FCC Record, Volume 26, No. 19, Pages 14991 to 15893, October 24 - November 10, 2011 Page: 15,058
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September 9, 2011, convorelay.tv was no longer in service; users could only access a CA via a ten-digit
number." In the Second Convo Waiver Amendment, Convo stated that, for the first ten days after
convorelay.tv was migrated to the Snap ACD, when a user called convorelay.tv, the user was forwarded
to a screen directing the user to call the ten-digit number to place a VRS call, and was then connected
directly to a CA after receiving that message.5"
17. We find good cause to grant Convo a waiver of the URL provisions of section
64.604(c)(5)(iii)(N)(1)(ii) from June 1, 2011 until September 9, 2011. Though Convo modified its
service structure by September 1, Convo did not complete that process until immediately before that
date." We find that the ten day transition period, during which former convorelay.tv users were
connected to a CA after being notified that, going forward, they would need to utilize a ten-digit number
in order to place a Convo subcontracted VRS call using a third-party videophone, was reasonable to avoid
user confusion and to avert potential disruption of service, and was of minimal duration. Under such
circumstances, we find that waiver of this rule until September 9, 2011 does not undermine the purposes
of the URL provisions of section 64.604(c)(5)(iii)(N)(I)(ii).' The Commission adopted that rule because
"[c]onsumers have been hindered in making informed choices when selecting their VRS companies
because of the complex branding and commercial relationships that have existed between [ineligible
providers] and eligible providers.'"" In this case, the brief transition period, during which convorelay.tv,
a second URL, was still active, was designed to prevent consumer confusion, and associated messaging to
users already identified Snap as the eligible provider.
18. To the extent Convo also requests waiver of section 64.604(c)(5)(iii)(N)(1)(iii) of the
Commission's rules, which the Commission has stayed until November 15, 201 I, ' we dismiss its request
as moot. Finally, we grant Convo's withdrawal request, and thus will not consider the portion of the
Convo Waiver Request pertaining to section 64.604(a)(7).M
IV. ORDERING CLAUSES
19. ACCORDINGLY, IT IS ORDERED that, pursuant to sections 1, 2, 4 and 225 of the
Communications Act of 1934, as amended, 47 U.S.C. 151, 152, 154 and 225, and section 1.3 of the
Commission's rules, 47 C.F.R. 1.3, and pursuant to authority delegated in sections 0.141 and 0.361 of
the Commission's rules, 47 C.F.R. 0.141 and 0.361, the request for temporary waiver filed by Convo
Communications, LLC of section 64.604(c)(5)(iii)(N)( )(i-ii) of the Commission's rules IS GRANTED to
the extent discussed above.
SX See Convo Waiver Supplement at 26.
i See Second Convo Waiver Amendment, Attach. at 20.
0 See Second Convo Wai er Amendment at 2.
(1 Because we grant Convo's waiver until September 9, 201 1, we need not address Convo's arguments that the use
of different URLs for the Anywhere and videophone products are compliant with the URL provisions of section
64.604(c)(5)(iii)(N)(1)(ii). See Convo Second Waiver Amendment at 2-4.
62 VRS Practices R&O. 26 FCC Red at 5574, para. 57
' See note 2, iptra.
See 9, supra.
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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/m1/82/: accessed January 20, 2018), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.