Consolidating telecom services allows for all of your services to be handled by one or more vendors that specialize in what your business needs most. Consolidation will help your firm cut costs and provide an easy solution for telecom expense management. In order to select the best plan of consolidation for your company, you must first analyze the options available.

Telecom Consolidation Options

Select a Tier 1 Telecom Vendor

By selecting one major provider you can easily manage your telecom services. This will also cut down on invoice paperwork and reduce the time your office staff must deal with providers. Having a single vendor to handle telecom services also mitigates the possibility of billing errors and error management.

Pursue Niche Telecom Vendors

This option allows you to choose several vendors with specific telecom service expertise. Using niche providers ensures your service will be the most up to date and reliable. Niche vendors are typically more agile than larger vendors so you can still see lower monthly costs and simpler telecom expense management.

Choose a Vendor That Offers Telecom Bundles

Bundle pricing may only provide you with a few choices, but in some cases the prices associated with bundling can’t be beat. Bundling allows you to get the service you need at a discounted price, all on one bill. Since you will be dealing with a single vendor, telecom expense management will be simplified.

Deciding to Make the Switch

Once you have decided which option to use to consolidate your telecom services, you must then select the vendor or vendors that best suit your needs. Unless you are completely unsatisfied with your current providers, reach out before making the switch. They may have the ability to help you consolidate within their services at a great price.

Performing a telecom audit can determine where your current providers are lacking and where they excel.  Switching providers can come with costs, you need to make sure these expenses are manageable. Here are 3 things to consider before consolidating your telecom:

  • Specific Needs:Your Company will grow and adapt to market changes, therefore you must select a company you can grow with. Your new provider should have the ability to scale services up or down depending on your growth rate. When choosing multiple niche providers, consider which services your company relies on the most.
  • Cost:If a service plan seems too good to be true, it probably is. Always consider the soft costs in addition to your monthly fees. Choose a provider that is upfront with set up, upgrade costs, and maintenance fees. Choosing the cheapest provider may not be the best way to go.  You want the best service at the most reasonable price, not necessarily the cheapest price.
  • Collective Improvement: Consolidating your telecom service should improve all of these basic factors: quick and accurate customer service, simplified invoicing, improved capabilities, coverage and options.

Remember, telecom consolidation has a wealth of advantages if you are willing to take the time to thoroughly review your options. Simplifying your telecom expense management will save your firm time, money, and headaches associated with handling multiple providers.

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Posted by on September 12, 2014 in Uncategorized


FCC opposes Sprint/T-Mobile teaming up for spectrum auctions

By Nick Wood, Total Telecom
Monday 04 August 2014

Sprint and T-Mobile US could be blocked from jointly bidding for frequencies as part of a broader effort by the Federal Communications Commission to encourage smaller companies to enter the U.S. mobile market.

A Wall Street Journal report in July claimed that the operators were in talks to form a $10 billion joint venture for the purposes of participating in next year’s TV spectrum auction in the event their anticipated merger is not completed in time.
However, in a notice of proposed rulemaking (NPRM) issued on Friday, the FCC said it would seek to prevent such partnerships.

“Our goal is to promote the participation of as many parties as possible in the auction. If two of the largest companies are able to bid as one combined entity in the auction, their combined resources may have the effect of suppressing meaningful competition,” explained Roger Sherman, chief of the FCC’s wireless telecommunications bureau, in a blog post.
“Therefore, the item tentatively concludes that joint bidding arrangements between nationwide providers should not be allowed,” he said.

Instead the FCC hopes to encourage smaller players to enter the sector by forming partnerships with larger companies in order “to gain access to capital and cash flow, not to mention operational experience”, said Sherman.
“Allowing structured entry into the wireless business makes sense, especially given the billions of dollars it would take to build a new national network from scratch,” he said.

The FCC said that once smaller companies have gained vital experience in operations and investment they stand a better chance of becoming more robust, facilities-based competitors in the marketplace.
“We hope all stakeholders will offer constructive suggestions so we can work together to empower small businesses and entrepreneurs to participate in the spectrum economy,” Sherman said

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Posted by on August 4, 2014 in Uncategorized



By Josh Long

A small fraction of Verizon Wireless’ 104.6 million retail connections have a tendency to hog bandwidth, prompting the company to manage the speeds of the top 5 percent of data users who subscribe to unlimited data plans.
FCC Chairman Tom Wheeler isn’t happy. In a letter Wednesday to Verizon Wireless CEO Daniel Mead, Wheeler said he was “deeply troubled” by the wireless carrier’s earlier announcement that it plans to slow the data speeds of some customers beginning in October.
“It is disturbing to me that Verizon Wireless would base its ‘network management’ on distinctions among its customers’ data plans, rather than on network architecture or technology,” wrote Wheeler, a former CEO of the Cellular Telecommunications & Internet Association.
‘I know of no past Commission statement that would treat as ‘reasonable network management’ a decision to slow traffic to a user who has paid, after all, for ‘unlimited’ service,” he added later.
Wheeler asked Verizon Wireless to answer a number of questions, including how it could justify its conduct under open Internet rules that the FCC adopted in 2010 including a “transparency” regulation that remains in effect. He also inquired into why the company was “extending speed reductions from its 3G network to its much more efficient 4G LTE network.”
On its website, Verizon Wireless explained it may reduce the data speeds of customers on an unlimited plan at times of high demand on a cellular tower and only “when necessary for us to optimize data network traffic in that area.” As of March 2014, the top 5 percent of data users were consuming 4.7 GB of data each month, according to the company.
Verizon Wireless said it will respond to Wheeler’s letter after it has received and reviewed it.
“However, what we announced last week was a highly targeted and very limited network optimization effort, only targeting cell sites experiencing high demand,” the company noted in a written statement. “The purpose is to ensure there is capacity for everyone in those limited circumstances, and that high users don’t limit capacity for others.”
Verizon Wireless distinguished its practice from what’s known as “throttling,” in which data speeds are reduced for a customer’s entire billing cycle. The company said it only reduces speeds at times of high demand.
“Once you are no longer connected to a site experiencing high demand, your speed will return to normal. This could mean a matter of seconds or hours, depending on your location and time of day,” the company explained in a Q&A.
In mid-2012, Verizon Wireless stopped offering unlimited data plans to its customers. However, existing subcribers with the plans can keep them if they pay full retail price for their device. The company doesn’t disclose the number of customers on its unlimited data plans. But as of the second quarter, more than half of Verizon Wireless’ accounts subscribed to More Everything Plans with shared data.

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Posted by on August 1, 2014 in Uncategorized


Netflix ensnared in Verizon/Level 3 debate

By: Josh Long
Posted on: 07/23/2014

A quarrel ensnaring Netflix, ISPs and the “transit providers” that interconnect with them underscore the complexities in the debate over Net neutrality that is pending before the FCC.

A fundamental question continues to divide some of the most prominent U.S. communications companies: When a subscriber of the nation’s biggest streaming video service has difficulty watching a movie or television show, who is to blame for the connectivity conundrum? An ISP such as Verizon? The transit provider (Level 3, for instance) that interconnects with an ISP? Or Netflix, whose massive U.S. subscriber base now exceeds 36 million?

Depending on the source, the answer differs drastically. The communications industry, at least, agrees on a finer point: that the connectivity problems trace back to where networks between an ISP and transit provider meet.

In a blog written in March, Netflix CEO Reed Hastings observed that a lack of adequate connectivity inhibited Netflix’s performance, “subjecting consumers who pay a lot of money for high-speed Internet to high buffering rates, long wait times and poor video quality.”

More recently on the blogosphere, Level 3 and Verizon have engaged in a war of words over whom is responsible for such degradation in service.

Verizon claimed Level 3 could pay for connections to its network but has chosen to rely on free peering arrangements. According to Verizon, Level 3 is sending far more traffic to Verizon than Verizon is sending to Level 3, creating an imbalance that is not contemplated under the peering agreement.

Rather than purchase needed capacity, Level 3 is insisting Verizon “add capacity to the existing peering link for additional downstream traffic even though the traffic is already wildly out of balance,” wrote David Young, vice president of Verizon federal regulatory affairs, in a blog.

Level 3 has countered that the telecommunications companies could solve the congestion through an easy fix: by connecting more ports on routers.

“Simple. Something we’ve been asking Verizon to do for many, many months, and something other providers regularly do in similar circumstances. But Verizon has refused,” wrote Mark Taylor, Level 3’s VP of content and media. “So Verizon, not Level 3 or Netflix, causes the congestion.”

Level 3 said it’s even willing to buy the port cards, which it says cost a few grand for each 10Gbps card that can support 5,000 or more streams.

Ed McFadden, a Verizon spokesman, offered yet another rebuttal to Level 3. 

“The point is they negotiated this port as a settlement-free port,” he said in a phone interview. “It was designed as settlement-free peering … They are trying to pull a fast one and get something for nothing without negotiating terms.”

What’s more, Verizon argued, Level 3 is a hypocrite. In a dispute years ago, Level 3 said Cogent Communications was sending more traffic to it than Level 3 was sending to Cogent. The imbalance in the traffic exchange caused Level 3 to terminate its peering agreement with Cogent and seek to enter into a commercial agreement with Cogent to deliver the traffic, Verizon pointed out.

S. Derek Turner, research director with the nonpartisan organization Free Press, sided with Level 3 in its current dispute with Verizon.

“Verizon thinks that Level 3 should pay Verizon for the ability to deliver the traffic that Verizon’s customer [requested] in the first place,” Turner said, referencing Netflix subscribers who use Verizon as their ISP. “That is absurd.”

The real culprit, argued Frost & Sullivan analyst Dan Rayburn, is Netflix itself.

Other major content providers on the Internet, such as Google, Microsoft and Yahoo, have long had direct interconnection agreements with ISPs such as Comcast and Verizon, he said.

“Google and Microsoft have direct interconnection agreements. Why is there no other company besides Netflix complaining about this?” Rayburn asked. “Where is Google? Where is Apple? Where is Microsoft? … these are all guys that pay ISPs for access to their network.”

And Netflix has actually joined the interconnection party, albeit perhaps reluctantly. As has been widely reported, Netflix has entered into a direct interconnection agreement with Verizon. The pact will cut out Level 3 as the transit provider of Netflix traffic to Verizon’s network.

In an interview this week with The Wall Street Journal, Netflix CEO Reed Hastings said he met with Verizon CEO Lowell McAdam at a media conference and they agreed to have both companies “work harder to have Netflix faster on Verizon.” Hastings said he anticipated “rapid improvement over the coming months.”

And earlier this year, Netflix reached a direct interconnection agreement with the nation’s largest cable company, Comcast, whose agreement to purchase Time Warner Cable is pending before the FCC.

In a blog written in April, a Netflix executive alleged the pact was inked after “Comcast allowed its links to Internet transit providers like Level3, XO, Cogent and Tata to clog up, slowing delivery of movies and TV shows to Netflix users.”

Such allegations have fueled the Net neutrality debate over protections U.S. regulators should adopt to protect consumers’ access to Internet content such as Netflix.

During a second-quarter earnings interview on Monday with representatives from JP Morgan and MoffettNathanson, Hastings described the conflicts that have occurred between cable networks and distributors, which have led to blackouts on television stations. He seemed to leave open the possibility that a disagreement between Internet providers and content companies could result in a blackout affecting an Internet service like Netflix.

“And we would hate to see ISPs brownout or blackout certain Internet sites while they tried to extract payments,” Hastings said. “That just ruins the consumer experiences idea, that when you sign up for the Internet you can get everywhere.”

Rayburn found Netflix’s argument disingenuous. He said there is no evidence ISPs have ever blacked out an Internet service such as Netflix.

“To say they are forced to pay Comcast or payments would have to be extracted from them is simply not accurate because they [Netflix] used to deliver content without many of those payments,” Rayburn said, pointing out that Netflix used to pay the likes of Level 3 and Akamai to deliver its content over their content delivery networks. 

Netflix now operates its own CDN Network called Open Connect.

“When you enter the market by building your own CDN networks, there are inherent costs associated with paying for that,” Rayburn said. “Some of those costs are paying for direct access to last-mile networks. In some cases, you might be able to exchange traffic for free. In other cases, you might have to pay. But all CDNs do that. All CDNs buy transit. All CDNs do some free peering.”

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Posted by on July 24, 2014 in Uncategorized


Verizon Messages with Integrated Messaging will be coming in September to business customers

Verizon Messages with Integrated Messaging will be coming in September to business customers. Integrated Messaging stores messages in the cloud for up to 90 days allowing a user to synchronize messages across multiple devices, including smartphones, tablets and the web.
Integrated Messaging is not designed for secure transmission or storage of personal healthcare information. Therefore, it must not be used to store or transmit Protected Health Information (PHI) as defined in the Health Insurance Portability & Accountability Act of 1996 and the Health Information Technology for Economic and Clinical Health Act of 2009 and accompanying regulations (collectively “HIPAA”). If your business is a Covered Entity or Business Associate under HIPAA, or if your business otherwise does not want its users to save messages to the cloud, you must block all users on your account by opting out at the link below by 8/24/14. After that date, you can block users per the directions found here.
Users who are blocked from using Integrated Messaging may still use other features of Verizon Messages. If users are not blocked, they will be able to self-provision and use Integrated Messaging.

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Posted by on July 22, 2014 in Uncategorized


POTS lines are Leaving your Business?

Your business is most likely using POTS services in some capacity. “Plain Old Telephone Service” (POTS) refers to the analog, signal-transmission technology in use since the introduction of the public telephone system in the late 19th century.

POTS technology has survived, in part, because of its reliability. In fact, it is the origin of the “five 9s” reliability standard, reflecting the 99.999 percent availability of the dial tone.

But for telcos such as AT&T and Verizon (who own 90% of all USA Copper Infrastructure) POTS has outlived its usefulness. Carriers devote a significant amount of their budgets to maintaining these outdated legacy copper architectures for a rapidly dwindling subscriber base. It’s an unsustainable model that diverts money from new investments in modern broadband services.

AT&T and Verizon are leading the charge to replace POTS networks with an all-IP broadband architecture. AT&T and Verizon have announced intent to transition to all-IP service by 2017..

AT&T and Verizon have announced a 20 percent increase in the monthly recurring charge for business analog POTS lines. The carriers are signaling to business customers that the time has come to make the change to modern, IP-based services.

At the same time, AT&T & Verizon have lifted most of the constraints solution providers like Total Telecom used to face when moving customers from legacy circuits to dedicated, IP-based services. That gives Total Telecom more flexibility to design and provision state-of-the-art solutions at highly competitive rates.

By working with Total Telecom, you gain a vendor-neutral advocate who will help ensure that you get the best deal and work with you through the provisioning and installation process.

We understand that carriers can be difficult to deal with, and will lend our expertise and experience to make the process as smooth as possible.

Carriers transitions to all-IP networks is a positive move that will provide consumers and businesses with a more modern communications infrastructure. The carriers plan to invest $30 billion to significantly expand wireless and wire-line broadband networks to support future IP data growth and deliver new services. Now is the time for businesses to make the move from legacy circuits to IP-based carrier services.

If you are using legacy copper circuits in your business let us review your options and develop a plan that will provide you an optimized cost structure and stable service quality.

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Posted by on June 23, 2014 in Uncategorized


TCPA Case Law and FCC Petitions Update via Technology Law Group



April 29, 2014                                                                             By: Matthew R. Friedman, Esq.


TCPA Case Law and FCC Petitions Update


As discussed in TLG’s October 17, 2013 SNAPUPdate, the Federal Communications Commission’s (“FCC” or “Commission”) latest revisions to its rules implementing the Telephone Consumer Protection Act of 1991 (“TCPA”), which limit certain telephone solicitation practices, went into effect on October 16, 2013.  This SNAPUPdate discusses actions being taken by the FCC to clarify its TCPA rules.


On March 27, 2014, the FCC adopted and released a Declaratory Ruling, which clarified that text-based social networks may send administrative texts confirming consumers’ interest in joining one of the social network’s groups without violating the TCPA when consumers give express consent to participate in such group.  That same day, the FCC issued an order excluding from its TCPA prohibitions alerts by package delivery companies to wireless consumers about their packages, so long as the consumers are not charged and can opt out of future messages.  While these clarifications and actions only address niche issues that apply to only a small subset of entities affected by the TCPA, they – along with specific statements by FCC Commissioner O’Rielly – demonstrate the FCC’s recognition that its TCPA rules are ripe for clarification and that, in certain circumstances, the Commission should consider narrowing the types of calls that are prohibited.


As a part of this process, the FCC has released a number of public notices requesting public comment on various petitions for declaratory ruling, clarification, forbearance, and rulemaking.   One of these petitions – a petition for rulemaking filed by ACA International – requests that the FCC initiate a rulemaking to clarify certain issues, including whether “predictive dialers” categorically qualify as autodialers and whether the FCC should establish a “wrong number” safe harbor for non-telemarketing calls, which have led to confusion and differing interpretations by courts.  The comment cycle established by the FCC’s public notice on this petition has already past, but the petition received significant support, increasing the likelihood that the FCC will take further action on the petition in the near future.


Other public notices issued recently by the FCC have requested and received comment on additional issues that are causing substantial confusion and are ripe for clarification, such as:


–          Whether the TCPA applies to on-demand text services that are: 1) initiated by the consumer and not a telemarketer; 2) isolated, one-time messages sent immediately in response to a consumer’s specific request; and (3) contain only the specific information requested by the consumer?;


–          Whether the TCPA applies to informational, non-telemarketing autodialed and prerecorded calls to wireless numbers for which valid prior express consent has been obtained but which, unbeknownst to the calling party, have subsequently been reassigned from one wireless subscriber to another?; and


–          Whether providing a “doing business as” (d/b/a) name registered with a state corporation commission (or comparable regulatory authority) satisfies the caller identification requirements for artificial or prerecorded voice calls?


One recent petition for declaratory ruling and clarification, filed by TextMe, Inc., is currently open for comment.  The FCC is seeking comment on a number of issues raised in the petition, such as the requests for clarification: 1) of the meaning of the term “capacity” as used in the TCPA’s definition of “automatic telephone dialing system”; and 2) that users of TextMe’s service, instead of TextMe itself, make or send calls or text messages for purposes of the TCPA, or alternatively, that third party consent obtained through an intermediary satisfies the TCPA’s “prior express consent” requirement for calls and texts to wireless numbers.  Comments on these issues are due on May 7, 2014 and reply comments are due onMay 22, 2014.


If you would like a more detailed analysis of these FCC actions and recent actions by courts in interpreting key TCPA provisions, have questions about these or other telemarketing issues, or if we may be of assistance to you, please feel free to contact us.




© 2014 Technology Law Group. Technology Law Group LLC, is a Washington-based law firm specializing in telecommunications, transactional, litigation and regulatory issues.  The attorneys at Technology Law Group can be reached by phone at +1 202 895 1707 and by e-mail at  TLG is dedicated to personal service and to providing high quality legal and consulting services that enable clients meet their business objectives.

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Posted by on April 29, 2014 in Uncategorized


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