Page:2020-06-09 PSI Staff Report - Threats to U.S. Communications Networks.pdf/101

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Through its wholesale international direct dial services, ComNet handles inbound and outbound voice traffic for U.S. carrier customers.[1] International voice traffic is routed through ComNet's global MPLS network.[2] Thus, ComNet uses a routing approach that allows data to be directed from one node to the next. based on routing labels.[3] Data is aggregated on its voice communications platform, which is located at ComNet's point of presence in Los Angeles.[4] From there, data is transmitted to the end-user through either an internet connection provided by Cogent or through a time-division multiplexing ("TDM") connection operated by U.S. carriers.[5] According to ComNet representatives, customers select which TDM vendor ComNet uses to route communications.[6] ComNet also provides SMS services to U.S. carrier customers. Unlike the voice communications platform housed at ComNet's Los Angeles facility, however, SMS communications are aggregated on CITIC's SMS hub platform in Hong Kong.[7] Thus, all international SMS communications are routed through CITIC's servers.[8]

ComNet's retail calling cards are targeted towards end-users in the United States.[9] The calls are routed in a similar manner as international voice calls, but customers in the United States must dial local access numbers.[10] ComNet obtains these numbers from major U.S. carriers.[11]

In 2017, ComNet began offering VoIP services to business customers.[12]

These services allow office users the functions of an office telephone system.[13] Through VoIP phones provided either by ComNet or by the business itself, users

  1. ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); Briefing with ComNet (Apr. 13, 2020).
  2. ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); Briefing with ComNet (Apr. 13, 2020).
  3. ↑ Multiprotocol Label Switching, Tech Target, https://searchnetworking.techtarget.com/definition/Multiprotocol-Label-Switching-MPLS.
  4. ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); Briefing with ComNet (Apr. 13, 2020).
  5. ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); Briefing with ComNet (Apr. 13, 2020); DHS00466-71, at DHS00468PSI. The TDM connection is a physical fiber line that connects two points. Briefing with ComNet (Apr. 13, 2020).
  6. ↑ Briefing with ComNet (Apr. 13, 2020).
  7. ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); Briefing with ComNet (Apr. 13, 2020).
  8. ↑ Cf. Briefing with ComNet (Apr. 13, 2020).
  9. ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); Briefing with ComNet (Apr. 13, 2020).
  10. ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); Briefing with ComNet (Apr. 13, 2020).
  11. ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); Briefing with ComNet (Apr. 13, 2020); Letter from Lerman Senter PLLC, counsel to ComNet, to the Subcommittee (June 2, 2020) (on file with the Subcommittee).
  12. ↑ DHS00466-71, at DHS00468PSI; TT-DOJ-521-23, at TT-DOJ-522.
  13. ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); DHS00466-71, at DHS00468PSI.

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