Subject: IPP> IPP 2 IFAX Integration Time and Date Stamp

From: Ron Bergman <[email-masked]>
Date: Tue, 6 Oct 1998 11:34:35 -0700 (Pacific Daylight Time)

Richard,

I thought I would send this out separate from the other issues, since this
appears to be the most critical fax issue.

The first question, from the IPP meeting that came from this discussion...
"Where is the time stamp afixed to the document?  (i.e. At the source or
the destination?)"  If the document image is ever stored between the two
points these times could be very different, even without the consideration
of time zone changes.

It was generally agreed by IPP participants that an IPP/IFAX compatible
printer could be required to implement a real-time clock.  The IPP/IFAX
feature would be a superset of the present IPP version 1.0, as it most
likely will require the inclusion of new attributes and other features
beyond the current specifications.  This is not a serious problem, since
IPP is very extensible and is not restricted by any legacy printing
applications.

The second question concerns the legal issues... "Would the legal
requirements of a real-time clock for current fax machines automatically
apply to an IPP/IFAX device?"  If this answer is yes, there would exist a
very strong incentive for a vendor not to build an IPP/IFAX device that
does not have a real-time clock.

Please let me know if there remains any issues regarding a time stamp.

	Ron Bergman
	Dataproducts Corp.

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From: Richard Shockey <[email-masked]>
Date: Tue, 06 Oct 1998 15:23:09 -0500

>points these times could be very different, even without the consideration

Well there are really 3 points where a traditional fax transmission is
time/date stamped.
First is in the senders log file and this is pretty much a common feature
of all current fax machines and fax software systems. A receipt is usually
generated at the end of the transmission or logged internally to the
machine/server and can be printed on demand. Every receipt or log file is
time date stamped.

Second the senders device/software usually "watermarks" each page of the
transmission at the top of the page with the time/date stamp, CSID sender
identification and usually the page number.  This watermark can be
suppressed and there is no legal requirement that the pages be so
"watermarked", however  US Federal law 47 USC 227 does state that, and I
quote: 

   "Identification Required on Fax Messages"

    The FCC's rules require that any message sent to a fax machine must
clearly mark on the first page or on each page of the message:

·	 the date and time the transmission is sent;
·	the identity of the sender; and
·	the telephone number of the sender or of the sending fax machine.

The operative word here is OR on each page of the message.  Most of this
data could be  covered by automatic cover page generation with an IPP
client. Clearly this regulation does not apply to facsimile transmissions
if the transmission is end to end IP, however if it is our intent to
demonstrate IPP as a facsimile service it would be useful to design the
protocol to comply with the sprit if not the letter of the current
regulations.  In addition, should a legal challenge be mounted to the
legitimacy of a IPP or RFC 2305 "facsimile" transaction it would be useful
to demonstrate the "original intent" of the protocol designers to comply
with the various national requirements for identification and replicate the
"look and feel" of a traditional analog fax service.

Of course there is time/date stamping by the recipient, who usually logs
transactions or generates a receipt in a manner similar to senders.

>Please let me know if there remains any issues regarding a time stamp.

It would not "automatically" apply since the legality of such a transaction
over a purely IP network has not been tested in court,  however if IPP were
to gateway [redirect in IPP terms] with RFC 2305 and the IPP transaction
transverses the PSTN at any point ...then the legal requirements would
apply.  

All fax transactions and indeed all SMTP transactions are time/date
stamped, therefore in my judgement IPP devices should have real-time clocks.

Richard Shockey
Shockey Consulting LLC                  
8045 Big Bend Blvd. Suite 110    
St. Louis, MO 63119
Voice 314.918.9020
Fax   314.918.9015
INTERNET Mail & IFAX : [email-masked]  
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