When I was reading the petition for relief filed by The Coalition (see 9/3/10 blog) I was really shocked by the information provided as Attachment A.  I was talking with my staff about how startling it was that, according to this information, more than 50% of all 866 and 877 numbers are being used by “chat/referred elsewhere” or “# unavailable/invalid.”  Even more surprising was the only 19% were answered by a business or residence.  When I showed Tom, our resident zealot for facts, he started asking questions about the attachment.  What does it mean by “Reserved by Other RespOrgs” and does this really mean that some called 129 of 16 million number in 866 and 877 and came to these conclusions?  Were these random numbers?  There are a number of things in this petition that I too am concerned about, but I am afraid that using data that is this unscientific will seem to the FCC as a reason to doubt the other more important issues.

ATL is still planning for the 855 code opening to be October 2 until we hear anything different from the FCC, but there has been a “Petition for Emergency Relief and Expedited Action” filed by a company or companies referring to themselves as the Toll Free Number Coalition.  The Coalition asserts that DSMI has not demonstrated that the allocation will be administered in “a fair, orderly, and non-discriminatory manner” as required by the SMS/800 tariff.   The docket suggests that if the FCC does not want to delay the code opening, then the numbers reserved for 855 should be held for 30-60 days before assignment to customers so that DSMI can review all the numbers and provide proof that the release met “fair and equitable”  standard.  The Coalition urged the FCC to issue an order no later than September 30, 2010.  At this time there is no indication, even to the FCC, who constitutes the Coalition.

Nothing like tooting our own horn, but we are the best and want to win this thing.  Here’s your chance to vote for ATL as the best RespOrg. 

Voter Qualification – Any commercial customer or consultant (telecom agent, channel partner, equipment reseller, computer VAR, auditor, etc.) that has had a direct experience with a nominated TA vendor or expert within the past 12 months can vote at www.TelecomVote.com. TA will contact all voters privately to confirm their voter eligibility and to confirm their vote.  Only one vote will be accepted from a company.

For as long as there have been toll free numbers there have been arguments over the sale of toll free numbers.  The argument stems from a statement in the FCC Tariff: 

“2.3.1  All entities, (e.g., RespOrgs, subscribers, service providers), are prohibited from selling, brokering, bartering, and releasing for a fee (or otherwise) any toll free number.” 

The FCC can do this because that agency is charged with protecting this “scarce resource” based on public interest.  These rules have not changed since the original FCC order decades ago.  

So do the 855 sites fall into “brokering” or “releasing for a fee?”  It depends on how you look at the service.  There are some who say that this doesn’t fall outside the rules because this is just a service to get numbers consumers want and, because there is an additional investment in systems, it is the cost of those systems that is being covered.  At least one industry person claims that once he has an agency agreement with a customer the legal requirements of that agency outweigh any rules that come from the FCC. 

So here is my opinion.  It goes on all the time and everyone knows it.  In 1995 we had the FCC listen to a recording that said, “If you want this toll free number here is how you buy it.”  Nothing happened and this launched a pet peeve of mine ever since.  We were offered $10,000 for a number once, but since we are more a “letter of the law” type than a “gray area to be tested” type,” we didn’t accept it. 

Domain names allow for selling and as the plans to tie toll free numbers and domain names together in future applications unfolds, it is time for the FCC to realize that selling the “market right” to toll free numbers is different than selling the number.  It is federally mandated that toll free numbers cannot be owned because they are a national resource, but that is different from allowing two companies that have a common purpose to exchange the control of a toll free number for money without sneaking around.  

Maybe this all changed last week, though.  Some RespOrgs including ATL received an FCC Inquiry requiring us to provide information on numbers reserved in January or March.  Due to the way that these inquiries work we aren’t privy to why this is being requested; whether some specific company suggested it or how many RespOrgs got the request, but I do know it wasn’t just ATL.  The last spreadsheet required demands a list of every toll free number for which the RespOrg received more than $100. 

Is this the policing some of the industry has asked for?  MORE TO COME …

I know of four websites advertising that they will work to get you your 855 numbers.  I apologize upfront to anyone else that has one, and please feel free to post a response to this blog and explain your offering. 

 Rightfully so, all point out that they cannot guarantee anything; none of us can.  Do they actually have a better chance of getting your numbers?  Is it a waste of money? 

I got the opportunity to hear two of these vendors arguing on a call last week.  Both claimed their offer was in the better interest of the customer and that the other might have a somewhat shadier purpose for his site.  The bottom line is that there are customers willing to pay for a better chance to get specific 855 numbers and therefore there is a market to try to satisfy those requests.  Statistically the best chance to get your numbers is to get as many RespOrgs as possible to be searching for your number on October 2.  The question is how much is it worth to you?.

In making a decision on a vendor for this adventure here are the things you should consider:

• How hot is your number going to be?  If you are looking for 855-555-5555 it’s going to take some doing.
• How much is it going to cost you if the vendor gets your number?
• How much is it going to cost if the vendor doesn’t get your number?
• How much do you know about the vendor?  Do you know if you can trust the company?  THIS IS ESSENTIAL BECAUSE YOU NEED TO KNOW HOW EASY IT WOULD BE FOR SOMEONE TO BRIBE THEM PUT SOMEONE AHEAD OF YOU!
• What do you know about the technical abilities of the vendor?  How knowledgeable are they about SMS?  What access options do they have (see last blog?)   I did not cover this topic in the comparisons below because I have no way to verify any of the information.
• What is it worth to you? 

Here are the four sites in alphabetical order with some differences noted: 

www.855reserve.com  csf Corporation’s site is operated on a fully first come first serve basis and will not take an order or any money if someone else has already requested the number on their site.   The charge is $500 up front with a $450 refund if csf doesn’t get your number.  For full disclosure, this is where ATL’s customers will be referred to because we are currently a customer of this company. 

http://www.855numbers.com/ Toll Free Numbers.com’s site was the first site I was aware of that was focused on 855 reservations.  The site has changed several times and I couldn’t find the rates on the one I looked at today, but Mr. Quimby, the owner of the site, sent me an e-mail saying they would be charging $8.55 for a request and an additional $41.50 if they got a number.   When the original site was out I was concerned that it seemed to indicate, but not state directly, that this company had a relationship with many of the large carriers to provide these reservations to them.  I talked to several of the carriers on the list and they said they had no relationship with this site.     

http://www.customtollfree.com/  According to Custom Toll Free’s site there is a charge of $495 for a deposit on the reservation and then $2000 if the number is reserved for you.  I do have an issue with the statement, “855 numbers are available for reservation now.”  Yes, you can order one from Custom Toll Free, but I think this is somewhat misleading because they cannot be reserved in SMS until October 2, 2010.  

http://www.tollfreemarket.com/ Vanity International is the only company that says on their site that the numbers are going to be provided on an auction basis, although in reality this may take place on other sites.  Vanity International calls them “contested numbers,” meaning more than one of their customers has requested the number and the number will be awarded by auction bids.  The other numbers are priced on a sliding scale from free for three numbers up to $500 for 200 numbers.   The site also uses the term “guaranteed results” which would indicate that there will be some selection of who gets numbers to accommodate the promise. 

So a good strategy is to have some “good numbers,” requests to replace your “great number” requests.  You may not win in the Gold Rush, but the Copper Rush may be good enough.  If you are an ATL customer you can reserve a number for our standard price of  $.15 and we will do the best we can – no if, ands, or buts about it.

On October 2, 2010 the new 855 code will be released to the approximately 400 RespOrgs.  There has been a flurry of offers on how to get you what you consider the hot numbers.  Some are legitimate and others – not so much.  What is the reality of the release and how valuable are these numbers?  Let me say up front that the following comments are just my opinion, but after 25 years in the toll free RespOrg and Regulatory world it is at least an educated opinion.

If you are reading this on the blog, www.atlc.com or the LinkedIn RespOrg group I will be covering this subject in three parts.

1. 855 code release-the basics.
2. A review of the sites that are presently advertising ability to get numbers for customers.
3. Is this selling numbers?

Part 1

Are the offers to get numbers for real?

To answer that question you first need to know who will have the best chance of getting the numbers because not all options are created equal.  There are there three ways of getting numbers on October 2.  These are in order of the chances, least to most.

1. Manual – All RespOrgs have manual access to SMS* through either WBA or “3270.”  3270 is the original dumb terminal emulation, but surprisingly it is still faster than WBA, the newer GUI interface.  Although the GUI is easier to navigate, the very programming that makes it easier also makes it slower.  A number of RespOrgs do not know how to use 3270, as it has been going out for years, but has been saved by those of us who rely on it.
2. MGI- Mechanized Generic Interface was designed in the 80’s to interface with the then Bell Operating Companies.  It has always been very expensive, but there are a few Non-bell Companies that have it and use it with a custom programming using newer technology.
3. Specially designed software – Some RespOrgs have designed software specifically for sweeping the SMS system to get specific numbers.  These take different forms like screen scrapers or just large numbers of SMS logon IDs to get greater access. 

The thing you need to consider is how many other people will be looking for the same number.  This is the fifth “gold rush” situation that my company has been through and it still surprises me how valuable the public sees these releases.  800-555 was the first release.  MCI had all the numbers within minutes.  888 was the next, but was somewhat different because it allowed for “replication.”  Replication allowed for companies to pre-reserve numbers if they had the 800 duplicate, so 800-FLOWERS was allowed to pre-reserve 888-FLOWERS.  Although suggested for the 877 and 866 release, the FCC ruled out the option.  There was some discussion in SNAC** about this for the 855 release, but not enough support at this time. 

The most similar to 855 was the 866 and 877 releases.  Hopefully in the 855 release there will be one major difference.  In both 877 and 866 SMS had major issues that locked out manual users in the first few minutes of the process which may explain some of the outcomes.  DSMI*** has assured SNAC that there have been fixes installed in the system to avoid that in the 855 release. 

Here are some things that happened in the earlier releases.

• Within minutes the companies with the specialized software had almost all the numbers that were popular because they spelled things.
• Thousand numbers (8XX-XXX-X000) were heavily taken early, but there were some random ones that were still able to be reserved by manual users.
• Hundred numbers (8XX-XXXX-XX00) had greater availability to manual users.
• The easiest specific numbers to get, not surprisingly, were numbers that were important to very specific users.  For instance a user wanting a number matching their local number or spelling their business name were generally able to get their numbers. 

Every RespOrg has an option for reserving 855 numbers on October 2, so let me say first, talk to your current RespOrg.  If you don’t know who your RespOrg is you can call 888-SMS-3300 and find out. Your RespOrg may already have plans for specific systems that will increase your chances for getting your numbers.  Many RespOrgs are working off of first come; first serve, so you want to do this soon. 

*SMS Service Management System

This is the organization and system that administers the centralized management of Toll Free numbers.  All toll free numbers are routed through this system. 

**SNAC SMS/800 Number Administration Committee

SNAC identifies, develops, and implements the resolution of issues impacting existing toll free products and services and evolving technologies affecting future developments in the toll free industry.  The committee is part of ATIS.  Currently there are about eight or ten active RespOrgs in ATIS.  Although membership is open to all RespOrgs, the cost is prohibitive for many.  ATL RespOrg Services is an active member. 

***DSMI Database Service Management, Inc.

When toll free number portability was launched in 1993 the FCC designated DSMI as the toll free administrator.  DSMI has a board that was originally made up of the seven Bell Operating companies.  Since merger and acquisitions there are currently only three board members.

It was announced today that the 855 release will be October 2, moved from October 1.  I have to say for those of us sending these directions to the FCC, this was embarrassing.  When SNAC (the national committee that I sit on that makes these kinds of requests) requested October 1, no one looked to see what day of the week that was.  We were just interested in when everyone could be ready.  It turned out that October 1 was a Friday and releases are always done on weekends so there won’t be any interference with the regular load on the system. 

Stay tuned for breaking news about FCC, and if you’re a RespOrg, see the discussions on the RespOrg group on LinkedIn. 

Aelea Christofferson

ATL Communications

Related Article

The www.855numbers.com  Website has changed substantially.  This may be due to criticism of the industry that the site made it appear that there was a direct tie between the site and the many companies listed, but the fact still remains, Mr. Quimby has not answered how he is verifying that the 855 requests he is getting have not been requested some other way.  I know he doesn’t have access to the numbers our clients have requested, nor is there any advantage to our clients to pay him for an “advance registration.” 

 What are your thoughts on the Website?  Does it seem that this is a reasonable way to make money?

The SNAC committee will be sending its 855 recommendation letter to the FCC tomorrow.  In the letter the release date for 855 is October 2, 2010.  The one day change makes the release a Saturday which is historically how releases are done to limit interference with the normal SMS workload.  Any reference to allocation was removed from the recommendation because as of last Monday, based on the current take rate of toll free numbers from spare, there were enough numbers to last until June 2012.  The movement of the take rate is being monitored in case allocation becomes necessary.

What actually happens when an 855 number and a company name is entered on this Website? I have checked with several of the large carriers listed and they do not provide any information. Bill Quimby, the owner of the site, gave this reply:

“It’s a service to collect and bring the reservations to their carrier. Most customers don’t know who to contact or what to do and most carriers don’t have much of a request process yet. So we are collecting and organizing their requests, preventing duplicates and bringing them to their carrier as soon as they’re able to take them. You are correct that none of the large carriers have any information or process for 855s yet. That’s why this is necessary and a service to the customer.

“Vanity number brokers (above) don’t want regular customers to submit requests ahead of time so that they will have more ability to grab what they want for themselves. But a pre-release request process is essential for end customers to have a chance against the brokers and squatters. And many companies may not set up much of a process ahead of time in the next 77 days. And since most phone companies put requests through roughly in the order they come in, this will give the people who place requests early at 855numbers.com a better chance.

“It’s also a benefit to the resporgs because it will reduce the rush of customer requests and make their life easier with an organized spreadsheet of their customer requests. So we’re just helping the regular phone companies and their resporgs by facilitating the communication. It’s a win win!”

To which I replied:

“In my discussions with some of the companies the feeling it is neither helpful nor is it a win/win. The feeling among some is that you are giving people the indication that you have some kind of relationship with these companies and that you shouldn’t list their names on your Website without some kind of permission from them.”