VI. OSP COLLECT CALLS COULD NOT BE VALIDATED WITH CALL RECORDS FROM AT&T OR VERIZON
For every call that takes place, telecommunications providers record certain data about that call in order to appropriately bill the telephone customer for the call.72 LECs, like AT&T and Verizon, maintain Automatic Messaging Accounting ("AMA") call records, also known as switch records. These AMA records contain detailed information about the call, including but not limited to the connect date and time, disconnect time, originating and terminating telephone numbers, dialed number, elapsed minutes for the call, and Carrier Identification Code (CIC).73 LECs automatically capture this data at their end office switch,74 which is a telephone central office switch that connects directly to the customer and where most of the call recording and billing are performed.75 Accordingly, each and every collect call for which OSP billed its "customers" should have an associated AMA call record from AT&T or Verizon.
However, as discussed below, from a random sample of 384 billing "records" submitted by OSP, representing a 95% confidence level, neither AT&T nor Verizon could validate with their own AMA records the existence of the OSP collect calls.76
A. No Matching AMA Records for "Records" Submitted by OSP
For all of its billings, OSP provided to its billing agents supposed billing "records" known as Exchange Message Interface ("EMI") records, which if legitimate would show that a customer authorized or received a collect call serviced by OSP.77 EMI records adhere to certain technical standards, and are generally used by third party vendors, like OSP, for billing purposes.78 With LEC billing, third party vendors provide their billing agents with EMI records so the billing agents know what to bill and collect on behalf of the third party vendor. In turn, the billing agents forward the EMI records to the appropriate LEC to bill and collect the third party charges directly from their customers.
A legitimate EMI record should have a matching AMA call record and should also contain data similar to what is included in AMA call records.79
As explained below, Staff randomly selected a sample of 384 of OSP's EMI "records" it submitted to billing agent TBR and attempted to validate them with AT&T and Verizon AMA call records. However, neither AT&T nor Verizon could match OSP's EMI "records" with their own AMA call records. From this, Staff infers that none of OSP's EMI "records" were valid. Thus, Staff alleges that OSP fabricated all of its EMI "records" and fraudulently billed customers for collect calls that never took place.
1. AT&T's AMA Records
As part of its investigation, Staff requested from TBR all OSP-related EMI "records" that served as TBR's basis for billing on behalf of OSP between
October 9, 2008 and August 31, 2009.80 TBR provided 252,694 EMI "records."81 From these 252,694 "records," Staff randomly selected a sample of 384 "records," which represents a 95% confidence level. Of the 384 sample EMI "records," 293 were associated with telephone numbers of AT&T's customers; the other 91 were associated with Verizon customers' telephone numbers.
Using as a search criteria the date and time of each call identified in the 293 EMI "records," AT&T could not find one matching AMA call record.82 In addition, AT&T analyzed the top 100 originating telephone numbers with high volumes from the total 252,694 EMI "records" and similarly could not find one matching AMA call record for these either.83 In some cases, AT&T found that the telephone numbers associated with these EMI "records" were not in service at the time of the purported collect calls.84
With regard to the thirteen complainants who provided declarations to Staff, AT&T could not locate any validating AMA call records for twelve of the complainants.85 As for the remaining complainant, AT&T could not locate any billing statement for this person, which means that this complainant may not have been an AT&T customer.86
2. Verizon's AMA Records
With respect to the 91 EMI "records" associated with Verizon customers, Verizon could not locate any completely matching AMA record.87 Verizon attempted to match its terminating usage data for these calls and conducted searches using three different sets of matching criteria. In the first search, Verizon attempted to match four attributes (to number, date, time, and from number), but did not locate any matching AMA call records. In the second search, Verizon attempted to match three attributes (to number, date, and time), but did not find any matching AMA call records. Finally, in the third search, Verizon attempted to match two attributes (to number and date) and found 72 matching AMA call records; however, the "time" and "from number" attributes substantially differed from OSP's EMI information, even with Verizon adjusting the time zone based on the originating point of the call.88
Staff further requested that Verizon recheck the 91 Verizon telephone numbers utilizing OSP's access numbers (877-487-9455 and 866-697-2198) as the originating numbers, in the event that these numbers may have been signaled as the originating point rather than the "from number" in OSP's EMI "records." However, Verizon found nothing different from its earlier searches.89
Moreover, since the "connect time" in the OSP EMI "records" is based on Pacific Time, they should match the local switch time in any of Verizon's terminating AMA call records.90 However, in yet another search attempting to match three attributes (date, time, and terminating number), Verizon still could not locate any matching AMA records.91
72 Ibid. at 17-18.
73 Ibid. at 18.
74 A switch is defined as: In communications systems, a mechanical, electro-mechanical, or electronic device for making, breaking, or changing the connections in or among circuits. 2. Deprecated synonym for central office, switching center. 3. In communications systems, to transfer a connection from one circuit to another. 4. In a computer program, a conditional instruction and a flag that is interrogated by the instruction. 5. In a computer program, a parameter that controls branching and that is bound, prior to the branch point being reached. Synonym switchpoint. 6. In computer programming, a programming technique or statement for making a selection, such as a conditional jump. 7. In computer software applications, a functional unit, such as a toggle button, used to make selections. See http://www.atis.org/glossary/definition.aspx?id=1208.
75 Staff Report at 18.
76 A confidence level is a measure of the reliability of a result. A confidence level of 95 per cent or 0.95 means that there is a probability of at least 95 per cent that the result is reliable. See http://www.thefreedictionary.com/confidence+level.
77 Staff Report at 17.
78 The EMI standards are established by the Alliance for Telecommunications Industry Solutions (ATIS) Ordering and Billing Forum (OBF). Full copies of the EMI standards are available through ATIS at http://www.atis.org.
79 Staff Report at 18.
80 Ibid. at 18-19.
81 Id.
82 Ibid. at 20.
83 Ibid. at 80.
84 Id.
85 Id.
86 Id.
87 Ibid. at 21-22.
88 Ibid. at 21.
89 Id.
90 Id.
91 Id.
