FCC Explains Applicability of IP CTS Rules That Survived Judicial Challenge


The FCC’s Consumer and Governmental Affairs Bureau (CGB) has issued a Public Notice in which it affirms the applicability of certain provisions of the FCC’s telecommunications relay services (TRS) rules in light of a June 2014 decision of the U.S. Court of Appeals for the District of Columbia Circuit which vacated in their entirety the FCC’s interim rules governing Internet Protocol Captioned Telephone Service (IP CTS) and vacated two of the FCC’s final rules governing IP CTS.  The two final IP CTS rules vacated by the court were the rule that prevented providers from receiving compensation for minutes of use generated by consumers using equipment that was provided at no charge or for less than $75; and the rule requiring IP CTS providers to ensure that their equipment and software applications have a default setting of captions off.  The FCC’s final rules requiring IP CTS providers to register and obtain self-certifications from certain users were upheld by the Court.  The CGB’s Public Notice explains the applicable registration and certification requirements for four groups of IP CTS users, who are defined based on when they enrolled with their IP CTS providers.  A summary of the registration and certification obligations for each class of IP CTS user is also included in the Appendix to the Public Notice.

For additional information, please contact Tony Veach.

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