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From: "Fred R. Goldstein" <>
Subject: Re: All AOS's Aren't Scum
Date: 21 Jun 91 18:28:46 GMT
Organization: Digital Equipment Corp., Littleton MA USA

In article <>, (Jim Allard)

> Since my favorite UNIX afficionado introduced me to the Digest a few
> months ago, I have been quietly sitting in the background reading the
> various utterings of respondents, as AOSs and COCOTs in general have
> been heavily smacked around.  While I will agree there are some
> unethical providers out there, some of us have made a serious effort
> to provide services which attempt to validate the reasons for the MFJ
>  -- competition.  ...

Mr. Allard has a disingenuous but ultimately specious defense of his
so-called "industry".  Beginning with his motherhood and apple pie
defense of "competition" (who's disputing that?), he then claims that
because his company is doing something apparently in competition with
AT&T, he must be good.  Hogwash.

Speaking as a diehard anti-monopolist who has taken the strong position 
that "divestiture" was a Good Thing (and disagreeing with the Moderator 
quite openly, to be sure), I still see no excuse for the AOS/COCOT
business to exist.  They're bottom-feeding scum whose very existence
is no more than an unhappy accident.

Fact: Nobody in "power" EVER planned on the COCOT/AOS situation.  It
was an accident caused by the confluence of several different legal
and regulatory events.  If it were chemistry, it would be the creature
from the Toxic Lagoon, one of those unhappy reactions.

Event 1: COCOTs.  This was planned.  Back in 1977, the FCC
Registration program (Part 68) specifically excluded pay phones.  At
the time, the only pay phones were the CO-controlled kind; mucking
with those lines could have caused mis-billing, fraud, etc.  No
problem.  But then somebody invented a new kind of pay phone that ran
on a standard line.  Was it allowed?  The FCC recognized the rationale
behind the original pay phone exemption and allowed registation of the
COCOT.  That was purely a technical issue.

Event 2: Resale.  This was planned.  Back in the '70s, the FCC allowed
resale carriers to operate under license; later, the license
requirement was dropped.  Anybody could resell anything.  At any
price.  This was fine; the telco still got the money from the original
supplier and if somebody chose to buy from a reseller, that's their
business.  This has recently begun in Canada, btw.  Reselling is a
cheap way to pretend to be an LD carrier.

Event 3: Divestiture.  This caused the LECs (RBOCs et al) to adopt an
arms-length relationship from LD carriers.  So they had to accept
billing requests from any and all LD comers, if they were to continue
to bill for AT&T.

Now with anybody allowed to put anything on a phone bill, bottom
feeders moved in.  They got aggregators and COCOTs to force calls
throgh themselves.  They charged outrageous, unregulated rates.  They
gave lousy service.  But it was all legal, since reselling was allowed
and resellers were, like carriers, allowed to buy LEC billing

Maybe, just maybe, Mr. Allard's company does't overcharge the way
99.44% of AOSs do.  But when I travel on business with my AT&T SDN
card, I don't expect to have to pay out of pocket to the hotel what
normally gets direct-billed via our Tariff 12 agreement.  I don't want
to have to argue with the poor underpaid sweatshop operators about my
right to be connected to AT&T (though I often do, and I NEVER let the
AOS get my money).  If we had a responsible FCC that required
resellers to file arguable tariffs, and required phones to offer the
actual callers a choice of carrier, that's fine.  But making "captive"
callers use some company, that exists only because of loopholes in the
law, is not going to win my sympathy.

Fred R. Goldstein              Digital Equipment Corp., Littleton MA   voice: +1 508 952 3274
  <insert standard disclaimer>

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