FCC Seeks Comments on Service Offering for Kids Restricting Access to the PSTN

With 42 years of industry experience, I rarely see services that are actually new rather than repackaged ones already available, albeit with newer technology. Recently, however, a small company called Tin Can has developed something new, and one that clearly has a market need.

As the founder of Tin Can Chet Kettleson notes,

Tin Can is a small start-up company, whose mission is to provide a safe alternative to the traditional telephone network especially for young children by limiting exposure to the Public Switched Telephone Network (PSTN), thereby limiting unwanted or fraudulent calls.

Tin Can provides its customers with a device that connects to the Internet and functions as a VoIP endpoint operating exclusively on Tin Can’s closed network.  Each Tin Can device is assigned a unique extension number within that network, and by default, communicates only with other Tin Can devices.

Recognizing that some users may need to reach trusted parties without Tin Can devices, the service also has an option that allows account holders, typically parents or caregivers, to “whitelist” a limited number of contacts.  Once a contact is whitelisted, the Tin Can customer may place and receive calls from that contact over the PSTN. No other PSTN access is permitted.

The app further empowers caregivers to impose additional restrictions on their child’s usage including establishing active and inactive call hours, monitoring call activity and adjusting or revoking whitelist contacts at any time.

Once a whitelist is established, the customer will have access to all emergency 911 services.

On May 20, 2025, Tin Can filed a Petition for Declaratory Ruling in Docket 25-288 requesting the FCC to find that its unique service does not constitute a VoIP service subject to the onerous Title II rules, or in the alternative that those rules are waived.  Those rules, which would be impossible for this start-up company with limited resources to comply with include:

Customer Proprietary Network Information (CPNI) – This rule exists to protect customers with access to the PSTN from having their information used for unwanted marketing or other nefarious purposes.  Tin Can argues that it shouldn’t apply to its service because there is only limited PSTN access.

Section 214 Discontinuance and Impairment – Exists to ensure legacy customers are not cut off from essential services.  It should not apply to Tin Can since it provides an optional service device rather than a family’s primary telephone service.

System Security and Integrity Plan – Submitting a detailed plan that combines with the Communications Assistance for Law Enforcement Act (CALEA) is burdensome and unnecessary.  The target audience of young children is unlikely to be part of CALEA needs.

Outage Reporting – Unlike Tin Can’s service, outage reporting requirements exist for services with continuous access to the PSTN. 

Finally, Tin Can argues that applying these onerous Title II requirements would be contrary to the public interest.  It simply wants to provide a safe calling and limited environment for young children.

Industry comments on Tin Can’s Petition for Declaratory Ruling are due on October 16, in Docket 25-288.  It will be interesting to see the industry reaction to this unique service offering. Frankly, it is likely we will soon see other companies offer their own version of this service.