[VOIPSEC] Odd e911 VoIP Regulatory Question

Thu Jan 29 10:11:04 CST 2009

The big picture is that if a user uses the VoIP services as his/her primary
phone line, it deppends on it as a standard PSTN line. This is a big and
endless discussion. This kind of problem could simply been solved by
regulation, like:
"VoIP is a Phone line as has to support the same servile level of PSTN
lines" or
"VoIP is not a standard phone line and the user must be aware that he won´t
have it operational at all times for all services as a PSTN line".

That is how I feel about it worldwide. until goverment don´t define it,
nobody will know for sure.

Example is England, they first tryed to consider VoIP as a standard PSTN
line IF the user uses only VoIP and no PSTN line. They changed their minds
and VoIP will not need to answer the same needs as the PSTN line, but all
user should be aware of that when they buy the service.

André Dutra
Security Consultant

2009/1/29 <voipsec-request at voipsa.org>

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> Today's Topics:
>
>   1. Re: Odd e911 VoIP Regulatory Question (Dustin D. Trammell)
>   2. Re: Odd e911 VoIP Regulatory Question (Carlos Alvarez)
>   3. Re: Odd e911 VoIP Regulatory Question (Danijel Starman)
>   4. Re: Odd e911 VoIP Regulatory Question (Victor Pascual ?vila)
>
>
> ----------------------------------------------------------------------
>
> Message: 1
> Date: Wed, 28 Jan 2009 17:54:17 -0600
> From: "Dustin D. Trammell" <dtrammell at breakingpoint.com>
> Subject: Re: [VOIPSEC] Odd e911 VoIP Regulatory Question
> To: Victor Pascual ?vila <victor.pascual.avila at gmail.com>
> Cc: voipsec at voipsa.org
> Message-ID: <1233186857.32439.108.camel at localhost>
> Content-Type: text/plain; charset=UTF-8
>
> On Wed, 2009-01-28 at 10:39 +0100, Victor Pascual ?vila wrote:
> > On Tue, Jan 27, 2009 at 9:17 PM, J. Oquendo <sil at infiltrated.net> wrote:
> > > Client --> VoIP_Provider --> Carrier (me) --> Calle
> > >
> > > In the scenario where I have to disconnect a mini
> > > VoIP_Provider who I'm supplying trunks to, THEIR
> > > clients won't be able to access e911. Am I mandated
> > > to send e911, is it on the VoIP_Provider...
> > >
> > > Any documentation clarifying this would be greatly
> > > appreciated.
> >
> > IANAL, but from [1]: "Interconnected VoIP providers must transmit all
> > 911 calls"
> >
> > [1] http://www.fcc.gov/cgb/consumerfacts/voip911.html
> >
> > So, I assume you are mandated to forward them-- this is just my
> > understanding from the text.
>
> I am also not a lawyer, but here's my take on this:
>
> If he's disconnecting them due to nonpayment, I would argue that it's
> safe to say that they are no longer a customer.  You left off the second
> half of that bullet point.  Here it is in it's entirety:
>
> "Interconnected VoIP providers must transmit all 911 calls, as well as a
> callback number and the caller?s registered physical location, to the
> appropriate emergency services call center or local emergency
> authority."
>
> This assumes that they have a callback number (not likely when
> disconnected) and the caller's registered location (not likely kept when
> no longer a customer).  Reading that entire page, you get the sense that
> this is a requirement only for the caller's provider in regard to their
> customers, and if they are no longer a customer I don't see the
> requirement likely to apply.  The first and second bullet points under
> the requirements strengthens this assumption, and in regard to the one
> quoted above, how is it even possible to receive a 911 call to then
> transmit if the customer's credentials no longer work due to being
> disconnected?
>
> If an interconnected VoIP provider were mandated to pass 911 calls for
> anyone that was ever their customer, what would prevent me from creating
> a business that explicitly provided free VoIP 911 service, getting
> trunks with as many providers as I can, not paying my bill until they
> disconnect my regular service, and then enjoying the fact that they have
> to route any 911 calls that I route to them forever?
>
> --
> Dustin D. Trammell
> Security Researcher
> BreakingPoint Systems, Inc.
>
>
>
>
> ------------------------------
>
> Message: 2
> Date: Wed, 28 Jan 2009 18:56:49 -0700
> From: Carlos Alvarez <carlos at televolve.com>
> Subject: Re: [VOIPSEC] Odd e911 VoIP Regulatory Question
> To: voipsec at voipsa.org
> Message-ID: <49810CE1.6040504 at televolve.com>
> Content-Type: text/plain; charset=ISO-8859-1; format=flowed
>
> > On Jan 28, 2009, at 4:54 PM, Dustin D. Trammell wrote:
> >
> > If he's disconnecting them due to nonpayment, I would argue that it's
> > safe to say that they are no longer a customer.  You left off the second
> > half of that bullet point.  Here it is in it's entirety:
>
>
> That's a very logical argument.  However, many huge lawsuits have
> drained a lot of money from defendants with a logical defense.  The
> question here is two-fold in my opinion:  What am I legally required to
> do, and what should I do to cover my butt?
>
> We have not yet had to disconnect a customer for non-payment, but this
> discussion has pointed out the need for us to at least include language
> in our contract that specifies that we will not carry 911 calls if a
> customer is disconnected for any reason.
>
>
>
>
>
>
>
> ------------------------------
>
> Message: 3
> Date: Thu, 29 Jan 2009 10:02:58 +0100
> From: Danijel Starman <Danijel.Starman at iskon.hr>
> Subject: Re: [VOIPSEC] Odd e911 VoIP Regulatory Question
> To: "voipsec at voipsa.org" <voipsec at voipsa.org>
> Message-ID:
>        <93FD33B1933B3C40BA00DE109E6EDBA90A5D653AEB at postino.iskon.local>
> Content-Type: text/plain; charset="iso-8859-2"
>
> > -----Original Message-----
> > From: voipsec-bounces at voipsa.org
> > [mailto:voipsec-bounces at voipsa.org] On Behalf Of Carlos Alvarez
> > Sent: 29. sije?anj 2009 2:57
> > To: voipsec at voipsa.org
> > Subject: Re: [VOIPSEC] Odd e911 VoIP Regulatory Question
> >
> > > On Jan 28, 2009, at 4:54 PM, Dustin D. Trammell wrote:
> > >
> > > If he's disconnecting them due to nonpayment, I would argue
> > that it's
> > > safe to say that they are no longer a customer.  You left
> > off the second
> > > half of that bullet point.  Here it is in it's entirety:
> >
> >
> > That's a very logical argument.  However, many huge lawsuits have
> > drained a lot of money from defendants with a logical defense.  The
> > question here is two-fold in my opinion:  What am I legally
> > required to
> > do, and what should I do to cover my butt?
> >
> > We have not yet had to disconnect a customer for non-payment,
> > but this
> > discussion has pointed out the need for us to at least
> > include language
> > in our contract that specifies that we will not carry 911 calls if a
> > customer is disconnected for any reason.
>
> This is an interesting discussion. I think a lawyer should be consulted in
> any case.
> Our residential customers are SIP users, first step after they don't pay
> after warnings is to stop them from making calls except for the emergency
> numbers and our toll free number. We are required by law to do this (In
> Croatia). If the customer doesn't pay after this after a period he is
> deactivated in our system and he can't make any calls. I belive this is in
> the contract the user signs (but I will check). I don't see a reason that a
> SIP trunk (or any other trunk) user should be any different.
>
>
> ------------------------------
>
> Message: 4
> Date: Thu, 29 Jan 2009 11:56:05 +0100
> From: Victor Pascual ?vila <victor.pascual.avila at gmail.com>
> Subject: Re: [VOIPSEC] Odd e911 VoIP Regulatory Question
> To: Danijel Starman <Danijel.Starman at iskon.hr>
> Cc: "voipsec at voipsa.org" <voipsec at voipsa.org>
> Message-ID:
>        <618e24240901290256s407b39e2kdfb58a76eb3cfb88 at mail.gmail.com>
> Content-Type: text/plain; charset=UTF-8
>
> 2009/1/29 Danijel Starman <Danijel.Starman at iskon.hr>:
> >> -----Original Message-----
> >> From: voipsec-bounces at voipsa.org
> >> [mailto:voipsec-bounces at voipsa.org] On Behalf Of Carlos Alvarez
> >> Sent: 29. sije?anj 2009 2:57
> >> To: voipsec at voipsa.org
> >> Subject: Re: [VOIPSEC] Odd e911 VoIP Regulatory Question
> >>
> >> > On Jan 28, 2009, at 4:54 PM, Dustin D. Trammell wrote:
> >> >
> >> > If he's disconnecting them due to nonpayment, I would argue
> >> that it's
> >> > safe to say that they are no longer a customer.  You left
> >> off the second
> >> > half of that bullet point.  Here it is in it's entirety:
> >>
> >>
> >> That's a very logical argument.  However, many huge lawsuits have
> >> drained a lot of money from defendants with a logical defense.  The
> >> question here is two-fold in my opinion:  What am I legally
> >> required to
> >> do, and what should I do to cover my butt?
> >>
> >> We have not yet had to disconnect a customer for non-payment,
> >> but this
> >> discussion has pointed out the need for us to at least
> >> include language
> >> in our contract that specifies that we will not carry 911 calls if a
> >> customer is disconnected for any reason.
> >
> > This is an interesting discussion. I think a lawyer should be consulted
> in any case.
> > Our residential customers are SIP users, first step after they don't pay
> after warnings is to stop them from making calls except for the emergency
> numbers and our toll free number. We are required by law to do this (In
> Croatia). If the customer doesn't pay after this after a period he is
> deactivated in our system and he can't make any calls. I belive this is in
> the contract the user signs (but I will check). I don't see a reason that a
> SIP trunk (or any other trunk) user should be any different.
>
> I've just taken out my SIM card from my GSM phone, and I can still
> dial the emergency number (112). Why should this be different for VoIP
> networks?
> --
> Victor Pascual ?vila
>
>
>
> ------------------------------
>
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