From owner-nanog@merit.edu Thu Aug 18 01:47:56 2005 Date: Thu, 18 Aug 2005 02:44:59 -0400 From: "Eric A. Hall" <ehall@ehsco.com> Cc: nanog@merit.edu Subject: Re: New N.Y. Law Targets Hidden Net LD Tolls
On 8/17/2005 10:04 PM, Fergie (Paul Ferguson) wrote:
A new law that's apparently the first in the nation threatens to penalize Internet service providers that fail to warn users that some dial-up numbers can ring up enormous long-distance phone bills even though they appear local.
aka, make ISPs liable for other people's fraud. What's the thinking here, anybody know?
*NOT* "other people's fraud". Just when you have 'intra-LATA' toll charges for some numbers within a single area-code. If the user is on one side of the area-code, and the provider's POP is on the far side of it, you can have a what appears to be a 'local' number, that does incur non-trivial per-minute charges. Without knowing _where_ a particular prefix is, you can't tell whether there will be toll charges for that call, or not, from any given call origin. Of course, this is true for *every* call in such an area -- if the new law is actually singling out ISPs (and ISPs -only-), I expect it could be successfully challenged as 'discriminatory'. The excessive 'local toll charge' situation is most visible on calls to ISPs, because those calls tend to be somewhat lengthy -- and frequent -- thus, the 'unexpected' charges can reach significant dollar value before the phone customer gets their first bill. Life gets _really_ messy, when the ISP gets phone service from a CLEC, because there is "no telling" _where_ the ILEC uses as the 'rate point' for handing the calls off to that CLEC. And the CLEC bills their customers based on distance from the caller's location to that hand-off point. The ISP equipment may be across the street from the caller, but the ILEC-CLEC hand-off is on the far edge of the area-code. and the 'local toll charges' are applied. The CLEC can't tell you (and thus, neither can the ISP) which prefixes are a 'non-toll' call to their numbeers. And trying to get an authoritative answer from the ILEC about what charges are to the CLEC's prefix can be _very_ difficult.