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[November 2, 2001]

Points Of Presence

By Laura Guevin
Editorial Director, Communications ASP

Complying With CALEA

Author's Note [11/06/01]: The information included below about compliance by November 19, 2001 with the two unchallenged "punch list" requirements is incorrect. The November 19 date is for packet-mode compliance only. Compliance with all punch list requirements has been suspended until the FCC resolves the four challenged requirements. I apologize for the error.

The FCC has once again extended the deadline for compliance with the Communications Assistance for Law Enforcement Act (CALEA) to November 19 for wireless, cellular, and broadband service providers. Specifically, those service providers will have to implement two "punch list" requirements by that date. Those items require service providers to provide the content of subject-initiated conference calls pursuant to a court order or legal authorization beyond a pen register order (which captures the phone numbers dialed on outgoing telephone calls), and to provide timing information to correlate call-identifying information with the call content of an interception. Four additional punch list requirements, which have been debated by various members of the industry, are still being discussed by the FCC as they involve separating call or packet-identifying information from the actual contents of a communication. Not all CALEA-compliance solutions available today have the capability to separate that information, and the diverse equipment found in many carriers' and service providers' networks makes it difficult to meet those requirements.

The FBI has been promoting DCS1000 (aka Carnivore) as the solution for compliance, as it can easily intercept wireline and wireless communications. One of the flaws of the system, however, is that it cannot separate call or packet identifying information from actual content, relying on the honesty of law enforcement agents doing the interception to prevent them from reading contents of communications they are not entitled to view.

But there are several alternatives to Carnivore already in use for intercepting wireline communications, and many of these solutions have been modified for use in packet and wireless interceptions.

I recently spoke to Scott Coleman, senior product manager at ADC about their CALEAserver, which offers targeted interception searches based on a specific subscriber's information. A new product, Xcipio, will be launched later this year, combining circuit-switched and IP interception capabilities and offering a migration path for service providers who are changing from Class 5 to packet-switching environments. The company is working closely with Telcordia and has integrated the server with their softswitch. They are also working on interoperability with four additional softswitch vendors.

One of the main differentiators of ADC's solution is that they offer a separate box for sniffing out packets in both ISP and legacy environments, so that law enforcement officials may obtain only the information they are entitled to (i.e. packet routing or signaling information, in the case of VoIP calls), and only on a specific subscriber. As for the disputed punch list items, Coleman said the company is waiting to see what the FCC decides before working on solutions that specifically address those issues. The items in question involve interception of subject-initiated dialing and signaling information, which requires carriers to give authorities access to dialing and signaling information from the subject; party hold, join, and drop information on conference calls; in-band and out-of-band signaling notification messages; and dialed digit extraction, which includes any digits dialed by the subject after connecting to another carrier's service.

"My feeling is that the generosity of extensions is going to be severely curtailed," said Coleman about the FCC's attitude on continuously extending the deadline for compliance with the punch list items. He believes the government will become more aggressive about deployment, and that service providers will be forced to find solutions that will work with the switching equipment they have in place. ADC plans to add new switching interfaces through the end of 2002, and to support additional standards as well.

CALEA compliance was announced Wednesday by CommWorks Corporation in its Total Control 1000 Interworking Function (IWF) High Density Gateway, a wireless gateway for code division multiple access (CDMA) service providers. The gateway enables CDMA providers with 2G and 2.5G data services to deliver Internet and corporate intranet access as well as voice and data services, and supports an interface with all major wireless switches. The company is also working on CALEA compliance for the Total Control 1000 3G Packet Data Serving Node.

Comverse Infosys, a subsidiary of Comverse Technology, offers the STAR-GATE solution for CALEA compliance, supporting both circuit-switched and packet networks. The system consists of a Mediation Device, which offers the delivery functions of surveillance, and a Surveillance Administration Subsystem, which assigns interception targets and oversees administration, maintenance, and security.

The VoiceBoxIII Digital Collection System from JSI Telecom supports circuit-switched intercepts, as well as fax, data, VoIP, and video within a single Windows environment. The solution also supports intercepts of all wireless services from Nextel. The system features a database analysis program for creating text and graphical reports, a post-processing option for generating and managing translations and transcriptions, and forensic capabilities like audio filters, adaptive equalizers, and video clean-up tools.

Pen-Link, Ltd. offers the Local Intercept Network Collection - On Line Network (LINCOLN), which is compatible with existing pen register equipment and may be used in wireline and wireless networks. The system is compliant with CALEA specifications, and may be used for wiretap, pen register, and trap and trace investigations. Pen-Link Software is included with the LINCOLN solution, enabling data collection, management, and analysis, as well as search, retrieval, and playback functions.

Alternative solutions to Carnivore certainly give wireless and broadband service providers a more level playing field for complying with CALEA and the approved punch list items. But compliance still won't be easy, and the FCC is allowing individual carriers to petition for extensions beyond the November 19 date, in anticipation of complications in meeting requirements. As for the contested punch list items, the FCC expects to reach a decision by the end of this year about the feasibility of requiring these items, and has set a date of June 30, 2002 for all carriers to be fully compliant with CALEA.

Laura Guevin welcomes your comments at

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