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Advocates for people who are deaf endorsed a proposal by Purple C...

Advocates for people who are deaf endorsed a proposal by Purple Communications for a ban on “white labeling” (CD April 28 p4), but rejected several of the telecom relay service provider’s suggestions for tightening certification requirements. White labeling is…

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a revenue-sharing arrangement for uncertified relay providers to offer service to consumers by billing through certified providers. In reply comments Monday, the National Association of the Deaf and six other consumer groups said they “generally agree” with Purple’s proposed ban on white-label providers. “The existence of ‘white label’ providers creates a market for unregulated services and presents substantial risks regarding the quality of services … being provided to the deaf and hard of hearing communities,” the groups wrote. When a provider applies for certification, it should be required to disclose ownership information, but it shouldn’t have to show that it meets a minimum level of capitalization or staffing, as Purple proposed, they said. “The FCC should not be in the business of reviewing relay providers’ financial statements to determine whether or not an Internet-based relay provider is ‘adequately’ funded.” A provider with more money won’t necessarily provide better service, and start-up companies “should have the opportunity to succeed or fail in the marketplace based on the merits of the service provided,” they said. Likewise, requiring a minimum amount of staffing “would make it impossible for a new provider to start small and grow in size,” they said. “The Commission should not be the arbiter of a relay provider’s business plan.” Finally, the consumer groups rejected Purple’s proposal to require FCC rather than state certification, saying states should retain certification power in cases where the provider is compensated from a state TRS fund. In separate reply comments, Purple said “divergent views” on its proposals “suggest that further discussion in a full rulemaking proceeding would be beneficial.” Opening one “would not have the effect of putting any existing certified provider at risk or disrupting such providers’ operations,” it said.