Hmm, the idea of a switchboard operation and someone on the other end of the SPOT system making a judgement call about the nature of the emergency might change the mix a bit. If it were just a pass through service like a cell phone connection, then I would expect the same rules to be in play, whether charged for or not (in the case of the cell providers, their fee for 911 service is absorbed as overhead, meaning the cost for the service is indirectly billed to the network as a whole, which I don't think alleviates their connections. A ham operator that provides a free interconnect on a community repeater can still be held accountable for other people's use of that system, especially if it violates any laws or regulations).

I guess we'll just have to see how that situation evolves. If SPOTs postion really is that tenuous, I suspect someone will eventually file suit against them in some way. If that happens and SPOT loses the case, I'll do my level best to make sure anyone I find using the service from then on has a legitimate cause for pushing the button, like a broken leg, or arm, or nose. LOL
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The ultimate result of shielding men from the effects of folly is to fill the world with fools.
-- Herbert Spencer, English Philosopher (1820-1903)