[Sipnoc24-attendees] Draft/proposed Eighth Report and Order was Deleted from Sep. 26, 2024 Open FCC Meeting

Thu Oct 31 23:28:44 UTC 2024

Phil this is just bats* crazy…

Talk about Halloween surprise.  <sigh> <geez>

I guess I need to check how much paper I have in my printer.

From: <pmacres at kleinlawpllc.com>
Date: Thursday, October 31, 2024 at 6:51 PM
To: Richard Shockey <richard at shockey.us>, "'Burger, Eric'" <ewburger at vt.edu>, <sipnoc24-attendees at sipforum.org>, 'Tina Donaldson' <tina at netnumber.com>
Subject: RE: [Sipnoc24-attendees] Draft/proposed Eighth Report and Order was Deleted from Sep. 26, 2024 Open FCC Meeting

Hi Richard – Great question!

On that front, I just sent around a clarification that there are now two (2) entirely different draft Eighth Report and Orders on circulation associated with two entirely different but related FCC proceedings: One in Docket No. 17-59 (from Sep., addressing call blocking etc.) and one in Docket 17-97 (on FCC’s Nov. 21 agenda concerning call authentication). 

Philip J. MacresPrincipalKlein Law Group PLLC PMacres at KleinLawPLLC.com  1250 Connecticut Ave. N.W. Suite 700Washington, D.C. 20036Office:  (202) 289-6956Mobile: (703)-346-4197                  
www.KleinLawpllc.com The information contained in this communication is confidential and may be subject to the attorney-client privilege.  It is intended solely for the use of the addressee(s).  Unauthorized interception, use or disclosure of this communication is prohibited and may be unlawful.  If you have received this communication in error, kindly notify us immediately by return e-mail and destroy this communication and any attachments.

From: Richard Shockey <richard at shockey.us> 
Sent: Thursday, October 31, 2024 3:43 PM
To: pmacres at kleinlawpllc.com; 'Burger, Eric' <ewburger at vt.edu>; sipnoc24-attendees at sipforum.org; 'Tina Donaldson' <tina at netnumber.com>
Subject: Re: [Sipnoc24-attendees] Draft/proposed Eighth Report and Order was Deleted from Sep. 26, 2024 Open FCC Meeting

Thanks for this… BTW did you run a text compare on the previous R&O vs this one.

Any significant differences in the text?

Yea drop in on Halloween.  Priceless. At it least was not tomorrow at 4:59 PM 

Richard Shockey

Shockey Consulting LLC

Chairman of the Board SIP Forum

www.shockey.us

www.sipforum.org

richard<at>shockey.us

Skype-Linkedin-Facebook –Twitter  rshockey101

PSTN +1 703-593-2683

From: <pmacres at kleinlawpllc.com>
Date: Thursday, October 31, 2024 at 5:39 PM
To: "'Burger, Eric'" <ewburger at vt.edu>, Richard Shockey <richard at shockey.us>, <sipnoc24-attendees at sipforum.org>, 'Tina Donaldson' <tina at netnumber.com>
Subject: RE: [Sipnoc24-attendees] Draft/proposed Eighth Report and Order was Deleted from Sep. 26, 2024 Open FCC Meeting

Good afternoon everyone,

I hope all is well. I thought I would follow up on my email below and share some Halloween goodies with you. 

In particular, while the FCC still has the draft Eighth Report and Order on circulation (i.e., it has yet to be adopted), the Chairwoman announced that the FCC’s Nov. 21, 2024 open meeting will include an order that addresses third-party authentication, which has been a heated topic. 

Here’s the FCC’s draft order and summary of it is pasted below (with emphases added): 

What the Report and Order Would Do: 
Define “third-party authentication” to provide a clear scope of the third-party authentication practices authorized and prohibited by the new rules. 
Authorize providers with a STIR/SHAKEN implementation obligation to engage third parties to perform the technological act of digitally “signing” calls consistent with the requirements of the STIR/SHAKEN technical standards, subject to two conditions: 
(1) The provider with the implementation obligation itself makes the critical “attestation level” decisions for authenticating caller ID information associated with its calls; and 
(2) All calls are signed using the certificate of the provider with the implementation obligation—not the certificate of a third party. 
Explicitly require all providers with an implementation obligation to obtain a Service Provider Code (SPC) token from the Policy Administrator and present that token to a STIR/SHAKEN Certificate Authority to obtain a digital certificate. 
Require any provider certifying to partial or complete STIR/SHAKEN implementation in the Robocall Mitigation Database to have obtained an SPC token and digital certificate and sign all its calls with that certificate, either themselves or when working with a third party to perform the technological act of signing calls. 
Adopt recordkeeping requirements for third-party authentication arrangements to monitor compliance with and enforce the Commission’s rules.

Interested stakeholders looking to have written or oral ex partes with the FCC on the draft order need to do so by Nov. 14, 2024.

Best regards and Happy Halloween,

Phil

Philip J. MacresPrincipalKlein Law Group PLLC PMacres at KleinLawPLLC.com  1250 Connecticut Ave. N.W. Suite 700Washington, D.C. 20036Office:  (202) 289-6956Mobile: (703)-346-4197                  
www.KleinLawpllc.com The information contained in this communication is confidential and may be subject to the attorney-client privilege.  It is intended solely for the use of the addressee(s).  Unauthorized interception, use or disclosure of this communication is prohibited and may be unlawful.  If you have received this communication in error, kindly notify us immediately by return e-mail and destroy this communication and any attachments.

From: pmacres at kleinlawpllc.com <pmacres at kleinlawpllc.com> 
Sent: Tuesday, October 1, 2024 2:45 PM
To: 'Burger, Eric' <ewburger at vt.edu>; 'Richard Shockey' <richard at shockey.us>; 'sipnoc24-attendees at sipforum.org' <sipnoc24-attendees at sipforum.org>; 'Tina Donaldson' <tina at netnumber.com>
Subject: RE: [Sipnoc24-attendees] Draft/proposed Eighth Report and Order was Deleted from Sep. 26, 2024 Open FCC Meeting

Good afternoon everyone, 

Although we are still waiting for the FCC to adopt its Eighth Report and Order on Circulation, attached is a consolation prize (in case you have not seen this already) – FCC’s EB Releases Traceback Data Report for Q2 2024.

Best regards,

Phil

Philip J. MacresPrincipalKlein Law Group PLLC PMacres at KleinLawPLLC.com  1250 Connecticut Ave. N.W. Suite 700Washington, D.C. 20036Office:  (202) 289-6956Mobile: (703)-346-4197                  
www.KleinLawpllc.com The information contained in this communication is confidential and may be subject to the attorney-client privilege.  It is intended solely for the use of the addressee(s).  Unauthorized interception, use or disclosure of this communication is prohibited and may be unlawful.  If you have received this communication in error, kindly notify us immediately by return e-mail and destroy this communication and any attachments.

From: pmacres at kleinlawpllc.com <pmacres at kleinlawpllc.com> 
Sent: Thursday, September 26, 2024 5:13 PM
To: 'Burger, Eric' <ewburger at vt.edu>; 'Richard Shockey' <richard at shockey.us>
Cc: 'Tina Donaldson' <tina at netnumber.com>; 'sipnoc24-attendees at sipforum.org' <sipnoc24-attendees at sipforum.org>
Subject: RE: [Sipnoc24-attendees] Draft/proposed Eighth Report and Order was Deleted from Sep. 26, 2024 Open FCC Meeting

Bear in mind, the FCC’s language in a draft/proposed order is fairly fluid, as it is basically a “courtesy view” of what the FCC is entertaining (just for the FCC to make sure it got it right - from its perspective of course). 

Note that the FCC’s release of draft/proposed orders on an FCC open meeting agenda only started happening during the Pia regime. 

At this point, the comment cycle has already occurred for the FCC to rule on this NPRM. 

Until the FCC adopts a draft/proposed order that it previously shared with the public, any language in the draft/proposed order is subject to change, which is why you will see a slew of ex partes on the item advocating change or not to the draft/proposed order before the sunshine period, which is the one-week quiet period just before the open meeting.

Best regards,

Phil 

Philip J. MacresPrincipalKlein Law Group PLLC PMacres at KleinLawPLLC.com  1250 Connecticut Ave. N.W. Suite 700Washington, D.C. 20036Office:  (202) 289-6956Mobile: (703)-346-4197                  
www.KleinLawpllc.com The information contained in this communication is confidential and may be subject to the attorney-client privilege.  It is intended solely for the use of the addressee(s).  Unauthorized interception, use or disclosure of this communication is prohibited and may be unlawful.  If you have received this communication in error, kindly notify us immediately by return e-mail and destroy this communication and any attachments.

From: Burger, Eric <ewburger at vt.edu> 
Sent: Thursday, September 26, 2024 12:59 PM
To: Richard Shockey <richard at shockey.us>
Cc: pmacres at kleinlawpllc.com; 'Tina Donaldson' <tina at netnumber.com>; sipnoc24-attendees at sipforum.org
Subject: Re: [Sipnoc24-attendees] Draft/proposed Eighth Report and Order was Deleted from Sep. 26, 2024 Open FCC Meeting

I don't they would do that without public comment. 

On Sep 26, 2024 10:13 AM, Richard Shockey <richard at shockey.us> wrote:

Thanks Phil for this. The real question is has the text changed substantively parts removed or beefed up IP maybe?

Richard Shockey

Shockey Consulting LLC

Chairman of the Board SIP Forum

www.shockey.us

www.sipforum.org

richard<at>shockey.us

Skype-Linkedin-Facebook –Twitter  rshockey101

PSTN +1 703-593-2683

From: <pmacres at kleinlawpllc.com>
Date: Thursday, September 26, 2024 at 10:41 AM
To: Richard Shockey <richard at shockey.us>, 'Tina Donaldson' <tina at netnumber.com>, <sipnoc24-attendees at sipforum.org>
Subject: RE: Draft/proposed Eighth Report and Order was Deleted from Sep. 26, 2024 Open FCC Meeting

FYI – Quick update on the above, I was told the Chairwoman’s Office has stated publicly that the item will move to Circulation. I have yet to see it on the FCC’s “Items on Circulation” list though. See https://www.fcc.gov/items-on-circulation. Perhaps we will see it appear in the next day or so.  

Philip J. MacresPrincipalKlein Law Group PLLC PMacres at KleinLawPLLC.com  1250 Connecticut Ave. N.W. Suite 700Washington, D.C. 20036Office:  (202) 289-6956Mobile: (703)-346-4197                  
www.KleinLawpllc.com The information contained in this communication is confidential and may be subject to the attorney-client privilege.  It is intended solely for the use of the addressee(s).  Unauthorized interception, use or disclosure of this communication is prohibited and may be unlawful.  If you have received this communication in error, kindly notify us immediately by return e-mail and destroy this communication and any attachments.

From: pmacres at kleinlawpllc.com <pmacres at kleinlawpllc.com> 
Sent: Tuesday, September 24, 2024 6:12 PM
To: 'Richard Shockey' <richard at shockey.us>; 'Tina Donaldson' <tina at netnumber.com>; 'sipnoc24-attendees at sipforum.org' <sipnoc24-attendees at sipforum.org>
Subject: Draft/proposed Eighth Report and Order was Deleted from Sep. 26, 2024 Open FCC Meeting

Good afternoon everyone, 

This afternoon the FCC deleted the draft/proposed Eighth Report and Order (which was the subject of a fair amount of discussion during SIPNOC 2024 last week) from the FCC’s Open Meeting on Sep. 26. 

At this point, it is unclear if this item was adopted on circulation or if the FCC hit the pause button given the various ex partes filed last week. 

I suspect we should know one way or another in short order. 

Best regards,

Phil

Philip J. MacresPrincipalKlein Law Group PLLC PMacres at KleinLawPLLC.com  1250 Connecticut Ave. N.W. Suite 700Washington, D.C. 20036Office:  (202) 289-6956Mobile: (703)-346-4197                  
www.KleinLawpllc.com The information contained in this communication is confidential and may be subject to the attorney-client privilege.  It is intended solely for the use of the addressee(s).  Unauthorized interception, use or disclosure of this communication is prohibited and may be unlawful.  If you have received this communication in error, kindly notify us immediately by return e-mail and destroy this communication and any attachments.

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