The Coalition is pleased to submit these comments in response to the Federal Communications Commission’s (“FCC” or “the Commission”) September 30, 2020 Further Notice of Proposed Rulemaking (“FNPRM”) regarding “robust, efficient, objective, and quantifiable measurement of the quality of service” for providers of Internet Protocol Captioned Telephone Service (“IP CTS”). We were delighted to learn that Acting Chairwoman Rosenworcel recently told the Commission staff, “We have work to do to ensure that our functional equivalency policies live up to our responsibilities under the Americans with Disabilities Act.” The Coalition agrees and appreciates this opportunity to engage with the Commission on the important issues in this proceeding.

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