On behalf of Net2Phone Global Services, LLC., and Net2Phone Cable Telephony, LLC.

1
December 15, 2003

• On behalf of Net2Phone Global Services, LLC., and
  Net2Phone Cable Telephony, LLC.
• for the
• Federal Communications Commission
• Cherie R. Kiser Elana Shapochnikov
• Mintz, Levin, Cohn, Ferris, Associate General
  Counsel
• Glovsky and Popeo, P.C. Net2Phone
• 701 Pennsylvania Avenue, NW 520 Broad Street
• Washington, DC 20004 Newark, NJ 07102
• crkiser_at_mintz.com eshapo_at_net2phone.com

2
Consumers Have Benefited from the FCCs
Hands-off Approach

• Since its inception, Net2Phone has provided
  consumers with a competitive alternative for
  voice services.
• Net2Phone has been recognized as the first
  company to bridge the Internet with the public
  switched telephone network.
• Net2Phone has invested in communications
  infrastructure by building its own proprietary
  network and gateways.
• Net2Phone has routed billions of minutes of
  traffic over its network.

3
Overview of Net2Phone

• Net2Phone has established itself as a world
  leader in delivering voice services over data
  networks.
• Net2Phone delivers new and innovative
  communication solutions to retail customers and
  cable operators worldwide.
• Net2Phone offers services through two
  subsidiaries
• Net2Phone Global Services (NGS) offers VoIP
  services to retail consumers and small- to
  medium-sized businesses around the world.
• Net2Phone Cable Telephony (NCT) provides cable
  operators in North America and Western Europe
  with the toolset to offer residential voice
  services to their subscribers utilizing their
  existing cable networks.

4
Key Milestones
5
Overview of NGS

• NGS offers a variety of VoIP-based products and
  services. Our centrally managed platform
  supports a full range of consumer and corporate
  hardware products and services that enhance
  quality, lower costs and improve ease of use and
  management.
• NGS is always evaluating and developing new
  products and service offerings including
• VoIP over wireless fidelity (WiFi)
• Integration and interoperability between our VoIP
  services and mobile devices
• Consumer broadband voice services and devices
• NGS is committed to bringing greater choice in
  high quality VoIP services to consumers.

6
Overview of NGS (contd)

• Enterprise Solutions. This suite of services
  permits small and medium-sized businesses to use
  their existing broadband connections to place
  calls among their corporate offices and primary
  business contacts. Several other services permit
  businesses to make low cost, high quality VoIP
  calls to anywhere in the world.
• Calling Cards and Prefix Dialing. Customers buy
  disposable or rechargeable calling cards that can
  be used to make low cost calls through
  Net2Phones VoIP platform.
• Broadband Voice. NGS sells devices that can be
  plugged into a high speed connection anywhere in
  the world to allow users to be reached at the
  telephone number assigned to their specific
  device. These devices also allow users to access
  Net2Phones VoIP platform to make high speed
  connections to anywhere in the world.
• Satellite VoIP. NGS offers VoIP products and
  services to satellite broadband providers that
  allow them to offer voice service in conjunction
  with their high speed data offerings. NGS has
  improved voice quality over satellite by
  implementing voice packet prioritization and
  working with third party device manufacturers
  such as LG Electronics and Hughes Network Systems
  to create devices that can be easily installed on
  existing equipment.
• Carrier Services. NGS sells excess capacity on
  its retail VoIP routes to other carriers for the
  transport and termination of VoIP traffic.

7
NGS Multiple Services One Platform
8
Overview of NCT

• Building on Net2Phones expertise in the VoIP
  arena, NCT has developed a fully outsourced
  PacketCable compliant VoIP solution for cable
  operators. NCTs solution enables cable
  operators to offer the triple play of voice,
  data, and video to their consumers.
• NCT targets small to mid-sized cable operators in
  the U.S. and operators of all sizes in Europe and
  Latin America. These cable operators may not
  have the significant technical and financial
  resources required to develop a self-provisioned
  cable broadband voice solution.
• Implementation of a viable cable voice service
  requires the expenditure of significant resources
  such as
• Personnel to support network operations
• Engineering
• Project management
• Significant capital expenditures for VoIP
  elements
• Costs to manage interconnection process

9
NCT Offers Full Outsourcing for Cable-Provided
Voice

• Business process development
• Solutions assurance
• Network systems engineering
• Billing provisioning integration
• Systems deployment

Planning and Deployment

• Network management
• OSS service management
• 24 x 7 NOC

Real-Time Assurance
Call Management Server

• Call agent and signaling
• Announcement server
• Class 5 feature support
• 411, 611 and voice mail
• Trunking gateways

Cable Voice Operations Support Systems (CVOSS)

• Infrastructure management
• Local and long distance bilateral termination
• Emergency support services

Voice Services Management
10
NCT Makes Cable-Provided Voice Work
11
Freedom from Regulation for VoIP Services
Promotes the FCCs Goals

• Goal 1 Investment
• Commissioner Abernathy at VoIP Forum any
  regulatory regime for VoIP must promote
  investment.
• VoIP investment has flourished under the hands
  off approach as the FCC predicted in the 1998
  Report to Congress.
• The FCCs 1998 findings still apply today As an
  empirical matter, the level of competition,
  innovation, investment, and growth in the
  enhanced services industry over the past two
  decades provides a strong endorsement for a
  deregulatory approach.

12
Freedom from Regulation for VoIP Services
Promotes the FCCs Goals

• Goal 2 Rural Deployment
• Commissioner Adelstein at VoIP Forum all
  Americans, whether urban or rural, should have
  access to high quality services at reasonable
  rates.
• Using NCTs end-to-end solution, smaller cable
  companies will have the ability to upgrade their
  networks to have the capability to offer voice
  services to their existing subscribers.
• These cable companies serve predominantly in
  rural and suburban areas.
• VoIP will provide these subscribers with
  competitive choices for residential voice service
  typically found only in urban areas.

13
Freedom from Regulation for VoIP Services
Promotes the FCCs Goals

• Goal 3 Provision of Social Services
• Chairman Powell at VoIP Forum the FCC must
  protect its critical initiatives, such as public
  safety, security, and consumer protection.
• Specific regulations and technical requirements
  are not necessary at this time
• NCT has a 911 solution in place today.
• The VoIP industry is independently pursuing
  voluntary solutions to the technical issues
  raised by 911, CALEA, and disability access.
• In light of the competitive nature of the VoIP
  market, VoIP providers must tailor their service
  offerings to meet consumer demand for certain
  service features.

14
Conclusion

• Consumers have benefited and will continue to
  benefit from a hands off approach.
• Freedom from regulation promotes
• Greater investment in infrastructure and networks
• Incentive to offer competitive alternatives to
  traditional providers
• Development of new and innovative service
  offerings tailored to meet customer demand
• Deployment of advanced services to rural areas
• Social policy concerns can be addressed by the
  VoIP industry without the imposition of
  burdensome regulation.

15
December 15, 2003

• On behalf of Net2Phone Global Services, LLC., and
  Net2Phone Cable Telephony, LLC.
• Cherie R. Kiser Elana Shapochnikov
• Mintz, Levin, Cohn, Ferris, Associate General
  Counsel
• Glovsky and Popeo, P.C. Net2Phone
• 701 Pennsylvania Avenue, NW 520 Broad Street
• Washington, DC 20004 Newark, NJ 07102
• crkiser_at_mintz.com eshapo_at_net2phone.com