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RE: RE : data point - anonymous E.164 number usage

  • To: "Jim Reid" < >
  • From: "Pat Walsh" < >
  • Date: Wed, 3 Mar 2004 16:10:41 -0000

Jim, it's a valid point that an 'unofficial' ENUM-type service could be
set up under some other domain and that could cause immense confusion.
It may happen anyway and I doubt that regulators will be the driving
force for it, if it happens. 

The point I wanted to make is that from a regulatory perspective the
E.164 number-holder is de-facto the ENUM domain holder for the
respective domain and effectively the rights/obligations
accrue because of the E.164 number not because of the domain. In fact in
my view every E.164 number-holder of a category acceptable for ENUM use
(which as you say is a national matter) *automatically* acquires a right
to use that number for ENUM purposes and equally nobody else has that
right (if we ignore fine points about possible difference between user
and subscriber). Furthermore, it would be an unacceptable situation from
a regulatory point of view if a number-holder's rights were infringed
because someone else somehow 'takes over' that domain - regardless of
whether the number-holder himself intends to register it for ENUM

I certainly don't think regulators should be placing unnecessary
barriers in the way of ENUM registration and use - quite the opposite.
My main point was to emphasise that regulators - even with the best will
in the world towards ENUM - would always think carefully about any
backwards impact on existing PSTN management that special arrangements
for ENUM might entail. At this stage the PSTN would be considered to be
the dog and ENUM the tail and if conflicting interests arose then .....
That may seem to be pessimistic and actually I feel the regulatory
(including numbering) barriers to ENUM are not so difficult and
regulators are generally taking a positive approach to it.

Pat Walsh - ComReg

-----Original Message-----
From: Jim Reid [
] Sent: 03 March 2004 15:24 To: Pat Walsh Subject: Re: RE : data point - anonymous E.164 number usage >>>>> "Pat" == Pat Walsh <[email protected] writes: Pat> The ENUM domain has a direct dependency on the Pat> E.164 number and the regulatory rights and obligations for Pat> the former would be seen by a Regulator as essentially the Pat> same as for the latter. Well yes and no. Names under are related to E.164 numbers and are "officially" sanctioned by the powers that be. But they're just domain names. They could easily go somewhere else in the DNS tree, albeit without the blessing of IETF, ITU, national regulators, etc. Not that I'm arguing for anchoring E.164 numbers elsewhere in the DNS or promoting alternate trees. That would be madness. I have concerns that a de facto solution could be imposed by the likes of Microsoft or Cisco by virtue of their massive installed base. This may not meet the valid concerns about national sovereignty, privacy, authentication, customer safeguards, competition, etc that we're grappling with. My fear is that the industry, especially a dominant player, could decide it can't wait for these issues to be solved. So if regulators push too hard down that path the outcome could be unpleasant for everyone. The challenge will be to get the balance right between the valid regulatory concerns and what is financially and practically achievable.

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