Telecom's Plumbing Problem: Routing, Regulation, and What Comes Next - Episode 669 of the Community Broadband Bits Podcast

Christopher Mitchell (00:12)
Welcome to another episode of the Community Broadband Bits podcast. I'm Christopher Mitchell at the Institute for Local Self-Reliance. I'm in St. Paul, Minnesota. We're off and on today. It looks like a snow globe. And Richard, I think it's pretty much the same for you out there in the Eastern part. It's dang, dang just cold. No snow globe. We've got Richard Shockey with Shockey Consulting and Chairman of the Board of the SIP Forum. Welcome back to the show, Richard.

Richard Shockey (00:30)
We're just cold. We're just cold.

Always a pleasure.

Christopher Mitchell (00:43)
You were on 7 years ago where we explained to everyone a number of these issues and I think later on in the show I'll ask you if we've made as much progress as you thought we would. Not as much as you knew we could, but if we made as much as you thought we might. But I want to start off by asking you, if we disconnected this video call right now and I picked up my mobile phone and I called your mobile phone, can you just give me a sense of how that technology works?

Richard Shockey (01:10)
Well, yeah, it is a complicated process. And I always tell people, you know, the government wanted competitive voice communications networks, and they got them. Okay. You don't think about calling Los Angeles or even London or Toronto or even Mexico City any longer. You just pick up the phone and dial. Okay.

And that was because in the 1996 Act the government permitted multiple entities to basically do voice communications and get access to telephone numbers. Now, the principal mechanism now is 70 % of all calls originate or terminate on a mobile network. That means AT&T, Verizon, T-Mobile, et cetera.

Etc. And they use the SIP protocol to do that. And SIP has been around for almost 30 years, basically since 2000. Henning Schulz fundamentally designed it. For the tactically oriented, it's really a variant of HTTP. It's an offer answer protocol. You send a little message.

over to the other guy going, can you do A, B, E, F, G? Here are the codices that I can support. and do you accept the call or not? Okay. So that, you know, that voice over IP is the principle way most calls in the United States operate. There is still a legacy network.

which is typically referred to as time division multiplexing and signaling system seven that uses the classic old analog like mechanisms out there. It is still there and part of the problems we have in the modern network is that legacy network is causing difficulties for everyone because corporate enterprises

that are trying to reach you for perfectly legitimate reasons. Yes, we're going to cut off your electricity or your gas, or we've detected fraud in your banking one way or the other. A lot of them are still using these analog networks. And there's issues involving how the traditional legacy network interconnects

with the modern VOIP network. And what we are still seeing is, okay, you wanted competitive voice markets, no good deed goes unpunished. And that's a...

Christopher Mitchell (03:58)
Right. This is, this

is one of those things that I think we can agree. Like we can disagree on a bunch of stuff on the 96 Act but like the success of competitive voice markets is pretty much like, there's, there's not a lot to argue about. We succeeded.

Richard Shockey (04:10)
There's not

a lot, there isn't, really. Again, you don't think about calling your grandma in Berkeley, California, if you want to, and talk for hours. Nobody cares about that anymore. And by the way, the effect of voice, really on the general Internet is so trivial to be, you're talking about less than .05 % of

Internet traffic is really voice. mean, you know, as an engineer, mean, my shock has always been, my God, we killed television. We killed linear television and the Internet still seems to work, you know, way or the other. So, you know, one of the issues is the cost of transport for both real-time tax and real-time voice is so negligible.

that it's creating all these particular kinds of issues. So in general, go ahead.

Christopher Mitchell (05:13)
Well, let me, I could,

so if I, in general, realizing that there's always weird complications and edge cases, if I call you and you're on T-Mobile and I'm on Verizon, we are all digital, there's no touching the legacy network, right? But then if I'm using a line where I'm actually connected to the wall with like one of the old schools at RJ12, like the copper line,

Richard Shockey (05:40)
For J11, yeah.

Christopher Mitchell (05:41)
RJ11, thank you. And then, and it's, you know, with a, when I have a contract with a local telephone company or something like that, then that is almost certainly legacy. Is that right? Or is there more complicated?

Richard Shockey (05:51)
Not necessarily,

it depends. Okay, so if you look at customer premise equipment, which is where you're talking about, you've got a legacy phone. I still have one, you know. The legacy phone connects to the service provider, typically through an analog device, either built into the box, hanging off the side of your wall.

or by some other mechanism. So I live in Northern Virginia and I have Verizon Fios. It's all fiber, all optical. It's wonderful, it's great. You know, I'm happy to write Verizon a check every single solitary month, but I've still got four pair RJ11 connections inside the house. However, they connect to the device.

attached to the side of my wall outside and there is where the analog to digital conversion actually occurs. So at that particular point, the call is all IP is routed into I'm shocked, I'm shocked, a data center, you know, because in Northern Virginia, less, and we've got a lot of those puppies, let me tell you here.

Christopher Mitchell (07:04)
In Northern Virginia, no less.

Richard Shockey (07:11)
about 620 at last count. So, well, yeah, you know, and I can do a podcast on data centers in Northern Virginia off the top of my head, but that's separate issue. So the idea that you have these big old monstrous central offices that have big old class five switches connecting calls, it's gone. It's with.

Christopher Mitchell (07:38)
Mm-hmm.

Richard Shockey (07:40)
Those things have been, you know, recycled, get the gold out of the circuit boards and when we are, and you know, there was, you know, big companies like Lulun and even Alcatel and when we are in Siemens, there are a lot of bills. These are all basically soft switches, which are the size of pretty much a small office refrigerator. Okay. Then each one can handle

hundreds and hundreds of thousands of call transparently every civil solitary day. There are issues in the way some legacy systems interconnect with each other and those are part of the kinds of proceedings that we see at the Federal Communications Commission. The FCC again has taken a gradual

process towards this, you know, because they, we still need voice, okay. The connection of voice to 911 is irrevocable. You can't upset the Apple car all that much without putting public safety in danger. So you've got all of these various kinds of issues here.

It's my belief that the FCC is moving towards several things. Basically setting a date specific by which the legacy voice network is in fact disconnected. The last switch will be sent to a telco museum someplace in Minneapolis or one way or the other. Yeah. So.

Christopher Mitchell (09:24)
There's a good one out in the Seattle area now.

Richard Shockey (09:29)
They're going to go away. In addition to that, there is an additional proceeding which is, I think it's quite important. The FCC is talking about mandating, using its authority, to mandate what is known as rich called data. The idea is within the SIP protocol, we've developed concepts and they're ITF based.

that would basically display on your devices exactly, they cryptographically ensure that the data that you see on your phone is in fact accurate and has been verified. Now what rich call data looks like is, okay, it's not only just name, it's potentially,

128 characters of ASCII. It could be reason for call and it could be logos and you know theme songs.

Christopher Mitchell (10:27)
This was

a lot of flexibility and it would come with a high level of trust.

Richard Shockey (10:32)
The highest level of trust cryptographically secure. Of course, that creates all kinds of other issues, which is the carrier needs to know who their customer are and can actually do the identity management and verification for doing this one way or another. So in terms of the basic problem.

data today that came out from one of the most reliable sources, which is U-Mail, basically going that we're still seeing, what is it, 3.8 billion robocalls a month. That is actually stable now month to month, one way or the other. Go ahead.

Christopher Mitchell (11:14)
Can ask,

definitionally, a robo call, does that include my son's school? Are we talking about calls that are unwanted when you use that number? Okay.

Richard Shockey (11:24)
Unwanted.

Good point. Right. So when your school district calls you about issues, pick up, you know, two feet of snow are coming in Minneapolis, maybe you to get your kid out, you know, that's exactly what it boils down to. Of course, one of the things we need to touch on a little bit later is impersonation scams, which is

Christopher Mitchell (11:49)
Mm-hmm.

Richard Shockey (11:52)
I am personally a great skeptic about AI. I think, you know, yes, it is a bubble. You can't spend a trillion dollars in capital without some return on invested capital. Gee, I'm shocked. I'm shocked. But, you know, the impersonation scams that, you know, people are trying to call, they're impersonating school districts.

Okay. And they're using AI to train the voice impersonation algorithms. So they try and call grandma or grandpa or aunts and uncles, you know, ⁓ my God, you know, I'm Julie, I'm in jail, come bail me out. it's like, yeah, just send me a gift card, you know, something along those lines. it impersonate, pardon me.

Christopher Mitchell (12:41)
And

this is, ⁓ and what you're talking about, this is important for what we've been talking about. It's related because it's that, I think what you're gonna say is that that interface between the legacy and the current SIP is where there's the opportunity for the scammers to get into the system, right?

Richard Shockey (13:00)
Correct, absolutely. And the FCC, wisely, has identified this. moving the federal bureaucracy is challenging.

It's not exactly the myth of Sisyphus, regulators are trying to be relatively cautious and give this idea that we're just going to turn it off. Now, we've actually done that before. I mean, we turned off essentially analog television, moved the channels around back and forth, and freed up.

endless spectrum for wireless applications. And guess what? It worked. It worked like a s-

Christopher Mitchell (13:41)
It did.

Endless is an interesting word. think there's an end to it. Now, when you say this, I think the concern has been with shutting it down, any number of things, including services that were built for the older system that deal with, think, people that have hearing issues and burglary systems that have refused to modernize. Those are the things that are often raised.

Richard Shockey (13:45)
There was an actual end.

The burger, yeah, the burger alarms were classic.

Right, they're always raised. But at some particular point in time, the dinosaurs went extinct. And stuff needs to be turned off. And not only that, mean, for...

For legacy technology, the US did in fact turn off 2G, 3G, and increasingly 4G wireless networks in favor of 5G and the soon to be whatever it is, 6G basic networks. And those transitions worked. And I could spend at least a half an hour explaining why they worked and why they worked so well.

But that allowed the carriers to take some of that spectrum in 2G, 3G, and 4G, re-map it to 5G, and increase the range, accuracy, and reliability of the wireless networks by an order of magnitude. the other thing about that was it created some really neat

Christopher Mitchell (15:05)
So.

Richard Shockey (15:10)
opportunities. mean, right now, for the wireless carriers, fixed wireless access is a big, big deal. They are, I think, the current numbers I've seen is 20 million American consumers are getting their broadband access, not from a landline provider, but basically from the wireless network itself.

Christopher Mitchell (15:37)
Yeah, think Comcast

and Charter's share price reflects that.

Richard Shockey (15:42)
Exact bingo. yeah, they got this and

Christopher Mitchell (15:46)
Well, let me ask, so is this,

would you say, I mean, I want to jump too far ahead and spoil things, but it seems like, you know, what you're suggesting is that, is that the best solution to deal with robo calls and unwanted calls is to just move as fast as we can to getting rid of the legacy interconnections, basically.

Richard Shockey (16:05)
Yes, and yes, let's put it that way, which is, you know, when we did the famous stir-shaken protocol in SIP, which basically cryptographically identified who, which entity actually owned the phone number. We kept telling people over and over and over again, this is not a silver bullet.

Okay, it's a question of one thing at a time that has to be put in place that helps protect consumers, you know, and protect businesses because financial institutions, healthcare institutions, I mean, they're sick of it. Nobody answers their phone any longer. and so initiatives like Rich Call Data,

it's also called branded calling you can look this stuff up on the Internet it's all over those kinds of things combined with all i p network and frankly a little bit more aggressive actions by law enforcement which is i have nothing but admiration and respect for a lot of the state attorney generals including

Christopher Mitchell (17:15)
Mm-hmm.

Richard Shockey (17:23)
Minnesota and North Carolina and here in Virginia about trying to hold the carriers responsible for what they can do. However, it would be really nice to put somebody in jail. I'd like to see some RoboCall Perp Watch. The United States Justice Department has a lovely facility.

in Florence, Colorado, which is, you know, I'm sure they could make room for a few robo-callers one way or the other. I mean, they've got all the spies, got all the traitors.

⁓ What's a robo-caller out there in Florence? Lock them up. Let's do some purple.

Christopher Mitchell (18:07)
So

to be clear then, we've seen bragging to some extent from the FCC on some of the size of the fines for robocallers. And that has not led to ⁓ what you would say is enough attention being paid, not just to other potential robocallers, like sort of the next scammer, but also to people who are being perhaps negligent. I don't want to go too far.

But like, but you're saying like you need to get the attention not just of criminals, but also people who are running systems from the telephone company or in order to make sure they're paying proper attention. Okay.

Richard Shockey (18:41)
It's all of

the above. It's a full spectrum. But you talk about FCC fines, the nasty question you have to ask is, how many of those fines have they actually collapsed?

Christopher Mitchell (18:57)
I was wondering.

Richard Shockey (18:58)
Well, you know, how many fingers do you see on his?

Christopher Mitchell (19:03)
We four or five depending on the whole thumb question.

Richard Shockey (19:05)
Right, right.

The problem is the FCC is not a law enforcement agency. Their powers are severely circumscribed by statute. And they can find people, but only the United States Department of Justice can actually collect. And for some reason, they seem to be busy with other kinds of things these days.

So again, it's not to fault. You know, the FBI or Department of Justice is that, if, you know, the FCC could pull licenses and the RoboCall mitigation database does that, in essence, by saying, if you don't comply with our rules, you are prohibited from interconnecting with any other carrier.

Christopher Mitchell (19:59)
Mm-hmm.

Richard Shockey (20:00)
which is really license revoked.

Christopher Mitchell (20:02)
And so this would apply to then a legitimate business actor within the telephone system. So if I'm a robo-caller and I'm abusing some technical gap to get in, what you're saying is that there's someone who is in a position of responsibility that is not closing that gap, who we need to get their attention in a sense of consequences for them to do their job and to close down that entry point. And that's just not happening.

Richard Shockey (20:29)
Well, yeah,

mean every major carrier in the state attorney general literally this week, know, sent out essentially demand notices to some very, very large firms. Basically saying, you're not, you have interconnection agreements with some of these entities and you are taking their traffic, you're cashing their checks, but you don't know who they are. So it's this.

know your customer problem. And there was a very famous case last year, a very, very reputable firm. Telnet was given a notice of apparent liability, which is essentially we got you kiddo. Okay. And they were basically told you are liable for $4.5 million in fines.

because you did not adequately vet who your customers were. In fact, when the story finally came out, Talonix was told that there was a problem. They immediately took remedial action, et cetera, et cetera. But then Talonix had to come back and go, how can you fine us for a violation of Know Your Customer when the FCC itself

actually has no policy about know your customer. I mean, there's no, you know, rule and order that basically says you have to do A, B, C, D, E, F, G to basically verify the validity of an entity that you're engaging in wholesale traffic origination.

Christopher Mitchell (22:04)
Mm-hmm.

Presumably there's a fear that that could be overwhelming and stifling of that a lot of networks have so many that it would be difficult for them to comply. I'm assuming. I don't know.

Richard Shockey (22:29)
Well,

yeah, but if this situation keeps going on again, I mean, I do have a great deal of respect for the FCC and staff at the wireline competition bureau that has to manage this process. But again, if you if you turn, you know, where's my wrench? Here, you know, if you you pull the wrench out and just keep tightening it one way after another.

Yeah, there will be some dislocation. then it turns into essentially something like it's a cost benefit analysis at that particular point, which is what is the cost to the United States, to American consumers of allowing these frauds to continue versus some additional bureaucratic mechanism. But the FCC itself

Christopher Mitchell (22:59)
Mm-hmm.

Richard Shockey (23:23)
have to say this is what Know Your Customer really is. These are the five, six proactive steps that you will be required to do before you allow someone to interconnect with you. And by the way, the problem is not just the United States. Everybody knows that it's a problem in Canada, it's a problem in the United Kingdom. There's a

Christopher Mitchell (23:29)
Mm-hmm.

Richard Shockey (23:53)
Five Eyes issues, certainly New Zealand, and especially in Australia, but the penalties in Australia are much more severe. And they're remarkably severe in Europe in general. So spoofing a telephone number in Germany, for instance.

triggers a 24,000 euro fine per incident.

Christopher Mitchell (24:23)
So I would hope they have a lot less of it.

Richard Shockey (24:26)
And surprise, surprise, have a lot, you I mean, they're not exactly, you know, ⁓

RoboCall hubs in the Philippines that speak German. Okay. ⁓ and there's one other thing that Germany does, which I absolutely admire. The BISDAA, the German regulator, has the legal authority to go into court, pre-adjudication, pre-adjudication, and lock down the bank account.

Christopher Mitchell (24:35)
Well, think I think with Canada if you want to scam them

Richard Shockey (24:59)
of any perpetrator they choose to do so. And this even before ruling, they just walk into a federal German court and go, we think this guy is a bad actor. Lock, lock his accounts down until. Oh, they went well, they well, it's a lower burden of proof in the sense that yeah, here's shut, you know, take lock their money down. You know, the money is.

Christopher Mitchell (25:15)
I would hope they have a higher burden of proof, but it's a...

Richard Shockey (25:28)
Shaki's law money is the answer. What is the question if you can get access to their bank accounts? Get access to the money flows So I mean, you know again in Germany, they don't have they have some But it it's not the scale that we've seen in Canada Britain there's a fair amount in France

And the robocall centers in France are all, I'm shocked, I'm shocked, in Algeria. ⁓

Christopher Mitchell (26:00)
You know, I was going to suggest

that the challenge of doing the robocalls in Canada is that you need to have them in both English and French.

Richard Shockey (26:08)
So that cuts down a little bit there while we are. And of course, I've had dealings with CRTC, the Canadian regulator, yeah, they know all this sort of stuff. It's a question of regulatory priorities. CRTC has a much larger brief than the FCC does.

Christopher Mitchell (26:17)
the Canadian regulator.

Richard Shockey (26:32)
They literally do regulate media.

Christopher Mitchell (26:35)
Let

me ask you something. So I was curious about this because with the robo calls, again, there's a definitional issue. There's clearly scammers, right? People that are going to tell me about my extended warranty does not exist. They never intend to have a business relationship with me, but I also get calls here in Minnesota. We get hail storms and then we get storms of roofers and I'm on the do not call list and the roofers, but the roofers want to have a real relationship with me, right? They want to send someone on.

Richard Shockey (26:55)
Alright.

Christopher Mitchell (27:01)
I don't know if it's just a lead agency, like, these the same sorts of technologies and things or the roofer is just calling? Like, do you have any sense of, is there a difference between those and the robo calls that we get?

Richard Shockey (27:13)
No. But from a technical perspective, they're exactly the same. Now, how they're getting lists of numbers is the interesting question. They're buying lists from somebody. And they're available. You can find them on the Internet one way or the other. And then they're just going down the list.

Christopher Mitchell (27:17)
Okay.

Richard Shockey (27:38)
And I've actually had those roofer guys call my home in Virginia after a hail storm. Yep. Classic. Absolutely classic stuff.

Christopher Mitchell (27:49)
So it's the same,

it's just a blatant scam and then they're handing off the lead likely and and hopefully just assuming they're not gonna get caught. And there's a plausible deniability between the company that's taking the leads and that, you have any sense? I mean, I know this isn't the technical operations of the phone company, but.

Richard Shockey (28:02)
Well, yeah, but

I mean, but you know, there are rules about this stuff. There is an act, the Telephone Consumer Protection Act, which is actually quite explicit about who you can call, why, and for what reasons. You have to have prior business relationship in some way, shape, or form. So the calls you get from your school district are clearly covered under TCPA.

you have a relationship with your local school district and your kids. there are clear exemptions for healthcare providers and certainly fiduciaries. That means banks, brokerage firms, loan processors, okay? Everybody.

Christopher Mitchell (28:48)
Certainly if you think

that someone's refrigerator is running.

Richard Shockey (28:52)
Right. It's not that you're right, but the loan processors in particular, they have a prima facie case for calling you. They want the money.

Christopher Mitchell (29:02)
And they're not going to mind if

they're authenticated. I mean, this is sort of back. Yeah.

Richard Shockey (29:06)
Now,

and utilities, by the way, utilities have an almost blanket exception for any number of reasons. The principal reasons being that they are going to call tax, what way, other, when you haven't paid your bill and they're going to cut you off is what it boils down to. And also, you know,

state local governments for emergency weather alerts, okay, of one form or the other. And there are statutory exemptions for legitimate law enforcement agencies. know, know, someone's prowling your neighborhood, don't open the door, you know, that kind of thing one way the other. So the TCPA, it used to be a favorite.

Christopher Mitchell (29:46)
Mm-hmm.

Richard Shockey (29:55)
of the plaintiff's bar, which is the TCPA lawyers were worse than ambulance chasers because there were statutory fines associated with it. So they would just go into court and go, yeah, you owe me, you know, $800,000. But the courts have reigned in those issues quite a bit. Still needs to be clarified somewhat, but.

I mean, realistically, common sense in terms of robocalls within the defined scope has actually been pretty good. It's really the guys, you know, the auto-warranty idiots and all the other kinds of stuff that are out there. But consumers do actually have to be proactive at the same time, which is...

If you don't recognize the number on the phone, you don't answer it, which is why Brent. Yeah. Right.

Christopher Mitchell (30:55)
Well, think increasingly we don't even have the option, right? I mean, both Apple and Android

have these systems now in which, and perhaps you know, I assume Stir Shaken has something to do with like other systems in which they determine the likelihood of a call being spam.

Richard Shockey (31:11)
And there are at least six firms that I know intimately that does this on a network layer basis. There's wonderful firms like HIA, T &S, U-Mail, TransUnion, First Orion. First Orion, in particular, the call authentication verification for T-Mobile. HIA does AT&T.

TNS does Verizon. So the network operators have some systems in place. And here's the other thing, which is the complaint was sometimes you'll get a call and it will say spam likely. And, you know, the false positive rates on some of these analytic engines.

is not huge, but it's significant enough. Therefore, it may well actually be Bank of America that's trying to call you. Okay.

Christopher Mitchell (32:12)
Right,

get this, my healthcare provider sometimes falls into it. Certainly a non-profit group looking for fundraising with whom I have a relationship, those often fall into that.

Richard Shockey (32:18)
Yes.

Right, and so you had to have some sort of system in place where you notify the carriers that no, no, no, no, no, this is actually a legitimate number by a legitimate organization with prior business relationship or one way or the other because those spam likely labels couldn't themselves be dangerous. So some sort of false positive remediation.

is what the FCC in the last 18 months has been adamant about. Specifically, nonprofits being a very, very good example of that. But unfortunately, some of these companies, they've done questionable things about how to get people to answer the calls. So they'll get a block of numbers, and they'll just rotate them.

right left for a limited period of time and then dump them back on the carrier because

Christopher Mitchell (33:23)
That's where they originate their call from is that block of numbers.

Richard Shockey (33:26)
Right.

Is that block of numbers, which are the legitimate numbers, but they're only used to try and, circumvent the carrier discovering that it's really a robocall campaign. Even if it is, even if it's legit, even if it's legitimate. Okay. Because they're trying to avoid the, possible spam label and mislabeling.

Christopher Mitchell (33:41)
And when you say that though, okay. Right.

Richard Shockey (33:54)
is a problem. Everybody understands it. It's

Christopher Mitchell (33:58)
So these

robocallers, they're acting legitimately and they're not exploiting that interface between legacy and the digital SIP.

Richard Shockey (34:08)
No, they're trying to get somebody to answer the phone. Okay. And you know, the problem of call completion is what has vac'd the, they call it the consumer experience. It's really the call center. Consumer experience data. BS like, you know, phrase what we have. And there's a massive industry for, you know, consumer experiences and the people who are trying to deal with this and

Christopher Mitchell (34:10)
Right.

Richard Shockey (34:35)
Number one, it's financial institutions, the fiduciaries. Number two is healthcare because I don't know about you. If I have to go to my doctor, I must get 10 messages pre-appointment to make sure I will show up. There are companies that do nothing, but it's the wildest little business.

Christopher Mitchell (34:51)
Yes.

Richard Shockey (35:00)
So you've got all of these companies that basically do vertical market application. The problem with voice is no business calls AT&T to get phone service. They call a smaller, know, C-Lac or basically one of these smaller customer experience, know, call center firms. So there is

three firms that I know of that do nothing but auto dealerships. Surprise, surprise, they're trying to get you on the phone to pick up your car. Okay. And so they do voice, they do text, they do email, one way or the other. And they sell their services because they know their customers. It's a vertical market. Okay.

Christopher Mitchell (35:49)
So I'm confused by this. Wouldn't they benefit from using the system in which they can authenticate themselves and say, yes, this is Joe's auto?

Richard Shockey (35:56)
They're doing it slowly

but deliberately. because there's, surprise, you've got branded calling out there and they're trying to sell it but somebody has to buy it. Okay.

It's an unregulated service right now, which is the price model for branded calling is whatever the market will bear. And I don't want to quote numbers, so I don't want to piss off too many of my friends. But again, auto dealerships have been remarkably well targeted. In addition to that, veterinarians.

Christopher Mitchell (36:18)
Okay.

Richard Shockey (36:32)
come and get your dog out of the animal hospital. He's fine one way or the other. Oh, these are absolutely legitimate calls.

Christopher Mitchell (36:39)
And these are legitimate calls. This is like, I've dropped my dog off and they're trying to make sure that I'm going

to get back before they close for the day and things like that.

Richard Shockey (36:47)
Right. And you know, there's a prior business relationship and so they're calling, but since they're not in your phone book, you don't answer the call. Right. The other is the major pizza delivery change. Domino's. Cause you've got guys out there that may own 15 or 20 Domino's restaurants in a particular city.

Christopher Mitchell (36:56)
Mm-hmm.

Richard Shockey (37:14)
township or county one way or the other. And, you know, they literally would like to play the dominoes chimes when the guy is at pounding your door with your pizza. And, you know, there's these vertical consumer experience vendors are just racing through vertical markets.

Christopher Mitchell (37:26)
Right. Right.

Richard Shockey (37:42)
Because frankly, AT&T and even Lumen and Verizon, it's just too small a market for them now. Now with these kinds of margins, know, again, you know, it's no good decos unpunished. So these, the consumer experience marketplace has moved in to, into these particularly unique areas.

It's the strip mall market, all of those guys. I've heard that there is one company that does nothing but hair salons for exactly the same reason. You make an appointment to get your hair cut one way or the other. They're going to send you a text. They're going send you an email. They're going to call you, you know, a half an hour before appointment because they want you to show up because you're not

Christopher Mitchell (38:22)
Mm-hmm.

yeah, the no-show rates,

for people who are responsible that like go to places, i feel like we're always surprised when we find out how many people don't

Richard Shockey (38:43)
How many people don't answer their phone?

Christopher Mitchell (38:45)
Yeah, or just like miss their appointments or I mean, and the head in the healthcare field, like I'm you know, we talk about no show rates and like 30 % I want to say like, I mean, it's shocking.

Richard Shockey (38:48)
yeah!

yeah,

right. And this is a problem that RoboCalls ultimately created. Now there are again clever solutions to this and it's gonna take time to work through it. But you know, imagine missing an appointment to pick up your dog at the veterinary.

Christopher Mitchell (39:12)
So you're saying I mean to make what we're talking about this is because Some people you might be under the impression that like well, we just stop answering our phones No big deal and you're saying there's a lot of legitimate reasons people may want to answer the phone from an unknown caller and we need a technical system that will allow this to happen

Richard Shockey (39:31)
Precisely, precisely, and that it's trusted, verifiable, and cryptographically secure.

Christopher Mitchell (39:38)
And you think we're heading there? We're not rushing there. So what do we have to do? What do we have to do? So obviously we talked already about shutting down the legacy system would do that. I think, you know, my friends at public knowledge would probably have a few reasons why they're hesitant to rush into that. But what

Richard Shockey (39:40)
Yes, we're not, we're heading there. Are we there yet? No. ⁓ but I mean.

no, no, look,

mean, Harold Feld and I, you know, chat all the time. I have nothing but respect for public knowledge, will we ever. And I know they have been deeply concerned about the transition issues because and, and they are legitimate, but you know, what Harold and I had, you know, public knowledge and I had talked about in the past was look.

It's got to, you got to turn this stuff off and we've got to turn it off. You can put guard rails in place, but, the last couple of FCC rulings has given the carriers extraordinary power to disconnect without doing a thing. And it's gotten, for instance, the California public utilities commission absolutely live it. And

Christopher Mitchell (40:29)
Yeah, we do at some point. Yeah.

Mm-hmm.

Richard Shockey (40:55)
Basically, AT&T told the California PUC, tough. This is an interstate service. We're regulated by the FCC. If you don't like it, take us to court. And California has refused to take AT&T to court over the two. It's called, tactically, the 214 disconnect notices. And I live with that.

here in Virginia a decade ago when Verizon did the major Fios rollout. Okay. They basically sent us a letter going, well, we're going to turn that copper off. You're going to have Fios with voice at exactly the same price, but you're not going to get DSL out of us anymore.

Christopher Mitchell (41:30)
Right.

Right, because it's fantastically expensive. I mean, at a certain point, like, you know, when you're, when you're having to maintain so many fixed costs, in order to support a dwindling number of users, there's reasons why, like from a public interest point of view, I can see why we would want to keep it on. But at a certain point, the costs are the costs and, and like, we just have to move ahead.

Richard Shockey (42:03)
Well, yeah. And the,

and you were, you were right earlier. The burglar alarm guys have been living from day one and you know, the basic attitude is now you don't like it.

Christopher Mitchell (42:16)
Right. Yeah, I mean, it's been, it's not, not, it's not been five years. It's not been 10 years. It's been more than 15, least from my personal knowledge. It's been a minute.

Richard Shockey (42:17)
you know, find a new technology.

Well, yeah, and I've been in the voiceover IP world for now, oh god, 25 years. You know, I've been dealing with this sort of stuff. And, you know, there is progress. I wouldn't exactly call it hope, but there are things, you know, I do think staff at the FCC basically get it now and, you know,

Christopher Mitchell (42:42)
Mm-hmm.

Richard Shockey (42:53)
They've taken a responsible way of dealing with this. Cause again, they, you you've read FCC filings. It's like, if you ever have insomnia, let me tell you. ⁓ jeez.

Christopher Mitchell (43:05)
Well, this

is my question, because you mentioned FCC staff. This is not something where you just have to convince three commissioners and move ahead. This is like the staff themselves need to be educated and understand a variety of the impacts and the needs and things like that. So it's been a massive education process.

Richard Shockey (43:23)
Well, and

I am going to be critical about them in one sense. The tactical expertise in the wireline parts of the FCC has been, it's not the same as it used to be. Now the FCC has excellent engineers dealing with spectrum. The spectrum issues are really what

motivates Chairman Carr, and they're on a reasonable track basically to expand, you know, they want to do another auction. They finally got Congress to approve it. So, you know, there's a lot of what

Christopher Mitchell (44:04)
briefing on a tribal priority

or the briefing on a tribal licensing window which I'm excited about.

Richard Shockey (44:11)
Yeah, mean, yeah, it's spectrum in tribal areas. mean, that's they're really, really quite good at dealing with radio frequency issues and stuff like that. And, you know, there is, you know, finally, by the grace of God, NTIA will get some BEAD money out the door for the underlying wire, you know, sort of stuff later. So.

Christopher Mitchell (44:22)
Right, right.

We'll see. I think there's a possibility that it all goes to Musk. I'm not convinced.

Richard Shockey (44:37)
I can't count.

Christopher Mitchell (44:43)
But you're making the point. are you saying the wireline engineers are kind of lacking compared to other areas where the engineering skills in the wireline aren't as top of the game as they are in other aspects of the FCC?

Richard Shockey (44:56)
You might think that I couldn't possibly comment.

Christopher Mitchell (45:00)
Okay, so I just want to make sure, because you say like, it wasn't clear to me as someone who's not been around if it has atrophied over the years as wireline has, you I think sort of, you know, there's the whole pixie dusk thing and I feel like the need to understand the spectrum seems to be declining with the retirement of all the people who, sorry, I spectrum, but I analog systems. You know, basically everyone who grew up with it is retiring.

Richard Shockey (45:23)
Either they're retiring or they're six feet under. I mean, literal. A different form of retirement, absolutely.

Christopher Mitchell (45:26)
Mm-hmm. Right. Well, that's just a different retirement. right. Okay. So,

so we need to see, you know, the FCC getting, I think moving this ahead a little more urgency is one of the things I'm getting from you in terms of that. Once we do make throw that switch and the legacy system is no longer preventing a surface for scammers to jump in, you feel like we're going to be in a very good position.

because of authentication requirements.

Richard Shockey (45:55)
Well, mean, here's the problem with technology like this, which is, you know, two steps forward, one step back. We may actually create problems we hadn't anticipated. OK, so, you know, it is I think the FCC has been sensible in, you know, that they come out with a new robocall order about once a quarter. OK, and.

you know, learn from experience, learn from, you know, you know, actual data in the field, and then adjust accordingly. But, you know, we're going to see this all in, we're going to see progress, and I actually do mean progress, in 2026. Implementing that progress, well, that's going to take some time. I mean, if they, you know, the number,

that's been floated around, would be potentially December 29, 2029 to turn it off. It's not like it's flipping a switch. But with the carriers and everybody else have to, I mean, they actually have to plan some of this stuff out. And there's a variety of issues in terms of

how numbering policy is deployed, who gets numbers and why, how that interconnection works. But one of the things that I forgot to mention was if you go all IP, the ability to trace the bad actors back enhances by an order of magnitude. I cannot say

enough nice things about US telecom and their traceback group. I cannot say that, look, mean, even public knowledge and stuff like that would agree with it. They've done a fine job. They've reduced the turnaround time on being able to isolate and identify bad actors from days to minutes.

Christopher Mitchell (47:39)
Sorry, we're out of time. No, I'm just kidding.

Richard Shockey (48:01)
They really thought it was pretty decent job, but it's that legacy network that continues to...

cause trouble and if it does take three years to turn it off, then so be it. the process needs to start now and I have a reasonable amount of confidence the FCC is willing to do it and willing to mandate rich called data across the network to be able to get people to answer the phone.

Christopher Mitchell (48:33)
was arguing against the rich call data.

Richard Shockey (48:35)
No one. No one would dare argue against it. The problem, of course, is carriers hate mandates. Then there's cost of implementation and cost to deploy.

Christopher Mitchell (48:37)
Sometimes that's worse.

Richard Shockey (48:53)
Those questions haven't been answered yet.

But tactically, it's quite doable under the current SIP protocol in Star Shaken. It derives directly from them. It's a passport header in the SIP headers that is different than the Star Shaken header, which basically gives you the authentication information for the phone number itself.

Now there's a lot of other things, by the way, I think the commission is going to do, which is they're going to prohibit foreign actors from using, uh, United States, helpful numbers to enter the United States. So, uh, call centers that are domiciled in Europe, for instance, or aware cannot use an amp number there. That's going to end the French have outlawed it. The Germans have outlawed it. The British.

getting ready to outlaw it. So the rules regarding the use of the phone number. So a Philippine call center cannot use a domestic United States North American numbering plan number to reach the United States.

Christopher Mitchell (50:09)
And so that would, if I'm getting a phone call, which would be a legitimate phone call from someone, but it would have the country code or the Philippines and I would be able to make a choice as a consumer basically, was whether or not to accept it.

Richard Shockey (50:18)
Yes, yes,

yes. There are some differentials in rules that could be made, but banning the practice of using NAMP numbers from overseas entities to reach the United States, that seems very, very clear to me. And that's easy. That's easy to do. The thing about phone numbers is that's the key.

mechanism that the FCC has. If you use phone numbers, the FCC has absolute total plenary control over how those numbers are used and who uses them.

Christopher Mitchell (51:00)
And they can really encourage

the DOJ to collect a fine if you really abuse it. Right.

Richard Shockey (51:04)
Well, I mean, it's statute. It's section, I mean,

I've memorized it for God's sake. It's section 251E1 of the 1996 act, which is the states have a few little, they've got some authority, but the Federal Communications Commission has absolute, unchallengeable plenary authority that in fact was tested in the courts in 2002.

I know it. Because I was involved in

Christopher Mitchell (51:35)
Which for people like us seems

recent.

Richard Shockey (51:38)
Well, well,

for me, it was. I mean, I was, I was working for a new star.

now TransUnion, and it was a case involving telephone number pooling. And it was in the Second Circuit, New York, and basically the, this was before Chevron deference, by the way. This was one of those rulings from appeal court, which is, look, dummy, it's black and white and statute, get out of my appeals court. I mean, it was that simple. Okay. Now there's other issues, know, legality.

Christopher Mitchell (51:57)
Mm-hmm.

Richard Shockey (52:13)
that we have not seen the full impact of Loper-Brite on FCC Federal Trade Commission rulings. It's coming. You know, we don't have Chevron deference any longer.

Christopher Mitchell (52:28)
Right, you're saying for people who aren't steeped in this stuff is that there's a new standard in which judges basically have more ability to second guess agencies. But your position is that

Richard Shockey (52:39)
No, it's

actually, Chevron deference was courts could second-gaff the agencies because it would give the administrative body deference to do whatever they bloody well pleased. They have no deference any longer. Either it's black and white in the statute or there needs to be an act of Congress. in terms of certain levels of enforcement authority,

Christopher Mitchell (52:54)
Right. Right. Right.

Richard Shockey (53:07)
The full effect of Loper Bride has yet to be understood.

Christopher Mitchell (53:13)
Right, no, I

agree. think my perspective on it is that we've sort of moved from agency decides to court decides or judge decides. I think that's an overstatement, that's... ⁓ But your point is that this is not an area that's probably in a gray area. The FCC has unquestioned control over the telephone numbers and therefore it can use those in ways to improve the overall system by in this case requiring

Richard Shockey (53:23)
Yeah, I would agree with that. The courts are...

Yes.

Christopher Mitchell (53:40)
call origination, if it's a US number, has to originate actually, presumably within the United States and territories. So they have a lot of great for Guam, right? The Philippines are gonna move a lot of folks to Guam.

Richard Shockey (53:47)
And it can, and, and, and because he, well, yeah. And, and

because the, have plenty area control over the phone number, they can, they can, they can, they can rule how those calls get interconnected and by who. So

Christopher Mitchell (54:05)
Does Guam have country code US01? Does Guam have the country code of the US? I wasn't, I'm not sure. I would think it would as a territory, but I don't know. Huh.

Richard Shockey (54:08)
Pardon me.

It's 13.

Guam, no. But don't quote me. Right.

Christopher Mitchell (54:18)
Okay. Yeah, I was just

curious, like Puerto Rico and others, I assume they're all part of the United States. Yeah, okay.

Richard Shockey (54:22)
Oh, absolutely. Yeah.

That's the U S territory. Uh, so it's basically the United States, Canada and the 12 that use plus one. All right. Um, and, uh, are we, Oh, and then, you I could go on and on and on, which is, we running out of phone numbers? The answer is yes.

Christopher Mitchell (54:32)
Okay.

Telephone v6, right?

Richard Shockey (54:48)
No, it's IoT.

Christopher Mitchell (54:50)
Well no, so actually this is fascinating because telephone numbers used to be five digits, right? Or maybe they were four and then they were five. I was amazed at how when you go back, how it gets already changed just because I assumed it was always the way it was when I was born.

Richard Shockey (55:03)
Well, yeah. And when we, when we, went to, you know, tend to do dialing and stuff like that, but there is a definite concern at the, I can go on and on on about this stuff. Yeah. the, the issue is yes, we are actually running out of phone numbers, but it's not because of robocalls. It's because of IOT and machine to machine. Okay.

Christopher Mitchell (55:15)
Yeah, we'll wrap in a second.

Mm-hmm.

Richard Shockey (55:29)
You may not know this, but every single solitary car sold in the United States and Canada has a phone number.

Christopher Mitchell (55:38)
No, I would not have suspected that.

Richard Shockey (55:41)
Right. So, yes. Okay. So it's all that telematic stuff. every postal van, FedEx van, UPS, when we are, they've all got phone numbers in there because that's how they communicate back to the home office.

Christopher Mitchell (56:00)
I would have thought they used

different address like I would have thought we've run out of phone numbers by now I guess I don't have a sense of how many cars there are

Richard Shockey (56:06)
Uh, 230 million?

And that's not trucks either. Every long haul truck in the United States has a phone number associated because they're using 5G to communicate back to their home office. And the only way they can connect is through what's called an MC. And that MC always must have a phone number in it. That's the account.

Christopher Mitchell (56:32)
just trying to in my head I'm just I'm having trouble doing the decimals okay there's a billion phone numbers is that right or I mean 10 billion is that right there's nine I think there's nine billion nine hundred nine nine thousand nine hundred you know whatever the run it down I guess that's if I put my comments correctly

Richard Shockey (56:44)
Something like that,

Right. But we're running out.

We're running out because of IOT.

Christopher Mitchell (56:56)
Yeah, huh

Richard Shockey (56:58)
And and look, it's a good thing. And it's like, I mean, when, when, UPS or drops off the package, to your doorstep, they basically send a message back through the 5g network and you get something on your phones going, okay, they're trying to.

Christopher Mitchell (57:16)
Yeah,

I'm fascinated. I would have assumed that that was just an IP address and not even connected, but no, it's a telephone number.

Richard Shockey (57:23)
It's a phone number.

Christopher Mitchell (57:25)
Wow.

I mean, it's got an IP address too, I'm sure.

Richard Shockey (57:28)
Well, yeah,

it's a phone number because you have to connect to the mobile access, the 5G network to do that.

Christopher Mitchell (57:34)
Right. Sure. Yeah. And

in my head, I never realized I assumed that you could engage in texting without a phone number. But of course, you need that number. You need that identifier.

Richard Shockey (57:45)
You need the account number and the account number is fundamentally a phone number. That's the way the wireless networks were put together. So, and this, by the way, it has started in the UK with what's called RCS business messaging, which is every package delivery company in Britain. Now it will send you a text. Will they deliver a pack?

Christopher Mitchell (57:51)
Okay.

Richard Shockey (58:15)
and that is authenticated and it has a logo sent with it. They're not rolling it out in the US just yet, but this is one of the more innovative uses of the 5G network along with fixed wireless access that is actually working. We don't see all the porch pirates that we still do, but... ⁓

Christopher Mitchell (58:40)
We've

switched responsibility now. That and ring cameras have really helped, think.

Richard Shockey (58:42)
Yeah, but it's like we told

you, you we told you, you know, you know, your your packages at the door and we said we were taxed and one way or other. So. ⁓

Christopher Mitchell (58:48)
Mm-hmm.

Right. And we've not rung your doorbell

and woke you up. So we hope you're happy. Yeah. Yeah.

Richard Shockey (58:57)
Right, exactly, they didn't ring the doorbell.

And that's what the package delivery guys have been fighting over one way or the other. it's like, the FCC has been well-focused on adapting and facilitating innovative uses of the wireless network. And Telematics is one of

You know package delivery is another I mean there's this is where the burglar alarm guys come back Which is ⁓ god all those burglar alarms are gonna need phone numbers because they're they can't connect over the copper network any longer They're gonna have to use 5g

Christopher Mitchell (59:26)
Mm-hmm.

Right. Well, Richard, it's been fun. We covered a lot more than I thought we would. And I hope that people have a sense of all of this, including why robo-calling will persist into the future and hopefully not have such a negative connotation as we engage in better authentication and people can actually

Richard Shockey (59:54)
And again, I'm happy to, once you get questions back from your audience, I'm on LinkedIn, I'm on Facebook, I'm on Twitter, and I always call it Twitter. If people would be interested in me answering questions, I'm more than happy to do that. Chris, the...

The next one is I will explain to you everything you ever wanted to know about data centers in Northern Virginia.

Christopher Mitchell (1:00:21)
I might take you up on it, it's one of those things we've all had to learn more about, so...

Richard Shockey (1:00:26)
Well, I

do. mean, they're literally in literally in my backyard.

Christopher Mitchell (1:00:30)
Right. All right, well, thank you.

Richard Shockey (1:00:32)
You're very welcome.