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Law Educator, Esq.
Law Educator, Esq., Attorney
Category: Employment Law
Satisfied Customers: 114782
Experience:  20+ Years of Employment Law Experience
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I own a small staffing/software development company. I

Customer Question

I own a small staffing/software development company. I bought couple vanity toll free numbers to use for online shopping or services that we could build and sell. Now it looks like we need to find a way to lease these numbers out instead of using it ourselves. Can my company be able to sell it out right or I can only lease these numbers? I was inquiring with another vanity number provider who leases numbers, and they said that FCC rules prevent them from selling the vanity numbers to others, once they bought it. I see the value in leasing, but want to make sure, leasing the vanity phone number does not create any legal issues for me, or selling the number would not create any legal issues to me or my company.
Submitted: 1 year ago.
Category: Employment Law
Expert:  Law Educator, Esq. replied 1 year ago.
Thank you for your question. I look forward to working with you to provide you the information you are seeking for educational purposes only.
Under Section 251(e)(1) of the Communications Act, it states that telephone numbers, including toll free numbers, must be made “available on an equitable basis.” This means that toll free numbers, including “vanity” numbers (e.g., 1 - 800 - FLOWERS), cannot be transferred to anyone else and must be returned to the phone number pool so that they can be made available to others interested in applying for them when the current owner of the number no longer wants it.
Section 52.107 of the FCC’s Rules specifically prohibits brokering, which is “the selling of a toll free number by a private entity for a fee.”
So you cannot sell the number off. Leasing the numbers is also considered illegal by the FCC, see:
Thus, you would have to return the number or use it to comply with the law. If you are selling off a business and that number is ***** with your business, you may sell the number as part of the business, since the buyer is purchasing the whole business, not only the number.
Customer: replied 1 year ago.
If I sell the services such as call routing, marketing and lead generation when the paying customer uses the number that I own, would that make me use the vanity numbers, and sell the services to the paying clients and generate leads for them in their markets using these vanity numbers?
I also have somewhat matching web domains to these vanity numbers and my intention is to provide lead generation services, through phone and web site for paying customers.
Expert:  Law Educator, Esq. replied 1 year ago.
Thank you for your reply.
Right, if you are their marketing service and you are including the number in your marketing service, then that is legal for you to do. Same with the web domains, you can package the web domain and phone number into the package deal and that is legal.

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