HLAA, with the assistance of TDI’s legal representation, filed a comment to the Federal Communications Commission about Global Caption, Inc.’s application for the certification as a Provider of Internet Protocol Captioned Telephone Service. 

Internet Protocol Captioned Telephone Service

We saw ways that Global Captions, Inc. is similar to other applications. These applications try to bypass many of the requirements ensuring quality of human-captioner-based IP CTS through the use of an ASR-only solution. Hence, we urged the Commission to carefully evaluate the Global Caption’s application. Furthermore, we asked them to have the goal of ensuring compliance with the low minimum requirements before granting approval. Moreover, the Commission should make sure that the Global Caption’s speech-to-text functionality has high quality. This level of quality ensures that the hard of hearing users are able to make and receive calls, along with relying on Global Caption’s caption accuracy and readability. Also, the Commission should heed to the Global Caption’s confidential portions. This attention should be on highlighting key parts that are impossible for us and the users to evaluate. 

Global Caption INC., Application

The Commission should carefully review the specific technological claims made by Global Caption. Automated systems can take the role of a person’s need to listen to a call. Yet, they may also need to record and listen to private conversations, which raises questions about the collection, storage, and maintenance of data. Global Caption said that they would not save the content of any calls. Nonetheless, we asked the Commission to ensure the agreement meets compliance of vendors’ practices related to customer data with the Global Caption’s promise. 

The Global Caption also seeks to provide ASR IP-CTS in carceral facilities where the hard of hearing or deafblind people reside.  The Commission should evaluate that its application is complying with the Commission’s policies. One such policy including making sure that the users are not charged for calls. We did note and acknowledge that the Commission is encouraging the providers to offer services in carceral facilities. However, we reminded the Commission that a single IP CTS provider effectively may provide the only conduit an incarcerated person who is hard of hearing or DeafBlind has to communicate with family, friends, legal counsel, or anyone else. We raised privacy concerns as the incarcerated people are closely monitored by the carceral officials. This close scrutiny raises concerns to provide a secure, private channels to communicate with legal counsel and clergy. 

Recommendations for the Commission

Finally, we also reminded the Commission repeatedly that they should focus on in-call switching functionality. This in-call switching functionality allows the users to switch to Communication Assistants (CA) if having a problem with ASR. The Global Caption did not have communication assistants. Noted that all providers of ASR-based IP CTS are required to have this functionality. 

Overall, we expressed that the Commission should set up an oversight regime and develop metrics. The rationale behind this is because metrics and standards for ASR are not part of the Commission’s rules. The users of these providers will continue to have a lack of information about the quality and privacy features of the services they use. We also call for the Commission to urgently adopt requirements for carceral communications accessibility.

For more information about TDI’s filing addressing Application of Global Caption, Inc., for Certification as Provider of Internet Protocol Captioned Telephone Service, visit the filing and full list of signatories at the following link:  https://www.fcc.gov/ecfs/search/search-filings/filing/10509013691258

Internet Protocol Captioned Telephone Service



CG 03-123 — Telecommunication Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities;


WC 12-375 — Rates for Interstate Inmate Calling Services

Special Thanks to:


Application of Global Caption, Inc., for Certification as Provider of Internet Protocol Captioned Telephone Service Filing Co-Signatories:

TDI, Hearing Loss Association of America (HLAA), National Association of the Deaf (NAD), Rehabilitation Engineering Research Center on Technology for the Deaf and Hard of Hearing (DHH-RERC)

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