DA 22-502 Mark Angell, Chairman Omer Varol, Chief Executive Officer Dial-Around Telecom, Inc. 1075 Rosewood Dr. Grapevine, TX 76051 Via Certified Mail, Return Receipt Requested Re: Potential Reclamation of Dial-Around Telecom, Inc.’s International Signaling Point Code, 3-053-3 (New York, NY) Dear Messrs. Angell and Varol: By this letter, we inform you of our intent to reclaim the above-captioned International Signaling Point Code (ISPC), provisionally assigned to Dial-Around Telecom, Inc. (Dial-Around), unless you respond to this letter within thirty (30) days, by June 6, 2022, and indicate whether Dial-Around is still using the code. The Federal Communications Commission (Commission), as the Administrator for the United States, assigns ISPCs for Signaling System No. 7 networks under ITU-T Recommendation Q.708. International Telecommunication Union (ITU), ITU-T Recommendation Q.708 (03/99), Series Q: Switching and Signalling, Specifications of Signalling System No. 7—Message Transfer Part (MTP), Assignment procedures for international signalling point codes, https://www.itu.int/rec/recommendation.asp?lang=en&parent=T-REC-Q.708-199903-I (ITU-T Recommendation Q.708). The Commission has explained that ISPCs are a scarce resource and “[a]s a result, code assignments are conditional upon their being used within one year lead time, so that the Commission can reassign unused codes to another carrier.” Reporting Requirements for U.S. Providers of International Telecommunications Services; Amendment of Part 43 of the Commission’s Rules, Notice of Proposed Rulemaking, 19 FCC Rcd 6460, 6474, para. 36, n.83 (2004); see also China Telecom (Americas) Corporation, GN Docket No. 20-109 et al., Order Instituting Proceedings on Revocation and Termination and Memorandum Opinion and Order, 35 FCC Rcd 15006, 15040, para. 58 (2020) (“ISPCs are a scarce resource that are used by international Signaling System 7 (SS7) gateways as addresses for routing domestic voice traffic to an international provider and anyone seeking an ISPC assignment is required by rule to file an application with the Commission and comply with its procedures.”). Finally, ITU-T Recommendation Q.708 provides that the Commission should withdraw an ISPC assignment if the code is “no longer in use or required” by the operator, among other reasons. ITU-T Recommendation Q.708 at 6. Pursuant to ITU-T Recommendation Q.708, the Commission also required Dial-Around to make several certifications in its application for the ISPC. First, Dial-Around certified that the “[c]ode assignments held in excess of 12 months without implementation must be returned to this Administrator for reassignment.” Dial-Around Telecom, Inc., File No. SPC-NEW-20040419-00012 (filed Apr. 19, 2004) (Dial-Around ISPC Application). To confirm this, the Telecommunications Division (Division) of the International Bureau (Bureau) in a letter provisionally assigning the code to Dial-Around on April 23, 2004, required Dial-Around to inform the Division of the date the code was implemented. Letter from Cathy Hsu, Policy Division, International Bureau, FCC to Mark Angell, Secretary, Dial-Around Telecom, Inc. (Apr. 23, 2004) (Dial-Around Grant Letter). at 2 (“. . . your implementation and notification to this office must occur on or before April 23, 2005.”). Second, Dial-Around certified “[it is] aware that all ISPC assignments are provisional and that nobody has a property right in [an] ISPC [and it is] aware that the Commission may take an assigned ISPC and reassign it to another person.” Dial-Around ISPC Application. In granting the Dial-Around ISPC Application, the Division also stated that requests for ISPCs must “strictly fit the [ITU-T Recommendation Q.708] guidelines and that ‘warehousing’ of assignments be avoided. . . .” Dial-Around Grant Letter at 1. Third, Dial-Around was subject to the annual traffic and revenue reporting requirements at the time of its ISPC assignment. Dial-Around certified that its failure to file this report would “be interpreted as inactive operation and could, therefore, result in the loss of the carrier’s point code assignment.” Dial-Around ISPC Application. Despite these certifications, we have no record that Dial-Around informed the Division or the Bureau of the date the code was implemented or filed any International Traffic and Revenue Reports for the years 2004-2015. In 2017, the Commission eliminated the requirement that U.S. providers of international telecommunications services file annual Traffic and Revenue Reports. See Section 43.62 Reporting Requirements for U.S. Providers of International Services; 2016 Biennial Review of Telecommunications Regulations, IB Docket Nos. 17-55 & 16-131, Report and Order, 32 FCC Rcd 8115 (2017). Providers, including Dial-Around, were required to file the final traffic and revenue data for calendar year 2015. In March 2020, Bureau staff made several attempts to contact Dial-Around to ascertain whether it is using its assigned ISPC. On March 6 and March 9, 2020, the staff sent inquiries to the email addresses on file, which were either returned due to an unknown user error or unanswered. Emails from Arthur Lechtman, Attorney-Advisor, Telecommunications and Analysis Division, International Bureau, to Mark J. Angell, Dial-Around Telecom, Inc. (m.angell@comcast.net; m.angell@comcast.netcom) (Mar. 6, 2020, 4:37 PM) and to Mark J. Angell and Vicki Angell (v.angell@comcast.net; m.angell@attbi.com) (Mar. 9, 2020, 4:42 PM); Return emails from Mail Delivery Subsystem to Arthur Lechtman, Attorney-Advisor, Telecommunications and Analysis Division, International Bureau (Mar. 6, 2020, 4:37 PM; Mar. 9, 2020, 4:45 PM; Mar. 14, 2020, 4:44 PM). These emails are reprinted in the Attachment below. Also on March 9, 2020, staff called Dial-Around’s phone numbers on record, which are either no longer in service or the calls went unanswered. Staff called the following telephone numbers: (817) 329-7424 and (877) 212-9865. The FCC’s Form 499 Filer Database indicates that Dial-Around has not been active since July 1, 2005 and that its account was “closed because the administrator could not contact the filer.” Dial-Around Telecom, Inc., FCC Form 499 Filer Database, https://apps.fcc.gov/cgb/form499/499detail.cfm?FilerNum=823278 (last visited Feb. 17, 2022). Finally, staff viewed Florida’s Department of State, Division of Corporations website, according to which Dial-Around has been inactive since 2013, when it was dissolved. See Florida, Department of State, Division of Corporations, Search Records, https://dos.myflorida.com/sunbiz/search/. Based on our inability to contact a representative of Dial-Around, our records, Dial-Around’s apparent failure to file any International Traffic and Revenue Reports for 2005-2014, and the records of Florida’s Department of State, we believe Dial-Around may no longer be providing service and may no longer be using its assigned ISPC. We request that you respond to this letter by June 6, 2022, and indicate the date the code was implemented and describe the current use of Dial-Around’s ISPC (3-053-3). A failure to respond to this letter by this date will serve as confirmation that Dial-Around is no longer using its provisionally assigned ISPC and has failed to comply with our ISPC requirements. Consistent with the terms of the ITU-T Recommendation Q.708, we will reclaim the ISPC (3-053-3) and immediately thereafter make the code available for reassignment if you fail to respond to this letter as requested. We are addressing this letter to the most recent contacts and addresses of record provided by Dial-Around. If you have any questions, please contact me at (202) 418-7370 or Francis.Gutierrez@fcc.gov or my colleague Arthur Lechtman at (202) 418-1465 or Arthur.Lechtman@fcc.gov. Sincerely, /Francis Gutierrez/ Francis Gutierrez Deputy Chief, Telecommunications and Analysis Division International Bureau cc: Mark J. Angell Dial-Around Telecom, Inc. 2637 East Atlantic Blvd., Suite 242 Pompano Beach , FL 33062 Vicki Angell VLA Associates, LLC 1075 Rosewood Drive Grapevine, TX 76051 Corporation Service Company 1090 Vermont Ave., NW Washington, DC 20005 Attachment Email Exchange 1 -----Original Message----- From: Mail Delivery Subsystem Sent: Friday, March 6, 2020 4:37 PM To: prvs=03340bc94c=arthur.lechtman@fcc.gov Subject: Returned mail: see transcript for details The original message was received at Fri, 6 Mar 2020 21:36:49 GMT from m0102176.ppops.net [127.0.0.1] ----- The following addresses had permanent fatal errors ----- (reason: 550 5.1.1 Not our Customer) (reason: 550 Host unknown) ----- Transcript of session follows ----- ... while talking to mx1.comcast.net.: >>> RCPT To: <<< 550 5.1.1 Not our Customer 550 5.1.1 ... User unknown >>> DATA <<< 503 5.5.0 need RCPT before DATA 550 5.1.2 ... Host unknown (Name server: comcast.netcom.: host not found) ### From: Arthur Lechtman Sent: Friday, March 6, 2020 4:37 PM To: m.angell@comcast.net; m.angell@comcast.netcom Cc: Francis Gutierrez ; Stacey Ashton Subject: Dial-Around Telecom, Inc. - International Signaling Point Code Hello Mr. Angell, I am writing to inquire whether Dial-Around Telecom, Inc. is still using the international signaling point code that it was assigned in 2004 (3-053-3). Please let me know by email or call me at the number below if you have any questions. Thank you, Artie Lechtman Federal Communications Commission International Bureau 202.418.1465 Email Exchange 2 -----Original Message----- From: Mail Delivery Subsystem Sent: Saturday, March 14, 2020 4:44 PM To: prvs=033760dc99=arthur.lechtman@fcc.gov Subject: Returned mail: see transcript for details The original message was received at Mon, 9 Mar 2020 20:42:29 GMT from m0102174.ppops.net [127.0.0.1] ----- The following addresses had permanent fatal errors ----- ----- Transcript of session follows ----- ... Deferred: Connection timed out with attbi.com. Message could not be delivered for 5 days Message will be deleted from queue ### -----Original Message----- From: Mail Delivery Subsystem Sent: Monday, March 9, 2020 4:45 PM To: prvs=033760dc99=arthur.lechtman@fcc.gov Subject: Returned mail: see transcript for details The original message was received at Mon, 9 Mar 2020 20:42:29 GMT from m0102174.ppops.net [127.0.0.1] ----- The following addresses had permanent fatal errors ----- (reason: 550 5.1.1 Not our Customer) ----- Transcript of session follows ----- ... Deferred: Connection timed out with attbi.com. ... while talking to mx1.comcast.net.: >>> RCPT To: <<< 550 5.1.1 Not our Customer 550 5.1.1 ... User unknown >>> DATA <<< 503 5.5.0 need RCPT before DATA ### From: Arthur Lechtman Sent: Monday, March 9, 2020 4:42 PM To: v.angell@comcast.net; m.angell@attbi.com Cc: Francis Gutierrez ; Stacey Ashton Subject: FW: Dial-Around Telecom, Inc. - International Signaling Point Code Hello- Please see the email below that was returned as undeliverable. Thank you. From: Arthur Lechtman Sent: Friday, March 6, 2020 4:37 PM To: m.angell@comcast.net; m.angell@comcast.netcom Cc: Francis Gutierrez ; Stacey Ashton Subject: Dial-Around Telecom, Inc. - International Signaling Point Code Hello Mr. Angell, I am writing to inquire whether Dial-Around Telecom, Inc. is still using the international signaling point code that it was assigned in 2004 (3-053-3). Please let me know by email or call me at the number below if you have any questions. Thank you, Artie Lechtman Federal Communications Commission International Bureau 202.418.1465 2