I once again hate to press this point further, but what exactly is meant by 
"your customer uses" and "another party"?

I don't mean this from a place of needless pedantry: there's a legitimate 
question here around what the limits of this concept are. Does the customer 
have to be human, and do the calls placed have to be manually dialed or 
automatically dialed on behalf of a human caller or agent of some sort? How 
"other" does the "another party" have to be?

For example, where would a (legitimate) outbound dialing service, such as an 
appointment reminder or other business automation service, fall on this 
spectrum? Since the beneficiaries of such an offering are third parties, 
presumably it is safe to say that the service provider is providing an 
originating voice service to a "customer" who "uses" it to make calls to 
"another party" not themselves. 

But what about companies who are themselves internal consumers of such a 
service, i.e. have an in-house telephony apparatus of some sort? 

What if the outbound calling is to members of one's own organisation and not to 
other parties, but on their personal mobiles? 

I suppose I was never quite sure where the delineation for "interconnected VoIP 
provider" or "VoIP service provider" falls. I have a commonsensical idea of 
what that is, and in most cases whether a company is inside or outside this 
bracket is fairly self-evident. However, for purposes of this regulation, that 
may not be enough.

-- Alex

> On May 31, 2023, at 4:03 PM, Mary Lou Carey <[email protected]> wrote:
> 
> Anytime your customer uses a DID or Telephone Number to make a phone call to 
> another party, that is an originating voice service. If the network you use / 
> lease operates via a VOIP (Voice Over Internet Protocol) switch then you must 
> have a STIR / SHAKEN certificate. If the underlying carrier you use has a 
> direct trunking connection with the local ILEC / RBOC then you're most likely 
> delivering via a PSTN connection.
> 
> MARY LOU CAREY
> BackUP Telecom Consulting
> Office: 615-791-9969
> Cell: 615-796-1111
> 
> On 2023-05-31 02:47 PM, Alex Balashov wrote:
>>> On May 31, 2023, at 3:45 PM, Mary Lou Carey <[email protected]> 
>>> wrote:
>>> Any carrier that provides originating VOIP or a combination of originating 
>>> VOIP / PSTN /  Wireless VOICE services needs to get its own certificate
>> I hate to press this point further, but must: what exactly are
>> originating VoIP "services"?

-- 
Alex Balashov
Principal Consultant
Evariste Systems LLC
Web: https://evaristesys.com
Tel: +1-706-510-6800

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