April 6, 2023 (Via ECFS)

Federal Communications Commission
445 12th Street
Washington, DC 20554

Re: WC Docket 17-97 - Call Authentication Trust Anchor

Dear Chairwoman Rosenworcel,

We are a relatively small VoIP provider based in Nashua, New Hampshire
with customers around the country spanning from large auto dealerships
to over 1,200 restaurants. Recently, over the past few months, we
began to receive complaints from our customers regarding a change in
the presentation of Caller ID, particularly the CNAM (or customer
name) portion. The complaints ranged from calls being labeled "spam
risk" to "city, state" and other misleading labels. We've been
Stir/Shaken compliant for several months and sign all of our
calls. The removal of CNAM and the mislabeling of our calls has served
to create harm both to our customers' businesses and to our reputation
as their provider. The worst of this is the resulting lack of faith
developing in the public phone system's seeming inability to label
calls correctly as well as calls not completing because called parties
are not answering their phones because the customer name is missing or
the call is mislabeled. I would like to chalk this up to the law of
unintended consequences but the fact remains that this recent
phenomenon has been somewhat of a secret. We received no pertinent
information from any of our upstream partners that would have
indicated that this practice was occurring and what the possible
remedy or remedies might be. As a matter of fact, we only discovered
the possible reasons for this after doing a fair amount of digging via
repeated Google searches uncovering companies like Hiya, TNS and First
Orion that we understand are responsible for call analytics.

https://www.fcc.gov/ecfs/document/10406144565925/1