[Electronics-talk] Amazon and Sony Are Requesting ThatThe Accessibility Requirement Be Waived for E-Book Readers

Anna Givens annajee82 at gmail.com
Fri Aug 9 20:13:33 UTC 2013


It depends on which ones are being sold to educational institutions.  If the Paper White is ever going to be used in an educational setting it must be accessible.  If not, then that sounds like a good deal.

Anna E Givens

On Aug 9, 2013, at 11:35 AM, Ray Foret jr <rforetjr at att.net> wrote:

> Nagosiate with MAmazon?  You kidding me?  They won't even talk to us.
> 
> 
> Sent from my mac, the only computer with full accessibility for the blind built-in!
> Sincerely,
> The Constantly Barefooted Ray
> Still a very proud and happy Mac and Iphone user!
> 
> On Aug 9, 2013, at 11:15 AM, "Rob Tabor" <rob.tabor at sbcglobal.net> wrote:
> 
>> Good morning colleagues,
>> 
>> It occurs to me we have a situation that could be ripe for an effective
>> negotiation with Amazon and Sony. Perhaps the NFB and other advocacy groups
>> could propose that we will not object to the petition for an exemption for
>> the Paper White in return for a good faith promise on their part to make all
>> other Kindle devices fully accessible as they have mostly done with the iOS
>> app. These decisions are made by folks much higher on the pay grade than I,
>> but it seems they are worth considering.
>> 
>> Best regards,
>> Rob Tabor JD
>> 
>> -----Original Message-----
>> From: Electronics-talk [mailto:electronics-talk-bounces at nfbnet.org] On
>> Behalf Of Baracco, Andrew W
>> Sent: Friday, August 09, 2013 10:59 AM
>> To: Discussion of accessible electronics and appliances
>> Subject: Re: [Electronics-talk] Amazon and Sony Are Requesting ThatThe
>> Accessibility Requirement Be Waived for E-Book Readers
>> 
>> They are not. They are requesting exemption for the Paper White, which has
>> no audio capability, and can access the internet only for the purpose of
>> retrieving books. Actually, the kindle Fire runs Android 4.0, and they are
>> working on implementing Explore by Touch.
>> 
>> Andy
>> 
>> 
>> -----Original Message-----
>> From: Electronics-talk [mailto:electronics-talk-bounces at nfbnet.org] On
>> Behalf Of Christopher Chaltain
>> Sent: Friday, August 09, 2013 8:43 AM
>> To: Discussion of accessible electronics and appliances
>> Subject: Re: [Electronics-talk] Amazon and Sony Are Requesting ThatThe
>> Accessibility Requirement Be Waived for E-Book Readers
>> 
>> Do you happen to have a link? I've read some pretty detailed articles posted
>> on list, but I haven't gone searching for the actual text of the waiver yet.
>> 
>> My big concern is whether Amazon is including the Kindle Fire in their
>> waiver. From what I've read, I suspect they are. Even if any one thinks the
>> ereader manufacturers have a point, the Kindle Fire runs Android, which
>> other manufacturers have shown can be made accessible at little or no cost.
>> Amazon may not consider the Kindle Fire to be a tablet, and they may not
>> push it's ACS capabilities, but I think including the Kindle Fire in the
>> waiver pushes us pretty far down that slipper slope.
>> 
>> On 08/09/2013 10:31 AM, Baracco, Andrew W wrote:
>>> If you go to the FCC site and read the full text of the petition, it
>> describes in detail exactly the type of device for which the waivure is
>> sought.
>>> 
>>> Andy
>>> 
>>> 
>>> -----Original Message-----
>>> From: Electronics-talk [mailto:electronics-talk-bounces at nfbnet.org] On 
>>> Behalf Of Walter Cone
>>> Sent: Thursday, August 08, 2013 5:50 PM
>>> To: 'Discussion of accessible electronics and appliances'
>>> Subject: Re: [Electronics-talk] Amazon and Sony Are Requesting ThatThe 
>>> Accessibility Requirement Be Waived for E-Book Readers
>>> 
>>> Andy if you read the original message you will notice Amazon and Sony 
>>> want to exempt all of the ebook readers.  This shouldn't be a ha ha 
>>> funny game to us blind people because Amazon and others are trying to 
>>> use the ebook readers for educational purposes and if this happens what
>> happens to us.
>>> Will we have to have a company like Freedom Unscientific or GW money 
>>> maker make a special ebook reader for 1500 to 2000 dollars knowing the 
>>> VA and the agencies for the blind will buy them?
>>> 
>>> 
>>> -----Original Message-----
>>> From: Electronics-talk [mailto:electronics-talk-bounces at nfbnet.org] On 
>>> Behalf Of Baracco, Andrew W
>>> Sent: Thursday, August 08, 2013 12:46 PM
>>> To: Discussion of accessible electronics and appliances
>>> Subject: Re: [Electronics-talk] Amazon and Sony Are Requesting That 
>>> The Accessibility Requirement Be Waived for E-Book Readers
>>> 
>>> I agree with the manufacturers on this one. For example, this would 
>>> only apply to one model of the Kindle, which they call the Paper 
>>> White. It is designed to do only one thing, and that is to display the 
>>> contents of a book in digitized text that looks like a printed page.
>>> It has no audio capability whatsoever. There is no way that this 
>>> device could be made accessible except to create a whole new device, 
>>> which would require a bigger battery, a more powerful processor, and 
>>> more robust hardware and software. The AC standards would still apply 
>>> to the more powerful and robust Kindle devices which are the ones that we
>> would want anyway.
>>> 
>>> Andy
>>> 
>>> 
>>> -----Original Message-----
>>> From: Electronics-talk [mailto:electronics-talk-bounces at nfbnet.org] On 
>>> Behalf Of David Andrews
>>> Sent: Wednesday, August 07, 2013 6:20 PM
>>> To: blindtlk at nfbnet.org
>>> Subject: [Electronics-talk] Amazon and Sony Are Requesting That The 
>>> Accessibility Requirement Be Waived for E-Book Readers
>>> 
>>> 
>>>> 
>>>> From: Howell, Scott (HQ-LE050)
>>>> Sent: Wednesday, August 07, 2013 5:00 AM
>>>> To: Moore, Craig E. (MSFC-EV43)
>>>> Subject: Fwd: Amazon and Sony Are Requesting That The Accessibility 
>>>> Requirement Be Waived for E-Book Readers
>>>> 
>>>> 
>>>> 
>>>> Craig,
>>>> 
>>>> 
>>>> 
>>>> Sharing as information.
>>>> 
>>>> 
>>>> 
>>>> 
>>>> 
>>>> Begin forwarded message:
>>>> 
>>>> 
>>>> 
>>>> Amazon and Sony Are Requesting That The Accessibility Requirement Be 
>>>> Waived for E-Book Readers
>>>> 
>>>> 
>>>> 
>>>> 
>>>> Details
>>>> 
>>>> 
>>>> 
>>>> The ) Twenty-First Century Communications and Video ) Accessibility 
>>>> Act of 2010 requires companies who make electronic devices to make 
>>>> them accessible to people with disabilities. At this time, none of 
>>>> the Ebook readers that are on the market meet this requirement. Since 
>>>> many companies feel that this requirement should not apply to Ebook 
>>>> readers, Amazon, Kobo, and Sony have submitted a petition to the FCC 
>>>> asking for a waiver. According to the petition, this is the 
>>>> definition of an Ebook
>>>> reader: "E-readers, sometimes called e-book readers, are mobile 
>>>> electronic devices that are designed, marketed and used primarily for 
>>>> the purpose of reading digital documents, including e-books and 
>>>> periodicals." Since Ebook readers are primarily designed for print 
>>>> reading, the companies are arguing that the disabled community would 
>>>> not significantly benefit from these devices becoming accessible.
>>>> They also argue that because the devices are so simple, making the 
>>>> changes to the devices to make them accessible, would cause them to 
>>>> be heavier, have poorer battery life, and raise the cost of the devices.
>>>> Finally, these companies argue that since their apps are accessible 
>>>> on other devices such as the iPad and other full featured tablets, 
>>>> that they are already providing access to their content.
>>>> We've posted the complete filing from the FCC's website below. Here 
>>>> is a <http://apps.fcc.gov/ecfs/document/view?id=7022314526>link to 
>>>> the original .PDF
>>>> 
>>>> Before the
>>>> FEDERAL COMMUNICATIONS COMMISSION
>>>> Washington, D.C. 20554
>>>> In the Matter of )
>>>> )
>>>> Implementation of Sections 716 and 717 of the ) CG Docket No. 10-213 
>>>> Communications Act of 1934, as Enacted by the ) Twenty-First Century 
>>>> Communications and Video ) Accessibility Act of 2010 )
>>>> )
>>>> )
>>>> Petition for Waiver of Sections 716 and 717 ) of the Communications 
>>>> Act and Part 14 of the ) Commission's Rules Requiring Access to ) 
>>>> Advanced Communications Services (ACS) and ) Equipment by People with 
>>>> Disabilities )
>>>> To: Chief, Consumer and Governmental Affairs Bureau COALITION OF 
>>>> E-READER MANUFACTURERS PETITION FOR WAIVER Gerard J. Waldron Daniel H.
>>>> Kahn COVINGTON & BURLING LLP
>>>> 1201 Pennsylvania Avenue NW
>>>> Washington, D.C. 20004-2401
>>>> (202) 662-6000
>>>> Counsel for the Coalition of E-Reader Manufacturers May 16, 2013 
>>>> TABLE OF CONTENTS I. INTRODUCTION AND SUMMARY
>> ...........................................................................
>>> ....
>>>> 1
>>>> II. E-READERS ARE A DISTINCT CLASS OF EQUIPMENT 
>>>> ...........................................
>>>> 2
>>>> III. E-READERS ARE USED PRIMARILY FOR READING 
>>>> ...............................................
>>>> 3
>>>> A. E-Readers Are Designed and Marketed for Reading 
>>>> ..............................................
>>>> 4
>>>> B. E-Readers Are Not Designed or Marketed for ACS 
>>>> ...............................................
>>>> 6
>>>> IV. THE REQUESTED WAIVER WILL ADVANCE THE PUBLIC INTEREST
>> ................
>>>> 8
>>>> Before the
>>>> FEDERAL COMMUNICATIONS COMMISSION
>>>> Washington, D.C. 20554
>>>> In the Matter of )
>>>> )
>>>> Implementation of Sections 716 and 717 of the ) CG Docket No. 10-213 
>>>> Communications Act of 1934, as Enacted by the ) Twenty-First Century 
>>>> Communications and Video ) Accessibility Act of 2010 )
>>>> )
>>>> )
>>>> Petition for Waiver of Sections 716 and 717 ) of the Communications 
>>>> Act and Part 14 of the ) Commission's Rules Requiring Access to ) 
>>>> Advanced Communications Services (ACS) and ) Equipment by People with 
>>>> Disabilities )
>>>> To: Chief, Consumer and Governmental Affairs Bureau PETITION FOR 
>>>> WAIVER I. INTRODUCTION AND SUMMARY
>>>> Pursuant to 47 U.S.C. § 617(h)(1) and 47  C.F.R. §§ 1.3, 14.5, the 
>>>> Coalition of E-Reader Manufacturers
>>>> 1
>>>> (hereinafter, "Coalition") respectfully  requests that the 
>>>> Commission waive the accessibility requirements for equipment used 
>>>> for advanced communications services
>>>> (ACS) for
>>>> a single class of equipment: e-readers. This Petition demonstrates 
>>>> that e-readers are devices designed, built, and marketed for a single 
>>>> primary purpose: to read written material such as books, magazines, 
>>>> newspapers, and other text documents on a mobile electronic device.
>>>> The
>>>> public interest would be served by granting this petition because the 
>>>> theoretical ACS ability of e- readers is irrelevant to how the 
>>>> overwhelming majority of users actually use the devices.
>>>> Moreover, the features and content available on e-readers are 
>>>> available on a wide range of multi-
>>>> 1 The Coalition of E-Reader Manufacturers consists of 
>>>> <http://Amazon.com/>Amazon.com, Inc.; Kobo Inc.; and Sony Electronics 
>>>> Inc.
>>>> purpose equipment, including tablets, phones, and computers, all of 
>>>> which possess integrated audio, speakers, high computing processing 
>>>> power, and applications that are optimized for ACS.
>>>> As explained below, e-readers are a distinct  class of equipment 
>>>> built for the specific purpose of reading. They are designed with 
>>>> special features optimized for the reading experience and are 
>>>> marketed as devices for reading. Although they have a similar shape 
>>>> and size to general-purpose tablet computers, e-readers lack many of
>> tablets'
>>>> features for general-purpose computing, including ACS functions.
>>>> E-readers simply are not designed, built, or marketed for ACS, and 
>>>> the public understands the distinction between e-readers and 
>>>> general-purpose tablets.
>>>> Granting the petition is in the public interest because rendering ACS 
>>>> accessible on e-readers would require fundamentally altering the 
>>>> devices to be more like general-purpose tablets in cost, form factor, 
>>>> weight, user interface, and reduced battery life, and yet the 
>>>> necessary changes, if they were made, would not yield a meaningful 
>>>> benefit to individuals with disabilities.
>>>> II. E-READERS ARE A DISTINCT CLASS OF EQUIPMENT
>>>> The Commission requires that a class waiver be  applicable to a 
>>>> "carefully defined"
>>>> class
>>>> of devices that "share common defining characteristics."
>>>> 2
>>>> E-readers are such a class. E-readers, sometimes called e-book 
>>>> readers, are mobile electronic devices that are designed, marketed 
>>>> and used primarily for the purpose of reading digital documents,
>>>> including e-books and periodicals.
>>>> 3
>>>> The noteworthy features of e-readers include  electronic ink 
>>>> screens optimized for reading
>>>> 2 14 C.F.R. § 14.5(b); Implementation of Sections 716 and 717 of the 
>>>> Communications Act of 1934, as Enacted by the Twenty-First Century 
>>>> Communications and Video Accessibility Act of 2010, CG Docket No.
>>>> 10-213, WT Docket No. 96-168, CG Docket No. 10-145, Report and Order 
>>>> and Further Notice of Proposed Rulemaking, 26 FCC Rcd 14557, 14639
>>>> (2011) [hereinafter ACS Report and Order]; Implementation of Sections
>>>> 716 and 717 of the
>>>> Communications Act of 1934, as Enacted by the Twenty-First Century 
>>>> Communications and Video Accessibility Act of 2010, CEA, NCTA, ESA, 
>>>> Petitions for Class Waivers of Sections 716 and 717 of the 
>>>> Communications Act and Part 14 of the Commission's Rules Requiring 
>>>> Access to Advanced Communications Services (ACS) and Equipment by 
>>>> People with Disabilities, Order, 27 FCC Rcd 12970, 12973 (2012) 
>>>> [hereinafter Waiver Order].
>>>> 3 "An e-reader is an electronic reading device used to view books, 
>>>> magazines, and newspapers in a digital format."
>>>> What is an E-Reader?, wiseGEEK,
>>>> <http://www.wisegeek.com/what-is-an-E-reader.htm>http://www.wisegeek.
>>>> co
>>>> m/what-is-an-E-reader.htm
>>>> (last visited May 16, 2013).
>>>> (including in direct sunlight) and designed to minimize eye strain 
>>>> during extended reading sessions. They also facilitate acquisition of 
>>>> e-publications and their user interfaces, both hardware and software 
>>>> features, are designed around reading as the primary user function.
>>>> As
>>>> explained more fully below, another important aspect of e-readers is 
>>>> the features they do not contain, which distinguishes them from 
>>>> general purpose devices such as tablets. Examples of e- readers 
>>>> include the Amazon Kindle E-Reader, the Sony Reader, and the Kobo Glo.
>>>> In 2006, Sony launched the first e-reader  available in the U.S.
>>>> utilizing electronic ink, and since that time the number of 
>>>> manufacturers and models has expanded substantially.
>>>> 4
>>>> Seven
>>>> years is a long time in the modern digital age, and the public 
>>>> understands that although e-readers may be somewhat similar in shape 
>>>> and size to general-purpose tablets, e-readers are aimed at a 
>>>> specific function.
>>>> 5
>>>> The distinctions between e-readers and tablets are explored next.
>>>> 4 Michael Sauers, History of eBooks & eReaders, Technology Innovation 
>>>> Librarian, Nebraska Library Commission, (Oct. 14, 2011), 
>>>> <http://www.slideshare.net/nebraskaccess/history-of-e-books-ereaders>
>>>> ht tp://www.slideshare.net/nebraskaccess/history-of-e-books-ereaders
>>>> .
>>>> 5 Product buying guides commonly reflect this distinction. See, e.g., 
>>>> Brian Barrett,
>>>> 5 Ways Ereaders Are Still Better
>>>> Than Tablets, Gizmodo (Dec. 12, 2012), 
>>>> <http://gizmodo.com/5970460/5-ways-ereaders-are-still-better-than-tab
>>>> le
>>>> ts>http://gizmodo.com/5970460/5-ways-ereaders-are-still-better-than-t
>>>> ts>ab
>>>> lets
>>>> ;
>>>> Paul Reynolds, 5 Reasons to Buck the Tide and Buy an E-book Reader, 
>>>> <http://ConsumerReports.org/>ConsumerReports.org
>>>> (Apr. 22, 2013),
>>>> <http://news.consumerreports.org/electronics/2013/04/5-reasons-to-buc
>>>> k-
>>>> the-tide-and-buy-




More information about the Electronics-Talk mailing list