Geographic Routing, Shared Use, and Location Based Services Among the Issues Discussed with Telecom Leaders in D.C.

MessageComm director Noah Rafalko recently met with leaders from the Wireless Telecommunications Bureau, the Consumer Government Affairs and the Office of Economics and Analytics to discuss current issues with consumer text messaging.

He also met in person with Travis Litman, Federal Communications Commissioner (FCC) Jessica Rosenworcel's senior legal advisor for wireline and consumer issues. 
 
While our goal is to provide safe and effective routing of text messages in compliance with consumer privacy laws, we believe Toll-Free service providers should be able to offer non-specific or ‘fuzzy’ geographic data routing and ‘Shared Use’ services without interference or unnecessary opt-ins. 
 
Further, we think there are better ways to manage text SPAM and finally, that consumer privacy and public safety could be at risk if and when there’s a lack of oversight or guidance over wireless operators.

Opting In Is Redundant
Consumers who consensually call a nationwide Toll-Free number are now being asked to ‘opt in’ before their call is completed. The result is that call abandonment rates have skyrocketed to over 50 percent. Messaging will eventually fall victim to the same narrow views. 

Messaging guidelines recently issued by the CTIAstate that consumers who text a Toll-Free number consent to the communication without needing to opt in. We believe requiring consumers to ‘opt in’ is not only unnecessary; it could even present a hindrance and possible safety issue. 

Let's Enable Location Based Services (LBS)
We support enabling the caller’s non-specific or ‘fuzzy’ geographic location – whether they call or message a Toll-Free number. 

When using course look-up to enable geographic routing of a Toll-Free call or message, telecommunications service providers do not store the consumer’s data, nor do they sell the data. Providers simply geographically route communications using ‘fuzzy’ locations (usually at the tower location and not the consumer’s GPS location), which doesn’t breech privacy.

‘Shared Use’ of high value numbers allows a nationwide business to use a single number such as 800-LAWYERS to provide services across a wide geographic region and have the call automatically routed according to the caller’s ‘fuzzy’ location. Shared Use is also a win for consumers who are directed to the business address closest to them. Plus, Shared Use can significantly increase the value of the most sought-after numbers in the 833 auction. 

Impeding the ability to route calls and messages to Toll-Free numbers to the business closest to the caller’s location (aka ‘Course’ Location Based Services or LBS) could even affect public safety, e.g., when callers contact help lines for poison control, domestic violence, commuter safety and so on. 

We believe the FCC could restore confidence and value to consumers by reminding mobile phone and originating carriers of their obligation to protect consumers’ precise location while providing only ‘fuzzy’ location data to Toll-Free service providers and wireless operators. 

We hope the FCC will support geographic routing and communications by rendering a positive decision on the Petition For Immediate Declaratory Relief or the Petition for Rulemaking, filed by 800 Response Information Services, LLC, CC Docket No. 96-115.

Managing SPAM 
Currently, wireless operators only use a self-managed SPAM reporting system which requires consumers to forward suspected SPAM texts to 7726 (SPAM).

However, we believe a better solution would be to provide critical SPAM data to industry policymakers and operators utilizing a neutral third party. 

By centralizing this data, this third party could alert networks of potential bad actors in real time, which could also prevent network hopping. Artificial Intelligence (AI) could then be used to better understand trends and quickly stop offenders, enabling our industry to maintain the trust consumers have in text messaging as a SPAM-free service.

Oversight Needed to Prevent a Monopoly
Within the existing Toll-Free texting space, the top four wireless operators as well as many other smaller operators use a single vendor that now enjoys a monopolistic proxy role. 

Not only is there no competition, there also is no oversight over this single gateway provider that fails to provide Reasons For Outages (RFO) that can extend for hours or any Service Level Agreements (SLAs) for this mission-critical communications service. 
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The FCC’s deregulation act protects against state and federal communications monopolies that impede interconnection rights. Last year, the FCC classified text messaging as a Title I service. However, we believe that consumer rights, privacy and public safety could be harmed if wireless operators are given complete control with no oversight or guidance.

At MessageComm, part of our mission is to advocate for the future of messaging, which has become a mission-critical communication channel for consumers, business and government alike. This blog summarizes the two Ex Partes filed with the FCC’s Consumer and Governmental Affairs Bureau, Wireless Telecommunications Bureau, and Office of Economics and Analyticsand the Office of Commissioner Jessica Rosenworcel. 
 
We will continue to keep you informed of our progress. We would love for you to join us!

Somos, the provider of trusted, neutral Toll-Free numbering and registry administration services for the telecommunications industry, has announced it has joined MessageComm, the only trade association solely focused on messaging.

“Somos is thrilled to join other thought-leaders in guiding the future of messaging,” said Gina Perini, Somos president and CEO. “As a company driven by fairness and neutrality, we applaud MessageComm’s mission to make messaging the most trusted and reliable form of communication and look forward to being at the forefront of enriching our industry.”

Somos’ Texting & Smart Services (TSS) Registry is the first formal industry-wide system to support the growing demand for the text enablement of Toll-Free Numbers. “The TSS Registry expands the scope of Toll-Free voice services to include text communication. And that helps our Toll-Free subscribers and their customers to make better connections all around,” Perini said.

“The meteoric growth in messaging has created significant security and privacy issues for both consumers and businesses,” said Noah Rafalko, CEO of Midori Interactive, Inc. Rafalko, VoIP pioneer Jeff Pulver, and diversity expert Adis Maria Vila, J.D., MBA share the co-directorship of MessageComm, which has applied for non-profit status.

“Thanks to the support of Somos, NetNumber and many other global telecom leaders, MessageComm is growing into a major force in the messaging industry,” Rafalko said. “Our mission is to make messaging the most trusted and reliable form of communication by creating industry best practices and standards, privacy rules and educational content.“

MessageComm represents a wide variety of industry participants, from carriers to large enterprises, registries to RESP ORGs. It is the only organization that is successfully corralling the combined enthusiasm and expertise of industry participants that have traditionally been in competitive rather than cooperative working relationships.

The new association’s goal is to resolve critical issues around messaging and help the industry evolve and change for the better. Somos and NetNumber are among the many organizations that have joined MessageComm in its quest to define new and better security and communications standards for both existing and future messaging channels.
 
“MessageComm is filling an important need in the broader messaging ecosystem,” said Joel Bernstein, Somos VP of Regulatory and Public Policy. “Toll-Free provides an important platform for messaging and we applaud MessageComm’s commitment to resolving important issues that can hamper growth.”

​“There’s clearly consensus that we must eliminate the noise and frustration from spammers, robocallers and other fraudulent communications that impede consensual communications,” Jeff Pulver said. “We want to bring everyone in the industry together to negotiate best practices, solve security issues and make messaging a golden service. We’re at the cusp of innovation. It’s going to change and it may as well be led by us.”

          Adis Maria Vila, J.D., MBA, has been named a director of MessageComm. Vila, along with VoIP pioneer Jeff Pulver and Midori Interactive CEO Noah Rafalko, will lead the new messaging trade association.
          MessageComm, which has applied for non-profit status, represents a wide variety of telecom industry participants, from carriers to large enterprises, registries to RESP ORGs. MessageComm is the only organization of its kind that is successfully corralling the combined enthusiasm and expertise of industry participants that have traditionally been in competitive rather than cooperative working relationships.
            Multicultural and multilingual, Vila, a Cuban refugee, came to the U.S. in 1962 at the age of eight. In 1982, she was selected a White House Fellow, the premier leadership program in the U.S. She is the former global head of international business development at Vigoro, a $750M international agri-business company and former head of regulatory policy for the western hemisphere at Nortel Networks, a $22B telecom supplier. She was also former secretary and CEO of the Florida State Department of Administration and former assistant secretary and COO of the U.S. Department of Agriculture. 
            An experienced financial executive, Vila qualifies as an audit committee financial expert under SEC and NYSE rules. In 2013, Vila retired from her position as the first chief diversity officer at the U.S. Air Force Academy and founded Vila & Associates, a consultancy focused on helping clients develop strategies to build diverse leadership and foster an inclusive organizational culture. Previously, she was a member of the Board of Directors of the Rural Telephone Bank in Washington D.C. and a member of the Advisory Board of Global Asset Management, a $15 billion mutual fund of Union Bank Suisse (UBS).
            “I am delighted to serve on the board of MessageComm, a trade association that’s ahead of its time,” Vila said. “Companies that would otherwise be competing have joined with mobile operators and regulators to identify and solve key issues facing the quickly evolving yet presently unregulated messaging industry. I hope to bring some of the regulatory experience I gained at Nortel to a group working collaboratively to ensure security in the messaging industry and bring order to the wild west world of messaging.”
            The new association’s goal is to resolve critical issues around messaging and help the industry evolve and change for the better.  MessageComm recently announced that NetNumber, which represents over 100 million individual subscriber numbers, recently joined MessageComm. Other major participants in MessageComm will be announced as they join.
            MessageComm members have been working on several fronts since the inaugural event last April. Last month, 22 representatives from 14 companies attended the  MessageComm meeting held after the Mobile World Congress Americas event in Los Angeles. Participants represented a diverse cross section of messaging innovators and providers, from small to multi-billon dollar industry leaders.Together, MessageComm participants are helping to define better security and communications standards for both existing and future messaging channels. 

Boston, MA, Sept. 12, 2018 – NetNumber has announced it has joined MessageComm, a new communications and messaging trade association. NetNumber operates the Override Services Registry (OSR) which enables efficient and accurate routing of text messaging services in the North American market between mobile operators and a broad community of MVNO and OTT service providers.  The OSR is the world’s largest collection of identifiable text-enabled MVNO and OTT subscriber numbers with over 100 million individual subscriber number entries. 
            Founded by VoIP pioneer Jeff Pulver and Midori Interactive CEO Noah Rafalko, MessageComm, which has applied for non-profit status, represents a wide variety of telecom industry participants, from carriers to large enterprises, registries to RESP ORGs. MessageComm is the only organization of its kind that is successfully corralling the combined enthusiasm and expertise of industry participants that have traditionally been in competitive rather than cooperative working relationships.
            The new association’s goal is to resolve critical issues around messaging and communications and help the industry evolve and change for the better.  NetNumber is just one of the many organizations that are helping MessageComm define new and better security and communications standards for both existing and future messaging channels.
            “NetNumber plays a critical role in the messaging ecosystem today by providing mobile operators, MVNOs, OTTs and value-added Messaging Service Providers with both the routing technology and shared industry data needed to support accurate routing of text messages across the ecosystem,” explains Steve Legge, General Manager of the NetNumber Global Data Service (GDS) business.
            “MessageComm gives the NetNumber team a valuable mechanism for sharing ideas with the messaging ecosystem so that we can continue to play our role as a primary routing infrastructure and registry provider to the industry.”
            “There’s clearly consensus even among industry competitors that we need to eliminate the noise and frustration from spammers, robocallers and other fraudulent communications that impede consensual communications,” Pulver said. “We want to bring everyone in the industry together to negotiate best practices, solve security issues and make messaging a golden service.”
            MessageComm participants have been working on several fronts since the inaugural event in April. Their next meeting will be held in September at the Mobile World Congress Americas event in Los Angeles. Other participants in MessageComm will be announced as they join, as will the outcomes from these large team meetings.
            “We are at that moment of time when things are going to change forever,” Pulver said.  “We’re at the cusp of innovation. It’s going to change and it may as well be led by us.”