NEW YORK. NY CHICAGO. IL STAMFORD. CT PARSIPPANY. NJ BRUSSELS. BELGIUM AFFILIATE OFFICES MUMBAI. INDIA KELLEY DRYE & WARREN LLP A LIMITED LIABILITY PARTNERSHIP WASHINGTON HARBOUR, SUITE 400 3050 K STREET, NW WASHINGTON, D.C. 20007-5108 (202) 342-8400 November 29,2011 By ECFS AND HAND DELIVERY Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Internet-Based TRS Certification Application of URrelay, Inc., CG Docket No.1 0-51 CONFIDENTIAL TREATMENT REQUESTED Dear Secretary Dortch: FACSIMILE (202) 342-8451 www.kelleydrye.com URrelay Inc. ("URrelay") hereby submits the accompanying Internet-based TRS Certification Application ofURrelay, Inc. ("Application"). URrelay submits a redacted public inspection copy ofthe Application through the Federal Communication Commission's Electronic Comment Filing System and seeks confidential treatment of the unredacted Application. URrelay respectfully requests that its Application be granted as soon as administratively feasible in order that its innovative services can be provided to the Deaf and Hard-of-Hearing Community as soon as possible. Should you have any questions regarding this application, please contact me at (202) 342- 8571 or Mr. William McClelland, COO, at (319) 533-5983. " Enclosure cc: Joel Gurin, Chief, Consumer & Governmental Affairs Bureau (via electronic delivery, [email protected]) Karen Peltz Strauss (via electronic delivery, [email protected]) Mark Stone (via electronic delivery, [email protected]) Greg Hlibok (via electronic delivery, [email protected]) Michael Jacobs (via electronic delivery, [email protected]) William Freedman (via electronic delivery, [email protected])
Transcript
NEW YORK. NY
CHICAGO. IL
STAMFORD. CT
PARSIPPANY. NJ
BRUSSELS. BELGIUM
AFFILIATE OFFICES
MUMBAI. INDIA
KELLEY DRYE & WARREN LLP
A LIMITED LIABILITY PARTNERSHIP
WASHINGTON HARBOUR, SUITE 400
3050 K STREET, NW
WASHINGTON, D.C. 20007-5108
(202) 342-8400
November 29,2011
By ECFS AND HAND DELIVERY
Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554
URrelay Inc. ("URrelay") hereby submits the accompanying Internet-based TRS Certification Application ofURrelay, Inc. ("Application"). URrelay submits a redacted public inspection copy ofthe Application through the Federal Communication Commission's Electronic Comment Filing System and seeks confidential treatment of the unredacted Application. URrelay respectfully requests that its Application be granted as soon as administratively feasible in order that its innovative services can be provided to the Deaf and Hard-of-Hearing Community as soon as possible.
Should you have any questions regarding this application, please contact me at (202) 342-8571 or Mr. William McClelland, COO, at (319) 533-5983. "
Enclosure cc: Joel Gurin, Chief, Consumer & Governmental Affairs Bureau (via electronic
A. URrelay Overview ................................................................................................. 2
II. COMPLIANCE WITH THE INTERNET-BASED TRS PROVIDER AND TRS PROGRAM CERTIFICATION REQUIREMENTS (47 C.F.R.§ 64.606) ...................... 4
A. The Forms ofInternet-Based TRS to be Provided (47 C.F.R. § 64.606(a)(2)(i» ...................................................................................................... 4
B. Applicant Will Meet All Non-Waived Mandatory Minimum Standards Applicable to Each Form ofTRS Offered (47 C.F.R. § 64.606(a)(2)(ii» ............. 5 1. Call Center Ownership (47 C.F.R. § 64.606(a)(2)(ii)(A)(1» .................... 5 2. Technology and Equipment Used to Support Call Center Functions
(47 C.F.R. § 64.606(a)(2)(ii)(A)(4» .......................................................... 6 3. Organizational Structure and the Executives and Officers (47
§ 64.604(c)(S)(iii)(N)) .............................................................................. 27 10. Procedures for Complaints (47 C.F.R. § 64.604(c)(6)) ........................... 27 11. Treatment of Customer Information (47 C.F.R. § 64.604(c)(7)) ............. 28
IV. EMERGENCY CALLING REQUIREMENTS (47 C.F.R. § 64.60S) ............................ 28
A. Emergency Call Requirements ............................................................................ 28 B. Registered Location Requirement. ....................................................................... 30
V. COMPLIANCE WITH WAIVED MANDITORY MINIMUM STANDARDS FOR THE PROVISION OF FEDERALLY-FUNDED VRS (47 C.F.R. § 64.606(a)(2)(ii)) ............................................................................................................... 31
A. Types of Calls ...................................................................................................... 31
VI. ADDITIONAL COMPLIANCE REQUIREMENTS ...................................................... 32
VII. SHOWING OF PUBLIC INTEREST ............................................................................. 32
VIII. CONCLUSION ................................................................................................................ 34
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Before the Federal Communications Commission
Washington, D.C. 20554
In the matter of Structure and Practices of the Video Relay Services Program
To: Chief
) ) ) ) )
CG Docket No. 10-51
Consumer and Governmental Affairs Bureau, TRS Certification Program
Internet-Based TRS Certification Application of URrelay, Inc.
URrelay, Inc. ("URrelay," or "Applicant"), pursuant to Section 64.606(a)(2) of the
Commission's rules, as amended, hereby submits its Application to the Federal Communications
Commission ("FCC" or "Commission") for certification that URrelay is eligible to receive
reimbursement directly from the federal Telecommunications Relay Service Fund (the "Fund" or
"TRS Fund") as a provider of Internet-Based Video Relay Service IP Relay services.
URrelay is an experienced relay and telecommunications services provider with
considerable familiarity offering communications services using the Internet. URrelay has both
the proven capability and the resources to provide high quality Video Relay Service ("VRS") and
Internet Protocol Relay Services that can benefit thousands of persons with speech or hearing
impairments. As described below, URrelay meets all of the standards required for certification
as a VRS and IP Relay Provider. By its Application, URrelay demonstrates that it has and
continues to meet or exceed the entirety of the Commission's Mandatory Minimum Standards
("MMS") for VRS and IP; specifically, Relay services pursuant to Sections 64.604, 64.605 and
64.606 as amended, and other applicable Commission regulations including but not limited to 47
C.F.R. §§ 64.611,64.613, and 52.34 ofthe Commission's rules and regulations, applicable
Commission orders, and certain waived MMS for the provision of Fund-compensable VRS and
IP Relay. URrelay respectfully requests that it be certified as a Fund eligible VRS and IP Relay
provider.
I. INTRODUCTION
A. URrelay Overview
URrelay, founded in 2006, is a privately held corporation with significant experience
providing telecommunications and relay services. The principals of the company include both
Bill McClelland and Benjamin Dudley, the creators and developers of internet based relay. Mr.
McClelland became the head ofMCl's relay division in 1997 and immediately started rebuilding
MCl's Telerelay Services in preparation for Year 2000. It was during this time that Mr.
McClelland first conceived of the notion of internet relay. From the inception of this original
idea in late 1999 that relay could be independent of PSTN lines and TTY machines, Mr.
McClelland developed and tested the technology and introduced IP Relay at Deaf Expo in 2000.
He testified before the FCC on behalf of both internet based text relay and video relay, and added
to the effort that saw these communication mediums be approved as reimbursable forms of
communication for the Deaf and Hard-of-Hearing Community. Ben Dudley joined Mel in 2002
and was the software architect that enabled the subsequent relay innovations and ideas to be put
into production and use.
The collaboration between Mr. McClelland, Mr. Dudley and a third key employee, Chris
Heidelbauer, a network and AIM bot specialist, produced many other firsts and innovations
including: Wireless relay in 2003; One Number (the first telephone number for a hearing person
to call a DHH person directly) in 2004; and AOL messaging, Instant messaging Yahoo and 1M
for the Sidekick and Blackberry. Mr. McClelland, Mr. Dudley and Mr. Heidelbauer form the
nucleus of the relay group at URrelay. Together, they have 32 years of unmatched experience
and accomplishments in relay and 78 years in telecommunications and software development,
2
including numerous patents and patents pending specifically in relay technology. Importantly,
Mr. McClelland created the first fraud controls in relay by developing IP based blocking for calls
originating outside the United States. URrelay has added numerous other fraud controls that
continue to block and shut down those both outside and inside the United States (including
"zombie computers") that would use the Relay system to harm American consumers and waste
TRS Fund resources.
More recent URrelay technological advances include iChat Video Relay, FaceTime
Video Relay, and Google Talk Video Relay. URrelay has the only proprietary automatic call
distribution ("ACD") and relay platform that has been built exclusively for relay, unique in the
industry. URrelay has provided service to five certified relay Providers. Such services include
technology platform, consoles, ACD, Internet-Based Telecommunications Relay Service
("iTRS") integration, Internet Text Relay processing and Video Relay Processing. URrelay is
housed in a fully compliant, 23,000 square foot facility which
This facility was
designed expressly for URrelay and the unique needs and requirements of a state of the art IP
Relay and Video Relay Center.
URrelay seeks to offer a complete range of services, including IP Relay and Video Relay
Service. URrelay has
The history, innovation, and resources ofURrelay have changed the world of
communications for our constituency and are perfectly aligned with the Commission's mandates
3
and objectives. Certification ofURrelay to provide VRS and IP Relay Services is both in the
public interest and consistent with the Commission's rules. URrelay fully commits to the
continued development of new and improved services to move ever closer to equal access.
Sections 64.604, 64.605 and 64.606 as amended, and other applicable Commission
regulations and rules, state that any entity desiring to provide VRS or IP Relay services and
desiring to receive compensation from the Interstate TRS Fund, shall submit documentation to
the FCC describing in narrative form matters designed to demonstrate its fitness and further that
it has and continues to meet or exceed the entirety of the Commission's Mandatory Minimum
Standards for VRS and IP Relay Service. URrelay hereby provides that information below.
II. COMPLIANCE WITH THE INTERNET -BASED TRS PROVIDER AND TRS PROGRAM CERTIFICATION REQUIREMENTS (47 C.F.R.§ 64.606)
In this section, URrelay demonstrates its compliance with the provisions of 47 C.F.R.
§ 64.606. 1
A. The Forms of Internet-Based TRS to be Provided (47 C.F.R. § 64.606( a )(2)(i))
URrelay is a common carrier seeking to become certified as a Fund eligible provider of
Internet-based Video Relay Services and IP Relay Services to the Public? URrelayoperates
twenty-four hours a day, seven days a week, three hundred sixty-five days per year, solely
utilizing its own call centers and staff.
URrelay's Internet-based VRS and IP Text Relay is available to any Deaf or Hard-of-
Hearing caller with a high-speed Internet connection and a videophone device, smart phone, PC
or Macintosh personal computer with webcam. Callers can use URrelay's system via a variety
1 47 C.F.R. § 64.606(a)(1) (state government providers) is inapplicable.
2 URrelay does not intend to TTY telecommunications relay services at this time
4
ofvideo-conferencing software available from URrelay and other VRS providers. URrelay's
VRS and IP Relay services are supported by a technologically-advanced, software-based,
proprietary, proven Relay platform, utilizing IP over broadband facilities, which URrelay has
deployed. Through this proprietary advanced Relay platform, URrelay provides VRS with
immediate interpreter access and a multitude of features supported by an established and
recognized communications platform that has been audited by the FCC's Inspector General
Office in early 2008. URrelay's Relay platform is unique in that it will support multiple call
types, including all Customer Premise Video Devices, Video Conferencing software SIP, IChat,
FaceTime, NexTalk, Google Talk, AIM and Flash.
URrelay's comprehensive Relay platform, functions and features provide state of the art
delivery of Relay, and it offers VRS and IP Text Relay consumers the choice of the best
application for their individual needs and lifestyle. URrelay offers IP-based relay through JAVA
based web access, AIM instant messaging and NexTalk software. The JA V A and AIM methods
of access are cross platform systems that enable consumers a wide choice of PC, MAC, Linux
and Mobile device access. The NexTalk software enables the user to have access to more forms
of communications than any other software or hardware. It is the only system that enables its
users to use VRS, IP-Text, TTY, FAX, email, instant messaging, direct video to h.323 systems,
text conference calls, interface with Braille systems and much more.
B. Applicant Will Meet All Non-Waived Mandatory Minimum Standards Applicable to Each Form ofTRS Offered (47 C.F.R. § 64.606(a)(2)(ii»
1. Call Center Ownership (47 C.F.R. § 64.606(a)(2)(ii)(A)(1)i
URrelay operates
inside a 23,000 square foot state ofthe art facility in Cedar Rapids, Iowa. The call center.
3 47 C.F.R. § 64.606(a)(2)(ii)(A)(2)-(3) are inapplicable.
5
This
facility is leased and a copy of the facility lease is attached as Confidential Exhibit A as required
under 47 C.F.R. § 64.606(a)(2)(ii)(A)(1). URrelay operates no other call centers. Photographs
of the interior and exterior of the call center are attached as Confidential Exhibit B.
2. Technology and Equipment Used to Support Call Center Functions (47 C.F.R. § 64.606(a)(2)(ii)(A)(4))
URrelay has designed and developed its own technology for Relay. It is the only Relay
system designed specifically for Internet-based Relay. URrelay has been providing this
technology to other Certified Relay Providers since 2006. Thus, the FCC has reviewed and
approved this technology as meeting the FCC's requirements when it has been used by certified
providers. In early 2008, one provider using URrelay technology underwent and passed a
compliance investigation by the FCC Office of Inspector General. In addition, American
Networks was certified in early 2009 to provide IP-Text using URrelay's ACD. More recently a
provider using URrelay's ACD, Convo Communications, LLC, was conditionally approved as a
newly certified provider ofVRS. A comprehensive description ofURrelay's technology is
included as Confidential Exhibit C.
URrelay designed, developed, wrote and owns a proprietary and fully Compliant Relay
platform and does not lease license technology from any Provider or non-Provider.4 The ACD is
on its own premises and is operated by URrelay's own people.
3. Organizational Structure and the Executives and Officers (47 C.F.R. § 64.606(a)(2)(ii)(B))
URrelay is a privately held corporation with a C filing status domiciled in Indiana and
registered in Iowa.
4 As a result, 47 C.F.R. §§ 64.606(a)(2)(ii)(A)(5)-(8) are inapplicable.
6
An organizational Chart is attached as Confidential Exhibit D.
4. Employee Information (47 C.F.R. § 64.606(a)(2)(ii)(C)-(D))
URrelay currently employs
categories:
Executives and Officers -_
Management Personnel -
Communications Assistants -
Technology -_
Video Phone Installers - ..
employees in the following
Employees involved in marketing and sponsorship activities -
URrelay affirmatively acknowledges its obligation to maintain, and does in fact maintain,
copies of employment agreements for all employees directly involved in TRS operations,
executives, and communications assistants, as well as a list of names of employees directly
involved in TRS operations. URrelay also maintains copies of employment agreements for
employees not directly involved in TRS operations. Further, URrelay covenants to retain copies
of all employment agreements for a minimum period of five years from the date of its
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Application, and is prepared to provide copies of employment agreements and a list of all
employees to the Commission or designee upon request.
C. Complaint Procedures (47 C.F.R. § 64.606(a)(2)(iii)-(v»
URrelay has implemented and maintains a complaint procedure for the timely resolution
of user complaints, including complaint processing procedures for CA' s and related training.
URrelay's documentation and escalation procedures are consistent with FCC requirements.
8
Customer feedback is seen as essential by URrelay in order to determine how best to
serve its customers. In our mission, the objective of moving ever closer to equal access can only
be accomplished through feedback from our constituency. This dedication to our customers is
maintained in both technological innovations, as well as in the employment and training of
Communication Assistants with superior skills and core beliefs.
URrelay maintains the required records and logs of complaints and responses. URrelay
further covenants that it will file annual compliance reports demonstrating continued compliance
with Commission rules and that it will cooperate with any complaint investigation. An executed
statement of compliance is attached as Exhibit E.
D. Site Visits (47 C.F.R. § 64.606(a)(3»
URrelay affirmatively acknowledges that pursuant to Section 64.606(a)(3), in order to
assess the merits of a certification application submitted by an Internet-based TRS provider, the
Commission may conduct one or more on-site visits of the applicant's premises, to which the
applicant must consent. Additionally, URrelay will have all documentation that the Commission
may request to demonstrate the truth of the representations made herein, and its compliance with
the Commission's requirements.
E. Substantive Changes (47 C.F.R. § 64.606(1)
URrelay affirmatively acknowledges it will have an obligation as a certificated VRS
provider, and covenants that it will notify the Commission of substantive changes in its TRS
programs, services, and features within 60 days of when such changes occur, and that it will
certify that it continues to meet federal minimum standards after implementing the substantive
change. URrelay acknowledges it will also have a responsibility to inform the Commission of
9
substantive changes in the provision of its VRS and its ongoing compliance with federal
minimum standards after implementing the substantive change. URrelay covenants that it will
comply with these responsibilities as set forth in the Commission's rules and any applicable
underlying policies.
As a certified TRS provider, URrelay recognizes that the entirety of its operations is
subject to appropriate Commission oversight. Because ofthe dynamic nature of any enterprise,
URrelay readily acknowledges its obligation to keep the Commission timely informed of any
changes to the Company's services and the effect that such changes may have on ongoing
compliance with other MMS. URrelay covenants that it will promptly inform the Commission
of any substantive change in service features and operations, of the impact of those changes, and
certify ongoing compliance with the MMS, in whatever form or process as the Commission may
establish pursuant to Section 64.606(f)(2).
F. Annual Reporting (47 C.F.R. § 64.606(g)
URrelay affirmatively acknowledges that it will have an obligation as a certificated TRS
provider to, and will, file the required annual reports with the Commission demonstrating that it
is in compliance with 47 C.F.R. § 64.604. These reports will update the information required in
47 C.F.R. § 64.606(a)(2) and include updated documentation and a summary of the updates, or
certify that there are no changes to the information and documentation submitted with the
application for certification, application for renewal of certification, or the most recent annual
report. URrelay's certification of compliance is attached as Exhibit F.
G. Unauthorized Service Interruptions (47 C.F.R. § 64.606(h)
URrelay affirmatively acknowledges that it will have an obligation as a certificated VRS
provider to "provide Internet-based TRS without unauthorized voluntary service interruptions."
In the event that URrelay must interrupt service for a period of 30 minutes or more in duration, it
10
will submit a written request to the Commission's Consumer and Governmental Affairs Bureau
("CGB") at least 60 days prior to any planned service interruption, with the detailed information
required pursuant to 47 C.F.R. §§ 64.606(h)(2)(i), (ii), and (iii).
Further, in the event of unforeseen service interruptions due to circumstances beyond its
control, or if a voluntary service interruption is less than 30 minutes in duration, URrelay will
submit a written notification to CGB within two business days of the commencement of the
service interruption, with an explanation of when and how URrelay has restored service or its
plan to do so. In the event URrelay has not restored service at the time such report is filed, the
Company will submit a second report within two business days of the restoration of service with
an explanation of when and how it has restored service. URrelay will also provide notification
of service outages to consumers on an accessible website, and that notification of service status
will be updated in a timely manner.
III. COMPLIANCE WITH NON-WAIVED MANDATORY MINIMUM STANDARDS (47 C.F.R. § 64.604)
Section 64.604 of the FCC's rules, as amended, establishes operational, technical, and
functional MMS governing the provision ofVRS. As set forth below, URrelay maintains that it
meets or exceeds the entirety of the Commission's MMS for the provision of Fund compensable
relay services and merits Commission certification to draw compensation from the federal TRS
Fund.
A. Operational Standards (47 C.F.R. § 64.604(a»
1. Communication Assistants (47 CF.R. § 64. 604(a) (l)(i)-(iv))
Qualified CAs are essential to the successful provision of both IP relay and VRS and
URrelay's ability to meet its consumers' specialized and varied communications needs. To
qualify for employment, CAs must first meet URrelay's minimum qualifications for employment
11
and certain skills, as well as all of the FCC's requirements. The CAs also must demonstrate
complete understanding ofURrelay's operating standards before the CA can begin working.
12
13
2. CA Call Handling (47 C.F.R. § 64.604(a)(J)(v)-(viii))
URrelay has adopted the FCC standard requiring CAs answering and placing a VRS call
to stay with the call for a minimum often minutes. Once URrelay begins providing STS, it will
require CAs on an STS call to stay with the call for at least fifteen minutes. As a general matter,
CA's are instructed to remain on each call until the call is terminated, even if the call extends
beyond the CA' s shift.
3. Confidentiality and Conversation Content (47 C.F.R. § 64.604(a)(2))
URrelay has adopted strict privacy standards, not only regarding communications
content, but also with regard to consumer data.
14
-URrelay CAs are generally bound to the requirement that they not intentionally alter a
relayed conversation and, unless inconsistent with the law, they must relay all conversations
verbatim unless specifically requested by the user. They comply with the standards of 47 C.P.R.
§ 64.604(a)(2)(ii) through compliance with national interpreter association codes of professional
15
conduct which have been adopted by URrelay.
4. Call Types and Functions (47 C.F.R. § 64.604(a)(3))
URrelay's CAs will not be permitted to refuse a single or sequential call or limit the
length of a call using relay services.
16
6 The Commission has temporarily waived certain requirements contained in 47 C.F.R. § 64.604(a)(3). See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities (Waiver Extension Order),26 FCC Red. 9449 (June 30, 2011). Nonetheless, as outlined in this section, URrelay already meets those waived requirements. With respect to all waived requirements, URrelay will file the required status
17
5. STS Called Numbers (47 C.F.R. § 64.604(a)(5))
URrelay's management
team participated in the setup and training of STS Service for the state programs in California,
Wisconsin, Massachusetts and Florida. URrelay understands the needs of the STS users and the
need for specific outreach in this specialized communications need.
VRS CAs have been trained and notified of the requirements in 47 C.F.R. § 64.604(a)(6)
and are instructed to disconnect any VRS call in which the caller or called party enables a
privacy screen (or similar feature) for more than five minutes or is unresponsive or unengaged
for more than five minutes (with the exception of a 911 call or when the call is legitimately
placed on hold by either the caller or called party). CAs are instructed to announce the intent to
terminate the call to both parties prior to doing so and can reverse this decision to terminate the
call if one of the parties indicates that the call should continue.
7. International Calls (47 C.F.R. § 64.604(a)(7))
report on or before April 16, 2012, updating the Commission on the progress made in complying with these waived requirements.
18
B. Technical Standards (47 C.F.R. § 64.604(b»
1. ASCII and Baudot (47 C.F.R. § 64.604(b)(1))
URrelay's IP Relay supports text over Internet Protocol.
2. Speed of Answer (47 C.F.R. § 64.604(b)(2))
URrelay has in the past and will continue to meet all speed of answer requirements.
7 The erlang (symbol E[l]) is a dimensionless unit that is used in telephony as a statistical measure of offered load or carried load on service-providing elements, such as telephone circuits, or telephone switching equipment and call center staffing.
URrelay acknowledges the complaint procedures contained in 47 C.F.R. § 64.604(c)(6)
and it will comply with all requirements contained in that provision.
27
11. Treatment of Customer Information (47 C.F.R. § 64.604(c)(7))
In the event that URrelay must transfer a customer profile to a new TRS or VRS vendor
or provider, URrelay will transfer that data to the new vendor in a useable format at least 60 days
prior to URrelay's last day of service to that customer. URrelay will not use that data for any
purpose other than to connect the TRS user with the called parties requested by that user and
URrelay will not sell, distribute, share or reveal this data in any other way, unless compelled to
do so by lawful order.
IV. EMERGENCY CALLING REQUIREMENTS (47 C.F.R. § 64.605)
A. Emergency Call Requirements
URrelay's platform has been designed to comply with the applicable requirements for
emergency call handling, and URrelay is currently compliant, as demonstrated in Confidential
Exhibit J. URrelay provides the required emergency call service for internet-based providers and
does not propose to provide TTY -based TRS.
28
29
URrelay will comply with the requirements of 47 C.F.R. § 64.605(a)(2)(iv).
B. Registered Location Requirement
30
V. COMPLIANCE WITH WAIVED MANDITORY MINIMUM STANDARDS FOR THE PROVISION OF FEDERALLY-FUNDED VRS (47 C.F.R. § 64.606(a)(2)(ii))
URrelay will comply with certain mandatory minimum standards that have been waived
for VRS subscribers, as follows:
A. Types of Calls
URrelay has been a long time innovator of technology and continues to close the gap of
functional equivalency.
31
VI. ADDITIONAL COMPLIANCE REQUIREMENTS.
In addition to the foregoing, Applicant affirmatively acknowledges that it has and will
continue to comply with all applicable regulations associated with the provision ofVRS
including but not limited to, Section 64.611, Internet-based TRS registration, and 64.613,
Numbering directory for Internet-based TRS users, as amended, and applicable Commission
orders and policies, as may be amended from time to time.
VII. SHOWING OF PUBLIC INTEREST.
Granting this application is in the public interest and will benefit the public throughout
the U.S. URrelay's history, experience and new innovations in the creation of internet relay have
changed the world of communication for the Deaf and Hard-of-Hearing citizens of the United
States. URrelay is dedicated to continuing to bring innovation and improvements to
communications for the Deaf and Hard-of-Hearing if it is certified as a relay provider.
Contractual obligations had precluded URrelay from submitting its own application previously.
Those obligations, however, no longer exist.
The challenge for relay providers and being addressed by URrelay is, not only to
maintain the pace of innovation for the Deaf and Hard-of-Hearing citizens, but also to work
toward fully equal access and equivalency for the community. Video technology continues to
evolve at a rapid pace with access to affordable high speed data increasing, and the constraints of
communication through land-lines receding. With more than twenty five percent of households
in the United States now having no land-lines into their home, the continuing development of
32
video technology for the Deaf and Hard of Hearing community is vital to equal access.8 URrelay
has the experience, the expertise and the motivation to develop the new technology that will
enable communications for the Deaf and Hard of Hearing Community to keep up with the
changing landscape of communications.
The granting of the Application and URrelay's provision ofIP relay and VRS services
will be of benefit to both the public and Deaf consumers. URrelay has demonstrated competency
in relay and its founders have a long history of innovation in relay. The quality and integrity of
its facility, the ability of the platform to be flexible and incorporate new technological
innovations rapidly with superior video quality, and the experience and competency of its staff,
all demonstrate the benefit that the community has and will continue to have by this approval.
URrelay believes that cost containment and efficient use of resources is a mandate for our
country. While technology costs have declined, the cost oflabor, benefits, energy, and other
human costs continue to increase. Part and parcel to the development of technological
innovation is the attention that must be placed upon the efficiency of CAs in both IP relay and
VRS. This continued attention to efficiency will help to control costs and allow the TRS fund to
provide more service at lower costs. The public in general and the Deaf community in particular
will continue to expand their use of media and the frequency of communication. The days of
video phone attached to TV s will end, and mobile communication using the latest technology
will expand. URrelay believes that the same communication options that the Deaf community
and general public use for communication, FaceTime, for example, should be equally available
8 In the Matter of Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, Annual Report and Analysis of Competitive Market Conditions With Respect to Mobile Wireless, Including Commercial Mobile Services, Fifteenth Report, WT Docket No.1 0-133, ~ 365 (June 27, 2011).
33
for Deaf to Hearing as it is from Deaf to Deaf or Hearing to Hearing. This is equivalency, what
is available for point to point communication is equally available for relay communication.
URrelay's founders recognized the limited access to TTY's in public places in the 1990s.
Their response was to create relay communications that needed only a web browser. They next
recognized that equal access meant dialing directly to a phone number that was the same as
anyone else's phone number, and not be dependent on 711. They created OneNumber, the first
system of direct dial numbers. They recognized that Instant Messaging was a new and
wonderful form of communication that could greatly increase the mobility of Deaf citizens, and
created Instant Messaging Relay. Today the history of imagining, designing and producing new
technological advances continues. All new mobile technologies, as well as all browser based
technologies, are dependent upon cellular networks and broadband access. Everything that
URrelay has created has increased demand for broadband services across the country, and
utilized that increase for equivalency and equal access. That demand will not decrease and these
technologies will continue to contribute to the deployment and use of broadband across the
United States.
VIII. CONCLUSION
The Commission's Report and Order and Order on Reconsideration establishes a
process whereby a VRS and IP relay provider may seek Commission certification of its
compliance with applicable minimum mandatory standards. This certification process enables
companies like URrelay, to draw from the federal TRS fund for the provision of compensable
TRS.
URrelay, from its inception, has delivered a comprehensive IP relay and VRS service.
URrelay conceived of, created and deployed the first platform built exclusively for relay, and
remains the leader of relay innovation and technology. The first IP relay call was answered on
34
April 15th, 2006 on that URrelay platform, by an URrelay CA in an URrelay facility. From the
beginning to today, URrelay has maintained a continuous presence in relay, serving the
technological needs of Relay Providers. URrelay remains one of the few, if not the only,
company that processes IP relay calls within the United States.
URrelay has ensured ongoing compliance with the Commission's Mandatory Minimum
Standards, currently waived Standards, and Orders, through a plan that incorporates
complementary tools, adequate procedures and remedies. URrelay has implemented a process
for providing consumers with information regarding complaint procedures, and maintains a fully
staffed customer service center and complaint logging capabilities, consistent with existing
complaint logging requirements.
URrelay has demonstrated that its services do not differ from, or in any way violate, the
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