FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011 Page: 5,550
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practices by VRS providers or their subcontractors.' Some of these allegations have resulted in criminal
investigations of VRS practices, which in turn have been the subject of semi-annual reports that the
Commission's Office of the Inspector General (OIG) has submitted to Congress.'6 The reports on these
investigations have noted evidence of the following illicit VRS activities:
* VRS callers specifically requesting that their calls not be relayed by the CA to the parties that
they call; "
* Calls placed to numbers that do not require any relaying, for example a voice-to-voice call;
* Calls initiated from international IP addresses'8 by callers with little or no fluency in ASL
where the connection is permitted to "run" (i.e., the line is simply left open without any
relaying of the call occurring);19
* Implementation of "double privacy screens" (i.e., where both users to the video leg of the call
block their respective video displays, thus making communication impossible);
* VRS CAs calling themselves;
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indicted for illegal VRS activities were call center managers, paid callers, and VRS CAs. Fraud uncovered by the
investigations associated with these indictments revealed tens of millions of dollars of payments that were
illegitimately collected from the Fund. Structure and Practices of the Video Relay Service Program, CG Docket
No. 10-51, Declaratory Ruling, Order and Notice of Proposed Rulemaking, 25 FCC Rcd 6012 at 6016, 16, n.22
(2010) (VRS Call Practices NPRM). Two primary sources of fraud uncovered through these investigations were
illegitimate calls made to taped programs and calls ostensibly made for the purpose of marketing and outreach.
S We previously noted that these have included reports of the use of VRS for video remote interpreting services, the
hosting or promotion of teleseminars for the express purpose of generating VRS minutes, and payment to
individuals or organizations to place VRS calls using a particular provider's service. See Structure and Practices of
the Video Relay Service Program, CG Docket No. 10-51, Notice of Inquiry, 25 FCC Rcd 8597 at 8607, 31 (2010)
(2010 VRS NO!).
16 See, e.g.. Office of Inspector General, Semi Annual Report to Congress, April I-September 30, 2009, available at:
http://ww .fcc.gov/oia/SAR 12-22-09.pdf (OIG Semi Annual Report).
17 In the OIG Semi Annual Report, the term "video interpreter," or "VI," is used to refer to a CA who handles VRS
calls. In this Order, such individuals are referred to as CAs throughout.
'8 We define calls made from international IP addresses as those that come from an IP address that the Fund
administrator detects as likely coming from a device associated with an individual initiating the call from a location
outside the United States.
'9 See United States v. John T.C. Yeh et al., Criminal No. 09-856, D.NJ. (Nov. 18, 2009). ("Defendants John Yeh,
Joseph Yeh, and Viable would pay friends and acquaintances to generate VRS calls that Viable employees often
referred to as 'r calls' or 'run calls.' These run calls would be made for the sole purpose of generating illegitimate
VRS minutes for which NECA would be fraudulently billed."); United States v. Kim E. Hawkins et al., Criminal No.
09-857, D.N.J. (Nov. 18, 2009). ("Defendants I.. Berke, D. Berke, and Goetz would generate and process certain
illegitimate VRS calls at Master Communications and KL Communications for the purpose of submitting those VRS
minutes to NECA, thus generating millions of dollars in revenue. These ... 'run calls' would be calls made for the
sole purpose of generating illegitimate VRS minutes for which NECA would be fraudulently billed.")5550
Federal Communications Commission
FCC I 1-54
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United States. Federal Communications Commission. FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011, book, April 2011; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc52169/m1/722/: accessed April 19, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.