Isn't the "FAX Over IP (T.38)" license for T.38 relay, like between controllers/network elements in a cluster, and requires a DSP-II module? I didn't think it was required for T.38 within a single controller... Just enable it in Network Zone 2 and apply Network Zone 2 to the local NE and MiCollab/MBG's.
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That is my understanding too and we are using T.38 on numerous systems successfully without t.38 licensing.