Skype & e911

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Tom Keating
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Skype & e911

Skype is trying to get an exemption from the newly mandated FCC e911 rules. If you think about it, how would Skype provide accurate e911 since it is a nomadic VoIP service? Many Skype users use Skype in their home, their office, on the road in hotels, etc. So how would Skype be able to detect where you are at any given time? The only thing they can do is figure out your IP address - which at best only gives you a geographic region - not enough location information to send to the local emergency response team. The text within the current FCC rules "places obligations on interconnected VoIP service providers that are similar to traditional telephone providers in that they enable customers to receive calls from and terminate calls to the public switched telephone network (PSTN)." In order words, it mandates that any VoIP service provider providing PSTN access must provide e911 access, including Skype. Russell Shaw has some interesting comments on both Skype & AT&T fighting the e911 rules you should check out..

Also, EnterpriseVoIPplanet has an excellent summary of Skype & e911: has ... learned that on May 9, 2005, Skype Communications, S.A. met with FCC Chairman Martin's chief of staff Daniel Gonzalez and Michelle Carey, Martin's legal advisor, and separately with Commissioner Copps and Jessica Rosenworcel, Copps'a legal advisor, on the topic of 911/e911 requirements to IP-enabled services. The details of that discussion are included in an ex parte letter sent by Skype's legal counsel, Henry Goldberg, the text of which was also obtained by

"Skype is concerned that overbroad application of 911/e911 requirements will impede rather than facilitate the provision of emergency services," Skype's letter states. "Skype does not have access to reliable real-time location information for its users—Skype may determine a user's IP address, but IP addresses (in addition to being vulnerable to spoofing) offer only the most general sense of a user's location. "

Another part of the FCC e911 order reads, "Although the customer must provide the location information, the VoIP provider must provide the customer a means of updating this information, whether he or she is at home or away from home," which gives me an idea.

Perhaps as part of the Skype login process the Skype software client can require the user to provide their current location. While this would add an extra step to the login process, it would eliminate liability from Skype by putting the onus on the customer to enter in that information. If Skype users hate this extra login step (which I am sure they will), maybe Skype could offer a check box that remembers the last location and uses that by default. So only the first time login requires that information and then it is remembered. If users change their location and forget to update that information and then dial 911 from another location, well, then that's their own fault.

Of course, everyone will probably check the box to remember the location and then complain to the FCC that Skype should automatically provide e911 without manually updating. Someone will die as a result of a user not updating their location and they will sue Skype causing Skype millions in legal fees. Of course, the FCC order as it stands now does not require "automatic" updating of e911 information - it states, "Finally, the Commission stated its intention to adopt, in a future order, an advanced E911 solution that includes a method for determining the customer’s location without the customer having to self report this information."

So Skype is at least "shielded" from having to automatically (and magically) figure out a person's location via their IP address - for now... But according to the FCC's own words, that will change in a future order. How Skype and other 'nomadic' VoIP providers will magically figure out a person's location only knowing the IP address is beyond me. The FCC just does not get technology in my opinion. They will have to provide some exemptions or they will kill nomadic VoIP, which is one of its most powerful and attractive features.

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