FCC Record, Volume 26, No. 19, Pages 14991 to 15893, October 24 - November 10, 2011 Page: 15,053
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Commission rules or requirements filed in response to the VRS Practices R&O and Waiver Guidance
Public Notice were not rendered moot, and thus remained pending.'2
5. Convo was founded as a company in March 2009, and in October 2009 applied for
Commission certification for eligibility for compensation from the Fund for its provision of VRS."'
Convo receives compensation from the Fund for its provision of VRS via a billing agreement with Snap
Telecommunications, Inc. (Snap), which is a certified VRS provider.'4 While not eligible for direct
compensation from the Fund, Convo asserts that it has "thousands" of deaf and hard of hearing customers,
and is the fifth-largest VRS provider measured by the number of minutes per month of VRS calls
relayed.'" Convo offers several different VRS products, including IM, an Apple iChat-based VRS;
Mobile and Desktop, which are video communications applications that allow deaf and hard of hearing
callers to make VRS calls from any computer with a web camera and an Internet connection; Anywhere,
which allows users to access VRS by opening a web browser on any Adobe Flash-powered computer or
smartphone that can be used to access the Internet; and access to Convo's VRS for users of videophones
furnished by other VRS providers."'
6. In support of its request to waive section 64.604(c)(5)(iii)(N)(1)(i),7 Convo cites its
"diligent, good faith efforts" to obtain certification since filing a certification application in October 2009.
It also asserts that such a waiver is consistent with the Commission's stated goal in the VRS Practices
R&O that it would consider requests for temporary waiver in order to afford non-certified VRS providers
"an opportunity to continue to provide VRS as a subcontractor with an eligible provider until such time as
they obtain certification,"'s and that such a waiver would avoid the result of Convo having to cease
operations, abandon its customers, and lay off its workforce.'
7. In support of its request to waive the branding provisions of section
64.604(c)(5)(iii)(N)(1)(ii), Convo asserts it has developed a reputation as an "established and reputable
provider of VRS" that handles more VRS minutes per month than the majority of certified providers,'"
o See I'RS Star Order, 26 FCC Red at 8328, para. 3 n.6. For these reasons, we dismiss as moot Convo's request for
waiver of section 64.604(c)(5)(iii)(N)(1)(iii) of the Commission's rules, and address Con, o's request for waiver of
section 64.604(c)(5)(iii)(N)(1)(i) and (ii). See I8, in/ra.
SSee ('onvo Waiver Request at 3-4.
4 See id at 4.
See id. at 2-4.
i See gtenerall' i. at 7-8, Second Conlvo Waiver Amendment, Attach.
17 Convo requests w% ai\ er of section 64.604(c)(5 )(i)( N)( I )(i) of the ('ommission's rules, and the branding
provisions of section 64.604(c)(5)(iii)(N)(1)( i) of the Comlnission's rules, until September 1, 2011, by when, it
asserts, it would complete the process of restructuring its business to become a bona fi/de subcontractor of Snap. See
Second ( C'onvo Waiver Amendment at 2. Convo originally requested waiver of these rules until the Commission
acts on C'onvo's application for Commission certification for its provision of VRS, see Convo Waiver Request at 13,
but modified the time period covered by its request in the Second Conv o Wai cer Amendment.
SVRS Pr-ctire R&O. 26 FCC Red at 5575. para. 62
" Convo Waiver Request at 14.
, Id. at 15, 1 8-19. Convo originally sought to contitinuc to offer VRS under its own brand name until the
Commission acts on its VRS certification application, but in the Second Convo Waiver Amendment modified the
time period covered by its request. See note 17, iqra.
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United States. Federal Communications Commission. FCC Record, Volume 26, No. 19, Pages 14991 to 15893, October 24 - November 10, 2011, book, November 2011; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc133013/m1/77/: accessed February 19, 2018), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.