NexTalk: IP Captioned Telephone Service Provider

Hearing Loss Association of America (HLAA), with the assistance of TDI’s legal representation, filed a comment to the Federal Communications Commission expressing their concerns about the Commission’s approach to reviewing and approving the ASR-based provider certifications. Specifically, IP Captioned Telephone Service Provider certifications. In previous comments with similar ASR-provider certification applications, we continued to raise concerns related to minimum requirements. These minimum requirements should have included available information for ASR offerings to the public. NexTalk is the next one that we currently see that is similar to previous applications.

We had that concern that the ASR solutions may overtake the human captioners. This concerns relates to having the commission to handle the quality, privacy, and other tradeoffs in using ASR. Thus, this application that NexTalk proposed bypasses the existing requirements to ensure the quality of captioning simply because it uses ASR.

Next Steps for IP Captioned Telephone Service Providers

Thus, we urged the Commission to review NexTalk’s application carefully, specifically, the SpeechPath (NexTalk’s speech to text functionality). NexTalk should have high-quality settings for the SpeechPath for hard-of-hearing users so they can easily participate in telephone conversations. Not only that, the Commission should examine NexTalk’s unclear claims that it ensures “90% accuracy out of the box” and “generally testing around 85 to 95% accuracy for business calls” without offering the methodology for proof of accuracy.

We again urged the Commission to create a viable oversight regime and develop metrics to ensure a viable level of quality and privacy from all IP CTS providers. Also, we urged the Commission to adopt a robust policy to ensure that diverse modes of delivering IP CTS, including switched, hybrid human-ASR, and other humans-in-the-loop models, remain viable until the Commission ultimately adopts metrics and standards.

For more information about TDI’s filing addressing NexTalk For Certification as a IP Captioned Telephone Service Provider, visit the filing and full list of signatories at the following link: https://www.fcc.gov/ecfs/file/download/DOC-5fe6476518800000-A.pdf

IP Captioned Telephone Service Provider

Filing

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

Special Thanks to:

SAMUELSON-GLUSHKO TECHNOLOGY LAW & POLICY CLINIC

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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