FCC Record, Volume 26, No. 19, Pages 14991 to 15893, October 24 - November 10, 2011 Page: 15,054
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with very few requests for reimbursement from the Fund being denied by the Fund administrator.
Nevertheless, in conjunction with moving its call traffic to Snap's automatic call distribution (ACD)
platform by September 1, 201 1, Convo pledges to brand its service "under a Snap logo that includes
reference to Convo as a subcontractor of Snap." 2 Convo submits a series of web screenshots
demonstrating the changes made to its branding, and explaining other actions it took to comply with
8. As general support for its requested waivers, Convo argues that granting the waivers is in
the public interest, and will not undermine the purposes of the rules adopted in the VRS Practices R&O.4
Convo states that the rules adopted in the VRS Practices R&O are intended to substantially reduce and
ultimately eliminate fraud and abuse, a goal that it shares given its own emphasis on implementing
internal controls to assure compliance and its lack of any history of fraud or abuse.25 Convo details how it
would come into compliance with all of the new requirements adopted in the VRS Practices R&O once
effective (except for those for which it requests temporary waiver)26 and has provided the requisite
documentation to support its request and to demonstrate its compliance with other regulations applicable
to VRS.'7 Moreover, it reiterates that grant of the waivers is in the public interest because it would
prevent Convo from having to abandon service to its "thousands of VRS customers."2"
9. Although Convo originally requested waiver of section 64.604(a)(7) of the Commission's
rules,29 which generally prohibits compensation from the Fund for VRS calls originating from an
international Internet Protocol address, Convo subsequently sought to withdraw such request, and
asserted that it was in compliance with that rule prior to its effective date of June 1, 2011.30
21 Convo maintains that the Fund administrator denies less than 0.05% of the minutes it requests for reimbursement.
See Convo Waiver Request at 19.
22 Second Convo Waiver Amendment at 2.
23 See Second Convo Waiver Amendment; Convo Waiver Supplement. See also 1i 13, infra. While it maintains that
separate URLs for its Anywhere and videophone products are a "technological necessity" fbr such products utilizing
different VRS interface technologies, and thus should be deemed in compliance with the URL provisions of section
64.604(c)(5)(iii)(N)( I )(ii) of the Commission's rules, Convo nevertheless also requests waiver of this portion of
section 64.604(c)(5)(iti)(N)(1)(ii) until October 1, 201 1, in the event the Commission rejects its interpretation. See
Second Convo Waiver Amendment at 2-4.
24 Convo Waiver Request at 16-17; see VRS Pi acts R es R&O. 26 FCC Red at 5575, para. 62.
2S Convo Waiver Request at 19.
26 See /i at 20-32. See abo First ('onvo Waiver Amendment; Second Convo Waiver Amendmndment.
,- See Convo Waiver Request. Appendix. While not specifically required by the i'RS Practices R&O. Convo has
submitted information to support its assertion that it has complied with the VRS regulations in effect prior to the
effectiveness of the VRS Pract'ces R&O See Convo Wai er Request at 17. 32-43.
" Convo Waiver Request at 19
- 47 C.F.R. 64.604(a)(7).
* See Second Convo Waiver Amendment at 4.
Federal Communicatinns Cn mmission
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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/m1/78/: accessed October 19, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.