4.4. On 22nd December 2009, ACL made written submissions to the Commission stating that the E1 link MSISDN 0751362050 was not used for any fraudulent/criminal activities for the whole period that it was in use. In addition, ACL submitted a printout of the downloaded Call Data Records (CDR) file for all calls that passed through their PABX for the whole period that the E1 link was ON which had been shared with ETKL for comparison with their own CDR. ACL complained that despite several requests to ETKL to share with them similar data concerning the alleged fraud, ETKL had neglected to do so. ACL further indicated that they had no capability to generate ETKL IMSIS insisting that such an exercise could only have been executed by ETKL personnel at their switches/servers. ACL further stated that the physical E1 link was unstable for the period between 1st and 4th November 2009 within which time the fraud is alleged to have taken place. As a result, the transmission of calls across and within their telecommunication systems was not seamless as provided for in Regulation 37(3) nor was there maintenance of end-to-end quality of service as provided in Regulation 36(c). 4.5. On 5th January 2010, ACL submitted to the Commission further correspondence exchanged with ETKL prior to the conclusion of the interconnection agreement and during the existence of the E1 link. 5. HEARING The hearing by the Commission was held on 4th and 5th January 2010 and the parties made their submissions as follows: ETKL SUBMISSIONS: a) ETKL and ACL entered into an agreement to interconnect their systems over a bidirectional E1 connection based on SS7 signaling protocol for provision of VoIP services; b) ETKL has provided a range of numbers to ACL one of which is 0751362050 designated as a pilot number. The numbers are to be accessed through the E1 link to reach ACL systems. All calls between the two companies are to pass through the E1 link; Page 5 of 11