I have a potential customer that has an IPO Basic Edition R9 that he pulled from a location that they recently closed. He called and asked if we could install/program the system in his current location.

I recommended that we should get the system up to date. In checking with our BP whom we go thru to get our Avaya licensing, I was told that Basic Edition is not compliant with Kari's Law, and that going forward all new installs and upgrades must be compliant. Beings that Kari's Law deals with the ability to dial 911 from any phone (at least as I understand it), and this is a Basic Mode system setup in Key System mode, doesn't that already make it compliant as all sets have line appearance keys and thus would be able to dial 911 directly. Or am I missing something?

Only phones that have their Auto Line Select set to Intercom-Line 1-Line-2-etc will be non-compliant. If the phone gets outside dial tone when going off hook, 911 gets you to emergency services

I was also informed that the system must be capable of sending and alert/notification to someone on premise (or to a manager cell for example) that a 911 call has been placed. I'm told the Basic Mode will not do this and that you must have Essential Mode. Basic Mode will probably be discontinued is the train of thought.

I'm sure we will push the Essential Mode license upgrade (just so that we are compliant), but does this sound right what I'm being told?

After explaining things to the customer, he was ok with us upgrading to Essential and then I know we have all of our bases covered.
Thank you for the reply.

Also, heard that Avaya has said it has Karis law compliance on the roadmap for Basic Edition. I think in the January timeframe.

I have a digital copy of Kari's law as printed, only the PDF is larger than allowed as an attachment.

Here is a copy and paste of the text. I've adjusting the formatting as best I can to match the original.



Public Law 115–127
115th Congress



Feb. 16, 2018
[H.R. 582] To amend the Communications Act of 1934 to require multi-line telephone systems
to have a configuration that permits users to directly initiate a call to 9–1–
1 without dialing any additional digit, code, prefix, or post-fix, and for other
purposes.

Kari’s Law Act Be it enacted by the Senate and House of Representatives of
of 2017. the United States of America in Congress assembled,
47 USC 609 note.


SECTION 1. SHORT TITLE.

This Act may be cited as the ‘‘Kari’s Law Act of 2017’’.

SEC. 2. CONFIGURATION OF MULTI-LINE TELEPHONE SYSTEMS FOR
DIRECT DIALING OF 9–1–1.

(a) IN GENERAL.—Title VII of the Communications Act of 1934
(47 U.S.C. 601 et seq.) is amended by adding at the end the
following:

47 USC 623 note. ‘‘SEC. 721. CONFIGURATION OF MULTI-LINE TELEPHONE SYSTEMS FOR
DIRECT DIALING OF 9–1–1.

‘‘(a) SYSTEM MANUFACTURE, IMPORTATION, SALE, AND LEASE.—
A person engaged in the business of manufacturing, importing,
selling, or leasing multi-line telephone systems may not manufacture
or import for use in the United States, or sell or lease or
offer to sell or lease in the United States, a multi-line telephone
system, unless such system is pre-configured such that, when properly
installed in accordance with subsection (b), a user may directly
initiate a call to 9–1–1 from any station equipped with dialing
facilities, without dialing any additional digit, code, prefix, or postfix,
including any trunk-access code such as the digit ‘9’, regardless
of whether the user is required to dial such a digit, code, prefix,
or post-fix for other calls.

‘‘(b) SYSTEM INSTALLATION, MANAGEMENT, AND OPERATION.—
A person engaged in the business of installing, managing, or operating
multi-line telephone systems may not install, manage, or
operate for use in the United States such a system, unless such
system is configured such that a user may directly initiate a call
to 9–1–1 from any station equipped with dialing facilities, without
dialing any additional digit, code, prefix, or post-fix, including any
trunk-access code such as the digit ‘9’, regardless of whether the
user is required to dial such a digit, code, prefix, or post-fix for
other calls.

‘‘(c) ON-SITE NOTIFICATION.—A person engaged in the business
of installing, managing, or operating multi-line telephone systems
shall, in installing, managing, or operating such a system for use
in the United States, configure the system to provide a notification









to a central location at the facility where the system is installed
or to another person or organization regardless of location, if the
system is able to be configured to provide the notification without
an improvement to the hardware or software of the system.

‘‘(d) EFFECT ON STATE LAW.—Nothing in this section is intended
to alter the authority of State commissions or other State or local
agencies with jurisdiction over emergency communications, if the
exercise of such authority is not inconsistent with this Act.

‘‘(e) ENFORCEMENT.—This section shall be enforced under title Applicability
V, except that section 501 applies only to the extent that such
section provides for the punishment of a fine.

‘‘(f) MULTI-LINE TELEPHONE SYSTEM DEFINED.—In this section,
the term ‘multi-line telephone system’ has the meaning given such
term in section 6502 of the Middle Class Tax Relief and Job Creation
Act of 2012 (47 U.S.C. 1471).’’.

(b) EFFECTIVE DATE.—The amendment made by subsection (a) 47 USC 623 note.
shall apply with respect to a multi-line telephone system that
is manufactured, imported, offered for first sale or lease, first sold
or leased, or installed after the date that is 2 years after the
date of the enactment of this Act.
Approved February 16, 2018.
47 USC 623 note.
Applicability.
VerDate Sep

LEGISLATIVE HISTORY—H.R. 582 (S. 123):
SENATE REPORTS: No. 115–124 (Comm. on Science, Commerce, and Transportation)
accompanying S. 123.
CONGRESSIONAL RECORD:
Vol. 163 (2017): Jan. 23, considered and passed House.
Vol. 164 (2018): Feb. 5, considered and passed Senate, amended.
Feb. 8, House concurred in Senate amendment.
Æ

There also seems to something odd about the attachment manager as it is set to "2 bytes". Bytes, not Kilobytes!

That would be helpful if Avaya did indeed follow thru on this.