Even if it is possible to comply with this ruling in the required timeframe, or longer, the FCC's E911 ruling is structurally flawed. The E911 system should natively support VoIP interfaces, then require VoIP carriers to integrate, instead this ruling requires VoIP carriers to integrate with the existing circuit switched E911 system. Monday 8/15 was the due date for comments to the FCC on the E911 NPRM attached to this ruling, my comments can be read here: http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518143005 Looks like Pulver and the "Global IP Alliance" made a major submission on this NPRM as well, which I'll read ASAP: http://pulverblog.pulver.com/archives/002680.html I will read your draft paper soon also. Don