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Purple Petition On Inbound And Outbound IP CTS Calls

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Released: August 27, 2013


Federal Communications Commission

News Media Information 202 / 418-0500


445 12th St., S.W.

TTY: 1-888-835-5322

Washington, D.C. 20554

DA 13-1814

Released: August 27, 2013




CG Docket Nos. 10-51 & 03-123

Comments: (15 days after date of publication in the Federal Register)

Reply Comments: (25 days after date of publication in the Federal Register)

On July 8, 2013, Purple Communications, Inc. (Purple) filed a petition (Purple Petition)
requesting expedited clarification or partial reconsideration, or, alternatively, a waiver of one aspect of the
VRS Reform Order regarding the use of Internet Protocol Captioned Telephone Service (IP CTS) through
web or wireless technologies.1 Specifically, Purple requests that the Commission clarify that footnote 122
of the VRS Reform Order, stating that "calls that are completed using a technology that does not provide
both inbound and outbound functionality are not compensable from the TRS Fund," does not apply when
users access IP CTS through web and wireless services.2 Purple asserts that this footnote, if left intact,
would force Purple and other IP CTS providers to cease the provision of IP CTS using web and wireless
applications because "there is no technology currently available that allows inbound IP CTS over web or
wireless technologies to be captioned without some intermediary step."3
Pursuant to Sections 1.429 of the Commission's rules, 47 C.F.R. 1.429, we invite interested
parties to file comments on the Purple Petition and to file reply comments on or before the dates specified
above. All filings must reference

CG Docket Nos. 10-51 & 03-123

. Comments may be filed using the
Commission's Electronic Comment Filing System (ECFS) or by filing paper copies. See Electronic
Filing of Documents in Rulemaking Proceedings. Comments may be filed electronically using the
Internet by accessing the ECFS: Filers should follow the instructions
provided on the website for submitting comments. In completing the transmittal screen, commenters
should include their full name, U.S. Postal Service mailing address, and

CG Docket Nos. 10-51 & 03-

1 Purple Communications, Inc., Petition of Purple Communications, Inc. for Expedited Clarification or Partial
Reconsideration or, Alternatively, a Waiver
, CG Docket Nos. 03-123 and 10-51 (filed July 8, 2013) (Purple
2 Purple Petition at 1.
3 Id. at 1-2.

Parties who choose to file by paper must file an original and one copy of each filing. If more than
one docket or rulemaking number appears in the caption of this proceeding, filers must submit one
additional copy for each additional docket or rulemaking number. Filings can be sent by hand or
messenger delivery, by commercial overnight courier, or by first-class or overnight U.S. Postal Service
mail. All filings must be addressed to the Commission's Secretary, Office of the Secretary, Federal
Communications Commission. All hand-delivered or messenger-delivered paper filings for the
Commission's Secretary must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325,
Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries must be held
together with rubber bands or fasteners. Any envelopes must be disposed of before entering the building.
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must be sent
to 9300 East Hampton Drive, Capitol Heights, MD 20743. U.S. Postal Service first-class, Express, and
Priority mail must be addressed to 445 12th Street, SW, Washington DC 20554.
A copy of this Notice, the Purple Petition and any subsequently filed documents in this matter
will be available during regular business hours at the FCC Reference Center, Portals II, 445 12th Street,
SW, Room CY-A257, Washington, D.C. 20554, (202) 418-0270. This Notice, Purple Petition and any
subsequently filed documents in this matter may also be purchased from the Commission's duplicating
contractor at its website,, or call 1-800-378-3160. A copy of the submission may also
be found by searching on ECFS (insert

CG Docket Nos. 10-51 & 03-123

into the Proceeding block).
People with Disabilities: To request materials in accessible formats for people with disabilities
(Braille, large print, electronic files, audio format), send an e-mail to or call the
Consumer and Governmental Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (TTY). This
document can also be downloaded in Word and Portable Document Format (PDF) at:
For further information, please contact Gregory Hlibok, Consumer and Governmental Affairs
Bureau, Disability Rights Office, at (202) 559-5158 (voice/videophone) or e-mail at

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