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Telium Support Group
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When the peers are in a state of dual-active contention one of the peers is considered improperly active (invalid state). In other words, it should not be processing calls at all. Usually trunks (E1/T1/SIP/IAX/etc) are forced to one peer or the other which means one peer will not be getting (more) calls. If your configuration allows both peers to handle calls simultaneous then you are in the minority (this is not typical).

For this reason the number of active calls is not a criteria in determining which peer to demote.