Ed’s Telecom Alert

Folks,

We have a tough issue!   I am very curious what you all think about that.

Remember the Number Order from the FCC indicate that we have to choose a VRS provider as a default VRS provider so we can get the 10-digit phone number (henceforth called "TN")?  Okay, now the order seems to say that we can later choose different VRS provider and port the same TN to the new "deafault" VRS provider.  What this means when we change to a different VRS provider, we keep the same TN.  Seems easy enough. 

Now does that mean the features of that VP VRS users enjoy; will these features stay the same when transferring to a new VRS provider with the same video phone? 

No says a couple of the VRS providers.  Not possible due to proprietary and/or technical issues.  One added that it does not make business sense and removes the incentive for VRS providers who have VP products.  The following links indicate that if features are transferred to another VRS provider, that means they are giving up investments already made into developing the VP.   In other words, one link indicate that is "stealing" from original VRS Provider’s idea without having to do the work of developing the features of VP.  

The following links are Sorenson’s Ex-Parte and SnapVRS’s Presentation.   These links will basically show that they worked hard to develop their VP, and the features of the VP, spending thousands or millions of dollars creating ideal VP, and all that…then to let other VRS provider have the features of VP?  Let other VRS provider use other company’s VP and its features, and make money out of it without doing the R&D themselves?     

SorensonVRS said will provide "vanilla" type with no features and will not open its "source" as they contain proprietary information.  SnapVRS is saying not possible to do that at all due to technical difficulties.  

Sorenson’s Ex Parte Meeting

SnapVRS Presentation

The following link were from comments were from CSDVRS, GoAmerica, Viable, and SnapVRS. 

CSDVRS GoAmerica Viable SnapVRS Comments

Above link is basically saying that it is very difficult to follow the instructions of the FCC where it says when a deaf/hoh changes from original VRS provider that distributes VP to a new default VRS provider; the link sez that new fault VRS provider does not have the capacity to collect routing info of the deaf/hoh user.  Instead, suggest that original VRS provider continue to provide routing info (in other words, doing the work for the new default VRS provider).  

The following link is from CSDVRS that challenges SorensonVRS’s comments and CSDVRS maintains the only solution is to require device distributor (VRS provider who distributes VP) maintain updating the routing information.   

CSDVRS Comments

The following is from GoAmerica.  GoAmerica also challenges SorensonVRS’s comments and maintains that since SorensonVRS controls 90% of the video phones in USA so the FCC should allow device distributor (i.e. SorensonVRS, or OJO, or Viable or CSDVRS or SnapVRS) must update the routing information to the central database and not the new default VRS provider. 

GoAmerica Comments 

What all this could mean is that the features of VP from the original VRS providers (i.e. VP-200 belongs to SorensonVRS, OJO belongs to SnapVRS, MVP belongs to GoAmerica, and so on) will not be "transferred" to new default VRS provider.  

Boy, this is a sticky one for sure; one of those damned if you do and damned if you don’t.  

I understand SorensonVRS’s and SnapVRS’s viewpoints.  Does that each VRS providers need to develop their own VP, and if we change default VRS provider to another one, does that mean we give up the original VP and take on the new VP?   If so, half of VRS providers will be out of business, unless, of course, other non-device VRS providers contracts with VRS providers with VP.  

I don’t know what the answer is…really don’t.   If the FCC forces the transfer of all features, then VRS providers who researched and developed their VP may lose the incentive to do further R&D and may give up VRS altogether?  

Perhaps follow the standard as developed by VoIP?   With each VoIP provider, you will get unique equipment solely for the VoIP provider that provided that.  Change to a different VoIP provider, you give up the original one, and use the new VoIP equipment with the new VoIP provider.   We want functional equivalence; this is functional equivalence.   Remember VoIP users still keep their phone numbers, but just change to new VoIP provider and the equipment.   Should VRS Industry follow that standard?  Let me know what you all think?

 eyes open & thumbs up,

Ed

All..

Now heard-tell that SorensonVRS fired several Video Interpreters because they performed unethical or illegal action of racking up inappropriate VRS minutes.  Happened in SorensonVRS Austin center.  I understood that SorensonVRS paid back all the VRS minutes that had been accumulated by nefarious video interpreters and paid back to the federal fund.  I understood that SorensonVRS did that without the FCC jumping on them. 

Also heard-tell that Viable closed one Austin Interpreting Center that they had contract with cuz the center was doing unethical or illegal actions of racking up inappropriate VRS Minutes.  Understood that Viable chose not to submit VRS minutes the last two months as result of that.   Viable did that without the FCC intervention.  A group of interpreters, not all of them, were responsible for that;.  Viable had tear up the contract with the Center because the CEO of the Austin Center was the one that encouraged racking up minutes.   WOW!   

If these are true, then I applaud both SorensonVRS and Viable to take the actions that they did.  

Truth be told, VRS providers should police themselves and ensure that ALL VRS minutes were done by deaf/hoh which met the FCC rules of "unnecessary VRS minutes".   I don’t see that happening in a few of them.  

Disclaimer:  These stories I know happened, but I do not have the gritty details.  

eyes open & thumbs up,

Ed 

All.

The following link is asking for comments on SorensonVRS’s request for limited waiver on proxy numbers.  SorensonVRS is asking the FCC to allow one year of using proxy numbers after the 10 digit real phone have been distributed (presumably Jan 1, 2009).   First wave of comments already passed, the second "Reply Comments" due tomorrow (Oct 21). 

FCC PN on Limited Waiver Request

 What do you think, folks?  Will granting the waiver by the FCC help lessen the confusion?  Or will it make it worse?  

I believe these proxy numbers will not be able to cross to other VP that are not the same type; that is, vp 200 to OJO or VPAD.  I believe SorensonVRS wants to be able to give real 10 digit ph numbers plus this proxy numbers.  

It appears that SorensonVRS is trying to phase out the proxy number over one year period instead of abrupt stopping proxy number on Jan 1, 2009.   It also makes "business" sense for SorensonVRS as it will help hold onto to people who already have vp-200 and that in time they will help them change over to ten digit phone numbers.  

The following are the first wave of comments and all were opposed to the waiver request. 

Hamilton is opposed to this as sez the following link

Hamilton Oppostion

GoAmerica Opposition from GoAmerica (HOVRS)

Nat’l Orgs Opposition - this is a combined national and state organizations; TDI, NAD, DHHCAN (Hard of Hearing Advocacy), HLLA, and CCASHDHH (Calif). 

Geez, lot of oppositions to Sorenson’s request for limited waiver.   

eyes open & thumbs up,

Ed B