media contact: for immediate release for american ...the honorable ajit v. pai chairman federal...

Media Contact: Will Wiquist, (202) [email protected]

For Immediate Release

CHAIRMAN PAI: CALLER ID AUTHENTICATION IS NECESSARY FOR AMERICAN CONSUMERS IN 2019

Many Phone Companies Have Offered Encouraging Timelines for Rolling Out This Critical Service for Combating Spoofed Robocalls

WASHINGTON, February 13, 2019—Federal Communications Commission Chairman Ajit Pai today reiterated his call for a robust caller ID authentication system to combat illegal caller ID spoofing. The Chairman recently asked the nation’s largest carriers to provide details about their caller ID authentication plans and he has called for implementation to take place this year.

“American consumers are sick and tired of unwanted robocalls, this consumer among them. Caller ID authentication will be a significant step towards ending the scourge of spoofed robocalls. It’s time for carriers to implement robust caller ID authentication. Uniform adoption will help improve authentication throughout the network and make sure no consumer gets left behind. I applaud those companies that have committed to deploy the SHAKEN/STIR framework in 2019. This goal should be achievable for every major wireless provider, interconnected VoIP operator, and telephone company—and I expect those lagging behind to make every effort to catch up. If it appears major carriers won’t meet the deadline to get this done this year, the FCC will have to consider regulatory intervention,” said Chairman Pai.

On November 5, 2018, Chairman Pai demanded that the phone industry begin providing caller ID authentication for consumers in 2019. In response, phone companies—including wireless companies, traditional landline providers, and tech companies offering VoIP—outlined their plans. The carriers’ responses can be found here.

While some carriers committed to rollout these services in the coming months, others hedged, citing concerns that other carriers appear to have already addressed. Chairman Pai believes that wireless providers, interconnected VoIP providers, and telephone companies should make real caller ID authentication (the SKAKEN/STIR framework) a priority and believes that major carriers can meet his 2019 goal.

Under the SHAKEN/STIR framework—a set of protocols and a multi-phase framework developed with the input of many stakeholders—calls traveling through interconnected phone networks would have their caller ID “signed” as legitimate by originating carriers and validated by other carriers before reaching consumers. The framework digitally validates the handoff of phone calls passing through the complex web of networks, allowing the phone company of the consumer receiving the call to verify that a call is from the person making it.

###

Office of Media Relations: (202) 418-0500ASL Videophone: (844) 432-2275

https://www.fcc.gov/document/chairman-pai-demands-industry-adopt-protocols-end-illegal-spoofing

https://www.fcc.gov/call-authentication

TTY: (888) 835-5322Twitter: @FCC

www.fcc.gov/media-relations

This is an unofficial announcement of Commission action. Release of the full text of a Commission order constitutes official action. See MCI v. FCC, 515 F.2d 385 (D.C. Cir. 1974).

Amanda E. Potter AT&T Services, Inc. Assistant Vice President- 1120 20th Street, NW Senior Legal Counsel Suite 1000

Washington, DC 20036 Phone: 202.457.2103 E-mail: [email protected]

November 19, 2018

VIA ECFS Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554

Re: Call Authentication Trust Anchor, WC Docket No. 17-97 Dear Ms. Dortch: Enclosed please find AT&T’s response to Chairman Pai’s letter dated November 5, 2018 to John Donovan, CEO of AT&T Communications. Please contact me should you have any questions.

Respectfully submitted, /s/ Amanda E. Potter Amanda E. Potter

Enclosure

T 202.457.3120

C 202 262 7479

[email protected]

AT&T Services, Inc.

1120 20th Street NW

Suite 1000

Washington, DC 20036

Joan Marsh

Executive Vice President

Regulatory & State External Affairs

November 19, 2018

The Honorable Ajit V. Pai

Chairman

Federal Communications Commission

445 Twelfth Street, SW


Re: AT&T’s Timeline for Implementation of SHAKEN/STIR; Call

Authentication Trust Anchor, WC Docket No. 17-97

Dear Chairman Pai:

On behalf of AT&T,1 I write in response to your November 5, 2018 letter to John Donovan,

CEO of AT&T Communications, in which you expressed support for our commitment to

combating the scourge of illegal robocalls, including through the early implementation of caller

ID authentication technology. Under your leadership, the Commission continues to be a valuable

partner of industry in the development and implementation of the technical protocols known as

Signature-based Handling of Asserted Information Using toKENs and the Secure Telephone

Identity Revisited (“SHAKEN/STIR”). AT&T is fully committed to this innovation and has

played a leading role in its development, but significant work remains to stand-up SHAKEN/STIR

across the industry. As your letters to AT&T and other service providers reflect, it will take

enormous commitments on the part of each company for SHAKEN/STIR to achieve its potential

and restore consumers’ confidence that they can answer their telephones without being subjected

to illegal robocalls. AT&T, as it has done since the 2016 Robocall Strike Force, will continue to

lead the way, and we thank you and your fellow commissioners for encouraging all service

providers to do the same.

As requested, enclosed please find a timeline detailing AT&T’s plans for the deployment

of SHAKEN/STIR. The timeline includes implementation benchmarks for testing, certain network

1 AT&T Services, Inc. files this letter on behalf of AT&T Mobility and its wireline

operating affiliates (collectively, “AT&T”).

2

buildout, the exchange of certificates, as well as call-signature display capability. The timeline

necessarily is dependent, in significant part, on factors beyond AT&T’s control, including

coordination with other voice service providers. For example, AT&T’s current target of

exchanging signed calls with one service provider in the third quarter of next year is based on

preliminary discussions initiated earlier this month. The aggressive timetable the parties are

considering, as reflected in the timeline, thus could encounter delays.

By the same token, the timeline does not detail all of the concurrent activity, both internal

and external to AT&T, to expand and enhance the capabilities of SHAKEN/STIR. Industry’s

ongoing work to develop best practices for the implementation of SHAKEN/STIR for business

VoIP (Enterprise) calls is one such example. AT&T is committed to signing business VoIP calls

consistent with those practices once they are available.2

AT&T also is considering various alternatives for delivering call-signature displays to

consumers, including proposals to leverage the enhanced capabilities of AT&T Call Protect to

deliver additional value to customers who subscribe to that service. At a minimum, beginning in

the third quarter of 2019, AT&T intends to have the ability to deliver displays for end-to-end

VoLTE wireless calls, and currently plans to provide displays to customers.

As the Commission is aware, the precise timing and format for consumer displays remain

a topic of discussion and debate among stakeholders. While AT&T is committed to delivering the

benefits of SHAKEN/STIR to its customers as soon as reasonably possible, we nevertheless urge

caution to ensure that the understandable enthusiasm to implement as quickly as possible does not

ultimately undermine the long-term effectiveness of SHAKEN/STIR. AT&T believes that careful,

intentional planning regarding consumer call-signature displays is critical to ensure that service

providers do not inadvertently miscommunicate the meaning or significance of call signatures (or

the lack of such signature) through their consumer displays. More specifically, AT&T believes

that the Commission and industry should work together to evaluate and, wherever possible,

manage consumer expectations regarding the call-signature displays that service providers present,

particularly in the early days of SHAKEN/STIR implementation. Absent appropriate planning

and coordination, AT&T is concerned that, as implementation ramps up, if consumers receive call-

signature displays for only a small number of legitimate calls (while the remaining legitimate calls

go unsigned), consumers could view SHAKEN/STIR as ineffective, and even disregard the call-

signature displays. It thus is critical that industry, in partnership with the Commission and other

2 Likewise, while the timeline reflects that AT&T’s initial implementation of

SHAKEN/STIR will involve the manual exchange of certificates, AT&T will implement

automated certificate exchange once the STI-PA/STI-CA functions are available.

3

appropriate stakeholders, consider these important issues before call-signature displays are

delivered to end users. AT&T will continue ongoing discussions and collaboration with the ATIS

SIP Forum Task Force and other implementing service providers and stakeholders to develop and

launch call-signature displays in a manner that is transparent to consumers.3

Please contact the undersigned should you or staff have questions regarding this letter.

Respectfully submitted,

________________________________________

Joan Marsh

Executive Vice President

Regulatory & State External Affairs

AT&T Communications

Enclosure

cc: The Honorable Michael O’Rielly

The Honorable Brendan Carr

The Honorable Jessica Rosenworcel

Eric Burger

Patrick Webre

Deborah Salons

3 Nevertheless, as described above, AT&T will be ready to begin providing call-signature

displays to customers.

DRAFT

© 2018 AT&T Intellectual Property. All rights reserved. AT&T Proprietary (Restricted) Only for use by authorized individuals within the AT&T companies and not for general distribution. Technology Strategy Group Opinion Only. Subject to contradiction or alternate evaluation by other organizations.

SHAKEN/STIR IMPLEMENTATION PLAN November 2018

4Q18 1Q19 2Q19 3Q19 4Q19 2020

Initiate SHAKEN/STIR-capable network buildout

Conduct field testing – Comcast

Commence lab testing – service provider 2

Complete Phase 1 of SHAKEN/STIR-capable network buildout

Capability to sign all AT&T-originated consumer VoIP calls

Capability to manually exchange certificates

Exchange signed calls – Comcast

Commence field testing – service provider 2

Commence lab testing – service provider 3

Complete Phase 2 SHAKEN/STIR-capable network buildout

Capability to sign all AT&T-originated VoLTE wireless calls

Exchange signed calls – service provider 2

Commence field testing – service provider 3

Capability to initiate consumer call-signature displays

Exchange signed calls – service provider 3

Test/Deploy/Implement with additional providers as they become ready

= Target Delivery Date = Planned

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November 19, 2018

Chainnan Ajit V. Pai

I~ COMCAST

Federal Communications Commission 445 12th Street SW Washington, DC 20554

Dear Chairman Pai:

On behalf of Comcast Corporation, thank you for your letter of November 5 to our Chairman and Chief Executive Officer, Brian Roberts, regarding our ongoing efforts in collaboration with the Commission to mitigate illegal robocalls relying on spoofed caller ID infonnation. As President of the Technology and Product organization within Comcast Cable, I have played a lead role in overseeing the development and implementation of measures targeting these abusive calling practices, and Mr. Roberts has asked me to provide this response to your letter.

Comcast is proud to be at the forefront of efforts to address the scourge of illegal spoofed robocalls in this country, including the development of the end-to-end call authentication protocol known as SHAKEN (Signature-based Handling of Asserted Infonnation Using toKENs) and STIR (Secure Telephone Identity Revisited). Comcast's Chris Wendt co-chairs the work group of the Alliance for Telecommunications Industry Solutions on the SHAKEN framework for caller ID authentication, is a primary author of the STIR specifications adopted by the Internet Engineering Task Force, and leads the development team pioneering an open source implementation of the specifications to promote testbeds and interoperability lab trials in the industry. Mr. Wendt also co-chaired the Authentication Working Group of the Robocall Strike Force, which was organized in 2016 to accelerate the development and adoption of new tools for mitigating fraudulent robocalls and has provided two detailed reports on those efforts to the Commission. Moreover, Comcast's Beth Choroser co-chaired the North American Numbering Council's Call Authentication Trust Anchor Working Group, which in May 2018 prepared a report for the Commission on the governance framework and timely deployment of the SHAKEN/STIR protocol. Comcast has been and continues to be at the cutting edge of innovation and leadership on these issues, and I am pleased to provide the following updates on our implementation progress in response to your questions.

As to your first question, we are continuing to pursue an aggressive timeline for deploying call authentication capability using SHAKEN/STIR on our network. Comcast has long been engaging in active lab trials of SHAKEN/STIR with AT&T and Verizon. These coordinated lab trials are vitally important not only to provide a common testbed that facilitates collaborative efforts to identify and address particular technical issues, but also to begin laying the groundwork for ensuring interoperability of the call authentication functionalities slated to be

One Comcast Center Philadelphia, PA 19103-2838 www.comcastcorporation.com

November 19, 2018 Page2

implemented by the participating providers. Additionally, Comcast has begun employee trials of SHAKEN/STIR on its own network; in these trials, we have turned on call-signing and other authentication functionalities for certain members of our technical team so that they can test and evaluate these capabilities in practice prior to wide-scale implementation.

Barring any unforeseen complications, we expect to have implemented the capability to sign calls originating from our residential voice customers for our entire residential subscriber base by the end of December 2018. This signing capability adheres to the relevant specifications laid out in the SHAKEN/STIR framework and is being implemented in stages, with the first set of 500,000 residential subscriber lines receiving this capability last week. We anticipate that, by the end of this year, all calls originating from Comcast residential subscribers will include headers containing SHAKEN/STIR-compliant signatures. 1

By the end of March 2019, absent any unexpected difficulties, we expect to have implemented the capability to verify calls that contain a SHAKEN/STIR-compliant signature for our entire residential subscriber base. Accordingly, by that time, all calls originating from a Comcast residential subscriber and terminating with a Comcast residential subscriber will be able to be signed and verified in accordance with the SHAKEN/STIR framework. Moreover, Comcast' s implementation of signing and verification capabilities by that time will enable the company to begin interoperating with other voice providers that have implemented such capabilities. Prior to officially establishing end-to-end call authentication with another voice provider, Comcast and the other voice provider will need to complete testing to ensure compatibility; while other providers have not yet settled on firm dates by which they will complete testing with Comcast, we are committed to doing all we can to move that process along with cooperating providers expeditiously. 2

Additionally, Comcast is taking concrete steps to implement call authentication capabilities for calls carried on Comcast' s network on behalf of other providers. Comcast has arrangements with certain other providers enabling those providers to use Comcast' s platform and telephone numbers allocated to Comcast to provide voice services to their subscribers. For

1 As noted below, the exchange of call authentication infonnation with other voice providers requires the completion of coordinated testing to ensure compatibility; as a result, during this initial phase preceding interoperability with other providers, Comcast will remove these headers for any calls bound for nonComcast numbers. 2 Because nearly all of the complaints Comcast receives regarding illegal spoofed robocalls are from our residential subscribers, we have prioritized implementation of SHAKEN/STIR for those customers. Comcast hopes to begin implementation for small business customers by the end of2019 or the first half of 2020, followed by implementation for enterprise customers thereafter. Xfinity Mobile is a mobile virtual network operator (MVNO) offering provided over Verizon's cellular network and is therefore reliant on Verizon's own implementation of SHAKEN/STIR.

2


relevant calls originating from those providers' residential subscribers, Comcast plans to implement the signing aspect of SHAKEN/STIR by the end of the second quarter of 2019, with verification capabilities to be implemented soon thereafter. Comcast also is actively exploring implementation of call authentication capabilities in connection with its wholesale voice transit and termination offerings. One particularly promising method by which wholesale providers may be able to sign calls on behalf of their carrier customers in the future is the Telephone Number Proof of Possession (TN-PoP) protocol-which is the subject of an ongoing and active standards-setting process led by Comcast personnel.

In response to your second question, Comcast plans to take a balanced approach in displaying information regarding call authentication information on end-user devices. We are sensitive to the fact that, while our customers generally will appreciate receiving information on their displays as to whether a particular call is signed and verified, some may be overwhelmed and confused by the appearance of additional labels indicating, for instance, that a call is improperly signed or unsigned. This will be particularly true in the period prior to widespread implementation of SHAKEN/STIR, when the vast majority of calls will lack a signature. Thus, as an initial step, Comcast plans to begin displaying a checkmark or other indicator on end-user devices whenever a call is signed and verified pursuant to SHAKEN/STIR, and expects to have the technical capability to do so by no later than the third quarter of 2019. This approach comports with the written specifications for SHAKEN/STIR, which focus on the display of "positive" information that the call is signed and verified, rather than "negative" information that a call is improperly signed or unsigned. 3 Particularly once SHAKEN/STIR is widely deployed, such labeling will give Comcast's customers significant protection against illegal spoofed robocalls. Comcast also continues to support the adoption of a rule expressly authorizing voice providers to block calls where the originating and terminating providers have both implemented SHAKEN/STIR for the type of call at issue and yet where authentication fails-as such a rule would help prevent illegal spoofed robocalls from even ringing on end-user devices.

Apart from pioneering the development and implementation of SHAKEN/STIR, Comcast is leading the industry's fight against illegal spoofed robocalls in various other ways. For example, Comcast is a member of the Industry Traceback Group, whose coordinated efforts to trace fraudulent calls to their source often results in a decision to add a particular number to the industry Do-Not-Originate (ONO) list. Comcast also has begun implementing specific robocall mitigation techniques authorized by the Commission's 2017 Robocall Blocking Order. We have already configured edge devices on our voice network to implement blocking of calls from numbers on the industry ONO list, and we block thousands of fraudulent robocalls through this method each month. Moreover, in the near future, we plan to begin deployment of a centralized capability for blocking calls appearing to originate from certain invalid and unallocated numbers.

3 Comcast also will continue to make third-party analytics tools (such as Nomorobo) available to customers who want more control over the display and treatment of inbound calls.

3


By implementing such call blocking in a centralized fashion, we not only can block a significantly greater volume of fraudulent robocalls, but also can move swiftly to add or remove numbers or ranges of numbers to be blocked as the need arises.

We also empower Comcast customers by offering free Nomorobo compatibility with our residential voice product and by providing an easily accessible webpage instructing customers on how to activate the service. Nomorobo, which was featured at the Commission's expo on robocall mitigation technologies in April 2018, is a third-party cloud-based service that can be configured by consumers to block various types of robocalls. We estimate that this service successfully blocks roughly 10 million fraudulent robocalls bound for Comcast customers every month.

As reflected in the efforts described above, Comcast is fully committed to putting an end to the menace of illegal spoofed robocalls. We deeply appreciate your attentive and thoughtful leadership on this important issue, as well as the Commission's appropriate and meaningful enforcement actions in this area, and we look forward to continuing our close work with the Commission in stopping these abusive practices once and for all.


~~ President of Technology and Product Comcast Cable

cc: Brian Roberts, Chairman and CEO, Comcast Corporation Deborah Salons (via email at [email protected])

4

Cox Communications – Law & Policy 6205-B Peachtree-Dunwoody Road

Atlanta, GA 30328 404 269-6735

[email protected]

November 19, 2018 VIA EFCS Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th St., S.W. Washington, D.C. 20554 Re: Call Authentication Trust Anchor, WC Docket 17-97 Dear Ms. Dortch: Attached is Cox Communications’ response to Chairman Pai’s November 5 letter regarding Cox’s plans for implementation of the SHAKEN/STIR framework. Sincerely,

Ken Culpepper Senior Director, Regulatory Affairs Cox Communications Attachment cc (via e-mail): Deborah Salons Jenny Prime

Kenneth Culpepper Senior Director, Regulatory Affairs

Cox Communications – Law & Policy 6205-B Peachtree-Dunwoody Road

Atlanta, GA 30328 404 269-7364

[email protected]

November 19, 2018 Chairman Ajit Pai Federal Communications Commission 445 12th St., S.W. Washington, DC 20554

Dear Chairman Pai: In response to your letter to Pat Esser, president of Cox Communications, Inc., dated November 5, 2018, Cox is pleased to provide the following information. As your letter notes, Cox is committed to implementing a robust call authentication framework in 2019. Cox has been actively involved for several years in the efforts to develop the SHAKEN/STIR framework in various industry standards fora. This includes participation on The Alliance for Telecommunications Industry Solutions (ATIS)/SIP- Forum IP-NNI Task Force and the Robocall Strike Force. Cox was also a participant in the Call Authentication Trust Anchor (CATA) working group of the North American Numbering Council (NANC) which led to the NANC recommendations referenced in your letter. And today, Cox is engaged in the ATIS activities involving the establishment of the SHAKEN/STIR governance authority. Cox is currently transitioning its residential customer base to a new IP Multimedia Subsystem (IMS) platform which will include the capability for deployment of the SHAKEN/STIR solution. The residential customer base will be substantially migrated to this new voice services platform throughout 2019. Based on Cox’s vendor’s commitments, the current timeline for deployment of the SHAKEN/STIR framework for Cox’s residential customers can be divided into the following four phases:

• Phase 1: Vendor production testing with a focus on call-signing – Q4, 2018: In this

Phase, Cox’s new voice services platform’s vendor is conducting production testing of

the SHAKEN/STIR call-signing and call-verification functional solution. Cox’s vendor will

perform call-signing on a significant majority of subscriber originated calls later in this

phase. Cox and its vendor will evaluate the results of these tests and ensure their

success before proceeding to Phase 2.

• Phase 2: Continued vendor production testing with a focus on call-verification– Q1,

2019: In this phase, Cox’s platform vendor will be conducting production call-

verification validation on signed-terminating calls. The validation is contingent upon

interoperability with other voice service providers to ensure compatibility. Cox and its

vendor will evaluate the results of the tests and ensure their success before proceeding

to Phase 3.

Jennifer Hightower Senior Vice President and General Counsel

• Phase 3: Cox production call-signing and call-verification – Q2, 2019 and beyond: In this

phase, Cox will perform call-signing and call-verification to the entire subscriber base

that has been migrated to Cox’s new voice services platform. Cox will evaluate the

results of the solution before proceeding to Phase 4.

• Phase 4: Customer facing display of verification status – Q3, 2019: In this phase, Cox

will enable verification status indicators to customers. To ensure consumer trust in

SHAKEN/STIR results, the three previous phases were carefully scoped to ensure

systemic and interoperability issues within SHAKEN/STIR are identified and corrected

prior to customer-facing indicator enablement, so issues are not experienced by

consumers, such as inconsistent verification status.

As described above, Phase 4 is an initial step in Cox’s plans to enable consumer information sharing – through the development of a technical capability. Cox is currently evaluating the best means by which to indicate improperly signed or unsigned calls via this capability. ATIS has produced a Technical Report suggesting a framework for signaling verified Caller ID information from the network to a User Equipment (UE) and displaying the information on the UE in a uniform manner, independent of technology. Conceptually this represents a viable means by which to inform customers of call status, but Cox believes the industry would benefit from a single standard if this framework is to be successful.

In addition, it should also be noted that Commission decisions in open proceedings may impact the need to inform customers of unsigned calls via status indicators. For example, the Commission has specifically asked if carrier-initiated blocking should be allowed on unsigned calls (see FCC 17-24, paragraph 32). Should the Commission authorize such blocking and provide a safe harbor to carriers electing to block such calls, the need to present customers with call status information may be mitigated.

Cox is supportive of the Commission’s efforts to stop unwanted robocalls and will do its part to ensure the success of those efforts. Sincerely,

Jennifer Hightower Senior Vice President and General Counsel Cox Communications

Daniel McCarthy President and CEO 401 Merritt 7 Norwalk, CT 06851 November 19, 2018 VIA ECFS Chairman Ajit V. Pai Federal Communications Commission 445 12th St., S.W. Washington, D.C. 20554 Re: WC Docket No. 17-97 Dear Chairman Pai:

Thank you for your November 5, 2018 letter. Frontier applauds the Commission’s leadership on reducing robocalls and supports the Commission’s stated goal to have SHAKEN/STIR implemented by this time next year. With this letter, Frontier commits to meeting this timeframe and implementing SHAKEN/STIR for internet protocol (IP) calls by this time next year.

Frontier continues to actively explore and implement solutions to combat the ever-

increasing blight of robocalls, including by testing the SHAKEN/STIR protocol. Indeed, Frontier has already deployed tools to empower its customers to better control what calls do and do not ring on their phones. Frontier remains committed to doing everything feasible to combat the proliferation of these disruptive calls.

Your specific questions are reprinted below, followed by Frontier’s responses: 1) What is preventing or inhibiting Frontier from signing calls today?

Frontier is a relatively small piece of the SHAKEN/STIR puzzle as Frontier does not originate

much IP call traffic. Accordingly, it has not made sense for Frontier or its customers for the company to fully implement SHAKEN/STIR before the largest call originators do. Additionally, the majority of Frontier’s voice lines remain legacy Time Division Multiplexing (TDM) lines, which are not compatible with SHAKEN/STIR.1 Thus, as Frontier continues to transition lines to IP, Frontier has been evaluating how best to implement SHAKEN/STIR for its customers. Frontier will continue evaluating the best strategy for targeting robocalls in a way that makes the most sense for consumers as the company continues the transition to IP and expanding its network. Frontier commits to implementing SHAKEN/STIR for IP calls by this time next year.

1 See Robocall Strike Force Report (Oct. 26, 2016), p. 6, available at https://transition.fcc.gov/cgb/Robocall-Strike-Force-Final-Report.pdf.

2

2) What is Frontier’s timeframe for signing calls originating on its network?

Frontier anticipates it can fully integrate SHAKEN/STIR for IP calls originating on its network by this time next year.

3) What tests has Frontier run on deployment and what were the results?

Frontier participated in the Neustar/ATIS SHAKEN/STIR testbed proof-of-concept in late

2017. Frontier has also tested functionality of the SHAKEN/STIR framework for IP originating calls in its lab. Initial results were favorable, and Frontier did not encounter any major issues.

4) What steps has Frontier taken to work with vendors to deploy a robust call

authentication framework?

Frontier has been engaged in discussions with several vendors regarding SHAKEN/STIR implementation and has narrowed the field for its likely vendor for IP calls to two providers. Frontier has also discussed the feasibility of a SHAKEN/STIR solution for TDM calls, as those calls comprise the majority of Frontier’s originating traffic, and has determined that there is no feasible SHAKEN/STIR solution for TDM-originating calls.

5) How often is Frontier an intermediate provider, and do we intend to transmit signed

calls from other providers?

Frontier is not currently an intermediate provider as Frontier does not offer wholesale long-distance termination services; accordingly, all traffic originates from Frontier customers.

6) How does Frontier intend to combat and stop originating and terminating illegally

spoofed calls on our network?

Beyond our commitment to deploying SHAKEN/STIR in the next twelve months, Frontier makes Nomorobo technology available to customers. Frontier has continuously worked with Nomorobo to make the customer-facing portal user-friendly to encourage customers to utilize this valuable tool.

7) If the Commission moves forward with authorizing voice providers to block all unsigned

calls or improperly signed call, how would Frontier ensure the legitimate calls of our customers are completed properly?

Frontier is committed to working with the Commission and other carriers to ensure that the technology used accurately identifies legitimate calls. Frontier will put originating calls through various platforms to ensure legitimacy. If we find the technology is misidentifying calls, we will work with the industry to come up with a solution.

We look forward to working with the Commission and the industry to continue the critical

3

work of protecting consumers. Please do not hesitate to contact us if you would like to discuss these important issues further.

Sincerely,

______________________

Daniel McCarthy cc: Deborah Salons via email ([email protected])

Google LLC 25 Massachuse�s Avenue NW Ninth Floor Washington, DC 20001

202-346-1100 maingoogle.com

November 19, 2018

Via Email and Electronic Filing

Deborah SalonsAttorney AdvisorWireline Competition BureauCompetition Policy DivisionFederal Communications Commission445 Twelfth Street SWWashington, DC 20554

Re: Call Authentication Trust Anchor (WC Docket No. 17-97)

Dear Ms. Salons:

We appreciate Chairman Pai’s November 5, 2018, letter acknowledging Google’s commitmentto implement a robust call authentication framework, and we welcome the opportunity to providethis update on our efforts. We are working toward the goal of implementing SHAKEN/STIR1

once the standards are finalized and approved. To that end, we have been deeply involved withthe Secure Telephone Identity Governance Authority (GA), including by serving as an at-largemember on its Board of Directors and through our representation on the GA’s TechnicalCommittee.

Once the SHAKEN/STIR framework is deployed, we intend to provide consumers with clearinformation to empower them to identify unsigned and improperly signed calls. We expect thisinformation to be very similar to what we are already providing—independent ofSHAKEN/STIR—at no cost today. Specifically, Google’s Phone app offers a robust solution forreducing the number of illegally spoofed calls to our users on Android phones. (Available athttps://play.google.com/store/apps/details?id=com.google.android.dialer&hl=en_US.) Anydevice manufacturer and/or carrier can adopt this solution and preload it on the devices theysell, with no cost to them or to the users who benefit.

In addition, we provide Android users with the ability to filter out spam calls—i.e., a way toprevent suspected spam calls, including illegally spoofed calls, from ringing and instead send

1 SHAKEN/STIR is an acronym of two sets of technical specifications: the Secure Telephone IdentityRevisited (STIR) protocols defined by the Internet Engineering Task Force (IETF), and theSignature-based Handling of Asserted information using toKENs (SHAKEN) specification defined by theATIS/SIP Forum’s IP-NNI Task Force.

https://play.google.com/store/apps/details?id=com.google.android.dialer&hl=en_US

those calls immediately to voicemail. This feature is optional and builds on the existing“suspected spam caller” warning. For more information, please visithttps://support.google.com/phoneapp/answer/3459196.

We also recently began offering the Call Screen feature on Pixel devices, which gives users theoption to have the Phone app ask who’s calling and why before they decide to answer a call.We’re working with other device manufacturers to enable this functionality on their phones aswell. More details about Call Screen are available athttps://support.google.com/phoneapp/answer/9118387.

Google shares the Commission’s concern for addressing the problem of illegally spoofed calls.We will continue to invest in our solutions for preventing such calls from reaching users, while atthe same time remaining committed to the deployment of STIR/SHAKEN.

This notice is being filed in the above-referenced docket for inclusion in the public record.Please contact me should you have any questions.


Darah FranklinCounsel

https://support.google.com/phoneapp/answer/3459196

https://support.google.com/phoneapp/answer/9118387

1 Letter from Keith Buell to Marlene Dortch, Docket No. 17-59 (May 15, 2018) (“Sprint stated that it supports the adoption of SHAKEN/STIR call authentication by carriers … .”; Comments of Sprint Corp., Docket No. 17-59 (July 20, 2018) (“Sprint commits to continue to work with the Commission and the industry to reduce the intrusions into daily life caused by unwanted and often illegal robocalls, including efforts to build the SHAKEN/STIR call authentication system.”); Reply Comments of Sprint Corp., Docket No. 17-59 (Oct. 8, 2018) (“Sprint continues to support the development and implementation of SHAKEN/STIR”).

Dr. John Saw

Chief Technology Officer 6550 Sprint Parkway Overland Park, KS 66215

November 19, 2018

Ajit Pai Chairman Federal Communications Commission 445 12th Street, SW Washington, DC 20554

Re: Call Authentication Trust Anchor, WC Docket No. 17-97

Dear Chairman Pai:

Thank you for your letter of November 5, 2018, regarding the Federal Communication Commission’s (“FCC”) efforts to combat the problem of illegal and unwanted robocalls. Sprint shares the FCC’s goal of ending unlawful caller ID spoofing and continues to work with the industry and the Alliance for Telecommunications Industry Solutions (“ATIS”) on strategies to address this serious problem.

More specifically, and as previously stated in its filings before the FCC,1 Sprint is fully committed to deploying and implementing SHAKEN/STIR. Full deployment of SHAKEN/STIR will be an important step in Sprint and the industry’s continuing work to eradicate the plague of illegal and unwanted robocalls.

Sprint is proud to have been an industry leader in efforts to develop and improve SHAKEN/STIR, and in other efforts to eradicate illegal and unwanted robocalls. Sprint participated in all four working groups of the FCC’s 2016 Robocall Strike Force and co-chaired the “Empowering Consumer Choice” working group. Sprint was a part of the FCC’s North American Numbering Council’s Call Authentication Trust Anchor Working Group that led to the establishment of the SHAKEN/STIR Governance Authority. Sprint regularly contributed to the ATIS/SIP Forum Joint Task Force on IP-NNI and submitted the contribution that led to the attestation claim of SHAKEN call authentication signatures.

Sprint has also worked with the industry and third parties to develop other strategies for addressing unwanted robocalls. Sprint worked with TNS and its Cequint mobile client subsidiary to develop an application for Sprint wireless customers that provides a robocall labeling and blocking service called Premium Caller ID. Numerous third-party solutions, some free, are also available to Sprint customers through mobile application stores such as Google Play or Apple’s App Store.

The following are responses to the individual questions in your letter:

What is preventing or inhibiting you from signing calls today?

While Sprint is committed to deployment of SHAKEN/STIR and is working with its vendors to begin testing various aspects of these protocols, there are several industry wide steps that must be taken before implementation can begin. The Governance Authority for SHAKEN/STIR was just established, and the request for proposals for the Policy Administrator was just issued on November 15. Once there is a Policy Administrator, it can begin the process of designating Certificate Authorities. Because the certificate infrastructure is not yet established, Sprint and other carriers will be required to develop self-signed certificates and manual distribution as a work-around. Sprint is working to accelerate and streamline the SHAKEN/STIR certificate management process through this interim measure and by using other alternative technologies. Sprint does not yet have VoIP peers or transit carrier partners who are prepared to accept signed calls from Sprint. Interoperability testing discussions with other major carriers are on-going but are in the early stages.

Finally, Sprint is in the midst of transitioning from CDMA voice to VoLTE. At its core, SHAKEN/STIR is a VoIP technology. There is no vendor support for CDMA voice application of SHAKEN/STIR and improvising a temporary solution would divert time and resources from completing the transition to VoLTE that will fully support SHAKEN/STIR.

What is your timeframe for signing (i.e., authenticating) calls originating on your network?

Sprint plans to conduct testing of SHAKEN signing and verification with large VoIP peering partners in the 2nd half of 2019 with the implementation of VoLTE on Sprint’s network.

What tests have you run on deployment, and what are the results? Please be specific.

No tests have been run on deployment, although Sprint anticipates lab and field integration testing in the 2nd and 3rd quarters of 2019.

What steps have you taken to work with vendors to deploy a robust call authentication framework?

Sprint has examined the products of multiple vendors to explore their offerings related to SHAKEN/STIR and how to integrate them into Sprint’s existing network architecture. Many of the products are still in development and subject to further revision as the SHAKEN/STIR standards continue to evolve. Sprint has partnered with TNS and its Cequint subsidiary on its Premium Caller ID product. Sprint and TNS are working together to determine how to incorporate authentication information into the analytics and customer display. Furthermore, Sprint is exploring methods to expand other anti-robocalling solutions to the broader customer base. How often is Sprint an intermediate provider, and do you intend to transmit signed calls from other providers?

Sprint estimates approximately 1 percent of its traffic is transit traffic. As SHAKEN/STIR is implemented by Sprint and other carriers, Sprint will make every reasonable effort to ensure all calls with signatures received are passed to the next carrier with the SHAKEN/STIR information preserved.

How do you intend to combat and stop originating and terminating illegally spoofed calls on your network?

Sprint has not been a significant originating source of illegally spoofed calls. The vast majority of Sprint’s customers are wireless customers, and mobile phones in general have not been the source of illegally spoofed calls. To our knowledge, Sprint’s enterprise voice customers have not engaged in illegal spoofing. TNS’s data shows that less than 7 percent of illegal and unwanted robocalls appear to originate from the five largest carriers in the United States, and that the majority of the calls in that 7 percent are spoofed and actually originate from other carriers.

For calls terminating to Sprint’s customers, Sprint has partnered with TNS to deploy Premium Caller ID service that allows Sprint customers on both Android and iOS devices to subscribe to an optional, paid service that empowers them to receive information about the type of caller that is attempting to reach them and to set up preferences to block spoofed calls and other robocalls.

TNS analyzes more than one billion call events per day across 400 carriers to identify nuisance and malicious calls. Premium Caller ID has processed hundreds of millions of calls for millions of Sprint customers and has categorized 64 million calls as being nuisance or malicious, thereby enabling Sprint’s customers to block or decline to answer these calls.

Sprint is exploring additional solutions to provide tools to combat robocalls to a wider customer base.

The Commission has already authorized voice providers to block certain illegally spoofed calls. If the Commission were to move forward with authorizing voice providers to block all unsigned calls or improperly signed calls, how would you ensure the legitimate calls of your customers are completed properly?

Sprint supports blocking of illegally spoofed calls. Sprint recognizes, however, that different levels of blocking will require different levels of analysis and liability protections. When performing opt-in blocking at the device level based on a customer request that they do not want to receive illegal or unwanted calls, Sprint would be lawfully entitled to act. Blocking all calls within the network regardless of customer request raises questions regarding proper identification and appropriate protections that the Commission is currently reviewing.

Sprint is confident that judicious network-level blocking can be done with little risk to legal callers. Carriers and their analytics partners use call routing information, call durations, Caller ID and other network analytics to identify illegal robocalls. SHAKEN/STIR will provide additional information to determine whether a call is spoofed. Sprint currently uses these analytics to empower consumer choice through Sprint’s Premium Caller ID app. But with further development, the same analytics could be used to implement network level blocking.

Thank you for your continued efforts and attention to this industry wide problem. Sprint remains committed to combating illegal and unwanted robocalls and will work with the FCC and the industry to develop and implement tools, including SHAKEN/STIR, to resolve this problem once and for all.

Sincerely,

John Saw Chief Technology Officer

T-Mobile USA, Inc. 601 Pennsylvania Avenue, Washington, DC 20004

November 19, 2018

Hon. Ajit V. Pai

Chairman

Federal Communications Commission

445 12th Street, SW


Dear Chairman Pai:

Thank you for your letter to our CEO, John Legere, regarding T-Mobile’s efforts to end

caller ID spoofing. Our customers hate fraudulent calls, and so do we. As the Un-carrier,

T-Mobile has been leading the industry to combat this problem—we have already

blocked over a billion scam calls and have immediate plans to do even more to spare our

customers from unwanted robocalls and fraud.

T-Mobile recently announced that we are the first carrier that is ready today to deploy the

industry-developed call-authentication system to ensure that all the calls we originate are

appropriately signed.1 And we are the first to announce that we are ready today to peer

with others that have adopted the FCC-recommended SHAKEN/STIR standards.2 We

look forward to adoption of the standards throughout the industry so that we can notify

customers that the calls they are receiving are verified as authentic, and not spoofed or

hijacked.

You have asked specifically what type of information we intend to provide to customers

to identify improperly signed or unsigned calls once SHAKEN/STIR is deployed and

handset specifications include the requirements to support the standards. We are still

considering various options, but for authenticated calls, it is likely that we will opt for a

“call verified” notification.

We also have recently announced the integration of new spoof identification technology

at the network level to enhance our existing free scam detection services—Scam ID and

Scam Block. Scam ID instantly alerts customers when an incoming call is likely a scam,

1 See T-Mobile Has Blocked Over a Billion Scam Calls, and Now Industry-Leading Tech Keeps

Customers Even Safer T-MOBILE, (Nov. 8, 2018), https://www.t-mobile.com/news/t-mobile-

fights-scam-calls.

2 Id.

Hon. Ajit V. Pai

November 19, 2018

Page 2

and Scam Block lets customers choose to block scam calls automatically before they

reach their devices. Since launching Scam ID and Scam Block 18 months ago, we have

tagged over six billion calls as Scam Likely and, as mentioned above, blocked over one

billion scam calls. Our recent improvements offer new protections against increasingly

common “neighborhood spoofing,” whereby scammers temporarily hijack a phone

number to match the area code and three-digit prefix of the person they are targeting,

making the incoming call look familiar. Existing consumer protection applications only

black-list against known scam numbers, not legitimate numbers that have been

temporarily hijacked by scammers. We identify these hijacked numbers by analyzing the

call details for a potential scam call before it reaches a customer’s phone.

We are proud of being the industry leader on scam identification and blocking and look

forward to continuing to work with you and the Commission in the fight to protect

American consumers against scam calls.

Sincerely,

Kathleen O’Brien Ham,

Senior Vice President, Government Affairs

cc: [email protected] (by e-mail)

WC Docket No. 17-97 (via ECFS)

mailto:[email protected]

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