Telephone Numbers – An infinitely available scarce resource

by DLA Piper

How can something infinite still be a scarce resource?  In telecoms that’s exactly what numbers are considered, and they are managed carefully by regulators and operators alike.  And with the advent of many more new communications services, this regulation and management is becoming ever more complex and necessary.

Pennsylvania 65000

Anyone who has made a phone call or owned a phone (everyone reading this?), has had to call a phone number or be called on a phone number – it can be a powerful identifier.  Do you remember a home phone number from your childhood?  Do you remember the number of your favourite takeaway?  But do you remember the number of your spouse?  Or your friend’s new number?  Or are these numbers just stored in your smartphone under their name or photo?

From a technical point of view, numbers are necessary to route calls to their destinations.  Traditionally, they identify locations – from countries, to regions, cities, local areas and exchanges and, finally, the premises.  With the advent of mobile phones, numbers became identified with SIM cards and also became mobile, although still identified to a network. Internet Protocol and IP addresses changed the game again, by identifying devices which can be also mobile or at least portable.

Lucky 7s

Numbers are necessary for the sending of a message from point A to point B. Given their bland technical necessity, one might wonder why people become so emotionally attached to a number. Also, given the advent of smart phone technology and other forms of communications services that don’t rely upon the end user remembering a number (Skype, Whatsapp etc.), the significance of a number for the end user may be diminishing somewhat.

Some numbers are still considered to be socially valuable, such as emergency services numbers, and there is almost a taboo against their abuse (if not an actual offence).  Some numbers are considered “nice” numbers, and are considered by some to be very financially valuable – recently the number 77777777 was auctioned in the UAE for 7,877,777 dirhams  (about US$2,100,000).  Clearly, the buyer saw the value in callers having to only press the lower left hand digit on a dial pad eight times.

So a phone number can be more precious than many people, at first blush, might think.  The popularity of number portability, the ability to carry a number from one place to another, or one network to another, is evidence of how much stock people place on keeping a number with them, if only because they don’t need to advertise to everyone they know about their new phone number.

1 in 26 billion

With the explosion of the human use of mobile phone services around the world combined with the new wave of M2M services and the anticipated “Internet of Things” (“IOT”), numbering resources are becoming ever more important, and strained. Their management, if only to avoid confusion in identifying locations or objects, is vital for the system to work. Gartner expect that by 2020 there could be up to 26 billion devices connected to the internet. Each one will need an identifying number.

So what is a numbering resource? Isn’t it just 1, 2, 3, 4, 5… until the never end? How are they managed?

At the top level, telephone numbers are managed by the International Telecommunications Union, which has issued a recommendation known as E.164, for international public telecommunications.  E.164 “provides the number structure and functionality for the five categories of numbers used for international public telecommunication: geographic areas, global services, Networks, groups of countries (GoC) and resources for trials[1].”

In turn, national regulatory bodies manage their domestic numbering plans, between regions, operators, and services; for example, emergency services, so called “free phone services”, or short code phone numbers that might be used for free calls to competitions or companies etc.

In most of these national systems the numbers are considered scarce national resources and are deemed to be the property of the government. They are not owned by the operator or the end user. However, although it might not be “your” number, many systems allow some form of portability, as discussed above. This flexibility has its limits, and so it is highly unlikely that you can, for instance, gift your phone number to a loved one in a will.

The number crunch

As more devices are connected to the internet, and these devices converge more services together, the management of numbers is becoming more complex.  In the CEPT/ECC Working Group for Numbering and Networks 2013 Greenpaper (“Greenpaper“), the working group anticipates that E.164 will remain the international standard for numbering[2]. However, a major transition will be the replacement of the prevalence of numbers as identifiers for people, with names and photos.  This conversion will be handled by technologies such as ENUM or mapping numbers using SIP addresses.   The ENUM system allows phone number to be mapped on a Domain Name System, effectively making them part of the internet system.

However, while that might work for people based interfaces, M2M services will still need numbers, and as most M2M services use SIM cards they will likely use E.164 numbers. The anticipated explosion of M2M services and the eventual IOT, is expected to put a strain on these numbering systems. Some regulatory bodies have taken action in this regard.  For instance, the Saudi Arabian regulator has implemented an M2M numbering range in its national numbering plan (coupled with a license for Automated Vehicle Location Systems).  However other regulatory bodies don’t appear to be facing up to this issue yet. This raises an interesting prospect: as numbering plans run out of numbers, but the demand for M2M services increases, CEPT/ECC anticipate that some M2M players may use the numbering ranges of another country, which the working group sees as potentially “…causing many problems in areas such as numbering plan administration, number portability, law-enforcement, localisation in case of an emergency call and possibility to evade from national regulatory requirements”[3].

Your number is up

The convergence of services and technology means that there has also been a convergence of various numbering regimes of traditional telephony with IP numbering and various mapping systems that allow these numbers to convert to other identifiers such as names or addresses.  Apart from simple human interactions, M2M services and the IOT are expected to mushroom and put further pressure on all communications resources, including numbering.  It remains to be seen how this will be actively managed, but one thing seems certain; the days of a telecom regulator’s traditional numbering plan seem, well, numbered.

(PS. We dialled the UAE number, 77777777, which is, unsurprisingly, “disconnected”)


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© DLA Piper | Attorney Advertising

Written by:

DLA Piper

DLA Piper on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
Privacy Policy (Updated: October 8, 2015):

JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources. Our policies with regard to data collection and use of personal information of users of the Service, regardless of the manner in which users access the Service, and visitors to the Website are set forth in this statement ("Policy"). By using the Service, you signify your acceptance of this Policy.

Information Collection and Use by JD Supra

JD Supra collects users' names, companies, titles, e-mail address and industry. JD Supra also tracks the pages that users visit, logs IP addresses and aggregates non-personally identifiable user data and browser type. This data is gathered using cookies and other technologies.

The information and data collected is used to authenticate users and to send notifications relating to the Service, including email alerts to which users have subscribed; to manage the Service and Website, to improve the Service and to customize the user's experience. This information is also provided to the authors of the content to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

JD Supra does not sell, rent or otherwise provide your details to third parties, other than to the authors of the content on JD Supra.

If you prefer not to enable cookies, you may change your browser settings to disable cookies; however, please note that rejecting cookies while visiting the Website may result in certain parts of the Website not operating correctly or as efficiently as if cookies were allowed.

Email Choice/Opt-out

Users who opt in to receive emails may choose to no longer receive e-mail updates and newsletters by selecting the "opt-out of future email" option in the email they receive from JD Supra or in their JD Supra account management screen.


JD Supra takes reasonable precautions to insure that user information is kept private. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. However, please note that no method of transmitting or storing data is completely secure and we cannot guarantee the security of user information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem by contacting us at In the unlikely event that we believe that the security of your user information in our possession or control may have been compromised, we may seek to notify you of that development and, if so, will endeavor to do so as promptly as practicable under the circumstances.

Sharing and Disclosure of Information JD Supra Collects

Except as otherwise described in this privacy statement, JD Supra will not disclose personal information to any third party unless we believe that disclosure is necessary to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal process; (4) protect the rights, privacy, safety or property of JD Supra, users of the Service, Website visitors or the public; (5) permit us to pursue available remedies or limit the damages that we may sustain; and (6) enforce our Terms & Conditions of Use.

In the event there is a change in the corporate structure of JD Supra such as, but not limited to, merger, consolidation, sale, liquidation or transfer of substantial assets, JD Supra may, in its sole discretion, transfer, sell or assign information collected on and through the Service to one or more affiliated or unaffiliated third parties.

Links to Other Websites

This Website and the Service may contain links to other websites. The operator of such other websites may collect information about you, including through cookies or other technologies. If you are using the Service through the Website and link to another site, you will leave the Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We shall have no responsibility or liability for your visitation to, and the data collection and use practices of, such other sites. This Policy applies solely to the information collected in connection with your use of this Website and does not apply to any practices conducted offline or in connection with any other websites.

Changes in Our Privacy Policy

We reserve the right to change this Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our privacy policy will become effective upon posting of the revised policy on the Website. By continuing to use the Service or Website following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, please do not continue using the Service or the Website.

Contacting JD Supra

If you have any questions about this privacy statement, the practices of this site, your dealings with this Web site, or if you would like to change any of the information you have provided to us, please contact us at:

- hide
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.