LoyalBlog

iPhone Can’t be DCA Compliant – * UPDATE * DCA Says it CAN!

*** UPDATE *** 11/17 – Turns out DCA doesn’t see it the same way I do. Even Apple says its not tamper-proof. I still don’t think that the iPhone is compliant with the letter of the law because the scenario from the DCA here relies on the third party’s server-side editing of the data. Thats kinda like tampering with it and its hard to verify after the fact that on a certain day and time, the server was synchronized, etc…, but if DCA’s own general counsel says it is compliant, then I gotta yield:

Per DCA:

Mr. (REDACTED)

As you know, the rule requires that the electronic record of service must be labeled with the GPS or cellular network date and military time maintained by the mobile device. Assuming that the reference clock providing the time to the Stratum 1 NTP clock to which the server is synchronized is a GPS or newtwork source, I think that the transmission of time from the server to the mobile device complies with the rule.

Sanford M. Cohen
Deputy General Counsel
NYC Department of Consumer Affairs
42 Broadway, 8th Floor
New York, NY 10004
Tel: (212) 487-4240
Fax: (212) 487-4197
nyc.gov/consumers

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So: DCA says an iPhone can be compliant with their rules…

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

Original Post:

Surprise! There’s no way to get a tamper-proof network time from the iPhone! See the response from Apple below as I asked them about getting a separate GPS signal date and time like our droid app does. So yes, our iPhone app is almost done, BUT IT IS NOT GOING TO BE DCA COMPLIANT! … and neither is anyone else’s iPhone app. That’s why you’re hearing phrases out there like *virtually* compliant. I don’t know about you, but unless you want a *virtual* fine from DCA, you need to be doing your homework about these apps and how they work or rubbing elbows with people that do.

Don’t listen to the marketing hype from some of these places. You are talking to sales people and their job is to sell you something. They don’t understand the programattical technicalities that the new DCA rules have in them. I wondered why they specified about the two dates and times they want in the rules. It tells me that someone there knows very well that the iPhone times can be tampered with and that’s why they want the GPS date and time/network time.

Winter’s coming, don’t get snowed. What you will see now is these other companies will rush to make droid apps, but what you should remember is none of them came clean with you and protected you and your business up front and honestly in the first place. They just glossed over it and wanted to sell you their iPhone apps while they scrambled. Make sure you’re putting your trust in the right people who not only have the knowledge and passion needed to protect you, but also the blunt honesty to tell you what time it is so you know what’s going on.

………………………………………….

Please include the line below in follow-up emails for this request.

Follow-up: 1751xxxxx (REDACTED)

Hello Robert,

Thank you for contacting Apple Developer Technical Support (DTS). Our engineers have reviewed your request and have concluded that there is no supported way to achieve the desired functionality given the currently shipping system configurations.

If you would like for Apple to consider adding support for direct access to the raw GPS data in the future, please submit an enhancement request via the Bug Reporter tool at .

While you were initially charged a technical support incident for this support request, we have assigned a replacement incident back to your account.

Thank you for taking the time to file this report. We truly appreciate your help in discovering and isolating issues.

Best Regards,

Developer Technical Support
Apple Worldwide Developer Relations

LoyalDog Pricing Structure Upgrade

We are changing our pricing structure!

At $350/month we are one of the more expensive options out there for process servers. This makes it harder for smaller agencies to afford us.

Our client list today encompasses some of the larger agencies in the country that leverage our high volume features and stability/responsiveness to lead their local markets and dominate their competitors.

10 years ago, I wrote LoyalDog for the little guy, though. My intention was to put out game-changing technology, listen to our customers and give them whatever they needed – whatever they wanted that their competitors didn’t have – and help them take on larger agencies and help them get greater market share.

Over the years we became recognized as the best process serving software hands down. It is alot of hard work to keep that distinction and we have gradually increased our rates to cover costs. It worked, we have many many large agencies as clients now, but only a few smaller ones.

I feel that with our current flat pricing structure, we are alienating smaller agencies from our product and deviating from our original mission of helping smaller agencies get ahead in their markets.

In this vein, we are changing our pricing structure to a volume-based plan:

0-500 jobs per month: $75/mo.

500-1000 jobs per month: $200/mo.

Over 1000 jobs per month: $350/month

We hope to get some input from smaller agencies and help them in their markets.

Rob

Mobile App Integration with Third Parties

The New York State Professional Process Servers Association has endorsed a mobile application that we wrote for a qualified third party provider called The Independent Server (http://theindependentserver.com)!

It’s quite an application and is in full compliance with the DCA Digital Records rule and the new GPS rule that is taking effect shortly.

What makes this application special is that it doesn’t just talk to LoyalDog. We have integrated it with some agencies that use proprietary software of their own and we have also integrated it with Edocxsolutions and Process Master. Special thanks to Robert Gillis for his support and technical savvy.

The teamwork is really amazing and we’re having a wonderful time integrating with these other platforms and learning new things.

It’s always good when everyone works together! Is your software provider staying ahead of the game and working together with others to make sure you have what you need no matter what?

Maybe they should.

Rob

Hot Mapping Feature On Droid App is IN!

Latest update of The Independent Server app for the phone has the map in it. If your agency is geo-coding their addresses, then you can use the Prox Map button to show you all the jobs around you. Just hit the closest one and you can hit the Get Directions button for turn by turn real time GPS directions! It even talks to you!

Next update will make the pushpins for the jobs you just attempted change color so you don’t select them again.

Get ready for more updates on the mobile phone side. We’re moving in leaps and bounds with this.

New GeoCode Addresses Feature

What is Geocoding?

Geocoding is getting a latitude and longitude for a street address.

What this feature does:

This new button (GeoCode Addresses) pulls up all open jobs that do not have geocoded addresses.

You can Select them and push them through Google to get latitude and longitude for them. Then you can Select them again and save them back to the database with the new information.

Why do I want to do Geocoding like this?

We’re going to be coming out with a nice new feature on our mobile app that will show your process servers which jobs they’re closest to and once they touch one of them its going to help them get there. This should help some of your servers be VERY efficient.

If you’re disciplined about doing this on your jobs as they come in, it can be a real game-changer when you present to prospective clients and boost your process server’s efficiency.

New NY DCA Proposed Rules are in!

NY DCA has released their proposed rules for GPS.

There’s some neat provisions in there and we’re adjusting the app accordingly to make it fully compliant.

These proposed rules aren’t law yet, but we’re figuring that some of them will be. Honestly, most of them are good practices and not too challenging for us to incorporate into the app.

Let’s hope the public hearings to come don’t result in anything too crazy. We’re watching this closely and are on top of it tuning the app accordingly as we go.

We’re going to end up with 2 apps here.

One that is DCA compliant for NY and another for everyone else. The DCA requirements as of today are going to forbid the phone to queue the data and require real time uploads of everything.

That’s slower than having the phone queue it up and upload it later (maybe at the end of a shift), but its also more secure and leaves less to question, because they can track when the information was taken vs when the information was uploaded.

Rob

Be Careful Who You Do Business With!

Normally, I try not to do fear mongering, but lately I have noticed a trend in some of the process serving software solutions that have come onto the market recently.

They’re owned by other process serving agencies!

I had an agency quite a few years back too – and when I did, the idea of putting my data on another process serving agency’s computers seemed insane to me.

I’m wondering if it seems insane to you?

Consider these fine programs:

Processs-360.com — This is owned and in use by a process serving agency.
CivilMap.com — This is owned and in use by a process serving agency.
MyTrueServe.com — This is owned and in use by a process serving agency.

To me, this is a conflict of interest. I’m not trying to smear them to get more customers – their programs are fine, but would I put my clients and pricing and server network on their computers where the data can easily be mined and analyzed?

Not in this lifetime.

So ask careful questions of the companies that you are considering to run your business and be privy to your confidential data.

1) Can I have my own server?
2) Can I have direct access to the database on it to make my own backups and reports?
3) Who owns the company?
4) Who owns the corporation(s) that own the company and what other ventures (like process serving agencies) do they also own or have involvement in.
5) How forthcoming with this information were they before I started asking detailed questions?
6) What reputation does the owner(s) have within the industry? Ask around and drop some names and see what responses you get.

Just a few extra minutes of due diligence could save you from your software provider (or someone they sold your data to) opening up a branch office a few blocks away from you and knowing who your clients are, what you charge, who you use to serve your papers and how long it takes you to get things done.

I’m not saying that this is the business model of the above companies.

These are just the things I would worry about if I had a process serving agency and was shopping for software. I would want to know if I was putting my data in my competitors’ computers.

Rob

12/10/2010 – DCA HEARING REPORT FOR PROCESS SERVERS IN NEW YORK

Hello Process Servers,

Today, we attended the DCA hearing. There was one hearing officer present and an assistant and they recorded the hearing. Present were 50+ process servers and less than a dozen attorneys from various Legal Services organizations.

NYSPPSA stated their objections and the legal services attorneys presented their requests to have the rules more clearly stated and asked for some stricter provisions.

I briefly testified appealing for a dialogue between Consumer Affairs and these Legal Services with the process serving community. I asked that all process servers don’t get painted with the same brush because of a couple of bad ones.

It dawned on me while I was there that these attorneys may have a bad opinion about process servers because they might be seeing alot of defective services. I think its kind of like watching the News at 11. You get 90% bad news and 10% good news. I had the sense at this meeting that neither side really knew the other very well. A good process service is quiet and is not noticed or usually challenged so it doesn’t show up on any radars. If the legal services are seeing mostly defective services, they may believe that most serves that happen are defective.

As a software provider, I probably see the better side of the business. Most of the people I know in the business are customers of ours and are nice honest people that run honest operations. I know there’s a few agencies out there that bury their heads in the sand and see no evil and hear no evil.

Joel Graber made an excellent point there that only the bad process servers should be punished instead of an entire industry. I agree with that.

As I observed the hearing and the attorneys from the legal services I felt an animosity on both sides towards the other. I had an employee of ours there with me who is more familiar with programming than the industry itself and as I was explaining what was happening to him it dawned on me that both sides are right.

Due to the American Legal debacle and a couple of other crooks, the public has been damaged. The judicial system itself has been tarnished. Serving process is very important. It is that act that invokes the court’s jurisdiction upon the defendant. Much damage has been done here and these legal services have had to deal with alot of it. Even though there are only a couple of bad process servers here, they had high volume accounts and did an unprecedented amount of damage to the court system and to the general public.

One company got put out of business, the other one was ran out of town too and had their owner sentenced to a year in jail. I know there’s still a crook or two out there. They’ll get what’s coming to them.

I think no matter what happens at these hearings or what laws get passed, we as process servers (and yes, software providers too) need to reach out and establish a dialogue with these people and try to repair the damage that has been done to our image. These people need to know some of the people that I know and that I look up to and admire in this industry and they need to know that nearly all of us are honest hard workers that want nothing to do with unethical behavior and sewer service.

I think this has been going on for a long time and it might take a long time to build a good relationship with these people.

Let us start soon and sieze this opportunity to build bridges and friendships and try to heal some of the damage that a few unsavory characters have done to our image. Somehow we need to pull together and take the first step. All of the Attorney Generals and process servers around the country are watching what is happening right here.

Both sides want the same thing: The bad process servers ran out of the business and the public protected from any more damage. Can they work together to help achieve this in a positive manner?

Rob

UPDATE GPS PROCESS SERVER LAW NEW YORK

In a prior blog post we indicated that we had no dialogue with Department of Consumer Affairs in New York. We’re pleased to tell you that we spoke with them via their reps a few days ago.

They have reached out to pretty much all of the software vendors and asked for input on the present technology and how to use it effectively as they write the provisions of their regulations.

We still have no idea what the specs are going to be, but I came away from the conversation feeling that they want to come out with a set of standards that process servers can comply with.

They made it clear that they do not want to do a vendor lock-in situation or endorse or certify any product as “approved by DCA”.

As soon as we get our hands on those specs, we’ll be adjusting things accordingly if we need to.

Rob

NEW Variable Threshold GPS Feasibility Analysis

Some Attorney General settlements and other market conditions are demanding you to run a feasibility analysis on your GPS data.

LoyalDog allows you to set the parameters for this so you can rachet down a tighter analysis in different demographic situations.

For example, running a 55mph threshold in downtown Manhattan might not be tight enough to flag things that don’t add up. In Los Angeles, however, a 20MPH threshold might show too many flags to investigate.

LoyalDog adapts to your particular situation and allows you to show exactly how and why you are performing your auditing and analysis.

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