Reply Comment Filing by Numeracle, Inc. in the matter of Reply Comments Re: for WC Docket No. 20-174, WC Docket No. 17-192, CC Docket No. 95-155 on Aug 13, 2020

Dear Ms. Dortch:

On June 11, 2020, iconectiv, Inc. filed an aggressive petition to the Commission accusing it of being a victim of an “anachronistic accident of history." Also, on June 11, 2020, the world’s economy was crashing, yet again, at all-time lows and the United States hit its two millionth coronavirus case. As a CEO during this time, I was focused on supporting our clients by extending payment forgiveness, helping them retain funding for payroll, and launching the Critical Calls Registry. Oddly, iconectiv was filing a “that’s not fair” complaint because they did not get the chance to own another thing. No regard or care to the impact and disruption a competitive bid process would have on the Resp Orgs, which are mostly small businesses. No concern for the challenges the Commission was facing to address the rapid economic impact to consumers on access to communications. It’s as though the rest of the world didn’t matter or just wasn’t happening and all iconectiv could focus on was having the chance to solely control yet another administrative, database or directory responsibility.

The Commission requested comment on the petition to implement a competitive procurement process to select the Toll Free Numbering Administrator. Somos, Inc. successfully fulfills the role, therefore the answer is no. A competitive bid process is a means to an end. It is to identify the right entity who will create an environment where its customers’ needs are adequately served via pricing, services and support. Many comments filed speak to the current low cost, high quality of service and unprecedented support provided by Somos serving as a testament to the accidental success of history benefiting the Commission and the Resp Orgs.

Numeracle is not a Resp Org. Comments regarding the low cost, transparency, choice, support and education provided by Somos, Inc. are plenty and from reliable sources. My comments below are related to Somos as a servant of the industry as experienced by Numeracle. Although Numeracle operates in the same industry as iconecitv, Inc., there are no experiences to which I could attest on their contributions of serving.

This reply comment is to attest to the collaboration, innovation, and witness of how Somos serves the Resp Orgs and those supporting them. Numeracle provides number registry services to RespOrgs. Somos reached out to Numeracle at the behest of Somos’ customers to learn how to solve the new challenges their customers were facing. This level of collaboration especially in this industry is rare and benefits the marketplace beyond a competitive bid process.

Should the Commission proceed with a bid process, Numeracle requests the Commission consider a detailed Notice of Inquiry so the Commission and interested parties can fully vet all possible effects of severely disrupting the toll-free industry. A choice to disrupt small businesses already experiencing disruption on a scale unimaginable should be taken with great care and concern.