8x8 2012 Annual Report Download - page 22

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The FCC may require providers like us to comply with regulations related to how we present bills to customers. The
adoption of such obligations may require us to revise our bills and may increase our costs of providing service which
could either result in price increases or reduce our profitability.
The FCC released an order with respect to preventing the placement of unauthorized charges on consumers’ telephone bills, a
practice referred to in the industry as "cramming." While the FCC did not extend regulations applicable to providers of
traditional telephone services to interconnected VoIP providers to prevent “cramming” and other “Truth-in-Billing”
requirements, the FCC indicated that it would continue to monitor the marketplace and may extend such obligation in the
future. The proceeding remains open. We cannot predict the outcome of this proceeding, nor can we predict its potential
impact on our business at this time. These events could increase our expenses, which would have an adverse effect on our
operating results.
The FCC adopted rules concerning disabilities access requirements that may expand disabilities access requirements to
additional services we offer.
In October, 2010, the "Twenty-First Century Communications and Video Accessibility Act" was signed into law. In October,
2011, the FCC adopted an order implementing the new accessibility requirements as well as released a Notice of Proposed
Rulemaking concerning certain, additional, discrete issues. We cannot predict whether we will be subject to additional
accessibility requirements or whether any of our service offerings that are not currently subject to disabilities access
requirements will be subject to such obligations. These events could increase our expenses, which would have an adverse effect
on our operating results.
There may be risks associated with our ability to comply with the requirements of federal law enforcement agencies.
The FCC requires all interconnected VoIP providers to comply with the Communications Assistance for Law Enforcement Act
(CALEA). The FCC allows VoIP providers to comply with CALEA through the use of a solution provided by a trusted third
party with the ability to extract call content and call-identifying information from a VoIP provider’ s network. While the FCC
permits companies like us to use the services provided by these third parties to comply with CALEA, we are ultimately
responsible for ensuring the timely delivery of call content and call-identifying information to law enforcement, and for
protecting subscriber privacy.
We selected a partner to work with us to develop a solution for CALEA compliant lawful interception of communications and,
as of May 14, 2007, we had installed this solution in our network operations and data centers, but had not yet completed
certification testing of all required intercept capabilities of this equipment. We completed formal CALEA compliance testing
with this partner in March 2009 and currently, our tested CALEA solution is fully deployed in our network. However, we
could be subject to an enforcement action by the FCC or law enforcement agencies for any delays related to meeting, or if we
fail to comply with, any current or future CALEA obligations.
There may be risks associated with our ability to comply with requirements of the Telecommunications Relay Service.
The FCC requires providers of interconnected VoIP services to comply with certain regulations pertaining to people with
disabilities and to contribute to the Telecommunications Relay Services, or TRS, fund. We are also required to offer 7-1-1
abbreviated dialing for access to relay services. As of April 5, 2008, we have implemented a 7-1-1 system which routes such
calls to the appropriate relay center based upon the customer’ s assigned telephone number. We may be subject to enforcement
actions including, but not limited to, fines, cease and desist orders, or other penalties if the FCC believes we are not compliant
with these new disability requirements.
There may be risks associated with our ability to comply with the requirements of federal and other regulations related
to Customer Proprietary Network Information (“CPNI”).
The FCC requires providers of interconnected VoIP services to comply with its customer proprietary network information, or
CPNI, rules. CPNI includes information such as the phone numbers called by a consumer, the frequency, duration, and timing
of such calls, and any services/features purchased by the consumer, such as call waiting, call forwarding, and caller ID, in
addition to other information that may appear on a consumer’ s bill.