For the past several years, the prospect of some kind of integration between traditional telephone service and Internet Telephony and message services has captured considerable interest. There are two significant technical hurdles: how to use common addresses across both environments, as well how to route calls to the right locations.

One of the more fanciful schemes coming out of an IETF standards group dubbed ENUM, involves the use of the Internet's Domain Name System to recreate a globally unique distributed database copy of all the world's phone numbers. The idea would allow end users to publish all kinds of different user Internet addresses linked to a phone number.

A small Massachusetts company called NetNumber has been providing a limited specialized service to corporate customers as a private venture for several years.

The IETF single global scheme would have died as a fanciful idea without much public consumer interest, with painful privacy problems, with significant security vulnerabilities, with nearly impossible administrative and regulatory hurdles, and with no revenue model. However, the Internet Society's Internet Architecture Board (IAB) advisory committee came up with the idea of convincing all the world's telecom regulatory authorities, telecom providers, and their Geneva-based intergovernmental organization, the International Telecommunication Union (ITU), to collectively adopt a grand global provisioning ENUM approach they call the "golden" tree or pyramid.

The Golden Tree consists of a single official government sanctioned provisioning pyramid granted to the IAB as a kind of trustee for the master "authoritative" DNS database for all the world's telephone numbers to be effected through ITU approval and cooperation. ICANN has allowed the IAB to use the ARPA top level domain to create the pyramid called E164.ARPA.

Although all of this is theoretically possible, its viability in the marketplace and the likelihood of getting all the world nations and telecom providers to buy into the single IAB pyramid idea is dubious at best. Indeed, ITU players are now suggesting that the ITU rather than the IAB should be responsible for the global pyramid.

A recent Internet Draft has been published suggesting an alternative approach. (The ID is a copy of an identical contribution to an upcoming ITU regulatory-standards group meeting.) This document suggest that rather than attempting a single global government sanctioned pyramid under the IAB (or anyone else), that carrier instead just make their existing inherently authoritative number databases available by contract to any Internet based provider who wanted to link phone numbers to other customer identifiers. Much of today's telephone networks work this way today for non-Internet service.

The idea is to make use of contractual agreements among providers and the marketplace for this telephone number to Internet linking, rather than create a single global monopoly overseen and regulated by all the governments of the world. The VeriSign proposal would also allow considerable flexibility as to alternative and evolving technologies.

For one thing, it rejects the necessity of addressing service integrity (800 is toll free, 900 is pay-per-call, etc.) This could wreak havoc on the U.S. 800 industry and marketers, and leave consumers open to a whole new generation of scams.

It also rejects the necessity of ascertaining that the assignee of a country code domain is the authorized entity.

VeriSign's POV, as posted,

"The Internet Domain Name System is a private, enhanced service that provides name mappings for Internet users. Under long standing law and policy, such services are not subject to regulation in most countries, especially the U.S.

E.164 is a numbering plan for Public Telecommunication Services. Those services are subject to considerable regulation.

Simply placing an E.164 number in an Internet based services directory shouldn't make that directory the subject of ITU jurisdiction and oversight. Indeed, it shouldn't make it the subject of any government regulatory schema.

... Don't these procedures adversely affect the existing providers of these services such as NetNumber?* Why is an intergovernmental body being asked to do something that adversely affects an existing U.S. provider? ... perhaps most important, it this kind of administrative and long-range policy going to be helpful to ENUM kinds of developments? or harmful?"

Contrast this last question with VeriSign's self-serving statement that, "Although there are significant legacy reasons for a so-called single Internet DNS root, this has no relevance to ENUM." (February 2002, STUDY GROUP 2 – CONTRIBUTION NN, "THE DNS RBL SERVICE – AN EXISTING ROBUST EXAMPLE FOR EFFECTIVE IMPLEMENTATION OF MULTIPLE DOMAINS FOR ENUM")

*Interestingly, NetNumber just posted an ITU Study Group 2 contribution "Additions to E.A-ENUM" that says "In the USA Delayed Contribution COM2-D46 it was stated that “… the implementation of such a system must neither preclude deployments of ENUM and other similar protocols in any other top level DNS domain, nor restrict the development of other innovative services that may serve as competing ENUM alternatives.” We believe that this principle should be recognized in E.A-ENUM. NetNumber goes on to propose language to be added to the current draft of E.A-ENUM.

To which VeriSign replied, "While we certainly support this contribution, it remains inexplicable how the U.S. could support *any* administrative-regulatory schema for an Internet-based information service pursuant to an ITU-T Recommendation."