UNITED STATES OF AMERICA

Before The

POSTAL RATE COMMISSION

WASHINGTON, D.C. 20268-0001

Complaint on Post E.C.S. ) Docket No. C99-1

> OFFICE OF THE CONSUMER ADVOCATE
>
> INTERROGATORIES TO UNITED STATES POSTAL SERVICE
>
> (OCA/USPS-19-34)
>
> August 25, 1999

Pursuant to sections 25 and 26 of the Rules of Practice of the Postal
Rate Commission, the Office of the Consumer Advocate hereby submits
interrogatories and requests for production of documents. Instructions
included with OCA interrogatories OCA/USPS-1-7 to the United States
Postal Service, dated June 28, 1999, are hereby incorporated by
reference.

> Respectfully submitted,

OFFICE OF THE CONSUMER ADVOCATE

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Ted P. Gerarden

Director

Shelley S. Dreifuss

Attorney

OCA/USPS-19. Please refer to the Attachment to this interrogatory. The
Attachment is a printout of information reported by Network Solutions at
its "Whois" site. \[Note: Network Solutions is "the world\'s leading
provider of Web address registration services . . . . Network Solutions
is responsible for maintaining the stability and security of the master
file of Internet Web addresses." <http://www.netsol.com/nsi/>\]

a.  Please confirm that the servers that may be used to provide Post ECS
    services are "GK-EAST.USPS.GOV" and "GK-WEST.USPS.GOV." If the
    Postal Service is unable to confirm, explain why not.

b.  In response to interrogatory OCA/USPS-12, the Postal Service stated
    that: "The Postal Service's server for Post ECS is physically
    located in the United States, in the State of California." Is the
    server located in California the same "GK-WEST.USPS.GOV" server
    listed in the Post ECS domain registration? If not, please explain.

c.  Please confirm that the server "GK-EAST.USPS.GOV" is located in the
    eastern part of the United States. If the Postal Service is unable
    to confirm, explain why not.

d.  At the present time, is the "GK-EAST.USPS.GOV" server listed in the
    Post ECS domain registration involved in the provision of Post ECS?
    If so, how? If not, why not?

e.  Please confirm that the I.P. addresses for the "GK-EAST.USPS.GOV"
    and "GK-WEST.USPS.GOV" servers are "56.0.96.11" and "56.0.72.11,"
    respectively. If the Postal Service is unable to confirm, explain
    why not.

f.  Please confirm that Martineau & Associates is the registrant for the
    POSTECS domain. If the Postal Service is unable to confirm, explain
    why not.

g.  Please confirm that Pierre Martineau is the Administrative and
    Billing contact for the POSTECS domain. If the Postal Service is
    unable to confirm, explain why not.

h.  What is the relationship between Martineau & Associates and the
    Postal Service with respect to Post ECS? Please explain in detail.

> (i). Include in the explanation a description of the duties and
> services performed by Martineau & Associates in connection with Post
> ECS.
>
> (ii). On what date did Martineau & Associates begin to perform
> services in connection with Post ECS?

i.  What is the relationship between Pierre Martineau and the Postal
    Service with respect to Post ECS? Please explain in detail.

> (i). Include in the explanation a description of the duties and
> services performed by Pierre Martineau in connection with Post ECS.
>
> (ii). On what date did Pierre Martineau begin to perform services in
> connection with Post ECS.

OCA/USPS-20. In response to question 2, posed by the Commission in Order
No. 1229, the Postal Service stated: "Based on customer feedback and
informal interviews with end users, it is known that transactions are
originated and directed to recipients within the U.S."

a.  Please break down the information cited above, i.e., customer
    feedback and informal interviews, into (1) domestic transactions,
    i.e., those originated in the U.S. and directed to recipients within
    the U.S,. and (2) those which are non-domestic, i.e., either
    initiation of the communication or receipt of the communication (or
    both) take place outside the U.S. Express the breakdown as
    percentages of total Post ECS transactions. The percentages for (1)
    and (2) should sum to 100 percent. Ballpark percentage estimates are
    acceptable if more precise information is unavailable.

b.  Has the Postal Service had additional customer feedback and/or
    informal interviews since the time that the answer to question 2 was
    filed on March 3, 1999? If so, please answer part a. of this
    interrogatory based on all feedback and informal interview
    information, including the most recent feedback and interview
    information.

c.  Does the Postal Service know "that transactions are originated
    \[or\] directed to recipients \[outside\] the U.S.?" If yes, how did
    the Postal Service obtain this knowledge?

OCA/USPS-21. Please confirm that Post ECS's Adobe Acrobat portable
document format technology "enables recipients to read any document
regardless of the software applications used to create them." (Refer to
p. 4 of Attachments to the Postal Service's response to interrogatory
UPS/USPS-5A). If the Postal Service is unable to confirm, explain why
not.

OCA/USPS-22. In response to interrogatory UPS/USPS-46B-C, the Postal
Service states that: "The sender and recipient \[of Post ECS\] can . . .
be located in any combination of locations." Please confirm that one
subset of the possible sender/recipient combinations consists of senders
and recipients located in the U.S. If the Postal Service is unable to
confirm, explain why not.

OCA/USPS-23. Would it be theoretically possible for the Postal Service
to add the following (or a similar) question to the screen filled in by
a Post ECS registrant at the time that a Post ECS service is purchased?

> "*Please darken one of the following boxes by clicking your computer
> mouse.*
>
> *Is this Post ECS communication being generated by a computer located*

-   ***in** the U.S.? or*

-   ***outside** the U.S.?*

> *(Please call 1-800-xxx-xxxx if you are uncertain about whether your
> location is 'in the U.S.' or 'outside the U.S.' for the purpose of
> answering this question.)"*

a.  Please give a "yes" or "no" answer to the question posed above,
    i.e., whether it would be theoretically possible to add such a
    question (or a similar question) at the time a Post ECS transaction
    is made. If the answer is "no," explain in full why it would not be
    possible for the Postal Service to ask such questions of
    registrants.

b.  If the answer is "yes," then give a ballpark estimate of the time
    that would be required to reprogram the Post ECS software to add
    such a question. State the assumptions made to generate the ballpark
    estimate.

c.  Please confirm that Post ECS test participants "agree to participate
    in market research conducted by the USPS during the course of the
    test." Attachment to Postal Service's response to interrogatory
    UPS/USPS-11, "*Post E.C.S.* Service Test Participant Application."

d.  Does the Postal Service agree that having information such as this
    for each Post ECS transaction could be used to separate domestic
    transactions from non-domestic transactions? If the answer is
    negative, please explain in full the basis for disagreement.

OCA/USPS-24. Would it be theoretically possible for the Postal Service
to add the following (or similar) questions to the screen filled in by a
Post ECS registrant at the time that a Post ECS service is purchased?

-   *"Is this Post ECS communication directed to a single recipient? (If
    not, then skip to the next set of questions).*

> *If so, then choose one of the following (click computer mouse to
> darken **one** of the 3 boxes below)---*
>
> *The location where the recipient will receive e-mail notification is
> located **in** the U.S.* , or
>
> *The location where the recipient will receive e-mail notification is
> located **outside** the U.S.,* or
>
> *Recipient's location is not known.*
>
> *(Please call 1-800-xxx-xxxx if you are uncertain about whether the
> recipient's location is 'in the U.S.' or 'outside the U.S.' for the
> purpose of answering this question.)*

-   *Is this communication directed to multiple recipients? (If not,
    then answer the set of questions immediately preceding this set).*

> *If so, then please fill in both of the boxes below (use "0" if
> appropriate)---*
>
> *Number of recipients located **in** the U.S.*
>
> *Number of recipients located **outside** the U.S.*
>
> *Number of recipients whose location is unknown.*

a.  Please give a "yes" or "no" answer to the question posed above,
    i.e., whether it would be theoretically possible for the Postal
    Service to add such questions (or similar questions) at the time a
    Post ECS transaction is made. If the answer is "no," explain in full
    why it would not be possible for the Postal Service to ask such
    questions of registrants.

b.  If the answer is "yes," then give a ballpark estimate of the time
    that would be required to reprogram the Post ECS software to add
    such questions. State the assumptions made to generate the ballpark
    estimate.

c.  Does the Postal Service agree that having information such as this
    for each Post ECS transaction could be used to separate domestic
    transactions from non-domestic transactions? If the answer is
    negative, please explain in full the basis for disagreement.

OCA/USPS-25. In response to interrogatory OCA/USPS-12, the Postal
Service states that "the 's' appended to the https:// denotes the secure
portion of a server." Please explain generally how the secure portion of
a server and the non-secure portion of a server differ physically.
Please describe generally any other differences between the secure and
non-secure portions of a server. Also, describe generally any measures
taken to ensure security in only a portion of a server.

OCA/USPS-26. Please refer to the "*Post E.C.S.* Test Pricing Guide"
attached to the Postal Service's response to interrogatory UPS/USPS-11.
In that Pricing Guide, the Postal Service represents that:

a.  The Electronic Postmark ™ serves as a "Third-party, trusted time and
    date stamp that can stand as legal evidence." Please provide all
    Postal Service notes, files, reports, memoranda, documentation,
    legal research, and all other written materials that support or
    address this claim. Also, furnish detailed summaries of any oral
    statements that underlie this claim, and identify the person(s)
    making such statements. Give specific citations to any federal or
    state laws supporting the Pricing Guide claim.

b.  The Postal Service also represents that the Electronic Postmark ™
    provides "Legal protections against tampering and misrepresentations
    of fact or identity." Please provide all Postal Service notes,
    files, reports, memoranda, documentation, legal research, and all
    other written materials that support or address this claim. Also,
    furnish detailed summaries of any oral statements that underlie this
    claim, and identify the person(s) making such statements. Give
    specific citations to any federal or state laws supporting the
    Pricing Guide claim.

OCA/USPS-27. Please refer to the "*Post E.C.S.* Account Request
Information" attached to the Postal Service's response to interrogatory
UPS/USPS-11.

a.  Please confirm that the Postal Service asks for the "Physical
    Address" of every account member.

b.  Does the Postal Service agree that it is reasonable to assume that
    *almost all* Post ECS account members whose physical address is in
    the U.S. will initiate their Post ECS communications in the U.S.? If
    the answer is negative, please explain in full the basis for the
    answer.

c.  Does the Postal Service agree that it is reasonable to assume that
    the *majority* of all Post ECS account members whose physical
    address is in the U.S. will initiate their Post ECS communications
    in the U.S.? If the answer is negative, please explain in full the
    basis for the answer.

d.  Does the Postal Service currently have any registrations on file for
    Post ECS account holders or account members whose physical address
    is located outside the U.S.? If so, please state the percentage of
    total account member registrations involving physical addresses
    located outside the U.S. (Or, conversely, state the percentage of
    total account member registrations involving physical addresses
    located within the U.S.) These two percentage figures should sum to
    100 percent.

OCA/USPS-28. Please state the probability that the proportion of
domestic Post ECS transactions has been less than the following
fractions.

a\. 0.0001

b\. 0.001

c\. 0.01

d\. 0.1

e\. 0.2

f\. 0.3

g\. 0.4

h\. 0.5

i\. 0.9

j\. 0.99

k\. 0.999

l\. 0.9999

OCA/USPS-29. For the fractions listed in OCA/USPS-28, please state the
probability that the proportion of domestic Post ECS transactions will
be less than the listed fractions in FY 2000.

OCA/USPS-30. If the probabilities requested in the two previous
interrogatories (OCA/USPS-28 and OCA/USPS-29) cannot be provided, please
state the basis for any belief of the Postal Service that some Post ECS
transactions will certainly be international in character. Please
distinguish the basis of the Postal Service\'s belief from the
statement, \"If an event \*might\* happen, then it \*will\* happen.\"

OCA/USPS-31. Does the Postal Service allow registration for Post ECS by
individuals or businesses located in Canada? Please explain in full.

OCA/USPS-32. Does the Postal Service allow registration for Post ECS by
individuals or businesses located in France? Please explain in full.

OCA/USPS-33. Canada Post imposes the following limitation on
registration: "Any business *within Canada* is eligible for Canada
Post\'s Post*e*CS™ 30 day free trial offer."

(http://www.canadapost.ca/CPC2/eps/postecs/registry.html; emphasis
added). Does the Postal Service impose a comparable restriction on
registration, i.e., that a registrant be located within the U.S.? Please
explain in full.

OCA/USPS-34. Please refer to the Postal Service\'s Attachment in
response to UPS/USPS-11, Post E.C.S. Test Pricing Guide. There it states
that \"Basic Transaction\" includes \"tracking.\" Please explain in
detail exactly what occurs when USPS \"tracks\" a transaction. Also,
please give a step-by-step narrative of this process.

CERTIFICATE OF SERVICE

I hereby certify that, on behalf of the Office of the Consumer Advocate,
I have this date served the foregoing document upon all participants of
record in this proceeding in accordance with section 12 of the rules of
practice.

Stephanie Wallace

Washington, D.C. 20268-0001

August 25, 1999