Leslie Bill

Barlow Keener
Keener Law Group
[email_address]
Tel: 617-671-1202
Blog: www.whydom.com
www.barlowkeener.com
FaceBook: Barlow Keener

Barlow Keener
Focused on helping innovators in wireless, internet, telecommunications and Internet media law navigate through the regulatory and legal issues
Experience
CEO and Legal Counsel, BrahmaCom, Inc. facilities-based CLEC
General Counsel, CSA, Inc. direct-to-the-consumer exercise equipment sales using cable and broadcast video ads
General Attorney, BellSouth Telecommunications
JD Emory University; BA University of the South; MA North Carolina Central University

Overview of Femtocells
Femtocell Regulations and Standards
911 Requirements
Billing Issues
Interference
Roaming Charges
Rogue Femtocells
Parasitic Use Problems: Deep Packet Inspection, Blocking, Sniffing
Femtocell Regulatory and Legal Issues

Femtocell Facts
Micro 10 -6 Nano 10 -9 Pico 10 -12 Femto 10 -15
Cell Towers: Macrocell Microcell Picocell Femtocell
60% of cell phone calls are home and office
Total world reach: 70m femtocells by 2012 ABI Research
Femtocell is a $2 billon device market by 2011
Carriers use customer’s DSL/Cable to solve carrier dilemma
#1 Poor coverage in the home – 10-15% of homes
#2 Growing demand on the towers caused by data
#3 Cellco will “own” the home taking wireline
#4 Femtocell Gateway – Storage and communication
End-User Benefits from Using Femtocells
For 15% of homes coverage is poor
New Bundled “unlimited” calling in the home
Data speed increases – 4 bars all the time
Femtocells - Basics

Femtocells: The Market Drivers and Rollouts
Femtocell goals
Replacement of wireline phone – gives “perfect” home service
Carrier fix for looming data problem with mobile video
Consumer FMC converging the wireline phone into wireless
Trials and Rollouts
Softbank July 2007 Trial in Japan
Telefonica O2 Trial in Madrid
Sprint Airave rollout in Denver, Indianapolis, and Nashville
Organizations and Standards
Femtocell Forum Founded July 2, 2007 with 59 members
13 Different Architectures working to simplify to promote the technology

Femtocells: The Vendors
Femtocell Back-End Systems – Controller Sytems
Sonus - mobilEdge, Zynetix, $13m, femtocell MSC controller with IMS, HLR
Airvana - controllers, radios, Qualcomm investment, Verizon
Tatara – connecting femtocells to network
Bitwave - Software defined radio femtocell
Alcatel-Lucent – in the lab, femtocell controllers
Femtocells
IP.access 250 employees, Cisco tied into Linksys gateway
6 years of Picocell experience
Ubiquisys – Google and T-Mobile invested
RadioFrame Networks
Huawei – strongest mover in femtocells
Chips and Femtocells
PicoChip – ABIS chip in all femtocells except Huawei
Huawei – 500 employees, built own chip, rolling out Mar 2008
Gateway – Owning the Home
2Wire AT&T investor
Thomson – 27,000 emp, Airvana partner Cisco – Linksys
Netgear

Femtocells v UMA
$19.99 per month for unlimited calls at home
Choice of 3 phones
WiFi routers $49.99
UMA WiFi service Femtocell service Sprint Airave
$15 per month for unlimited calls at home
Any Sprint phone
Airave femtocell $49.99

Verizon fined $1m for “unlimited” advertisement
Verizon announces 5G limit on EDVO use
Ultra Mobile PC connected via cell data service
Coverage
Frequency effect
Fact 1: To have same coverage on frequency 2x higher, 4x more base stations are required for similar coverage
Fact 2: 2G->3G
Bandwidth Effect
Fact 3: To upgrade data service from 64kbps to 2Mbps, 10x * more base stations are required for similar coverage
Fact 4: Advertised data service moving: 384kbps->8Mbps
Femtocell Cost – Complaints from the carriers
Carriers seeking $100 - $200 femtocell
Churn $250 to obtain a new customer
Towers: 1 Mobile Video download = 100 voice calls
Tower cost $50,000 equipment + legal
Power, Rent, Backhaul
Femtocells become more cost effective than new towers
Femtocell -- The Cellco Broadband Problem

Femtocell Nomadicity
New set of problems as femtocells usage from Europe and Asia could start showing up in the US without restrictions
Difficult to monitor and enforce – Consumers are in control
Consumers are not educated, FCC Enforcement Bureau is weak
Proliferation of femtocells will be tremendous – one per home
100 wireless providers in the US: Will all use locked and blocked femtocells?
FCC Regulations:
No FCC Orders dealing directly with femtocells by name or device description
911 regulations: a mix of VoIP and Wireless for femtocells
Licensed spectrum geography restrictions: FCC Enforcement Bureau
FCC Device Regulation
Unregulated Cell Amplifiers “Repeaters” are being looked at by FCC staffers
Informal complaints by carriers of “unauthorized” amplifiers interference
Public Safety complaints to FCC about repeater interference
Femtocells: No Standards, No Regulations

Femtocells - 911 Issues
100,000 911 calls made each day from wireless phones
FCC: Anyone near a carrier tower - femtocell - including roamers, must have 911 access
Applies to femtocells that now have subscriber limitations – users at the home
If femtocell is out of the “approved” location or licensed territory area, should 911 calls be required to be made?
FCC 911 Antenna location regulation
Phase I FCC's Order (94-102) require that carriers to deliver location of cell site
Phase II mandates that carriers must pinpoint a customer's actual location
2007 FCC 911 NPRM – proposed the idea of a hybrid location requirement using GPS location and tower location in the network
Problem with GPS Femtocell location inside buildings
Requirement that carriers provide 911 even in areas that have weak signals
Automatic A/B Roaming-Intelligent Retry (with some modifications), Adequate/Strongest Signal, and Selective Retry.

911 Issues - Femtocells look like VoIP
Femtocell 911 Location mergers cell and VoIP issues
Femtocell call: Carried over the customer’s internet service
Do 911 regulations for VoIP Wireless trump?
Convergence of VoIP and wireless predicted in orders
FMC 911 calls from within the large enterprise or university campus
FMC will drive IMS as the 911 technology solution
From the computer, VoIP, WiMax, office
Solutions and Problems: GPS – CDMA – can be used to “lock” the femtocell
E911 Order requires carriers to report the location of base stations
A nomadic femtocell can be locked if it moves from the home
2007 FCC NPRM recommends Automatic Location Identification for VoIP
VoIP user goes to hotel, location is provided by network, not user
Non-GPS femtocells could be moved by customers
GPS is not technically needed for non-GSM femtocells
GPS does not work in buildings
GPS is not in all cell phones – this could change, but not solve problem

Femtocell Interference: Traveling Towers
Femtocell interference
If the Femtocell is moved into another licensed area, it will cause interference if not “turned off”
Licensed areas are exclusive to the licensed carrier
Nomadic femtocells are the responsibility of the customer’s carrier
Customers, not carriers, control the location of the femtocell
Rogue or nomadic femtocells cells
Femtocell technology provides the opportunity for rogue devices
Picocells, for example, are used on cruise ships
A ”traveling licensed area” – along with the traveling picocell
No regulatory limitations on femtocell devices
Location of towers controlled where customers use the service
Femtocells without location controls can be used anywhere
Interference with rogue femtocells in licensed spectrum

Billing Challenges
Flat Rate Service from the Femtocell
Class action lawsuits Small billing irregularities for wireless providers = trouble
Oct 2007 AT&T settles with California attorney for not refunding charges on stolen phones $500,000 in legal fees + refunds
Aug 2007 BellSouth settles class action for $8.2m for charging Kentucky internet tax
Jun 2005 Cincinnati Bell settles class action for $6m for incorrect roaming billing
Femtocell Calling: Customers call from home with femtocell service plan but unknowlingly are on the minute clicking macro cell
A per minute rate is charged without customer’s knowledge
Difficult for the carrier to determine the problem
Large numbers of minutes and customers = class action
Voice and Data Speed Expectations by the Customers
Femtocells that use 1xRTT will result in slower speeds / or none at home
Result of unmet femtocell expectations could result in issues
State Attorney General or Class Actions: False billings
False Advertising: $1m NY AG against Verizon for “Unlimited” Internet Oct 2007

Femtocells: Roaming charge issues
Customers get excited about femtocells for 3 reasons
1. Poor cell phone service at home 10-15% of the homes
2. Taking advantage of the bundle package of “free” calls
3. Taking the femtocell to the vacation home without cell service
There are 90 smaller cell phone companies in the US
Femtocells can be created without GPS or user restrictions
Customers can move their femtocell to another carriers
U.S. customer could be charged by a foreign carrier where US customer locks on to foreign Femtocell – Mexico example
Roaming Issues are created
Carrier A customer moves femtocell to Carrier B’s licensed territory
Femtocell is used by customers of Carrier B in the new territory
Call through femtocell shows up as delivered by Carrier A
Carrier A bills for roaming charges for call originated Carrier B’s territory
Difficult to monitor and detect

Parasitic Use Problems
Carriers will be transmitting calls through a customer’s internet
VoIP carriers like Vonage have regularly been called “parasitic”
The voice call is carried on unrelated 3 rd party’s service
New opportunities for listening and interfering with calls
“Wiretapping” by customers at home?
Assumption is that femtocell will have encryption
Assumption that femtocell will restrict non-family from use
But if not, potential for “sniffing” and listening to other cell callers
Sniffing is not limited to enterprise internet systems
Blocking: Internet providers have blocked VoIP, P2P
Deep Packet Inspection: Allows providers to see/listen to all traffic

Barlow Keener
Keener Law Group
[email_address]
Tel: 617-671-1202
Blog: www.whydom.com
Web site: www.barlowkeener.com

Leslie Bill

by Carl Ford on Mar 22, 2008

Accessibility

Categories

Tags

Upload Details

Usage Rights

1 Embed 3

Statistics

Leslie Bill — Presentation Transcript