Analytical Surmises of a GXS Strategy Barring Loren Data Corp from Interconnecting to the TGMS VAN.

Monday May 23
Alan D. Wilensky, Consulting Analyst to Loren Data Corp.

Executive Summary
Note: Background information on the Loren Data Corp v. GXS Antitrust Lawsuit, see the footnotes and appendices for supplementary briefings.

The theory underlying GXS refusal to interconnect with Loren Data Corps ECGrid EDI network relates to the momentum of B2B services, specifically, the increased availability of web based B2B applications (cloud computing, SAAS1 or on-demand services) becoming an accepted model of consuming supply chain IT services. The B2B Service Provider model, exemplified by companies such as SPS Commerce and Di Central, is at odds with a GXS worldview of bundled, captive services. B2B Service Providers also show a tendency to prefer Loren Data EDI Network services over the EDI VAN offerings of GXS or its ilk. The decaying VAN market2 faces negative client perceptions of the legacy providers, with GXS leading the negative sentiment trend as measured by textual analysis of blogs and fora catering to professional discussions of B2B topics. This bolsters the authors opinion3 that new EDI Ventures and corporate endusers are are turning from the VANs to seek alternatives - this dynamic is the VAN exodus. Loren Data Corp has contributed substantially to the advancement of EDI network services during a period completely bereft of innovation. A great insurgence of small and medium businesses began flocking to the likes of SPS Commerce and other on-demand B2B Service provider companies, and these mid market entrants were hard-pressed in adopting EDI due to the sunken costs of software and training. Service Providers made EDI accessible to the SME via the web - a model now well known as SAAS or Cloud Computing. Electronic Commerce Service Providers had no desire to re-create EDI communications facilities from whole cloth, and were forced to selected among the extant VANs for communications. The VANs relationship to the Service Providers is problematic however, as VANs duplicate the offerings of these fast moving Commerce Ventures. The resultant unease between VANs and ECSPs, each selling into the others channels4, registers as a hostile detente threatening to erupt at the slightest provocation.

1Software 2The 3

as a service, (via the web browser)

VAN market may be decaying amidst buyouts and wrongheaded initiatives, but EDI provided by alternative providers is growing We might add that the general exodus from VANs, to self-managed hubs (the no-VAN alternatives), is symptomatic of the poor state of VAN services in the eyes of end-users. This is a strong, negative statement backed by actions - the taking on of complex in-house infrastructure to simply liberate an organization from a captive services arrangement. This is why the B2B service providers and Enterprise 2.0 vendors are thriving, and poised to take remaining market from the legacy VANs..
4

with one wholly dependent on the other for communications

Starting in the 1990s, after much development, several leading service providers selected Loren Data Corp as their preferred communications provider, one targetign and enhan to their business model. ECGrid came to the market, offering unbundled, enhanced5, stand alone communications. Loren Data Corps executive leadership made the difficult decision to not pursue end-user accounts. ECGrid therefore became the ECSPs haven against diversionary back door sales tactics of VANs selling connectivity, followed by a phalanx into a Service Providers client book6. A long, tortured legacy of the GXS relationship to Loren Data One might think that even a ten year dispute might have been salved by cool-headed professionals, but an enigmatic question is yet to be answered to the satisfaction of any observer: why would GXS, company 450+ times the size of Loren Data Corp waste time and money defending a lawsuit, when they could just as easily grant the interconnection, crushing such an insignificant competitor in due course, via hostile pricing and saturation marketing? Reading through the correspondences of Messrs. Gould and Scala does not clarify the issues at all, as GXS chest beating over branding, topology, and business models is a turgid amalgam of self-serving, contrived terms of art. GXS position, as stated in the infamous letter, leaves otherwise well-informed readers with the impression of a document penned by committee, one sequestered behind the confines of a GXS parapet removed from the concerns of EDI end users, and disconnected from the issues challenging the B2B industry. As the simplest explanation is often the most accurate, the reasons for GXS denying Loren Data ECGrid interconnection as a settlement-free peer, must be fear in its most basic manifestation. GXS fears the innovations of Todd Gould, a technical founder of a company with insight and skill (Gould is the engineer, architect, and programmer of ECGrid), able to deliver solutions into the dynamic and growing end of the B2B market, and accomplishing these technical feats with a speed GXS could never hope match. To bring advancements into a settled interconnected market assumes that the truly important fulcrum issues are fully understood in all their details; not being cognizant of these make / break issues relegates a technical market participant from making any substantive contribution, regardless of the number of outsourced engineers deployed. An impartial harvesting of sentiment sourced from various on-line discussion venues leaves the impression of a GXS that could not compete with Loren Data Corp on a level playing field, in any time frame, at any cost. The public perception is of a company with a damaged brand, its technical architecture flawed, and its ability to act as industry steward of innovations and standards, in question . Merely operating its current systems competently seems to evade the grasp of GXS. Rationale

5Ther

had not been forward movement in the EDI communications repertoire for decades, until Todd Goulds ECGrid offered enhanced control of the message stream, detailed controls designed for service providers, and a programmable interface for custom EDI systems of the new order..
6The

client bookings of service providers or any trading relationships are transparent to any EDI Network shameless enough to harvest and exploit EDI message data.

If the core issue truly concerns interconnection, then a simple explanations may be best, as follows: GXS has begun the process of herding its largest clients onto the TGMS VAN, exploiting the TGMS gateway, or routing border, and subsequently arbitraging access to some of the largest supply chain operations that are resident clients on the GXS networks, mainly TGMS. These actions were accomplished with Private Equity funding, by acquiring the three largest EDI networks7 that were host to numerous prestigious retailers and manufacturers. Interconnection arbitrage is the act of blackmailing other network providers, testing who will acquiesce to the threat of pay to play, regardless of a trading partners right to choose a preferred network. It would not be arbitrage if GXS uniformly settled data transiting accounts with all networks bidirectionally, but this has not been the case in the EDI VAN market - GXS is connected to dozens of collegial operators in non-settlement agreements where neither party pays the other. In the case of Loren Data Corp, GXS has decided to not only demand settlement, but to intentionally under-provision the ECGrid-TGMS interconnection via a mailbox arrangement. With such a large population of subscribers gained by rolling up the IBM, Inovis, and GEIS VANs, other network operators are at the mercy of GXS in its campaign to overthrow decades of VAN peering policy - existing VANs remaining with legacy non-settlement interconnects to TGMS are tolerated due to their ability to effect a retaliation in a routing war, or are tolerated as non-threatening entities that will be maintained until such a time as GXS deems that specific interconnect superfluous. As this is an examination of policy, and not a technical treatise, GXS may be compared to the pre divestiture AT&T. And, just as the first mega monopolies, (telcos, railroads, and petro-pipeline monopolies) exploited access to infrastructure via interconnection abuses, these tactics became identified as detrimental to connected marketplaces, and later, became rich fodder for DOJ antitrust actions. Therefore, the established systems of collegial (non-settlement) interconnections, primarily conceived to establish and enhance the markets they serve by offering the trading partners global connectivity, is simply under siege. We have, as a society, come to expect such wide area connectivity from modern, networked services. We should not tolerate incumbent networks who hammer competitors with interconnection arbitrage; to allow such policies to reemerge in the EDI market, after being rendered obsolete in many other sectors, is a symptom of malaise within the regulatory agencies Notes on Justifications: This author is unable to reconcile the fact that GXS has, during a period of industry upheaval, retained a clientele so worthy of transformation into objects of leverage, into business relations to conduct the strategies executed by the arbitrageurs employed by GXS Inc. Other interconnection dependent markets remarkably similar to the EDI Communications market, have also struggled with interconnection arbitrage. The Incumbents arbitrageurs who conducted such campaigns were found to have either skirted the law or have found themselves fouled in the net of U.S. Antitrust Statutes.
7GEIS,

Inovis, and IBM IE

And now, quite nearby to GXS HQ, a Federal Judge in Greenbelt, MD, is considering the pending motions that will decide that fate of Loren Data Corp v. GXS Inc., defining the future conduct of the business of interconnections between Value Added Networks and Independent, Specialized EDI Network Providers. To be determined: 1) Are interconnections nothing more that items of leverage, to be exploited in order to cement an incumbents market position, as a substitute for fresh ideas and innovative solutions? 2) Is interconnection a practice conducted for the markets long term viability, implemented solely on behalf of trading partners who will determine, by exercising their discernment of the market based merits, select a network that will best serve their needs? GXS finds itself in the enviable position of AT&T before Kingsburys Commitment to the ICC8 , of Standard Oil before the Trust-Busting era, and of numerous wire-line operators9 given Carte Blanche by legislators and Regulators. Any of the aforementioned stakeholders still adhering to an antiquated notion of beneficial monopoly are artifacts of a bygone era hanging on by their fingernails for dear life. Will GXS, potentially prevailing against Loren Data Corp, a company 1/450th of its size, convert the essential practice of cooperative interconnection between collegial competitors, into nothing more than an instrument of competitive leverage. to be turned upon every Service Provider, VAN, and selfadministered corporate supply chain hub? Loren Data Corp, founded by Todd Gould in 1987, if it prevails, could potentially set the Industrys table for Renaissance where interconnects are a proper lubricant of growth, and a platform for advanced network services. Judge ever so astutely, Magistrate. Confounding GXS Justifications In a seminal letter by GXS Executive VP Steve Scala (GXS) says, (paraphrased here) that, we cannot be assured of quality, latency, etc., when allowing Loren Data to hand off traffic to other systems, or to otherwise become an arbiter of who shall transit traffic over TGMS (the trading parties existing a priori of interconnections are not mentioned, {author}), in essence stating, we do not want GXS interconnections democratized, and do not want service provider traffic crossing TGMS via interconnects brokered by a specialist EDI network whomsoever. GXS confuses the nature of EDI trading relationships! GXS is unashamed of logical inconsistencies: GXS routinely takes data transit business from the service providers, and they do so regularly. In addition to GXS misunderstanding (deliberately exploiting) the nature and needs of its clients, hiding them behind the TGMS routing border, antitrust
8http://www.cato.org/pubs/journal/cjv14n2-6.html 9VANs

as originally constituted were firmly in the wire-line camp before the Internet revolution.ripe for regulation as carriers of the same critical supply chain and order data that previously regulated telegraph and TLX provided.

defense council, Chadbourne and Parke, deliberately portrays GXS trading partners as proprietary assets of the GXS VAN. Scala, GXS et al, ignore the fact that, 1) valid messages between mutual, commercial trading parties transit ECGrid , 2) they are conveyed via service providers on behalf of the trading partners, 3) who initiate transactions. These trading relationships exist a priori of a GXS connection to GXS clients (mutually participating in beneficial, contractual trading relationships with the aforementioned parties (conveying their data via ECGrid and the Service Providers), therefore, is GXS deliberately, and with forethought, interfering in the trade of the parties? To the point, the messages carried over a reciprocal routing path is as important to a GXS trading partner as they are to the trading partners on ECGrid and the Service Providers. To say that the GXS clients are privileged, or proprietary, is a complete mischaracterization of trading relationships enabled by EDI systems - a fact Chadbourne and Parke ignore or misconstrue in their motion10. What this suit is really about is that Loren Data wants free access, and GXS has suggested that Loren Data should pay for it. The antitrust laws do not require GXS to deal with Loren Data at all. They certainly do not require that GXS give away the fruit of its labor for free. Rather than compete for those customers on the merits, Loren Data asks this court to bestow on it the customers and terms of business that Loren Data has been unable to secure through its own acumen in the market. Loren Data's suit is not about restoring competition, it's about protecting Loren Data. Ad nauseum... Particular attention must be paid to the terms, those customers, at the crux of Chadbournes subject matter, apart from the legal, antitrust technicalities. Who are those customers? Are they Trading Partners, located on TGMS? If so, an interconnection between ECGrid and TGMS will not usurp GXS relationship with those clients, but will permit electronic message routing, i.e., trading, between those Clients, and the trading parties that have selected ECGrid, via their service providers, according to their free market will, perceived value, and Lorens acumen in capturing the business of these counter-parties to an EDI transaction. Not parenthetically, the Chadbourne motion again goes on to misstate, Loren Data asks this court to bestow on it the customers and terms of business that Loren Data has been unable to secure through its own acumen in the market. The terms, the customers, terms of business, and own acumen, highlighted, are again, a complete dissembling of the facts; Loren Data Corp does not need GXS Customers bestowed upon it, Loren Data Corp merely seeks the same peering and parity of interconnection enjoyed by the entire VAN industry to GXS-TGMS, so that Loren Data Corp ECGrid customers, which Loren Data certainly has secured via its own acumen, may lawfully transact using EDI documents. GXS grants these standard interconnections to its chief rival, Sterling commerce and dozens of other VANs as nonsettlement agreements. A proper examination of GXS VAN interconnections would show, in Chadbournes parlance, that the fruit of GXS labor is exposed via its routing reach via its interconnections. Therefore, the points of the
10Chadbourne

studiously avoids the why of interconnection denial or grant.

motion that must be refuted on subject matter, should proceed on the confusion as to who those customers are, and what role they occupy in an EDI enabled relationship. It is patently absurd that Chadbourne or GXS expects a court or any sentient party to concede that the parties joined via an EDI trading partnership be resident on one, and only one, network. In that context, the construct of those customers, makes perfect sense. Alas, GXS grants interconnections without settlement, to the vast majority of at-scale EDI network operators, including IBM-Sterling, their most dangerous adversary. Why? All other GXS interconnects GXS does not consider any of its VAN interconnects, even the IBM-Sterling interconnect, a taking of GXS Fruitful Labors; terminating the Sterling Interconnect would end GXS tenure as a viable VAN, as the value of any VAN is equal to its global reach to trading partners on other networks, hubs, VANs, or X.400 systems in the EU. The retaliation of IBM-Sterling in the midst of a VAN Routing War would lead to an absurd, futile, and industry damaging event that would further erode an already tarnished GXS reputation. Extorting Loren Data Corp via Interconnection arbitrage (how much can we charge for this interconnection?), only works while Loren Data accedes to the blackmail; if it becomes necessary for Loren Data to break this tenuous detente11, a massive, industry-wide routing default will occur. GXS will be solely responsible for this breakage, and be publicly exposed for all to see. The entire transcript of negotiations between Loren Data and GXS will be aired, exemplifying the patience, goodwill, and forbearance of Todd Gould in the midst of crisis, counterpoised against a numb, unimaginative, and greedy GXS. The peculiar hallmark of GXS conduct underlying this interconnection debacle is one of callousness and disregard for the trading partners. So, how did we come to such a frightful conclusion? Clients on the GXS networks are not owned by GXS; their transformation into assets secreted behind the GXS routing border provides GXS with interconnection bargaining chips against other networks, but does not serve GXS clients one iota. To serve their clients would mean acting as a neutral communications broker among the trading partners residing on any network. And GXS, with a comprehensive list of VAN interconnects (as stated plainly on their website), certainly states as much to its prospects and clients - GXS provides cooperative interconnections to the world of VANs, as a stated practice. The established practice of VANs since the inception of the first interconnects is to interconnect liberally with other networks without settlement. Loren Data Corps liberal interconnection policy speaks volumes about its character as an organization. If GXS trading partners were aware of GXS using their cachet as bargaining chips, there would be hell to pay. It is beyond conjecture that any GXS customer would would advocate for their trading partners having the widest possible array of EDI communications options possible.

11

If Loren Data Corp cannot or will not pay for the peer routes that GXS provides gratis to the entire corpus of collegial competitors

The proof of this assertion is that the numerous retailers at the top of the supply chain, many who are GXS clients, refer their suppliers to Service Providers who also furnish connectivity services. If it is taken at face value that the controversy stems from GXS distaste for the Service Provider, and hence by association we have the GXS campaign of interfering with ECGrid interconnections to GXS TGMS. GXSs clients silently stand at the sidelines, not entirely happy with GXS hostilities carried on to the detriment of smaller suppliers, and not entirely aware of GXS using the weight of its Fortune 1000 retailers and manufacturers to cast a giant shadow in the industry. Several well known service providers are marquee clients of Loren Data Corp ECGrid, as there are manifold advantages inherent in the ECGrid technology, business and support models that Loren Data Corp has tailored specifically for the service provider market. GXS rise to power: How did they become the worlds largest EDI VAN? Did GXS attain its stature via competitive aplomb, acumen, or technological innovation? Or, did Private Equity drive key acquisitions that allowed the company to scale, despite a willful lack of thought leadership? Regardless of the metrics applied in measuring each company, Loren Data operates at 1/450 the revenues of GXS, its five employees stand against the 1,800 employed by GXS. Contriving to create a dispute over a trivial interconnect, resulting in an antitrust lawsuit, GXS has unwittingly drawn the industrys focus to the accomplishments of Loren Data Corp, whose technical innovations need not be recounted in line with this paragraph. During ten years of fruitless correspondence, Loren Data Corps President Todd Gould proposed numerous measures to demonstrate what the EDI industry already knows - Loren Data Corp ECGrid is one of the most reliable EDI networks in the industry, with a reputation and brand equity exceeding that of GXS. The incremental enhancement gained by interconnecting ECGrid to GXS TGMS removes a few important impediments from Loren Datas full and unfettered participation in the VAN market. ECGrid clients will gain the native ability to communicate with trading partners on GXS, just as the entire cohort of other VANs do at present, only without the settlement of accounts. What Loren Data Corp currently pays for, GXSs arch competitor, IBM Sterling, receives gratis as a fundamental and standard courtesy to the trading parties resident on the two competing networks. Network client migrations are more direct, and less complicated when connected via a standard interconnect, as opposed to a paid mailbox service. With all other GXS attributes unchanged, Loren Data remains dwarfed by GXS in size and capital; Loren Data Corps lack of capital is richly offset by its culture of innovation, and its penchant for attracting partners of excellence, as well as a prescience for navigating the industrys evolution. Loren Data Corp will not soon be making any multimillion dollar acquisitions, but its intellectual advantages are far beyond the grasp of GXS. This unattainable culture of technical aplomb vexes the GXS executives, and may have been the precursor to GXS campaign of interconnection arbitrage.

Rationalizing non-settlement agreements for VAN Interconnects The benefits of non-settlement interconnections have been studied in the telecommunications and inter-carrier IP services market. Most studies have shown that connected markets are aided by removing settlement from the equation. Shepherding the core network providers past their inbred need to profiteer by eliminating the billing hijinx between communications providers allows for the formation of creative partnerships and diverse services. Sender-based and bilateral settlements have a place in carrier network services, such as cellular backhaul, local exchange termination, pure IP transit services, and so on. These types of services are aimed exclusively at other networks. When not regulated via tariffs, modern networks, ISPs in one instance, owe their grown in part to nonsettlement peering agreements. The keystones of modern networks are technical standards and permissive attachment policies that foster a market driven climate user choice and constant innovation. Standards and permissive entry policies created an entire ecosystem, where the networks, servers, APIs, and infrastructure form a self perpetuating economic engine. You cant stop the Internet. The EDI Communications marketplace as exemplified by VANs, however, took the exact opposite approach, where technology took a back seat to small-minded, scarcity-based thinking - if we let you in, we lose, if we create directories and ID portability, then our customers will find it easier to leave us. If we allow the fast moving innovator to interconnect with our large, low-tech VAN, they will then democratize access, and we will lose our hegemony over the EDI market. How long can such attitudes endure? Two years? Five? The VAN market, exemplified by GXS, has taken a small-minded, no-innovation approach where the trading partners rights are trampled; the most fundamental right of any trading partner is the ability to select or move to any network so chosen. A stronger statement might be, Trading Partners have no standing or representation in the law or by advocates within the EDI industry, The VAN markets lack of leadership, stewardship, and vision regarding Interconnections The early VAN market stood at a crossroad in its formative years. The larger manufacturers had organized their many suppliers to reside on one selected VAN or another - therefore it seemed (to the myopic VANs) that a closed network model might work- ignoring the advantages that interconnection brings to the end-users. Why connect to ones competition when enforcing a closed system, or severely limit the pool of selected interconnects could keep clients captive? The companies that formed todays GXS (GEIS, Inovis, IBM) built their businesses based on the EDI industrys traditional (non-settlement) interconnection methods of connecting to other VANs. At the time of EDIs initial adoption, fostering the growth and viability of the EDI market devolved upon all of the companies participating in the sector. The founding VANs, and those that came shortly after them, understood that interconnection was not just a necessary evil, but was the intrinsic act of creating the market, the essential core service conveyed to trading partners. Virtually all networked markets share in this realization: the benefits of network effects accrue to the consumers alone, enhancing their reach,

making services ubiquitous, lowering costs, and fertilizing the innovations and enhancements built on top of these basic network services. Being hostile to the adoption of ubiquitous interconnections (and peering methodologies that enable them), destroys markets. Put another way, why would anyone want to use services that did not reach all, or practically speaking, as many network subscribers as possible? We have come to expect such default access from any phone company that friends, business partners, and family members use? But in the dark ages of telephone, telegraph, early data networks, and even pipelines and railroads, such interconnection strong arming was a routine practice used to disadvantage or destroy competitors. A reading of the history of AT&T before its divestiture is a lesson in how to conduct hostile interconnection arbitraging. As EDI became attractive and often compulsory to the increasingly diverse supply chain industry, (most notably, retail), the numbers of trading partners exploded - new VANs and alternative service providers sprang up at a furious pace. While many key players did realize (some too late) that such large pools of subscribers could never be corralled onto a few selected, privileged networks; others stood their ground and resisted any new market entry via non-settlement interconnections, electing instead to charge these providers, manipulate (i.e. degrade) their data transit service levels, and otherwise delay the entry of fresh and innovative EDI Network operators. It was not beyond the moral conscience or control of the founding VANs to stall interconnection standards. Once they had agreed to interconnect with a selected seed cohort, and variously allowed the pool to grow gingerly, painfully, reluctantly, or not at all . The VANs resisted technological network enhancements, such as directory services and programmable interfaces, forestalling any dynamic whatsoever that would transform EDI Communications from an arcane, vexing, and fussy service, to one that could be as robust as sending email or dialing a phone. The Dispute of Oddly Mismatched Adversaries The act of limiting the industrys growth was ceded to GXS by the entire VAN sector silently allowing GXS to act as interconnection arbiter, a role gained by becoming the must have EDI routing terminus. This was accomplished via a PE funded initiative to acquire three anchor VANs, i.e., GEIS, IBM-IE, and Inovis. Although the VANs have been more liberal than GXS in regards to interconnection12, the collective actions of the industry has been to limit entry of new competitors, and to keep innovation stagnant. GXS therefore maintains dozens of interconnections as non-settlement agreements with other VANs. Very few new interconnect agreements have been created to enable traffic routing to the GXS TGMS system, since the early 2000s.13

12Interconnections

to other VANs does not alleviate the problem of routing traffic to GXS-TGMS, as the primitive EDI routing system does not allow replicable or permissive routing (where any alternate point of access assures that a message will be delivered to its proper destination).
13The

choking off started with a well-known historical event concerning Internet Commerce Corp, see appendix for further.

Todd Gould, as the sole engineer of his systems and the quarterback of a crack team, deploys new services, leads the EDI communications market, insofar as innovative network services are concerned. GXS might be fearful of Loren Data Corp being interconnected to the tarnished TGMS system, thereby democratizing access for ever more innovative EDI start-ups. Would this one interconnection affect GXS? GXS would remain 450x the size and revenue of Loren Data Corp. In time, if an interconnect was established, a level playing field would prevail and the two companies would retain their value propositions as determining factors of success. GXS could simply choose to compete, acting as other large companies, resorting to mere ruthlessness in pricing and marketing, conducting its campaigns at a scale Loren Data Corp could never hope to achieve, regardless of technological prowess or the existence of a GXS interconnect to TGMS, scaling to the size of the behemoth would be a great feat. If any remaining issues are14, in truth, connected to the burden of maintaining or supporting interconnections15, let the court appoint an impartial emeritus of the EDI industry, to reconcile the interconnection between the litigants; Loren Data Corp maintains immaculate relations with other. We shall end with a question, rather than a conclusion: Will the entire domestic supply chain communications business, controlling the data representing trillions of dollars in trade, become subject to the absolute monopoly of GXS, with GXS picking winners and losers through its manipulation of interconnections? The exact scenario was accomplished by AT&T, who, by acquiring competitors and controlling interconnections, eventually controlled every aspect of the nations telecommunications infrastructure. The AT&T era was a time rife with frustration for entrepreneurs desiring entry into the telecoms business16; barred at every turn by the AT&T megalith, they could only rely on the protracted efforts of the Federal Government to prize away the conglomerates power via forced divestiture. In a very similar fashion, we see EDI Communications as a sector that should have flourished, yet struggling on in spite of the deficiencies caused by the chill climate caused by GXS holding the industrys interconnection choke point. Unbound from the monopolistic actor, the EDI market would become a place where innovative solutions would become increasingly available at lower costs, to ever more diverse users.

14A

specious position, stated by GXS Counsel

15That

GXS claims VAN interconnections are high water mark facilities is absurd and flies in the face of all common knowledge of EDI expertise. Interconnections supporting X12.56 are the least labor and resource intensive facilities, compared to mailboxes.
16The

Landmark desision of Carterphone v. AT&T