855 Number Allocation

Toll-Free 855 allocations by “Randomized Round Robin”

Vanity International, a consultancy and small RespOrg, hereby submits comments in response to the Commission’s Public Notice; DA 10-1604 in CC Docket 95-155 released August 27, 2010.

 We do not support “rationing” of 855 numbers per se, as we believe rationing will not have the desired effect; “to ensure that all parties have equal access to the new 855 toll free numbers.”  Further, it’s clear from a majority of the comments submitted thus far that this approach is being fostered by a write-in campaign promoted by just one RespOrg without MGI access, TollFreeNumbers.Com.

 Indeed, fixed daily “rationing” would disadvantage major carriers like AT&T, Verizon, Sprint, Qwest, and others constrained to 500 or 1,000 per entity—regardless of size or customer base (Does AT&T not have “real customers,” too, that “need to build their businesses?”). Further, a fixed ration of great numbers is just as appealing as an unlimited amount, so why would any of the participants dial back their automation?

Rather, we propose that the FCC direct DSMI to adopt an off-line allocation process called, “Randomizing Round Robin,” as this permits each RespOrg to submit as many numbers as they need while ensuring that all participants have “equal access.”

The problem

The Introduction of 855 numbers will allow some of the most sought-after numbers to be acquired; numbers, for example, that map to vanity overlays like 855-Flowers, 855-Doctors, 855-Dentist, as well as easy to dial numbers like 855-555-5555 and others. There will, therefore, be a momentary spike in demand as the best 5-12% of the 855 numbers are reserved immediately upon the code opening. Beyond that, there’s no reason to assume the weekly demand will be any greater then it had been before the launch.

The fact is that a code opening is anomaly. “Rationing” is not a viable solution, as it does nothing to avert those with most powerful connections from getting first pick of the best available numbers – and overwhelming the SMS/800 system with real-time requests. Indeed, “rationing” will simply result in daily system jams for as many days as it takes to satisfy demand.

Those with slower or manual connections would still get “leftovers,” only now on a daily or weekly basis rather than en masse at the release.  The fact is that RespOrg do not have “equal access” speeds, so there is no dynamic way to ensure “equal access” to 855 toll free numbers.

Rather, we propose an allocation method recently used in the “land rush” of .info/.biz Internet domains called a, “randomized round robin,” which naturally averts the need for rationing.  In effect, this approach emulates a “rationing” of one request per RespOrg and truly levels the playing field for all participants.

The Process

In a Randomized Round Robin (RRR), each RespOrg submits a single, comprehensive list of all requested 855 numbers in digital form – as many 855 requests as desired -- by a date and time certain, say, by noon, Oct 2, 2010. From the standpoint of the RespOrg, this is exactly what they must be prepared to do anyway, so there’s no need to extend the timeframe.

Once submitted, the Help Desk would then “randomize” the order of each digital list. This is key, and ensures that submitted numbers are not processed in any order of preference and that the best numbers are not all reserved in the first round.

The round robin order is also randomized, ensuring that each RespOrg has an equal change of drawing first, second, and so forth. All participating RespOrgs get one 855 request in each round, from their now randomized request list.  This initial, random order is then maintained round after round.

As the RRR proceeds, each unreserved 855 request becomes a reservation. However, when an 855 request comes up that is already reserved, that RespOrg loses that round and gets no reservation—just as though they had requested a reserved number in real time that was already taken. The round robin continues until all lists are exhausted, ultimately processing the tail end of the longest submitted list.

This is all done off-line and the “success” list is batched by the Help Desk and placed in “Reserve” status for the requesting RespOrg.

Key Advantages are:

  • All RespOrgs gain “equal access,” regardless of technology, bandwidth, programming, or size.
  • Randomizing whom, “comes first” preserves, “First come, first serve”.
  • The process naturally limits reservations to one each round, so there’s no need for “rationing,” yet all demand is satisfied en masse.
  • RespOrgs can submit all desired numbers by the deadline and not staff over the weekend of October 2, 2010.
  • If the largest or smallest RespOrgs somehow feel disadvantaged by this attempt at “equal access,” it is essential to note that “real customers” are in no way disadvantaged; they can place their order with any RespOrg they like.
  • Lists are randomizes so that there is no advantage to seeding the best selections first. Great numbers will still be available in later rounds!
  • The draw order is randomized so all RespOrgs have any equal chance becoming the first to draw.
  • The Help Desk can conduct the RRR off-line with a spreadsheet or simple database, then simply reserve the successful list of numbers with a batch submission, prior the actual code opening.
  • Code opens with virtually all competitive reservations in place.
  • Opening system load is minimized – and access priority is not at issue -- but should still take place on a weekend.

Key Contraints are:

  • One request per primary RespOrg per round, regardless of size.
  • Sub-RespOrgs must feed through the primary RespOrg.
  • Primary RespOrgs put in place after September 1, 2010 – or even earlier -- cannot be allowed to participate in the RRR, or RespOrgs will have an incentive to add RespOrgs to increase their success rates.
  • If a RRR is adopted, there is no need for additional notice or to move the date of submission. However, the actual code opening will be pushed back a week or two.
  • There is no need or rationale to include a trademark holders “sunrise” period for 855 numbers as they did with the .info/.biz domains.
  • All Help Desk randomization should be done in supervised teams to ensure the integrity of the process.

 

 

Reply Comments

Toll-Free 855 allocations by “Randomized Round Robin”

Vanity International, a consultancy and small RespOrg, hereby submits reply comments in response to the Commission’s Public Notice; DA 10-1604 in CC Docket 95-155 released August 27, 2010.

In our reply comments we wish to address the illusion of “equal access” by rationing, the futility of ration size, and why off-line allocation uniquely addresses the anomaly of a code opening.

The Illusion of “Equal Access” by Rationing

There seems to be a common misconception among those who submitted comments that a daily cap on toll free numbers, or even a replication set-aside, will somehow reduce computer load[1] or prevent inadvertent “log offs” and “lock outs” during the critical moments when the 855 code is opened. There’s no basis for this belief.

The only certain effect of “rationing” is that it will reduce the duration of the computer jam that will most surely occur upon the 855 code opening. The intent of an automated reservation system is to be first and that incentive endures regardless of whether there are 100, 1000, or 10000 permitted reservations. No one will “dial back[2]” their automation because of a cap or reduced availability, as suggested.

Indeed, massive automation is used every night against just a few dozen toll free numbers[3] as they go spare. It only takes a few minutes, but any RespOrg who has ever tried knows they have zero chance of manually reserving numbers in the face of these automated systems.

An actual sample from the SMS/800 history file below is representative of an automated reservation. Toll free number 866-227-9277 was reserved on Aug 20, 2010 in 95 milliseconds, as it went from “spare” status at 11:01 28.810 seconds to “reserved” status at 11:01 28.905:

Time                        Status              RespOrg

23:01:28.0 810         S(pare)            AT X01

23:01:28.0 905         R(eserve)         AB C01

No one on earth can type fast enough to compete with these automated reservation systems, and anyone without them – or without a hired agent – is hopelessly disadvantaged.

The fact is that here will be “unfair and unequal access,” as the Direct Marketing Association put it, if allocation is done by computer war – rationing or not; fixed or scaled. It just doesn’t matter. Those with the automation will get their allocation within seconds. The rest – those with manual access or small-scale automation-- will get “leftovers.”

The only advantage to a fixed or scaled daily “ration” will that the automated systems will be cut off at some point, so they won’t get all the numbers; just the best ones. Yet, let there be no illusion of fairness or “equal access.”[4] The edict of, “First come, First served,” given today’s realities means, “Big come, Big Served.”

The Futility of Ration Size

It is essential to note that the vast majority of the comments supporting a daily “anti-hording cap” -- 93% as of 5PM, September 10, 2010 -- are a result of a write-in campaign[5] by just one ambitious, yet misinformed, RespOrg operator who lacks any meaningful automation. Most of these commenters parrot Mr. Bill Quimby’s support for a daily cap on toll free numbers to, “prevent a few vanity number businesses from hoarding a huge amount of the 855 numbers that real customers need to build their businesses.”

Mr. Quimby is promoting the idea of a fixed daily ration of 500 or 1,000 regardless of customer base which, for example, awards him with exactly the same number of  daily reservations as AT&T – a company almost 100 times his size, based on active toll-free numbers. This proposal flies in the face of fairness and appears to be self-serving.

Further, Mr. Quimby seeks to disadvantage RespOrgs who share a common administrator, by “rationing” on a per-administator basis rather than a per-RepOrg basis. Such a restriction would pre-judge and penalize entities for how they manage their operations.

The FCC should also note that forming a primary RespOrg requires certification and several thousand dollars, so there is always some business rationale for doing so. Sub-RespOrg, however, can be formed by a signature and should not be given any weight.

Finally, Mr. Quimby’s premise that the FCC must urgently act to prevent “horders” from depriving “real customers,” is just a calculated distraction from a RespOrg operator who publically equates call centers with drug dealers.[6]

Clearly, the use of inflammatory language, the small business hardship plea, and the write-in campaign are all designed to justify his version of a rationing plan. Since when are call centers not “real customers?” Do larger RespOrgs like Verizon, Sprint, and AT&T no longer represent “real customers?”

The real reason we need a code opening plan was brought to light by the Toll Free Number Coalition in their “Petition for Emergency Relief and Expedited Action.” The Coalition clearly described the unjust experiences various RespOrgs had during the 877 and 866 codes opened.  We, too, studied the aftermath of those code openings and agree with their background assessment.

When they described how past code openings were, "confused and disorderly, with many RespOrgs 'locked out' of the SMS database for an extended period of time while one or more others reserved at least 10,000 numbers," those 10,000 reservations were not made by some “vanity number business,” but by AT&T – the largest RespOrg and co-owner of the SMS/800 database.

Using the SMS/800 database for this code opening – regardless of cap size – will result in the same chaos as there is no practical difference to setting a cap of 100, 1000, or 10000.  In fact, even if a cap were set at just one toll free 855 number per day, everyone would use their massive automation to get the one they want.

This great axiom foretells what we can expect on Oct 2, 2010 is:

 

To err is human- but to really foul things up requires a computer."

-Farmers' Almanac

 

Yet, even Mr. Quimby acknowledges that, “the smaller the daily limit in the beginning, the more even the allocation of the most desirable numbers would be.” We agree with this one point, and that’s why were proposed an allocation of one per RespOrg by using an off-line, Randomized Round Robin – achieving a level of fairness and “equal access” that would take “forever” if attempted on-line using daily rations and our current system. 

Why Off-line Allocation Uniquely Addresses the Anomaly of a Code Opening

The essence of this problem is the use of the SMS/800 database -- designed for everyday load[7] -- under the stress and anomaly of a code opening. We can safely predict the results will be “riddled with irregularities,” as they were in the past.

Yet, we see no reason to take, “appropriate steps to help assure that the [SMS/800} system is ready to handle the expected activity.”[8]  Rather, why use it?

It’s not the SMS/800 system design or RespOrgs with automatic reservation systems that will cause this predictable outcome, but the anomaly of a code opening. Three unique factors mark this one-time event.

  • Brut Force is of the essence: During the daily drop-to-spare, automation is not the only factor; intelligence also plays a key roles, i.e. knowing which numbers go spare on what nights, for example. During a code opening, however, specialized knowledge is unnecessary – everyone knows what’s available -- so the brut force of automation is the only factor.
  • There are millions of available numbers, not just the few hundred that go spare nightly.
  • Massive RespOrgs who don’t bother with the nightly drop-to-spare, always participate in the code opening.

It makes no sense to upgrade the SMS/800 system for a one-time event when better results can be achieved with a spreadsheet in a matter of hours. With competitive reservations in place, SMS/800 system load will be close to normal upon the code opening and both the system design and automation systems will no longer be of issue.

A Randomized Round Robin[9] (RRR) is a proven process that exactly solves the unequal access problem. During each round, every RespOrg has an opportunity to reserve one number – regardless of access or automation. In addition:

  • Every number from every RespOrg is processed and all known demand is satisfied;
  • The code opens under close to normal load, as all known competitive reservations are already in place; and
  • There’s no technical reason to delay the submissions beyond the scheduled date of October 2, 2010.

Our industry was build upon the edict of, “First come, first serve.” Yet, there’s no inherent requirement that the massive demand of this code opening be satisfied live in the SMS/800 database when a RRR can truly provide “equal access” in an orderly process.

The fact is that computers are just tools, and there is no doubt that SMS/800 was not built for the massive job of a code opening –  a fact known both by admission and previous experience. So rather than permit “unfair and unequal access” to rule the day, we recommend that DSMI allocate competitive 855 numbers off-line using RRR.

Randomized Round Robin works by mathematics; it cannot fail.

 

Loren Stocker

Vanity International

www.TollFreeMarket.com

 

The following is a true and correct screen shot of Mr. Quimby’s "1-800 Drug Dealer Close" as of 5PM, September 10, 2010:

 

[1] From the Updated Comments of Bill Quimby: “All of the [computer] capacity issues will be eliminated or greatly reduced with rationing.” From the Toll Free Number Coalition, Comment (3): “The Coalition also respectfully submits that the restoration of the right of first refusal early reservation plan previously used for the 888 code release would greatly lessen the demands on the code opening system, thus allowing more orderly access to the vast majority of the 855 numbers remaining.”  

[2] Randomized Round Robin proposal, Vanity International.

[3] Each night at 11pm Central, the SMS/800 system spares toll free numbers at the end of their 4-month aging period.

[4] The FCC’s stated intent in Commission’s Public Notice of August 27, 2010 is to, “ensure that all parties have equal access to the new 855 toll free numbers.”

[5] 65 of the 72 comments submitted as of noon, September 10, 2010 appear to be a direct result of Mr. Quimby’s write-in campaign, which began on Aug 30, 2010.

[6] From “1-800 Drug Dealer Close,” Mr. Quimby says, “I just talked to someone that said an organization offering to rent a good 800 number offered 6 months free to test it. This might sound attractive to some people but it’s kind of like an 800 number Drug Dealer offering free samples.” The screen shot is also attached, should Mr. Quimby take down this article to prevent viewing.

[7] In the comment by DSMI, Mr. Wade states, “Like all well designed and properly sized systems, the SMS/800 system is designed to handle the normal day-to-day volume of traffic presented to it by its user population, with sufficient extra capacity to handle the expected peaks that occur from time to time.”

[8] Toll Free Number Coalition in their “Petition for Emergency Relief and Expedited Action.”

[9] See September 3, 2010 filing by Vanity International, “Randomized Round Robin.”