TELNIC LIMITED: A PAPER IN RESPONSE TO THE
LETTER FROM ITU TO ICANN ON TELEPHONY-RELATED
TLDS
DATED 1 NOVEMBER 2000I. EXECUTIVE SUMMARY
This document sets out
a response to the letter from the International Telecommunication Union (“ITU”) to
the Internet Corporation for Assigned Names and Numbers (“ICANN”) on 1 November 2000
(the “Letter”) and profiles the position adopted by Telnic Limited (“Telnic”) in
respect of its application for the .TEL top level domain (“TLD”). In essence,
ITU’s recommendation to ICANN is that it would be “…premature for ICANN to grant
any E.164-related TLD application …”. The ITU only takes on a “coordinating
role” regarding numbering assignment which should be contrasted with the administration
and operation of the network infrastructure.
The success of the Internet is due
largely to its accessibility and facilitation. The Internet allows access by
a wide variety of hosts due to the numerous protocols available to the Internet community,
and these protocols allow disparate machines to communicate over a disparate network.
ITU wants the development of a global numbering/addressing scheme to accommodate
PSTN and IP-based networks before telephony-related TLDs are issued. However,
as advocated by ITU itself, there is a convergence of networks that allow one network
to be integrated with any other network. The use of IP and this ability to
integrate with existing networks allows for the global integration of voice, video
and data facilities.
In contrast to the other three telephony related applications
which make use of digits in their addressing system, Telnic’s .TEL uses characters
and words and follows current domain naming schemes. The Telnic .TEL concept is therefore,
a character/word based addressing system reliant on DNS, and the relevancy of the
E.164 related argument is questioned. The Telnic .TEL relies on existing IP
technology in that it allows for DNS look up to enable the IP-enabled device to make
the call. This means that, fundamentally, Telnic does not use E.164 numbers
in its domain names and therefore Telnic’s application should not be affected by
the ITU recommendation or be subject to the telecommunications regulatory regime.
Accordingly, Telnic’s .TEL TLD application should fall under the remit of ICANN.
Telnic agrees that the regulatory aspect of the Internet should be managed in
a transparent way that ensures that domain names and addressing systems are maintained
on an equitable basis, to facilitate the protection of intellectual property rights
and to promote a fair competitive environment. However, the development of the Internet
is largely driven by private initiative and is, of course, market led.
II. “.TEL” A NAME AND ADDRESS MAPPING SYSTEM : A BASIC OVERVIEW
In order to
understand the complex issues raised by the ITU in its Letter with respect to the
position of Internet Protocol Telephony (“IP Telephony”) in the highly regulated
world of the telecommunications industry and the .TEL TLD application, it is essential
to understand both IP Telephony and its relationship with the domain name registry
business.
In a nutshell, this Telnic .Tel concept is to create a new telephone
addressing system based on words and names instead of numbers. Telnic’s objective
is to allow for identification of voice-enabled Internet devices through the DNS
i.e. in order to call John Smith in London a caller would simply enter johnsmith.london.tel
instead of having to dial a traditional telephone number for John Smith, such
as + 44 207 498 7257.
1. IP Telephony
1.1 IP Telephony is generally a term which
is used for many different ways of transmitting voice, fax and related services over
packet switched Internet Protocol based networks. IP Telephony can be subdivided
into two major groups: Internet Telephony and Voice over IP (“VoIP”). IP Telephony
presents a fundamental transformation of the global telecommunications industry.
The most important concept in IP Telephony is packet switching which breaks up electronic
transmissions into smaller packets which are then transmitted and reconfigured at
the receiving end. This differs significantly from traditional public switched
telephone networks (“PSTN”) where circuits remain open until the connections are
terminated even when no information is being transmitted. As a result, IP Telephony
not only represents a cheaper and more efficient use of bandwidth but is also more
versatile as data and voice related services can be supported on the same backbone.
1.2 IP
Telephony takes several different forms and not all voice related services are the
same, nor are they treated uniformly by governments and industry around the world.
IP Telephony is used as an umbrella term for the various different ways of transmitting
voice over packet switched IP-based networks.
1.3 IP Telephony can generally
be distinguished by three characteristics:
· The use of gateways between the IP
Networks and the PSTN;
· The type of terminal devices; and
· The underlying
means of transmission.
Gateways
Gateways are the link between an IP network and
a circuit switched telephone network. This is the point at which voice signals
become digitised, converted into packets or converted from packets into voice.
The use of gateways are determined by the type of terminal devices.
Terminal Devices
The
three most common types of IP Telephony are:
PC/Internet Enabled Device (“IED”)
to PC/IED (“PC to PC”)
PC to PC was the first generation of IP Telephony which
transmitted voice related services over the public Internet. The connection
and transmission takes place entirely over the Internet and no gateway with the PSTN
is required because calls are never switched by the PSTN. This form of IP Telephony
and the following PC to Phone is the platform in which a .TEL domain name would serve
its function.
PC/IED to Phone (“PC to Phone”)
This enables voice related services
to be transmitted from a PC/IED to an individual on a regular non-Internet enabled
device but requires a gateway in order to convert the packet data into a receivable
form on the circuit network. From a service providers position, this is more
complex than a PC to PC service because calls need to be billed and routing arrangements
negotiated with Public Telephone Operators (“PTOs”) who operate the circuits.
Phone
to Phone
Phone to Phone or “Voice terminating on PSTN” IP Telephony, is currently
the major developing market for voice data. Whilst this involves phone to phone
communication, which utilises the Internet as the transmission medium, a PSTN connects
each party to an IP voice provider, who in turn processes the call and gains the
revenue therefrom. Phone to Phone technology is seen by many as the future
of consumer IP Telephony as it reflects a more cost effective copy of the present
telecommunications structure.
Means of Transmission
As mentioned earlier, IP
Telephony is a generic term for the transmission of voice related services over packet
switched IP-based networks. However, IP Telephony can in turn be characterised
by the distinction between Internet Telephony and VoIP which lie in the nature of
the underlying IP network, or the means of transmission. The former primarily
uses the public Internet while the latter utilises managed private IP based networks.
IP Telephony is therefore the means of transmission that a domain name such as
.TEL would utilise in order to transmit a voice related service as domain names work
within the public Internet platform and not a closed private network.
1.4 As a
result of the developments in IP Telephony, concerns have been raised by the telecommunications
industry and regulators at the impact of this potentially cheaper environment and
hence the desire to restrict the progression of IP Telephony, or at least bring them
under the same standard as the PTOs.
2. Domain Name Registry Business
2.1 Telnic’s
service supports the PC to PC and PC to Phone Internet Telephony as its use of domain
names indicates that voice data will be sent largely through the public Internet
via Internet Service Providers (“ISPs”) rather than any PTO or private IP based network.
2.2 Whilst
the US Federal Communications Commission (the “FCC”), the ITU and the Internet community
continue to debate IP Telephony and where their roles within this new communication
environment fit into these converging industries, it is essential to remind ourselves
that the Telnic application to ICANN for the issuance of the new .TEL TLD is simply
an application for the licence to operate the new TLD. Although ICANN has identified
Telnic, whose potential domain name may have strong connections with telecommunications
and in particular IP Telephony, it is essential to remember that domain names simply
map a series of numbers which enable data to be identified. Neither the TLD
nor Telnic’s registry service enable voice related services to be transmitted over
an IP-based network. Telnic’s .TEL TLD is simply a highly versatile “tool”
whereby a PC/IED can identify another a PC/IED and transmit any form of electronic
data including voice related services.
2.3 Telnic, is not, therefore an IP Telephony
company. However, it can be likened to a domain name registry that provides, in addition
to domain names for use as websites, domain names which can equally be utilised by
the IP Telephony industry. Telnic’s service is therefore a “tool” which aids
and assists identification of a DNS address rather than an application which enables
IP Telephony. IP Telephony works, not because of the domain name, but because
of the software which converts data into packets and then routes that data.
The domain name simply eases the identification of individuals, businesses and organisations.
The transmission is routed according to the network arrangements of the caller’s
telecom provider, over which Telnic has no influence.
3. Whilst it is arguable
that governments and the ITU may have some, as yet unidentified, role in the regulation
and standardisation of IP Telephony, it is harder to see how they may have any role
in the allocation of TLDs. The telecommunications industry is clearly unsettled
by the competition created by these technological advances, and given that the ITU
may determine, in conjunction with interested parties, that IP Telephony should fall
under the remit of telecommunications regulations, it is arguable, as has been noted
by industry observers, that IP Telephony does not fall under the same rules and regulations
as the PTOs because the transmission over IP-based networks is of data rather than
specifically voice related services.
III. ARE IP - COMMUNICATIONS SERVICES
REGULATED BY THE TELECOMMUNICATIONS REGULATORY FRAMEWORK?
1. Internet Protocol
Telephony v traditional PSTN Telecommunication services
By way of background, there
has been a shift from the traditional PSTN circuit switched voice networks to packet
switched data networks amongst the telecommunications industry for the following
reasons:
a. voice represents an ever-diminishing percentage of overall telecommunications
traffic when compared to data;
b. all else (i.e. quality, convenience and reliability)
being equal, IP Telephony potentially offers a cheaper alternative to traditional
voice telephony (i.e. direct dial telephone calls on either fixed lines or mobile
phone networks) as fees charged for such services will be at the rate of a local
call; and
c. packet switched networks do not restrict the use of the available
bandwidth for an unnecessary period of time (i.e. “during silences in an IP voice
conversation, no packets are sent and the available bandwidth is used by other IP
applications”) thereby allowing a much higher volume of information to be transmitted
in a shorter period of time.
Given the increasing use of packet switched networks
by the telecommunications community and the use by ISPs of circuit switched networks,
in their provision of IP Telephony services (i.e. PC to PC, PC to Phone; and Phone
to Phone), there is a convergence of the functions and services provided, and the
technologies used by these industries, so that both types of networks are becoming
and will become more alike.
Considering that IP Telephony runs in parallel with
and is functionally equivalent to traditional PSTN voice telephony, the telecommunications
community argues that IP Telephony should fall within the ambit of a telecommunications
service and should be regulated under the telecommunication regulation regimes.
Notwithstanding
the foregoing, Telnic’s application for the .TEL TLD is merely a name/address mapping
system (as discussed under Section II above) that aids and assists the identification
of a DNS address by way of utilisation of the IP-based network. Telnic’s .TEL
concept does not therefore provide IP Telephony services as such. Telnic does not
reroute calls, but only “allows a look up” of the routing instructions, i.e. a domain
name server or “DNS” look up, which the IP-enabled device will then use to make the
call. The call is then routed according to network arrangements of the caller’s telecom
provider, in respect of which Telnic has no influence.
In addition, it should be
noted, that Telnic’s business predominantly takes place between a generic “PC to
PC” model (i.e. the next generation of IP communications device to IP communications
device), making use of IP-based networks, thereby reinforcing the argument that Telnic’s
business is not part of the traditional telecommunications system, as it makes no
use or very limited use of the telecommunications PSTN network. Telnic’s approach
and model for .TEL is totally neutral, it does not impinge or conflict in any way
with PSTN or related structures.
Therefore, Telnic’s .TEL TLD application does
not relate to telecommunications services and should not be prevented from being
granted on the basis that the ITU considers the issuance of such a TLD as being premature.
2. Should
IP - Communications be governed under the Telecommunications Regulatory Framework
(“TRF”)?
If ICANN takes the view that in running the .TEL TLD Telnic provides IP
Telephony services rather than just the enabling tools, the question arises whether
and/or how IP Telephony fits into the telecommunication regulatory regimes.
Until
recently, most Internet services have been classified by regulators as "non-basic
or non-voice services” and as such ISPs have generally not been subjected to the
“more restrictive and onerous licensing or market entry requirements that frequently
apply to conventional voice telephony service providers”.
Currently there are
no explicit regulations relating to IP Telephony (in most countries), including without
limitation, the European Union and the United States of America.
Although, arguably
the telecommunications regulatory regimes may be applied to IP Telephony on the basis
that:
a. IP Telephony is functionally equivalent to traditional voice telephony;
b. IP
Telephony is likely to make use of the public switching telecommunication networks
more frequently in the future;
c. the Internet is not covered by a regulatory
framework as such; and
d. the telecommunication regulations are already well established,
neither
the European Union nor the United States of America have taken the approach that
IP Telephony services should be covered by the telecommunication regulations.
Please refer to Annex A hereto for a more detailed discussion relating to the position
in the European Union and the United States of America.
3. IP - Communications
regulated by a completely new Regulatory Framework and new Regulator?
Given the
above discussions (as well as those in Annex A) it does seem inevitable that IP Telephony
will in time be regulated in some way or form. However, whether or not such a regulatory
framework will be in the form of the telecommunications regulatory framework or a
new regulatory framework needs to be considered.
As the nature of IP Telephony
is in effect a convergence between the functions and technologies relating to both
the Internet and telecommunications, it may seem unreasonable and/or even impractical
for such services to be governed solely by the TRF, as that regime was set up to
deal with traditional voice telephony and not the “new generation IP Telephony”.
Therefore, this new generation of IP Telephony should arguably be subject to new
regulations (some of which may not be too dissimilar to the telecommunication regulations),
that would be specifically adopted to deal with the convergence of these two technologies.
There is a strong argument for such a new regulatory framework to be controlled and
administered by a regulator that protects the interests of both industries, considering
the convergence of not only the technologies but also the industries.
IV. RESPONSE
TO ITU LETTER TO ICANN DATED 1 NOVEMBER 2000
It would appear that ITU’s primary
concern is the claim that the .TEL TLD (as a telephony-related TLD) would involve
the mapping of the E.164 numbering plan onto the DNS. E.164 is the ITU-T standard
that specifies telephone number type address formats. Addresses are a maximum
of 15 digits and are arranged in a geographical hierarchy to enable worldwide routing.
As a contrast, IP addressing schemes are organisationally oriented.
In brief,
Telnic intends to offer its users Internet addressing by way of domain names.
Each user will be allocated a .TEL address called a “Telname” to allow users to communicate
without the requirement for a conventional telephone number. After a review
of the Letter, it appears that there is a misunderstanding of Telnic’s .TEL concept
and Telnic’s use of the IP network. For example, is a Telname a telephone number
and therefore an E.164 number? Further, is a Telname a TLD which involves the
“mapping of the E.164 numbering plan onto the DNS”? The ITU firmly objects
to the issuance of telephony-related TLDs that involve the mapping of the E.164 numbering
plan onto DNS. .TEL is not a telephone number, it uses characters and words and follows
current domain naming schemes. The Telnic .TEL concept is therefore, a character/word
based addressing system reliant on DNS, and the relevancy of the E.164 related argument
is questioned.
ITU further argues that the issuance of telephony-related
TLDs would jeopardise the technical standards work currently being undertaken by
the ITU and the ITEF. Perhaps the ITU has a desire for the transformation of
E.164 numbers onto DNS and the subsequent use of existing DNS services so that “E.164
telephone numbers would reach a subscriber regardless of whether IP-based or PSTN
network technologies are used”.
Telnic considers that Internet regulators
should seek to find an acceptable median between the desire to rigidly control the
network and the freedoms expected by users and the business community.
ITU state that URL scheme names are generally associated with “widely-deployed protocols
or existing naming/addressing resources”. Following on from this statement,
Telnic’s concern stems from ITU’s assertion that control over a corresponding TLD
“may suggest control over the corresponding protocol or naming/addressing resource”.
It is questioned whether this is a legitimate claim by ITU. Telnic is developing
an Internet addressing system, however, this addressing system is inside the .TEL
namespace and is reliant upon existing IP technology. How can Telnic therefore,
control the “corresponding protocol” when Telnic is not and never has been in control
of IP, Telnic simply uses the existing IP-based network for transmission.
In trying
to understand ITU’s concern, it is concluded that some of ITU’s apprehension potentially
rests with the issue of ownership and thus control over the .TEL domain name/Telname,
rather than control of the protocol. For example, if a .TEL applicant is successfully
issued a .TEL domain name and Telnic effectively “owns” that name, it could be argued
that Telnic may not allow competing IP Telephony providers access to information
regarding the Telname, i.e. the underlying IP address. The use and protection
of DNS voiced by ITU in its Letter is likely to be as a result of the fact that telephone
numbers can be mapped directly to the hierarchical structure of DNS. DNS can
then be used for identifying available services connected to an E.164 number.
Another argument raised by ITU in its Letter is that it may not benefit the Internet
community to allocate certain TLDs at this time. Telnic would assert that it is in
the interests of the Internet community to issue additional TLDs at this time because
it will lead to increased TLD availability and a better choice for individuals and
businesses.
It may be perceived in the marketplace that the ITU’s concern stems
from the capability of the Telnic concept to be able to supply users with an Internet-communication
address for life that can be used to make a call anywhere in the world, where the
maximum call-cost is at the local rate. Accordingly, the implications of .TEL and
a mature Internet-communication industry could be far-reaching on the billing structure
and revenue streams of the PTOs. Even if there is a move to levy charges or exercise
control more familiar to the traditional telecommunications industry, ICANN should
not use the inevitable convergence and progress of technology, on the recommendation
of the ITU, as a reason to supress the innovation of the Internet. As technologies
continue to converge and blur the already indistinct boundaries, the pressure to
deregulate and simplify the global regulation of telephony and Internet integration
will increase.
As discussed above, the Telnic .TEL concept relies on existing technology
in that it allows for DNS look up to enable the IP-enabled device to make the call.
The call is then routed according to network arrangements of the caller’s
telecom provider, over which Telnic has no influence. It always has been and
still is Telnic’s intention to not reroute calls using its own technical arrangements.
For the Telnic concept to work and for Telnic to succeed as a registry of .TEL, Telnic
realises that it needs to be perceived as a neutral and impartial organisation and
has consequently devised its .TEL application in such a way that it is reliant on
DNS rather than PSTN so as not to encroach on the telecommunications sector. The
concept of addressing how calls pass from circuit switched to packet switched networks
is a technical argument utilised by ITU to dissuade ICANN from issuing telephony-related
TLDs. Integration technology exists already to allow calls to pass from one
technology to another without the ITU’s suggestion of the creation of “an integrated
global subscriber access plan”. Telnic therefore considers this to be a rather
weak argument because gateway technology has, is and will continue to be developed
to improve network connectivity and quality of service.
Telnic agrees that
the regulatory aspect of the Internet should be managed in a transparent way that
ensures that domain names and addressing systems are maintained on an equitable basis,
to facilitate the protection of intellectual property rights and to promote a fair
competitive environment. However, the development of the Internet is largely driven
by private initiative and is, of course, market led. Telnic does not believe
that ICANN’s possible decision not to issue telephony-related TLDs will prevent or
slow down the development of IP-based networks and the growth of the e-global economy.
*
* *
Contact Details
Squire, Sanders & Dempsey, London Telnic Limited
Cathy
B. Horton (Partner) Fabien Chalandon (Director)
Tel: + 44 207 7765244 Tel: + 331
47 03 34 24
Fax: + 44 207 7765233 Fax: + 331 47 03 33 71
E-mail: chorton@ssd.com E-mail:
fabienchalandon@compuserve.com
Martin Augier
Tel: + 44 207 7765221
E-mail:
augier@telnic.org
ANNEX A
Should IP - Communications be governed under
the Telecommunications Regulatory Framework?
European Union
Voice telephony
in the European Union is defined in Article 1 of Directive 90/388/EEC (“the
Directive”), which provides that “voice telephony means the commercial provision
for the public of the direct transport and switching of speech in real-time between
public switched network termination points, enabling any user to use equipment connected
to such a network termination point in order to communicate with another termination
point”.
On 20 October 1995, the European Commission (“the Commission”) published
a Communication on the status and implementation of the Directive, which set
out the Commission’s approach on the implementation of the definition of voice telephony.
In particular, the Commission emphasised that, for a service to be defined as voice
telephony, all the cumulative criteria set out in the definition had to be fulfilled,
namely: (1) the service had to be provided on a commercial basis; (2) for the public;
(3) for the purpose of direct transport and switching; (4) of speech in real time;
(5) between public switched termination points.
In 1998, taking note of technological
development allowing for the transmission of voice communications over the Internet,
the Commission issued a Notice on the status of voice communications on the Internet
under Community law (“the Notice”) particularly in light of the definition
of voice telephony contained in Directive 90/388/EEC. The Notice considered two issues:
(i) whether IP telephony fulfilled the conditions for voice telephony; and (ii) the
extent to which the obligations attached to voice telephony services (especially
in terms of licensing and the financing of universal service) should apply to voice
communications services provided over the Internet.
The Commission took the view
in the Notice that, at the time, the cumulative criteria of the voice telephony definition
were not, in most cases, met in relation to the provision of IP telephony. In particular,
the Commission considered that:
· the commercial provision of the transport of
voice was, at the time, not the principal aim of the access providers (in most cases
IP telephony services were provided as only one part of an integrated Internet service,
where the voice services only was ancillary to other elements of the Internet service);
and
· as regards real-time transmission, the Commission took the view that “the
time period required for processing and transmission from one termination point to
the other [was] generally still such that [IP telephony service] [could not] be considered
as of the same quality as a standard real-time voice service”.
IP telephony services
were, consequently, considered to fall outside the scope of voice telephony services.
As such, no individual licence could be required for the provision of IP telephony
services and no contribution for the financing of the universal service could be
required from Internet access providers.
The Commission highlighted, however,
that the position of IP telephony under Community law might change in light of further
technical and market developments. The Notice consequently provided for a periodic
review of the Notice, and at the latest, before 1 January 2000. The review
of the Notice was therefore launched in June 2000 with the publication by the Commission
of a Consultative Communication. In the Consultative Communication, the
Commission takes the view that, despite market trends indicating a development of
IP telephony services, the impact of Internet voice has not been felt yet in a major
way in the European Union. In particular, the Commission considers that while “Internet
telephony can be viewed as a positive and innovative activity, which will indirectly
put pressure on existing price structures in the same way as call-back or calling-card
services”, Internet voice services, when offered as a discrete and stand alone service,
have remained a limited activity due to the difficulty of guaranteeing a quality
level as normally expected from voice telephony and the user inconvenience due to
technical complexity and to evaluating different market offers. Moreover, margins
have also eroded subsequent to a decline retail process for telephone services over
the PSTN, particularly for long distance and international calls.
There
is every indication to suggest that the Commission will confirm its proposal to maintain
the position set out in the Notice. Accordingly, it will confirm that Internet telephony
continues to fall outside the definition of voice telephony, since:
(i) it does
not in most cases meet the criteria of reliability and sound quality as normally
required for voice telephony; and
(ii) it is not offered as a single service or
the main element of a range of bundled services marketed as voice telephony.
The
consultation procedure is now coming to an end. The Commission has received a broad
support for its proposed conclusions. The publication of a short notice confirming
the findings of the original Notice is scheduled to occur before the end of year
2000.
In this context, it should be noted that the current drafts of the EU regulatory
framework intended to come into force on 1 January 2003 use the Electronic Communications
Services concept in place of the voice telephony concept. Electronic Communications
Services are services provided for remuneration which consist wholly or mainly in
the transmission and routing of signals on electronic communications networks.
It therefore seems likely that VoIP services provided for remuneration will be regulated
in the same way as electronic services.
United States of America
In 1998 the
Federal Communications Commission (“FCC”) considered in its “Universal Service Report”
to Congress whether IP Telephony service providers qualify as “telecommunications
carriers”, who fall within the telecommunications regulatory regime or whether they
qualify as information service providers who fall outside the parameters of such
a regime.
The arguments raised for and against IP Telephony service providers qualifying
as “telecommunications carriers” were as follows:
· Argument for IP Telephony service
providers qualifying as telecommunications carriers
It was argued that IP Telephony
is “simply another form of technology, like satellite or fiber-optic transmissions”
which provides the same function as traditional voice telephony. Therefore, the choice
by the user of a new technology should not deter from the underlying function “which
squarely falls within the definition of telecommunication services”. As such
it was argued that the telecommunications regulatory framework should regulate IP
Telephony service providers.
· Argument against IP Telephony service providers
qualifying as telecommunications carriers
The FCC in the “Universal Service Report”
considered and found that Internet Service Providers and IP voice providers are not
“common carriers that offer telecommunications” but rather argued that they offer
an “information service” as they are “capable of generating, acquiring, storing,
transforming, processing, retrieving, utilizing, or making available information”.
The FCC appeared prepared to distinguish between computer to computer and Phone
to Phone IP voice offerings, placing emphasis on the “packetising of the transmission”.
Therefore, although the FCC stopped short of holding that IP voice providers supply
either telecommunications or information services because there “was insufficient
information in the public record to come to a definitive standard treatment of IP
voice services” it stated that:
“We recognise that our treatment of Phone to Phone
IP Telephony may have implications for the international telephony market.
In the international realm, the FCC has stated that IP Telephony serves the public
interest by placing significant downward pressure on international settlement rates
and consumer prices. In some instances, moreover, IP Telephony providers have
introduced an alternative calling option. We continue to believe that alternative
calling mechanisms are an important pro-competitive force in the international services
market. We need to consider carefully the international regulatory requirements to
which Phone to Phone providers would be subject. For example, it may be appropriate
to apply the international accounting rate regime (part of the telecommunications
regulatory regime) to IP Telephony”.
In view of the above, it is possible that
IP Telephony services may in due course be subject to similar regulations as traditional
voice telephony (although it is not clear whether the current telecommunications
regulatory framework will apply or whether a new framework will be created).