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Ottawa, 30 April 2010

Our Reference:  8622-D11-200917114


Mr. Donald Cavanagh
Vice President – Telecommunications
Distributel Communications Limited
Suite 300, 177 Nepean Street
Ottawa, Ontario  K1A 0N2

Ms. Brenda Stevens
Director, Intercarrier Relations
Rogers Cable Communications Inc.
333 Bloor Street East, 9th Floor
Toronto, Ontario  M4W 1G9

Mr. Yuval Barzakay
Comwave Telecom Inc.
61 Wildcat Rd.
Toronto, Ontario  M3J 2P5

Mr. Marcel Mercia
Chief Operating Officer
Cybersurf Corp.
300 West Tower, 1144 – 29th Ave. NE
Calgary, Alberta  T2E 7P1

Dear Madam and Sirs:

Re:  Bulk Porting of Telephone Numbers Acquired by Distributel/CTI - Interrogatory

Commission staff considers that additional information is required for the Commission to make a determination regarding the above-noted application.

As such, the parties to whom this letter has been sent are to submit their response to the attached interrogatory with the Commission no later than 5 May 2010.

Where a document is to be filed or served by a specific date, the document must be actually received and not merely sent by that date.


Original signed by

Mario Bertrand
Director, Competition Implementation and Technology

Encl.:  Interrogatory


Under the current supplier arrangement, Communication Télosystème Inc. (CTI) has acquired the VoIP end-user customers of Cybersurf Corp (Cybersurf).  CTI, a wholly owned subsidiary of Distributel Communications Limited (Distributel), has a service arrangement (e.g. billing, customer care, service changes, etc.) with these customers.

However, these customers are still being served by Rogers Cable Communications Inc. (Rogers Cable) network via resale arrangements between Rogers Cable, Comwave and Cybersurf.  This means that Rogers Cable is the carrier/CLEC of record and Comwave and Cybersurf are the service providers of record for customer transfer processes as contained in the Canadian Local Ordering Guidelines (C-LOG).

1.  Considering this arrangement, provide a detailed explanation of how the customer transfer local service request (LSR) and local service confirmation (LSC) process would occur and how the C-LOG customer transfer validation requirements would be met and by which entity or entities for the following scenarios:

a. A CTI-acquired VoIP end-user (with Rogers/Comwave telephone number) wishes to transfer to the service of another independent service provider that is not Distributel, Rogers Cable, Cybersurf or Comwave.

b. A CTI-acquired VoIP end-user (with Rogers/Comwave telephone number) wishes to transfer to the service directly provided by Rogers Cable.

c. A CTI-acquired VoIP end-user (with Rogers/Comwave telephone number) wishes to transfer to the service directly provided by Distributel.

2.  Identify any problems and/or issues that could arise in determining to which entity an LSR should be sent, obtaining customer transfer authorizations, generating the LSC with all needed information and coordinating the customer transfer.

3.  Provide a detailed explanation, as well as any issues that could arise on how and who would enter the required porting information in the Number Portability Administration Center (NPAC) in order to create and then approve a subscription version to initiate the porting process.

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