FCC Record, Volume 26, No. 19, Pages 14991 to 15893, October 24 - November 10, 2011 Page: 15,056
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waiver of such rules must show, among other things, its ability to comply with the relevant requirements
within three months after the rules became effective, i.e., September 1, 201 I.- We find that Convo
timely sought a waiver of section 64.604(c)(5)(iii)(N)(1)(i-ii) for the period from June 1, 2011 to
September 1, 2011, made all of the particular waiver showings required in the VRS Practices R& O,42 and
substantially came into compliance with section 64.604(c)(5)(iii)(N)(1)(i-ii) by September 1, 2011.4- We
therefore find that Convo has demonstrated good cause to grant its requested waivers. The Commission
specifically contemplated considering requests for a temporary waiver of the requirements adopted in the
VRS Practices R&O, in order to give entities an opportunity to continue to provide VRS as a
subcontractor with an eligible provider until such time as they may obtain, if merited, certification under
the procedures ultimately adopted in the iTRS Certification Order.44 Combined with the stay of
effectiveness of section 64.604(c)(5)(iii)(N)(I)(iii), these waivers accomplish precisely that objective by
allowing Convo - the fifth-largest VRS provider (as measured by the number of minutes per month of
VRS calls relayed) with "thousands" of deaf and hard of hearing customers - to continue providing
service pending certification as an eligible provider.t
13. In conjunction with its waiver showing, Convo also asserted that it has complied with all of
the requirements adopted in the VRS Practices R&O by their June 1 effective date, except for those
subject to the instant waiver request. As for its compliance with section 64.604(c)(5)(iii)(N)(1)(i) and the
branding provisions of section 64.604(c)(5)(iii)(N)(1)(ii), Convo asserts that, by September 1, 201 1, it
had rebranded its VRS logo to a "Subcontractor Logo" which first exhibits the name and logo of an
eligible VRS provider, Snap, and then presents the Convo name, which is clearly identified as "a
subcontractor of Snap! VRS."'" The top of Convo's VRS homepage, which is found at the URL
http://snapvrs.convorelav.com/vrs.html,7 displays the Subcontractor Logo prominently.t In addition, for
all of its products, Convo states that it has sent its users an email explaining that Convo has become a
subcontractor to Snap, and no longer independently offers VRS."4 According to Convo, except for calls
from its "Anywhere" product, none of the Convo products utilizes a URL in order to connect to a CA for
purposes of placing a VRS call.' Furthermore, Anywhere is accessed using the URL
41 See VRS Practices R&O. 26 FCC Rcd at 5575-76, para. 63.
4 See 6-8, supra.
04 As discussed m/fru, although Convo was not in compliance with the URL provisions of section
64.604(c)(5)(iii)(N)(1)(ii) on September 1, 2011, we find good cause to grant a waiver of that provision until
September 9, 201 1. See 17, infra.
See VRS Practces s R&O, 26 FCC Red at 5575, para. 62.
See 1 5, supra We make this determination without prejudice to the merits of the certification application that
Convo files once all of the rules adopted in the iTRS Ce'rtlication Order become effective.
U See generally Cono Waiver Supplement. As demonstrated therein, Convo also took a number of steps to list
Snap first on webpages and utilize the Snap logo.
" No VRS call actually can be routed directly from this home page. Instead, it contains links to reach a wcbsite
specific to each VRS product, with each such website hearing the Subcontractor Logo. See Convo Waicer
Supplement at 1-3. Moreover, as discussed below. except for calls from its "'Anywhere" product, none of the Convo
products utilizes a URL in order to connect to a CA for purposes of placing a VRS call.
, See Convo Waiver Supplement at 3.
SSee. e g. ul. at 5.
a See. e g, ui at I.
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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/m1/80/: accessed March 29, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.