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Copy of memo to MCI re: 800-CALL-INFO

daemon@ATHENA.MIT.EDU (David C. Gingrich)
Fri Nov 18 12:55:38 1994

Date: Fri, 18 Nov 1994 12:09:26 -0500
To: resnet-forum@MIT.EDU, telecomreg@relay.adp.wisc.edu
From: gingrich@lma.com (David C. Gingrich)

Dear Rhonda,

I have received your fax of a memo to consultants from Virginia Hennigar
attempting to justify the existence of MCI's 800-CALL-INFO service. I could
not find  Ms. Hennigar listed in any of the MCImail directories available
to me on the Internet, but I did find your listing, so I hope you will
forward my comments to her.

As you are well aware, 800-CALL-INFO has generated considerable
controversy, primarily because there is considerable sensitivity to any
service that generates a charge to the caller for dialing any 800 number.
MCI has been led to the market by many 800 service "scam" plans and now it
appears you have invented one of your own.

Provision of this service may meet the letter of the law as it currently
exists but, in my opinion it is inconsistent with original intent of 800
service and, over the long term, may damage the viability of those
services. If 800 service can no longer be counted on to not generate any
charge to the caller, many system managers will have to consider
restricting the availablity those services.  The most likely restriction in
a PBX or Centrex is simply to block calls to all 800 numbers.  Some systems
may have the software capability to narrow the block to certain numbers or
ranges of numbers, but the management burden of maintaining the tables is
considerable and will simply not be accepted.

You refer to the ability to screen calls from businesses. In most LEC
territories, adding the call screening class marks comes at considerable
expense. Here in Indiana, Ameritech charges $14 per month PER line for this
service. Without it, call screening codes are not delivered to any IXC. My
higher education and healthcare clients have small trunk groups with the
call screening services in place primarily to support 0+ and 10XXX-0+
dialing which is an FCC required provision for resident students and
hospital patients. The FCC does NOT require a university, hospital or hotel
to provide access to 800 services, although most do, because up until now,
there was no risk associated with the service. Now 800-CALL-INFO is a major
hole in most toll restriction schemes and security arrangements. If not
just for the INFO call, but also for calls completed through the service.

You also refer to the ability for businesses to add their numbers to your
screening database. This "negative option" scheme seems presumptuous on
your part, particularly for those organizations that otherwise do not have
a business relationship with MCI. It would seem to me that random, probably
surprise billings to a customer is not a popular way to start a business
relationship.

The benefits of this service to end users are small, NPA-555-1212 has
served us well, (in fact you often pay commissions on 0+ calls). The only
siginificant benefits are to MCI for D/A and call completions that might
otherwise go to another company. The potential for damage to the universal
nature of 800 service is enormous. As long as services such as this exist,
I will recommend to my clients that their internal networks be
substantially blocked to 800 services to prevent unauthorized charges. I
will also recommend that payments not be made for unauthorized charges.

It is amazing to me this program was invented by MCI, one of the major
players in 800 service industry. I hope that it will be withdrawn before
additional damage is done to 800 services in general and specifically to
your company.

Sincerely,
David C. Gingrich

===============================================================
David C. Gingrich, K9DC              Internet: gingrich@lma.com
Lockman Mills & Associates             Office: (317) 845-0204
Telecommunications Consultants            Fax: (317) 845-0163
7007 Graham Road, Suite 201               Res: (317) 849-1353
Indianapolis, Indiana 46220
===============================================================



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