Potential Hoarding of Toll Free Numbers
The FCC has regulations against hoarding and brokering. Hoarding is defined as taking more numbers from the Available pool than you have a legitimate business need for. Brokering is taking numbers from the Available pool for the purpose of reselling them. I’ve explained why I think the danger isn’t abuse by end users but by phone companies. Plus toll free numbers are also invisible and have no physical presence so very few people ever see how many numbers each phone company has.
For various reasons, the FCC hasn’t been overly aggressive in enforcing this type of abuse, combined with the inability of anyone to see or appreciate how many numbers different companies have, is enabling some companies to take advantage of the situation. I obviously can’t do anything about the FCC, but I can make toll free numbers more visible, and expose just a little of the possible abuses of the system.
I don’t do this to condemn anyone, but with 855 numbers coming out the danger of major abuse will be exponentially increased. In the mean time I’m going to show the volume of numbers activated and controlled by some companies. For instance, the fact that one company recently took over 400,000 numbers at one time, doesn’t prove that they are hoarding or brokering numbers, but at some point it has to be at least a little suspicious. If you’re wondering why we’re running out of toll free numbers, take a look at the amount of numbers activated by CallSource.com. Over the past two years the volume of numbers available has decreased by about 3 million numbers, while at the same time CallSource alone, increased by almost 1 million numbers, (from half a million to one and a half million numbers!)
Here’s the actual monthly numbers.
| DataDate | 800Cnt | 888Cnt | 877Cnt | 866Cnt |
| 01-Jan-09 | 43932 | 274110 | 133621 | 123365 |
| 01-Feb-09 | 44177 | 275708 | 134267 | 123833 |
| 01-Mar-09 | 44515 | 276000 | 134718 | 149053 |
| 01-Apr-09 | 44972 | 288446 | 138569 | 164453 |
| 01-May-09 | 45344 | 289176 | 139738 | 164642 |
| 01-Jun-09 | 46281 | 328177 | 140522 | 164607 |
| 01-Jul-09 | 46687 | 328118 | 140829 | 164374 |
| 01-Aug-09 | 47052 | 312114 | 144102 | 155346 |
| 01-Sep-09 | 47964 | 313700 | 151205 | 174888 |
| 01-Oct-09 | 49758 | 339040 | 176823 | 174979 |
| 01-Nov-09 | 52393 | 340069 | 178754 | 174921 |
| 01-Dec-09 | 55508 | 356340 | 190435 | 175204 |
| 01-Jan-10 | 57720 | 357277 | 191946 | 175444 |
| 01-Feb-10 | 97831 | 358105 | 193092 | 175733 |
| 01-Mar-10 | 99926 | 408507 | 193886 | 175829 |
| 01-Apr-10 | 97806 | 448599 | 194168 | 176017 |
| 01-May-10 | 106066 | 466312 | 195263 | 266331 |
| 01-Jun-10 | 115371 | 716662 | 346143 | 272265 |
| 01-Jul-10 | 112828 | 709516 | 346705 | 272533 |
I understand that this isn’t proof of hoarding, but there’s certainly a lot of smoke here.
See also a previous article about Call Source sucking up over 10,000 out of the 22,000 “800″ numbers released in April 2009 from RCC numbers! Watch out 855 numbers!
(1 votes, average: 5.00 out of 5)
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Elliot Leiboff says:
July 20, 2010 at 2:39 pm
Mr. Quimby,
I know you won’t publish my response, just as you failed to publish my last one. Each time you raise this accusation of hoarding, I explain to you that CallSource is in the business of tracking telephone response to advertising.
We accomplish this by assigning a unique toll-free number to each ad campaign or marketing source our clients employ. We route these calls to our client’s contact centers. We add further value by appending demographics to caller phone numbers, by recording client interactions with callers, by analyzing marketing and conversion efficiency and by training our clients to improve their call-handling skills.
We serve approximately 10,000 direct-response advertisers who run multiple ads and track more than 1,000,000 ads for well-known publications and online listing services- who use us to audit their lead-generation performance.
The reason we use an ever-increasing number of toll-frees is that our clients find our services valuable and our customer base continues to grow. The FCC does not have a problem with our business model, and neither should you.
Thank you.
Elliot Leiboff
Chief Operating Officer
CallSource
Bill Quimby (678 comments.) says:
July 20, 2010 at 4:56 pm
Mr. Leiboff,
I’m not blocking your comments. If you tried to reply before it was probably routed to spam. That’s the only reason it wouldn’t have been allowed. This message was sent to moderation, and I approved it verbatim without touching anything.
First of all, I’m not accusing you of hoarding. That would be a legal determination that the FCC would have to make. I’m not doing this because I’m trying to attack you or your organization either. I’m merely pointing out to the industry what’s going on and trying to let a couple of the organizations that might be tempted to suck up large amounts of 855 numbers, know that what they’re doing will be very visible.
About your claim that you NEED this many numbers in order to conduct your business, I would merely point out that there are multiple call tracking companies and NOBODY ELSE uses that many numbers for call tracking. If what you’re doing was normal, all it would take to need a new area code is five companies that start doing call tracking like you do. There is a limited number of toll free numbers and if you can’t run a call tracking business with the million numbers you had before you took the last 400,000 numbers, it doesn’t take very much to figure out that you’re probably doing something wrong.
You already had a million toll free numbers before you took the last 400,000 numbers in May. So by your own math, you just took 400,000 more numbers than you need. The pace that you’re taking them also adds to the concern a little. It’s hard to justify it as just your regular need, to server your customers when you grab so many numbers at a time that it makes the SMS stats look like there’s only a couple weeks supply of numbers left. The following chart shows your monthly growth of numbers. It doesn’t count the numbers that are dropped, but you don’t drop all that much.
You can say that it’s just your clients finding your service valuable, but why would your customer needs jump by 40% in a single month?! If you use the previous year’s growth rate as a guide, 400,000 numbers would constitute more than a year’s growth. So it’s really not just your normal growth. But it’s not me that you have to justify that to, it’s the FCC. And fortunately they don’t listen to me and probably won’t ever read this. So you can claim you need that many numbers because you’re such a great company, if you want to. I’m just pointing out how it looks and that it’s possible to see how many numbers phone companies take each month.
Bill Quimby
Elliot Leiboff (3 comments.) says:
July 20, 2010 at 7:21 pm
It took exactly 8 clients to utilize all 500,000 numbers reserved in May.
I’m sorry that you disapprove of our business model. Fortunately, our clients and the 200+ people we hired this year disagree with you.
Elliot
Bill Quimby (678 comments.) says:
July 20, 2010 at 8:33 pm
Elliot,
Your claim that this massive amount of numbers is totally necessary just to service 8 customers only shows even more clearly that you’re doing something wrong. Not to mention that you clearly weren’t adding that many numbers before and your business obviously survived.
By that count if you got maybe 50 more customers you would need the entire, 855 area code. If that’s not abusive to the system I don’t know what is.
You don’t have to justify that to me. But there should ultimately be some accounting for this somewhere in the system. Resporgs have a responsibility to utilize toll free numbers responsibly. And like my mother says, you have to avoid not only evil, but the appearance of evil. So even if you’re not doing anything wrong you shouldn’t do it in such a way that it looks like you’re doing something wrong.
That was the point of the post. To warn vanity number resporgs (yourself included) not to do anything that looks suspicious, (like this!)
Bill Quimby
Elliot Leiboff says:
July 21, 2010 at 5:14 pm
You are a real piece of work…
Bill Quimby (678 comments.) says:
July 21, 2010 at 5:34 pm
Funny, that’s exactly what I thought about you trying to justify half a million numbers as just your everyday normal customers needs…
Bill Quimby
Elliot Leiboff (3 comments.) says:
July 21, 2010 at 5:45 pm
Tell me, Bill…
Why is it wrong for eBay Motors or Cars.com to deliver and track telephone leads for a few hundred thousand of their advertisers? How is your clients’ use of toll-free numbers any more legitimate?
Elliot
Bill Quimby (678 comments.) says:
July 21, 2010 at 6:26 pm
I thought about what you said and figured it wouldn’t be hard to determine how many of the numbers are being used, as you claim.
I picked a few blocks of numbers pretty much at random, just knowing that there were more numbers available with 0s and 1s. I checked 1000 888 numbers and found 118 that were CallSource numbers. I called them and wrote down the response. I also noticed when I sorted them by date your “need” for the numbers became clear.
For older numbers, 18 out of 18 or 100% of the numbers are used
For numbers set up earlier this year, 4 out of 10 or 40% are in use.
For numbers acquired in May, 1 out of 90 numbers or 1% are in use.
This isn’t scientific but it does raise some questions and seem to warrant more investigation. It reminds me of something else my mother said, “What you do screams so loud, that I can’t hear what you’re saying.”
Like I said, I’m not doing this to give you a hard time, but just to let you know how this looks to the rest of the world and to remind you that the whole world can see what you’re doing. It’s easy to forget that in this often overlooked little corner of the world. I’m not drawing any conclusions and I didn’t say anything was illegitimate. Hopefully this will just serve as a timely reminder for all the resporgs in the vanity number business.
8887010226 3/30/2000 Myer Motors
8887010281 3/30/2000 Holiday Automotive
8887010266 4/17/2001 Leasing information for unknown company
8887010224 4/12/2005 Lee Morehead
8887010229 4/12/2005 Enterprise Car Sales
8887010233 4/12/2005 Pauls Boat and RV
8887010235 4/12/2005 Connecticut Trailers
8887010238 4/12/2005 Somebody’s Toyota and Psion
8887010239 4/12/2005 Bob Smith Motors
8887010240 4/12/2005 Palm Partners
8887010243 4/12/2005 Keyler Motor Car
8887010245 4/12/2005 Lou Offs Used Cars
8887010246 4/12/2005 The Monteray
8885010202 2/12/2008 Optimum Cable Co.
8885010404 2/12/2008 Evening Creek Apt. Homes
8883010209 7/21/2008 Crawley Chrysler Jeep Dodge
8888010243 3/17/2009 No longer in service.
8887010213 12/7/2009 Shamburg Auto Sales
For older numbers, 18 out of 18 or 100% of the numbers are used
8885010104 3/20/2010 Omaha Steaks answers
8885010106 3/20/2010 No longer in service.
8885010107 3/20/2010 No company, person answered
8885010108 3/20/2010 No longer in service.
8885010109 3/20/2010 No longer in service.
8885010120 3/20/2010 Recording wanting your name and message
8885010122 3/20/2010 Guardian – Medical alert service
8885010125 3/20/2010 No longer in service.
8885010126 3/20/2010 No longer in service.
8885010127 3/20/2010 No longer in service.
For numbers set up earlier this year, 4 out of 10 or 40% are in use.
8885010284 5/23/2010 No longer in service.
8885010294 5/23/2010 No longer in service.
8885010304 5/23/2010 No longer in service.
8885010314 5/23/2010 No longer in service.
8885010324 5/23/2010 No longer in service.
8885010334 5/23/2010 No longer in service.
8885010340 5/23/2010 No longer in service.
8885010341 5/23/2010 No longer in service.
8885010342 5/23/2010 No longer in service.
8885010343 5/23/2010 No longer in service.
8885010344 5/23/2010 No longer in service.
8885010345 5/23/2010 No longer in service.
8885010346 5/23/2010 No longer in service.
8885010347 5/23/2010 No longer in service.
8885010348 5/23/2010 No longer in service.
8885010349 5/23/2010 No longer in service.
8885010354 5/23/2010 No longer in service.
8885010364 5/23/2010 No longer in service.
8885010374 5/23/2010 No longer in service.
8885010384 5/23/2010 No longer in service.
8885010394 5/23/2010 No longer in service.
8885010401 5/23/2010 No longer in service.
8885010403 5/23/2010 No longer in service.
8885010405 5/23/2010 No longer in service.
8885010406 5/23/2010 No longer in service.
8885010407 5/23/2010 No longer in service.
8885010408 5/23/2010 No longer in service.
8885010409 5/23/2010 No longer in service.
8885010412 5/23/2010 No longer in service.
8885010413 5/23/2010 No longer in service.
8885010414 5/23/2010 No longer in service.
8885010416 5/23/2010 No longer in service.
8885010417 5/23/2010 No longer in service.
8885010418 5/23/2010 No longer in service.
8885010419 5/23/2010 No longer in service.
8885010420 5/23/2010 No longer in service.
8885010421 5/23/2010 No longer in service.
8885010422 5/23/2010 No longer in service.
8885010423 5/23/2010 No longer in service.
8885010424 5/23/2010 No longer in service.
8885010425 5/23/2010 No longer in service.
8885010426 5/23/2010 No longer in service.
8885010427 5/23/2010 No longer in service.
8885010428 5/23/2010 No longer in service.
8885010429 5/23/2010 No longer in service.
8885010431 5/23/2010 No longer in service.
8885010433 5/23/2010 No longer in service.
8885010434 5/23/2010 No longer in service.
8885010435 5/23/2010 No longer in service.
8885010436 5/23/2010 No longer in service.
8885010437 5/23/2010 No longer in service.
8885010438 5/24/2010 No longer in service.
8885010439 5/24/2010 No longer in service.
8885010440 5/24/2010 No longer in service.
8885010441 5/24/2010 No longer in service.
8885010442 5/24/2010 No longer in service.
8885010443 5/24/2010 No longer in service.
8885010445 5/24/2010 No longer in service.
8885010446 5/24/2010 No longer in service.
8885010447 5/24/2010 No longer in service.
8885010448 5/24/2010 No longer in service.
8885010449 5/24/2010 No longer in service.
8885010450 5/24/2010 No longer in service.
8885010451 5/24/2010 No longer in service.
8885010452 5/24/2010 No longer in service.
8885010453 5/24/2010 No longer in service.
8885010455 5/24/2010 No longer in service.
8885010456 5/24/2010 No longer in service.
8885010458 5/24/2010 No longer in service.
8885010459 5/24/2010 No longer in service.
8885010460 5/24/2010 Check your listing on Yellow.com
8885010461 5/24/2010 No longer in service.
8885010462 5/24/2010 No longer in service.
8885010463 5/24/2010 No longer in service.
8885010464 5/24/2010 No longer in service.
8885010465 5/24/2010 No longer in service.
8885010477 5/24/2010 No longer in service.
8885010481 5/24/2010 No longer in service.
8885010482 5/24/2010 No longer in service.
8885010483 5/24/2010 No longer in service.
8885010484 5/24/2010 No longer in service.
8885010485 5/24/2010 No longer in service.
8885010486 5/24/2010 No longer in service.
8885010487 5/24/2010 No longer in service.
8885010488 5/24/2010 No longer in service.
8885010490 5/24/2010 No longer in service.
8885010491 5/24/2010 No longer in service.
8885010492 5/24/2010 No longer in service.
8885010493 5/24/2010 No longer in service.
8885010494 5/24/2010 No longer in service.
For numbers acquired in May, 1 out of 90 numbers or 1% are in use.
Bud says:
July 22, 2010 at 10:31 am
Wow, Checkmate! This was a little long but Bill, you’re right on. It’s what they do that counts, not what they say.
Elliot Leiboff (3 comments.) says:
July 22, 2010 at 10:38 am
I don’t suppose you remembered from our earlier exchange that, in order to assure accurate call counts, we hold newly reserved numbers for 90 days before assigning them, in order to filter out those with wrong-number traffic.
Bill Quimby (678 comments.) says:
July 22, 2010 at 4:33 pm
Great, I’ll do a follow up with you in a couple months, maybe after the 855 numbers are released. You won’t have to do an aging process on them!
I’m also not sure what exchange you’re referring to, but admitting that you’re not using any of the half a million numbers you took, probably doesn’t help your case a whole lot. The regulation against hoarding don’t say it’s alright to hoard for just a little while.
Besides, you know that they had to be in disconnect for four months before they could be returned to the spare pool. Most of them haven’t been used in several months on top of that. And half the misdials come from dialing wrong, not from past or out of date advertising. So that may sound smart on the surface, but again, it’s just an excuse, and not a very solid one at that.
Bill Quimby
PS. Please talk to your legal department before responding any more, because you just keep digging yourself in even deeper here! The point of this article wasn’t to prove that you’re hoarding. But the more you keep making excuses, the worse it’s making you look.
I keep telling you that the point is just to remind you and anyone else that will be tempted to grab large amounts of 855 numbers, how this type of thing looks and how visible it ultimately is. I guess the secondary point is now, that “excuses” are just that and don’t give you the right to do anything you want.
Bill Quimby (678 comments.) says:
July 22, 2010 at 5:13 pm
I think this post dovetails with another post from just a couple days earlier about how if I go out of business I’ll go work as a consultant for the FCC. http://www.tollfreenumbers.com/blogs/about-us/fcc-consultant.html
Bill Quimby (678 comments.) says:
July 23, 2010 at 3:09 pm
There’s one more piece of data missing from this that I thought might be helpful to add. It’s a comparison of the amount of numbers that other companies took. If this was just their normal customer’s needs how much did customers ask for at other companies?
We could go into this same type of detail with any resporg but this is illustrative enough for this conversation.
Bill Quimby
Kevin says:
September 22, 2010 at 7:51 pm
Im calling my senator on Call Source.
This is bad for small business growth.
The bread & butter of America
Jarred says:
September 24, 2010 at 7:41 pm
Bill, good work. We’ll see what happens on the first of next month at the 855 landrush.
Spencer says:
October 1, 2010 at 11:11 am
Bill,
I have to say I’m very impressed with your knowledge of the industry and your passion to give your customers the best possible service. Other companies should really take notes on you. It’s this type of service that will keep me coming back in the future.
I don’t think enough people tell it how it is anymore and you should be commended for speaking up.
Thank you!
Dymond MacNamera(new comment) says:
September 19, 2011 at 4:55 pm
Can companies like CallSource charge resporg fees? I think they charge $50 per line or has it noted in their agreement… how can they charge for something they do not own?