[WISPA] CALEA Document

2017-01-25 Thread Sam Morris
It's my understanding that one just needs to have documentation in place 
as to what they will do if presented with a CALEA request. Does this 
need to be extremely detailed, or can it be boilerplate? Does anyone 
have a CALEA document they wouldn't mind sharing? There's a couple beers 
in it for you at Wispapalooza. :)

Thanks
Sam
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Re: [WISPA] Calea Compliance

2011-03-08 Thread Marlon K. Schafer (509-982-2181)
Re: [WISPA] Calea ComplianceRight.

There are documents that WISPA has created to help with this.

http://www.wispa.org/?page_id=2022

We also have an implementation guide but the board has not determined how 
that's to be distributed.  We can certainly get a copy to you if you are a 
member.

Please note, that we're in the middle of a minor re-write that will focus on 
IPv6 issues and a couple of clarifications that needed work in the original 
version.
marlon

  - Original Message - 
  From: Jeff Broadwick - Lists 
  To: ro...@g5i.net ; 'WISPA General List' 
  Sent: Monday, March 07, 2011 5:59 AM
  Subject: Re: [WISPA] Calea Compliance


  You would be better off putting a passive tap inline and the router as a 
probe.  If you do that, it will be completely invisible to the end customer.

   

  Regards,

  Jeff
  ImageStream Sales Manager
  800-813-5123 x106


--

  From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On 
Behalf Of Roger Howard
  Sent: Saturday, March 05, 2011 10:50 PM
  To: WISPA General List
  Subject: Re: [WISPA] Calea Compliance

   

  Ok, but the FBI wouldn't know I stuck the hardware there at the last
  minute. And the tower glitches off whenever I do a firmware upgrade
  anyway. The customer wouldn't know the difference.

  On Sat, Mar 5, 2011 at 9:45 PM, Josh Luthman
  j...@imaginenetworksllc.com wrote:
   Depends who you ask.  Some might say the customer could notice a change in
   network and hence non compliant.
  
   On Mar 5, 2011 10:43 PM, Roger Howard g5inter...@gmail.com wrote:
   Would I cover myself for calea by having a mikrotik router on the
   shelf, set up as a bridge, with the calea module installed. Then if I
   get subpoenaed for a tap, I just run out to the appropriate tower and
   put it on the ethernet interface of whichever AP the subscriber is on?
  
   Thanks,
   Roger
  
  
  
   

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Re: [WISPA] Calea Compliance

2011-03-07 Thread Jeff Broadwick - Lists
You would be better off putting a passive tap inline and the router as a
probe.  If you do that, it will be completely invisible to the end
customer.

 

Regards,

Jeff
ImageStream Sales Manager
800-813-5123 x106

  _  

From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Roger Howard
Sent: Saturday, March 05, 2011 10:50 PM
To: WISPA General List
Subject: Re: [WISPA] Calea Compliance

 

Ok, but the FBI wouldn't know I stuck the hardware there at the last
minute. And the tower glitches off whenever I do a firmware upgrade
anyway. The customer wouldn't know the difference.

On Sat, Mar 5, 2011 at 9:45 PM, Josh Luthman
j...@imaginenetworksllc.com wrote:
 Depends who you ask.  Some might say the customer could notice a change
in
 network and hence non compliant.

 On Mar 5, 2011 10:43 PM, Roger Howard g5inter...@gmail.com wrote:
 Would I cover myself for calea by having a mikrotik router on the
 shelf, set up as a bridge, with the calea module installed. Then if I
 get subpoenaed for a tap, I just run out to the appropriate tower and
 put it on the ethernet interface of whichever AP the subscriber is on?

 Thanks,
 Roger






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Checked by AVG - www.avg.com
Version: 10.0.1204 / Virus Database: 1435/3487 - Release Date: 03/07/11




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Re: [WISPA] Calea Compliance

2011-03-06 Thread John Scrivner
The FBI told me (and I am paraphrasing) that if you work with them that they
will work with you. Basically as long as you are not acting like you do not
think they have a right to do the tap and are not being a pain in the behind
then you will get all the support you need from them in a lawful intercept
situation. I would say that having this box on the shelf shows your
intentions of being compliant to the act. CALEA is all about 2 things. It is
about making sure that tools exist to find and stop crime on the Internet
and about making sure that we help be a check against government becoming
too intrusive.

CALEA has many regs which say when we are doing too much to help tap
connections.  The WISPA CALEA standard was created to act as a guideline for
WISPs. It tells precisely what our obligations are in helping assure we can
perform lawful intercepts in our network and in preventing overstepping the
bounds of what is lawful.
Scriv


On Sat, Mar 5, 2011 at 9:49 PM, Roger Howard g5inter...@gmail.com wrote:

 Ok, but the FBI wouldn't know I stuck the hardware there at the last
 minute. And the tower glitches off whenever I do a firmware upgrade
 anyway. The customer wouldn't know the difference.

 On Sat, Mar 5, 2011 at 9:45 PM, Josh Luthman
 j...@imaginenetworksllc.com wrote:
  Depends who you ask.  Some might say the customer could notice a change
 in
  network and hence non compliant.
 
  On Mar 5, 2011 10:43 PM, Roger Howard g5inter...@gmail.com wrote:
  Would I cover myself for calea by having a mikrotik router on the
  shelf, set up as a bridge, with the calea module installed. Then if I
  get subpoenaed for a tap, I just run out to the appropriate tower and
  put it on the ethernet interface of whichever AP the subscriber is on?
 
  Thanks,
  Roger
 
 
 
 
 
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Re: [WISPA] Calea Compliance

2011-03-06 Thread Butch Evans
On 03/06/2011 09:18 AM, John Scrivner wrote:
 The FBI told me (and I am paraphrasing) that if you work with them 
 that they will work with you. Basically as long as you are not acting 
 like you do not think they have a right to do the tap and are not 
 being a pain in the behind then you will get all the support you need 
 from them in a lawful intercept situation. I would say that having 
 this box on the shelf shows your intentions of being compliant to the 
 act. CALEA is all about 2 things. It is about making sure that tools 
 exist to find and stop crime on the Internet and about making sure 
 that we help be a check against government becoming too intrusive.

Correct.  Protect the rights of our customers, protect the rights of the 
service provider AND allow for what LEA needs to get a conviction for 
the guilty party.  All of these are built into CALEA.


 CALEA has many regs which say when we are doing too much to help tap 
 connections.  The WISPA CALEA standard was created to act as a 
 guideline for WISPs. It tells precisely what our obligations are in 
 helping assure we can perform lawful intercepts in our network and in 
 preventing overstepping the bounds of what is lawful.

In addition, the WCS for IPNA provides technical requirements as well.  
It defines the technical standard that our software/hardware MUST meet.  
For the original poster:  Be sure you are familiar enough with the way 
the MT handles the CALEA software so that you can properly capture this 
data for the LEA.  Mikrotik's CALEA implementation is 2 parts.  It 
requires a server AND a tap.  One box CAN be both pieces.

-- 

* Butch Evans   * Professional Network Consultation*
* http://www.butchevans.com/* Network Engineering  *
* http://store.wispgear.net/* Wired or Wireless Networks   *
* http://blog.butchevans.com/   * ImageStream, Mikrotik and MORE!  *
*NOTE THE NEW PHONE NUMBER: 702-537-0979   *





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Re: [WISPA] Calea Compliance

2011-03-06 Thread Justin Wilson
 The easy answer is if you get a warrant you should ask the agency for
help before doing anything.  They are more than willing to help in my
experience.  My advice is:

1.Get your attorney involved to the point they know what you are doing
2.Call the agency who the warrant is for and ask for technical assistance.

 They have done this many times and can make sure you don't mess things up.

 Justin
-- 
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Wisp Consulting ­ Tower Climbing ­ Network Support




On 3/6/11 11:02 AM, Butch Evans but...@butchevans.com wrote:

On 03/06/2011 09:18 AM, John Scrivner wrote:
 The FBI told me (and I am paraphrasing) that if you work with them
 that they will work with you. Basically as long as you are not acting
 like you do not think they have a right to do the tap and are not
 being a pain in the behind then you will get all the support you need
 from them in a lawful intercept situation. I would say that having
 this box on the shelf shows your intentions of being compliant to the
 act. CALEA is all about 2 things. It is about making sure that tools
 exist to find and stop crime on the Internet and about making sure
 that we help be a check against government becoming too intrusive.

Correct.  Protect the rights of our customers, protect the rights of the
service provider AND allow for what LEA needs to get a conviction for
the guilty party.  All of these are built into CALEA.


 CALEA has many regs which say when we are doing too much to help tap
 connections.  The WISPA CALEA standard was created to act as a
 guideline for WISPs. It tells precisely what our obligations are in
 helping assure we can perform lawful intercepts in our network and in
 preventing overstepping the bounds of what is lawful.

In addition, the WCS for IPNA provides technical requirements as well.
It defines the technical standard that our software/hardware MUST meet.
For the original poster:  Be sure you are familiar enough with the way
the MT handles the CALEA software so that you can properly capture this
data for the LEA.  Mikrotik's CALEA implementation is 2 parts.  It
requires a server AND a tap.  One box CAN be both pieces.

-- 

* Butch Evans   * Professional Network Consultation*
* http://www.butchevans.com/* Network Engineering  *
* http://store.wispgear.net/* Wired or Wireless Networks   *
* http://blog.butchevans.com/   * ImageStream, Mikrotik and MORE!  *
*NOTE THE NEW PHONE NUMBER: 702-537-0979   *




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[WISPA] Calea Compliance

2011-03-05 Thread Roger Howard
Would I cover myself for calea by having a mikrotik router on the
shelf, set up as a bridge, with the calea module installed. Then if I
get subpoenaed for a tap, I just run out to the appropriate tower and
put it on the ethernet interface of whichever AP the subscriber is on?

Thanks,
Roger



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Re: [WISPA] Calea Compliance

2011-03-05 Thread Josh Luthman
Depends who you ask.  Some might say the customer could notice a change in
network and hence non compliant.
On Mar 5, 2011 10:43 PM, Roger Howard g5inter...@gmail.com wrote:
 Would I cover myself for calea by having a mikrotik router on the
 shelf, set up as a bridge, with the calea module installed. Then if I
 get subpoenaed for a tap, I just run out to the appropriate tower and
 put it on the ethernet interface of whichever AP the subscriber is on?

 Thanks,
 Roger




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Re: [WISPA] Calea Compliance

2011-03-05 Thread Roger Howard
Ok, but the FBI wouldn't know I stuck the hardware there at the last
minute. And the tower glitches off whenever I do a firmware upgrade
anyway. The customer wouldn't know the difference.

On Sat, Mar 5, 2011 at 9:45 PM, Josh Luthman
j...@imaginenetworksllc.com wrote:
 Depends who you ask.  Some might say the customer could notice a change in
 network and hence non compliant.

 On Mar 5, 2011 10:43 PM, Roger Howard g5inter...@gmail.com wrote:
 Would I cover myself for calea by having a mikrotik router on the
 shelf, set up as a bridge, with the calea module installed. Then if I
 get subpoenaed for a tap, I just run out to the appropriate tower and
 put it on the ethernet interface of whichever AP the subscriber is on?

 Thanks,
 Roger



 
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[WISPA] Fw: [WISPA CALEA Questions] [CALEA] CALEA Question

2010-07-30 Thread Marlon K. Schafer
signatureFor those asking about the recent FCC statement that broadband is now 
defined as 4/1 meg. and how that relates (if at all) to CALEA requirements.

The answer to that question is below.

In a nutshell, it doesn't change anything because the new definition only 
applies to reported deployment rates not the legal requirement for CALEA 
intercepts.

For those that didn't make the breakfast board meeting at St. Louis, Larry 
Bruss is the one that gave the CALEA standards update on my behalf.

Hope this helps!
marlon

- Original Message - 
From:  
To: ca...@wispa.org 
Cc: caleaquesti...@wispa.org 
Sent: Wednesday, July 28, 2010 2:56 PM
Subject: Re: [WISPA CALEA Questions] [CALEA] CALEA Question


Martha,

Mike,

Marlon,

WISPA members,

 

I have reviewed your EMail questions regarding the FCC's new definition of 
broadband and have discussed them with the DOJ's Office of General Counsel 
(OGC).  

 

OGC sent me the following response to your questions:

 

 

The FCC has not changed its regulatory definition of broadband Internet access 
service provider.  What changed most recently was that the FCC updated the 
standard it uses to determine whether households are served by broadband 
services.  It uses this standard in its annual broadband deployment reports 
as mandated by section 706 of the Telecommunications Act of 1996 to determine 
whether advanced telecommunications capability (a term it uses 
interchangeably with broadband) is being deployed to all Americans in a 
reasonable and timely fashion.  This standard is supposed to evolve over time 
in order to accurately reflect the minimum speed necessary to stream 
high-quality video while leaving sufficient bandwidth for basic web browsing 
and e-mail.  The FCC's determination clearly applies only to that report:  As 
a result, we find that the 200 kbps threshold is no longer the appropriate 
benchmark for measuring broadband deployment for the purpose of this broadband 
deployment report.  See para. 4 of the Sixth Broadband Deployment Report, FCC 
10-129 (July 20, 2010), available at 
http://www.fcc.gov/Daily_Releases/Daily_Business/2010/db0720/FCC-10-129A1.pdf 
(emphasis added).  This is stated unambiguously in footnote 46:

 

We emphasize that we are benchmarking broadband in this report solely for 
purposes of complying with our

obligations under section 706. We specifically do not intend this speed 
threshold to have any other regulatory

significance under the Commission's rules absent subsequent Commission action. 
For example, today's report has

no impact on which entities are classified as interconnected VoIP providers or 
what facilities must be provided on an

unbundled basis. . . .

 

By contrast, the FCC in its 2005 First Report and Order declared that CALEA 
applies to all broadband Internet access service providers.  There, it stated 
that broadband is defined as 200 kbps, but we also include as 'broadband' - 
for purposes of CALEA only - those services such as satellite-based Internet 
access services that provide similar functionalities but at speeds less than 
200 kbps.  FCC 05-153 para. 24 n.74.  That ruling is completely undisturbed by 
what Julius Knapp was talking about in his keynote, which was referring only to 
the definition of broadband used in the broadband deployment report.  The FCC 
did not state and did not intend that the definition of the service covered by 
CALEA would evolve to correspond with the definition used in those reports.  
CALEA remains applicable to WISPs and all other facilities-based Internet 
access service providers as defined in 2005.

 

 

I hope this clarifies Mr. Knapp's remarks and the on-line article referenced in 
previous Emails regarding CALEA and the definition of Broadband.

 

Regards,

 

Larry Bruss

Telecommunications Engineer

Tridea Works, LLC

1 503 343 9010

1 703 985 6711

 

 

 

From: calea-boun...@wispa.org [mailto:calea-boun...@wispa.org] On Behalf Of 
Martha Huizenga
Sent: Monday, July 26, 2010 5:17 AM
To: ca...@wispa.org
Cc: caleaquesti...@wispa.org; Michael Erskine
Subject: Re: [CALEA] CALEA Question

 

I can't believe that they are saying that even more Americans are not using 
broadband! I saw this article, completely ridiculous.

Anyway I think we are still subject. I think it's anyone with a connection to 
the Internet. I bet they could come after people with dial-up. Maybe we should 
ask Larry though?

Martha Huizenga
DC Access, LLC
202-546-5898
Friendly, Local, Affordable, Internet!
Connecting the Capitol Hill Community
Join us on Facebook or follow us on Twitter


On 7/25/2010 11:35 PM, Marlon K. Schafer wrote: 

Hi All, Anyone have a read on this? I didn't think CALEA was limited to 
broadband.  If it is though.marlon - Original Message - From: 
Michael Erskine To: o...@odessaoffice.comSent: Thursday, July 22, 2010 
11:29 AMSubject: CALEA Question  Marlon; Since the FCC has redefined the term 
broadband again, I wonder whatimpact

[WISPA] Fw: [WISPA CALEA Questions] Trango and CALEA

2008-12-21 Thread Marlon K. Schafer
fyi
marlon

- Original Message - 
From: J.C. Utter j...@imagestream.com
To: CALEA Questions caleaquesti...@wispa.org
Sent: Sunday, December 21, 2008 12:59 PM
Subject: Re: [WISPA CALEA Questions] [WISPA] Trango and CALEA


 In an ideal world one would never even touch a packet that had nothing
 to do with the target of any legal requirement we might receive.  The
 understanding that proceeds from the application of CALEA to packet
 switched networks from the circuit switched world is that the same
 privacy rights that exist in the circuit switched world exist in a
 packet switched world.  In other words we are not allowed to let the
 probe touch any other circuit.  When applying an intercept device, in an
 ideal world, it would isolate traffic by IP/MAC and completely ignore
 any other traffic.  It would forward only the data packets which are
 associated with the target of the legal action that authorized the
 intercept.  Sometimes that is possible, sometimes it is not.  When it is
 not possible the physical TAP will likely forward all traffic to a
 storage system which will drop any packets that are not covered in the
 legal requirement establishing the intercept.

 Thanks for the background Mike. I think your analysis is generally
 spot-on, but I do have a technical issue to address in what you have said
 here.

 I would argue that the storage step in this process is the only step
 that is equivalent to what we are calling collection. For example, when
 a software tap in one of our routers is used to perform an intercept, we
 are already touching all of the packets in the sense that the router is
 looking at them and forwarding them. I don't think this is what you mean
 when you talk about touching a packet. I think when you talk about
 touching a packet you're talking about privacy. So, in an intercept like
 this, only the packets of interest are forwarded to the collector which
 is essentially the storage device. No extra touching of unauthorized
 traffic is required by our routers during an intercept, in the context of
 privacy, which I think is what you are talking about.

 Similarly, when you look at a passive hardware monitoring tap, which
 creates a second copy of the network traffic, the tap is nearly
 indistinguishable from a wire in terms of its intelligence and the
 device's actual ability (or inability in this cae) to collect network
 traffic. So in this scenario, installing a hardware tap on a ciruit to
 create a copy of the circuit's traffic is not really collecting anything,
 and in terms of privacy, it does not touch the traffic any more than the
 other wires that carry customer data to its appropriate destination.
 With a hardware tap, network traffic continues to be treated as private
 until the act of collection (or perhaps another act of viewing of the
 data) commences, where the output of the tap is actually stored or viewed
 by a person. This is why it is legal to install hardware taps throughout a
 network in advance of a court order, and then begin using the output of
 the tap to perform a lawful intercept once the court order is issued.

 In a lawful intercept, the output of the hardware tap is filtered before
 it is stored. In this scenario, if there is no storage of the data and no
 access to that data which is to remain private (i.e. not covered by the
 intercept order), then no one has effectively touched the data from a
 privacy perspective. In this context, it is also important to note that
 even though some traffic may be authorized for collection, it too must be
 kept private, and the carrier is not allowed to view the contents of an
 intercept.

 I know I'm being fairly nit-picky with terminology here, but we are
 interpreting the law, and the FBI can be quite nit-pickey when they want
 to. You comments made it sound like the act of installing a tap is somehow
 less private than not installing a tap, which is not the case. It is just
 as private as any other wire on the network that carries traffic and could
 be viewed or collected, but the traffic is not being collected or viewed.

 I hope this is helpful. I agree that CALEA codifies data privacy
 requirements under the law, and it is a big step in the right direction. I
 also believe that installing taps on a network is no more a threat to
 privacy than having other wires carrying private customer traffic that
 might be viewed and/or collected. It is really a matter of whether the
 carrier collects private traffic, and hardware taps do not collect
 traffic, even when an intercept is being performed with proper filtering.


 So, what I am saying is this.  We must collect our packets as close to
 the target of the legal action as possible.  We must filter those
 packets for any which are not pertinent and drop those at the earliest
 convenience.  We must *never* record those packets which are not
 pertinent on any permanent medium unless that is the only possible way
 to satisfy the legal requirement.

 Yes

[WISPA] Fw: [WISPA CALEA Questions] Trango and CALEA

2008-12-20 Thread Marlon K. Schafer

- Original Message - 
From: Michael Erskine mic...@kaballero.com
To: CALEA Questions caleaquesti...@wispa.org
Sent: Friday, December 19, 2008 11:01 AM
Subject: Re: [WISPA CALEA Questions] [WISPA] Trango and CALEA


 CALEA prevents even the WISP from over collecting.  We are no longer 
 permitted to tap any communications in our own networks except for the 
 purposes of satisfying a subpoena, a Title 3, or CALEA action or for 
 maintainance purposes.  We are now, because of CALEA, under exactly the 
 same intercept constraints as the telcos.  Your tap may run in 
 permissive mode; however, if you interpret the statue strictly, you have 
 to filter at the tap in the software.  Hence my concern that the vendors 
 get WCS-IPNA implemented post haste.  Other solutions are too pricey for 
 the little guys.  We need OpenCALEA yesterday.
 
 just my two.
 -m-
 
 
 Jesse Norell wrote:
 On Fri, 2008-12-19 at 08:32 -0700, Jesse Norell wrote:
   
 So as long as you offer the data they ask regardless of what you
 actually collect that is acceptable?
   
   Correct, you can over collect data, then you filter out just what
 you need and only give them that.  And if you're following a standard
 like WCS-IPNA, you would make/record the checksums on only the data
 you
 present the LEA.
 

   I guess I'll qualify that permissibility to overcollect with the
 requirements of the standard you're following.  Eg. the CableLabs CBIS
 does not allow it (see 5.1.6 Isolation).  But (from memory) the CALEA
 law does not prohibit that approach; it does require that you be capable
 of 103(a)(4) facilitating .. interceptinos .. in a manner that protects
 (A) the privacy and security of communications and call-identifying
 information not authorized to be intercepted, hence the WCS-IPNA
 standard (and all others) don't allow you to present that overcollected
 data to the LEA(*).

 Jesse

 (*) there is a controversial nat-in-the-ap exemption in wcs-ipna that
 will expire soon that violates this point


   
 
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[WISPA] Fw: [WISPA CALEA Questions] Trango and CALEA

2008-12-20 Thread Marlon K. Schafer
fyi
marlon

- Original Message - 
From: Michael J. Erskine mic...@kaballero.com
To: CALEA Questions caleaquesti...@wispa.org
Sent: Friday, December 19, 2008 6:10 PM
Subject: Re: [WISPA CALEA Questions] [WISPA] Trango and CALEA


 Good evening everyone!  Happy Christmas to all of you.

 It has been a long and profitable day.  I found a problem I have been
 working for four months.  Yeah!

 I have time now to try to explain what I intended to say.

 CALEA complicates these issues because it is an application of circuit
 switching law to a packet switched environment.  It was never suited, or
 intended, to apply to packet switched networks, but the FCC/FBI found it
 convenient in these times to force that foot into that glass slipper.  :)

 No law longer than one sentence will ever be followed to the letter in
 every instance.  That is impossible.  Still, judges believe that the
 letter of the law is what matters.  I guess that is because you can not
 infer spirit without also inferring opinion as well.  Reasonable enough.

 The law of intercept has been hashed about between NSA, the FBI, and the
 State Department for about a hundred and fifty years at this point and
 the rights of the citizens are fairly well defined.  We were
 intercepting telegraph during the Civil War, WWI, and all manner of
 communications by WWII.  The various court cases which arose from those
 intercepts helped to exercise the Constitution and The Bill of Rights
 and to define the limits to which citizens and government may act in the
 invasion of another person's privacy.  That battle will continue to be
 waged forever.  Never the less, the FCC's application of CALEA to packet
 switched networks actually substantiates protections in a packet
 switched world which were not previously applied.  For this reason,
 CALEA is actually a good thing.

 CALEA protects our customers from *anyone* who would collect information
 from their communications streams without proper court approval.  CALEA
 applies the protections which the TELCOs must observe to *all* IP
 carriers, whether they are end nodes or transport nodes in the packet
 switched network.  This is a good thing, but problematic when we are
 forced to discuss the letter (and not the intent) of the law.

 The pertinent principles defined in CALEA, are Authentication,
 Validation, Isolation, Proportionality, and Completeness.  When reading
 the WISPA-CS-IPNA 2.0 we see that the committee derived from the statute
 that we must collect the minimum information that will satisfy any legal
 requirement.  This was not done to relieve the ISP of work, rather it
 was done to ensure the privacy of the user is the *first* concern in any
 intercept action.

 In an ideal world one would never even touch a packet that had nothing
 to do with the target of any legal requirement we might receive.  The
 understanding that proceeds from the application of CALEA to packet
 switched networks from the circuit switched world is that the same
 privacy rights that exist in the circuit switched world exist in a
 packet switched world.  In other words we are not allowed to let the
 probe touch any other circuit.  When applying an intercept device, in an
 ideal world, it would isolate traffic by IP/MAC and completely ignore
 any other traffic.  It would forward only the data packets which are
 associated with the target of the legal action that authorized the
 intercept.  Sometimes that is possible, sometimes it is not.  When it is
 not possible the physical TAP will likely forward all traffic to a
 storage system which will drop any packets that are not covered in the
 legal requirement establishing the intercept.

 So, what I am saying is this.  We must collect our packets as close to
 the target of the legal action as possible.  We must filter those
 packets for any which are not pertinent and drop those at the earliest
 convenience.  We must *never* record those packets which are not
 pertinent on any permanent medium unless that is the only possible way
 to satisfy the legal requirement.

 WISPA-CS-IPNA defines the relationship between the WISP/ISP and the
 LEA.  It does not define the relationship between the WISP/ISP and the
 customer; however, the law, CALEA, is based upon the existence of a set
 of rights and responsibilities which were established in a circuit
 switched world.  If, in the process of satisfying a legal action, we
 violate those established principles, we can find ourselves in a legal
 quagmire like the one that ATT so recently stepped into.

 Just my two.


 J.C. Utter wrote:
 Everyone gets confused easily in this conversation because participants
 use the word tap to mean different things. I use passive tap to refer
 to real taps that you install on the line for out-of-band collection.
 However, many people in the industry think of a tap as a software
 collector. I don't use the word tap in refernce to software, but I 
 think
 Mike was not talking about the kind of device we

Re: [WISPA] [WISPA CALEA Questions] Trango and CALEA

2008-12-19 Thread Jeff Broadwick
That would be my suggestion.  That's radio vendor neutral.

Jeff
 

-Original Message-
From: caleaquestions-boun...@wispa.org
[mailto:caleaquestions-boun...@wispa.org] On Behalf Of Marlon K. Schafer
Sent: Friday, December 19, 2008 9:21 AM
To: WISPA General List
Cc: caleaquesti...@wispa.org
Subject: Re: [WISPA CALEA Questions] [WISPA] Trango and CALEA

You'll just have to drop a tap in right behind the AP.

If you have client to client allowed I have no idea how to help you.

Anyone else have any ideas for Josh?  (remember to hit reply all) marlon

- Original Message -
From: Josh Luthman j...@imaginenetworksllc.com
To: WISPA General List wireless@wispa.org
Sent: Wednesday, December 17, 2008 8:50 AM
Subject: [WISPA] Trango and CALEA


 Has anyone got any ideas on how to use Trango's p2mp equipment and support
 CALEA?

 Josh Luthman
 Office: 937-552-2340
 Direct: 937-552-2343
 1100 Wayne St
 Suite 1337
 Troy, OH 45373

 Those who don't understand UNIX are condemned to reinvent it, poorly.
 --- Henry Spencer





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[WISPA] Fw: [WISPA CALEA Questions] Trango and CALEA

2008-12-19 Thread Marlon K. Schafer
Jesse is one of the main writers of the WISPA CALEA standard.
marlon

- Original Message - 
From: Jesse Norell je...@kci.net
To: Josh Luthman j...@imaginenetworksllc.com
Cc: CALEA Questions caleaquesti...@wispa.org
Sent: Friday, December 19, 2008 7:32 AM
Subject: Re: [WISPA CALEA Questions] [WISPA] Trango and CALEA


 On Fri, 2008-12-19 at 09:57 -0500, Josh Luthman wrote:
 So as long as you offer the data they ask regardless of what you
 actually collect that is acceptable?

  Correct, you can over collect data, then you filter out just what
 you need and only give them that.  And if you're following a standard
 like WCS-IPNA, you would make/record the checksums on only the data you
 present the LEA.


 Josh Luthman
 Office: 937-552-2340
 Direct: 937-552-2343
 1100 Wayne St
 Suite 1337
 Troy, OH 45373

 Those who don't understand UNIX are condemned to reinvent it, poorly.
 --- Henry Spencer


 On Fri, Dec 19, 2008 at 9:53 AM, Jeff Broadwick jeffl...@comcast.net
 wrote:
 Not if you have a collector behind the tap.  You can still
 filter out the
 traffic that you don't need for the warrant.

 Jeff


 -Original Message-
 From: wireless-boun...@wispa.org
 [mailto:wireless-boun...@wispa.org] On
 Behalf Of Josh Luthman
 Sent: Friday, December 19, 2008 9:50 AM
 To: WISPA General List


 Subject: Re: [WISPA] Trango and CALEA

 That was my only idea, however that includes data from other
 CPE radios
 which voids the rules of engagement :/

 On 12/19/08, Jeff Broadwick jeffl...@comcast.net wrote:
  That would be my suggestion.  That's radio vendor neutral.
 
  Jeff
 
 
  -Original Message-
  From: caleaquestions-boun...@wispa.org
  [mailto:caleaquestions-boun...@wispa.org] On Behalf Of
 Marlon K.
  Schafer
  Sent: Friday, December 19, 2008 9:21 AM
  To: WISPA General List
  Cc: caleaquesti...@wispa.org
  Subject: Re: [WISPA CALEA Questions] [WISPA] Trango and
 CALEA
 
  You'll just have to drop a tap in right behind the AP.
 
  If you have client to client allowed I have no idea how to
 help you.
 
  Anyone else have any ideas for Josh?  (remember to hit reply
 all)
  marlon
 
  - Original Message -
  From: Josh Luthman j...@imaginenetworksllc.com
  To: WISPA General List wireless@wispa.org
  Sent: Wednesday, December 17, 2008 8:50 AM
  Subject: [WISPA] Trango and CALEA
 
 
  Has anyone got any ideas on how to use Trango's p2mp
 equipment and
  support CALEA?
 
  Josh Luthman
  Office: 937-552-2340
  Direct: 937-552-2343
  1100 Wayne St
  Suite 1337
  Troy, OH 45373
 
  Those who don't understand UNIX are condemned to reinvent
 it, poorly.
  --- Henry Spencer
 
 
 
 
 
 --
  --
  
  WISPA Wants You! Join today!
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 --
 Josh Luthman
 Office: 937-552-2340
 Direct: 937-552-2343
 1100 Wayne St
 Suite 1337
 Troy, OH 45373

 Those who don't understand UNIX are condemned to reinvent it,
 poorly.
 --- Henry Spencer


 
 
 
 WISPA Wants You! Join today!
 http://signup.wispa.org

[WISPA] Calea compliance contractors

2008-11-25 Thread Christopher Orr
Hi all-

I'm just curious if anyone has a contact for someone that is
a CALEA compliance contractor.

Essentially we are looking for a third party that can verify
compliance.

Hit me offlist, please.

Regards,
-chris



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Re: [WISPA] Calea compliance contractors

2008-11-25 Thread Marlon K. Schafer (509) 982-2181
Hi Chris,

Butch would be a good place to start.  I've also cc'd the rest of the WISPA 
calea team.  Maybe there are people on there that do things I don't know 
about.

laters,
Marlon
(509) 982-2181
(408) 907-6910 (Vonage)Consulting services
42846865 (icq)WISP Operator since 1999!
[EMAIL PROTECTED]
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam



- Original Message - 
From: Christopher Orr [EMAIL PROTECTED]
To: wireless@wispa.org
Sent: Tuesday, November 25, 2008 9:42 AM
Subject: [WISPA] Calea compliance contractors


 Hi all-

 I'm just curious if anyone has a contact for someone that is
 a CALEA compliance contractor.

 Essentially we are looking for a third party that can verify
 compliance.

 Hit me offlist, please.

 Regards,
 -chris


 
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Re: [WISPA] CALEA

2007-11-30 Thread Mark Nash
The info in this post about being paid for this service is important to us
smaller WISPs.  This means that we CAN invest some small amount in
equipment, just as we would deploy an AP to gain customers.  Then, over
time, we charge for the intercepts we receive and eventually can recover the
expense.

We can look at this as a marketable service to law enforcement.  Thinking on
the extreme hillarious side of it, we can even make our LEAs aware that we
HAVE this capability.

Message to all LEAs:
We are here and ready, so think of using this method of law enforcement
more often than not. Send us your subpoenas...we are not afraid...along with
your billing address, of course.

;)

PEOPLE THIS IS MEANT TO BE FUNNY, OK???

Mark Nash
UnwiredOnline.Net
350 Holly Street
Junction City, OR 97448
http://www.uwol.net
541-998-
541-998-5599 fax

- Original Message - 
From: Butch Evans [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Friday, November 30, 2007 8:32 AM
Subject: RE: [WISPA] CALEA


 On Fri, 30 Nov 2007, Jeff Broadwick wrote:

 1.  The ISP will know a actual intercept subpoena is coming before
 they receive it.

 Actually, in a couple of cases, this was true.  In the others, the
 subpoena came without any notice.

 3.  The LEA would like the ISP to have all the CALEA I's dotted
 and T's crossed, but are willing to work with a cooperative
 provider.

 This is the main point of the post I made.  They are willing to work
 with us, because we have something they need.

 Can you verify that they ISPs got their direct expenses back from
 the LEAs? That would be valuable information to have!

 I do know in one case, the ISP did get paid.  He only billed the LEA
 for my fees, plus some other small expense, though I don't recall
 what it was for.  If I recall correctly, the total bill was about
 $800.

 I was told by a law enforcement agent that Verizon charges something
 like $1250 + some amount per day for each tap.  I don't recall the
 actual fees, but it was close to that amount.

 I DO believe that the LEAs will become more technically aware over
 time.  I also believe that they will be less forgiving of providers
 who do not have a CALEA plan over time.

 This is still new to both law enforcement and WISPs.  I agree that
 over time, those that are not capable of providing the information
 will begin to see themselves in trouble.

 -- 
 Butch Evans
 Network Engineering and Security Consulting
 573-276-2879
 http://www.butchevans.com/
 My calendar: http://tinyurl.com/y24ad6
 Training Partners: http://tinyurl.com/smfkf
 Mikrotik Certified Consultant
 http://www.mikrotik.com/consultants.html


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Re: [WISPA] CALEA

2007-11-30 Thread Butch Evans

On Fri, 30 Nov 2007, Frank Muto wrote:

I have a question though you may or may be able to answer it. In 
point 1, you said you gave the LEA information on how to word their 
subpoena? Was this knowledge based on an attorneys consult? I'll 
assume it may have been unless you are an attorney yourself.


Perhaps I worded that incorrectly.  What they asked for in the first 
subpoena was not technically possible to provide because they asked 
about a NAT address and they cannot allow us to provide them a list 
of 200 names.  I simply explained to him how we could go about 
limiting the information and he got the appropriate subpoenas worded 
in a way that allowed us to gather the information he needed.


From a procedural standpoint, it would have been much easier if he 
had let us help him understand that in the first place before he got 
the first subpoena, which was useless.


Secondly, why would an attorney or anyone provide legal consult 
to the LEA? The DOJ has all the required information any LEA needs 
to obtain the information they need in an investigation. Most of it 
is basically fill in the blank and the forms have multiple QA to 
write up the subpoena.


My consultation with them was not legal in natureit was 
technical.  Either way, I specifically recommended that my customers 
seek legal council regarding the information they are providing the 
LEA.  I don't know if they did that, but I did recommend that.


Having gone through enough of this over the past couple years, I 
have doubts that helping an LEA is in your best interest. How do 
you warrant or have legal standing on telling an LEA that their 
subpoena does not have the correct information for the request?


They asked for something that was not technically possible to 
provide.  It is that simple.  We could have given them the names of 
200+ people, but that would not help them, and could have hurt their 
case.  Whether it is CALEA or some other statute that the subpoena 
is based on, we, as citizens, have a duty to provide the information 
they are requesting under the law.  I don't want to rehash this 
whole idea of whether it is in our best interest or not.  The law is 
the law.


It is up to the LEA to get the proper legal consult they need when 
writing up a subpoena and or warrant to present to the court.


Not just legal consult, but technical.  I don't mind if they get the 
technical part from me...it's what I do for a living.  ;-)


--
Butch Evans
Network Engineering and Security Consulting
573-276-2879
http://www.butchevans.com/
My calendar: http://tinyurl.com/y24ad6
Training Partners: http://tinyurl.com/smfkf
Mikrotik Certified Consultant
http://www.mikrotik.com/consultants.html



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RE: [WISPA] CALEA

2007-11-30 Thread Butch Evans

On Fri, 30 Nov 2007, Jeff Broadwick wrote:

1.  The ISP will know a actual intercept subpoena is coming before 
they receive it.


Actually, in a couple of cases, this was true.  In the others, the 
subpoena came without any notice.


3.  The LEA would like the ISP to have all the CALEA I's dotted 
and T's crossed, but are willing to work with a cooperative 
provider.


This is the main point of the post I made.  They are willing to work 
with us, because we have something they need.


Can you verify that they ISPs got their direct expenses back from 
the LEAs? That would be valuable information to have!


I do know in one case, the ISP did get paid.  He only billed the LEA 
for my fees, plus some other small expense, though I don't recall 
what it was for.  If I recall correctly, the total bill was about 
$800.


I was told by a law enforcement agent that Verizon charges something 
like $1250 + some amount per day for each tap.  I don't recall the 
actual fees, but it was close to that amount.


I DO believe that the LEAs will become more technically aware over 
time.  I also believe that they will be less forgiving of providers 
who do not have a CALEA plan over time.


This is still new to both law enforcement and WISPs.  I agree that 
over time, those that are not capable of providing the information 
will begin to see themselves in trouble.


--
Butch Evans
Network Engineering and Security Consulting
573-276-2879
http://www.butchevans.com/
My calendar: http://tinyurl.com/y24ad6
Training Partners: http://tinyurl.com/smfkf
Mikrotik Certified Consultant
http://www.mikrotik.com/consultants.html



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RE: [WISPA] CALEA

2007-11-30 Thread Larry Yunker
Comments Below...

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Frank Muto
Sent: Friday, November 30, 2007 8:37 AM
To: WISPA General List
Subject: Re: [WISPA] CALEA

I have a question though you may or may be able to answer it. In point 1,
you said you gave the LEA information on how to 
word their subpoena? Was this knowledge based on an attorneys consult? I'll
assume it may have been unless you are an 
attorney yourself.

Secondly, why would an attorney or anyone provide legal consult to the
LEA? The DOJ has all the required information any 
LEA needs to obtain the information they need in an investigation. Most of
it is basically fill in the blank and the forms 
have multiple QA to write up the subpoena.

Having gone through enough of this over the past couple years, I have doubts
that helping an LEA is in your best interest. 
How do you warrant or have legal standing on telling an LEA that their
subpoena does not have the correct information for the 
request?

It is up to the LEA to get the proper legal consult they need when writing
up a subpoena and or warrant to present to the 
court.

- Comments --

If I am not mistaken, when you are being asked to provide information in a
legal matter in which you are not a named-party in the legal action, you are
being placed in the position of a witness.

If a witness divulges information which proves to be harmful to one of the
parties in the action AND if the information which is divulged is NOT
protected as being required under subpoena, then the witness could potential
open themselves up for a civil lawsuit with claims of libel, slander,
defamation, wrongful interference, etc.

So, it is NOT uncommon or unwise for a witness to seek legal counsel before
disclosing information under a subpoena.  I don't know if a witness' lawyer
could coach the requesting party in the wording of the subpoena.  On the
other hand, I'm quite certain that IF a witness felt that the information
that they held was pertinent and the witness wanted clarification on whether
they could divulge the information under the subpoena, they could request a
hearing before the judge in the pending matter.  The judge could do an
in-camera review to determine what stays and what goes.  Then it's up to the
judge to tell the requesting party if and to what extent their subpoena
needs to be modified.

Larry Yunker
Network Consultant  Law Student
[EMAIL PROTECTED]

Disclaimer: The information contained in this message is not to be
considered legal advice.  I am not a lawyer (yet) and therefore I am not in
a position to provide legal advice.  






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RE: [WISPA] CALEA

2007-11-30 Thread Butch Evans

On Fri, 30 Nov 2007, Larry Yunker wrote:

If I am not mistaken, when you are being asked to provide 
information in a legal matter in which you are not a named-party in 
the legal action, you are being placed in the position of a 
witness.


Exactly.  This is where the duty that I mentioned in my response 
to Frank comes from.  If we have information regarding illegal 
behaviour, we should provide that information to law enforcement. 
I'm gonna stop now with this line of thinking...it leads down a long 
dark road.  :-)


So, it is NOT uncommon or unwise for a witness to seek legal 
counsel before disclosing information under a subpoena.  I don't 
know if a witness' lawyer


As I said to Frank, my first recommendation to those WISPs who 
called for assistance was to talk to their attorney to let them 
handle the legal part of it.  I am just being hired to handle the 
technical parts and am not qualified to provide legal advice.


--
Butch Evans
Network Engineering and Security Consulting
573-276-2879
http://www.butchevans.com/
My calendar: http://tinyurl.com/y24ad6
Training Partners: http://tinyurl.com/smfkf
Mikrotik Certified Consultant
http://www.mikrotik.com/consultants.html



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RE: [WISPA] CALEA

2007-11-30 Thread Jeff Broadwick
According to the FBI, they have no interest in receiving real-time streamed
data, despite the requirement in the standard.  They want capture and
send/retrieve.   

Our understanding is that the FBI will challenge that part of the standard
once the WISPA Standard is ratified.  That will give them the alternative
they have been looking for.  We are very close to sending the WISPA Standard
to the FBI.  They have been part of the process all along, so ratification
should not be a major task.

Jeff


-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Jeromie Reeves
Sent: Friday, November 30, 2007 8:33 AM
To: WISPA General List
Subject: Re: [WISPA] CALEA

It looks like the FCC making us be CALEA compliant was a total waste of time
 effort (on both parties sides) and only made a atmosphere of fear. It also
sounds like while they filed for information that has classically been
available pre-calea, has anyone had to comply with the real time streaming
section or the remote data logging and can share the experience?


On 11/30/07, Butch Evans [EMAIL PROTECTED] wrote:
 I just wanted to make a brief post relating a few experiences relating 
 to the CALEA scare that was recently the talk of the town (so to 
 speak).  I should preface this post with a bit of information that 
 will give some insight into how common (or not) law enforcement will 
 or will not use CALEA to get information from you/us.  I have about 
 225 customers in my database.  I work on a regular basis for about 
 15-20 of those each week.  Since April, I have worked 4 cases with my 
 customers (actually, it was 6, but 3 were related) that were filed as 
 CALEA actions.

 Of these cases, 3 of my customers were using Mikrotik and 1 was using 
 ImageStream.  I can't reveal anything related to the cases, but I 
 wanted to help people understand what kind of information we are being 
 asked for under CALEA, and what that translates to in terms of 
 capability requirements.

 1. The first subpeona wanted to know who had a specific IP at a 
 certain time and date.  That was all that was requested.  This 
 particular WISP has about 450 customers, and about 225 of those are 
 using private IPs that are natted at the border.  It so happened that 
 the IP we were requested information about was the NAT IP.  I called 
 the officer who had requested the data and explained the situation to 
 him.  After an hour or so, he understood that there is nothing we 
 could do without more information.  The case was an ongoing thing, and 
 he was tracking contact to a specific website, so we were able to 
 determine a specific customer who was using that website.  We did not 
 tell the officer who it was, but we DID explain how he needed to word 
 his subpoena so that we COULD get him what he wanted.  After he got 
 the legal jargon to match the technical requirements of our 
 capabilities, we were able to capture and provide him with the 
 communications he was needing.

 2. The next 3 were related to one another (sort of).  In this case, 
 the subpeona asked for customer billing records and login information 
 for the past year for 3 IP addresses.  We had part of this information 
 (this WISP used public IP addresses for all his customers).  Since the 
 subpeona requested historical information, we were somewhat limited in 
 what we could provide, but we did get the required information and LEA 
 was happy.

 3. The other 2 were not related but were similar.  They asked for 
 telephone information that the targets made between a couple of dates 
 in the past.  Since the WISPs in both cases were not the provider of 
 the VoIP (they were just the transport) service, we explained to the 
 LEA that the information they are seeking would not be available at 
 the WISP, eventually they went elsewhere for their information (I 
 guess), but the WISPs, in the end, did not provide ANY customer data 
 to the LEA.

 The point I am making here is that all of the information requested in 
 all 3 cases, was easily obtainable using equipment available within 
 the WISP networks already.  We used information that the Mikrotik 
 and/or Imagestream enabled us to gather, log files and RADIUS logs to 
 gather login information and capturing of data along with their 
 business records to answer all 6 subpeonas (7 if you count the one 
 that had to be re-done).

 In all cases, the law enforcement officer who was our first contact 
 was not technically capable of understanding what they wanted/needed, 
 but without fail, there WERE people at the agencies involved who were.  
 Of these subpeonas, 3 were from the FBI, 2 were local LE and 1 was 
 homeland security.

 Incidentally, none of these WISPs spent any extra money to be 
 compliant (other than some legal work that had to be done).  Billing 
 for my time cost less than $350 (much less in some cases) to help 
 gather necessary information.  All of these (I think) ended up billing 
 these costs

Re: [WISPA] CALEA

2007-11-30 Thread Frank Muto
I have a question though you may or may be able to answer it. In point 1, you said you gave the LEA information on how to 
word their subpoena? Was this knowledge based on an attorneys consult? I'll assume it may have been unless you are an 
attorney yourself.


Secondly, why would an attorney or anyone provide legal consult to the LEA? The DOJ has all the required information any 
LEA needs to obtain the information they need in an investigation. Most of it is basically fill in the blank and the forms 
have multiple QA to write up the subpoena.


Having gone through enough of this over the past couple years, I have doubts that helping an LEA is in your best interest. 
How do you warrant or have legal standing on telling an LEA that their subpoena does not have the correct information for the 
request?


It is up to the LEA to get the proper legal consult they need when writing up a subpoena and or warrant to present to the 
court.



Frank Muto
President
FSM Marketing Group, Inc










- Original Message - 
From: Butch Evans [EMAIL PROTECTED]

To: Wispa List wireless@wispa.org
Sent: Friday, November 30, 2007 3:57 AM
Subject: [WISPA] CALEA


I just wanted to make a brief post relating a few experiences relating to the CALEA scare that was recently the talk of 
the town (so to speak).  I should preface this post with a bit of information that will give some insight into how common 
(or not) law enforcement will or will not use CALEA to get information from you/us.  I have about 225 customers in my 
database.  I work on a regular basis for about 15-20 of those each week.  Since April, I have worked 4 cases with my 
customers (actually, it was 6, but 3 were related) that were filed as CALEA actions.


Of these cases, 3 of my customers were using Mikrotik and 1 was using ImageStream.  I can't reveal anything related to the 
cases, but I wanted to help people understand what kind of information we are being asked for under CALEA, and what that 
translates to in terms of capability requirements.


1. The first subpeona wanted to know who had a specific IP at a certain time and date.  That was all that was requested. 
This particular WISP has about 450 customers, and about 225 of those are using private IPs that are natted at the border. 
It so happened that the IP we were requested information about was the NAT IP.  I called the officer who had requested the 
data and explained the situation to him.  After an hour or so, he understood that there is nothing we could do without more 
information.  The case was an ongoing thing, and he was tracking contact to a specific website, so we were able to 
determine a specific customer who was using that website.  We did not tell the officer who it was, but we DID explain how 
he needed to word his subpoena so that we COULD get him what he wanted.  After he got the legal jargon to match the 
technical requirements of our capabilities, we were able to capture and provide him with the communications he was needing.


2. The next 3 were related to one another (sort of).  In this case, the subpeona asked for customer billing records and 
login information for the past year for 3 IP addresses.  We had part of this information (this WISP used public IP 
addresses for all his customers).  Since the subpeona requested historical information, we were somewhat limited in what we 
could provide, but we did get the required information and LEA was happy.


3. The other 2 were not related but were similar.  They asked for telephone information that the targets made between a 
couple of dates in the past.  Since the WISPs in both cases were not the provider of the VoIP (they were just the 
transport) service, we explained to the LEA that the information they are seeking would not be available at the WISP, 
eventually they went elsewhere for their information (I guess), but the WISPs, in the end, did not provide ANY customer 
data to the LEA.


The point I am making here is that all of the information requested in all 3 cases, was easily obtainable using equipment 
available within the WISP networks already.  We used information that the Mikrotik and/or Imagestream enabled us to gather, 
log files and RADIUS logs to gather login information and capturing of data along with their business records to answer all 
6 subpeonas (7 if you count the one that had to be re-done).


In all cases, the law enforcement officer who was our first contact was not technically capable of understanding what they 
wanted/needed, but without fail, there WERE people at the agencies involved who were.  Of these subpeonas, 3 were from the 
FBI, 2 were local LE and 1 was homeland security.


Incidentally, none of these WISPs spent any extra money to be compliant (other than some legal work that had to be done). 
Billing for my time cost less than $350 (much less in some cases) to help gather necessary information.  All of these (I 
think) ended up billing these costs to the LEA and as far as I know

RE: [WISPA] CALEA

2007-11-30 Thread Jeff Broadwick
Thanks for posting this Butch!  It illustrates a number of things that I've
believed from early on:

1.  The ISP will know a actual intercept subpoena is coming before they
receive it.
2.  The LEA staff requesting the subpoena are generally less technically
savvy than most service providers.
3.  The LEA would like the ISP to have all the CALEA I's dotted and T's
crossed, but are willing to work with a cooperative provider. 

Can you verify that they ISPs got their direct expenses back from the LEAs?
That would be valuable information to have!

I DO believe that the LEAs will become more technically aware over time.  I
also believe that they will be less forgiving of providers who do not have a
CALEA plan over time.

Regards,

Jeff


-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Butch Evans
Sent: Friday, November 30, 2007 3:57 AM
To: Wispa List
Subject: [WISPA] CALEA

I just wanted to make a brief post relating a few experiences relating to
the CALEA scare that was recently the talk of the town (so to speak).  I
should preface this post with a bit of information that will give some
insight into how common (or not) law enforcement will or will not use CALEA
to get information from you/us.  I have about 225 customers in my database.
I work on a regular basis for about 15-20 of those each week.  Since April,
I have worked 4 cases with my customers (actually, it was 6, but 3 were
related) that were filed as CALEA actions.

Of these cases, 3 of my customers were using Mikrotik and 1 was using
ImageStream.  I can't reveal anything related to the cases, but I wanted to
help people understand what kind of information we are being asked for under
CALEA, and what that translates to in terms of capability requirements.

1. The first subpeona wanted to know who had a specific IP at a certain time
and date.  That was all that was requested.  This particular WISP has about
450 customers, and about 225 of those are using private IPs that are natted
at the border.  It so happened that the IP we were requested information
about was the NAT IP.  I called the officer who had requested the data and
explained the situation to him.  After an hour or so, he understood that
there is nothing we could do without more information.  The case was an
ongoing thing, and he was tracking contact to a specific website, so we were
able to determine a specific customer who was using that website.  We did
not tell the officer who it was, but we DID explain how he needed to word
his subpoena so that we COULD get him what he wanted.  After he got the
legal jargon to match the technical requirements of our capabilities, we
were able to capture and provide him with the communications he was needing.

2. The next 3 were related to one another (sort of).  In this case, the
subpeona asked for customer billing records and login information for the
past year for 3 IP addresses.  We had part of this information (this WISP
used public IP addresses for all his customers).  Since the subpeona
requested historical information, we were somewhat limited in what we could
provide, but we did get the required information and LEA was happy.

3. The other 2 were not related but were similar.  They asked for telephone
information that the targets made between a couple of dates in the past.
Since the WISPs in both cases were not the provider of the VoIP (they were
just the transport) service, we explained to the LEA that the information
they are seeking would not be available at the WISP, eventually they went
elsewhere for their information (I guess), but the WISPs, in the end, did
not provide ANY customer data to the LEA.

The point I am making here is that all of the information requested in all 3
cases, was easily obtainable using equipment available within the WISP
networks already.  We used information that the Mikrotik and/or Imagestream
enabled us to gather, log files and RADIUS logs to gather login information
and capturing of data along with their business records to answer all 6
subpeonas (7 if you count the one that had to be re-done).

In all cases, the law enforcement officer who was our first contact was not
technically capable of understanding what they wanted/needed, but without
fail, there WERE people at the agencies involved who were.  Of these
subpeonas, 3 were from the FBI, 2 were local LE and 1 was homeland security.

Incidentally, none of these WISPs spent any extra money to be compliant
(other than some legal work that had to be done).  Billing for my time cost
less than $350 (much less in some cases) to help gather necessary
information.  All of these (I think) ended up billing these costs to the LEA
and as far as I know, they got their direct expenses back.

I got another call today to assist with a subpoena and it got me thinking
about the others.  I just thought this information may be useful/educational
to some on this list.

--
Butch Evans
Network Engineering and Security Consulting
573-276

[WISPA] CALEA

2007-11-30 Thread Butch Evans
I just wanted to make a brief post relating a few experiences 
relating to the CALEA scare that was recently the talk of the 
town (so to speak).  I should preface this post with a bit of 
information that will give some insight into how common (or not) law 
enforcement will or will not use CALEA to get information from 
you/us.  I have about 225 customers in my database.  I work on a 
regular basis for about 15-20 of those each week.  Since April, I 
have worked 4 cases with my customers (actually, it was 6, but 3 
were related) that were filed as CALEA actions.


Of these cases, 3 of my customers were using Mikrotik and 1 was 
using ImageStream.  I can't reveal anything related to the cases, 
but I wanted to help people understand what kind of information we 
are being asked for under CALEA, and what that translates to in 
terms of capability requirements.


1. The first subpeona wanted to know who had a specific IP at a 
certain time and date.  That was all that was requested.  This 
particular WISP has about 450 customers, and about 225 of those are 
using private IPs that are natted at the border.  It so happened 
that the IP we were requested information about was the NAT IP.  I 
called the officer who had requested the data and explained the 
situation to him.  After an hour or so, he understood that there is 
nothing we could do without more information.  The case was an 
ongoing thing, and he was tracking contact to a specific website, so 
we were able to determine a specific customer who was using that 
website.  We did not tell the officer who it was, but we DID explain 
how he needed to word his subpoena so that we COULD get him what he 
wanted.  After he got the legal jargon to match the technical 
requirements of our capabilities, we were able to capture and 
provide him with the communications he was needing.


2. The next 3 were related to one another (sort of).  In this case, 
the subpeona asked for customer billing records and login 
information for the past year for 3 IP addresses.  We had part of 
this information (this WISP used public IP addresses for all his 
customers).  Since the subpeona requested historical information, we 
were somewhat limited in what we could provide, but we did get the 
required information and LEA was happy.


3. The other 2 were not related but were similar.  They asked for 
telephone information that the targets made between a couple of 
dates in the past.  Since the WISPs in both cases were not the 
provider of the VoIP (they were just the transport) service, we 
explained to the LEA that the information they are seeking would not 
be available at the WISP, eventually they went elsewhere for their 
information (I guess), but the WISPs, in the end, did not provide 
ANY customer data to the LEA.


The point I am making here is that all of the information requested 
in all 3 cases, was easily obtainable using equipment available 
within the WISP networks already.  We used information that the 
Mikrotik and/or Imagestream enabled us to gather, log files and 
RADIUS logs to gather login information and capturing of data along 
with their business records to answer all 6 subpeonas (7 if you 
count the one that had to be re-done).


In all cases, the law enforcement officer who was our first contact 
was not technically capable of understanding what they 
wanted/needed, but without fail, there WERE people at the agencies 
involved who were.  Of these subpeonas, 3 were from the FBI, 2 were 
local LE and 1 was homeland security.


Incidentally, none of these WISPs spent any extra money to be 
compliant (other than some legal work that had to be done).  Billing 
for my time cost less than $350 (much less in some cases) to help 
gather necessary information.  All of these (I think) ended up 
billing these costs to the LEA and as far as I know, they got their 
direct expenses back.


I got another call today to assist with a subpoena and it got me 
thinking about the others.  I just thought this information may be 
useful/educational to some on this list.


--
Butch Evans
Network Engineering and Security Consulting
573-276-2879
http://www.butchevans.com/
My calendar: http://tinyurl.com/y24ad6
Training Partners: http://tinyurl.com/smfkf
Mikrotik Certified Consultant
http://www.mikrotik.com/consultants.html



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Re: [WISPA] CALEA

2007-11-30 Thread Jeromie Reeves
It looks like the FCC making us be CALEA compliant was a total waste
of time  effort (on both parties sides) and only made a atmosphere of
fear. It also sounds like while they filed for information that has
classically been available pre-calea, has anyone had to comply with
the real time streaming section or the remote data logging and can
share the experience?


On 11/30/07, Butch Evans [EMAIL PROTECTED] wrote:
 I just wanted to make a brief post relating a few experiences
 relating to the CALEA scare that was recently the talk of the
 town (so to speak).  I should preface this post with a bit of
 information that will give some insight into how common (or not) law
 enforcement will or will not use CALEA to get information from
 you/us.  I have about 225 customers in my database.  I work on a
 regular basis for about 15-20 of those each week.  Since April, I
 have worked 4 cases with my customers (actually, it was 6, but 3
 were related) that were filed as CALEA actions.

 Of these cases, 3 of my customers were using Mikrotik and 1 was
 using ImageStream.  I can't reveal anything related to the cases,
 but I wanted to help people understand what kind of information we
 are being asked for under CALEA, and what that translates to in
 terms of capability requirements.

 1. The first subpeona wanted to know who had a specific IP at a
 certain time and date.  That was all that was requested.  This
 particular WISP has about 450 customers, and about 225 of those are
 using private IPs that are natted at the border.  It so happened
 that the IP we were requested information about was the NAT IP.  I
 called the officer who had requested the data and explained the
 situation to him.  After an hour or so, he understood that there is
 nothing we could do without more information.  The case was an
 ongoing thing, and he was tracking contact to a specific website, so
 we were able to determine a specific customer who was using that
 website.  We did not tell the officer who it was, but we DID explain
 how he needed to word his subpoena so that we COULD get him what he
 wanted.  After he got the legal jargon to match the technical
 requirements of our capabilities, we were able to capture and
 provide him with the communications he was needing.

 2. The next 3 were related to one another (sort of).  In this case,
 the subpeona asked for customer billing records and login
 information for the past year for 3 IP addresses.  We had part of
 this information (this WISP used public IP addresses for all his
 customers).  Since the subpeona requested historical information, we
 were somewhat limited in what we could provide, but we did get the
 required information and LEA was happy.

 3. The other 2 were not related but were similar.  They asked for
 telephone information that the targets made between a couple of
 dates in the past.  Since the WISPs in both cases were not the
 provider of the VoIP (they were just the transport) service, we
 explained to the LEA that the information they are seeking would not
 be available at the WISP, eventually they went elsewhere for their
 information (I guess), but the WISPs, in the end, did not provide
 ANY customer data to the LEA.

 The point I am making here is that all of the information requested
 in all 3 cases, was easily obtainable using equipment available
 within the WISP networks already.  We used information that the
 Mikrotik and/or Imagestream enabled us to gather, log files and
 RADIUS logs to gather login information and capturing of data along
 with their business records to answer all 6 subpeonas (7 if you
 count the one that had to be re-done).

 In all cases, the law enforcement officer who was our first contact
 was not technically capable of understanding what they
 wanted/needed, but without fail, there WERE people at the agencies
 involved who were.  Of these subpeonas, 3 were from the FBI, 2 were
 local LE and 1 was homeland security.

 Incidentally, none of these WISPs spent any extra money to be
 compliant (other than some legal work that had to be done).  Billing
 for my time cost less than $350 (much less in some cases) to help
 gather necessary information.  All of these (I think) ended up
 billing these costs to the LEA and as far as I know, they got their
 direct expenses back.

 I got another call today to assist with a subpoena and it got me
 thinking about the others.  I just thought this information may be
 useful/educational to some on this list.

 --
 Butch Evans
 Network Engineering and Security Consulting
 573-276-2879
 http://www.butchevans.com/
 My calendar: http://tinyurl.com/y24ad6
 Training Partners: http://tinyurl.com/smfkf
 Mikrotik Certified Consultant
 http://www.mikrotik.com/consultants.html


 
 WISPA Wants You! Join today!
 http://signup.wispa.org/
 

 WISPA Wireless List: 

RE: [WISPA] CALEA (recovering costs) ???

2007-10-29 Thread Jeff Broadwick
In theory, you should be able to bill the government for your time/costs
incurred for THE INTERCEPT, not any recurring or upfront charges.  In
theory...

 

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Dylan Bouterse
Sent: Monday, October 29, 2007 1:33 PM
To: WISPA General List
Subject: [WISPA] CALEA (recovering costs) ???

I guess from the lack of response nobody is compensating for their CALEA
costs?...or maybe my email didn't make it to the list?

Dylan

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Dylan Bouterse
Sent: Friday, October 26, 2007 5:25 PM
To: WISPA General List
Subject: [WISPA] CALEA (recovering costs)

It was mentioned back during the CALEA hype that some had considered or did
add a CALEA fee on their Internet Service bills. I'm curious if this was
done and if it was successful (without upsetting customers or creating too
many billing inquiries). Feel free to reply off list if you don't want to
advertise your response to the general list.

Dylan




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[WISPA] CALEA (recovering costs) ???

2007-10-29 Thread Dylan Bouterse
I guess from the lack of response nobody is compensating for their CALEA
costs?...or maybe my email didn't make it to the list?

Dylan

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Dylan Bouterse
Sent: Friday, October 26, 2007 5:25 PM
To: WISPA General List
Subject: [WISPA] CALEA (recovering costs)

It was mentioned back during the CALEA hype that some had considered or
did add a CALEA fee on their Internet Service bills. I'm curious if this
was done and if it was successful (without upsetting customers or
creating too many billing inquiries). Feel free to reply off list if you
don't want to advertise your response to the general list.

Dylan



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Re: [WISPA] CALEA (recovering costs) ???

2007-10-29 Thread Martha Huizenga

Hi Dylan,

I am not compensating for this. I am not sure that customers would be 
appreciative or understand. Also, the costs that you are referring to 
could possibly happen only when you are given a subpoenaed unless you 
are paying a monthly fee for a product you bought from a vendor.


Martha

Dylan Bouterse wrote:

I guess from the lack of response nobody is compensating for their CALEA
costs?...or maybe my email didn't make it to the list?

Dylan

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Dylan Bouterse
Sent: Friday, October 26, 2007 5:25 PM
To: WISPA General List
Subject: [WISPA] CALEA (recovering costs)

It was mentioned back during the CALEA hype that some had considered or
did add a CALEA fee on their Internet Service bills. I'm curious if this
was done and if it was successful (without upsetting customers or
creating too many billing inquiries). Feel free to reply off list if you
don't want to advertise your response to the general list.

Dylan



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Re: [WISPA] CALEA (recovering costs) ???

2007-10-29 Thread George Rogato
I understood from a vendor who was looking to sell me a calea solution 
that they would bill us for the cost of each intercept, etc, but not 
expect us to pay them until we get re-reimbursed by the government.


Light bulb went off.



Jeff Broadwick wrote:

In theory, you should be able to bill the government for your time/costs
incurred for THE INTERCEPT, not any recurring or upfront charges.  In
theory...

 


-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Dylan Bouterse
Sent: Monday, October 29, 2007 1:33 PM
To: WISPA General List
Subject: [WISPA] CALEA (recovering costs) ???

I guess from the lack of response nobody is compensating for their CALEA
costs?...or maybe my email didn't make it to the list?

Dylan

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Dylan Bouterse
Sent: Friday, October 26, 2007 5:25 PM
To: WISPA General List
Subject: [WISPA] CALEA (recovering costs)

It was mentioned back during the CALEA hype that some had considered or did
add a CALEA fee on their Internet Service bills. I'm curious if this was
done and if it was successful (without upsetting customers or creating too
many billing inquiries). Feel free to reply off list if you don't want to
advertise your response to the general list.

Dylan




WISPA Wants You! Join today!
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WISPA Wireless List: wireless@wispa.org


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--
George Rogato

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RE: [WISPA] CALEA (recovering costs) ???

2007-10-29 Thread Marty Dougherty
One more question- I need 100Meg Ethernet (copper)as well- can you add a
card for that or is there a combo that will do 10/100/1000 copper?

MArfty

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Martha Huizenga
Sent: Monday, October 29, 2007 1:32 PM
To: WISPA General List
Subject: Re: [WISPA] CALEA (recovering costs) ???


Hi Dylan,

I am not compensating for this. I am not sure that customers would be 
appreciative or understand. Also, the costs that you are referring to 
could possibly happen only when you are given a subpoenaed unless you 
are paying a monthly fee for a product you bought from a vendor.

Martha

Dylan Bouterse wrote:
 I guess from the lack of response nobody is compensating for their 
 CALEA costs?...or maybe my email didn't make it to the list?

 Dylan

 -Original Message-
 From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] 
 On Behalf Of Dylan Bouterse
 Sent: Friday, October 26, 2007 5:25 PM
 To: WISPA General List
 Subject: [WISPA] CALEA (recovering costs)

 It was mentioned back during the CALEA hype that some had considered 
 or did add a CALEA fee on their Internet Service bills. I'm curious if

 this was done and if it was successful (without upsetting customers or

 creating too many billing inquiries). Feel free to reply off list if 
 you don't want to advertise your response to the general list.

 Dylan


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[WISPA] CALEA (recovering costs)

2007-10-26 Thread Dylan Bouterse
It was mentioned back during the CALEA hype that some had considered or
did add a CALEA fee on their Internet Service bills. I'm curious if this
was done and if it was successful (without upsetting customers or
creating too many billing inquiries). Feel free to reply off list if you
don't want to advertise your response to the general list.

Dylan





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[WISPA] CALEA FCC Comments

2007-06-21 Thread Peter R.

PLEADING CYCLE EXTENDED IN THE MATTER OF PETITION FOR EXPEDITED
RULEMAKING TO ESTABLISH TECHNICAL REQUIREMENTS AND STANDARDS
PURSUANT TO SECTION 107(b) OF THE COMMUNICATIONS ASSISTANCE FOR LAW
ENFORCEMENT ACT (CALEA)
RM-11376
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-2522A1.pdf
Comments Due: July 25, 2007
Reply Comments Due: September 25, 2007
On May 15, 2007, the United States Department of Justice, the Federal 
Bureau of Investigation,
and the Drug Enforcement Administration (“Petitioners”) filed a 
“Petition for Expedited Rulemaking”
requesting the Commission to initiate a proceeding to find that the 
J-STD-025-B standard published
jointly by the Telecommunication Industry Association and the Alliance 
for Telecommunications, is
deficient pursuant to Section 107(b) of the Communications Assistance 
for Law Enforcement Act
(“CALEA”), 47 U.S.C. 1006(b).1 Petitioners specifically contend that 
four additional or modified
intercept capabilities must be included in the J-STD-025-B with respect 
to CDMA2000 packet data
wireless services, pursuant to the requirements of CALEA Section 103(a), 
47 U.S.C. § 1002(a). These
capabilities are: packet activity reporting; provision of more granular 
mobile handset location
information at the beginning and end of a communication; service 
quality, including security,
performance and reliability requirements; and timing information (time 
stamping). Petitioners ask the
Commission to mandate these capabilities, adopt appropriate rules, and 
order telecommunications
carriers to provide the capabilities within twelve months after the 
effective date of a final Commission

order.
Petitioner’s CALEA Section 107(b) filing requires the Commission to 
undertake a detailed
analysis of complex technical and legal issues associated with each of 
the four intercept capabilities
identified in the petition. Although the Commission appreciates the need 
to move quickly to address the
petition, it is essential that commenters have the opportunity to 
develop a full and detailed record for the
Commission’s consideration. Accordingly, on its own motion and pursuant 
to delegated authority, the
Public Safety and Homeland Security Bureau hereby extends the comment 
and reply comment filing
dates in the above-referenced matter as follows: interested parties may 
file comments on or before July
25, 2007 and reply comments on or before September 25, 2007. See 47 
U.S.C. § 154(i); 47 C.F.R. §§

0.191, and 0.392.
The Commission expects that all parties will fully utilize this 
opportunity to carefully and
completely address in their filed comments all relevant issues. The 
Commission reiterates, however, its
desire to expeditiously address Petitioners’ request. No additional 
extensions of comment and reply

comment dates should be expected.2
All comment and reply comment filings should refer to RM-11376.
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[WISPA] CALEA solutions.

2007-05-17 Thread Marlon K. Schafer (509) 982-2181

Hi All,

The CALEA committee is currently working on a number of possible CALEA 
solutions for you guys.  These won't be a WISPA standard but should do the 
trick for you if you do get called upon before we can get a standard 
written.


As I get these from the folks we're working with (all solutions will be 
either from or looked over by the CALEA committee members, no endorsements 
etc. blah blah blah though) on the committee I'll get them added to the 
WISPA CALEA page so you can easily find them again.


Here's the first one I've gotten back from a committee member.  Yeah, I know 
this only talks about one companies solution, I'll add more as I get them. 
Also, in light of the recent self promotion thread please direct all issues 
to me directly.  It's MY decision to publicize the solutions that our 
committee members prefer.


ImageStream recently released new software for its routers that can be used
to perform CALEA intercepts with or without a TTP. The current ImageStream
Linux distribution supports direct LEA delivery with fan-out to multiple
collectors using the ATIS LAES intercept delivery protocol, which provides a
safe harbor for intercept compliance. This solution also includes a
collector module, which can be run on a standard Linux server to support
local capture-to-disk.

In the coming weeks, ImageStream plans to release a new product called
Intercept Manager, which will provision intercepts remotely to comply with
the CALEA confidentiality requirements that affect most midsize and large
carriers. Intercept Manager will also be available with a hard drive to
support capture-to-disk for those who prefer not build their own Linux
systems.

ImageStream routers support WAN and LAN interfaces from T1 through OC12, and
ethernet over copper and fiber. Prices for the entry-level Envoy router
start at $499. WISPs who already use ImageStream routers can simply upgrade
to the latest ImageStream Linux distribution, which includes the tools
required to perform CALEA intercepts.

As an alternative to buying new production routers, WISPs may use
ImageStream taps to passively tap LAN or WAN links for CALEA intercepts with
legacy equipment. An ImageStream router is connected to the tap and acts as
an out-of-band probe for intercept filtering and delivery. A tap and
probe solution like this for a single 10/100 ethernet segment lists for
under $1,300 including a year of technical support and warranty.

ImageStream is also offering an intensive 1-day training seminar on its
CALEA solutions, to be held concurrently with ICNA certification in Orlando,
Florida on June 18th, 2007. If you have any questions
about CALEA compliance solutions, please contact ImageStream at (800)
813-5123 x106 or e-mail [EMAIL PROTECTED]

Jeff Broadwick
Sales Manager, ImageStream
800-813-5123 x106 (US/Can)
+1 574-935-8484 x106  (Int'l)
+1 574-935-8488   (Fax)

Hope this helps some folks out.
Marlon
(509) 982-2181
(408) 907-6910 (Vonage)Consulting services
42846865 (icq)WISP Operator since 1999!
[EMAIL PROTECTED]
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam



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Re: [WISPA] What is WISPA? (CALEA timeline)

2007-05-17 Thread Peter R.

Sam Tetherow wrote:

I don't want to drag this topic up again, BUT ;)  Two years ago, did 
this apply to ISPs or just VOIP providers?  I don't remember anyone on 
the lists talking about CALEA being for anything other than VOICE in 
various forms, but maybe my memory is selective, wouldn't be the first 
and probably won't be the last time.



On March 10, 2004, DOJ filed a petition asking the Commission to declare 
that

broadband Internet access services and VoIP services are covered by CALEA.

It was a part of the original order:  
Adopted: August 5, 2005  Released: September 23, 2005

In May 2006, the second order was released answering specific questions.

- Peter
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[WISPA] CALEA FAQ Questions

2007-05-10 Thread Dawn DiPietro

Marlon,

I have been reading the WISPA CALEA FAQ and was a little concerned about 
question #10. If the LEA does not know who the suspect is using an open 
access point does this mean that everyone that has used that access 
point will have their data handed over to the LEA? It would seem that if 
the LEA is only allowed to receive the data requested in the subpoena 
this would be a violation.


As far as I can tell question #15 does not get answered in the paragraph 
following the question. It talks more about acceptable billing and the 
fact that WISPA might have a solution in the future.


One of the questions in section 23 asks Does the FBI speak for other 
LEA's?. Unless I am mistaken this question does not get answered.


Also the document says over and over again that the LEA's will work with 
WISP's, which sounds like there is no easy way this can always be done 
transparently with the current broadband equipment deployed by WISP's. 
So the workaround is the WISP should give them the all the data from the 
device in question and the LEA's will sort it out and separate it.


If I am out of line please let me know but if I have questions about the 
FAQ then I am guessing there are others that do too.


Regards,
Dawn DiPietro
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Re: [WISPA] CALEA FAQ Questions

2007-05-10 Thread Ryan Langseth
On Thu, 2007-05-10 at 09:37 -0400, Dawn DiPietro wrote:
 Marlon,
 
 I have been reading the WISPA CALEA FAQ and was a little concerned about 
 question #10. If the LEA does not know who the suspect is using an open 
 access point does this mean that everyone that has used that access 
 point will have their data handed over to the LEA? It would seem that if 
 the LEA is only allowed to receive the data requested in the subpoena 
 this would be a violation.

I asked a similar question in the Bear Hill webinar.  I had asked about
private IPs and how the request would be made to us, would it be an IP
or name, unfortunately it can be either one.  We would most likely need
to provide the data from that IP if that is how the request was made.
Now with a tap of a external IP of a private IP range, you would have to
provide the data from the inside of the network, so that they could
analyze it and determine what internal IP is the suspect.

I have only been working in this industry for a little under a year and
I have been amazed at the use of private IPs for customers.  We have
them setup here, in my opinion it cause more trouble than its worth  I
hope to move away from private IPs over the next year.  They will still
exist in our network for networking devices, but ideally no more
customers would get them.
 
 
 As far as I can tell question #15 does not get answered in the paragraph 
 following the question. It talks more about acceptable billing and the 
 fact that WISPA might have a solution in the future.
 
 One of the questions in section 23 asks Does the FBI speak for other 
 LEA's?. Unless I am mistaken this question does not get answered.
 
 Also the document says over and over again that the LEA's will work with 
 WISP's, which sounds like there is no easy way this can always be done 
 transparently with the current broadband equipment deployed by WISP's. 
 So the workaround is the WISP should give them the all the data from the 
 device in question and the LEA's will sort it out and separate it.
 
 If I am out of line please let me know but if I have questions about the 
 FAQ then I am guessing there are others that do too.
 
 Regards,
 Dawn DiPietro

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Re: [WISPA] CALEA FAQ Questions

2007-05-10 Thread Matt

I have been reading the WISPA CALEA FAQ and was a little concerned about
question #10. If the LEA does not know who the suspect is using an open
access point does this mean that everyone that has used that access
point will have their data handed over to the LEA? It would seem that if
the LEA is only allowed to receive the data requested in the subpoena
this would be a violation.


In the past WISP's have asked if there was anyway to keep users from
NATing and connecting more then 1 PC.  There is no way to block this
and no easy way to prevent or detect it.  From the ISP perspective
there is no way isolate single hotspot user since they all come in on
the same IP.  If the ISP has control and management of the hotspot
they may be able to isolate the traffic of a given mac but this would
not be reliable if they connect with a different laptop the next day.
Of course it depends what kind of hotspot and how its setup.

I would say your going to have to give the LEA all the traffic for the
hotspot and let them filter/figure out what they need.  Moral of the
story: open non-encrypted wireless routers are NOT secure to use.
Unless your a bad guy and just drive around tell you find one then do
your ill deeds there.

Just my opinion.

Matt
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Re: [WISPA] CALEA FAQ Questions

2007-05-10 Thread Lonnie Nunweiler

Do they issue search warrants for a whole apartment building because
they suspect someone living there is doing something bad?  It was my
understanding that a bit more info is required and it has to actually
have a person or persons in mind.  Why would data taps be treated any
differently?

Lonnie

On 5/10/07, Matt [EMAIL PROTECTED] wrote:

 I have been reading the WISPA CALEA FAQ and was a little concerned about
 question #10. If the LEA does not know who the suspect is using an open
 access point does this mean that everyone that has used that access
 point will have their data handed over to the LEA? It would seem that if
 the LEA is only allowed to receive the data requested in the subpoena
 this would be a violation.

In the past WISP's have asked if there was anyway to keep users from
NATing and connecting more then 1 PC.  There is no way to block this
and no easy way to prevent or detect it.  From the ISP perspective
there is no way isolate single hotspot user since they all come in on
the same IP.  If the ISP has control and management of the hotspot
they may be able to isolate the traffic of a given mac but this would
not be reliable if they connect with a different laptop the next day.
Of course it depends what kind of hotspot and how its setup.

I would say your going to have to give the LEA all the traffic for the
hotspot and let them filter/figure out what they need.  Moral of the
story: open non-encrypted wireless routers are NOT secure to use.
Unless your a bad guy and just drive around tell you find one then do
your ill deeds there.

Just my opinion.

Matt
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Lonnie Nunweiler
Valemount Networks Corporation
http://www.star-os.com/
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Re: [WISPA] CALEA FAQ Questions

2007-05-10 Thread Martha Huizenga
This is not the sense that I get from the meeting we had with the FBI. 
They will know who the target is and be issuing an order for that 
person. However, if they happen to live with several people all on one 
wireless network, then the traffic is going to be mixed most likely. The 
best you can do is give them the traffic at that IP. According to the 
FBI, it's just like when they tap phones. The are to listen to only the 
target conversations and not the other people in the home.


Lonnie Nunweiler wrote:

Do they issue search warrants for a whole apartment building because
they suspect someone living there is doing something bad?  It was my
understanding that a bit more info is required and it has to actually
have a person or persons in mind.  Why would data taps be treated any
differently?

Lonnie

On 5/10/07, Matt [EMAIL PROTECTED] wrote:
 I have been reading the WISPA CALEA FAQ and was a little concerned 
about
 question #10. If the LEA does not know who the suspect is using an 
open

 access point does this mean that everyone that has used that access
 point will have their data handed over to the LEA? It would seem 
that if

 the LEA is only allowed to receive the data requested in the subpoena
 this would be a violation.

In the past WISP's have asked if there was anyway to keep users from
NATing and connecting more then 1 PC.  There is no way to block this
and no easy way to prevent or detect it.  From the ISP perspective
there is no way isolate single hotspot user since they all come in on
the same IP.  If the ISP has control and management of the hotspot
they may be able to isolate the traffic of a given mac but this would
not be reliable if they connect with a different laptop the next day.
Of course it depends what kind of hotspot and how its setup.

I would say your going to have to give the LEA all the traffic for the
hotspot and let them filter/figure out what they need.  Moral of the
story: open non-encrypted wireless routers are NOT secure to use.
Unless your a bad guy and just drive around tell you find one then do
your ill deeds there.

Just my opinion.

Matt
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Re: [WISPA] CALEA FAQ Questions

2007-05-10 Thread Marlon K. Schafer (509) 982-2181

Hi Dawn,

Please let me preface this by saying that there are not always easy answers. 
And we can't always come up with a pre-made solution for every situation 
that may arise.  We've talked with the FBI about all of these issues.  We 
all know what the law says, and we all know what's actually possible.  They 
aren't always lined up in nice little rows with all of the i's dotted and 
t's crossed.


More below.
Marlon
(509) 982-2181
(408) 907-6910 (Vonage)Consulting services
42846865 (icq)WISP Operator since 1999!
[EMAIL PROTECTED]
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam



- Original Message - 
From: Dawn DiPietro [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Thursday, May 10, 2007 6:37 AM
Subject: [WISPA] CALEA FAQ Questions



Marlon,

I have been reading the WISPA CALEA FAQ and was a little concerned about 
question #10. If the LEA does not know who the suspect is using an open 
access point does this mean that everyone that has used that access point 
will have their data handed over to the LEA? It would seem that if the LEA 
is only allowed to receive the data requested in the subpoena this would 
be a violation.


We've talked about this a lot.  *I've* personally talked with the head of 
the FBI CALEA division about this issue both via email and phone.  It's one 
of the very first issues we talked about and why the WISPA standards effort 
is so important.  If we can clear it, things like this will fall under the 
safe harbor.


They (the FBI) know that some things just won't be possible/practical.  Lets 
use my office as an example (I've done this with them so don't go hollering 
from the mountains about how I'm being a fool, too late).  I have a FREE 
OPEN Linksys wireless router set up as a hotspot.  Anyone that comes to town 
can sit in my office, in their car out front, or soon on a picinic table 
that I'll provide, and get all the free internet that they need while they 
are in the area.  No charge.  No tracking, heck, I won't even know it's 
happened.


What happens when that IP addy shows up on a wire tap order?  I can't change 
the ap so that we can insert an MT unit or some other box that would allow 
an individual's tap.  Doing so would tip off the suspect.  There are only 
two ways to get the data.  One, tap the wireless transmissions and sort it 
all out on that side.  Not something I have the ability, expertise, tools 
etc. to do.  OR, we can just grab all of the data going to/from that device 
on the ethernet side.  The LEA will have to sort out the data streams on 
their own.  WE can't do it because we're not going to know exactly what data 
they are looking for.


It's not a perfect solution but it's all there is.  They'll have to do the 
same thing if the local Starbucks has a user that shows up somewhere.




As far as I can tell question #15 does not get answered in the paragraph 
following the question. It talks more about acceptable billing and the 
fact that WISPA might have a solution in the future.


The FAQ is only a starting point.  We took the major questions people had, 
condenced them and got the best answers we could.


We're also hanstrung a little bit because there are some things that we're 
not allowed to tell publicly.  Much more of that coming.  Might as well get 
ready to be even more frustrated by those of us on the committee telling you 
things that you can't verify other ways and we won't be able to tell you 
exactly what we're basing our statements on due to NDA's signed with the 
FBI.




One of the questions in section 23 asks Does the FBI speak for other 
LEA's?. Unless I am mistaken this question does not get answered.


They do and they don't.  They are the ones to approve a standard.  If they 
clear it, all other LEAs are bound by it.  But there may be things we are 
asked to do etc. that are not up to the FBI.




Also the document says over and over again that the LEA's will work with 
WISP's, which sounds like there is no easy way this can always be done 
transparently with the current broadband equipment deployed by WISP's. So 
the workaround is the WISP should give them the all the data from the 
device in question and the LEA's will sort it out and separate it.


There are likely going to be times when this is true.  The reason for CALEA 
is to make sure that the LEA can't get to things that they've not been 
specifically cleared to get.  I believe that sometimes they get things that 
they weren't looking for in physical searches too.  If they raid a house 
looking for stolen property and run into a meth lab, that doesn't mean that 
they shouldn't have gone into the house in the first place.  OR, if on their 
way to a bust they see a stolen car in your driveway, they just happened to 
be in the right place at the right time.


As I said before, we can all come up with more situations that don't fit the 
law than the law can possibly deal

Re: [WISPA] CALEA FAQ Questions

2007-05-10 Thread Sam Tetherow
This is one of the things that has always bothered me when it comes to 
wire tapping a data connection.  On a phone call it can be pretty easy 
to tell if your suspect is involved in the conversation, assuming they 
have not used a voice modulator.  But when it comes to a data 
connection, how do you know?


   Sam Tetherow
   Sandhills Wireless

Martha Huizenga wrote:
This is not the sense that I get from the meeting we had with the FBI. 
They will know who the target is and be issuing an order for that 
person. However, if they happen to live with several people all on one 
wireless network, then the traffic is going to be mixed most likely. 
The best you can do is give them the traffic at that IP. According to 
the FBI, it's just like when they tap phones. The are to listen to 
only the target conversations and not the other people in the home.


Lonnie Nunweiler wrote:

Do they issue search warrants for a whole apartment building because
they suspect someone living there is doing something bad?  It was my
understanding that a bit more info is required and it has to actually
have a person or persons in mind.  Why would data taps be treated any
differently?

Lonnie

On 5/10/07, Matt [EMAIL PROTECTED] wrote:
 I have been reading the WISPA CALEA FAQ and was a little concerned 
about
 question #10. If the LEA does not know who the suspect is using an 
open

 access point does this mean that everyone that has used that access
 point will have their data handed over to the LEA? It would seem 
that if

 the LEA is only allowed to receive the data requested in the subpoena
 this would be a violation.

In the past WISP's have asked if there was anyway to keep users from
NATing and connecting more then 1 PC.  There is no way to block this
and no easy way to prevent or detect it.  From the ISP perspective
there is no way isolate single hotspot user since they all come in on
the same IP.  If the ISP has control and management of the hotspot
they may be able to isolate the traffic of a given mac but this would
not be reliable if they connect with a different laptop the next day.
Of course it depends what kind of hotspot and how its setup.

I would say your going to have to give the LEA all the traffic for the
hotspot and let them filter/figure out what they need.  Moral of the
story: open non-encrypted wireless routers are NOT secure to use.
Unless your a bad guy and just drive around tell you find one then do
your ill deeds there.

Just my opinion.

Matt
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Re: [WISPA] CALEA FAQ Questions

2007-05-10 Thread John Scrivner

Sam,
The evidence that LEAs collect is just part of a case. If a suspect is 
doing bad things then data will be collected. Next steps would usually 
involve a warrant to get the computer and have it looked over. I have 
seen other tools used by LEAs to gather evidence. I am guessing that 
data-taps will rarely be the basis for an entire case. If it is then 
defense attorneys better call on us because I can tell them how easy it 
is to make data traffic appear to come from one person or another 
without the person's knowledge. That is Hacker 101 type stuff. People 
sneaking access on open APs is obviously going to lead to some false 
data tap information in many cases. Maybe people will start locking down 
their home APs after that happens a few times.

Scriv


Sam Tetherow wrote:

This is one of the things that has always bothered me when it comes to 
wire tapping a data connection.  On a phone call it can be pretty easy 
to tell if your suspect is involved in the conversation, assuming they 
have not used a voice modulator.  But when it comes to a data 
connection, how do you know?


   Sam Tetherow
   Sandhills Wireless

Martha Huizenga wrote:

This is not the sense that I get from the meeting we had with the 
FBI. They will know who the target is and be issuing an order for 
that person. However, if they happen to live with several people all 
on one wireless network, then the traffic is going to be mixed most 
likely. The best you can do is give them the traffic at that IP. 
According to the FBI, it's just like when they tap phones. The are to 
listen to only the target conversations and not the other people in 
the home.


Lonnie Nunweiler wrote:


Do they issue search warrants for a whole apartment building because
they suspect someone living there is doing something bad?  It was my
understanding that a bit more info is required and it has to actually
have a person or persons in mind.  Why would data taps be treated any
differently?

Lonnie

On 5/10/07, Matt [EMAIL PROTECTED] wrote:

 I have been reading the WISPA CALEA FAQ and was a little 
concerned about
 question #10. If the LEA does not know who the suspect is using 
an open

 access point does this mean that everyone that has used that access
 point will have their data handed over to the LEA? It would seem 
that if
 the LEA is only allowed to receive the data requested in the 
subpoena

 this would be a violation.

In the past WISP's have asked if there was anyway to keep users from
NATing and connecting more then 1 PC.  There is no way to block this
and no easy way to prevent or detect it.  From the ISP perspective
there is no way isolate single hotspot user since they all come in on
the same IP.  If the ISP has control and management of the hotspot
they may be able to isolate the traffic of a given mac but this would
not be reliable if they connect with a different laptop the next day.
Of course it depends what kind of hotspot and how its setup.

I would say your going to have to give the LEA all the traffic for the
hotspot and let them filter/figure out what they need.  Moral of the
story: open non-encrypted wireless routers are NOT secure to use.
Unless your a bad guy and just drive around tell you find one then do
your ill deeds there.

Just my opinion.

Matt
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[WISPA] calea notes

2007-05-08 Thread Matt Liotta
Is there a standard for the captured data and do you have to use it to 
be CALEA compliant?


Individual carriers are free to choose any technical solution that meets 
the assistance capability
requirements of CALEA, whether based on an industry standard or not.  
Carriers, therefore, have some
degree of flexibility in deciding how they will comply with the section 
103 requirements.20  Subsection
107(a)(2) of CALEA contains a safe harbor provision, stating that [a] 
telecommunications carrier shall
be found to be in compliance with the assistance capability requirements 
under section 103, and a
manufacturer of telecommunications transmission or switching equipment 
or a provider of
telecommunications support services shall be found to be in compliance 
with section 106, if the carrier,
manufacturer, or support service provider is in compliance with publicly 
available technical requirements or
standards adopted by an industry association or standard-setting 
organization, or by the Commission under

subsection (b), to meet the requirements of section 103.

The above demonstrates that no standard is required. However, if you 
want safe harbor then you really need to use a standard. To date, only 
ATIS's standard has been approved for safe harbor. Any additional 
standards need to be submitted for review and approval. My understanding 
is the DoJ is the agency that must ultimately sign off as the FBI's sign 
off does not get you all the way.


Is WISPA going to have an approved standard that provides safe harbor in 
time for Monday? If you aren't waiting on WISPA, ask your CALEA vendor 
is they are using the ATIS standard. If not, find out if they will 
provide a written statement regarding safe harbor. If you can't get safe 
harbor through using a CALEA vendor then why not just take your chances 
with PCAP? Ask your attorney.


I spoke with a number of CALEA vendors today and most seem willing to 
admit that you can't achieve safe harbor with their equipment. Watch out 
for limited liability clauses like the following:


SOLERA NETWORKS, INC. IS NOT RESPONSIBLE FOR YOUR ORGANIZATION'S 
COMPLIANCE WITH CALEA. SOLERA NETWORKS, INC. WILL NOT PAY ANY FEES, 
FINES, OR OTHER COSTS ASSOCIATED WITH YOUR COMPLIANCE EFFORTS




Here are some interesting stats from 2004 regarding intercepts. One can 
only assume the numbers will increase dramatically after May 14th.


Authorized intercept orders:  1,710
   Federal:  730
   State:  980

Average duration:  43 days

Longest duration:  390 days

Average cost:  $63,011

-Matt
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Re: [WISPA] CALEA Question

2007-05-07 Thread Ross Cornett
We use a DLINK hotspot router that emails me every connect and disconnect 
from our hotels.  The FBI could take that log and compare it to room number 
and date of stay and they can find their man that way... FYI



- Original Message - 
From: Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Friday, May 04, 2007 12:57 PM
Subject: Re: [WISPA] CALEA Question



There will likely be cases where that's impossible.

Lets say that I have a customer that's a hotel.  They, at first, only know 
the ip addy or mac addy.  A subpoena comes to me looking for info on the 
user in question.  There's no way to use the hotel's Linksys hardware to 
do the tap to find the specific think that LEA is looking for.  Can't 
change the network because any action on our side tips off the suspect.


In some cases it won't be possible to filter out all info.  Especially if 
we don't know what we're looking for (which we won't and shouldn't) as far 
as specific data goes.


I talked to the head of the FBI's CALEA group for about an hour again 
yesterday.  They know full well that there are just some things that can't 
be done.  At the end of the day, the just need our help when and where we 
can give it to them.  There are far too many possibilities to deal with 
every single possible situation, we know that, they know that.


As long as we make a real effort to help I don't think we have to worry 
about getting in trouble.  It's those that thumb their noses that will run 
enforcement risks.


I was told that there has NEVER been an enforcement issue occur.

laters,
Marlon
(509) 982-2181
(408) 907-6910 (Vonage)Consulting services
42846865 (icq)WISP Operator since 
1999!

[EMAIL PROTECTED]
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam



- Original Message - 
From: Dawn DiPietro [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Friday, May 04, 2007 3:48 AM
Subject: Re: [WISPA] CALEA Question



Marlon,

I was under the impression the providers are only supposed to send the 
LEA the data covered in the subpoena and no more.


Regards,
Dawn DiPietro


Marlon K. Schafer wrote:
Read the FAQ.  In some cases they may have to sort through ALL data to 
get at what they want.

marlon

- Original Message - From: Tom DeReggi 
[EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 9:12 AM
Subject: Re: [WISPA] CALEA Question



In my opinion, I don;t think it will fly because of NAT.
The law inforcement agrency needs to be able to differenciate what 
customer traffic is comming from, and if you use NAT for any of your 
customers, the facilities based upstream provider would have no way to 
identify the end user, and the WISP would become the customer and be 
liable. To many degrees of seperation at the upstream for the captured 
data to be meaningful.


Tom DeReggi
RapidDSL  Wireless, Inc
IntAirNet- Fixed Wireless Broadband


- Original Message - From: David E. Smith [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Wednesday, May 02, 2007 11:27 PM
Subject: Re: [WISPA] CALEA Question



The FCC wrote:

we conclude that establishments that
acquire broadband Internet access service from a facilities-based
provider to enable their patrons or customers to access the Internet
from their respective establishments are not considered 
facilities-based

broadband Internet access service providers

Hm.

It'd be one heckuva stretch, but by reading the letter (as opposed to 
the spirit) of that paragraph, many smaller WISPs would automatically 
be exempt. I know my office has acquired broadband Internet access 
service from a facilities-based provider (our upstream ISP) and we're 
enabling our customers to access the Internet from their respective 
establishments (i.e. our customers pay for Internet at their homes or 
offices).


By the letter of that paragraph (and, to be fair, I haven't read all 
the context surrounding it) most any single-homed WISP would be 
exempt, as they could just say go talk to our upstream. (I doubt 
it'd work for multi-homed ISPs, as that would require multiple 
upstreams to be tapped and somehow synchronized, which is probably 
technically annoying.)


David Smith
MVN.net
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Re: [WISPA] CALEA Question

2007-05-07 Thread Lonnie Nunweiler

I don't think this is covered anyway, unless the guy is a permanent
resident at the hotel.  The subpoena will cover the suspect and any
known IP or MAC info and I believe would cover a particular physical
location.

I was told that a subpoena cannot simply say anything, anywhere.  It
has to get fairly specific, and traffic from a Motel is not very
specific.

Lonnie

On 5/4/07, Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] wrote:

There will likely be cases where that's impossible.

Lets say that I have a customer that's a hotel.  They, at first, only know
the ip addy or mac addy.  A subpoena comes to me looking for info on the
user in question.  There's no way to use the hotel's Linksys hardware to do
the tap to find the specific think that LEA is looking for.  Can't change
the network because any action on our side tips off the suspect.

In some cases it won't be possible to filter out all info.  Especially if we
don't know what we're looking for (which we won't and shouldn't) as far as
specific data goes.

I talked to the head of the FBI's CALEA group for about an hour again
yesterday.  They know full well that there are just some things that can't
be done.  At the end of the day, the just need our help when and where we
can give it to them.  There are far too many possibilities to deal with
every single possible situation, we know that, they know that.

As long as we make a real effort to help I don't think we have to worry
about getting in trouble.  It's those that thumb their noses that will run
enforcement risks.

I was told that there has NEVER been an enforcement issue occur.

laters,
Marlon
(509) 982-2181
(408) 907-6910 (Vonage)Consulting services
42846865 (icq)WISP Operator since 1999!
[EMAIL PROTECTED]
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam



- Original Message -
From: Dawn DiPietro [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Friday, May 04, 2007 3:48 AM
Subject: Re: [WISPA] CALEA Question


 Marlon,

 I was under the impression the providers are only supposed to send the LEA
 the data covered in the subpoena and no more.

 Regards,
 Dawn DiPietro


 Marlon K. Schafer wrote:
 Read the FAQ.  In some cases they may have to sort through ALL data to
 get at what they want.
 marlon

 - Original Message - From: Tom DeReggi
 [EMAIL PROTECTED]
 To: WISPA General List wireless@wispa.org
 Sent: Thursday, May 03, 2007 9:12 AM
 Subject: Re: [WISPA] CALEA Question


 In my opinion, I don;t think it will fly because of NAT.
 The law inforcement agrency needs to be able to differenciate what
 customer traffic is comming from, and if you use NAT for any of your
 customers, the facilities based upstream provider would have no way to
 identify the end user, and the WISP would become the customer and be
 liable. To many degrees of seperation at the upstream for the captured
 data to be meaningful.

 Tom DeReggi
 RapidDSL  Wireless, Inc
 IntAirNet- Fixed Wireless Broadband


 - Original Message - From: David E. Smith [EMAIL PROTECTED]
 To: WISPA General List wireless@wispa.org
 Sent: Wednesday, May 02, 2007 11:27 PM
 Subject: Re: [WISPA] CALEA Question


 The FCC wrote:
 we conclude that establishments that
 acquire broadband Internet access service from a facilities-based
 provider to enable their patrons or customers to access the Internet
 from their respective establishments are not considered
 facilities-based
 broadband Internet access service providers
 Hm.

 It'd be one heckuva stretch, but by reading the letter (as opposed to
 the spirit) of that paragraph, many smaller WISPs would automatically
 be exempt. I know my office has acquired broadband Internet access
 service from a facilities-based provider (our upstream ISP) and we're
 enabling our customers to access the Internet from their respective
 establishments (i.e. our customers pay for Internet at their homes or
 offices).

 By the letter of that paragraph (and, to be fair, I haven't read all
 the context surrounding it) most any single-homed WISP would be exempt,
 as they could just say go talk to our upstream. (I doubt it'd work
 for multi-homed ISPs, as that would require multiple upstreams to be
 tapped and somehow synchronized, which is probably technically
 annoying.)

 David Smith
 MVN.net
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Re: [WISPA] CALEA Question

2007-05-04 Thread Dawn DiPietro

Marlon,

I was under the impression the providers are only supposed to send the 
LEA the data covered in the subpoena and no more.


Regards,
Dawn DiPietro


Marlon K. Schafer wrote:
Read the FAQ.  In some cases they may have to sort through ALL data to 
get at what they want.

marlon

- Original Message - From: Tom DeReggi 
[EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 9:12 AM
Subject: Re: [WISPA] CALEA Question



In my opinion, I don;t think it will fly because of NAT.
The law inforcement agrency needs to be able to differenciate what 
customer traffic is comming from, and if you use NAT for any of your 
customers, the facilities based upstream provider would have no way 
to identify the end user, and the WISP would become the customer and 
be liable. To many degrees of seperation at the upstream for the 
captured data to be meaningful.


Tom DeReggi
RapidDSL  Wireless, Inc
IntAirNet- Fixed Wireless Broadband


- Original Message - From: David E. Smith [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Wednesday, May 02, 2007 11:27 PM
Subject: Re: [WISPA] CALEA Question



The FCC wrote:

we conclude that establishments that
acquire broadband Internet access service from a facilities-based
provider to enable their patrons or customers to access the Internet
from their respective establishments are not considered 
facilities-based

broadband Internet access service providers

Hm.

It'd be one heckuva stretch, but by reading the letter (as opposed 
to the spirit) of that paragraph, many smaller WISPs would 
automatically be exempt. I know my office has acquired broadband 
Internet access service from a facilities-based provider (our 
upstream ISP) and we're enabling our customers to access the 
Internet from their respective establishments (i.e. our customers 
pay for Internet at their homes or offices).


By the letter of that paragraph (and, to be fair, I haven't read all 
the context surrounding it) most any single-homed WISP would be 
exempt, as they could just say go talk to our upstream. (I doubt 
it'd work for multi-homed ISPs, as that would require multiple 
upstreams to be tapped and somehow synchronized, which is probably 
technically annoying.)


David Smith
MVN.net
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Re: [WISPA] CALEA Question

2007-05-04 Thread Marlon K. Schafer (509) 982-2181

There will likely be cases where that's impossible.

Lets say that I have a customer that's a hotel.  They, at first, only know 
the ip addy or mac addy.  A subpoena comes to me looking for info on the 
user in question.  There's no way to use the hotel's Linksys hardware to do 
the tap to find the specific think that LEA is looking for.  Can't change 
the network because any action on our side tips off the suspect.


In some cases it won't be possible to filter out all info.  Especially if we 
don't know what we're looking for (which we won't and shouldn't) as far as 
specific data goes.


I talked to the head of the FBI's CALEA group for about an hour again 
yesterday.  They know full well that there are just some things that can't 
be done.  At the end of the day, the just need our help when and where we 
can give it to them.  There are far too many possibilities to deal with 
every single possible situation, we know that, they know that.


As long as we make a real effort to help I don't think we have to worry 
about getting in trouble.  It's those that thumb their noses that will run 
enforcement risks.


I was told that there has NEVER been an enforcement issue occur.

laters,
Marlon
(509) 982-2181
(408) 907-6910 (Vonage)Consulting services
42846865 (icq)WISP Operator since 1999!
[EMAIL PROTECTED]
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam



- Original Message - 
From: Dawn DiPietro [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Friday, May 04, 2007 3:48 AM
Subject: Re: [WISPA] CALEA Question



Marlon,

I was under the impression the providers are only supposed to send the LEA 
the data covered in the subpoena and no more.


Regards,
Dawn DiPietro


Marlon K. Schafer wrote:
Read the FAQ.  In some cases they may have to sort through ALL data to 
get at what they want.

marlon

- Original Message - From: Tom DeReggi 
[EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 9:12 AM
Subject: Re: [WISPA] CALEA Question



In my opinion, I don;t think it will fly because of NAT.
The law inforcement agrency needs to be able to differenciate what 
customer traffic is comming from, and if you use NAT for any of your 
customers, the facilities based upstream provider would have no way to 
identify the end user, and the WISP would become the customer and be 
liable. To many degrees of seperation at the upstream for the captured 
data to be meaningful.


Tom DeReggi
RapidDSL  Wireless, Inc
IntAirNet- Fixed Wireless Broadband


- Original Message - From: David E. Smith [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Wednesday, May 02, 2007 11:27 PM
Subject: Re: [WISPA] CALEA Question



The FCC wrote:

we conclude that establishments that
acquire broadband Internet access service from a facilities-based
provider to enable their patrons or customers to access the Internet
from their respective establishments are not considered 
facilities-based

broadband Internet access service providers

Hm.

It'd be one heckuva stretch, but by reading the letter (as opposed to 
the spirit) of that paragraph, many smaller WISPs would automatically 
be exempt. I know my office has acquired broadband Internet access 
service from a facilities-based provider (our upstream ISP) and we're 
enabling our customers to access the Internet from their respective 
establishments (i.e. our customers pay for Internet at their homes or 
offices).


By the letter of that paragraph (and, to be fair, I haven't read all 
the context surrounding it) most any single-homed WISP would be exempt, 
as they could just say go talk to our upstream. (I doubt it'd work 
for multi-homed ISPs, as that would require multiple upstreams to be 
tapped and somehow synchronized, which is probably technically 
annoying.)


David Smith
MVN.net
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Re: [WISPA] CALEA Question

2007-05-03 Thread Peter R.

Tim Kery wrote:


Examples of these types of establishments may include some hotels,
coffee shops, schools, libraries, or book stores. DOJ has stated that it
has no desire to require such retail establishments to implement CALEA
solutions, DOJ Comments at 36, and we conclude that the public interest
at this time does not weigh in favor of subjecting such establishments
to CALEA.

So, Starbucks doesn't need to comply with CALEA but the service provider
that provides bandwidth to Starbucks does.

Hope this helps.

Tim Kery
BearHill Security, Inc.
[EMAIL PROTECTED]
 


Starbucks doesn't, but T-Mobile, the actual ISP does.
Joe's Cup-a-Joe does have to , but the ISP providing the service does.
SOME schools don't have to be because it is defined as a private network (see 
the ACE PDF on exemptions here: www.rad-info.net/fcc/ACE_CALEA_sum.pdf)

Commercial offering of Internet access means you need to be compliant.

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Re: [WISPA] CALEA Question

2007-05-03 Thread Peter R.

David E. Smith wrote:


The FCC wrote:


we conclude that establishments that
acquire broadband Internet access service from a facilities-based
provider to enable their patrons or customers to access the Internet
from their respective establishments are not considered facilities-based
broadband Internet access service providers


Hm.

It'd be one heckuva stretch, but by reading the letter (as opposed to 
the spirit) of that paragraph, many smaller WISPs would automatically 
be exempt. I know my office has acquired broadband Internet access 
service from a facilities-based provider (our upstream ISP) and we're 
enabling our customers to access the Internet from their respective 
establishments (i.e. our customers pay for Internet at their homes or 
offices).


By the letter of that paragraph (and, to be fair, I haven't read all 
the context surrounding it) most any single-homed WISP would be 
exempt, as they could just say go talk to our upstream. (I doubt 
it'd work for multi-homed ISPs, as that would require multiple 
upstreams to be tapped and somehow synchronized, which is probably 
technically annoying.)


David Smith
MVN.net


Why not check with a knowledgeable legal professional instead of guessing?

Susan Crawford, Kris Twomey, Chris Savage, Jim Baller, and the offices 
of Cole, Raywid  Braverman have written opinions that if you operate a 
router or switch and commercially sell internet, you must be CALEA 
compliant.


Now you can choose to ignore it, and say a prayer daily that Barney Fife 
or any other LEA officer does not knock on your door, but the ISP's who 
will see the most warrants are Residential ISP's. (Not much child porn 
or terrorrism happening at the work place). So, roll the dice.


Call an attorney for advice Or get on the call with Chris Savage of DWT 
on May 9.


--


Regards,

Peter Radizeski
RAD-INFO, Inc. - NSP Strategist
We Help ISPs Connect  Communicate
813.963.5884 
http://www.marketingIDEAguy.com



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Re: [WISPA] CALEA Question

2007-05-03 Thread David E. Smith
Peter R. wrote:

 Why not check with a knowledgeable legal professional instead of guessing?

That'd be my boss's department. :D

I'm just a pundit - full of opinions and hot air.

 Now you can choose to ignore it, and say a prayer daily that Barney Fife
 or any other LEA officer does not knock on your door

I'd encourage Barney Fife to knock on my door, I wouldn't mind having
his autograph. Remember him from Three's Company?

Edit: Apparently Don Knotts died last year. Now I'm sad. :(

David Smith
MVN.net
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Re: [WISPA] CALEA Question

2007-05-03 Thread Ross Cornett
I give up I just signed a contract to ensure my protection under CALEA. My 
hope is tht those that become compliant do not get underminded by those that 
have hidden in the bushes and took the risk upon themselves by not becoming 
compliant.


It appears that it is time to start charging a homeland security fee. 
Since we cannot authorize taxes, we can charge fees that will allow us to 
mange these cost.  By my figures, I will have to charge at least $1.53 per 
month per customer.  Since this doens't include dialup customers, my 
broadband customers will have to incurr this burden alone.


What are you thougths on this.


- Original Message - 
From: David E. Smith [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 10:42 AM
Subject: Re: [WISPA] CALEA Question



Peter R. wrote:

Why not check with a knowledgeable legal professional instead of 
guessing?


That'd be my boss's department. :D

I'm just a pundit - full of opinions and hot air.


Now you can choose to ignore it, and say a prayer daily that Barney Fife
or any other LEA officer does not knock on your door


I'd encourage Barney Fife to knock on my door, I wouldn't mind having
his autograph. Remember him from Three's Company?

Edit: Apparently Don Knotts died last year. Now I'm sad. :(

David Smith
MVN.net
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Re: [WISPA] CALEA Question

2007-05-03 Thread Tom DeReggi

In my opinion, I don;t think it will fly because of NAT.
The law inforcement agrency needs to be able to differenciate what customer 
traffic is comming from, and if you use NAT for any of your customers, the 
facilities based upstream provider would have no way to identify the end 
user, and the WISP would become the customer and be liable. To many degrees 
of seperation at the upstream for the captured data to be meaningful.


Tom DeReggi
RapidDSL  Wireless, Inc
IntAirNet- Fixed Wireless Broadband


- Original Message - 
From: David E. Smith [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Wednesday, May 02, 2007 11:27 PM
Subject: Re: [WISPA] CALEA Question



The FCC wrote:

we conclude that establishments that
acquire broadband Internet access service from a facilities-based
provider to enable their patrons or customers to access the Internet
from their respective establishments are not considered facilities-based
broadband Internet access service providers

Hm.

It'd be one heckuva stretch, but by reading the letter (as opposed to the 
spirit) of that paragraph, many smaller WISPs would automatically be 
exempt. I know my office has acquired broadband Internet access service 
from a facilities-based provider (our upstream ISP) and we're enabling 
our customers to access the Internet from their respective establishments 
(i.e. our customers pay for Internet at their homes or offices).


By the letter of that paragraph (and, to be fair, I haven't read all the 
context surrounding it) most any single-homed WISP would be exempt, as 
they could just say go talk to our upstream. (I doubt it'd work for 
multi-homed ISPs, as that would require multiple upstreams to be tapped 
and somehow synchronized, which is probably technically annoying.)


David Smith
MVN.net
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Re: [WISPA] CALEA Question ... fees

2007-05-03 Thread Peter R.

Ross Cornett wrote:

I give up I just signed a contract to ensure my protection under 
CALEA. My hope is tht those that become compliant do not get 
underminded by those that have hidden in the bushes and took the risk 
upon themselves by not becoming compliant.


It appears that it is time to start charging a homeland security fee. 
Since we cannot authorize taxes, we can charge fees that will allow us 
to mange these cost.  By my figures, I will have to charge at least 
$1.53 per month per customer.  Since this doens't include dialup 
customers, my broadband customers will have to incurr this burden alone.


What are you thougths on this.


Design a web page to explain the fee clearly and concisely.

Point all questions about CALEA to the FCC or FBI.

Emphasize it is a law; it is for homeland security; it is about child porn and 
terrorism - and it is to protect you.
All providers must follow these rules.

- Peter

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Re: [WISPA] CALEA Question

2007-05-03 Thread John Scrivner
I think you better just take a rate increase and chalk it up to 
increased expenses all the way around as opposed to creating a CALEA 
charge line item. Adding a fee as a line item could get you in trouble 
with the FTC if not approved as a legitimate added government fee (just 
my opinion, nothing to base this on other than my gut). Your fuel and 
electricity have jumped considerably I am sure. I am considering a rate 
increase over these added costs also. I see no way around it. I have 
never raised my rates in 10 years. Times are changing I am afraid.

Scriv


Ross Cornett wrote:

I give up I just signed a contract to ensure my protection under 
CALEA. My hope is tht those that become compliant do not get 
underminded by those that have hidden in the bushes and took the risk 
upon themselves by not becoming compliant.


It appears that it is time to start charging a homeland security fee. 
Since we cannot authorize taxes, we can charge fees that will allow us 
to mange these cost.  By my figures, I will have to charge at least 
$1.53 per month per customer.  Since this doens't include dialup 
customers, my broadband customers will have to incurr this burden alone.


What are you thougths on this.


- Original Message - From: David E. Smith [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 10:42 AM
Subject: Re: [WISPA] CALEA Question



Peter R. wrote:

Why not check with a knowledgeable legal professional instead of 
guessing?



That'd be my boss's department. :D

I'm just a pundit - full of opinions and hot air.

Now you can choose to ignore it, and say a prayer daily that Barney 
Fife

or any other LEA officer does not knock on your door



I'd encourage Barney Fife to knock on my door, I wouldn't mind having
his autograph. Remember him from Three's Company?

Edit: Apparently Don Knotts died last year. Now I'm sad. :(

David Smith
MVN.net
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RE: [WISPA] CALEA Question

2007-05-03 Thread Cliff Leboeuf
A few years ago, I added a line item to my invoices as follows...
Surcharge for Bellsouth, FCC and other regulatory compliance fees and
costs.

This added fee is based on what I think it cost me to comply with
reporting to the FCC, licensed links, and 'hidden' fees that the phone
company itemizes inexcess of the actual circuit costs.

This is no different than airlines and trucking companies adding 'fuel
surcharges' and the quick lube business charging me an 'environmental
disposal fee' when I have my oil changed.

I added $2.97 per month, at the time it was the same that Bellsouth was
charging for the USF on their 'itemized invoices.' I didn't loose one
customer, but did have to explain the reason to two and they completely
understood. That additional $3 for each DSL and wireless user was worth
those two explinations. I don't charge the fee for hosting or dialup
plans.

There is nothing wrong raising your prices to be competitive with the
'big boys!' :)

Cliff


-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of John Scrivner
Sent: Thursday, May 03, 2007 2:46 PM
To: WISPA General List
Subject: Re: [WISPA] CALEA Question

I think you better just take a rate increase and chalk it up to 
increased expenses all the way around as opposed to creating a CALEA 
charge line item. Adding a fee as a line item could get you in trouble 
with the FTC if not approved as a legitimate added government fee (just 
my opinion, nothing to base this on other than my gut). Your fuel and 
electricity have jumped considerably I am sure. I am considering a rate 
increase over these added costs also. I see no way around it. I have 
never raised my rates in 10 years. Times are changing I am afraid.
Scriv


Ross Cornett wrote:

 I give up I just signed a contract to ensure my protection under 
 CALEA. My hope is tht those that become compliant do not get 
 underminded by those that have hidden in the bushes and took the risk 
 upon themselves by not becoming compliant.

 It appears that it is time to start charging a homeland security fee. 
 Since we cannot authorize taxes, we can charge fees that will allow us

 to mange these cost.  By my figures, I will have to charge at least 
 $1.53 per month per customer.  Since this doens't include dialup 
 customers, my broadband customers will have to incurr this burden
alone.

 What are you thougths on this.


 - Original Message - From: David E. Smith [EMAIL PROTECTED]
 To: WISPA General List wireless@wispa.org
 Sent: Thursday, May 03, 2007 10:42 AM
 Subject: Re: [WISPA] CALEA Question


 Peter R. wrote:

 Why not check with a knowledgeable legal professional instead of 
 guessing?


 That'd be my boss's department. :D

 I'm just a pundit - full of opinions and hot air.

 Now you can choose to ignore it, and say a prayer daily that Barney 
 Fife
 or any other LEA officer does not knock on your door


 I'd encourage Barney Fife to knock on my door, I wouldn't mind having
 his autograph. Remember him from Three's Company?

 Edit: Apparently Don Knotts died last year. Now I'm sad. :(

 David Smith
 MVN.net
 -- 
 WISPA Wireless List: wireless@wispa.org

 Subscribe/Unsubscribe:
 http://lists.wispa.org/mailman/listinfo/wireless

 Archives: http://lists.wispa.org/pipermail/wireless/



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Re: [WISPA] CALEA Question

2007-05-03 Thread Ross Cornett

Sounds good thanks Sriv.


- Original Message - 
From: John Scrivner [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 2:46 PM
Subject: Re: [WISPA] CALEA Question


I think you better just take a rate increase and chalk it up to 
increased expenses all the way around as opposed to creating a CALEA 
charge line item. Adding a fee as a line item could get you in trouble 
with the FTC if not approved as a legitimate added government fee (just 
my opinion, nothing to base this on other than my gut). Your fuel and 
electricity have jumped considerably I am sure. I am considering a rate 
increase over these added costs also. I see no way around it. I have 
never raised my rates in 10 years. Times are changing I am afraid.

Scriv


Ross Cornett wrote:

I give up I just signed a contract to ensure my protection under 
CALEA. My hope is tht those that become compliant do not get 
underminded by those that have hidden in the bushes and took the risk 
upon themselves by not becoming compliant.


It appears that it is time to start charging a homeland security fee. 
Since we cannot authorize taxes, we can charge fees that will allow us 
to mange these cost.  By my figures, I will have to charge at least 
$1.53 per month per customer.  Since this doens't include dialup 
customers, my broadband customers will have to incurr this burden alone.


What are you thougths on this.


- Original Message - From: David E. Smith [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 10:42 AM
Subject: Re: [WISPA] CALEA Question



Peter R. wrote:

Why not check with a knowledgeable legal professional instead of 
guessing?



That'd be my boss's department. :D

I'm just a pundit - full of opinions and hot air.

Now you can choose to ignore it, and say a prayer daily that Barney 
Fife

or any other LEA officer does not knock on your door



I'd encourage Barney Fife to knock on my door, I wouldn't mind having
his autograph. Remember him from Three's Company?

Edit: Apparently Don Knotts died last year. Now I'm sad. :(

David Smith
MVN.net
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Re: [WISPA] CALEA Question

2007-05-03 Thread Marlon K. Schafer
If you decide to take advantage of companies that have solutions in place, 
you'll have to do what you have to do.


Know, however, that you do NOT have to follow anyone's standard!  You just 
have to be able to give the LEA the data they MAY ask for.


I've rounded up folks that know how to get the stream off of my routers and 
folks that know how to program the server to store the data till LEA can 
download it.


I have to pick up a managed switch or two but other than that, I'll cross my 
fingers and hope that I don't have to spend money complying till the WISPA 
effort is approved.


marlon

- Original Message - 
From: Ross Cornett [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 8:52 AM
Subject: Re: [WISPA] CALEA Question


I give up I just signed a contract to ensure my protection under CALEA. My 
hope is tht those that become compliant do not get underminded by those 
that have hidden in the bushes and took the risk upon themselves by not 
becoming compliant.


It appears that it is time to start charging a homeland security fee. 
Since we cannot authorize taxes, we can charge fees that will allow us to 
mange these cost.  By my figures, I will have to charge at least $1.53 per 
month per customer.  Since this doens't include dialup customers, my 
broadband customers will have to incurr this burden alone.


What are you thougths on this.


- Original Message - 
From: David E. Smith [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 10:42 AM
Subject: Re: [WISPA] CALEA Question



Peter R. wrote:

Why not check with a knowledgeable legal professional instead of 
guessing?


That'd be my boss's department. :D

I'm just a pundit - full of opinions and hot air.


Now you can choose to ignore it, and say a prayer daily that Barney Fife
or any other LEA officer does not knock on your door


I'd encourage Barney Fife to knock on my door, I wouldn't mind having
his autograph. Remember him from Three's Company?

Edit: Apparently Don Knotts died last year. Now I'm sad. :(

David Smith
MVN.net
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Re: [WISPA] CALEA Question

2007-05-03 Thread Marlon K. Schafer
Read the FAQ.  In some cases they may have to sort through ALL data to get 
at what they want.

marlon

- Original Message - 
From: Tom DeReggi [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 9:12 AM
Subject: Re: [WISPA] CALEA Question



In my opinion, I don;t think it will fly because of NAT.
The law inforcement agrency needs to be able to differenciate what 
customer traffic is comming from, and if you use NAT for any of your 
customers, the facilities based upstream provider would have no way to 
identify the end user, and the WISP would become the customer and be 
liable. To many degrees of seperation at the upstream for the captured 
data to be meaningful.


Tom DeReggi
RapidDSL  Wireless, Inc
IntAirNet- Fixed Wireless Broadband


- Original Message - 
From: David E. Smith [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Wednesday, May 02, 2007 11:27 PM
Subject: Re: [WISPA] CALEA Question



The FCC wrote:

we conclude that establishments that
acquire broadband Internet access service from a facilities-based
provider to enable their patrons or customers to access the Internet
from their respective establishments are not considered facilities-based
broadband Internet access service providers

Hm.

It'd be one heckuva stretch, but by reading the letter (as opposed to the 
spirit) of that paragraph, many smaller WISPs would automatically be 
exempt. I know my office has acquired broadband Internet access service 
from a facilities-based provider (our upstream ISP) and we're enabling 
our customers to access the Internet from their respective establishments 
(i.e. our customers pay for Internet at their homes or offices).


By the letter of that paragraph (and, to be fair, I haven't read all the 
context surrounding it) most any single-homed WISP would be exempt, as 
they could just say go talk to our upstream. (I doubt it'd work for 
multi-homed ISPs, as that would require multiple upstreams to be tapped 
and somehow synchronized, which is probably technically annoying.)


David Smith
MVN.net
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Re: [WISPA] CALEA Question

2007-05-03 Thread Marlon K. Schafer

We have a line item of:
Surcharge to cover the cost of a sales tax being charged against our fiber 
connection.  Or words to that effect.  We don't call it a tax, we 
specifically call it a surcharge.  I think that several out here do 
something similar.


We also charge a $10 trip charge anytime gas is over $2.50 per gallon in 
this area.  If it hits anywhere close to $4 I'll likely raise that to $15. 
People don't like it but they do understand.  Especially when nearly 
everyone else out here has also put on fuel charges.


The only good thing about current gas prices is that crop prices are also 
way up.  I'll take $3 fuel with $6 wheat any day :-)

marlon

- Original Message - 
From: John Scrivner [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 12:46 PM
Subject: Re: [WISPA] CALEA Question


I think you better just take a rate increase and chalk it up to increased 
expenses all the way around as opposed to creating a CALEA charge line 
item. Adding a fee as a line item could get you in trouble with the FTC if 
not approved as a legitimate added government fee (just my opinion, nothing 
to base this on other than my gut). Your fuel and electricity have jumped 
considerably I am sure. I am considering a rate increase over these added 
costs also. I see no way around it. I have never raised my rates in 10 
years. Times are changing I am afraid.

Scriv


Ross Cornett wrote:

I give up I just signed a contract to ensure my protection under CALEA. 
My hope is tht those that become compliant do not get underminded by 
those that have hidden in the bushes and took the risk upon themselves by 
not becoming compliant.


It appears that it is time to start charging a homeland security fee. 
Since we cannot authorize taxes, we can charge fees that will allow us to 
mange these cost.  By my figures, I will have to charge at least $1.53 
per month per customer.  Since this doens't include dialup customers, my 
broadband customers will have to incurr this burden alone.


What are you thougths on this.


- Original Message - From: David E. Smith [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 10:42 AM
Subject: Re: [WISPA] CALEA Question



Peter R. wrote:

Why not check with a knowledgeable legal professional instead of 
guessing?



That'd be my boss's department. :D

I'm just a pundit - full of opinions and hot air.

Now you can choose to ignore it, and say a prayer daily that Barney 
Fife

or any other LEA officer does not knock on your door



I'd encourage Barney Fife to knock on my door, I wouldn't mind having
his autograph. Remember him from Three's Company?

Edit: Apparently Don Knotts died last year. Now I'm sad. :(

David Smith
MVN.net
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Re: [WISPA] CALEA Question

2007-05-03 Thread George Rogato

gas 3.20 per gallon here. $95.00 to fill my truck yesterday.

Sheesh

Marlon K. Schafer wrote:

We have a line item of:
Surcharge to cover the cost of a sales tax being charged against our 
fiber connection.  Or words to that effect.  We don't call it a tax, we 
specifically call it a surcharge.  I think that several out here do 
something similar.


We also charge a $10 trip charge anytime gas is over $2.50 per gallon in 
this area.  If it hits anywhere close to $4 I'll likely raise that to 
$15. People don't like it but they do understand.  Especially when 
nearly everyone else out here has also put on fuel charges.


The only good thing about current gas prices is that crop prices are 
also way up.  I'll take $3 fuel with $6 wheat any day :-)

marlon

- Original Message - From: John Scrivner [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 12:46 PM
Subject: Re: [WISPA] CALEA Question


I think you better just take a rate increase and chalk it up to 
increased expenses all the way around as opposed to creating a CALEA 
charge line item. Adding a fee as a line item could get you in trouble 
with the FTC if not approved as a legitimate added government fee 
(just my opinion, nothing to base this on other than my gut). Your 
fuel and electricity have jumped considerably I am sure. I am 
considering a rate increase over these added costs also. I see no way 
around it. I have never raised my rates in 10 years. Times are 
changing I am afraid.

Scriv


Ross Cornett wrote:

I give up I just signed a contract to ensure my protection under 
CALEA. My hope is tht those that become compliant do not get 
underminded by those that have hidden in the bushes and took the risk 
upon themselves by not becoming compliant.


It appears that it is time to start charging a homeland security fee. 
Since we cannot authorize taxes, we can charge fees that will allow 
us to mange these cost.  By my figures, I will have to charge at 
least $1.53 per month per customer.  Since this doens't include 
dialup customers, my broadband customers will have to incurr this 
burden alone.


What are you thougths on this.


- Original Message - From: David E. Smith [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Thursday, May 03, 2007 10:42 AM
Subject: Re: [WISPA] CALEA Question



Peter R. wrote:

Why not check with a knowledgeable legal professional instead of 
guessing?



That'd be my boss's department. :D

I'm just a pundit - full of opinions and hot air.

Now you can choose to ignore it, and say a prayer daily that Barney 
Fife

or any other LEA officer does not knock on your door



I'd encourage Barney Fife to knock on my door, I wouldn't mind having
his autograph. Remember him from Three's Company?

Edit: Apparently Don Knotts died last year. Now I'm sad. :(

David Smith
MVN.net
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George Rogato

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Re: [WISPA] CALEA Question

2007-05-03 Thread W.D.McKinney
Yes and up here is $350.00 oer month for a 1MB Business connect.


Alaska Wireless Systems
1(907)240-2183 Cell
1(907)349-2226 Fax
1(907)349-4308 Office
www.akwireless.net



- Original Message -
From: George Rogato
[mailto:[EMAIL PROTECTED]
To: WISPA General List
[mailto:[EMAIL PROTECTED]
Sent: Thu, 03 May 2007 20:00:17 -0800
Subject:
Re: [WISPA] CALEA Question


 gas 3.20 per gallon here. $95.00 to fill my truck yesterday.
 
 Sheesh
 
 Marlon K. Schafer wrote:
  We have a line item of:
  Surcharge to cover the cost of a sales tax being charged against our 
  fiber connection.  Or words to that effect.  We don't call it a tax, we 
  specifically call it a surcharge.  I think that several out here do 
  something similar.
  
  We also charge a $10 trip charge anytime gas is over $2.50 per gallon in 
  this area.  If it hits anywhere close to $4 I'll likely raise that to 
  $15. People don't like it but they do understand.  Especially when 
  nearly everyone else out here has also put on fuel charges.
  
  The only good thing about current gas prices is that crop prices are 
  also way up.  I'll take $3 fuel with $6 wheat any day :-)
  marlon
  
  - Original Message - From: John Scrivner [EMAIL PROTECTED]
  To: WISPA General List wireless@wispa.org
  Sent: Thursday, May 03, 2007 12:46 PM
  Subject: Re: [WISPA] CALEA Question
  
  
  I think you better just take a rate increase and chalk it up to 
  increased expenses all the way around as opposed to creating a CALEA 
  charge line item. Adding a fee as a line item could get you in trouble 
  with the FTC if not approved as a legitimate added government fee 
  (just my opinion, nothing to base this on other than my gut). Your 
  fuel and electricity have jumped considerably I am sure. I am 
  considering a rate increase over these added costs also. I see no way 
  around it. I have never raised my rates in 10 years. Times are 
  changing I am afraid.
  Scriv
 
 
  Ross Cornett wrote:
 
  I give up I just signed a contract to ensure my protection under 
  CALEA. My hope is tht those that become compliant do not get 
  underminded by those that have hidden in the bushes and took the risk 
  upon themselves by not becoming compliant.
 
  It appears that it is time to start charging a homeland security fee. 
  Since we cannot authorize taxes, we can charge fees that will allow 
  us to mange these cost.  By my figures, I will have to charge at 
  least $1.53 per month per customer.  Since this doens't include 
  dialup customers, my broadband customers will have to incurr this 
  burden alone.
 
  What are you thougths on this.
 
 
  - Original Message - From: David E. Smith [EMAIL PROTECTED]
  To: WISPA General List wireless@wispa.org
  Sent: Thursday, May 03, 2007 10:42 AM
  Subject: Re: [WISPA] CALEA Question
 
 
  Peter R. wrote:
 
  Why not check with a knowledgeable legal professional instead of 
  guessing?
 
 
  That'd be my boss's department. :D
 
  I'm just a pundit - full of opinions and hot air.
 
  Now you can choose to ignore it, and say a prayer daily that Barney 
  Fife
  or any other LEA officer does not knock on your door
 
 
  I'd encourage Barney Fife to knock on my door, I wouldn't mind having
  his autograph. Remember him from Three's Company?
 
  Edit: Apparently Don Knotts died last year. Now I'm sad. :(
 
  
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[WISPA] CALEA Question

2007-05-02 Thread David Peterson
As I am finding myself back into sales, I have a question concerning CALEA.  I 
just read this blurb:

The “facilities-based” terminology was meant to include providers offering 
connectivity infrastructure between end users and the Internet. However, 
establishments that acquire broadband Internet access service from a 
facilities-based provider to enable their customers to access the Internet from 
their respective establishments are excluded. The FCC explicitly exempted 
retail providers such as those offering hot spot WiFi (News - Alert) service 
where the actual Internet connectivity is obtained from another provider

From this site:  http://www.rad-info.net/fcc/calea1.htm

This would indicate to me that if you are a retail provider, i.e. you buy your 
broadband from someone else and resell it to your customers, that you are 
exempt.  This would suggest that the onus is on your provider to monitor your 
T-1 or other connection to them in the event of a need for a tap.

Any clarity on this would be great.



WirelessGuys
David Peterson
Senior Wireless Engineer
[EMAIL PROTECTED]
207 W. Los Angeles Avenue, Suite 300
Moorpark, CA 93021-1862
tel: 800-945-3294
mobile: 979.224.4192
AIM: ultramesh inc
Skype ID:nexuswirelessusa




No virus found in this outgoing message.
Checked by AVG Free Edition. 
Version: 7.5.467 / Virus Database: 269.6.2/784 - Release Date: 5/1/2007 2:57 PM
 





CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may 
contain confidential and privileged information for 
the use of the designated recipients. If you are not the intended recipient, 
(or authorized to receive for the recipient) you are hereby 
notified that you have received this communication in error and that any 
review, disclosure, dissemination, distribution or copying of it 
or its contents is prohibited. If you have received this communication in 
error, please destroy all copies of this communication and any 
attachments and contact the sender by reply email or telephone (800) 945-3294. 

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[WISPA] CALEA Exemption for Small Wireless ISPs

2007-05-02 Thread Jack Unger

Dear Representative Stupak,

I'm writing to support your request on March 14, 2007 asking that the 
FCC Commissioners consider a waiver from CALEA regulations for small 
broadband providers.


In a nutshell, the costs of complying with the CALEA provisions are far 
in excess of what small broadband providers can afford to pay. It is 
poor government policy to allow the costs of CALEA compliance to 
literally put small broadband providers out of business thereby denying 
broadband Internet access to many rural Americans.


Do you plan to introduce legislation that directs the FCC to reconsider 
their regulations and to consider the compliance costs when regulating 
small Internet access providers?


Please advise me how I can further support your effort to retain 
broadband Internet access service for rural Americans.


Thank you for your time, interest, and efforts.

Sincerely,
Jack Unger


P.S. - I am copying this email to the general email list maintained by 
the Wireless Internet Service Providers Association (WISPA.org) to help 
as many small ISPs as possible learn about and support your efforts in 
their behalf. I will forward your response to this list.



--
Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc.
FCC License # PG-12-25133
Serving the Broadband Wireless Industry Since 1993
Author of the WISP Handbook - Deploying License-Free Wireless WANs
True Vendor-Neutral Wireless Consulting-Training-Troubleshooting
FCC Part 15 Certification Assistance for Wireless Service Providers
Phone (VoIP Over Broadband Wireless) 818-227-4220  www.ask-wi.com


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Re: [WISPA] CALEA Compliance

2007-05-02 Thread Sam Tetherow

Tim Kery wrote:

Hi Ross,

 
  

SNIP

You also have to remember that Law Enforcement's primary focus is Law
Enforcement and not developing technology. The FBI/DEA/DOJ said as much
when in 2004 they petitioned the FCC to expand CALEA to broadband and
VoIP. Essentially, they argued that it isn't possible for them to keep
up with the pace of technology. (By the way, this isn't an ability
issue, the FBI and Secret Service, ect. have exceptionally talented
teams. Instead it really is a resource issue; the number of staff they
have to cover these issues can't cover the scale of the problem.) 
  
So I, as a small provider, am suppose to have more and better resources 
than the federal government and their various agencies?



Sam Tetherow
Sandhills Wireless

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Re: [WISPA] CALEA Compliance

2007-05-02 Thread Ross Cornett
I appreciated Tim's remarks, but this sounded very much like a response from 
someone that is getting fed by the process of CALEA.  If I am wrong I duly 
appologize.  if I am correct then I have said enough.



I agree with you Sam.  It boils down to Uncle Sam is pushing an INTERNET 
SECURITY  TAX on the everyone in the industry and only funding the TELCO's 
Side of it  and we have no say so in the matter.  They have plenty of 
resources and just determined that we can take it or shut down.  This too is 
another way that the multi funded telcos will continue to be fed by the feds 
and we will have to pickup the scraps that the telco's don't have time or 
the interest to reach.  Now doing that will just be a tougher battle.


It must be nice getting a subcity... only a telcos know how to spell 
that the rest of us have never had money give to us we have to earn 
it. lol


Ross




- Original Message - 
From: Sam Tetherow [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Wednesday, May 02, 2007 4:20 PM
Subject: Re: [WISPA] CALEA Compliance



Tim Kery wrote:

Hi Ross,



SNIP

You also have to remember that Law Enforcement's primary focus is Law
Enforcement and not developing technology. The FBI/DEA/DOJ said as much
when in 2004 they petitioned the FCC to expand CALEA to broadband and
VoIP. Essentially, they argued that it isn't possible for them to keep
up with the pace of technology. (By the way, this isn't an ability
issue, the FBI and Secret Service, ect. have exceptionally talented
teams. Instead it really is a resource issue; the number of staff they
have to cover these issues can't cover the scale of the problem.)
So I, as a small provider, am suppose to have more and better resources 
than the federal government and their various agencies?



Sam Tetherow
Sandhills Wireless

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Re: [WISPA] CALEA Question

2007-05-02 Thread Peter R.

As I understand it anyone who runs a router has to be CALEA compliant.

Call the FCC ... these guys will answer your question and call you back:
www.fcc.gov/calea

Or ask a Legal Professional like Kris Twomey.
Chris Savage or KC Halm from Davis Wright Tremaine LLP will take your 
questions about CALEA on May 9th  
(http://radinfo.blogspot.com/2007/05/attorney-call-for-calea.html)


- Peter


David Peterson wrote:


As I am finding myself back into sales, I have a question concerning CALEA.  I 
just read this blurb:

The “facilities-based” terminology was meant to include providers offering 
connectivity infrastructure between end users and the Internet. However, 
establishments that acquire broadband Internet access service from a 
facilities-based provider to enable their customers to access the Internet from 
their respective establishments are excluded. The FCC explicitly exempted 
retail providers such as those offering hot spot WiFi (News - Alert) service 
where the actual Internet connectivity is obtained from another provider

From this site:  http://www.rad-info.net/fcc/calea1.htm

This would indicate to me that if you are a retail provider, i.e. you buy your 
broadband from someone else and resell it to your customers, that you are 
exempt.  This would suggest that the onus is on your provider to monitor your 
T-1 or other connection to them in the event of a need for a tap.

Any clarity on this would be great.



WirelessGuys
David Peterson
Senior Wireless Engineer


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Re: [WISPA] CALEA Question

2007-05-02 Thread Mike Hammett

Well, everybody gets their Internet from someone else.


-
Mike Hammett
Intelligent Computing Solutions
http://www.ics-il.com


- Original Message - 
From: David Peterson [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Wednesday, May 02, 2007 1:57 PM
Subject: [WISPA] CALEA Question


As I am finding myself back into sales, I have a question concerning CALEA. 
I just read this blurb:


The “facilities-based” terminology was meant to include providers offering 
connectivity infrastructure between end users and the Internet. However, 
establishments that acquire broadband Internet access service from a 
facilities-based provider to enable their customers to access the Internet 
from their respective establishments are excluded. The FCC explicitly 
exempted retail providers such as those offering hot spot WiFi (News - 
Alert) service where the actual Internet connectivity is obtained from 
another provider



From this site:  http://www.rad-info.net/fcc/calea1.htm


This would indicate to me that if you are a retail provider, i.e. you buy 
your broadband from someone else and resell it to your customers, that you 
are exempt.  This would suggest that the onus is on your provider to monitor 
your T-1 or other connection to them in the event of a need for a tap.


Any clarity on this would be great.



WirelessGuys
David Peterson
Senior Wireless Engineer
[EMAIL PROTECTED]
207 W. Los Angeles Avenue, Suite 300
Moorpark, CA 93021-1862
tel: 800-945-3294
mobile: 979.224.4192
AIM: ultramesh inc
Skype ID:nexuswirelessusa




No virus found in this outgoing message.
Checked by AVG Free Edition.
Version: 7.5.467 / Virus Database: 269.6.2/784 - Release Date: 5/1/2007 2:57 
PM







CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may 
contain confidential and privileged information for
the use of the designated recipients. If you are not the intended recipient, 
(or authorized to receive for the recipient) you are hereby
notified that you have received this communication in error and that any 
review, disclosure, dissemination, distribution or copying of it
or its contents is prohibited. If you have received this communication in 
error, please destroy all copies of this communication and any
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Re: [WISPA] CALEA Question

2007-05-02 Thread George Rogato

Hmmm,

Well during the dial up days, Jokingly, I was thinking about starting a 
new internet business. Internet on a disk! . Each week we send you a 
new disk. We start you off with disk labeled, beginning internet a-ab, 
next week it will be ac-ad. This way the sites will be fast loading and 
won't tie up your telephone lines, nor will you have to buy a fancy high 
speed internet line. No more connection issues.


Well I did ell a couple of my subs this, and they wanted to know what 
would be cheaper grin




Mike Hammett wrote:

Well, everybody gets their Internet from someone else.


-
Mike Hammett
Intelligent Computing Solutions
http://www.ics-il.com


- Original Message - From: David Peterson 
[EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Wednesday, May 02, 2007 1:57 PM
Subject: [WISPA] CALEA Question


As I am finding myself back into sales, I have a question concerning 
CALEA. I just read this blurb:


The “facilities-based” terminology was meant to include providers 
offering connectivity infrastructure between end users and the Internet. 
However, establishments that acquire broadband Internet access service 
from a facilities-based provider to enable their customers to access the 
Internet from their respective establishments are excluded. The FCC 
explicitly exempted retail providers such as those offering hot spot 
WiFi (News - Alert) service where the actual Internet connectivity is 
obtained from another provider



From this site:  http://www.rad-info.net/fcc/calea1.htm


This would indicate to me that if you are a retail provider, i.e. you 
buy your broadband from someone else and resell it to your customers, 
that you are exempt.  This would suggest that the onus is on your 
provider to monitor your T-1 or other connection to them in the event of 
a need for a tap.


Any clarity on this would be great.



WirelessGuys
David Peterson
Senior Wireless Engineer
[EMAIL PROTECTED]
207 W. Los Angeles Avenue, Suite 300
Moorpark, CA 93021-1862
tel: 800-945-3294
mobile: 979.224.4192
AIM: ultramesh inc
Skype ID:nexuswirelessusa




No virus found in this outgoing message.
Checked by AVG Free Edition.
Version: 7.5.467 / Virus Database: 269.6.2/784 - Release Date: 5/1/2007 
2:57 PM





 



CONFIDENTIALITY NOTICE: This e-mail communication and any attachments 
may contain confidential and privileged information for
the use of the designated recipients. If you are not the intended 
recipient, (or authorized to receive for the recipient) you are hereby
notified that you have received this communication in error and that any 
review, disclosure, dissemination, distribution or copying of it
or its contents is prohibited. If you have received this communication 
in error, please destroy all copies of this communication and any
attachments and contact the sender by reply email or telephone (800) 
945-3294.




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Re: [WISPA] CALEA Exemption for Small Wireless ISPs

2007-05-02 Thread cw
My opinion is that you're not helping the big picture by saying compliance 
is more than you can handle. The FCC is not going to go out of their way to 
hand out more spectrum to providers that can't perform basic requirements. 
Just like they're not going to help providers that refuse to file 475 forms. 
You can build a unix box for five hundred dollars that will do the job for 
you. Or you can buy a turnkey box with support for seven thousand. I've seen 
it suggested people pool their funds and share a $7000 turnkey box. If you 
can't do any of these things, then you can't provide required services. I 
don't like or trust government but I don't think they're out of line 
requiring providers be CALEA compliant. This one ain't special interests 
motivated. - cw


Jack Unger wrote:

Dear Representative Stupak,

I'm writing to support your request on March 14, 2007 asking that the 
FCC Commissioners consider a waiver from CALEA regulations for small 
broadband providers.


In a nutshell, the costs of complying with the CALEA provisions are far 
in excess of what small broadband providers can afford to pay. It is 
poor government policy to allow the costs of CALEA compliance to 
literally put small broadband providers out of business thereby denying 
broadband Internet access to many rural Americans.


Do you plan to introduce legislation that directs the FCC to reconsider 
their regulations and to consider the compliance costs when regulating 
small Internet access providers?


Please advise me how I can further support your effort to retain 
broadband Internet access service for rural Americans.


Thank you for your time, interest, and efforts.

Sincerely,
Jack Unger


P.S. - I am copying this email to the general email list maintained by 
the Wireless Internet Service Providers Association (WISPA.org) to help 
as many small ISPs as possible learn about and support your efforts in 
their behalf. I will forward your response to this list.




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Re: [WISPA] CALEA Exemption for Small Wireless ISPs

2007-05-02 Thread Jack Unger

Dear cw,

Thank you for your opinion. I respectfully disagree.

There's nothing wrong with admitting that small local providers can't 
afford to comply with the same requirements that big carriers like ATT 
can comply with. That's the problem here; small local businesses are 
being asked to shell out more money than they can afford just so the 
FBI/DOJ/ATF/CIA/NSA/DHS can quickly and conveniently wiretap. As to 
whether the big carriers have provided input to the FCC 
(FBI/DOJ/ATF/CIA/NSA/DHS) on this issue; the jury is out on that 
question for the moment.


jack

P.S. - The issue of obtaining more spectrum from the FCC will be moot 
once the ranks of the small, local license-free spectrum users are 
thinned much further. In short, no one will be around to need any more 
spectrum.



cw wrote:
My opinion is that you're not helping the big picture by saying 
compliance is more than you can handle. The FCC is not going to go out 
of their way to hand out more spectrum to providers that can't perform 
basic requirements. Just like they're not going to help providers that 
refuse to file 475 forms. You can build a unix box for five hundred 
dollars that will do the job for you. Or you can buy a turnkey box with 
support for seven thousand. I've seen it suggested people pool their 
funds and share a $7000 turnkey box. If you can't do any of these 
things, then you can't provide required services. I don't like or trust 
government but I don't think they're out of line requiring providers be 
CALEA compliant. This one ain't special interests motivated. - cw


Jack Unger wrote:

Dear Representative Stupak,

I'm writing to support your request on March 14, 2007 asking that the 
FCC Commissioners consider a waiver from CALEA regulations for small 
broadband providers.


In a nutshell, the costs of complying with the CALEA provisions are 
far in excess of what small broadband providers can afford to pay. It 
is poor government policy to allow the costs of CALEA compliance to 
literally put small broadband providers out of business thereby 
denying broadband Internet access to many rural Americans.


Do you plan to introduce legislation that directs the FCC to 
reconsider their regulations and to consider the compliance costs when 
regulating small Internet access providers?


Please advise me how I can further support your effort to retain 
broadband Internet access service for rural Americans.


Thank you for your time, interest, and efforts.

Sincerely,
Jack Unger


P.S. - I am copying this email to the general email list maintained by 
the Wireless Internet Service Providers Association (WISPA.org) to 
help as many small ISPs as possible learn about and support your 
efforts in their behalf. I will forward your response to this list.





--
Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc.
FCC License # PG-12-25133
Serving the Broadband Wireless Industry Since 1993
Author of the WISP Handbook - Deploying License-Free Wireless WANs
True Vendor-Neutral Wireless Consulting-Training-Troubleshooting
FCC Part 15 Certification Assistance for Wireless Service Providers
Phone (VoIP Over Broadband Wireless) 818-227-4220  www.ask-wi.com


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Re: [WISPA] CALEA Exemption for Small Wireless ISPs

2007-05-02 Thread George Rogato
I believe the feds have secret deals with the telcos so they can do what 
ever they want besides calea. Just like I pointed out that fiber att 
wiretapping deal in the very first days of wispa calea  discussion.


This is where I see the imbalance,
The little guys carry the weight and the big guys get gravy secret 
contracts that help shoulder the burden.


I will still do what I have to do to be compliant. But there is a 
reality to the even handedness of this.


George


Jack Unger wrote:

Dear cw,

Thank you for your opinion. I respectfully disagree.

There's nothing wrong with admitting that small local providers can't 
afford to comply with the same requirements that big carriers like ATT 
can comply with. That's the problem here; small local businesses are 
being asked to shell out more money than they can afford just so the 
FBI/DOJ/ATF/CIA/NSA/DHS can quickly and conveniently wiretap. As to 
whether the big carriers have provided input to the FCC 
(FBI/DOJ/ATF/CIA/NSA/DHS) on this issue; the jury is out on that 
question for the moment.


jack

P.S. - The issue of obtaining more spectrum from the FCC will be moot 
once the ranks of the small, local license-free spectrum users are 
thinned much further. In short, no one will be around to need any more 
spectrum.



cw wrote:
My opinion is that you're not helping the big picture by saying 
compliance is more than you can handle. The FCC is not going to go out 
of their way to hand out more spectrum to providers that can't perform 
basic requirements. Just like they're not going to help providers that 
refuse to file 475 forms. You can build a unix box for five hundred 
dollars that will do the job for you. Or you can buy a turnkey box 
with support for seven thousand. I've seen it suggested people pool 
their funds and share a $7000 turnkey box. If you can't do any of 
these things, then you can't provide required services. I don't like 
or trust government but I don't think they're out of line requiring 
providers be CALEA compliant. This one ain't special interests 
motivated. - cw


Jack Unger wrote:

Dear Representative Stupak,

I'm writing to support your request on March 14, 2007 asking that the 
FCC Commissioners consider a waiver from CALEA regulations for small 
broadband providers.


In a nutshell, the costs of complying with the CALEA provisions are 
far in excess of what small broadband providers can afford to pay. It 
is poor government policy to allow the costs of CALEA compliance to 
literally put small broadband providers out of business thereby 
denying broadband Internet access to many rural Americans.


Do you plan to introduce legislation that directs the FCC to 
reconsider their regulations and to consider the compliance costs 
when regulating small Internet access providers?


Please advise me how I can further support your effort to retain 
broadband Internet access service for rural Americans.


Thank you for your time, interest, and efforts.

Sincerely,
Jack Unger


P.S. - I am copying this email to the general email list maintained 
by the Wireless Internet Service Providers Association (WISPA.org) to 
help as many small ISPs as possible learn about and support your 
efforts in their behalf. I will forward your response to this list.







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Re: [WISPA] CALEA Exemption for Small Wireless ISPs

2007-05-02 Thread Sam Tetherow
My opinion then, is that the FCC can get off their duffs and provide 
internet to the hinterlands themselves. 

There is more to CALEA than having a $500 unix box, and sharing a $7000 
turnkey box is not an option unless you are sharing it within a tight 
geographical area since response times on execution of certain parts of 
CALEA is shorter than an overnight shipment.


As for getting more spectrum, quite honestly I will believe it when I 
see it.  The FCC is far more interested in the cash that spectrum sales 
bring in than it is interested in providing the best use of the spectrum 
for the American public.


   Sam Tetherow
   Sandhills Wireless

cw wrote:
My opinion is that you're not helping the big picture by saying 
compliance is more than you can handle. The FCC is not going to go out 
of their way to hand out more spectrum to providers that can't perform 
basic requirements. Just like they're not going to help providers that 
refuse to file 475 forms. You can build a unix box for five hundred 
dollars that will do the job for you. Or you can buy a turnkey box 
with support for seven thousand. I've seen it suggested people pool 
their funds and share a $7000 turnkey box. If you can't do any of 
these things, then you can't provide required services. I don't like 
or trust government but I don't think they're out of line requiring 
providers be CALEA compliant. This one ain't special interests 
motivated. - cw


Jack Unger wrote:

Dear Representative Stupak,

I'm writing to support your request on March 14, 2007 asking that the 
FCC Commissioners consider a waiver from CALEA regulations for small 
broadband providers.


In a nutshell, the costs of complying with the CALEA provisions are 
far in excess of what small broadband providers can afford to pay. It 
is poor government policy to allow the costs of CALEA compliance to 
literally put small broadband providers out of business thereby 
denying broadband Internet access to many rural Americans.


Do you plan to introduce legislation that directs the FCC to 
reconsider their regulations and to consider the compliance costs 
when regulating small Internet access providers?


Please advise me how I can further support your effort to retain 
broadband Internet access service for rural Americans.


Thank you for your time, interest, and efforts.

Sincerely,
Jack Unger


P.S. - I am copying this email to the general email list maintained 
by the Wireless Internet Service Providers Association (WISPA.org) to 
help as many small ISPs as possible learn about and support your 
efforts in their behalf. I will forward your response to this list.





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Re: [WISPA] CALEA Compliance (Netequalizer)

2007-05-02 Thread John Thomas

For people that run Netequalizers, they are helping you comply

As promised, NetEqualizer is now offering the utilities necessary to 
meet requirements set forth this month by CALEA, or the Communications 
Assistance for Law Enforcement Act. This law oversees telecommunication 
security and has now been expanded to Internet security. There are some 
fairly harsh federal penalties for noncompliance that became effective 
May 1.



John

Marlon K. Schafer wrote:
There won't be a WISPA standard done in time.  We're still waiting on 
some documentation from the FBI and we need to get some internal 
documentation together as well.


But you don't have to be compliant with ANY standard to be CALEA 
compliant! You just have to understand what you have to do if they ask 
and have mechanisms in place to do it.


The basic parts you'll need are:
Linux based router or tap capabilities on the on you have.  OR a 
managed switch that will allow you to mirror a port.

Linux server with OpenCALEA and an FTP program on it.
Knowledge of how to make it record and distribute the needed data for 
LEA.


You don't HAVE to use a TTP.  You don't HAVE to follow a standard.  
You don't HAVE to panic just yet.


*I've* talked to the folks at the FBI.  They are NOT interested in 
running anyone out of business.  They just want to catch bad guys and 
they *may* need our help to do it.  Everything past that point is FUD.


Why have a standard at all then?  Because if you don't follow a 
standard you have to TRY to do anything that LEA asks of you.  If you 
are standards compliant you only have to do what the standard says you 
have to do.


Believe it or not, guys like Tim at Bearhill are working WITH WISPA in 
our efforts to develop a low cost/no cost solution to CALEA.  We all 
know that many in this industry are still trying to figure out how to 
pay the bill on that latest order for 3 cpe units.  I was sometimes 60 
days behind with EC. I always paid but rarely on time.  Sucked for me 
and for them.  Fortunately, they hung with me and today we're as 
likely to be prepaid as we are to owe them.  It's a nice change of 
pace.  We also order radios in bulk, every couple to few weeks, rather 
than 1 or 2 at a time.  Wondering how to make payroll, or buy diapers 
sucks.  Most of us have been there.  We got through those times partly 
because others reached a hand down and helped us where they could.  We 
worked hard, honestly and consistently.


I suggest that those of you in panic mode over CALEA go to 
www.askcalea.net and read up on it.  Contact the FCC and the FBI 
yourselves if you don't believe those of us that are doing this work.  
So far I've found that folks are more than happy to answer my direct 
questions.


At LEAST contact those that WISPA sent to the FBI!  They know a lot of 
answers and they have a direct line to the FBI if they don't know the 
answer.


Yeah, CALEA is a big deal.  Yeah it's complicated.  Yeah, it'll suck 
to have to perform.  Yeah, you have to do it anyway :-).  Might as 
well stop whining and start figuring out what all of those ttp's have 
already gotten figured out.


Someone's gonna make money off of those out there that can't/won't 
figure it out for themselves.  Might as well be you!

marlon

- Original Message - From: Todd Barber [EMAIL PROTECTED]
To: 'WISPA General List' wireless@wispa.org
Sent: Monday, April 30, 2007 8:19 PM
Subject: RE: [WISPA] CALEA Compliance



John,

The part that is causing disbelief for me is the deadline is only 
days away

and I haven't seen this solution or the costing for the solution.

Todd Barber
Skylink Broadband Internet
[EMAIL PROTECTED]
970-454-9499


-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of John Scrivner
Sent: Monday, April 30, 2007 9:14 PM
To: WISPA General List
Subject: Re: [WISPA] CALEA Compliance



I personally do not believe that any CALEA can be cost effective. Quite
simply, solving CALEA requires spending money without earning any
additional revenue. The only way to justify the CALEA expense is to 
accept

it as a cost of doing business. This means simply that your market
opportunity is lost if you aren't CALEA compliant. I firmly believe 
every
service provider should have plans for being CALEA compliant or have 
plans
for exiting the business. This one is different than E911; the 
liability

will be staggering.

-Matt



Matt,
We look forward to proving that this thinking is wrong. What part of
CALEA compliance is it that makes you think we cannot develop a low cost
and reasonable solution which will not break the bank?
Scriv


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Re: [WISPA] CALEA Exemption for Small Wireless ISPs

2007-05-02 Thread Marlon K. Schafer

Uh Sam, you do remember the 5.4 gig band right?

255 mhz of NEW spectrum, made available last year.

There's also 24ghz and 60ghz available.  We just need people building the 
new toys at price points that will work for us.


Know what I want?  A 15 or 20 meg $1500 to $2000 60 gig solution good for a 
mile or two.


marlon

- Original Message - 
From: Sam Tetherow [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Wednesday, May 02, 2007 6:52 PM
Subject: Re: [WISPA] CALEA Exemption for Small Wireless ISPs


My opinion then, is that the FCC can get off their duffs and provide 
internet to the hinterlands themselves.
There is more to CALEA than having a $500 unix box, and sharing a $7000 
turnkey box is not an option unless you are sharing it within a tight 
geographical area since response times on execution of certain parts of 
CALEA is shorter than an overnight shipment.


As for getting more spectrum, quite honestly I will believe it when I see 
it.  The FCC is far more interested in the cash that spectrum sales bring 
in than it is interested in providing the best use of the spectrum for the 
American public.


   Sam Tetherow
   Sandhills Wireless

cw wrote:
My opinion is that you're not helping the big picture by saying 
compliance is more than you can handle. The FCC is not going to go out of 
their way to hand out more spectrum to providers that can't perform basic 
requirements. Just like they're not going to help providers that refuse 
to file 475 forms. You can build a unix box for five hundred dollars that 
will do the job for you. Or you can buy a turnkey box with support for 
seven thousand. I've seen it suggested people pool their funds and share 
a $7000 turnkey box. If you can't do any of these things, then you can't 
provide required services. I don't like or trust government but I don't 
think they're out of line requiring providers be CALEA compliant. This 
one ain't special interests motivated. - cw


Jack Unger wrote:

Dear Representative Stupak,

I'm writing to support your request on March 14, 2007 asking that the 
FCC Commissioners consider a waiver from CALEA regulations for small 
broadband providers.


In a nutshell, the costs of complying with the CALEA provisions are far 
in excess of what small broadband providers can afford to pay. It is 
poor government policy to allow the costs of CALEA compliance to 
literally put small broadband providers out of business thereby denying 
broadband Internet access to many rural Americans.


Do you plan to introduce legislation that directs the FCC to reconsider 
their regulations and to consider the compliance costs when regulating 
small Internet access providers?


Please advise me how I can further support your effort to retain 
broadband Internet access service for rural Americans.


Thank you for your time, interest, and efforts.

Sincerely,
Jack Unger


P.S. - I am copying this email to the general email list maintained by 
the Wireless Internet Service Providers Association (WISPA.org) to help 
as many small ISPs as possible learn about and support your efforts in 
their behalf. I will forward your response to this list.





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[WISPA] CALEA Question

2007-05-02 Thread Tim Kery
David,

Regarding your question, the FCC was referring to Retail
Establishments and not Retail Providers. The FCC defines facilities
based as follows:

facilities-based meant entities that provide transmission or
switching over their own facilities between the end user and the
Internet Service Provider (ISP)

So if your customer traffic traverses over a router, switch or bridge
that you own, and your offering exceeds 200Kbps in either direction in
the last mile, then you meet the commissions definition of a
facilities-based broadband service provider. The FCC did exclude some
retail establishments from the CALEA requirement. 

Specifically, in the FCC's First Report and Order and NPRM (05-153), pg
19. paragraph 36 states:

 Finally, in finding CALEA's SRP to cover facilities-based providers of
broadband Internet access service, we conclude that establishments that
acquire broadband Internet access service from a facilities-based
provider to enable their patrons or customers to access the Internet
from their respective establishments are not considered facilities-based
broadband Internet access service providers subject to CALEA under the
SRP.99 We note, however, that the provider of underlying facilities to
such an establishment would be subject to CALEA, as discussed above. 

Footnote #99 on the same page further clarifies:

Examples of these types of establishments may include some hotels,
coffee shops, schools, libraries, or book stores. DOJ has stated that it
has no desire to require such retail establishments to implement CALEA
solutions, DOJ Comments at 36, and we conclude that the public interest
at this time does not weigh in favor of subjecting such establishments
to CALEA.

So, Starbucks doesn't need to comply with CALEA but the service provider
that provides bandwidth to Starbucks does.

Hope this helps.

Tim Kery
BearHill Security, Inc.
[EMAIL PROTECTED]

[WISPA] CALEA Question
David Peterson DPeterson at Wirelessguys.com
mailto:wireless%40wispa.org?Subject=%5BWISPA%5D%20CALEA%20QuestionIn-R
eply-To=e702557f0705021144t38638587y585f4544732c9b6d%40mail.gmail.com 
Wed May 2 13:57:48 CDT 2007 
*   Previous message: NOW: CALEA Waiver Request WAS: [WISPA] Ok,
here's my CALEA statement, and farewell.
http://lists.wispa.org/pipermail/wireless/2007-May/035125.html 
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http://lists.wispa.org/pipermail/wireless/2007-May/035173.html 
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subject ]
http://lists.wispa.org/pipermail/wireless/2007-May/subject.html  [
author ]
http://lists.wispa.org/pipermail/wireless/2007-May/author.html  

As I am finding myself back into sales, I have a question concerning
CALEA.  I just read this blurb:

The facilities-based terminology was meant to include providers
offering connectivity infrastructure between end users and the Internet.
However, establishments that acquire broadband Internet access service
from a facilities-based provider to enable their customers to access the
Internet from their respective establishments are excluded. The FCC
explicitly exempted retail providers such as those offering hot spot
WiFi (News - Alert) service where the actual Internet connectivity is
obtained from another provider

From this site:  http://www.rad-info.net/fcc/calea1.htm

This would indicate to me that if you are a retail provider, i.e. you
buy your broadband from someone else and resell it to your customers,
that you are exempt.  This would suggest that the onus is on your
provider to monitor your T-1 or other connection to them in the event of
a need for a tap.

Any clarity on this would be great.



WirelessGuys
David Peterson
Senior Wireless Engineer
DPeterson at WirelessGuys.com
http://lists.wispa.org/mailman/listinfo/wireless 
207 W. Los Angeles Avenue, Suite 300
Moorpark, CA 93021-1862
tel: 800-945-3294
mobile: 979.224.4192
AIM: ultramesh inc
Skype ID:nexuswirelessusa






 http://www.bearhill.com/ 




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Re: [WISPA] CALEA Exemption for Small Wireless ISPs

2007-05-02 Thread Sam Tetherow
You do have a point on the 5.4 Marlon, although it was otherwise 
unsellable spectrum.  The power restrictions along with DFS requirements 
limited it to something I doubt many would be willing to pay for.  Not 
saying we can't use it though.  I'm eagerly awaiting affordable gear 
since it fits my model quite well.  Most of my customers are within 3 
miles of my towers.


   Sam Tetherow
   Sandhills Wireless

Marlon K. Schafer wrote:

Uh Sam, you do remember the 5.4 gig band right?

255 mhz of NEW spectrum, made available last year.

There's also 24ghz and 60ghz available.  We just need people building 
the new toys at price points that will work for us.


Know what I want?  A 15 or 20 meg $1500 to $2000 60 gig solution good 
for a mile or two.


marlon

- Original Message - From: Sam Tetherow [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Wednesday, May 02, 2007 6:52 PM
Subject: Re: [WISPA] CALEA Exemption for Small Wireless ISPs


My opinion then, is that the FCC can get off their duffs and provide 
internet to the hinterlands themselves.
There is more to CALEA than having a $500 unix box, and sharing a 
$7000 turnkey box is not an option unless you are sharing it within a 
tight geographical area since response times on execution of certain 
parts of CALEA is shorter than an overnight shipment.


As for getting more spectrum, quite honestly I will believe it when I 
see it.  The FCC is far more interested in the cash that spectrum 
sales bring in than it is interested in providing the best use of the 
spectrum for the American public.


   Sam Tetherow
   Sandhills Wireless

cw wrote:
My opinion is that you're not helping the big picture by saying 
compliance is more than you can handle. The FCC is not going to go 
out of their way to hand out more spectrum to providers that can't 
perform basic requirements. Just like they're not going to help 
providers that refuse to file 475 forms. You can build a unix box 
for five hundred dollars that will do the job for you. Or you can 
buy a turnkey box with support for seven thousand. I've seen it 
suggested people pool their funds and share a $7000 turnkey box. If 
you can't do any of these things, then you can't provide required 
services. I don't like or trust government but I don't think they're 
out of line requiring providers be CALEA compliant. This one ain't 
special interests motivated. - cw


Jack Unger wrote:

Dear Representative Stupak,

I'm writing to support your request on March 14, 2007 asking that 
the FCC Commissioners consider a waiver from CALEA regulations for 
small broadband providers.


In a nutshell, the costs of complying with the CALEA provisions are 
far in excess of what small broadband providers can afford to pay. 
It is poor government policy to allow the costs of CALEA compliance 
to literally put small broadband providers out of business thereby 
denying broadband Internet access to many rural Americans.


Do you plan to introduce legislation that directs the FCC to 
reconsider their regulations and to consider the compliance costs 
when regulating small Internet access providers?


Please advise me how I can further support your effort to retain 
broadband Internet access service for rural Americans.


Thank you for your time, interest, and efforts.

Sincerely,
Jack Unger


P.S. - I am copying this email to the general email list maintained 
by the Wireless Internet Service Providers Association (WISPA.org) 
to help as many small ISPs as possible learn about and support your 
efforts in their behalf. I will forward your response to this list.





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Re: [WISPA] CALEA Question

2007-05-02 Thread David E. Smith

The FCC wrote:

we conclude that establishments that
acquire broadband Internet access service from a facilities-based
provider to enable their patrons or customers to access the Internet
from their respective establishments are not considered facilities-based
broadband Internet access service providers

Hm.

It'd be one heckuva stretch, but by reading the letter (as opposed to 
the spirit) of that paragraph, many smaller WISPs would automatically be 
exempt. I know my office has acquired broadband Internet access service 
from a facilities-based provider (our upstream ISP) and we're enabling 
our customers to access the Internet from their respective 
establishments (i.e. our customers pay for Internet at their homes or 
offices).


By the letter of that paragraph (and, to be fair, I haven't read all the 
context surrounding it) most any single-homed WISP would be exempt, as 
they could just say go talk to our upstream. (I doubt it'd work for 
multi-homed ISPs, as that would require multiple upstreams to be tapped 
and somehow synchronized, which is probably technically annoying.)


David Smith
MVN.net
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Re: [WISPA] CALEA Exemption for Small Wireless ISPs

2007-05-02 Thread John Scrivner
Thank you Jack. I am glad to see someone doing something for their 
beliefs instead of kicking WISPA in the chins for not doing it for them. 
WISPA is here for all of you to interact and decide what and how you 
want to represent yourselves and your industry. Jack knows that means he 
can do something and is doing something. Way to go Jack. It is usually 
only 4 or 5 of us within WISPA who actually do something to light a fire 
under people's butts. I am glad to see you take the step this time. 
That's called leadership people. Jack showed you how its done folks. If 
you want change then make it happen. This was less work than complaining 
about the problem and is infinitely more productive toward getting 
something done about the issues that many have been talking about here 
with regard to fears of inability to meet the demands of CALEA.

Scriv


Jack Unger wrote:


Dear Representative Stupak,

I'm writing to support your request on March 14, 2007 asking that the 
FCC Commissioners consider a waiver from CALEA regulations for small 
broadband providers.


In a nutshell, the costs of complying with the CALEA provisions are 
far in excess of what small broadband providers can afford to pay. It 
is poor government policy to allow the costs of CALEA compliance to 
literally put small broadband providers out of business thereby 
denying broadband Internet access to many rural Americans.


Do you plan to introduce legislation that directs the FCC to 
reconsider their regulations and to consider the compliance costs when 
regulating small Internet access providers?


Please advise me how I can further support your effort to retain 
broadband Internet access service for rural Americans.


Thank you for your time, interest, and efforts.

Sincerely,
Jack Unger


P.S. - I am copying this email to the general email list maintained by 
the Wireless Internet Service Providers Association (WISPA.org) to 
help as many small ISPs as possible learn about and support your 
efforts in their behalf. I will forward your response to this list.




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Re: [WISPA] CALEA Compliance

2007-05-01 Thread Mark Koskenmaki

- Original Message - 
From: Jack Unger [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Monday, April 30, 2007 7:56 PM
Subject: Re: [WISPA] CALEA Compliance

I went to email him, but his website says he will not respond to emails from
outside his district.

his website has no mention of his letter to the FCC.

Is there anyone in his district on-list who can email or call him?
People from outside his district are obviously going to be far back on the
list of things to take time to deal with.   I won't call unless there's
nobody in his district.


I did a lot of searching for additional information about his request, but I
found nothing.   I did find he has a lot of interest in internet /
telecommunications, though I see he and I are on the opposite sides of a lot
of things.

His district is the upper peninsula of Michigan.

Anyone?





 I'd like to hear the FCC response to Rep. Bart Stupak's request to waive
 the CALEA regulations for small broadband providers, as described in the
 following link.

 http://www.wispa.org/?p=21

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Re: [WISPA] CALEA Compliance

2007-05-01 Thread Butch Evans

On Mon, 30 Apr 2007, Todd Barber wrote:

I have seen numerous posts on the WISPA list indicating that a cost 
effective and compliant solution for this issue was being worked on 
and would become available in the near future.


All I can say is please be patient.  An answer to your question is 
coming.  We (the wispa calea committee) are working on building the 
standard now.


I have seen numerous posts indicating that small providers should 
not be concerned and that attaining CALEA compliance would not put 
them out of business.


Those posts would be correct.

I contacted them today.  If this is the cost effective solution 
that is available, it isn’t cost effective enough for our 
operation.  The monthly is ¼ of our current bandwidth costs and the 
upfront is twice the cost of our head-end router that is servicing 
all of our customers.


Bearhill (or any other TTP) is a good solution if you want someone 
else to assist in managing your CALEA compliance.  A TTP is NOT a 
requirement, however.


If someone has better information on how a small ISP can become 
CALEA compliant in a cost effective manner, please contact me as I 
am all ears. If there is better information or a defined solution 
being presented on the WISPA member list, I am more than willing to 
pay membership dues to access it.  If there isn’t a better solution 
being discussed there, I would just as well save the due money as 
it will probably not be long before we are out of business or sell 
to a larger competitor and the membership will be useless.


All I can say is (again), be patient.  This information is coming.

BTW, becoming a WISPA member is a good idea anyway.  CALEA will not 
be the downfall of anyone (except those that refuse to obey the 
law).


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Re: [WISPA] CALEA Compliance

2007-05-01 Thread Matt Liotta

John Scrivner wrote:


We look forward to proving that this thinking is wrong. What part of 
CALEA compliance is it that makes you think we cannot develop a low 
cost and reasonable solution which will not break the bank?


Even if you do come up with a way to handle LI in time for the deadline 
that is only going to solve one part of CALEA. We checked with Cisco in 
the beginning regarding CALEA. We were assured they were working on it 
and would have a solution in time (much the same way WISPA has). We now 
have Cisco's solution and understand it does exactly what they say it 
would do; namely LI. Unfortunately, LI isn't enough as I have outlined 
in other posts. We have had to develop the rest of the solution on our own.


Reread my post on the practical requirements of dealing with ELSUR and 
check with your attorneys. I think you'll find no technical solution to 
those requirements.


-Matt
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Re: [WISPA] CALEA Compliance

2007-05-01 Thread Ross Cornett
I still would like to know the amount of incident that this CALEA will cause 
for all of its costs to our industry.  Did anyone ask the FBI, why they 
cannot have several machines and deliver them as needed pre-configured then 
we can install them when they are needed.  It is highly unreasonable for the 
FBI to ask everyone to have a utility and manage this utility when it will 
never be used by a very large portion of our industry.  It is far cheaper 
for the government to sameday ship their device to us anywhere in the nation 
then it is to have everyone else trying to scramble to satisfy a need that 
will largely be an expensive dust collector in most businesses.



Anyone know if this has been posed to the FBI.



- Original Message - 
From: Matt Liotta [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Tuesday, May 01, 2007 7:54 AM
Subject: Re: [WISPA] CALEA Compliance



John Scrivner wrote:


We look forward to proving that this thinking is wrong. What part of 
CALEA compliance is it that makes you think we cannot develop a low cost 
and reasonable solution which will not break the bank?


Even if you do come up with a way to handle LI in time for the deadline 
that is only going to solve one part of CALEA. We checked with Cisco in 
the beginning regarding CALEA. We were assured they were working on it and 
would have a solution in time (much the same way WISPA has). We now have 
Cisco's solution and understand it does exactly what they say it would do; 
namely LI. Unfortunately, LI isn't enough as I have outlined in other 
posts. We have had to develop the rest of the solution on our own.


Reread my post on the practical requirements of dealing with ELSUR and 
check with your attorneys. I think you'll find no technical solution to 
those requirements.


-Matt
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Re: [WISPA] CALEA Compliance

2007-05-01 Thread Ross Cornett
If we can come up with a device to capture and send to an FTP server and 
allow for VPN connectivity then why can the most powerful law agency in the 
world not do the same.  This way  they controll it all. We just provide the 
pipe to get the data back to their preferred location.   I do not know much 
about CALEA.  I am still reading more and more, but if they are asking us to 
do something, then they had better already know how to do it.


ross
- Original Message - 
From: Matt Liotta [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Tuesday, May 01, 2007 9:54 AM
Subject: Re: [WISPA] CALEA Compliance



Ross Cornett wrote:
I still would like to know the amount of incident that this CALEA will 
cause for all of its costs to our industry.  Did anyone ask the FBI, why 
they cannot have several machines and deliver them as needed 
pre-configured then we can install them when they are needed.  It is 
highly unreasonable for the FBI to ask everyone to have a utility and 
manage this utility when it will never be used by a very large portion of 
our industry.  It is far cheaper for the government to sameday ship their 
device to us anywhere in the nation then it is to have everyone else 
trying to scramble to satisfy a need that will largely be an expensive 
dust collector in most businesses.


Let's assume that the FBI would send you a box for LI. What about the 
remaining requirements for CALEA?


-Matt

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Re: [WISPA] CALEA Compliance

2007-05-01 Thread Mike Hammett
You'd come across a lot of privacy issues giving the FBI that sort of 
access.



-
Mike Hammett
Intelligent Computing Solutions
http://www.ics-il.com


- Original Message - 
From: Ross Cornett [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Tuesday, May 01, 2007 9:59 AM
Subject: Re: [WISPA] CALEA Compliance


If we can come up with a device to capture and send to an FTP server and 
allow for VPN connectivity then why can the most powerful law agency in 
the world not do the same.  This way  they controll it all. We just 
provide the pipe to get the data back to their preferred location.   I do 
not know much about CALEA.  I am still reading more and more, but if they 
are asking us to do something, then they had better already know how to do 
it.


ross
- Original Message - 
From: Matt Liotta [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Tuesday, May 01, 2007 9:54 AM
Subject: Re: [WISPA] CALEA Compliance



Ross Cornett wrote:
I still would like to know the amount of incident that this CALEA will 
cause for all of its costs to our industry.  Did anyone ask the FBI, why 
they cannot have several machines and deliver them as needed 
pre-configured then we can install them when they are needed.  It is 
highly unreasonable for the FBI to ask everyone to have a utility and 
manage this utility when it will never be used by a very large portion 
of our industry.  It is far cheaper for the government to sameday ship 
their device to us anywhere in the nation then it is to have everyone 
else trying to scramble to satisfy a need that will largely be an 
expensive dust collector in most businesses.


Let's assume that the FBI would send you a box for LI. What about the 
remaining requirements for CALEA?


-Matt

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Re: [WISPA] CALEA Compliance

2007-05-01 Thread Matt Liotta

Ross Cornett wrote:
I still would like to know the amount of incident that this CALEA will 
cause for all of its costs to our industry.  Did anyone ask the FBI, 
why they cannot have several machines and deliver them as needed 
pre-configured then we can install them when they are needed.  It is 
highly unreasonable for the FBI to ask everyone to have a utility and 
manage this utility when it will never be used by a very large portion 
of our industry.  It is far cheaper for the government to sameday ship 
their device to us anywhere in the nation then it is to have everyone 
else trying to scramble to satisfy a need that will largely be an 
expensive dust collector in most businesses.


Let's assume that the FBI would send you a box for LI. What about the 
remaining requirements for CALEA?


-Matt

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Re: [WISPA] CALEA Compliance

2007-05-01 Thread Peter R.

You need to filter out data that is not under the subpoena.
And (as I understand it) the LEA should work with you to get the data.


Ross Cornett wrote:

If we can come up with a device to capture and send to an FTP server 
and allow for VPN connectivity then why can the most powerful law 
agency in the world not do the same.  This way  they controll it all. 
We just provide the pipe to get the data back to their preferred 
location.   I do not know much about CALEA.  I am still reading more 
and more, but if they are asking us to do something, then they had 
better already know how to do it.


ross


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Re: [WISPA] CALEA Compliance

2007-05-01 Thread Mark Koskenmaki
Prior to CALEA, my plan for helping law enforcement consisted of the
following... Introducing them to my upstream (they'd already know them
anyway, because my netblocks belong to them) and having them use my
provider's nice, secure NOC for tapping into my upstream traffic via a
managed switch and mirroring.

I have no place to put a mediation box, no place to put any kind of physical
tap.   I have no physical point this can be done, WITHIN THE BOUNDARIES OF
MY NETWORK.   Physically, it has to be located at someone else's facility.
This is not compliant.

And one says why are you stressing?  Ok, how many of you have dealt with
the IRS?  How about electrical codes?   Building codes?   OSHA?  Saying that
the feds just want the data is just like saying the IRS just wants some
money.   Wrong.  They want absolute compliance, to the letter.   When we
had to dispose of solvents and cleaners, we went many rounds with the DEQ
for Oregon.  There was no accomplish this goal, it was obey the letter,
period.   Great solutions were not allowed, because they didn't fit the
absolute letter.  Welcome to the world of regulatory hell.

Conversations with people in DC are one thing.  They will present as a nice
of face as possible to disarm you.  The IRS people are pleasant... at
first.. too.So was the DEQ.   Oh, we don't want to fine you, just get
you into compliance, but the moment we talked to them, we had to
immediately do what they demanded, or face fines.  For instance, we had to
clean some parts in something like carb cleaner.  It is washed off with high
pressure hot water.   That means that it, and the water you wash it off
with... is hazardous waste.   So, limits on the disposal of hazardous
waste?   Well, we had a gallon limit.  So, we said, we buy 20 gallons a
year, does this mean we generate 20 gallons of waste?   The answer was
no.   Every gallon of water used to rinse it off became another measured
gallon.   They told us that the preferred method of disposal was to
evaporate the carb cleaner.  So, we said great... we'll just rinse it off
with water and evaporate the water and cleaner.  Nope.  if we rinse it with
water, then that water counts toward hazardous waste gallons.   Stupid, eh?
No matter how much water we used, we were still evaporating 20 gallons of
this solvent.  But the evaporated water was 'hazardous waste and if we
mixed too much water in this, we went over the gallon limit.

Read the document...  They will read your filings, and then they will start
on a process of bringing you into compliance.   Tapping at your gateway?
That's fine.  That's good faith to start.   Then you will have to
demonstrate contined progress toward compliance.   Dont' have 24 hour
response?  That's fine.  You will only need to say WHEN you'll have it.
You WILL eventually have to capture it at the client end, or at the AP if
you're wireless.   You WILL provide a date when this will happen.

I hate to say it, but it sounds like some very gullible people talked to the
feds.   They're not the ones who will be reading the forms and assessing
fines.  They are there to put a nice face on things.   But compliance, to
the letter?   That's what the name of the game is.  Always will be.   Always
has been.

What has to be gotten across, is that some technologies do not work this
way.   They will have to make a definitive statement ( the calea faq is
woefully out of date - www.askcalea.net , with contradictory information
published later) .   I quote:  The primary goal of the Order is to ensure
that Law Enforcement Agencies have all of the resources that CALEA
authorizes with regard to facilities-based broadband Internet access
providers (ISP) and interconnected voice over Internet protocol (VOIP)
providers. 

Not to do what you can but to get EVERYTHING they they are authorized to
get.
That's my opinion of how the future is going to play out, unless something
changes between now and then.   They make the statement that we don't
intend to alter the way networks work.   But when you read the way
enforcement works.. You will.

Just witness how many people are talking about fundamentally altering
network operations to be compliant now.

But more importantly... from this day forward, you will not be able to
start, or deploy a wireless or any other kind of internet providing network
that doesn't have ALL aspects of  CALEA compatibility built in.   That
pretty much rules out the vast majority of present equipment and methods of
deployment.


- Original Message - 
From: Ross Cornett [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Tuesday, May 01, 2007 7:40 AM
Subject: Re: [WISPA] CALEA Compliance


 I still would like to know the amount of incident that this CALEA will
cause
 for all of its costs to our industry.  Did anyone ask the FBI, why they
 cannot have several machines and deliver them as needed pre-configured
then
 we can install them when they are needed.  It is highly unreasonable for
the
 FBI to ask

Re: [WISPA] CALEA Compliance

2007-05-01 Thread Tim Kery
Hi Ross,

 

To your point below, it was actually the FBI's (and other law
enforcement agencies(LEAs)) inability to do just what you describe that
precipitated expanding CALEA to facilitates based broadband and
interconnected VOIP providers. 

 

To date, every time law enforcement has shown up at one of our clients'
doors, the intercept had to be handled on an individual case basis
(ICB). Now if you think about the variety of broadband offerings (DSL,
Cable, Fiber, Wireless, Satellite, Broadband over Power Lines, etc), the
endless possible backbone configurations and vendor equipment choices,
and then factor in the complexity and mobility of VOIP offerings from
Skype to Vonnage, ect, you end-up with a situation where no one LEA can
have a 'magic box' that they can drop into every environment that:

 

1.)collects evidence in a legally admissible manner

2.)protects the privacy of users that aren't targeted

 

Because of this it isn't possible for the LEA to quickly get a intercept
up and running in many environments and in time sensitive situations
such as an Amber Alert or public safety emergency (i.e. - terrorism),
this can be a serious impediment.

 

You also have to remember that Law Enforcement's primary focus is Law
Enforcement and not developing technology. The FBI/DEA/DOJ said as much
when in 2004 they petitioned the FCC to expand CALEA to broadband and
VoIP. Essentially, they argued that it isn't possible for them to keep
up with the pace of technology. (By the way, this isn't an ability
issue, the FBI and Secret Service, ect. have exceptionally talented
teams. Instead it really is a resource issue; the number of staff they
have to cover these issues can't cover the scale of the problem.) 

 

As a result of the FBI/DEA/DOJ request, the FCC posted a Notice of
Proposed Rulemaking (NPRM) in August of 2004 seeking comment from all
effected parties (industry, consumers, and law enforcement). In August
of 2005 the FCC Released the First Report and Order and Further NPRM
that outlined some of the FCC's ruling sought further comment on certain
aspects the ruling. In May of 2006 the FCC's Second Order and Report on
this issue finalized the expansion of CALEA to facilities based
broadband providers and interconnected VoIP providers. Shortly
thereafter in June 2006, the DC circuit court of appeals upheld FCC's
CALEA Broadband Order in American Council on Education vs. FCC.

 

Hope this helps.

 

Tim Kery

BearHill Security, Inc.

[EMAIL PROTECTED]

 

Date: Tue, 1 May 2007 09:40:06 -0500

From: Ross Cornett [EMAIL PROTECTED]

Subject: Re: [WISPA] CALEA Compliance

To: WISPA General List wireless@wispa.org

Message-ID: [EMAIL PROTECTED]

Content-Type: text/plain; format=flowed; charset=iso-8859-1;

  reply-type=response

 

I still would like to know the amount of incident that this CALEA will
cause for all of its costs to our industry.  Did anyone ask the FBI, why
they cannot have several machines and deliver them as needed
pre-configured then we can install them when they are needed.  It is
highly unreasonable for the FBI to ask everyone to have a utility and
manage this utility when it will never be used by a very large portion
of our industry.  It is far cheaper for the government to sameday ship
their device to us anywhere in the nation then it is to have everyone
else trying to scramble to satisfy a need that will largely be an
expensive dust collector in most businesses.

 

Anyone know if this has been posed to the FBI.

 

http://www.bearhill.com/ 

 

 

 

 

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[WISPA] CALEA Compliance

2007-04-30 Thread Todd Barber
I have been quietly watching and waiting as the CALEA compliance issue has
been discussed and information pertaining to it has become available over
the last few months.

 

I have seen numerous posts on the WISPA list indicating that a cost
effective and compliant solution for this issue was being worked on and
would become available in the near future.

 

I have seen numerous posts indicating that small providers should not be
concerned and that attaining CALEA compliance would not put them out of
business.

 

One of the latest posts indicated that Bearhill would be a good company to
contact to get details and pricing for a cost effective TTP.  

 

I contacted them today.  If this is the cost effective solution that is
available, it isn’t cost effective enough for our operation.  The monthly is
¼ of our current bandwidth costs and the upfront is twice the cost of our
head-end router that is servicing all of our customers.  

 

Fortunately, our business is making enough money to actually pay for this
but it does significantly impact our business model.  It seriously makes me
consider whether staying in the WISP business is worthwhile.

 

Larger operators can easily say that CALEA compliance is just another cost
of doing business and that the cost of implementing it is reasonable.
Larger operators can also say that we have a poor business model and if our
business model was different this compliance would be a non issue.  

 

The facts remain that our business model currently is profitable and we are
providing a valuable service in a rural area.  The added costs of CALEA
compliance jeopardize our ability to continue providing service.  Who needs
to explain to the hundreds of happy customers I currently service in a rural
community that they no longer have high speed internet and don’t have an
alternative broadband solution?  

 

If someone has better information on how a small ISP can become CALEA
compliant in a cost effective manner, please contact me as I am all ears.
If there is better information or a defined solution being presented on the
WISPA member list, I am more than willing to pay membership dues to access
it.  If there isn’t a better solution being discussed there, I would just as
well save the due money as it will probably not be long before we are out of
business or sell to a larger competitor and the membership will be useless.


 

Thanks in advance for any help.

 

 

Todd Barber

Skylink Broadband Internet

[EMAIL PROTECTED]

970-454-9499

 

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Re: [WISPA] CALEA Compliance

2007-04-30 Thread mliotta
 I have seen numerous posts on the WISPA list indicating that a cost
 effective and compliant solution for this issue was being worked on and
 would become available in the near future.

I think that is wishful thinking on some people's part. When you see
companies like Cisco struggle to provide a minimum of support on a small
subset of their products you can begin to imagine the scope of the
problem. Every post I have seen where people have suggest a solution, the
suggestion only solved one specific part of CALEA. Solving part of the
problem is not enough.

 I have seen numerous posts indicating that small providers should not be
 concerned and that attaining CALEA compliance would not put them out of
 business.

I would argue that small providers should be very concerned. Not just
about CALEA, but a concerted effort on the part of large telcos to ruin
competition through seemingly legimate public safety issues.

 The facts remain that our business model currently is profitable and we
 are
 providing a valuable service in a rural area.  The added costs of CALEA
 compliance jeopardize our ability to continue providing service.  Who
 needs
 to explain to the hundreds of happy customers I currently service in a
 rural
 community that they no longer have high speed internet and don’t have an
 alternative broadband solution?

Unfortunately, many consumers will lose as small companies go under. This
won't be the first policy that is designed for the good of the many as
opposed to the few. It isn't fair, but it is done.

 If someone has better information on how a small ISP can become CALEA
 compliant in a cost effective manner, please contact me as I am all ears.
 If there is better information or a defined solution being presented on
 the
 WISPA member list, I am more than willing to pay membership dues to access
 it.  If there isn’t a better solution being discussed there, I would just
 as
 well save the due money as it will probably not be long before we are out
 of
 business or sell to a larger competitor and the membership will be
 useless.

I personally do not believe that any CALEA can be cost effective. Quite
simply, solving CALEA requires spending money without earning any
additional revenue. The only way to justify the CALEA expense is to accept
it as a cost of doing business. This means simply that your market
opportunity is lost if you aren't CALEA compliant. I firmly believe every
service provider should have plans for being CALEA compliant or have plans
for exiting the business. This one is different than E911; the liability
will be staggering.

-Matt
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Re: [WISPA] CALEA Compliance

2007-04-30 Thread Jack Unger
I'd like to add my own brief CALEA comments and concerns. Out of respect 
for the maximum of 5 posts per day proposal, I'll keep it short.


I'm thinking that extending CALEA to small WISPs without compensating 
them for their costs has more to do with the big fish eating the little 
fish than it has to do with national security or fighting crime.


It also has a lot to do with Big Brother's quest for efficient control 
of the citizenry. It's much easier for government overseers to deal with 
a few big businesses than it is for them to deal with thousands of small 
businesses.


I also can't help but wonder who owns the TTPs. Heck, if some of those 
are government front companies or owned by friends of people already 
installed in the Justice Department or the CIA, wouldn't that make 
illegal information gathering (for business or political purposes) even 
easier?


But that's only my 2 cents worth... and I could be wrong.

I'd like to hear the FCC response to Rep. Bart Stupak's request to waive 
the CALEA regulations for small broadband providers, as described in the 
following link.


http://www.wispa.org/?p=21


In addition, this next link provides an interesting summary of what 
CALEA means to small ISPs and WISPs.


http://www.freerepublic.com/focus/f-chat/1825361/posts


jack


[EMAIL PROTECTED] wrote:

I have seen numerous posts on the WISPA list indicating that a cost
effective and compliant solution for this issue was being worked on and
would become available in the near future.


I think that is wishful thinking on some people's part. When you see
companies like Cisco struggle to provide a minimum of support on a small
subset of their products you can begin to imagine the scope of the
problem. Every post I have seen where people have suggest a solution, the
suggestion only solved one specific part of CALEA. Solving part of the
problem is not enough.


I have seen numerous posts indicating that small providers should not be
concerned and that attaining CALEA compliance would not put them out of
business.


I would argue that small providers should be very concerned. Not just
about CALEA, but a concerted effort on the part of large telcos to ruin
competition through seemingly legimate public safety issues.


The facts remain that our business model currently is profitable and we
are
providing a valuable service in a rural area.  The added costs of CALEA
compliance jeopardize our ability to continue providing service.  Who
needs
to explain to the hundreds of happy customers I currently service in a
rural
community that they no longer have high speed internet and don’t have an
alternative broadband solution?


Unfortunately, many consumers will lose as small companies go under. This
won't be the first policy that is designed for the good of the many as
opposed to the few. It isn't fair, but it is done.


If someone has better information on how a small ISP can become CALEA
compliant in a cost effective manner, please contact me as I am all ears.
If there is better information or a defined solution being presented on
the
WISPA member list, I am more than willing to pay membership dues to access
it.  If there isn’t a better solution being discussed there, I would just
as
well save the due money as it will probably not be long before we are out
of
business or sell to a larger competitor and the membership will be
useless.


I personally do not believe that any CALEA can be cost effective. Quite
simply, solving CALEA requires spending money without earning any
additional revenue. The only way to justify the CALEA expense is to accept
it as a cost of doing business. This means simply that your market
opportunity is lost if you aren't CALEA compliant. I firmly believe every
service provider should have plans for being CALEA compliant or have plans
for exiting the business. This one is different than E911; the liability
will be staggering.

-Matt


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Re: [WISPA] CALEA Compliance

2007-04-30 Thread John Scrivner



I personally do not believe that any CALEA can be cost effective. Quite
simply, solving CALEA requires spending money without earning any
additional revenue. The only way to justify the CALEA expense is to accept
it as a cost of doing business. This means simply that your market
opportunity is lost if you aren't CALEA compliant. I firmly believe every
service provider should have plans for being CALEA compliant or have plans
for exiting the business. This one is different than E911; the liability
will be staggering.

-Matt
 


Matt,
We look forward to proving that this thinking is wrong. What part of 
CALEA compliance is it that makes you think we cannot develop a low cost 
and reasonable solution which will not break the bank?

Scriv


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RE: [WISPA] CALEA Compliance

2007-04-30 Thread Todd Barber
John,

The part that is causing disbelief for me is the deadline is only days away
and I haven't seen this solution or the costing for the solution.  

Todd Barber
Skylink Broadband Internet
[EMAIL PROTECTED]
970-454-9499


-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of John Scrivner
Sent: Monday, April 30, 2007 9:14 PM
To: WISPA General List
Subject: Re: [WISPA] CALEA Compliance


I personally do not believe that any CALEA can be cost effective. Quite
simply, solving CALEA requires spending money without earning any
additional revenue. The only way to justify the CALEA expense is to accept
it as a cost of doing business. This means simply that your market
opportunity is lost if you aren't CALEA compliant. I firmly believe every
service provider should have plans for being CALEA compliant or have plans
for exiting the business. This one is different than E911; the liability
will be staggering.

-Matt
  

Matt,
We look forward to proving that this thinking is wrong. What part of 
CALEA compliance is it that makes you think we cannot develop a low cost 
and reasonable solution which will not break the bank?
Scriv


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Re: [WISPA] CALEA Compliance

2007-04-30 Thread Marlon K. Schafer
There won't be a WISPA standard done in time.  We're still waiting on some 
documentation from the FBI and we need to get some internal documentation 
together as well.


But you don't have to be compliant with ANY standard to be CALEA compliant! 
You just have to understand what you have to do if they ask and have 
mechanisms in place to do it.


The basic parts you'll need are:
Linux based router or tap capabilities on the on you have.  OR a managed 
switch that will allow you to mirror a port.

Linux server with OpenCALEA and an FTP program on it.
Knowledge of how to make it record and distribute the needed data for LEA.

You don't HAVE to use a TTP.  You don't HAVE to follow a standard.  You 
don't HAVE to panic just yet.


*I've* talked to the folks at the FBI.  They are NOT interested in running 
anyone out of business.  They just want to catch bad guys and they *may* 
need our help to do it.  Everything past that point is FUD.


Why have a standard at all then?  Because if you don't follow a standard you 
have to TRY to do anything that LEA asks of you.  If you are standards 
compliant you only have to do what the standard says you have to do.


Believe it or not, guys like Tim at Bearhill are working WITH WISPA in our 
efforts to develop a low cost/no cost solution to CALEA.  We all know that 
many in this industry are still trying to figure out how to pay the bill on 
that latest order for 3 cpe units.  I was sometimes 60 days behind with EC. 
I always paid but rarely on time.  Sucked for me and for them.  Fortunately, 
they hung with me and today we're as likely to be prepaid as we are to owe 
them.  It's a nice change of pace.  We also order radios in bulk, every 
couple to few weeks, rather than 1 or 2 at a time.  Wondering how to make 
payroll, or buy diapers sucks.  Most of us have been there.  We got through 
those times partly because others reached a hand down and helped us where 
they could.  We worked hard, honestly and consistently.


I suggest that those of you in panic mode over CALEA go to www.askcalea.net 
and read up on it.  Contact the FCC and the FBI yourselves if you don't 
believe those of us that are doing this work.  So far I've found that folks 
are more than happy to answer my direct questions.


At LEAST contact those that WISPA sent to the FBI!  They know a lot of 
answers and they have a direct line to the FBI if they don't know the 
answer.


Yeah, CALEA is a big deal.  Yeah it's complicated.  Yeah, it'll suck to have 
to perform.  Yeah, you have to do it anyway :-).  Might as well stop whining 
and start figuring out what all of those ttp's have already gotten figured 
out.


Someone's gonna make money off of those out there that can't/won't figure it 
out for themselves.  Might as well be you!

marlon

- Original Message - 
From: Todd Barber [EMAIL PROTECTED]

To: 'WISPA General List' wireless@wispa.org
Sent: Monday, April 30, 2007 8:19 PM
Subject: RE: [WISPA] CALEA Compliance



John,

The part that is causing disbelief for me is the deadline is only days 
away

and I haven't seen this solution or the costing for the solution.

Todd Barber
Skylink Broadband Internet
[EMAIL PROTECTED]
970-454-9499


-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of John Scrivner
Sent: Monday, April 30, 2007 9:14 PM
To: WISPA General List
Subject: Re: [WISPA] CALEA Compliance



I personally do not believe that any CALEA can be cost effective. Quite
simply, solving CALEA requires spending money without earning any
additional revenue. The only way to justify the CALEA expense is to accept
it as a cost of doing business. This means simply that your market
opportunity is lost if you aren't CALEA compliant. I firmly believe every
service provider should have plans for being CALEA compliant or have plans
for exiting the business. This one is different than E911; the liability
will be staggering.

-Matt



Matt,
We look forward to proving that this thinking is wrong. What part of
CALEA compliance is it that makes you think we cannot develop a low cost
and reasonable solution which will not break the bank?
Scriv


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Re: [WISPA] CALEA Compliance

2007-04-30 Thread Mark Koskenmaki

John, the reason I don't buy it, is as has been said...we're days from the
deadline, and we have nothing.

And, further, we don't know what's being worked on.   There's a whole LOT of
issues.   There's extraction.  There's picking out what's required.
There's  storage, there's VPN to the LEA,  the list just goes on and on and
on.   Nobody can build a single device or program that can be applied to
even the majority of networks.   Not even a single point passthrough device
that caches everyting (think solera) is going to work, if we have mutliple
gateways in physically diverse locations.No solution is going to be
universal.   We all have such diverse ways of doing things that I'd say that
any single solution won't even apply to the majority.

There's the data format requirement, and the list goes on and on.   What
particular aspect is being worked on?   The part that converts data to what
they want?   What about the tools to get the right information?   What about
a handbook that explains what data is required by the babble that shows up
as acronyms or legalese?What about LEA's VPN's?   What standard do they
follow? Once you start down the road analyzing what you have to do after
looking at the requirements, the 'assurances' here, at least, leave more
questions than before.   Without knowing what WISPA's doing, or anyone else
is doing, we don't even know what parts won't work for us and we need to try
to synthesize in two weeks.

I have many hours of reading  everything I can find, starting with the rules
published by the FCC.   Much of what is being said on this list by WISPA
CALEA project people appears to conflict with what I read from the FCC
itself.Once you start through the process they outline, you will FULLY
comply, or you will exit the business, and that FULLY comply requires a
lot of things that have been pooh-pooh'ed publicly here.

Now, not to pick a fight, which I don't want to do.   Nor to argue the
merits of ANY of this,  I consider myself reasonably bright and at least
somewhat capable of running a WISP... And yet I cannot, seriusly, cannot
figure out what I really have to do and not do.

Much of what's being discussed here and elsewhere is VERY confusing.For
instance,  I keep reading that if you follow the industry standard, then you
only have to do what's in the standard.  But if you don't, then you have to
do everything they ask.   How the heck can the standard be acceptable if it
doesn't do everything they want?If we must capture all the traffic, then
it must be done at the client end.   If we  can't, then we really ARE NOT
compliant.   What's the point in working on something that's obviously
deficient in the first place?

Mostly, a lot of us just understand in our guts, that they have all the
power, and absolutely NO hesitation in destroying us individually.
Washington DC DOES NOT CARE ABOUT INDIVIDUAL PROVIDERS.  Learn this, accept
it, it is the definitive truth.Reassurances that they're not out to get
us is nothing more than the attitude of a few political types in DC that
have talked to WISPA people.   We won't be dealing with them.  Their
assurances are...  worth less than the ink required to print them out.
The only hesitation they have, is if they get painted badly in the evening
news.And we'll never make the news.

The fact is, the people enforcing the rules are going to go by the letter.
The absolute letter, bent as far as possible in the direction they want it
bent.   And that won't be our favor.Enforcement won't be impressed by
but I was assured you won't put me out of business.We're just a number
and name, and not even a face.   They'll do what government does... hand out
fines as agressively as they can justify.  And since none of us can
individually mount a defense of any kind, we ARE gone and dead.

Why WISPA did not say in first response This CANNOT BE DONE, I have no
idea.   But you spoke for us and said you thought it ws a good idea.   You
killed us without any more consideration, apparently, than DC has for us.
I say this to the people who communicated / filed / responded to the FCC and
FBI.

Frankly, I suggest we collectively hire some legal counsel to find some way
of just stepping around it or a solid strategy for dealing with the fallout.
Some real legal eagle shark type stuff.  I suspect whether we do our utmost
or ignore it, we're mostly going to end up in the same shoes.






- Original Message - 
From: John Scrivner [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Monday, April 30, 2007 8:13 PM
Subject: Re: [WISPA] CALEA Compliance



 I personally do not believe that any CALEA can be cost effective. Quite
 simply, solving CALEA requires spending money without earning any
 additional revenue. The only way to justify the CALEA expense is to
accept
 it as a cost of doing business. This means simply that your market
 opportunity is lost if you aren't CALEA compliant. I firmly believe every

[WISPA] CALEA Costs-Shifting Relief

2007-04-26 Thread Peter R.

*Section 109(b)(1) Petitions for Cost-Shifting Relief*

CALEA section 109(b) permits a “telecommunications carrier,” as that 
term is defined by CALEA, to file a petition with the FCC and an 
application with the Department of Justice (DOJ) to request that DOJ pay 
the costs of the carrier’s CALEA compliance (cost-shifting relief) with 
respect to any equipment, facility or service installed or deployed 
after January 1, 1995. First, the carrier must file a section 109(b)(1) 
petition with the FCC and prove that, based on one or more of the 
criteria set forth in section 109(b)(1)(A)-(K), implementation of at 
least one particular solution that would comply with a particular CALEA 
section 103 capability requirement is not “reasonably achievable.” 
Second, if the Commission grants a section 109(b)(1) petition, the 
carrier must then apply to DOJ, pursuant to section 109(b)(2), to pay 
the reasonable costs of compliance for one of the solutions proposed in 
the section 109(b)(1) petition. DOJ may then either pay the reasonable 
costs of compliance or deny the application.


If DOJ denies the section 109(b)(2) application, then the carrier is 
deemed to be CALEA compliant for the facilities, networks, and services 
(facilities) described in the section 109(b)(1) petition until those 
facilities are replaced, significantly upgraded or otherwise undergo a 
major modification. When those facilities are replaced, significantly 
upgraded or otherwise undergo a major modification, the carrier is 
obligated under the law to become CALEA compliant. The FCC may also 
specify in its CALEA section 109(b)(1) order granting a carrier’s 
petition the specific date when the replacement, upgrade or modification 
will occur and when CALEA compliance is required. Thus, a carrier’s 
obligation to comply with all CALEA requirements is only deferred when 
(1) the FCC grants a section 109(b)(1) petition, and (2) DOJ declines to 
pay the additional reasonable costs to comply with one or more of the 
CALEA requirements. No qualifying carrier is exempt from CALEA.


Section 109(b)(1) petitions must be adequately supported, and the FCC 
decides whether to grant the petition strictly in reference to criteria 
set out in section 109(b)(1). Accordingly, carriers are encouraged to 
consult with competent legal and technical counsel before filing such a 
petition. Please note that a filing fee of $5,000.00 is required to 
accompany all CALEA section 109(b)(1) petitions filed with the FCC. See 
Appendix E entitled “Section 109(b)(1) Petitions for Cost-Shifting 
Relief: Filing Instructions,” and paragraphs 38-57 of the CALEA Second 
Report and Order 
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-56A1.pdf for 
detailed filing instructions and further explanation of the scope of 
relief, and its limitations, available under section 109(b).


More at the bottom of this page: http://www.fcc.gov/calea/
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Re: [WISPA] CALEA Costs-Shifting Relief

2007-04-26 Thread Dawn DiPietro

Peter,

Thank you for posting this information. Since there is a $5000 
application fee and that the provider has to prove that they have tried 
to comply I doubt the providers that scream the loudest will even take 
this information seriously and discount it like everything else we have 
heard about recently. I have heard on other lists that it is very 
difficult to get anything to come of this but as you know the 
misinformation flies rampantly these days. :-)


Regards,
Dawn DiPietro


Peter R. wrote:

*Section 109(b)(1) Petitions for Cost-Shifting Relief*

CALEA section 109(b) permits a “telecommunications carrier,” as that 
term is defined by CALEA, to file a petition with the FCC and an 
application with the Department of Justice (DOJ) to request that DOJ 
pay the costs of the carrier’s CALEA compliance (cost-shifting relief) 
with respect to any equipment, facility or service installed or 
deployed after January 1, 1995. First, the carrier must file a section 
109(b)(1) petition with the FCC and prove that, based on one or more 
of the criteria set forth in section 109(b)(1)(A)-(K), implementation 
of at least one particular solution that would comply with a 
particular CALEA section 103 capability requirement is not “reasonably 
achievable.” Second, if the Commission grants a section 109(b)(1) 
petition, the carrier must then apply to DOJ, pursuant to section 
109(b)(2), to pay the reasonable costs of compliance for one of the 
solutions proposed in the section 109(b)(1) petition. DOJ may then 
either pay the reasonable costs of compliance or deny the application.


If DOJ denies the section 109(b)(2) application, then the carrier is 
deemed to be CALEA compliant for the facilities, networks, and 
services (facilities) described in the section 109(b)(1) petition 
until those facilities are replaced, significantly upgraded or 
otherwise undergo a major modification. When those facilities are 
replaced, significantly upgraded or otherwise undergo a major 
modification, the carrier is obligated under the law to become CALEA 
compliant. The FCC may also specify in its CALEA section 109(b)(1) 
order granting a carrier’s petition the specific date when the 
replacement, upgrade or modification will occur and when CALEA 
compliance is required. Thus, a carrier’s obligation to comply with 
all CALEA requirements is only deferred when (1) the FCC grants a 
section 109(b)(1) petition, and (2) DOJ declines to pay the additional 
reasonable costs to comply with one or more of the CALEA requirements. 
No qualifying carrier is exempt from CALEA.


Section 109(b)(1) petitions must be adequately supported, and the FCC 
decides whether to grant the petition strictly in reference to 
criteria set out in section 109(b)(1). Accordingly, carriers are 
encouraged to consult with competent legal and technical counsel 
before filing such a petition. Please note that a filing fee of 
$5,000.00 is required to accompany all CALEA section 109(b)(1) 
petitions filed with the FCC. See Appendix E entitled “Section 
109(b)(1) Petitions for Cost-Shifting Relief: Filing Instructions,” 
and paragraphs 38-57 of the CALEA Second Report and Order 
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-56A1.pdf 
for detailed filing instructions and further explanation of the scope 
of relief, and its limitations, available under section 109(b).


More at the bottom of this page: http://www.fcc.gov/calea/


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Re: [WISPA] CALEA Costs-Shifting Relief

2007-04-26 Thread Mark Koskenmaki
I'm a bit confused, because I thougth the FCC specifically stated that there
is no longer any funds, nor are any applications under those sections
accepted anymore.

http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-56A1.pdf

Relevant paragraph:

2. More generally, we herein specify mechanisms to ensure that
telecommunications

carriers comply with CALEA. Specifically, under the express terms of the
statute, all carriers subject to

CALEA are obliged to become CALEA-compliant. We find that sections 107(c)
and 109(b) of CALEA

provide only limited and temporary relief from compliance requirements, and
that they are

complementary provisions that serve different purposes, which are,
respectively: (1) extension of the

CALEA section 103 compliance deadline for equipment, facility, or service
deployed before October 25,

1998; and (2) recovery of CALEA-imposed costs.







- Original Message - 
From: Dawn DiPietro [EMAIL PROTECTED]
To: [EMAIL PROTECTED]; WISPA General List wireless@wispa.org
Sent: Thursday, April 26, 2007 9:38 AM
Subject: Re: [WISPA] CALEA Costs-Shifting Relief


 Peter,

 Thank you for posting this information. Since there is a $5000
 application fee and that the provider has to prove that they have tried
 to comply I doubt the providers that scream the loudest will even take
 this information seriously and discount it like everything else we have
 heard about recently. I have heard on other lists that it is very
 difficult to get anything to come of this but as you know the
 misinformation flies rampantly these days. :-)

 Regards,
 Dawn DiPietro


 Peter R. wrote:
  *Section 109(b)(1) Petitions for Cost-Shifting Relief*
 
  CALEA section 109(b) permits a “telecommunications carrier,” as that
  term is defined by CALEA, to file a petition with the FCC and an
  application with the Department of Justice (DOJ) to request that DOJ
  pay the costs of the carrier’s CALEA compliance (cost-shifting relief)
  with respect to any equipment, facility or service installed or
  deployed after January 1, 1995. First, the carrier must file a section
  109(b)(1) petition with the FCC and prove that, based on one or more
  of the criteria set forth in section 109(b)(1)(A)-(K), implementation
  of at least one particular solution that would comply with a
  particular CALEA section 103 capability requirement is not “reasonably
  achievable.” Second, if the Commission grants a section 109(b)(1)
  petition, the carrier must then apply to DOJ, pursuant to section
  109(b)(2), to pay the reasonable costs of compliance for one of the
  solutions proposed in the section 109(b)(1) petition. DOJ may then
  either pay the reasonable costs of compliance or deny the application.
 
  If DOJ denies the section 109(b)(2) application, then the carrier is
  deemed to be CALEA compliant for the facilities, networks, and
  services (facilities) described in the section 109(b)(1) petition
  until those facilities are replaced, significantly upgraded or
  otherwise undergo a major modification. When those facilities are
  replaced, significantly upgraded or otherwise undergo a major
  modification, the carrier is obligated under the law to become CALEA
  compliant. The FCC may also specify in its CALEA section 109(b)(1)
  order granting a carrier’s petition the specific date when the
  replacement, upgrade or modification will occur and when CALEA
  compliance is required. Thus, a carrier’s obligation to comply with
  all CALEA requirements is only deferred when (1) the FCC grants a
  section 109(b)(1) petition, and (2) DOJ declines to pay the additional
  reasonable costs to comply with one or more of the CALEA requirements.
  No qualifying carrier is exempt from CALEA.
 
  Section 109(b)(1) petitions must be adequately supported, and the FCC
  decides whether to grant the petition strictly in reference to
  criteria set out in section 109(b)(1). Accordingly, carriers are
  encouraged to consult with competent legal and technical counsel
  before filing such a petition. Please note that a filing fee of
  $5,000.00 is required to accompany all CALEA section 109(b)(1)
  petitions filed with the FCC. See Appendix E entitled “Section
  109(b)(1) Petitions for Cost-Shifting Relief: Filing Instructions,”
  and paragraphs 38-57 of the CALEA Second Report and Order
  http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-56A1.pdf
  for detailed filing instructions and further explanation of the scope
  of relief, and its limitations, available under section 109(b).
 
  More at the bottom of this page: http://www.fcc.gov/calea/

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