ns. These systems are used for ordering and providing service for voice, data, and Internet services. A customer places an order for service that leads to various internal systems for the network firm: "workflow, ordering, inventory, circuit design/engineering, provi- sioning, and activation." Each of these systems has associated software, information, and management processes. Additional systems connect these processes to make sure that the right network facilities are made available and the necessary network elements are activated (International Engineering Consortium [IEC] n.d.). According to the IEC, "the largest problem [ILECs] face is facilitating access to information residing within their OSSs." The IEC points out that OSSs are "standalone, proprietary mainframe systems that were never designed to share information with external systems or trading partners" (IEC). However, under the 1996 Act, ILECs must allow CLECs access to OSS functions used for obtaining customer data, ordering service, and providing service. To comply with the Act and FCC enforcement requirements, ILECs must invest in substantially modifying or replacing automated internal information systems. There is a substantial cost to making available the network firm's internal systems that can provide service requested by the customers of another firm. In addition, ILECs must provide external interfaces to allow information exchange with the information systems of CLECs. To achieve systems integration between their systems and those of CLECs, ILECs must invest in complex software and hardware systems for electronic data interchange. CLECs must invest in cor- responding systems to gather preorder customer information from ILECs and to transmit order information to ILECs (IEC n.d.). Not only must ILECs and CLECs exchange ordering and confirmations upon customer signup, but also they must share ongoing service usage data for billing purposes. It should be evident that OSS interfaces between ILECs and CLECs require substantial investment and opera