Iristel says traffic stimulation accusation “rests on false speculation”

Iristel Inc. has responded to a Part 1 application by Rogers Communications Inc. accusing it of “traffic stimulation,” stating that “the entire factual basis for underlying the Application rests on false speculation.” In a November filing, Rogers defined traffic stimulation as “a mechanism for local exchange carriers to profit from increasing the volume of incoming traffic for termination of their local exchange network.” Pointing to an ad by a Toronto-area radio station that allows listeners to call a Northwest Territories-area phone number owned by Iristel, Rogers said that if those customers have unlimited Canada-wide calling, they “can call this number to get the radio service and leave it on for as long as they like without paying any extra. Meanwhile, the local gets a windfall of revenue.” In a Dec. 2 reply, Iristel said it is “not engaged in any form of regulatory arbitrage or unjust enrichment via exploitation of the regulatory framework for local competition.” It said that any unlimited service will “naturally attract a population of consumers who intend to use the service excessively,” and that Rogers could easily use its fair usage policy to put an end to such behaviour among its own customers. “Rogers knows full well that it possesses the tools and contractual rights to address situations involving customers who use any of its unlimited services excessively,” Iristel said. It also denied any revenue-sharing agreement with AudioNow, the company behind the call-to-listen service, though it did assign the numbers involved to another entity, whose name was not disclosed in the public version of the document, and said that Iristel’s agreement with that company “does contemplate revenue sharing.” “Presumably, AudioNow is a customer or user of services. Iristel had no knowledge of this possibility until it was presented with this Application. This is because it is Iristel’s policy not to scrutinize the business model, marketing strategies, and business relationships of any of its customers.” It added that it “therefore follows that Iristel is not engaged in any arrangement or conspiracy with AudioNow to stimulate traffic in order to take advantage of Rogers’ Canada-wide and unlimited calling plan. Based on Rogers’ misstatements of fact alone, the application should be dismissed in its entirety.”

Iristel says traffic stimulation accusation “rests on false speculation”

Brief | December 13, 2016

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Iristel says traffic stimulation accusation “rests on false speculation”

Brief | December 13, 2016

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