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Control Number: 36164

Item Number : 48

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SOAH DOCKET NO. 473-09-2277

PUCT DOCKET NO. 36164

APPLICATION OF TRUE WIRELESS

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BEFORE THE t.

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LLC FOR DESIGNATION AS AN

ELIGIBLE TELECOMMUNICATIONS

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PUBLIC UTILITY CO^!IMIS:qfOrg

CARRIER AND ELIGIBLE

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TELECOMMUNICATIONS PROVIDER

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OF TEXAS

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SUPPLEMENTAL RESPONSE TO STAFF'S THIRD SET OF REQ^JEST^F,O g4

INFORMATION

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TO THE HONORABLE COMMISSION:

COMES NOW, TRUE WIRELESS, LLC (Applicant) and responds to Staff's Third Set of

Data Requests as follows. Applicant stipulates that these responses can be treated by all parties as if they were filed under oath.

3-7 Provide a detailed explanation as to who owns the switch that True Wireless is leasing. In addition, provide the physical address as to where the switch is located, the CLLI code for that specific switch and the point codes for the switch.

ANSWER: Call Universal owns the switch that True Wireless is leasing. Also, there are

no point codes. Call Universal is simply leasing switching to True Wireless. True Wireless is transmitting, routing, and then from the Call Universal switch, terminating calls via the Excel carrier on a SIP basis. Interconnectivity document between the True Wireless leased Call Universal switch and Excel (carrier) is attached. SEE

ATTACHMENT C filed with the original response to the Third Set of RFIs.

A CLLI code is an identifier for a fixed facility such as a switch, room or building in the context of SS7 signaling. Likewise, point codes are identifiers used in the context of SS7 signaling. CLLI codes and point codes are exclusive identifiers for switches that use SS7 signaling or are a part of the SS7 network. The switch in question does not require SS7 signaling and is not a part of the SS7 network because the services provided do not require SS7. Therefore, there is no CLLI code or point codes for the TRUE Wireless/Call Universal switch. This switch is collocated and interconnected with a Tex Link

Communications switch located at 13601 Preston Suite 22C Dallas, Texas 75240. The CLLI code for that Tex Link switch is DLLSTXBKDSO.

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3-7 Provide a list of all trunks going to/from that switch (including type of facility - i.e. PRI, DS 1, DS3, OC3, etc.) and what type of traffic is being carried on each of those trunks, and to whom those trunks terminate/originate. Provide a copy of all ASP's for these trunks.

ANSWER: DA and OS Trunks (directory assistance and operator services) have been contracted with NCIC and KGB operator services. Calls to directory assistance and operator services will be sent to these companies from the TrueWireless\Call Universal switch by means of voice over I.P. or by dialing local DID numbers assigned to True Wireless by the respective companies. There will not be any physical trunking connectivity between True Wireless and the DA and OS providers.

All local and IXC traffic will be terminated using Inter Exchange Carriers (IXC). This traffic will be sent to IXCs by means of voice over I.P. This also does not require physical trunking between True Wireless and the respective IXCs that will be used to terminate traffic. As stated previously, True Wireless has contracted with Excel Communications which is an IXC to terminate all local and long distance traffic terminating from the True Wireless\Call Universal switch by means of voice over I.P.

This virtual trunking is also known as Session Initiation Protocol (SIP). SIP is a signalling protocol, widely used for setting up and tearing

down multimedia communication sessions such as voice and video calls over the Internet. SIP Trunking is the de facto standard for VoIP applications. A SIP Trunk is primarily a concurrent call that is routed over the IP backbone of a carrier using VoIP technology. SIP Trunks are used in conjunction with an IP-PBX and are thought of as replacements for traditional PRI or analog circuits. The popularity of SIP Trunks is due primarily to the cost savings of SIP along with the

increased reliabili as backed by the SLAs of SIP Trunk Providers.

SIP Trunking is simply a single conduit pipeline for multimedia elements (voice, video and data). SIP Trunking reduces or eliminates the need for PSTN media gateways as well as reduce or eliminate the need for narrow-band voice circuits (www.voip-news.com/art/l0i.html). SIP Trunking provides a smart and cost effective solution to customers by eliminating the need to purchase additional

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equipment, such as managed media gateway devices to interface between IP voice to the PSTN.

Prepared: Mark Foster

Sponsoring Witnesses: Pravin Kurishingal, Byron Young

3-13 (A)Provide a detailed description of who performs the local number portability function. If this is being performed by the True Wireless leased switch as described in 3-7 above, (B)then provide a call flow diagram. (C)Provide the LRN assigned to the leased switch in 3-7 above.

ANSWER: (A)The local number portability function is performed by the carriers which are PCM (PC Management) and\or Immix Wireless on behalf of Telspace. Telspace provides this functionality to True Wireless on behalf of Telspace and its partners\service providers\carriers PCM and Immix Wireless that are a part of the Telspace network.

(B) CALL FLOW DIAGRAM-- This function is not being provided by the True Wireless switch. Therefor no attached call flow diagram is provided. (LNP functionality is being provided by PC Management and\or Immix Wirelss on behalf of Telspace.)

(C) There is no LRN assigned to the leased switch in 3-7 above. (A LOCAL ROUTING NUMBER or "LRN" is exclusively used in the case of local

switches, most commonly used in conjunction with CLECS or ILECS. The Call

Universal switching facility leased by True Wireless is not a local switch. Therefore the True Wireless\Call Universal switch does not have, nor does it require an assigned LOCAL ROUTING NUMBER for performing the tasks required by True Wireless.) True Wireless obtains DID numbers from Telspace. Telspace obtains said DID numbers from Level 3 on a resold basis. True Wireless is awating a response from Telspace.

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Respectfully submitted, Mark Foster

Attorney at Law 702 Rio Grande Street Austin, TX 78701 (512) 708-8700 (512) 697-0058/fax

By:

Mark Foster

Texas Bar No. 07293850 markgmfo sterlaw. com

Attorney for TRUE Wireless, LLC

CERTIFICATE OF SERVICE

I hereby certify that a true and complete copy of the above and foregoing document was served on the following individual on this the 24`h day of March, 2009. Mr. Patrick H. Peters III

Attorney - Legal Division

Public Utility Commission of Texas 1701 N. Congress Avenue

Austin, TX 78701

Via E-mail: patrick.peters@puc.state.tx.us

^*^ ^

Mark Foster

References

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