Someone asked me this question and we wound up talking about the industry and shared use, what the FCC might do to clean it up and the right way to do it. I wanted to share this because I think this is important. This isn’t written to attack or defend anyone nor is it meant to be legal advice. It’s just my personal opinion about how to tell whether a shared use business is legitimate or not.

This is similar to my post on the 3 problems with Shared Use. But it’s written from a common sense perspective of how real shared use should be defined. Shared use companies are by definition the end user of the numbers and can’t also be phone companies and they have to actually share their numbers.

Shared Use by definition requires Sharing

It seems like many shared use companies have forgotten the meaning of SHARED. To me a shared use company must have more customers than it has toll free numbers to be considered a “shared use” company. Several so called shared use companies are nothing more than an excuse to hoard numbers and sit on large pools of good numbers and then on top of that, they use it as an excuse to “Rent” numbers because they make much more and wind up with absolute control over their customers. If you don’t have more actual unique customers using and paying you for numbers, than you have toll free numbers, you’re really not sharing anything.

The justification of shared use is that it takes a scarce resource and makes it available to more end users. But if you’re taking more resources than a regular phone company would, there is no benefit. That’s where you cross the line from sharing numbers into hoarding numbers. Another very similar red flag is when they give one company the whole country except Alaska or a province in Canada or Puerto Rico. That’s not sharing and it’s not shared use.

Shared Use companies can’t also be phone companies

Secondly a shared use company is by definition a customer holding the end user rights to a number. Several shared use companies have ended up setting up their own resporg and are trying to have their cake and eat it too. They claim the rights of an end user and at the same time exercise the rights of a phone company too. A good example of this is CustomTollFree.com (although there are certainly more).

When you go to their website they look and act like a phone company, and will automatically reserve any number you find available with their look up tool. That’s a slimy practice designed to entrap customers into their service, but they take it a step further and claim that the numbers are reserved in their name, not the customer’s. So they will make you rent THEIR number which they got out of the pool because you thought they were a phone company and used their phone company lookup tool.

It’s OK for shared use companies to have a search function to search their numbers, but they shouldn’t be allowed to be both a phone company and a shared use number owner at the same time. And playing games by pretending to be two different organizations is a farce and we all know it.

There are also some regular phone companies that have started to offer shared use like services, renting numbers that they claim ownership. This is slightly different but again is an example of a company being both a resporg and wanting the end user rights at the same time. Hello OneBox and CallSource!

Just my two cents

All the FCC would have to do is clarify the definition of a shared use organization by defining them as an organization with more than one unique paying customer per number which is not a resporg or phone company and does not look or act like a regular phone company and is not directly affiliated or related to one.

Like I said, I’m not a lawyer and I know this wouldn’t solve everything. But I’ve been in this business for a long time and I think some standards need to be applied and would end up helping everyone. I’m not writing this to condemn anyone. I hope that writing this might encourage some people to take steps to clean up their act a little before more drastic measures become necessary. I’m concerned that with the new administration coming in 2009, the FCC could look to make examples of some people.

I’ll put this up on a weekend because it’s not necessarily a main stream issue. Your comments are certainly welcome as well. This is by no means cast in stone.

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