.e., voice, data or voice and data), instantaneously or slightly-delayed, to be transmitted and received in a digital format through the use of Internet Protocol (IP) data packet transmission. A packet is the fundamental unit of information transmitted over a digital network or over a digital communication link. IP is a standard describing software that keeps track of the Internetwork addresses for different nodes, routes outgoing messages, recognizes incoming messages and allows a packet to traverse multiple networks on the way to its final destination. -- PA PUC: Investigation into Voice over Internet Protocol as a Jurisdictional Service, Docket M-00031707, PA PUC Motion of C Glen Thomas Closing Investigation April 15, 2004


 VoIP is a service using Internet technology that is utilized today by business and residential customers. In offering ubiquitous real-time, point-to-point voice service, VoIP competes with traditional providers of voice telephony, including incumbent telephone companies (ILECs), competitive local exchange carriers and cable telephony providers. At the same time, the ILECs and cable operators themselves have deployed, or have announced plans to deploy, VoIP on a commercial basis to business and/or residential customers over the next few years. Many of these providers, such as SBC and TimeWarner, are actively migrating customers to VoIP technology. Recently, Time Warner filed an application with the Commission to provide local and intrastate VoIP service in California. VoIP represents the next generation technology for the provision of voice and other services.
. . . .
 IP is a type of digital transmission technology over which services are provided. Voice using IP is a substitute for voice using traditional digital protocols, such as Time Division Multiplexing (TDM). VoIP is similar to digital protocol interfaces of two decades ago enabling existing customer telephone equipment to transmit voice calls under a new and different protocol. In both cases, the customer's analog voice signal is converted into a digital format and transmitted as data to the point of termination, at which point the voice is converted back to an analog format. In both cases, there is no net change in form or content of the voice message, and no net protocol conversion. VoIP providers offer a telephone number and a network translator device to the customer.
         Like voice transmitted using TDM digital protocol, VoIP transmissions interconnect with the PSTN and utilize telephone numbers from the North American Numbering Plan (NANP). VoIP requires a customer to have a high-speed connection to the Internet. Typically, this connection is either a Digital Subscriber Line (DSL) offered by the incumbent telephone company, a competitive local exchange carrier or a high-speed cable line offered by cable operators. While these high-speed services require their own continuous electric supply (and supply their own backup), VoIP service itself is dependent on the customer also having a continuous supply from their electric service provider to power the network translator device, which is generally not connected to a computer. VOIP providers may take the same route and include battery backup to maintain service.
        VoIP may be provided between computers, between a standard telephone and a computer, between a computer and a standard telephone, or between two standard telephones. With the exception of computer-to-computer transmissions, all other transmissions interconnect with the PSTN.
-- 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

 



VoIP is a means of using packet switching techniques, the same basic techniques used by internet backbone carriers and providers, to offer voice services traditionally provided by "switched-voice" technology, either analog or digital.
--In The Matter Of The Investigation Into Voice Over Internet Protocol (Voip) Services, Docket No. 03M-220T, Order Closing Docket ¶ 1 ( Colorado PUC Dec. 17, 2003)


Internet Protocol (IP) telephony services enable real-time voice transmission using Internet protocols. The services can be provided in two basic ways: through software and hardware at the customer's premises or through "gateways" that enable applications originating and/or terminating on the public switched telephone network (PSTN). Gateways are computers that transform the circuit-switched voice signal into IP packets, and vice versa, and perform associated signalling, control, and address translation functions. The voice communication can be transmitted along with other data on the "public" Internet, or can be routed through PSTNs or through intranets or other private data networks. (In the Matter of Federal-State Joint Board on Universal Service, cc Docket No. 96-45, 13 FCC RD 11501, Release Number 98- 67, released April 10, 1998, Para 84).
-- Complaint of Frontier Company of Rochester Against DataNet Corporation Concerning Alleged Refusal to Pay Intrastate Carrier Access Charges Case 01-C-1119, Order Requiring Payment of Intrastate Access Charges n. 3 (May 31, 2002)

 VoIP - State - Not in Regulatory Proceding

"Voice is data, not voice and data. That is the essence of the application of packet technology to the provision of voice services. The transport of voice over packet-switched networks will become increasingly" Vermont Telecommunications Plan, Sept 2004, p. 1-6


Voice-Over IP: VoIP delivers voice service using Internet Protocol. Voice information is sent in digital form rather than by the traditional methods of the public switched telephone network. VoIP offers another means of connecting users within a "campus" environment.
-- Indiana Telecommunications Network, http://www.in.gov/intel/networkservices/tele_comm.html


Voice over Internet Protocol (VoIP): A service that allows a caller to place telephone calls via the Internet.
-- Utility Glossary, Indiana Office of Utility Consumer Counselor (OUCC) http://www.in.gov/oucc/pdf/OUCCGlossary.pdf

        VoIP Defined as Bypass

"Voice over the Internet Protocol ("VOIP") is a technology that uses the Internet to bypass the traditional telephone switching centers to complete voice calls (both local and toll)." -- TELEPHONE REPORT TO THE REGULATORY FLEXIBILITY COMMITTEE OF THE INDIANA GENERAL ASSEMBLY Sept 29, 2003 Page 12 PDF

  Various Service / Network Designs

It can be used in many configurations to provide telephone services. For example, VoIP has for several years been deployed in the network backbone and in private corporate networks allowing those network operators to achieve cost savings by converging voice and data traffic on one platform. Cable companies are using VoIP to roll out stand-alone telephone services over their existing fiber-coax cable networks.3 Other companies, such as Vonage, use VoIP to provide voice communications over a customer’s existing high-speed Internet access service, providing the customer a normal telephone number and the ability to call any phone in the world. Still others, such as Pulver and Skype, provide VoIP-based software to enable voice communications between member users on the Internet. Traditional telephone companies, such as AT&T, are also using VoIP technology to carry calls between switches on their long-haul networks. Even traditional local carriers, such as Verizon, can use VoIP technology for their interoffice traffic.
-- Complaint of Frontier Telephone of Rochester, Inc. Against Vonage Holdings Corporation Concerning Provision of Local Exchange and InterExchange Telephone Service in New York State in Violation of the Public Service Law, CASE 03-C-1285, Order Establishing Balanced Regulatory Framework for Vonage Holding Corporation, p. 3 (May 21, 2004)

Free World Dial Up (Pulver)

4. FWD is an Internet application. The Internet is a distributed packet-switched network of interconnected computers enabling people around the world to communicate with one another, invoke multiple Internet services simultaneously and access information with no knowledge of the physical location of the server where that information resides.7 The Internet represents a paradigmatic shift in network technology: intelligence in the system no longer resides, as it did in the legacy circuit-switched network, primarily in the network itself, but has instead migrated to the edge of a vastly different type of network - to the end user's CPE. FWD is an example of this migration because, as explained below, Pulver's service bears no geographic correlation to any particular underlying physical transmission facilities. FWD depends on whether a user can establish a presence on the network at some point, not whether
the user can access the network from a specific geographically defined end point. Internet applications like FWD thus separate the user from geography and the application enabling voice or other types of communication from the network over which the communication occurs.
    5. As described by Pulver, FWD offers users of broadband Internet access the opportunity to join other such users worldwide in talking with one another directly over the Internet as well as communicating directly via video or text.8 FWD facilitates this interactive
communication capability by offering such users the ability to become FWD members through an initial registration process followed by the new member complying with other requirements specified by FWD that are necessary to enable communications to be made.9 Specifically, members must have an existing broadband Internet access service as Pulver does not offer any transmission service or transmission capability.10 In addition, members must acquire and appropriately configure Session Initiation Protocol (SIP) phones or download software that enables their personal computers to function as "soft phones."11 Once these criteria are met,
anyone anywhere in the world can obtain a Pulver-assigned five- or six-digit FWD number (not a North American Numbering Plan (NANP) number)12 to facilitate using the member's broadband service to make free voice over Internet Protocol (VoIP) or other types of peer-to-peer communications to other FWD members.13 According to Pulver, it neither knows nor needs to know where its members are geographically located in order for its members to use FWD.14 In addition, Pulver indicates it can not determine its members' geographic location.15 Once an FWD member obtains its FWD number, that number is completely portable to any broadbandaccessible location to which that member may go.16 Moreover, FWD members may not even know where other members are physically located during any given communication session with another member as FWD enables members to register up to 25 different locations for potential receipt of communications from other members, any one of which locations may end up being
the Internet address from where the communication is actually answered.17
    6. According to Pulver, FWD acts as a directory or translation service, informing its members when other members are online or "present," thus available to receive a call, as well as informing them of the Internet address necessary to reach other members during their on-line presence.18 Moreover, Pulver indicates that FWD: offers voice mail capabilities to those members who opt-in to this function; offers conference bridging capabilities to members; and performs limited Internet address repair for its members.19 Although FWD facilitates VoIP or other types of communications over the Internet between its members, Pulver indicates that FWD is merely an Internet application that provides its members information that those members use to communicate with other members.20 Pulver states that it is the members' end-user devices, not Pulver, that establish the actual connections and manage the calls.21

7 See, e.g., GTE Telephone Operating Cos., GTE Tariff No. 1, GTOC Transmittal No. 1148, CC Docket No. 98-
79, Memorandum Opinion and Order, 13 FCC Rcd 22466, 22468, para. 5 (1998) (GTE ADSL Order).
8 Pulver Petition at 3; Pulver Reply at 2-3 & n.2.
9 Id. Pulver indicates it does not verify the identifying information members submit on the FWD registration
screen such as name, address, state or country. See Letter from Susan M. Hafeli, Counsel, pulver.com, to Marlene
H. Dortch, Secretary, Federal Communications Commission, WC Docket No. 03-45, at 1 (filed Dec. 16, 2003)
(Pulver Dec. 16 Ex Parte Letter).
10 Pulver Petition at 3. According to Pulver, its service operates with any type of broadband connection (e.g.,
cable modem, digital subscriber line, satellite, or wireless). Id. As noted above, we do not address FWD to the
extent it may be usable via dial-up access. See supra note 3.
11 Pulver Petition at 3-4. Session Initiation Protocol is an application-layer control (signaling) protocol for
creating, modifying, and terminating sessions with one or more participants. These sessions include Internet
telephone calls, multimedia distribution, and multimedia conferences. See J. Rosenberg et al, "SIP: Session
Initiation Protocol" RFC 3261, June 2002; see also Letter from A. Renee Callahan, Counsel, to Marlene Dortch,
Secretary, Federal Communications Commission, WC Docket No. 03-45, at n.5 (filed Dec. 12, 2003) (MCI Dec. 12
Ex Parte Letter).
12 Pulver Petition at 3; Pulver Dec. 11 Ex Parte Letter at 2-3.
13 "Peer-to-peer" is a communications model in which each party has the same capabilities and either party can
initiate a communication session. In recent usage, peer-to-peer has come to describe applications in which users can
use the Internet to, for example, exchange files with each other directly or through a mediating server. See
http://searchnetworking.techtarget.com/sDefinition/0,sid7_gci212769,00.html.
14 See Pulver Dec. 16 Ex Parte Letter at 1-2.
15 Id. In fact, the record shows that it is impractical or impossible for Pulver to obtain member location
information (i.e., the originating and terminating points) for any given communication between its members.
According to Pulver, since it "manages only the signaling component of the call," it has access only to the
application layer of the network and, thus, the information available to it is "inadequate to determine the actual
physical location of an underlying IP address." Id.
16 Id; see also Letter from Scott Blake Harris, Counsel, Cisco, to Marlene Dortch, Secretary, Federal
Communications Commission, WC Docket No. 03-45, at 3-4 (filed Dec. 11, 2003) (Cisco Dec. 11 Ex Parte Letter).
17 See Letter from Glenn S. Richards, Counsel, pulver.com, to Marlene H. Dortch, Secretary, Federal
Communications Commission, WC Docket No. 03-45, at 1 (filed Jan. 20, 2004) (Pulver Jan. 20 Ex Parte Letter).
18 Pulver Dec. 11 Ex Parte Letter at 2.
19 Pulver Dec. 11 Ex Parte Letter at 2; Pulver Jan. 15 Ex Parte Letter.
20 Pulver Dec. 11 Ex Parte Letter at 2.
21 Pulver Dec. 11 Ex Parte Letter at 2-3 (noting with support Electronic Frontier Foundation's statement that
"FWD simply allows FWD subscribers to use telephone-like 5- or 6-digit numbers to locate and call other FWD
subscribers, much as DNS translation allows Internet users to use http://www.eff.org instead of
http://209.237.229.14.").

-- -- In re Petition for Declaratory Ruling that pulver.com's Free World Dialup is Neither Telecommunications Nor a Telecommunications Service, WC Docket No. 03-45, Memorandum Opinion And Order  (FCC February 19, 2004)

 Vonage

The Vonage Digital VoiceSM service enables its subscribers to complete telephone calls to other Digital VoiceSM subscribers over the public Internet and to users of any public telephone networks in the world. To place a call, a Vonage customer typically uses a normal telephone and dials a standard telephone number. The number and voice are “digitized” into IP packets by a Multimedia Terminal Adapter (MTA) and transmitted using VoIP and the customer’s broadband Internet connection to a Vonage gateway server. If the call is to another Vonage customer, the call is completed to the called party over the Internet. If the call is to a non-Vonage customer, the Vonage server converts the packetized information into a Time Division Multiplexed (TDM) signal to enable completion to the called party via connections through one or more common carriers (incumbent and competitive local exchange carriers and/or interexchange carriers). When a non-Vonage customer calls a Vonage subscriber, the call is also dialed normally and then traverses the originating carrier’s network and perhaps other carriers’ networks (all typically using TDM) until it is passed to Vonage, which packetizes the signal and transmits it to the called Vonage customer. Given Vonage’s current limited subscriber base, a vast majority of the calls are connected over other carriers’ networks.[4]

[4]Vonage has about 150,000 customers in the United States and estimates it will have 250,000 customers by the end of 2004. The company estimates it has approximately 10,500 customers with New York billing addresses. (Vonage Comments at p.5)

-- Complaint of Frontier Telephone of Rochester, Inc. Against Vonage Holdings Corporation Concerning Provision of Local Exchange and InterExchange Telephone Service in New York State in Violation of the Public Service Law, CASE 03-C-1285, Order Establishing Balanced Regulatory Framework for Vonage Holding Corporation, p. 4 (May 21, 2004)


Vonage markets and sells Vonage DigitalVoice, a service that permits voice communication via a high-speed ("broadband") Internet connection.1 Vonage's service uses a technology called Voice over Internet Protocol ("VoIP"), which allows customers to place and receive voice transmissions routed over the Internet.
. . . . .
Essential to using Vonage's services is that a third-party Internet service provider ("ISP"), provides a broadband Internet connection. Vonage does not function as an ISP for its customers. A Vonage customer may make and receive computer-to-computer calls. With another person connected to the PSTN, a Vonage customer may make computer-to-phone calls and receive phone-to-computer calls. During computer-to-computer calls, via a broadband Internet connection, an outgoing voice communication is converted into IP data packets which then travel the Internet to the person using a second computer.
    For computer-to-phone calls and phone-to-computer calls, Vonage uses a computer to transform the IP data packets into a format compatible with the PSTN, and vice versa. Rather than using the POTS equipment, Vonage's customers use special customer premises equipment ("CPE") that enables voice communication over the Internet.
    Vonage obtains ten-digit telephone numbers from telephone companies that it then uses to provide service to its customers. PSTN users may dial that ten-digit number and reach one of Vonage's customers. A telephone number associated with a Vonage customer is not associated with that customer's physical location. The number is instead associated with the customer's computer. Vonage's customers may use Vonage's services at any geographic location where they can access a broadband Internet connection. Thus, a customer could make and receive calls anywhere in the world where broadband access is available. Vonage is not capable of determining the geographic location from which its customers access its service.
     Vonage has approximately 500 customers with billing addresses in Minnesota. It also has thirty-eight customers with Minnesota billing addresses who have requested telephone numbers with area codes not geographically situated within Minnesota, and eighty-eight customers with billing addresses outside of Minnesota who have requested telephone numbers geographically situated within Minnesota. Because Vonage is unable to determine the geographic location of its customers, it requires customers to register their location before they can dial "911" for public safety purposes.
-- Vonage v. Minnesota PUC, Civil No. 03-5287, Sec. III (MJD/JGL) (DMN October 16, 2003)

AT&T

The service at issue in AT&T's petition consists of an interexchange call that is initiated in the same manner as traditional interexchange calls - by an end user who dials 1 + the called number from a regular telephone.   When the call reaches AT&T's network, AT&T converts it from its existing format into an IP format and transports it over AT&T's Internet backbone.   AT&T then converts the call back from the IP format and delivers it to the called party through local exchange carrier (LEC) local business lines.
-- In re Petition for Declaratory Ruling that AT&T's Phone-to-Phone IP Telephony Services are Exempt from Access Charges, WC Docket No. 02-361, Order. para 1 (April 21, 2004)