Broadband? Re: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]

2004-06-19 Thread Stephen J. Wilcox

On Fri, 18 Jun 2004, Michael Painter wrote:

 A coupla' years ago, the FCC defined Broadband as 200Kbps and above.

Hmm different jurisdiction but Tiscali  NTL seems to think broadband is as low 
as 100Kbps

http://www.tiscali.co.uk/products/broadband/3xfaster.html?code=ZZ-NL-11MR
http://www.ntlhome.co.uk/ntl_internet/broadband.asp?cust=ntlcom_broadbandtextlink

Wrongful trading or say what you like if you make it up as you go along.. ?

Steve



Re: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]

2004-06-19 Thread Steven M. Bellovin

In message [EMAIL PROTECTED], Sean Donela
n writes:

In reality, CALEA is a funding bill; it has very little to do with
technology. 

There's a lot more to it than that -- there's also access without 
involving telco personnel, and possibly the ability to do many more 
wiretaps (have you looked at the capacity requirements lately), but 
funding is certainly a large part of it.  From Section (e) of
http://www4.law.cornell.edu/uscode/18/2518.html :

Any provider of wire or electronic communication service,
landlord, custodian or other person furnishing such facilities
or technical assistance shall be compensated therefor by the
applicant for reasonable expenses incurred in providing such
facilities or assistance. 


--Steve Bellovin, http://www.research.att.com/~smb




Re: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]

2004-06-19 Thread David Lesher

Speaking on Deep Background, the Press Secretary whispered:
 
 
   Any provider of wire or electronic communication service,
   landlord, custodian or other person furnishing such facilities
   or technical assistance shall be compensated therefor by the
   applicant for reasonable expenses incurred in providing such
   facilities or assistance. 
 
 
   --Steve Bellovin, http://www.research.att.com/~smb

The issue, I suspect, is, who defines reasonable here? Is it
like Blue Cross who decides that UCR is 50% of what every MD
charges, and refuses to justify their decision?

I suspect some here have already been there, done that...

Then there is the issue of getting paid in a timely manner,
Prompt Payment Act or not.


-- 
A host is a host from coast to [EMAIL PROTECTED]
 no one will talk to a host that's close[v].(301) 56-LINUX
Unless the host (that isn't close).pob 1433
is busy, hung or dead20915-1433


where is whois.arin.net?

2004-06-19 Thread Jon Lewis

whois.arin.net appears to have been down for at least the past hour or
two.  Anyone know what happened or an ETR for it?

ARIN seems to block ping/traceroute at their border, but www.arin.net is
still usable.  The web frontend to whois at www.arin.net seems
nonfunctional at this time as well.

--
 Jon Lewis   |  I route
 Senior Network Engineer |  therefore you are
 Atlantic Net|
_ http://www.lewis.org/~jlewis/pgp for PGP public key_


ARIN whois server offline ?

2004-06-19 Thread Mike Tancsa

Reachability to the network seems OK, but the server seems to time out.
marble% whois -h whois.arin.net 220.175.8.27
whois: connect(): Operation timed out
marble%
marble% traceroute whois.arin.net
traceroute to whois.arin.net (192.149.252.43), 64 hops max, 44 byte packets
 1  iolite4-fxp2 (199.212.134.10)  0.114 ms  0.105 ms  0.090 ms
 2  tor-hespler-360-mica (64.7.143.42)  3.105 ms  3.365 ms  3.691 ms
 3  h66-59-189-97.gtconnect.net (66.59.189.97)  4.509 ms  4.644 ms  3.871 ms
 4  216.18.63.93 (216.18.63.93)  15.021 ms  14.774 ms  15.044 ms
 5  POS4-0.PEERA-CHCGIL.IP.GROUPTELECOM.NET (66.59.191.86)  14.175 
ms  14.009 ms  14.556 ms
 6  p4-6-2-0.r01.chcgil01.us.bb.verio.net (129.250.10.97)  14.892 
ms  14.477 ms  14.667 ms
 7  p16-2-0-0.r01.chcgil06.us.bb.verio.net (129.250.5.70)  14.680 
ms  14.497 ms  14.477 ms
 8  POS5-2.BR3.CHI2.ALTER.NET (204.255.174.233)  15.266 ms  15.298 
ms  14.956 ms
 9  0.so-5-2-0.XL2.CHI2.ALTER.NET (152.63.68.6)  15.469 ms  14.989 
ms  15.546 ms
10  0.so-0-0-0.TL2.CHI2.ALTER.NET (152.63.68.89)  15.618 ms  15.804 
ms  16.736 ms
11  0.so-3-0-0.TL2.DCA6.ALTER.NET (152.63.19.170)  34.436 ms  34.240 
ms  34.352 ms
12  0.so-7-0-0.CL2.DCA1.ALTER.NET (152.63.32.181)  34.680 ms  35.498 
ms  35.267 ms
13  194.ATM5-0.GW4.DCA1.ALTER.NET (152.63.37.65)  35.113 ms  35.455 
ms  35.452 ms
14  arin-gw2.customer.alter.net (65.207.88.74)  110.848 ms  37.177 
ms  38.229 ms
15  *^C
marble%




Mike Tancsa,  tel +1 519 651 3400
Sentex Communications,[EMAIL PROTECTED]
Providing Internet since 1994www.sentex.net
Cambridge, Ontario Canada www.sentex.net/mike


Re: VoIP a potential haven for terrorists

2004-06-19 Thread Hank Nussbacher
At 04:32 PM 18-06-04 -0500, Stephen Sprunk wrote:
Thus spake Daniel Golding [EMAIL PROTECTED]
 The amount of money the FBI would need to spend to tap a VoIP call is
 highest with the first option, intermediate with the second, and lowest
with
 the last. Some services companies are really salivating for the chance to
 add CALEA hardware to VoIP networks. I won't mention any particular
 companies here, as they have taken a recent beating on this list. Piling
on
 seems rather cruel.
Electronic Surveillance Needs for Carrier-Grade Voice over Packet (CGVoP) 
Service
CALEA Implementation
Federal Bureau of Investigation
Jan 29, 2003
http://www.ictlaw.net/upload/fbivoip.pdf

-Hank


Re: Verisign vs. ICANN

2004-06-19 Thread Michael Froomkin - U.Miami School of Law


Just curious.  How much would it differ from 

http://www.amazon.com/exec/obidos/redirect?tag=icannwatch-20path=tg/detail/-/0262134128/qid%3D1041619276/sr%3D1-1

and

http://www.law.miami.edu/~froomkin/articles/icann.pdf

?

On Fri, 18 Jun 2004, Jonathan Slivko wrote:

 
 Maybe try these guys?
 http://cyber.law.harvard.edu/is99/governance/love.html
 -- Jonathan
 
 On Fri, 18 Jun 2004 15:38:50 -0700, Peter H Salus [EMAIL PROTECTED] wrote:
  
  
  Paul (et al.),
  
  If you can find a willing publisher and an organization
  able to supply some funds, I would be delighted to
  work on a real history of Internet governance since
  RFCs 881-883.
  
  (Most of the funds would be for travel, Xeroxing, etc.)
  
  Peter
  -
  
  Peter H. Salus, Ph.D.   40 IH 35 N  #4A3Austin, TX 78701
 consultant  author
 [EMAIL PROTECTED] +1 512 478-7562
  
 
 
 

-- 
http://www.icannwatch.org   Personal Blog: http://www.discourse.net
A. Michael Froomkin   |Professor of Law|   [EMAIL PROTECTED]
U. Miami School of Law, P.O. Box 248087, Coral Gables, FL 33124 USA
+1 (305) 284-4285  |  +1 (305) 284-6506 (fax)  |  http://www.law.tm
 --It's warm here.--



Re: Verisign vs. ICANN

2004-06-19 Thread Peter H Salus


I will admit to only thinking about this for a few days.

However, it seems to me that the Harvard material is rather
narrowly focussed both on a temporal and on a topical level.
I am an admirer of Froomkin's essays, and have published 
at least one of them (in the distant past when Matrix News
was published).  I haven't really looked at Ruling the Root,
because I was turned off by Dave Crocker's review in IPJ.
But, anyway, as it appeared in 2002, I imagine it contains
little of the recent Verisign/Netsol business.  However,
I should most likely give Mueller more leeway, as I really
liked his telephony book.

Peter


Re: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]

2004-06-19 Thread Sean Donelan

On Sat, 19 Jun 2004, Steven M. Bellovin wrote:
 There's a lot more to it than that -- there's also access without
 involving telco personnel, and possibly the ability to do many more
 wiretaps (have you looked at the capacity requirements lately), but
 funding is certainly a large part of it.  From Section (e) of
 http://www4.law.cornell.edu/uscode/18/2518.html :

   Any provider of wire or electronic communication service,
   landlord, custodian or other person furnishing such facilities
   or technical assistance shall be compensated therefor by the
   applicant for reasonable expenses incurred in providing such
   facilities or assistance.

That is not part of CALEA.

Carriers found to be covered by CALEA must provide certain capabilities
to law enforcement.  For telecommunication equipment, facilities or
services deployed after January 1 1995 the carrier must pay all reasonable
costs to provide the capabilities.

The capacity requirements are interesting.  In some cases, the carrier is
required to have more law enforcement tapping capacity than customer
capacity.  The government sets the capacit requirements without any
regard for the cost of maintaining the capacity.  If there are multiple
competitive carriers in the same area, all of the carriers must have the
same capacity. If you have a single customer in Los Angeles, you must
provide the capacity for at least 1,360 simultaneous interceptions.  How
many SPAN ports do you have?

As I mentioned, the wiretap acts and CALEA are really independent.


RE: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]

2004-06-19 Thread Hannigan, Martin



It's not just a funding bill. It provided $500MM for carrier network
upgrades and for switch software compliance. That fund has been exhausted
from what I have been told. It also clearly defined technical expectations
that carriers and manufacturers have to live up to.

All that being CALEA compliant means is that you are capable, as required, 
to provide service to a legal order i.e. pin register, trap, trace, DTMF
extration, flash hook operations ala three way calling, CALLER ID, and 
voice intercept. There's no secret sauce to CALEA. 

CALEA doesn't expand LEA's authority, it puts them on an even 
playing field with suspected criminals with regards to access.

-M


--
Martin Hannigan (c) 617-388-2663
VeriSign, Inc.  (w) 703-948-7018
Network Engineer IV   Operations  Infrastructure
[EMAIL PROTECTED]



 -Original Message-
 From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Behalf Of
 Sean Donelan
 Sent: Saturday, June 19, 2004 1:49 AM
 To: Stephen Sprunk
 Cc: North American Noise and Off-topic Gripes
 Subject: Re: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]
 
 
 
 On Fri, 18 Jun 2004, Stephen Sprunk wrote:
  I'm told that most CALEA warrants only authorize a pen 
 register, not an
 
 CALEA and wiretaps are independent subjects.  You can have CALEA
 obligations even if you never, ever implement a single wiretap. On
 the other hand you may need to implement many wiretaps even though
 you have no CALEA obligations.
 
 For example, hotels and universities have traditionally been 
 considered
 not to have CALEA obligations.  However, both hotels and 
 universities must
 comply with court orders if law enforcement wants to wiretap 
 one of their
 phones.  Should CALEA be extended to hotels and universities? 
  Are hotels
 and universities broadband Internet providers when they offer Internet
 service in student dorm rooms or hotel rooms?
 
 In reality, CALEA is a funding bill; it has very little to do with
 technology.  Imagine if law enforcement thought DNA testing was too
 expensive, so Congress passes a law requiring all doctors to purchase
 DNA testing equipment and provide free DNA tests to law enforcement.
 DNA is a complicated subject.  Few police officers are qualified to
 analyze DNA. Instead law enforcement pays for professional DNA testing
 when it needs DNA testing.
 
 The FCC comment period has closed.  Everyone had an 
 opportunity to submit
 comments on the topic to the FCC.
 
 Consult your own attorney if you want real legal advice.
 


Re: Verisign vs. ICANN

2004-06-19 Thread Paul Vixie

 Just curious.  How much would it differ from 
 
 http://www.amazon.com/exec/obidos/redirect?tag=icannwatch-20path=tg/detail/-/0262134128/qid%3D1041619276/sr%3D1-1
 
 and
 
 http://www.law.miami.edu/~froomkin/articles/icann.pdf

as i said, it can't be written by an ambulance-chaser or nobody will pay
attention.


Re: Verisign vs. ICANN

2004-06-19 Thread Alexei Roudnev

(read it only today, so sorry if I repeat something).

The technical roots of the problem are: proposed services VIOLATES internet
specification (which is 100% clean - if name do not exist, resolver must
receive negative response). So, technically, there is not any ground for
SiteFinder - vice versa,
now you can add client-level search SiteFinder (MS did it, and it took LOONG
to turn off their dumb 'search' redirect) so allowing
competition between ISP, browsers and so on.

Anyway, please - those who knows history and can read this 'official'
English (little bored) - I am sure, that we can find many inconsistencies in
the filing; it may be reasonable to provide a set of independent _technical_
reviews, showing that ICANN plays a role of technical authority, just do not
allowing to violate a protocols. For the second case (waiting lists), it is
not technical issue, but it is anti-competitional attempt from Verisign as
well. I can ask my Russian folks to review it as well (dr. Platonov, Dimitry
Burkov) but I am not sure, if it is of any use... Anyway, good review,
explaining history and revealing real ICANN role, should be done.

If VeriSign wish to deploy services - they must put thru new RFC first.

PS. I am excited - Vixie as a co-conspirator... Vixie, you can be proud -:).

Alexei Roudnev





 PV Date: 18 Jun 2004 05:58:00 +
 PV From: Paul Vixie

 PV Paul Vixie is an existing provider of competitive services for
 PV registry operations, including providing TLD domain name
hosting
 PV services for ccTLDs and gTLDs, and a competitor of VeriSign
for
 PV new registry operations.  [...]

 I'm missing something.  By what stretch of whose imagination does
 root nameserver operations compete with a registrar?


 Eddy
 --
 EverQuick Internet - http://www.everquick.net/
 A division of Brotsman  Dreger, Inc. - http://www.brotsman.com/
 Bandwidth, consulting, e-commerce, hosting, and network building
 Phone: +1 785 865 5885 Lawrence and [inter]national
 Phone: +1 316 794 8922 Wichita
 _
 DO NOT send mail to the following addresses:
 [EMAIL PROTECTED] -*- [EMAIL PROTECTED] -*- [EMAIL PROTECTED]
 Sending mail to spambait addresses is a great way to get blocked.





RE: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]

2004-06-19 Thread Hannigan, Martin



Sean, the capacity requirements aren't as straightforward as you
are interpreting them. 

If you are a CLEC and you cover a full five state
area in the Northeast, you probably are subject to a county aggregate
of a capacity requirement of 1500. You would then look at your
historicals, refer to the Federal Register for the actual maximum,
and adjust your capacity as required to meet your own historicals 
and averages -- that also should take into consideration other 
RBOCs/CLECs operating in the same five state region as the orders
will more than likely be broken out by access line % per carrier 
unless a single carrier dominates in a traditionally active area.

In New York City and Los Angeles, the two most active areas, there was
a mean average of .035 active electronic/oral intercepts per day.

It's complicated, but noone is subject to a straight 1200+ capacity
required. There were 1,442 NON FISA oral and electronic intercepts in
the entire United States last year.[2]

I have the Federal Register Notice if you want a copy. Let me know.


[1] Federal Register Volume 63, No. 48 - March 12, 1998 NOTICE 12231
[2] 30 APR 2004 Press Release, Admin office of US Courts 

-M







--
Martin Hannigan (c) 617-388-2663
VeriSign, Inc.  (w) 703-948-7018
Network Engineer IV   Operations  Infrastructure
[EMAIL PROTECTED]



 -Original Message-
 From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Behalf Of
 Sean Donelan
 Sent: Saturday, June 19, 2004 4:24 PM
 To: Steven M. Bellovin
 Cc: North American Noise and Off-topic Gripes
 Subject: Re: [Fwd: [IP] Feds: VoIP a potential haven for terrorists] 
 
 
 
 On Sat, 19 Jun 2004, Steven M. Bellovin wrote:
  There's a lot more to it than that -- there's also access without
  involving telco personnel, and possibly the ability to do many more
  wiretaps (have you looked at the capacity requirements lately), but
  funding is certainly a large part of it.  From Section (e) of
  http://www4.law.cornell.edu/uscode/18/2518.html :
 
  Any provider of wire or electronic communication service,
  landlord, custodian or other person furnishing such facilities
  or technical assistance shall be compensated therefor by the
  applicant for reasonable expenses incurred in providing such
  facilities or assistance.
 
 That is not part of CALEA.
 
 Carriers found to be covered by CALEA must provide certain 
 capabilities
 to law enforcement.  For telecommunication equipment, facilities or
 services deployed after January 1 1995 the carrier must pay 
 all reasonable
 costs to provide the capabilities.
 
 The capacity requirements are interesting.  In some cases, 
 the carrier is
 required to have more law enforcement tapping capacity than customer
 capacity.  The government sets the capacit requirements without any
 regard for the cost of maintaining the capacity.  If there 
 are multiple
 competitive carriers in the same area, all of the carriers 
 must have the
 same capacity. If you have a single customer in Los Angeles, you must
 provide the capacity for at least 1,360 simultaneous 
 interceptions.  How
 many SPAN ports do you have?
 
 As I mentioned, the wiretap acts and CALEA are really independent.
 


Re: Verisign vs. ICANN

2004-06-19 Thread Stephen J. Wilcox

Hi Alexei,
 I do not believe there is any technical spec prohibiting this, in fact that DNS 
can use a wildcard at any level is what enables the facility. I think this is a 
non-technical argument.. altho it was demonstrated that owing to the age and 
status of the com/net zones a number of systems are now in operation which make 
assumptions about the response in the event of the domain not existing...

Steve

On Sat, 19 Jun 2004, Alexei Roudnev wrote:

 
 (read it only today, so sorry if I repeat something).
 
 The technical roots of the problem are: proposed services VIOLATES internet
 specification (which is 100% clean - if name do not exist, resolver must
 receive negative response). So, technically, there is not any ground for
 SiteFinder - vice versa,
 now you can add client-level search SiteFinder (MS did it, and it took LOONG
 to turn off their dumb 'search' redirect) so allowing
 competition between ISP, browsers and so on.
 
 Anyway, please - those who knows history and can read this 'official'
 English (little bored) - I am sure, that we can find many inconsistencies in
 the filing; it may be reasonable to provide a set of independent _technical_
 reviews, showing that ICANN plays a role of technical authority, just do not
 allowing to violate a protocols. For the second case (waiting lists), it is
 not technical issue, but it is anti-competitional attempt from Verisign as
 well. I can ask my Russian folks to review it as well (dr. Platonov, Dimitry
 Burkov) but I am not sure, if it is of any use... Anyway, good review,
 explaining history and revealing real ICANN role, should be done.
 
 If VeriSign wish to deploy services - they must put thru new RFC first.
 
 PS. I am excited - Vixie as a co-conspirator... Vixie, you can be proud -:).
 
 Alexei Roudnev
 
 
 
 
 
  PV Date: 18 Jun 2004 05:58:00 +
  PV From: Paul Vixie
 
  PV Paul Vixie is an existing provider of competitive services for
  PV registry operations, including providing TLD domain name
 hosting
  PV services for ccTLDs and gTLDs, and a competitor of VeriSign
 for
  PV new registry operations.  [...]
 
  I'm missing something.  By what stretch of whose imagination does
  root nameserver operations compete with a registrar?
 
 
  Eddy
  --
  EverQuick Internet - http://www.everquick.net/
  A division of Brotsman  Dreger, Inc. - http://www.brotsman.com/
  Bandwidth, consulting, e-commerce, hosting, and network building
  Phone: +1 785 865 5885 Lawrence and [inter]national
  Phone: +1 316 794 8922 Wichita
  _
  DO NOT send mail to the following addresses:
  [EMAIL PROTECTED] -*- [EMAIL PROTECTED] -*- [EMAIL PROTECTED]
  Sending mail to spambait addresses is a great way to get blocked.
 
 
 
 



Re: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]

2004-06-19 Thread Niels Bakker

* [EMAIL PROTECTED] (Jeff Shultz) [Fri 18 Jun 2004, 21:42 CEST]:
 Pay for it? If I remember from CALEA, the providers pay for it
 (and eventually their customers), and as for broadband Internet
 providers... I'm guessing anyone who offers end user customers
 a circuit bigger than 53.333k. 

Pet peeve: broadband isn't a synonym for faster than a modem.
Cable and DSL are broadband due to those technologies using a wide range
of frequencies.  Ethernet is not broadband (but baseband).


-- Niels.


Re: Broadband? Re: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]

2004-06-19 Thread Suresh Ramasubramanian

Stephen J. Wilcox [19/06/04 16:38 +0100]:
 
 On Fri, 18 Jun 2004, Michael Painter wrote:
 
  A coupla' years ago, the FCC defined Broadband as 200Kbps and above.
 
 Hmm different jurisdiction but Tiscali  NTL seems to think broadband is as
 low  as 100Kbps

In India, it is anywhere over 64 Kbps, and the maximum offered over cable /
dsl is currently 512 Kbps.

And of course, anything below several Mbps (or 100 Mbps in the case of FTTH)
is definitely not broadband in Japan :)

srs


RE: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]

2004-06-19 Thread Sean Donelan

On Sat, 19 Jun 2004, Hannigan, Martin wrote:
 Sean, the capacity requirements aren't as straightforward as you
 are interpreting them.

You are absolutely correct, they are not that straightforward.  You
should consult a telecommunications attorney with expertise in this area
for legal advice.

 If you are a CLEC and you cover a full five state
 area in the Northeast, you probably are subject to a county aggregate
 of a capacity requirement of 1500.

No.  The FBI is very clear, if you are a CLEC and cover a full five state
area in the Northeast, you are subject to the CUMULATIVE capacity require
for every county in those five states.

See the www.askcalea.com web site for full details.

 You would then look at your
 historicals, refer to the Federal Register for the actual maximum,
 and adjust your capacity as required to meet your own historicals
 and averages -- that also should take into consideration other
 RBOCs/CLECs operating in the same five state region as the orders
 will more than likely be broken out by access line % per carrier
 unless a single carrier dominates in a traditionally active area.

Although this was suggested by commentators, the FBI explicitely rejected
that.  The theory was the Mafia would then buy phone service from some
smaller carrier without enough capacity to monitor all their calls.

   Individual carriers must provide sufficient capacity so that law
   enforcement has the ability to simultaneously conduct any number of
   call content interceptions, pen registers, and trap and trace devices,
   not to exceed the estimated actual and maximum requirements (which are
   based on historical interception activity) at any location within a
   county.
Appendix A of the Final Notice of Capacity (63 Fed Reg 12217,
12238)

However, there is an exception, no single switch is required to support
more than 386 simultaneous pen registers and trap and trace devices or
75 simultaneous call content interceptions.  What is a switch?

http://www.askcalea.com/docs/capsecg.pdf

Individual carriers can take the legal gamble and use other network
deployment strtegies, such as making assumptions of how many pen
registers, trap and trace and intercepts will occur on their network
versus a competitors network.  Assume 95% of the court orders will go
to your competitors, so you only need to provide 5% of the capacity
in the county. But you can't escape the penalties by depending on your
competitor's capacity.

   The obligation to satisfy the capacity requirements in a
   cost-effective andreasonable manner is the responsibility
   of all carriers that operate within a given geographic area.

How often do you see all the competitors in an industry sit down in a
room and decide how they will divide up the costs and establish pricing?


 It's complicated, but noone is subject to a straight 1200+ capacity
 required. There were 1,442 NON FISA oral and electronic intercepts in
 the entire United States last year.[2]

Actually, they are expected to provide far more than that.  As you know,
the Wiretap report does not include pen registers.  There is no public
source for the number of pen registers in the US, but some industry
sources estimate it at 70,000 to 75,000 per year.



RE: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]

2004-06-19 Thread Hannigan, Martin




 -Original Message-
 From: Sean Donelan [mailto:[EMAIL PROTECTED]
 Sent: Saturday, June 19, 2004 8:39 PM
 To: Hannigan, Martin
 Cc: North American Noise and Off-topic Gripes
 Subject: RE: [Fwd: [IP] Feds: VoIP a potential haven for terrorists] 
 
 
 On Sat, 19 Jun 2004, Hannigan, Martin wrote:
  Sean, the capacity requirements aren't as straightforward as you
  are interpreting them.
 
 You are absolutely correct, they are not that straightforward.  You
 should consult a telecommunications attorney with expertise 
 in this area
 for legal advice.


It's a law that has technical requirements co mingled so 
you need both lawyers and engineers. 


  If you are a CLEC and you cover a full five state
  area in the Northeast, you probably are subject to a county 
 aggregate
  of a capacity requirement of 1500.
 
 No.  The FBI is very clear, if you are a CLEC and cover a 
 full five state
 area in the Northeast, you are subject to the CUMULATIVE 
 capacity require
 for every county in those five states.
 
 See the www.askcalea.com web site for full details.

I have. And I continue to disagree. 

[snip] 

Individual carriers must provide sufficient capacity so that law
enforcement has the ability to simultaneously conduct any number of
call content interceptions, pen registers, and trap and 
 trace devices,
not to exceed the estimated actual and maximum 
 requirements (which are
based on historical interception activity) at any location within a
county.
   Appendix A of the Final Notice of Capacity (63 Fed Reg 12217,
   12238)


Which is what I defined. Sufficient capacity with capability to increase
if needed.

 
 However, there is an exception, no single switch is required 
 to support
 more than 386 simultaneous pen registers and trap and trace devices or
 75 simultaneous call content interceptions.  What is a switch?

That's what the federal register notice I pointed you at said. And in 
come cases, a single switch can carry a five state area. Softswitch 
comes to mind.

 
 http://www.askcalea.com/docs/capsecg.pdf
 
 Individual carriers can take the legal gamble and use other network
 deployment strtegies, such as making assumptions of how many pen
 registers, trap and trace and intercepts will occur on their network
 versus a competitors network.  Assume 95% of the court orders will go
 to your competitors, so you only need to provide 5% of the capacity
 in the county. But you can't escape the penalties by depending on your
 competitor's capacity.

You can't service a competitors legal orders so I'm not sure
what you're getting at.

You're almost saying every carrier should have one DS0 for every 
single dialup user.

 
The obligation to satisfy the capacity requirements in a
cost-effective andreasonable manner is the responsibility
of all carriers that operate within a given geographic area.
 
 How often do you see all the competitors in an industry sit down in a
 room and decide how they will divide up the costs and 
 establish pricing?

What has pricing intercepts have to do with concurrent intercepts? CLECS
are not going to make money servicing legal orders. I doubt RBOCS make
money doing it either. 

  It's complicated, but noone is subject to a straight 1200+ capacity
  required. There were 1,442 NON FISA oral and electronic 
 intercepts in
  the entire United States last year.[2]
 
 Actually, they are expected to provide far more than that.  

They're expected to have the capability. So let me rephrase. They
are subject. The actual and historic are relevant.

 As you know,
 the Wiretap report does not include pen registers.  There is no public
 source for the number of pen registers in the US, but some industry
 sources estimate it at 70,000 to 75,000 per year.

I'll check on the pen-register comment. 

You keep saying talk to a lawyer, but quoting legalese. Are you an attorney?
Not being smarmy. Just curious.

Hypothetical.

How many bankrupt CLEC's do you expect to see this year complying
with CALEA and providing, as an example, a fully loaded 1200 concurrent
session infrastructure in a  100 a year historically survielled area? 


N0TE: I am speaking from experience on the LEC side, nowhere else.



Re: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]

2004-06-19 Thread Stephen Sprunk

Thus spake Niels Bakker [EMAIL PROTECTED]
 * [EMAIL PROTECTED] (Jeff Shultz) [Fri 18 Jun 2004, 21:42 CEST]:
  Pay for it? If I remember from CALEA, the providers pay for it
  (and eventually their customers), and as for broadband Internet
  providers... I'm guessing anyone who offers end user customers
  a circuit bigger than 53.333k.

 Pet peeve: broadband isn't a synonym for faster than a modem.
 Cable and DSL are broadband due to those technologies using a wide range
 of frequencies.  Ethernet is not broadband (but baseband).

Congress can define a word (in the US legal context) to mean anything they
want; whether such has any relation to its technical definition is
irrelevant.  I doubt they care about the technology used to deliver IP
service, only the capabilities and typical users; defining broadband as
any circuit 56kbps or above would likely suffice for their intent,
regardless of how incorrect it is.

However, I fail to see how broadband or link speeds in general even matter
in this context; what matters is whether the link is of sufficient speed for
VoIP to be feasible, in which case anything from 9.6kbps cellular to WiFi,
from ARCnet to OC192/10GE might qualify -- or might not, if IP isn't running
over it.

S

Stephen Sprunk  Those people who think they know everything
CCIE #3723 are a great annoyance to those of us who do.
K5SSS --Isaac Asimov



Justice Dept: Wiretaps should apply to Net calls

2004-06-19 Thread Fergie (Paul Ferguson)


The battle rages on, apparently. The more things change, the more
things stay the same, it would seem. ;-)

This is from this past Wednesday --I'm surprised that I somehow
overlooked it and only just now saw this.

 http://www.cnn.com/2004/TECH/internet/06/16/telecoms.voip.reut/index.html

FYI,

- ferg

--
Fergie, a.k.a. Paul Ferguson
 Engineering Architecture for the Internet
 [EMAIL PROTECTED]



Re: Justice Dept: Wiretaps should apply to Net calls

2004-06-19 Thread Fergie (Paul Ferguson)


I guess the Akami hoopla caused me to overlook it, but one more thing:

I always did like John McCain. His quote: Since it is a breakthrough
technology, there's going to be a lot of china broken.

Shake, rattle, roll. Same as it ever was.

- ferg


-- Fergie (Paul Ferguson) [EMAIL PROTECTED] wrote:


The battle rages on, apparently. The more things change, the more
things stay the same, it would seem. ;-)

This is from this past Wednesday --I'm surprised that I somehow
overlooked it and only just now saw this.

 http://www.cnn.com/2004/TECH/internet/06/16/telecoms.voip.reut/index.html

FYI,

- ferg

--
Fergie, a.k.a. Paul Ferguson
 Engineering Architecture for the Internet
 [EMAIL PROTECTED]



real-time DDoS help?

2004-06-19 Thread Charles Sprickman

Howdy,

Is there any place where people with experience dealing with DDoS attacks
hang out?  I'm getting very little assistance from my upstream beyond
call whomever is in charge of each IP attacking and make them stop, and
even though we null route the destination IP being attacked, this traffic
will be billed.

I've got a nice snippet of flows, so I can mostly see where everything is
coming from, and it's obvious what the target is, but my
flow-stat/flow-report skills are pretty weak.

Oddly, in eight years of working for smallish ISPs I've never been hit
very hard, believe it or not.  Is the response from my upstream typical?
I was expecting a bit more cooperation rather than them seeing as this as
an opportunity to bill me for lots of traffic.

Thanks,

Charles

--
Charles Sprickman
[EMAIL PROTECTED]



Re: real-time DDoS help?

2004-06-19 Thread Laurence F. Sheldon, Jr.
Charles Sprickman wrote:
even though we null route the destination IP being attacked, this traffic
will be billed.



Re: real-time DDoS help?

2004-06-19 Thread Jonathan Slivko

Hmmm.
Maybe if NANOG had irc.nanog.org, maybe that might be something to
consider - a real-time network of communication for network operators
to deal with issues, etc.

-- Jonathan

On Sat, 19 Jun 2004 22:04:36 -0400 (EDT), Charles Sprickman
[EMAIL PROTECTED] wrote:
 
 
 Howdy,
 
 Is there any place where people with experience dealing with DDoS attacks
 hang out?  I'm getting very little assistance from my upstream beyond
 call whomever is in charge of each IP attacking and make them stop, and
 even though we null route the destination IP being attacked, this traffic
 will be billed.
 
 I've got a nice snippet of flows, so I can mostly see where everything is
 coming from, and it's obvious what the target is, but my
 flow-stat/flow-report skills are pretty weak.
 
 Oddly, in eight years of working for smallish ISPs I've never been hit
 very hard, believe it or not.  Is the response from my upstream typical?
 I was expecting a bit more cooperation rather than them seeing as this as
 an opportunity to bill me for lots of traffic.
 
 Thanks,
 
 Charles
 
 --
 Charles Sprickman
 [EMAIL PROTECTED]
 
 




-- 
  Jonathan M. Slivko - [EMAIL PROTECTED]
Linux: The Choice for the GNU Generation
 - http://www.linux.org/ -

Don't fear the penguin.
 .^.
 /V\
   /(   )\
^^-^^
  He's here to help.


RE: [Fwd: [IP] Feds: VoIP a potential haven for terrorists]

2004-06-19 Thread Sean Donelan

On Sat, 19 Jun 2004, Cade,Marilyn S - LGCRP wrote:
 Jim  Dempsey's testimony at Senator Sununu's hearing is very
 interesting, and very educational on these issues.

 CALEA was not written for the IP world.

When CALEA was being written, the Internet, IP and information services
were all debated.

 But, the facts are that IP service providers comply with law
 enforcement's requests. IF more legal vehicles are needed, beyond what
 law enforcement has today, then Congress should make that determination.

CALEA doesn't reduce law enforcement's wiretap authority or the
obligation for carriers to provide technical assistance under Title
III or ECPA or other statutes. Law enforcement has been conducting
wiretaps for decades prior to the passage of CALEA.  Law enforcement
has been using Title III and ECPA to tap e-mail, internet communications,
pagers, etc for years.  The FBI even demostrated its Canivore DSC1000
box at NANOG in Washington DC a few years ago.

A SPAN port could satisfy an ISP's obligations under TitleIII/ECPA, but
not satisfy CALEA.


Re: real-time DDoS help?

2004-06-19 Thread Suresh Ramasubramanian

On Sat, 19 Jun 2004, Jonathan Slivko wrote:

 Maybe if NANOG had irc.nanog.org, maybe that might be something to
 consider - a real-time network of communication for network operators
 to deal with issues, etc.

There's always http://puck.nether.net/mailman/listinfo/nsp-security

-- 
srs (postmaster|suresh)@outblaze.com // gpg : EDEDEFB9
manager, outblaze.com security and antispam operations



Re: real-time DDoS help?

2004-06-19 Thread Charles Sprickman

On Sun, 20 Jun 2004, Suresh Ramasubramanian wrote:

 On Sat, 19 Jun 2004, Jonathan Slivko wrote:

  Maybe if NANOG had irc.nanog.org, maybe that might be something to
  consider - a real-time network of communication for network operators
  to deal with issues, etc.

 There's always http://puck.nether.net/mailman/listinfo/nsp-security

I can tell you right off AS8059 doesn't meet the requirements.  I'd gladly
respond to any reports of attacks from them, but I don't think you'd ever
see any.

Basement multihomers unite.

Charles

 --
 srs (postmaster|suresh)@outblaze.com // gpg : EDEDEFB9
 manager, outblaze.com security and antispam operations



Re: real-time DDoS help?

2004-06-19 Thread Rubens Kuhl Jr.

 Is there any place where people with experience dealing with DDoS attacks
 hang out?  I'm getting very little assistance from my upstream beyond
 call whomever is in charge of each IP attacking and make them stop, and
 even though we null route the destination IP being attacked, this traffic
 will be billed.

It seems that you should look somewhere else for your next bandwidth
contract...

 I've got a nice snippet of flows, so I can mostly see where everything is
 coming from, and it's obvious what the target is, but my
 flow-stat/flow-report skills are pretty weak.

Fake or real source IPs ? TCP SYNs, ICMPs, UDPs ?



Rubens



S.2281 Hearing (was: Justice Dept: Wiretaps...)

2004-06-19 Thread John Curran

The particular hearing that set this all off is the Senate Commerce 
Committee's review of S.2281 (VoIP Regulatory Freedom Act) that
took place on last Wednesday, and in general, the hearing has a 
higher content to noise ratio than the resulting press coverage.

The agenda and statements of the participants can be found here:
http://commerce.senate.gov/hearings/witnesslist.cfm?id=1230

S.2281 takes the middle of the road position in areas such as lawful 
intercept, universal service fund, and E911.   At a high-level, those 
VoIP services which offer PSTN interconnection (and thereby look like 
traditional phone service in terms of capabilities) under S.2281 pick up 
the same regulatory requirements.  Those VoIP services which do not 
interconnect are continue to be treated as information services and 
therefore excluded from these requirements.

With respect to facilitating lawful intercept, the opening comments of 
Ms. Laura Parsky (Deputy Assistant Attorney General, US DoJ) and 
James Dempsey, Executive Director of the Center for Democracy and
Technology (CDT) are quite informative.   The DoJ view is that S.2281 
is not enough, and any service using switching or transport should
facilitate lawful intercept.  This position has the advantage of clarity,
but there are lots of communications (chat/IM/etc) that are going to
hard to decode and make readily available as needed.  It is also an
expansion of the current framework of CALEA, which specifically sets
aside information services including email and messaging.

The CDT position is interesting, noting that CALEA came into being to
address concerns that law enforcement wouldn't be able to readily
pursue lawful intercept orders without directly mandating call intercept 
capacity in each service provider.   This works fine with one application
(voice) but that replicating this model for data services makes no sense 
given the diversity of Internet communications applications.  CDT proposes
that if law enforcement really needs better intercept capabilities for data
applications, it should work on its own decode capabilities or get service
bureaus to handle that same, and that the Internet service providers 
shouldn't have to do anything other supply a copy of the relevant users
raw packet stream...

Despite the angst on both sides, requiring just those VoIP services 
which look like traditional phone service (due to PSTN interconnection) 
as requiring ready lawful intercept capacity will result in the equivalent 
situation as we have today with CALEA, and appears to be the likely 
outcome of the debate.

Apologies for length,
/John


Re: real-time DDoS help?

2004-06-19 Thread Mike Lewinski
Charles Sprickman wrote:
Is there any place where people with experience dealing with DDoS attacks
hang out?  I'm getting very little assistance from my upstream beyond
call whomever is in charge of each IP attacking and make them stop, and
even though we null route the destination IP being attacked, this traffic
will be billed.
While I hate the blame the victim mentality in general, I'd guess that 
 up to half of all the packet floods we've experienced were aimed at 
compromised client boxes that were hosting illegitimate services. If 
your victim has no idea why they're being attacked, I'd scrutinize the 
target host very carefully.

Or if your victim is a shell host who's probably got some skript kiddie 
engaged in channel wars, it will likely save you a lot of time and grief 
to just dump that client. Is losing one worth sacrificing the rest?

Unless you know exactly why you're being attacked and are willing to 
suffer these consequences indefinitely, you will do yourself a big favor 
by looking at the victim to see why the attack is occurring and removing 
the target from your network.


Re: real-time DDoS help?

2004-06-19 Thread Christopher L. Morrow


On Sat, 19 Jun 2004, Charles Sprickman wrote:


 On Sun, 20 Jun 2004, Suresh Ramasubramanian wrote:

  On Sat, 19 Jun 2004, Jonathan Slivko wrote:
 
   Maybe if NANOG had irc.nanog.org, maybe that might be something to
   consider - a real-time network of communication for network operators
   to deal with issues, etc.
 
  There's always http://puck.nether.net/mailman/listinfo/nsp-security

 I can tell you right off AS8059 doesn't meet the requirements.  I'd gladly
 respond to any reports of attacks from them, but I don't think you'd ever
 see any.

which of your 2 upstreams isn't helping out? I'm fairly certain both
providers have security groups, and do mitigate attacks for customers on a
regular basis. Perhaps you are not getting in touch with the correct
customer service folks? We often have this issue ;(


 Basement multihomers unite.


hurray!


Re: real-time DDoS help?

2004-06-19 Thread Charles Sprickman

On Sun, 20 Jun 2004, Christopher L. Morrow wrote:

 which of your 2 upstreams isn't helping out? I'm fairly certain both
 providers have security groups, and do mitigate attacks for customers on a
 regular basis. Perhaps you are not getting in touch with the correct
 customer service folks? We often have this issue ;(

I don't want to go too much into it, but HE.net, once they supplied me
with the proper channels immediately null-routed the IP, hurrah!  I'm
waiting on the answer as to whether we get billed or not for this traffic.

The other upstream whom I won't name is through a reseller.  That wasn't
necessarily our first choice, but their own sales department told us to go
with a reseller as they were not interested in two cabinets and a 100Mb
handoff, so that's what we did.

I'm hoping their reseller is just misunderstanding something here.  For a
long time he kept telling me this is illegal, you need to contact the
source networks and make them stop it, so I'm guessing DDoS is not a
subject he's intimately familiar with (nor am I, but I understand the
mechanics of it, and I don't think that I could contact each source in my
lifetime).

Thanks to everyone for your input.  To answer some other questions, the
box under attack is not a client box, but it is the main webserver for the
ISP's own site and ~user sites.  It's also has shell accounts, but since
I've been here I've not seen one complaint about any of our users.  Most
seem to not know much beyond how to use pine.  I think most of our
heavy-duty irc users are using windows clients at home, any irc tools on
the server are horribly dated.  Not saying it's not a possibility, but I
do personally watch abuse@ and I've not seen anyone complain about the
box.

Thanks again,

Charles

 
  Basement multihomers unite.
 

 hurray!



Re: real-time DDoS help?

2004-06-19 Thread Suresh Ramasubramanian
Charles Sprickman wrote:
I don't want to go too much into it, but HE.net, once they supplied me
with the proper channels immediately null-routed the IP, hurrah!  I'm
waiting on the answer as to whether we get billed or not for this traffic.
One other way to get a hold of clueful contacts, especially if you have 
your own AS, is the inoc-dba project - http://www.pch.net/inoc-dba/

	srs


Re: real-time DDoS help?

2004-06-19 Thread Bubba Parker
I could host and/or setup the irc server if anyone is interested.

On Sun, Jun 20, 2004 at 03:23:06AM +, Christopher L. Morrow wrote:
 
 
 On Sat, 19 Jun 2004, Charles Sprickman wrote:
 
 
  On Sun, 20 Jun 2004, Suresh Ramasubramanian wrote:
 
   On Sat, 19 Jun 2004, Jonathan Slivko wrote:
  
Maybe if NANOG had irc.nanog.org, maybe that might be something to
consider - a real-time network of communication for network operators
to deal with issues, etc.
  
   There's always http://puck.nether.net/mailman/listinfo/nsp-security
 
  I can tell you right off AS8059 doesn't meet the requirements.  I'd gladly
  respond to any reports of attacks from them, but I don't think you'd ever
  see any.
 
 which of your 2 upstreams isn't helping out? I'm fairly certain both
 providers have security groups, and do mitigate attacks for customers on a
 regular basis. Perhaps you are not getting in touch with the correct
 customer service folks? We often have this issue ;(
 
 
  Basement multihomers unite.
 
 
 hurray!

-- 
Bubba Parker
[EMAIL PROTECTED]
CityNet LLC
http://www.citynetinfo.com/


pgprb5nAZjPzK.pgp
Description: PGP signature


Re: S.2281 Hearing (was: Justice Dept: Wiretaps...)

2004-06-19 Thread Sean Donelan

On Sat, 19 Jun 2004, John Curran wrote:
 S.2281 takes the middle of the road position in areas such as lawful
 intercept, universal service fund, and E911.   At a high-level, those
 VoIP services which offer PSTN interconnection (and thereby look like
 traditional phone service in terms of capabilities) under S.2281 pick up
 the same regulatory requirements.

It sounds good, if you assume there will always be a PSTN.  But its
like defining the Internet in terms of connecting to the ARPANET.

What about Nextel's phone-to-phone talk feature which doesn't touch
the PSTN?  What about carriers who offer Free on-net calling, which
doesn't connect to the PSTN and off-net calling to customers on the
PSTN or other carriers.

Will the bad guys follow the law, and only conduct their criminal
activities over services connected to the PSTN?

 With respect to facilitating lawful intercept, the opening comments of
 Ms. Laura Parsky (Deputy Assistant Attorney General, US DoJ) and
 James Dempsey, Executive Director of the Center for Democracy and
 Technology (CDT) are quite informative.   The DoJ view is that S.2281
 is not enough, and any service using switching or transport should
 facilitate lawful intercept.  This position has the advantage of clarity,
 but there are lots of communications (chat/IM/etc) that are going to
 hard to decode and make readily available as needed.  It is also an
 expansion of the current framework of CALEA, which specifically sets
 aside information services including email and messaging.

Its a return to DoJ's pre-CALEA position.  Its almost a word-for-word
replay of the debates in 1992/1993 and the Digital Telephony proposals.

http://www.eff.org/Privacy/CALEA/digtel92_old_bill.draft

Briefing Report to the Subcommittee on Telecommunications and Finance,
Committee on Energy and Commerce of the House of Representatives by the
United States General Accounting Office (GAO/IMTEC-92-68BR, July 1992),

  The FBI now has the technical ability required to wiretap certain
  technologies, such as analog voice communications carried over public
  networks' copper wire. However, since 1986, the FBI has become
  increasingly aware of the potential loss of wiretapping capability due
  to the rapid deployment of new technologies, such as cellular and
  integrated voice and data services, and the emergence of new
  technologies such as Personal Communication Services, satellites, and
  Personal Communication Numbers.

  There are six current or imminent telecommunications technologies that
  the FBI needs to be able to wiretap. These are (1) analog and digital
  using copper wire transport, (2) analog and digital using fiber optic
  transport, (3) Integrated Services Digital Network (ISDN), (4) Private
  Branch Exchange (PBX), (5) broadband, and (6) cellular. There are also
  three future technologies for which wiretapping capabilities need to be
  addressed: (1) satellite switches, (2) Personal Communication Services
  (PCS), and (3) Personal Communication Number (PCN). Further, the FBI
  needs to be able to wiretap any special features, such as call
  forwarding or electronic mail.



Re: S.2281 Hearing (was: Justice Dept: Wiretaps...)

2004-06-19 Thread John Curran

At 12:06 AM -0400 6/20/04, Sean Donelan wrote:
On Sat, 19 Jun 2004, John Curran wrote:
 S.2281 takes the middle of the road position in areas such as lawful
 intercept, universal service fund, and E911.   At a high-level, those
 VoIP services which offer PSTN interconnection (and thereby look like
 traditional phone service in terms of capabilities) under S.2281 pick up
 the same regulatory requirements.

It sounds good, if you assume there will always be a PSTN.  But its
like defining the Internet in terms of connecting to the ARPANET.

Correct.  It's a workable interim measure to continue today's practice
while the edge network is transitioning to VoIP.  It does not address
the more colorful long-term situation that law enforcement will be in
shortly with abundant, ad-hoc, encrypted p2p communications.

What about Nextel's phone-to-phone talk feature which doesn't touch
the PSTN?  What about carriers who offer Free on-net calling, which
doesn't connect to the PSTN and off-net calling to customers on the
PSTN or other carriers.

Will the bad guys follow the law, and only conduct their criminal
activities over services connected to the PSTN?

Sean - what alternative position do you propose?
/John


Re: S.2281 Hearing (was: Justice Dept: Wiretaps...)

2004-06-19 Thread Henry Linneweh

if the pro-ported bad guys are so swift why would they
use anything packaged anyway?

They have engineers and scientific minds in their
ranks that understand devices, boards and the likes
and could simply create their own data centers and
simply use new protocols to communicate over the
public
lines and not one person would know the difference,
all
the laws in the world would not stop them, since US
law
doesn't apply to anyone but US citizens and most other
nations could care less about what we imagine,
contrive and go into hysterics about.

-Henry

--- John Curran [EMAIL PROTECTED] wrote:
 
 At 12:06 AM -0400 6/20/04, Sean Donelan wrote:
 On Sat, 19 Jun 2004, John Curran wrote:
  S.2281 takes the middle of the road position in
 areas such as lawful
  intercept, universal service fund, and E911.   At
 a high-level, those
  VoIP services which offer PSTN interconnection
 (and thereby look like
  traditional phone service in terms of
 capabilities) under S.2281 pick up
  the same regulatory requirements.
 
 It sounds good, if you assume there will always be
 a PSTN.  But its
 like defining the Internet in terms of connecting
 to the ARPANET.
 
 Correct.  It's a workable interim measure to
 continue today's practice
 while the edge network is transitioning to VoIP.  It
 does not address
 the more colorful long-term situation that law
 enforcement will be in
 shortly with abundant, ad-hoc, encrypted p2p
 communications.
 
 What about Nextel's phone-to-phone talk feature
 which doesn't touch
 the PSTN?  What about carriers who offer Free
 on-net calling, which
 doesn't connect to the PSTN and off-net calling to
 customers on the
 PSTN or other carriers.
 
 Will the bad guys follow the law, and only conduct
 their criminal
 activities over services connected to the PSTN?
 
 Sean - what alternative position do you propose?
 /John