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Xunity Inc.
Principals, Affiliates, Subsidiaries & Parent: M. Mariotti
{"ct_name":"Chuck Mariotti","ct_title":"Owner","ct_dept":"Technology","ct_address":"13 Seymour Ave | Toronto M4J 3T3 | Ontario","ct_tel":"+14164695008","ct_email":"cmariotti@xunity.com","bz_address":"13 Seymour Ave | Ontario M4J 3T3 Toronto, Canada","country":"Canada","declare":"2024-05-24","last_seen":"2024-07-25","sys_id":"dd8bbfaa1bd6c6103252ec20f54bcb20","is_new":0,"gw_prov":"false","gw_prov_choice":"No","combined_gw":"false","ipr_imported":"false","voice_choice":"Yes","intermed_choice":"No","investigated":"No","intermed_exempt_rule":"","gw_exempt_rule":"","voice_exempt_rule":"Exemption Justification:\nXunity Inc. is based in Canada and primarily serves Canadian clients. While Xunity Inc. ensures compliance with local regulations, the requirement for full STIR\/SHAKEN implementation applies primarily to U.S.-based service providers under FCC jurisdiction. Our upstream provider, which is based in the USA, has fully implemented the STIR\/SHAKEN framework and provides these services to us. We leverage their compliance to meet the necessary authentication standards for our call traffic.\n\nDetails of Exemption Application:\n\nGeographical Jurisdiction: Xunity Inc. operates within Canada and serves Canadian customers, which places us under Canadian regulatory jurisdiction rather than the FCC.\nUpstream Provider Compliance: Our upstream provider, located in the USA, has implemented the STIR\/SHAKEN framework in compliance with FCC requirements. We utilize their infrastructure and services, which includes STIR\/SHAKEN authentication for calls originated on our network.\nTechnical Constraints: Our current infrastructure involves Asterisk servers, which do not fully support native STIR\/SHAKEN implementation. Transitioning to full compliance would require significant technical upgrades and investment. However, we have configured our management interface to support call authentication via our upstream provider's implementation.\nRobocall Mitigation Efforts: Despite the partial implementation, Xunity Inc. has robust robocall mitigation measures in place, including traffic monitoring, caller ID management, and customer vetting, as detailed in our robocall mitigation program.\nSummary:\nXunity Inc. is committed to preventing illegal robocalls and ensuring compliance with relevant regulations. By leveraging the full STIR\/SHAKEN implementation of our upstream provider and maintaining comprehensive mitigation measures, we effectively manage and mitigate the risks associated with robocalls. This approach aligns with the intent of the FCC's regulations while recognizing our operational context and geographical location.","investigate_descript":""}
Partial S/SRMPNYS2024-05-24