FCC Record, Volume 26, No. 19, Pages 14991 to 15893, October 24 - November 10, 2011 Page: 15,057
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rCUglam ( r Iul llmai atiun3 ('LinmuI cmian.1lAllV l ii--l' "m
ltp:i Cont oanv lher.sna~p rs.con, where "snapvrs" is the parent domain and "convoanywhere" is the
14. In the VRS Ptrachtices R&O, the Commission required, as codified in section
64.604(c)(5)(iii)(N)(1)(i), that only eligible entities under the Commission's rules will be eligible to
provide VRS and hold themselves out as providers of VRS to the general public.2 The Commission
explained that, "[t]o ensure that this is achieved, we further require that VRS service be offered under the
name by which the provider became certified and in a manner that clearly identifies that provider of the
service."'; In other words, compliance with the branding requirements of section
64.604(c)(5)(iii)(N)(1)(ii) may help to establish compliance with section 64.604(c)(5)(iii)(N)(1)(i). Based
on the record, we conclude that Convo modified its branding and messaging to users, on its web pages
and in correspondence to users, in a manner that clearly demonstrates that it is currently a subcontractor to
Snap, an eligible provider. We find that the myriad changes made by Convo to its service structure and
branding by September 1, 2011 constitute timely and substantial compliance with section
64.604(c)(5)(iii)(N)(l)(i) and the branding requirements of section 64.604(c)(5)(iii)(N)(1)(ii) for purposes
of continuing to provide subcontracted VRS for the duration of the stay of effectiveness of section
64.604(c)(5)(iii)(N)(1)(iii), during which the subcontracting of core VRS functions is still permitted.
15. We also find that waiving section 64.604(c5)(iii)(N)()(1)(i) and the branding requirements
of section 64.604(c)(5)(iii)(N)(I)(ii) will not undermine the purposes of the rules adopted in the VRS
Practices R&O. Convo asserts in its waiver request that it does not offer VRS under any name, brand, or
sub-brand other than "Convo." " As previously noted, in the VRS Practices R&O. the Commission
adopted section 64.604(c)(5)(iii)(N)(1)(i-ii) in order to reduce fraud, establish better oversight of the VRS
program, and address unauthorized revenue sharing arrangements." The adoption of such rules was due
in substantial part to illicit activities by individuals associated with or employed by VRS providers not
eligible for compensation from the Fund, and the difficulties experienced by the Commission and other
investigatory authorities in "identifying who these entities are or what services they provide."'" Because
Convo's branding and messaging to users clearly identifies it as a subcontractor to Snap, and because
Convo offers its subcontracted service only under one brand name, we find that Convo's service structure
and branding, for the duration of the stay of effectiveness of section 64.604(c)(5)(iii)(N)(1)(iii), do not
present many of the oversight and provider identification issues that the rules adopted in the VRS
Practices R&O are designed to address, and thus, do not undermine the purposes of those rules.
16. We also conclude that, subject to an additional limited waiver, as discussed below, Convo
timely came into compliance with the URL provisions of section 64.604(c)(5)(iii)(N)(1)(ii). As discussed
above, there is only one product - Anywhere -- through which a user of Convo subcontracted VRS may
make a VRS call using a URL.57 Previously, third-party videophone users also accessed Convo's
subcontracted VRS through a second URL. convorelay.tv. However, the record shows that as of
SSee id at 5_
SSee VRS Practices R& O, 26 FCC' Red at 5574, para. 57: ee al/ao 47 C.F.R. 64.604(c)()(5)(iii)(N)(1)(i).
See VRS Prac tic es R&O, 26 i CC Red at 5574, para. 57; :ee also 47 ('.F.R. 64.604(c)(5)(ii)(N)(1)(i).
Se Se C'onvo Waiver Request at 15.
SSee VRS Practices R&(O, 26 F'(C Red at 5574, para. 57.
' i. at 5573, para. 55.
See 13, supra.
Fedral Comu~ni n mi n
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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/m1/81/: accessed April 24, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.