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Federal Communications Commission DA 17-941
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Sorenson Communications, LLC
)
)
)
)
)
File No.:  EB-TCD-16-00022015
Acct. No.:  201732170008
FRN:  0015648942
ORDER
Adopted:  September 29, 2017 Released:  September 29, 2017
By the Chief, Enforcement Bureau:
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission has 
entered into a Consent Decree to resolve its investigation into whether Sorenson Communications, LLC 
(Sorenson or Company) met its obligations as a Telecommunications Relay Service (TRS) provider.  
Sorenson experienced a preventable service outage which resulted in the Company’s failure to handle all 
types of calls and provide Video Relay Service (VRS) in the manner required by the Commission’s rules 
(Rules). To settle this matter, Sorenson has agreed to reimburse the TRS Fund the sum of $2,700,000, and 
pay a settlement to the United States Treasury in the amount of $252,000.
2. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree and terminating the 
referenced investigation regarding Sorenson’s compliance with Sections 64.604(a)(3)(ii) and 64.604(b)(4) 
of the Rules.1
3. In the absence of material new evidence relating to this matter, we do not set for hearing 
the question of Sorenson’s basic qualifications to hold or obtain any Commission license or 
authorization.2
4. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Act3 and the 
authority delegated by Sections 0.111 and 0.311 of the Rules,4 the attached Consent Decree IS 
ADOPTED and its terms incorporated by reference.
5. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED in 
accordance with the terms of the attached Consent Decree.
  
1 47 CFR §§ 64.604(a)(3)(ii), (b)(4).
2 See 47 CFR § 1.93(b).
3 47 U.S.C. § 154(i).
4 47 CFR §§ 0.111, 0.311.
Federal Communications Commission DA 17-941
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6. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first class mail and certified mail, return receipt requested, to R. Scott Wood, General Counsel, 
Sorenson Communications, LLC, 4192 South Riverboat Road, Salt Lake City, UT 84234, and to John T. 
Nakahata, Esq., Harris, Wiltshire & Grannis, LLP, 1919 M Street NW, 8th Floor, Washington, DC 20036.
FEDERAL COMMUNICATIONS COMMISSION
Rosemary C. Harold
Chief 
Enforcement Bureau
Federal Communications Commission DA 17-941
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Sorenson Communications, LLC
)
)
)
)
)
File No.:  EB-TCD-16-00022015
Acct. No.:  201732170008
FRN:  0015648942
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and Sorenson 
Communications, LLC, by their authorized representatives, hereby enter into this Consent Decree to settle 
the Enforcement Bureau’s investigation of the service outage affecting Sorenson’s Video Relay Service 
between June 6 and 8, 2016.
I. DEFINITIONS
2. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended.1
(b) “Adopting Order” means an order of the Bureau adopting the terms of this Consent 
Decree without change, addition, deletion, or modification.
(c) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(d) “Commission” and “FCC” mean the Federal Communications Commission and all of 
its bureaus and offices.
(e) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which Sorenson is 
subject by virtue of its business activities, including but not limited to the TRS Rules.
(f) “Default Provider” has the same meaning as the term is defined in 47 CFR § 
64.601(a)(11).
(g) “Dial-Around” means a VRS call handled by a Provider other than the Registered 
Internet-based TRS User’s Default Provider.
(h) “Effective Date” means the date by which both the Bureau and Sorenson have signed 
the Consent Decree.
(i) “Internet-based TRS” or “iTRS” has the same meaning as the term is defined in 47 
CFR § 64.601(a)(15).
(j) “Investigation” means the investigation commenced by the Bureau in EB-TCD-16-
00022015 regarding whether Sorenson violated the TRS Rules.
(k) “Parties” means Sorenson and the Bureau, each of which is a “Party.”
(l) “Point-to-Point” means a non-relay video call between two parties that uses a TRS 
platform but does not involve a Communications Assistant.
(m) “Provider” means an entity that is eligible to receive compensation from the TRS 
Fund for providing compensable TRS service.
  
1 47 U.S.C. § 151 et seq.
Federal Communications Commission DA 17-941
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(n) “Registered Internet-based TRS User” has the same meaning as is defined in 47 CFR 
§ 64.601(a)(27).
(o) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
(p) “Service Outage Notice” means a notice, as described in paragraph 14 below, which 
provides consumers information related to a VRS Service Interruption.
(q) “Sorenson” or “Company” means Sorenson Communications, LLC, its parent, 
subsidiaries, and successors in interest.
(r) “Sorenson.com” means the domain name Sorenson uses as the primary access point 
for users to initiate a Video Relay Service call through SVRS.
(s) “SVRS” means the brand name of Sorenson’s video relay service.
(t) “Telecommunications Relay Service” or “TRS” has the same meaning as the term is 
defined in 47 CFR § 64.601(a)(32).
(u) “TRS Fund” or “Fund” means the fund used to compensate Providers for their 
reasonable costs of providing interstate relay service and Internet-based TRS, which 
include interstate and intrastate relay calls.2
(v) “TRS Fund Administrator” means the entity designated by the Commission to 
administer the TRS Fund.3
(w) “TRS Rules” means the regulations set forth at 47 CFR §§ 64.601 through 64.636 
and §§ 64.5101 through 64.5111, Commission orders implementing and interpreting 
47 U.S.C. § 225 of the Act, and any other Rules and orders applicable to iTRS 
Providers.
(x) “Video Relay Service” or “VRS” has the same meaning as the term is defined in 47 
CFR § 64.601(a)(40).
(y) “VRS Service Interruption” means any event resulting from the Company’s action or 
failure to act, that results in an inability of multiple VRS users using a commercially 
deployed service to make or receive calls for more than thirty (30) minutes by:  (i) 
SVRS’ Registered Internet-based TRS Users, regardless of the device used; or (ii) 
Dial-Around or Point-to-Point callers using Sorenson’s platform.
II. BACKGROUND
3. Telecommunications Relay Service (TRS) allows persons with hearing or speech 
disabilities to communicate with others in a manner similar to hearing persons using a telephone.4 There 
are currently multiple forms of TRS, some of which use only the public switched telephone network, and 
others of which also utilize the Internet.  Video Relay Service (VRS), Internet Protocol Relay Service (IP 
Relay), and Internet Protocol Captioned Telephone Service (IP CTS) are forms of Internet-based TRS 
(iTRS) and require Internet Protocol-enabled devices.
  
2 See 47 CFR § 64.604(c)(5)(iii).
3 Id.
4 See 47 CFR § 64.601(a)(15).  There are multiple forms of TRS, three of which are iTRS—Video Relay Service 
(VRS), Internet Protocol Relay Service (IP Relay), and Internet Protocol Captioned Telephone Service (IP CTS).
Federal Communications Commission DA 17-941
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4. Sorenson is a TRS Provider based in Salt Lake City, Utah.  The Company holds a 
Commission certification to provide two forms of iTRS—VRS and IP CTS.5 Sorenson is eligible for 
compensation from the TRS Fund if it provides service in accordance with the TRS Rules and submits 
“true and adequate data” to the TRS Fund Administrator.6 As a Provider, Sorenson’s VRS must be 
capable of handling any type of call normally provided by telecommunications carriers, including 911 
calls,7 and be provided for 24 hours every day.8
5. Sorenson.com is a domain name Sorenson uses to provide access to SVRS.9 On the 
morning of June 6, 2016, Sorenson experienced a VRS Service Interruption that resulted from a 
preventable, internal operational failure.10 This failure led the domain registration for Sorenson.com to 
expire and be deactivated.  After the deactivation occurred and before Sorenson could correct the 
situation, some Internet Service Providers (ISPs) updated their records to reflect that the domain was 
expired.  If a user’s ISP updated its records while the domain was shown as expired, that user could not 
make or receive calls routed through Sorenson.com—including VRS, 911, Dial-Around, and Point-to-
Point calls—during at least part of the outage.  
6. Upon discovery of the VRS Service Interruption, Sorenson took immediate steps to 
correct the problem and notify callers.  Once the domain name was reactivated, each caller’s ISP had to 
take certain steps to ensure that calls were routed through Sorenson.com.  To expedite this process, 
Sorenson reached out to multiple large ISPs, such as Verizon and Comcast, and posted information about 
the VRS Service Interruption on its website11 and social media outlets.  The VRS Service Interruption 
continued for some callers through the morning of June 8, 2016.
  
5 See Notice of Grant of Conditional Certification for Sorenson Communications, Inc., as Reorganized Pursuant to 
Chapter 11, to Provide Internet-Based Telecommunications Relay Services Pending Commission Action on 
Sorenson’s Application for Certification, CG Docket Nos. 03-123, 10-51, & 13-24, Public Notice, 29 FCC Rcd 4111 
(CGB 2014). 
6 See 47 CFR § 64.604(c)(5)(iii)(D)(1).  Data submitted to the TRS Fund Administrator is also used to determine 
TRS Fund revenue requirements and the per-minute compensation rate.  TRS Providers are also required to retain all 
data to support claims for payment from the TRS Fund for five years.  See 47 CFR § 64.604(c)(5)(iii)(D)(7).  The 
TRS Fund Administrator and the Commission have the authority to examine and verify TRS provider data as 
necessary to assure the accuracy and integrity of TRS Fund payments.  47 CFR § 64.604(c)(5)(iii)(D)(6).
7 See 47 CFR §§ 64.604(a)(3)(ii), (a)(4).  The mandatory minimum standards governing the provision of TRS 
require that TRS providers have the capability to handle any type of call normally provided by telecommunications 
carriers unless the Commission determines that it is not technologically feasible to do so or the requirement to 
handle a specific type of call has been waived by the Commission.  Therefore, this requirement applies to both forms 
of iTRS provided by Sorenson.
8 47 CFR § 64.604(b)(4)(i).  See Telecommunications Relay Services and Speech-to-Speech Services for Individuals 
with Hearing and Speech Disabilities, CG Docket Nos. 03-123 & 98-67, Report and Order, 20 FCC Rcd 13165 at 
13179, para. 30 (2005) (VRS 24/7 Order) (“VRS providers must offer this service 24/7 to be eligible for 
compensation from the Interstate TRS Fund.”); see also VRS 24/7 Order, 20 FCC Rcd 13179, para. 29 (“As 
consumers increasingly rely on VRS as their preferred means of using TRS to access the telephone system, it 
becomes imperative that consumers have access to this service 24/7.  Indeed, Congress expressly recognized that 
having TRS available 24/7 is central to the notion of functional equivalency; it included that requirement in the 
statute.”).
9 See Letter from John T. Nakahata, Harris, Wiltshire & Grannis, LLP, Counsel to Sorenson, to Chana Wilkerson, 
Telecommunications Consumers Division, FCC Enforcement Bureau (July 7, 2016) (on file in EB-TCD-16-
00022015).  
10 Sorenson notified the Commission’s Consumer and Governmental Affairs Bureau of the system outage on the 
morning of June 6, 2016.
11 The Company acknowledged that while an ISP was affected by the outage, its users would not have been able to 
view information on Sorenson.com through that ISP.
Federal Communications Commission DA 17-941
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7. The Bureau and Sorenson negotiated the following terms and conditions of settlement 
and hereby enter into this Consent Decree as provided below.
III. TERMS OF AGREEMENT
8. Adopting Order.  The provisions of this Consent Decree shall be incorporated by the 
Bureau in an Adopting Order.
9. Jurisdiction.  Sorenson agrees that the Bureau has jurisdiction over it and the matters 
contained in this Consent Decree and has the authority to enter into and adopt this Consent Decree.
10. Effective Date; Violations.  The Parties agree that this Consent Decree shall become 
effective on the Effective Date as defined herein.  As of the Effective Date, the Parties agree that this 
Consent Decree shall have the same force and effect as any other order of the Commission.
11. Termination of Investigation.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
terminate the Investigation.  In consideration for the termination of the Investigation, Sorenson agrees to 
the terms, conditions, and procedures contained herein.  The Bureau further agrees that, in the absence of 
new material evidence, it will not use the facts developed in the Investigation through the Effective Date, 
or the existence of this Consent Decree, to institute, on its own motion, any new proceeding, formal or 
informal, or take any action on its own motion against Sorenson concerning the matters that were the 
subject of the Investigation.  
12. Representations and Warranties.  Sorenson represents and warrants that it will treat the 
Settlement Amount set forth herein as a penalty within the meaning of Section 162(f) of the Internal 
Revenue Code.12 The Company also agrees that it will not treat any payment of the Settlement Amount 
described below in paragraph 19 as tax deductible for purposes of federal, state, or local law or include 
the expense as a business cost in its annual cost submission (i.e., the Annual Relay Service Data Request 
filing) to the TRS Fund Administrator.
13. Notification to the Commission.  As of the Effective Date, Sorenson shall notify the 
Commission within one (1) business day of the Company’s detection of any VRS Service Interruption of 
more than two (2) hours in duration. The notification shall describe the VRS Service Interruption and at a 
minimum shall state when the VRS Service Interruption was discovered, the steps being taken to restore 
service, the effect of the VRS Service Interruption on callers to the extent known, and the anticipated time 
of service restoration.  Once service is fully restored, Sorenson must notify the Commission within one 
(1) business day of such restoration.  Sorenson’s notification shall include, at a minimum, the day and 
time at which service was fully restored, the cause of the VRS Service Interruption, and to the extent 
known, the full effect on callers, including the Company’s current estimate of the total number of callers 
and calls impacted during the duration of the VRS Service Interruption, and a separate count of the 
number of affected 911 calls.  Sorenson’s notifications shall be submitted electronically to the Deputy 
Chief, Telecommunications Consumers Division (TRS), Enforcement Bureau via e-mail to 
fccebaccess@fcc.gov; and to the Deputy Chief, Disability Rights Office, Consumer and Governmental 
Affairs Bureau via e-mail to TRSreports@fcc.gov.  
14. Notification to the Public. Within sixty (60) calendar days after the Effective Date, 
when a VRS Service Interruption occurs, Sorenson shall prominently display on the front page of the 
Company’s website, a Service Outage Notice.  The Service Outage Notice will be linked to a webpage 
that provides consumers with:  (i) the latest information on the VRS Service Interruption including the 
estimated time of service restoration, (ii) information or instructions for making and receiving calls, 
including 911 calls, during the VRS Service Interruption, and (iii) notice of any recommended actions 
that users should take during or after a VRS Service Interruption.  Within thirty (30) calendar days of the 
  
12 See 26 U.S.C. § 162(f).
Federal Communications Commission DA 17-941
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Effective Date, the Company shall also use its social media pages to notify users of a VRS Service 
Interruption and how to seek additional information.  Additionally, within 180 days after the Effective 
Date, the Company shall deploy and/or make available a software update that allows the Company to post 
notice of VRS Service Interruptions on the front screen of videophones and mobile and desktop 
applications.  The Company shall issue any Service Outage Notice described above as soon as possible 
and, to the extent possible, within two (2) hours of Sorenson’s discovery of any VRS Service Interruption 
unless the VRS Service Interruption is fully resolved by the time notice would be required.
15. Reporting Noncompliance.  Sorenson shall report any noncompliance with the TRS 
Rules with respect to VRS Service Interruptions and with the terms and conditions of this Consent Decree 
within fifteen (15) calendar days after discovery of such noncompliance.  Such reports shall include a 
detailed explanation of:  (i) each instance of noncompliance; (ii) the steps that the Company has taken or 
will take to remedy such noncompliance; (iii) the schedule on which such remedial actions will be taken; 
(iv) an estimate of the number of callers and/or the number of calls impacted by the noncompliance; and 
(v) the steps that the Company has taken or will take to prevent the recurrence of any such 
noncompliance.  All reports of noncompliance shall be submitted to Chief, Telecommunications 
Consumers Division, Enforcement Bureau, Federal Communications Commission, Room 3-C366, 445 
12th Street, SW Washington, DC 20554, with a copy submitted electronically to the Deputy Chief, 
Telecommunications Consumers Division (TRS), Enforcement Bureau via e-mail to 
fccebaccess@fcc.gov; and to the Deputy Chief, Disability Rights Office, Consumer and Governmental 
Affairs Bureau via e-mail to TRSreports@fcc.gov.
16. Annual Certification.  Sorenson shall file an annual certification signed by Sorenson’s 
Compliance Officer or General Counsel certifying that the Company has conducted quarterly staff review 
of every domain used for VRS to ensure that all steps have been taken to renew any domain names that 
are set to expire within the next year.  Sorenson shall file this annual certification by October 31 of each 
calendar year.
17. Termination Date.  Unless stated otherwise, the requirements set forth in paragraphs 13-
16 shall expire 24 months after the Effective Date.
18. Fund Reimbursement.  The Company will the pay the sum of two million seven 
hundred thousand dollars ($2,700,000) to the TRS Fund within two (2) business days after the Effective 
Date to reimburse the Fund for payments received for the days when SVRS was unavailable to some 
callers as described in paragraphs 5 and 6.
19. Settlement Amount.  Sorenson will pay a settlement to the United States Treasury in the 
amount of two hundred fifty-two thousand dollars ($252,000) within thirty (30) calendar days of the 
Effective Date.  This Settlement Amount is separate from and does not include the Fund Reimbursement 
included in Paragraph 18.  Sorenson shall send electronic notification of payment to fccebaccess@fcc.gov 
on the date said payment is made.  The payment must be made by check or similar instrument, wire 
transfer, or credit card, and must include the Account Number and FRN referenced above.  Regardless of 
the form of payment, a completed FCC Form 159 (Remittance Advice) must be submitted.13 When 
completing the FCC Form 159, enter the Account Number in block number 23A (call sign/other ID) and 
enter the letters “FORF” in block number 24A (payment type code).  Below are additional instructions 
that should be followed based on the form of payment selected:
· Payment by check or money order must be made payable to the order of the Federal 
Communications Commission. Such payments (along with the completed Form 159) must be 
mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-
  
13 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
Federal Communications Commission DA 17-941
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9000, or sent via overnight mail to U.S. Bank – Government Lockbox #979088, 
SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101.
· Payment by wire transfer must be made to ABA Number 021030004, receiving bank 
TREAS/NYC, and Account Number 27000001.  To complete the wire transfer and ensure 
appropriate crediting of the wired funds, a completed Form 159 must be faxed to U.S. Bank 
at (314) 418-4232 on the same business day the wire transfer is initiated.
· Payment by credit card must be made by providing the required credit card information on 
FCC Form 159 and signing and dating the Form 159 to authorize the credit card payment.  
The completed Form 159 must then be mailed to Federal Communications Commission, P.O. 
Box 979088, St. Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank –
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
63101.
Questions regarding payment procedures should be addressed to the Financial Operations Group 
Help Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.
20. Event of Default.  The Parties agree that an Event of Default shall occur upon failure by 
Sorenson to pay any amount due under the terms of this Consent Decree by the due date specified in this 
Consent Decree.  An Event of Default constitutes a violation of this Consent Decree.
21. Interest and Charges for Collection.  After an Event of Default has occurred under this 
Consent Decree, the then unpaid amount of the Settlement Amount and/or Fund Reimbursement shall 
accrue interest, computed using the U.S. Prime Rate in effect on the date of the Event of Default plus 4.75 
percent, from the date of the Event of Default until payment in full.  Upon an Event of Default, the then 
unpaid amount of the Settlement Amount, together with interest, any penalties permitted and/or required 
by the law, including but not limited to 31 U.S.C. § 3717 and administrative charges, plus the costs of 
collection, litigation, and attorneys’ fees, shall become immediately due and payable, without notice, 
presentment, demand, protest, or notice of protest of any kind, all of which are waived by Sorenson.  
Upon an Event of Default, the then unpaid amount of the Fund Reimbursement shall become immediately 
due and recovered through offsets from the TRS Fund.
22. Waivers.  As of the Effective Date, Sorenson waives any and all rights it may have to 
seek administrative or judicial reconsideration, review, appeal or stay, or to otherwise challenge or contest 
the validity of this Consent Decree and the Adopting Order.  Sorenson shall retain the right to challenge 
Commission interpretation of the Consent Decree or any terms contained herein.  If either Party (or the 
United States on behalf of the Commission) brings a judicial action to enforce the terms of the Consent 
Decree or the Adopting Order, neither Sorenson nor the Commission shall contest the validity of the 
Consent Decree or the Adopting Order, and Sorenson shall waive any statutory right to a trial de novo.  
Sorenson hereby agrees to waive any claims it may otherwise have under the Equal Access to Justice 
Act14 relating to the matters addressed in this Consent Decree.
23. Severability.  The Parties agree that if any of the provisions of the Consent Decree shall 
be held unenforceable by any court of competent jurisdiction, such unenforceability shall not render 
unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not 
containing the particular unenforceable provision or provisions, and the rights and obligations of the 
Parties shall be construed and enforced accordingly.
24. Invalidity.  In the event that this Consent Decree in its entirety is rendered invalid by any 
court of competent jurisdiction, it shall become null and void and may not be used in any manner in any 
legal proceeding.
  
14 See 5 U.S.C. § 504; 47 CFR §§ 1.1501–1.1530.
Federal Communications Commission DA 17-941
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25. Subsequent Rule or Order.  The Parties agree that if any provision of the Consent 
Decree conflicts with any subsequent Rule or Order adopted by the Commission (except an Order 
specifically intended to revise the terms of this Consent Decree to which Sorenson does not expressly 
consent) that provision will be superseded by such Rule or Order.
26. Successors and Assigns.  Sorenson agrees that the provisions of this Consent Decree 
shall be binding on its successors, assigns, and transferees.
27. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation. The Parties further 
agree that this Consent Decree does not constitute either an adjudication on the merits or a legal finding or 
determination regarding any compliance or noncompliance with the Communications Laws with regards 
to the matters described in paragraphs 3-7; and that, by entering into the Consent Decree, Sorenson makes 
no admissions of liability of any kind.
28. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
29. Paragraph Headings.  The headings of the paragraphs in this Consent Decree are 
inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent 
Decree.
30. Authorized Representative.  Each Party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.  Each person signing this Consent Decree on 
behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this Consent 
Decree and to bind the Party to its terms and conditions.
31. Counterparts.  This Consent Decree may be signed in counterpart (including 
electronically or by facsimile).  Each counterpart, when executed and delivered, shall be an original, and 
all of the counterparts together shall constitute one and the same fully executed instrument.
________________________________
Rosemary C. Harold
Chief
Enforcement Bureau
________________________________
Date
________________________________
R. Scott Wood
General Counsel 
Sorenson Communications, LLC
________________________________
Date