Back To Bed
Bayswater Factory Direct
29 Jersey Road
Bayswater VIC 3153
30 November 2011
Australian Communications and Media Authority
PO Box 13112
Melbourne VIC 8010
Our business, Back To Bed, has been Melbourne‟s futon specialist for over 20 years.
We have been promoting our highly valuable and instantly memorable „category killer‟ phone name 1800 FUTONS for over 6 years.
Futons are highly affordable bedding solutions and are often purchased by people in fiscally-challenged socioeconomic groups.
Having a phone name that combines the free call prefix „1800‟ with the word „FUTONS‟ is the foundation of our brand and our highly effective consumer marketing communications strategy.
As such, we are very much in support of your proposal to make calls to 1800 numbers free from mobiles. As are our customers!
1800 „free call‟ numbers should be just that – i.e. “FREE TO CALL”.
We understand that our inbound call rates may need to increase slightly as a result of this change to call charges due to the need for a „Mobile Access
Charge‟ payable to the mobile carriers to compensate them for loss of calling party revenue.
As long as this „Mobile Access Charge‟ is regulated by the ACCC in the same way they regulate the „Mobile Termination Charge‟ we see no issues with this.
What we do have a major issue with is the idea of a new number range being
introduced that is „Free Call From Mobile‟.
We see „1800‟ as a brand in its own right.
When consumers think of „1800‟ they think of „Free Call‟.
The fact that calls from mobiles to 1800 numbers are not currently free is an anomaly that needs to be fixed. Fast.
The introduction of a new „free to call from mobiles‟ number range would lead to massive consumer confusion.
If 1800 is free call, what is the new „1XXX‟ number range called? “Really Free Call”?
Further, if a new „free to call from mobile‟ number range was introduced, it would completely undermine the „consumer promise‟ and „value proposition‟ of the „1800‟ prefix.
Companies that have built their brands and trade marks around their „1800 free call‟ numbers - such as we have - would potentially seek damages due to loss of trade if competitors were to secure the new „free to call from mobiles‟ version of their number.
The solution is so simple.
Make „Free Call‟ 1800 numbers free to call from all phones including mobiles.
You said it best. „Free‟ means „Free‟.