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   September 29, 2011

   VIA E-MAIL, FIRST CLASS MAIL, AND CERTIFIED MAIL

   RETURN RECEIPT REQUESTED

   IW Relay, Inc.

   Attn: Mr. Jeff Born

   779 N. 1180 E

   Orem, UT 84097

   E-mail: jeff@iwrelay.com

   RE: EB-11-TC-102

   This is an official CITATION issued by the Federal Communications
   Commission (Commission or FCC) pursuant to section 503(b)(5) of the
   Communications Act of 1934, as amended (the Communications Act or Act), 47
   U.S.C. S: 503(b)(5), to IW Relay, Inc. (IW Relay or the Company) for
   violations of section 225 of the Act and section 64.601 et seq. of the
   Commission's rules. As explained below, any future violations of section
   225 of the Act or section 64.601 et seq. of the Commission's rules may
   subject the Company to further legal action, including monetary fines
   (forfeitures) and/or other penalties.

   Section 64.601 et seq. of the Commission's rules generally establishes the
   requirements for entities participating in the Telecommunications Relay
   Services (TRS) program, including those relating to the eligibility of
   entities offering and providing TRS, mandatory minimum operating
   standards, and data submissions. Under the Commission's rules, to the
   extent that a TRS provider chooses to offer Video Relay Service (VRS), an
   Internet-based form of TRS, the service can only be offered to the public
   in the name of a provider eligible to receive reimbursements directly from
   the TRS Fund (Eligible Providers). Eligible Providers may also utilize
   sub-brand(s) to identify their VRS. Additionally, Eligible Providers must
   route all VRS calls through a single URL address used by the Eligible
   Provider to provide its VRS or a URL address it uses to provide VRS in the
   name of a sub-brand.

   Under section 64.604(c)(5)(iii)(N)(1)(iii) of the Commission's rules,
   Eligible Providers were prohibited from having contracts authorizing a
   third party to provide core functions associated with providing VRS.
   However, the Commission stayed the effective date of section
   64.604(c)(5)(iii)(N)(1)(iii) until October 1, 2011. This stay allows
   Eligible Providers to have certain revenue sharing arrangements, including
   subcontracting with third parties to provide interpretation services and
   call center functions on the Eligible Provider's behalf. In such cases,
   the third-party may not hold itself out as offering or providing the
   service; the Eligible Provider must always be identified as the entity
   offering and providing the VRS regardless of whether the service is
   offered directly by the Eligible Provider or through a contract with a
   third-party. Again, as discussed above, the stay of section
   64.604(c)(5)(iii)(N)(1)(iii) of the Commission's rules is temporary.
   Effective October 1, 2011, or such other date as the Commission may
   designate, Eligible Providers will be prohibited from contracting with or
   otherwise authorizing any third party to act on their behalf to provide
   interpretation service or call center functions unless the third party has
   been certified by the Commission as an Eligible Provider (i.e., it will be
   a violation of section 64.601 et  seq. for the Company to offer or provide
   VRS, or act on behalf of an Eligible Provider by providing interpretation
   services or call center functions, without having obtained from the
   Commission a certification authorizing the Company to provide VRS and
   receive reimbursements directly from the TRS Fund.).

   Based on the foregoing and the record developed in this case, the
   Enforcement Bureau (Bureau), acting through its delegated authority, finds
   that IW Relay, Inc. violated section 225 of the Act and section 64.601 et
   seq. of the Commission's rules governing TRS. Specifically, after June 1,
   2011, the Company:

     * Held itself out to the public as offering and providing VRS when the
       Company is not an Eligible Provider.

     * Did not clearly identify an Eligible Provider as the entity that a VRS
       user is using when the Company handled a VRS call initiated through
       the Company's URL.

     * Routed a VRS call through the Company's URL, a URL not used by an
       Eligible Provider for its brand or sub-brand(s).

   Our investigation of the Company's violations is continuing. Recovery of
   any monies associated with minutes that were processed through the
   Company's URL and submitted to the TRS Fund administrator for
   reimbursement will be handled through a separate process. The Commission
   and/or the TRS Fund administrator will notify the Eligible Provider that
   submitted such minutes to the TRS Fund administrator of any monies that
   must be repaid.

   If, after receipt of this citation, the Company. again violates section
   225 of the Act or section 64.601 et seq. of the Commission's rules, the
   Commission may impose monetary forfeitures up to $16,000 for each such
   violation, or up to $16,000 per day of a continuing violation. You are
   advised that the Company's continued engagement in the activities
   discussed above or engaging in the provision of VRS without proper
   certification after issuance of this citation is a violation of section
   64.601 et seq. and section 225 and could subject the Company to monetary
   forfeiture in accordance with section 503 of the Communications Act.

                                   * * * * *

                          RESPONDING TO THIS CITATION

   You may respond to this citation within 30 days of the date of this letter
   through (1) a written statement, (2) a telephone interview with the
   Commission's Telecommunications Consumers Division in Washington, DC, or
   (3) a personal interview at the Commission Field Office nearest to your
   place of business.

   If you would like to arrange a teleconference or personal interview,
   please contact Ms. Sharon Lee at (202) 418-7534. Such teleconference or
   interview must take place within 30 days of the date of this letter.

   If you would like to submit a written response, including any supporting
   documentation, you must send the response within 30 days of the date of
   this letter to the address below:

   Richard A. Hindman, Chief

   Telecommunications Consumers Division

   Enforcement Bureau

   Federal Communications Commission

   445 12th Street, S.W., Rm. 4-C224

   Washington, D.C. 20554

   Reference EB-11-TC-102 when corresponding with the Commission.

   Reasonable accommodations for people with disabilities are available upon
   request. Provide a description of the accommodation you will need,
   including as much detail as you can. Also include a way we can contact you
   if we need more information. Please allow at least five business days
   advance notice; last minute requests will be accepted, but may be
   impossible to fill. Send an e-mail to fcc504@fcc.gov or call the Consumer
   & Governmental Affairs Bureau:

   For sign language interpreters, CART, and other reasonable accommodations:

   202-418-0530 (voice), 202-418-0432 (TTY);

   For accessible format materials (Braille, large print, electronic files,
   and audio format):

   202-418-0531 (voice), 202-418-7365 (TTY).

   Under the Privacy Act of 1974, 5 U.S.C. S: 552a(e)(3), we are informing
   you that the Commission's staff will use all relevant material information
   before it, including information that you disclose in your interview or
   written statement, to determine what, if any, enforcement action is
   required to ensure your compliance with the Communications Act and
   Commission's rules.

   The knowing and willful making of any false statement, or the concealment
   of any material fact, in reply to this citation is punishable by fine or
   imprisonment pursuant to 18 U.S.C. S: 1001.

   Thank you in advance for your cooperation.

   Sincerely,

   Richard A. Hindman, Chief

   Telecommunications Consumers Division

   Enforcement Bureau

   Federal Communications Commission

   cc: Andrew O. Isar

   See 47 U.S.C. S: 225 and 47 C.F.R. S: 64.601 et seq.

   All references in this citation to IW Relay, Inc. include all d/b/a
   entities and any other entity names used by the Company to provide VRS.
   Further, all references in this citation to the Company also include the
   owners, principals and officers of this entity, as well as the corporate
   entity itself.

   47 C.F.R. S:S: 64.601-613.

   47 C.F.R. S: 64.604(c)(5)(iii)(N)(1)(i). Entities that do not meet the
   criteria currently in effect under section 64.604(c)(5)(iii)(F) of the
   Commission's rules are prohibited from holding themselves out to the
   public as providing VRS.

   S: 64.604(c)(5)(iii)(N)(1)(ii) of the Commission's rules, 47 C.F.R. S:
   64.604(c)(5)(iii)(N)(1)(ii). Sub-brands refer to brands such as those
   associated with specific states, regions, communities, etc., established
   by an Eligible Provider for the provision of its VRS.

   Id.

   47 C.F.R. S: 64.604(c)(5)(iii)(N)(1)(iii).

   Structure and Practices of the Video Relay Service Program, CG Docket No.
   10-51, Order Suspending Effective Date, 26 FCC Rcd 8327 (2011). The stay
   did not affect the requirements under section 64.604(c)(5)(iii)(N)(1)(i)
   and (ii).

   Call Center functions include call distribution, call routing, call setup,
   mapping, call features, billing, and registration. 47 C.F.R. S:
   64.604(c)(5)(iii)(N)(1)(iii).

   S: 64.604(c)(5)(iii)(N)(1)(ii). Brand names such as XYZ Co. powered by
   Eligible Provider or XYZ Co., a subcontractor of Eligible Provider, do not
   comply with the requirement that service be offered in the name of the
   Eligible Provider. Neither of these brand names clearly identifies the
   Eligible Provider as the entity actually providing the service. See
   Structure and Practices of the Video Relay Service Program, CG Docket No.
   10-51, Report and Order and Further Notice of Proposed Rulemaking, 26 FCC
   Rcd 6862 (2011).

   See section 64.604(c)(5)(iii)(C) of the Commission's rules, 47 C.F.R. S:
   64.604(c)(5)(iii)(C).

   Federal Communications Commission DA 11-1620

   2

   2

   Federal Communications Commission DA 11-1620

                       FEDERAL COMMUNICATIONS COMMISSION

                            WASHINGTON, D.C.  20554