Non-Service Initialized Phones and 9 -1 -1 Michigan

Non-Service Initialized Phones and 9 -1 -1 Michigan 2009 Fall Forum on Next Generation 9 -1 -1 and Other Emerging Technologies November 3, 2009

Agenda • Introduction • What is an NSI phone? • The Challenge of NSI phones 2 - TCS Confidential -

TCS Fast Facts Established in 1987 – – Annapolis HQ, Seattle, Tampa, London Data Centers in WA, AZ, MD NOCs in Seattle and Annapolis NASDAQ: TSYS Strategic Offers – – Wireless Location & Messaging Solutions Satellite Services and Deployable Systems Homeland Security Professional Services Industry Relations – Founding Member: SMS Forum, PAM Forum, IN Forum – Member: 3 GPP, CTIA, ETSI, GSM, NENA, APCO, OMA, TIA, ESIF, NRIC VII, IETF 3 - TCS Confidential -

TCS E 9 -1 -1 Solutions • Meets wireless E 9 -1 -1 Phase I and Phase II FCC requirements • Provides standards-based Vo. IP i 2 E 9 -1 -1 service (Owns the original i 2 patent) • Displays caller location to police, fire and emergency personnel (lifesaving information) • Supports 24/7 monitoring and operations • Operates 2 fully redundant data centers • Serves over 100 million subscribers • Processes over 125, 000 calls/day • Has completed over 100, 000 E 9 -1 -1 calls to date • Operates the only TL 9000 certified NOC in the 911 industry 4 - TCS Confidential -

TCS Facilities/NOC/Data Center Seattle Network Operations Center Seattle Data Center - TCS Confidential - Backup NOC & Data Center 5 Phoenix, AZ

What is an NSI Phone? – Every cell phone is unique and must be positively identified via an electronic “handshake” with the wireless switch before service is activated. – An NSI phone is one that has not completed the handshake, or has failed the handshake. • • Discarded (failed) Newly purchased (failed) Power –up (not complete) Service lost/restored (not complete) 6 - TCS Confidential -

Why are NSI Phones Capable of 9 -1 -1? • Congressional pressure (Eshoo, D-Ca) – FCC Mandate • Similar to “warm dial tone” for landline • For 9 -1 -1 calls, carriers skip the handshake • The road to hell…. . 7 - TCS Confidential -

How do NSI Phones Work? • Call routing based on cell sector (same as normal wireless call) • PSAP receives ESRK, but no CBN • The CBN is typically 911 + 7 digits of Electronic Serial Number • Location info is provided (assuming capability of phone and PSAP) – Accuracy not adequate to pinpoint user (same as normal Phase 2) 8 - TCS Confidential -

NSI Phones Are Perfect Harrassment Tools • No phone number=no CBN, in exact location, not traceable • Many children find amusement by playing with their NSI phones • Older users are malicious No good deed goes unpunished 9 - TCS Confidential -

Consequences • Dispatcher in Chicago, victimized by one too many prank calls, chastised child for playing with the phone. The call was legitimate, however, with tragic results and lawsuits. • Numerous anecdotal reports of false reports of serious crimes causing responders to kick in the doors of innocent, sleeping, unsuspecting victims • Intentional misdirection of police away from a crime in progress. 10 - TCS Confidential -

Statistics • Tennessee – 2% of NSI calls are legit – Oct-Dec ‘ 06: 54 different callers dialed 9 -1 -1 from an NSI phone more than 10 times (max=140) – Of these 54 people, 8 were children 11 - TCS Confidential -

More Statistics • Florida – 12 -county survey for one month – 4% of all NSI calls were legit • Michigan – 2 -month survey –. 05% of 1000 NSI calls were legit (5 calls) • Washington – Snohomish County-6 week survey – 2% of 553 NSI calls were legit 12 - TCS Confidential -

What is Being Done About NSI Phones? • FCC has amended the NSI mandate to allow carriers to block harassment calls • Carriers are reluctant to block calls due to liability concerns and cost considerations – Who has authority to identify a harasser? – No existing technology to block specific NSI calls. 13 - TCS Confidential -

What is Being Done About NSI Phones? • Petition to FCC – NENA, APCO, NASNA, several states – Petition called for FCC Notice of Inquiry • FCC Notice of Inquiry (Nov 3, 2003) – 70+ Respondants with various recommendations: • Block all NSI Phones; terminate NSI requirement • Block specific NSI Phones using various technologies – NENA submitted reply response 14 - TCS Confidential -

NENA Response to FCC Notice of Inquiry – Opposed termination of NSI requirement and supported blocking of individual calls – Called for Advisory Working Group for negotiated rule making – Identified issues to be resolved • What technology to be used to block calls? • How to define a harassment call; what triggers blocking? • Liability • How long should blocking persist on any one phone? • Funding/Cost Recovery 15 - TCS Confidential -

Options – Terminate all 9 -1 -1 service for NSI phones (if the phones don’t work for regular calls, why should there be an expectation for 9 -1 -1? ) Or, – Block Harassment Calls from specific phones 16 - TCS Confidential -

Technology for Blocking Individual NSI Calls • Block at the PSAP – Recommended by carriers – Assuages liability concerns – Places burden for blocking on the entity that wants the calls blocked – Does hardware/software exist to block NSI calls? – Can calls be routed to recording? 17 - TCS Confidential -

Technology for Blocking Individual NSI Calls • Block at the MSC/MPC – Development work required – How to communicate block order? – Automated timer on blocks – Calls can be routed to recording – Possible call processing delays for all 911 calls 18 - TCS Confidential -

Potential issues if all NSI wireless handsets are blocked • The carrier processing the call may not be able to distinguish a handset that has no active account with any carrier from a handset subscribed to a carrier with whom the carrier processing the call does not have an automatic roaming agreement. • A carrier may block a 911 call due to billing errors or disputes or a simple case of a check lost in the mail. • Immediately and for several seconds after power on, MSC to MSC handoff, recovery from loss of service in a tunnel etc, system "reboots", and other normal network events a handset will appear to be non-initialized and be blocked from making 911 calls. 19 - TCS Confidential -

Potential Issues if we block individual wireless handsets • Each suspect handset will have to be blocked on every carrier with a compatible air interface or the handset will simply roam to another compatible network. • Bad actors will simply get another NSI handset at a yard sale or thrift store. There is a virtually unlimited supply of such handsets. • Bad actors may donate the blocked handset to a thrift store which could prevent a decent citizen from making a 911 call to request help for someone else who really needs it. • Call processing can be delayed or complicated as the telephone’s electronic serial number on every 911 call will have to be compared to a list of blocked serial numbers. • Because it is extremely difficult, perhaps impossible, to uniquely identify NSI handsets even using the ESN of the handset, the wrong handset may be blocked when attempting to block a harassing caller 20 or other inappropriate 911 calls. - TCS Confidential -

Thank you Dickinson Sr. Director, Public Safety Tele. Communication Systems, Inc 206 -792 -2224 ddickinson@telecomsys. com 21 - TCS Confidential -