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Press Release:

Reply Comment Period Ends on Telcordia Petition

WASHINGTON, DC and Piscataway, NJ - September 24, 2007 - Telcordia today welcomed the end of the Federal Communication Commission's (FCC) 30-day reply comment period on its petition (FCC Docket 07-149) regarding number portability administration.

"We are pleased that the comment period, and now the reply comment period on our petition, has been completed. The longer this languishes, the longer inflated prices are paid and so we look forward to a speedy resolution," said Richard Jacowleff, President, Interconnection Solutions, Telcordia. "We maintain our position that the current process is fundamentally flawed, and look to the FCC to continue to act quickly to eliminate the financial penalty provisions of the current contract and direct the NAPM LLC to implement an open competitive bidding process. Only an open, competitive bidding process will ensure the best product for consumers at the most reasonable cost."

Background information on this issue is available online at:
http://www.telcordia.com/services/number_portability/fcc.html

The Executive Summary of the Telcordia reply comments is below. The full reply can be found at http://www.telcordia.com/collateral/fcc/telcordia_petition_reply_sept2007.pdf

TELCORDIA EXECUTIVE SUMMARY

Telcordia has asked the Commission to restore competition to the market for number portability services and thereby save consumers at least $60 million per year. The Commission can do this simply by striking the anticompetitive provisions of Amendment 57 to the NeuStar/NAPM contract for number portability administration and reforming the contract process to require competitive bidding.

The anticompetitive provisions of Amendment 57 impose enormous financial penalties on both the telecommunications industry and consumers if NAPM either seeks or advocates competition. These provisions clearly violate the law and, along with the lack of an open competitive process, undermine Commission policy by effectively eliminating any possibility of competition in the market for number portability services until 2012 and perhaps beyond. Simply put, NeuStar and NAPM struck a deal to replace the Commission's and Congress' competitive framework with what is at heart a solesource contract.

NeuStar and NAPM — the authors of Amendment 57 — defend their anticompetitive provisions essentially by arguing that no one is unhappy with the current lack of competition so the Commission need not worry about it. This argument is fundamentally flawed, because the current single vendor system enshrined by Amendment 57 causes substantial public harm. This proceeding is about far more than NeuStar, NAPM, and its members. It is about the hundreds of other carriers and millions of consumers paying inflated charges because of a closed-door anticompetitive deal.

From the start of number portability, the Commission has embraced competition and recognized that there are clear advantages to competition in number portability administration — including lower prices and quality service. NeuStar's hand-waving about Telcordia's attempt to offer its services in 2005 and its self-congratulatory prose about its services cannot distract the Commission from the core issue. Amendment 57 is anticompetitive. The sole purpose of the penalty provisions is to eliminate the possibility of competition. NeuStar and NAPM have subverted Commission intent and, behind closed and confidential doors, effectively eliminated competition. The Commission, which has plenary authority over all numbering matters, has the power — and the obligation — to correct the situation and re-open the market for numbering portability administration to competition.

About Telcordia

Contact:
Sharon Oddy
Telcordia Technologies, Inc.
(732) 699-4203
oddys@telcordia.com

Bill McCloskey
(301) 379-4709
bmccloskey@greenerandhook.com