IdHp.net – Style And Gadget

Federal Communications Commission  DA 09-2210
October 9, 2009

Richard S. Whitt, Esq.
Washington Telecom and Media Counsel
Google Inc.
1101 New York Avenue, NW, Second Floor
Washington, DC 20005
RE: Google Voice Calling Restrictions
Dear Mr. Whitt:
Recent reports indicate that Google’s Google Voice service restricts calling from consumers to certain rural communities.1  In light of pending Commission proceedings regarding concerns about so called “access stimulation,”2 the Commission’s prohibition on call blocking by carriers,3 as well as the Commission’s interest in ensuring that “broadband networks are widely deployed, open, affordable, and accessible to all consumers,”4 we are interested in gathering facts that can provide a more complete understanding of this situation.
To that end, please provide answers to the following questions by close of
business on Wednesday, October 28, 2009.
1. We understand that Google Voice offers a number of different
functionalities, including: (a) the ability to have calls to a Google Voice
telephone number forwarded to designated telephone numbers; (b) the

1 See Google’s New phone Service Poses Questions for Regulators, Wall Street Journal (Sept. 18, 2009); The intellectual contradiction of Google Voice, Financial Times (Sept. 22, 2009); Google Says Apple Rejected Google Voice Application in July, Communications Daily (Sept. 21, 2009).
2 Establishing Just and Reasonable Rates for Local Exchange Carriers, WC Docket No. 07-135, Notice of Proposed Rulemaking, 22 FCC Rcd 17989 (2007).
3 Establishing Just and Reasonable Rates for Local Exchange Carriers; Call Blocking by Carriers, WC Docket No. 07-135, Declaratory Ruling and Order, 22 FCC Rcd 11629 (2007).
4 Appropriate Framework for Broadband Access to the Internet over Wireline Facilities; Review of Regulatory Requirements for Incumbent LEC Broadband Telecommunications Services; Computer III Further Remand Proceedings: Bell Operating Company Provision of Enhanced Services; 1998 Biennial Regulatory Review — Review of Computer III and ONA Safeguards and Requirements; Inquiry Concerning High-Speed Access to the Internet Over Cable and Other Facilities; Internet Over Cable Declaratory Ruling; Appropriate Regulatory Treatment for Broadband Access to the Internet Over Cable Facilities, CC Docket Nos. 02-33, 01-337, 98-10, 95-20, GN Docket No. 00-185, CS Docket No. 02-52, Policy Statement, 20 FCC Rcd 14986 (2005) (Internet Policy Statement).
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, D.C. 20554
2
ability to place outgoing calls from the Google Voice website; (c) the
ability to place outgoing calls from the Google Voice mobile site; and (d)
the ability to place outgoing calls by calling your own Google number and
signing into the Google voicemail system.
(i)  For each of these functionalities, and any other functionalities
that allow Google Voice users to place calls, please describe how
the Google Voice call is routed and whether calls to particular
telephone numbers are restricted.  For each functionality for which
calls to particular telephone numbers are restricted, please describe
the technological means by which those restrictions are
implemented.
(ii)  How does Google inform Google Voice users about any
restrictions in the numbers to which calls can be placed using
Google Voice?
(iii)  To what extent are each of these Google Voice functionalities
offered for free?  To what extent, if any, does Google charge for
any of these services?  Does Google intend to charge at some point
for the service? How does Google currently pay for the service?
2. Please explain specifically what is meant by “invitation-only.”5 How
many users of Google Voice are there at this time?  Are there any plans to offer Google Voice on other than an invitation-only basis?
3 How does Google believe its various Google Voice services fit within the
statutory classifications in the Communications Act of 1934, as amended
(the Act) and the Commission’s regulatory classifications (e.g.,
interconnected VoIP)?6 Do you believe its “invitation-only”
subscribership affects the classification of Google Voice in any way?  If
so, please explain.  Does the Google Voice service compete with any
services classified as “telecommunications services” under the Act?  Is
Google Voice a reseller of “telecommunications services?”  Please explain
your answers.
4 How does Google identify the telephone numbers to which it restricts
calls?  Does it restrict calls to individual telephone numbers, or to
particular exchanges or NPA-NXXs?  Why does Google Voice restrict
calls to these numbers?
5 Does Google contract with third parties to obtain inputs for its Google
Voice service, such as access to telephone numbers, transmission of
telephone calls, and interconnection with local telephone networks?
Please provide the names of such third parties.