4. WRITTEN SUBMISSIONS
WRITEN SUBMISSIONS FROM ETKL
4.1. On 22nd December 2009, ETKL made written submissions to the Commission
in support of their allegation that the E1 link had been used fraudulently
between 1st and 4th November 2009. The submission included data from
AREDU, the ETKL designated roaming partner in Dubai. The submission
indicated that roaming call records had been created although ETKL had not
yet unlocked their out-roaming services to their subscribers, which they
considered a fraudulent activity attributable to the E1 link allocated to ACL.
ETKL indicated that they resolved the problem by disconnecting the E1 link
on 4th November 2009 and no further call records were created after the
disconnection. ETKL also indicated in the submission that their roaming
partner had established records and generated charges amounting to
Ksh.753,844.66 payable to AREDU, which it attributed to fraudulent activity.
4.2. On 28th December 2009, ETKL made further written submissions to the
Commission indicating that ETKL lines identified as having made calls on the
AREDU network in Dubai were locked into the ETKL network in Kenya and
were barred from roaming. In addition, ETKL indicated that since the alleged
numbers were seen in the local Visitor Location Register (VLR), the only way
the roaming calls could have been made was through by-passing the ETKL
systems. In addition, ETKL requested the Commission to clarify whether
agreements for provision of E1 links where a mobile service provider offers a
link (access) to an ISP to route traffic are classified as interconnection
agreements.
4.3. On 6th January 2010, ETKL submitted additional documents to the
Commission which included copies of their roaming agreement and a GSM
invoice for roaming traffic from AREDU.
WRITTEN SUBMISSIONS FROM ACL
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