Federal Internet Law & Policy
An Educational Project
VoIP: Federal Activity Dont be a FOOL; The Law is Not DIY

Telecom Service Classification
IP Enabled Services Proceeding
Discontinuance of Service Non Dom Rules Sec. 214
Interconnected VoIP
Outage Reporting
Interconnected VoIP
Number Portability
interconnected VoIP
Access to Numbers
Interconnected VoIP
Interconnected VoIP
Access Charges
Pending. But See Intercarrier Comp
PSTN VoIP Interconnection
interconnected VoIP
PSTN VoIP Blocking
Madison River
IP in the Middle
IP in the Middle
Data Reporting, Sec. 706
Interconnected VoIP
Not Connected to PSTN, no NANP, and Free
"Not a Telecom Service" Pulver
interconnected VoIP
interconnected VoIP
Universal Service Fund contribution
interconnected VoIP
Telecommunications Relay Service
21st Century Communications and Video Accessibility Act
Regulatory Fees
Interconnected VoIP
Privacy CPNI
interconnected VoIP

VoIP services has the potential to fall within one of three regulatory classifications:

US Government Activity


FCC Solution Summits

Regulatory Proceeding

In this Order we address a petition filed by SBC Communications Inc. (SBC) requesting that the Commission forbear from the application of “Title II common carrier regulations” as contained in the Communications Act of 1934, as amended (the Act), to “IP Platform Services. For the reasons set forth below, we deny SBC’s petition. We find that the petition is procedurally defective because it asks us to forbear from the application of statutory provisions and regulations that “may or may not” apply to the telecommunications carrier or telecommunications service at issue. In addition, the evidence and arguments set out in SBC’s petition and subsequent pleadings are insufficiently specific to permit a finding that forbearance is appropriate

WC DOCKET NO. 04-29 
February 12, 2004 Comments Due: May 12, 2004 
Reply Due:   June 11, 2004

Provision  of  Directory  Listing  Information under  the  Telecommunications  Act  of  1934 (Sec. 222)
.CC-Docket No. 99-273

"In the Order, the Commission also resolved certain issues relating to telephone directory publishing, including extending rights to subscriber list information at nondiscriminatory and reasonable rates to publishers of telephone directories on the Internet.  The Commission also concluded that publishers of telephone directories on the Internet should not be restricted in the manner in which they display or allow customers to access the data." 
--Press Release Jan 24, 2001 [ Text | MS Word97 | PDF ]   47 USC § 222

Press Release Jan 24, 2001
[ Text | MS Word97 | PDF ]  - Report and Order Text | Word | PDF

See also Customer Proprietary Network Information discussion.


E Signature Letters of Authority


On July 21, 2000, the FCC implemented the new Electronic Signatures in Global and National Commerce Act by "permitting preferred carrier changes to be conducted electronically through the use of Internet Letters of Agency (LOAs). Internet LOAs must comply with all current Commission authorization and verification requirements, and consumers must have the option of using alternative authorization and verification methods, such as written LOAs or independent third party verification. " 

FCC rules require that changes of telephone services be with one of four verification methods:  written Letters of Authority, electronic (i.e., telephone) authorization, independent third party verification, or State-enacted verification procedure.  This requirement is designed to stop the fraudulent practices of "slamming" (involuntary switching of services) and "cramming" (involuntary adding of unwanted services).  The new rules permit carriers to receive authorization for changes in telephone service over the Internet.  However, carriers must continue to comply with authorization and verification requirements, and where a change of service is contested, the burden of proof is on the carrier to establish that the change was authorized by the consumer.  This means that carriers have an incentive to design their webpages in such a way that it can be confirmed that when consumers change services, they really in fact meant to change services - and that some third party is not involuntary changing services on them.

FCC Press Release July 21, 2000

FCC Order Revising Slamming rules to permit Internet Letters of Authority, ¶¶ 6-20 (permitting consumers to acquire and change telephone services online) Word | Text

S 761 Electronic Signatures in Global and National Commerce Act



Local Competition and Broadband Reporting Closed

Local Competition and Broadband Reporting, Notice of Proposed Rulemaking in CC Docket No. 99-301 (broadband data gathering - asking questions about IP Telephony).  This proceeding developed reporting requirements for telephone competition.  Discussing the reporting of local lines, the FCC states "As a result, when evaluating the development of local competition, we believe it is necessary to include the development of IP-telephony service.  However, while the proposed survey instructions direct reporting entities to report lines that may be used in connection with IP- telephony service, as discussed below, the survey questions do not identify the use of IP- telephony per se.  We seek comment whether we should undertake a more specific determination of the extent to which the  internet is being used to provide telephony services and how we should do so. "  The Report and Order that closed the proceeding does not seem to reference IP Telephony at all.

See WIP Broadband Webpage.

Computer Inquiries

For further regulatory history, see the FCC's Computer Inquiries which created the Basic versus Enhanced dichotomy, creating a regulatory scheme in which all applications over computer networks fall within unregulated enhanced / information services .


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