◆ SpookStack

CPNI does nothing to address a significant portion of CPNI, specifically information needed for billing disputes, which will still need to be secured.”* In fact, the material retained will most likely be the most recent records and hence possibly the most useful for data brokers. Rather than expending effort on promulgating rules with significant omissions, the Commission should instead focus its efforts, and those of carriers, on appropriate security measures that ensure that any access to such records is done only with valid legal authority. As the Department of Justice has urged the Commission for years, one large step in that direction would be to require that CPNI of U.S. customers of domestic services be stored exclusively within the United States.’ In opposing and pointing out the inadequacies of a data destruction regime, the Departments do not thereby imply that the current CPNI rules are adequate effectively to meet law enforcement's needs or protect public safety and national security. As noted above, the Departments have previously asked the Commission to strengthen the security of these records in a number of ways.” Further, developments in the world and in the communications marketplace since the Commission’s last examination of these rules have highlighted the limited scope of the Commission’s rules. Today, many modern 6 The statute of limitations in Section 415 of the Communications Act for billing disputes is two years. 47 U.S.C. § 415. The nature of Section 415 necessarily compels carriers to maintain all potentially relevant documents needed in connection with resolving actions concerning recovery of lawful charges or damages. ” See Reply Comments of the United States Department of Justice and the Federal Bureau of Investigation, fn the Matter of Implementation of the Telecommunications Act of 1996; Telecommunications Carriers’ Use of Customer Proprietary Network Information and Other Customer Information, Third Further Notice of Proposed Rulemaking, CC Docket No. 96-115 at 4, n.& (filed Nov. 19, 2002). 28 See id. See also Comments of the United States Department of Justice, fn the Afatter of [P-Enabled Services, Notice of Proposed Rulemaking, WC Docket No. 04-36 (filed May 28, 2004).