[nfbcs] Amazon and Sony Are Requesting That The Accessibility Requirement Be Waived for E-Book Readers

[Suzanne Germano]

Good thing Microsoft didn't add a screen reader. The screen reader wouldn't
have worked anyway. Their built in magnification is completely useless.


On Fri, Aug 9, 2013 at 11:16 PM, Gabe Vega Via Iphone4S <
theblindtech at gmail.com> wrote:

>  No, my iPhone dictation messed that message. But what I do know is that
> the nfb threatened to file a lawsuit against Microsoft if they went ahead
> and put a built-in screen reader into windows that would have possibly put
> out of business the other screen widowmakers. And this is documented and we
> all know it's true.
> Now, when it suits the nfb, why is it okay for them to just switch sides
> at whatever Wimbsley wish
>
> Gabe Vega
> Sent from my iPhone
> CEO
> Commtech LLC
> The leader of computer support, training and web development services
> Web: http://commtechusa.net
> Twitter: http://twitter.com/commtechllc
> Facebook: http://facebook.com/commtechllc
> Email: info at commtechusa.net
> Phone: (888) 351-5289 Ext. 710
> Fax: (480) 535-7649
>
> > On Aug 9, 2013, at 10:09 PM, Jim Barbour <jbar at barcore.com> wrote:
> >
> > Hey Gabe,
> >
> > Are you suggesting the NFB filed a lawsuit against Microsoft in
> > order to protect the business interests of the major screen reader
> > manufacturers?
> >
> > Jim
> >
> >> On Fri, Aug 09, 2013 at 07:54:59PM -0700, Gabe Vega Via Iphone4S wrote:
> >> Microsoft tried this am a late 90s, does anyone remember? Why is of the
> PNFP happens to always forget this fact. But it was the NFB (suit, if
> Microsoft made a screen reader, a full functioning screenwriter into
> windows. Triberg to protect freedom scientific and other screenwriter
> makers. But now that the design the Apple Leeds is all integral, now nfb
> wants to switch sides
> >>
> >> Gabe Vega
> >> Sent from my iPhone
> >> CEO
> >> Commtech LLC
> >> The leader of computer support, training and web development services
> >> Web: http://commtechusa.net
> >> Twitter: http://twitter.com/commtechllc
> >> Facebook: http://facebook.com/commtechllc
> >> Email: info at commtechusa.net
> >> Phone: (888) 351-5289 Ext. 710
> >> Fax: (480) 535-7649
> >>
> >>> On Aug 9, 2013, at 5:13 PM, Kevin Fjelsted <kfjelsted at gmail.com>
> wrote:
> >>>
> >>> Screen readers take very little resource if designed correctly.
> >>>
> >>> In fact if the display was eliminated and only audio was provided the
> cost could be lowered for the hardware including the processor.
> >>>
> >>> Design is key.
> >>> We have gotten used to the huge resources required by  JAWS as an
> example because of the outboard nonintegrated approach for that screen
> reader, i.e., it isn't integral  to windows.
> >>>
> >>> If Microsoft had prioritized designing screen reading into windows
> from the ground up
> >>> we would have over 90% of apps accessible and resources would be much
> better managed.
> >>> Regarding the eReader, more processing power is used trying to keep
> the visual experience smooth,, scrolling the pages, compensating for the
> change in font size either through the user expanding the font, or by
> varied styles in the book.
> >>>
> >>>> On Aug 9, 2013, at 7:02 PM, Jim Barbour <jbar at barcore.com> wrote:
> >>>>
> >>>> Hey Kevin,
> >>>>
> >>>> I take your point, but I don't really buy into it.
> >>>>
> >>>> We can talk about how to limit the device, but the original point
> >>>> remains the same.
> >>>>
> >>>> If the bandwidth of the wifi, or the capabilities of the CPU, or the
> >>>> amount of memory in the original design wouldn't support a screen
> >>>> reader, than Amazon will have two choices.  Find a way to opt out of
> >>>> accessibility or radically alter (and increase the price of) the
> >>>> device.
> >>>>
> >>>> I'd argue that the amount of technology needed to support larger fonts
> >>>> is far less than that needed to support a screen reader.
> >>>>
> >>>> Jim
> >>>>
> >>>>> On Fri, Aug 09, 2013 at 06:55:15PM -0500, Kevin Fjelsted wrote:
> >>>>> Requiring speakers or headphone just puts limits on the approach.
> >>>>> Remember when we were told that touch screens cannot be used by the
> BLind?
> >>>>> One way to get around the accessibility issue is to send the speech
> info out the same wireless that the books come in on i.e., such as via
> Airplay protocol, which can be picked up by many cell phones.
> >>>>> So much of the work is done in software that trying to classify a
> device by speakers…  has some import ants but it certainly should not be
> used as an excuse to avoid speech.
> >>>>> Perhaps we should take the reverse and ask that if accessibility is
> permitted to be removed that indeed it should be mandated as removed
> including the ability to have large print fonts.
> >>>>> After all, perhaps those with less than 20-20 vision don't really
> need to use these devices if so why permit the fonts to be made large
> enough for large print users?
> >>>>> Perhaps if a device is permitted not to be accessible then a
> descriptive label should be mandated i.e.,
> >>>>> "Reading tablet " not fore the BLind or anyone with less than 20-20
> vision" Caution, for those with 20-20 vision the font is small but
> readable, make sure to limit your use of the device to avoid eyestrain.
> >>>>> -Kevin
> >>>>>
> >>>>>> On Aug 9, 2013, at 6:44 PM, Jim Barbour <jbar at barcore.com> wrote:
> >>>>>>
> >>>>>> Aaron, I want to thank you very much for these talking points.  I
> hope
> >>>>>> you don't mind if I add to them.
> >>>>>>
> >>>>>> I agree with a lot of your commentary.
> >>>>>>
> >>>>>>> 1. E-readers are different than tablets.
> >>>>>>
> >>>>>> There is a real problem with this argument.  Amazon is trying to say
> >>>>>> that their e-readers are outside the definition of a tablet, but
> >>>>>> aren't defining how.  If this stands, it will be much easier for
> >>>>>> other hardware providers to say "hey, my thingy is a book reader too
> >>>>>> and not a tablet.  Pay no attention to those apps, they're just
> icing
> >>>>>> on the cake."
> >>>>>>
> >>>>>> I would actually be okay with the FCC saying that if it doesn't have
> >>>>>> speakers, headphone jack, and enough CPU/memory to support text to
> speech;
> >>>>>> then it's not a tablet.  That would include the paper white.
> >>>>>>
> >>>>>>> 2. E-readers are marketed and used for reading, and are not
> designed for accessibility, even on a secondary basis.
> >>>>>>
> >>>>>> I agree, this is not relevant to their case.
> >>>>>>
> >>>>>>> 3. Adding accessibility features would fundamentally alter the
> devices.
> >>>>>>
> >>>>>> I agree this isn't talked about in their submission.  If the device
> >>>>>> must be given speakers, a headphone jack, a larger CPU, and more
> RAM to
> >>>>>> support a screen reader and onboard text to speech, then it does
> alter
> >>>>>> the device.
> >>>>>>
> >>>>>>> 4. Adding such features would not help the blind or visually
> impaired, as they have alternatives.
> >>>>>>
> >>>>>> So, I don't think Amazon and Sony have standing to make this
> argument,
> >>>>>> but it is one that we should pay attention to.
> >>>>>>
> >>>>>> If we can read Kindle material using their tablet app, then we need
> >>>>>> to be very clear about why we're also asking for their hardware
> >>>>>> solutions to be made accessible.
> >>>>>>
> >>>>>> The reasons I'm aware of are...
> >>>>>>
> >>>>>> * Cost (paper white is significantly cheaper than an iPod touch)
> >>>>>> * Availability (blind students should be able to use the same
> hardware as their sighted counterparts)
> >>>>>>
> >>>>>> Are there other arguments to the point that we shuuld have access to
> >>>>>> hardware, as well as software, solutions?
> >>>>>>
> >>>>>> Jim
> >>>>>>
> >>>>>>>>> On 8/7/13, David Andrews <dandrews at visi.com> wrote:
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>> 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.com/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>
> http://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-tablets>
> http://gizmodo.com/5970460/5-ways-ereaders-are-still-better-than-tablets
> >>>>>>>>> ;
> >>>>>>>>> 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-buck-the-tide-and-buy-an-e-book-reader.html
> >
> http://news.consumerreports.org/electronics/2013/04/5-reasons-to-buck-the-tide-and-buy-an-e-book-reader.html
> >>>>>>>>> .
> >>>>>>>>> Wikipedia, an aggregator of knowledge and
> >>>>>>>>> therefore a useful measure of conventional
> >>>>>>>>> understanding, differentiates
> >>>>>>>>> e-readers from tablets, explaining that, among
> >>>>>>>>> other differences, “[t]ablet computers
> >>>>>>>>> . . . are more versatile, allowing
> >>>>>>>>> one to consume multiple types of content . . .
> >>>>>>>>> .” It states that “[a]n e-book reader,
> >>>>>>>>> also called an e-book device or e-
> >>>>>>>>> reader, is a mobile electronic device that is
> >>>>>>>>> designed primarily for the purpose
> >>>>>>>>> of reading digital e-books and
> >>>>>>>>> periodicals.” Wikipedia, E-Book Reader,
> >>>>>>>>> <http://en.wikipedia.org/wiki/E-reader>
> http://en.wikipedia.org/wiki/E-reader
> >>>>>>>>> (last visited May 16, 2013).
> >>>>>>>>> 6 47 C.F.R. § 14.5(a)(ii).
> >>>>>>>>> III. E-READERS ARE USED PRIMARILY FOR READING
> >>>>>>>>> E-readers are “designed primarily for purposes other than using”
> ACS.
> >>>>>>>>> 6
> >>>>>>>>> Specifically,
> >>>>>>>>> they are designed to be used for reading.
> >>>>>>>>> Moreover, they are marketed as tools for
> >>>>>>>>> reading, and
> >>>>>>>>> reading is their predominant use. Conversely,
> >>>>>>>>> e-readers are not designed or marketed
> >>>>>>>>> as tools for
> >>>>>>>>> using ACS.
> >>>>>>>>> A. E-Readers Are Designed and Marketed for Reading
> >>>>>>>>> In contrast to general-purpose tablets, the
> >>>>>>>>> features in e-readers are designed and
> >>>>>>>>> built
> >>>>>>>>> around reading as the primary function. Features
> >>>>>>>>> that e-readers possess for reading
> >>>>>>>>> optimization
> >>>>>>>>> include:
> >>>>>>>>> • Screens optimized to reduce eyestrain and prevent glare;
> >>>>>>>>> 7
> >>>>>>>>> • Low power consumption and extremely long
> >>>>>>>>> battery life to facilitate long reading
> >>>>>>>>> sessions and use during extended travel;
> >>>>>>>>> 8
> >>>>>>>>> • Navigation that place reading features,
> >>>>>>>>> including e-publication acquisition, front
> >>>>>>>>> and center;
> >>>>>>>>> 9
> >>>>>>>>> and
> >>>>>>>>> • Built-in reading tools such as highlighting,
> >>>>>>>>> bookmarking, and lookup features.
> >>>>>>>>> 10
> >>>>>>>>> 7 See Dr. Shirley Blanc, E-readers: Better for Your Eyes?,
> Medcan Clinic,
> >>>>>>>>> <http://www.medcan.com/articles/e->
> http://www.medcan.com/articles/e-
> >>>>>>>>> readers_better_for_your_eyes/
> >>>>>>>>> (last visited May 16, 2013) (“E-readers have
> >>>>>>>>> improved the level of text/background
> >>>>>>>>> contrast, and the matte quality of the screen
> >>>>>>>>> can reduce glare even in bright sunlight.”).
> >>>>>>>>> 8 See Greg Bensinger, The E-Reader Revolution:
> >>>>>>>>> Over Just as It Has Begun?, Wall St.
> >>>>>>>>> J., Jan. 4, 2013,
> >>>>>>>>> <
> http://online.wsj.com/article/SB10001424127887323874204578219834160573010.html
> >
> http://online.wsj.com/article/SB10001424127887323874204578219834160573010.html
> >>>>>>>>> (stating that compared to
> >>>>>>>>> tablets, “dedicated e-readers have . . . a
> >>>>>>>>> different style of display [that] improves
> >>>>>>>>> their battery life”).
> >>>>>>>>> 9 See John P. Falcone, Kindle vs. Nook vs. iPad:
> >>>>>>>>> Which E-book Reader Should You Buy?,
> >>>>>>>>> CNET (Dec. 17, 2012),
> >>>>>>>>> <
> http://news.cnet.com/8301-17938_105-20009738-1/kindle-vs-nook-vs-ipad-which-e-book-reader-should-you-buy/
> >
> http://news.cnet.com/8301-17938_105-20009738-1/kindle-vs-nook-vs-ipad-which-e-book-reader-should-you-buy/
> >>>>>>>>> (noting that an advantage of e-readers is
> >>>>>>>>> fewer distracting features not focused
> >>>>>>>>> on reading).
> >>>>>>>>> 10 See Levy Smith, Using a Kindle or eReader as
> >>>>>>>>> a Leadership Tool (Sept. 13, 2010),
> >>>>>>>>> <
> http://www.itsworthnoting.com/productivity/using-a-kindle-or-ereader-as-a-leadership-tool/
> >
> http://www.itsworthnoting.com/productivity/using-a-kindle-or-ereader-as-a-leadership-tool/
> >>>>>>>>> (“With an eReader, you
> >>>>>>>>> can effortlessly highlight and comment as you
> >>>>>>>>> read and either share quotes or musings
> >>>>>>>>> real time. . . .”).
> >>>>>>>>> 11 Falcone, supra note
> >>>>>>>>> 9
> >>>>>>>>> .
> >>>>>>>>> 12 See Barrett, supra note
> >>>>>>>>> 5
> >>>>>>>>> .
> >>>>>>>>> Product reviews emphasize the centrality of
> >>>>>>>>> reading to the design of e-readers.
> >>>>>>>>> For
> >>>>>>>>> instance, technology review site CNET explains
> >>>>>>>>> that “[i]f you want to stick with
> >>>>>>>>> ‘just reading’ . .
> >>>>>>>>> . an e-ink reader is probably your best bet.”
> >>>>>>>>> 11
> >>>>>>>>> Similarly, popular technology blog Gizmodo
> >>>>>>>>> explains that e-readers “do one thing well . . .
> >>>>>>>>> reading. And that’s a blessing.”
> >>>>>>>>> 12
> >>>>>>>>> Consistent with these features, e-readers are
> >>>>>>>>> marketed to readers with one activity
> >>>>>>>>> in
> >>>>>>>>> mind: reading. For example, on the Amazon
> >>>>>>>>> product listing for the 5th generation
> >>>>>>>>> Kindle E-
> >>>>>>>>> Reader, all nine bullets at the top of the page
> >>>>>>>>> describing the device contain phrases
> >>>>>>>>> referring to
> >>>>>>>>> books or reading, including “lighter than a
> >>>>>>>>> paperback,” “for easier reading,” “[r]eads
> >>>>>>>>> like paper,”
> >>>>>>>>> “[d]ownload books,” “[h]olds over 1,000 books,”
> >>>>>>>>> “[m]assive book selection,” “books
> >>>>>>>>> by best-
> >>>>>>>>> selling authors,” “[s]upports children’s books,” and “[l]ending
> >>>>>>>>> [l]ibrary.”
> >>>>>>>>> Reader, all nine bullets at the top of the page
> >>>>>>>>> describing the device contain phrases
> >>>>>>>>> referring to
> >>>>>>>>> books or reading, including “lighter than a
> >>>>>>>>> paperback,” “for easier reading,” “[r]eads
> >>>>>>>>> like paper,”
> >>>>>>>>> “[d]ownload books,” “[h]olds over 1,000 books,”
> >>>>>>>>> “[m]assive book selection,” “books
> >>>>>>>>> by best-
> >>>>>>>>> selling authors,” “[s]upports children’s books,” and “[l]ending
> >>>>>>>>> [l]ibrary.”
> >>>>>>>>> Reader, all nine bullets at the top of the page
> >>>>>>>>> describing the device contain phrases
> >>>>>>>>> referring to
> >>>>>>>>> books or reading, including “lighter than a
> >>>>>>>>> paperback,” “for easier reading,” “[r]eads
> >>>>>>>>> like paper,”
> >>>>>>>>> “[d]ownload books,” “[h]olds over 1,000 books,”
> >>>>>>>>> “[m]assive book selection,” “books
> >>>>>>>>> by best-
> >>>>>>>>> selling authors,” “[s]upports children’s books,” and “[l]ending
> >>>>>>>>> [l]ibrary.”
> >>>>>>>>> Reader, all nine bullets at the top of the page
> >>>>>>>>> describing the device contain phrases
> >>>>>>>>> referring to
> >>>>>>>>> books or reading, including “lighter than a
> >>>>>>>>> paperback,” “for easier reading,” “[r]eads
> >>>>>>>>> like paper,”
> >>>>>>>>> “[d]ownload books,” “[h]olds over 1,000 books,”
> >>>>>>>>> “[m]assive book selection,” “books
> >>>>>>>>> by best-
> >>>>>>>>> selling authors,” “[s]upports children’s books,” and “[l]ending
> >>>>>>>>> [l]ibrary.”
> >>>>>>>>> Reader, all nine bullets at the top of the page
> >>>>>>>>> describing the device contain phrases
> >>>>>>>>> referring to
> >>>>>>>>> books or reading, including “lighter than a
> >>>>>>>>> paperback,” “for easier reading,” “[r]eads
> >>>>>>>>> like paper,”
> >>>>>>>>> “[d]ownload books,” “[h]olds over 1,000 books,”
> >>>>>>>>> “[m]assive book selection,” “books
> >>>>>>>>> by best-
> >>>>>>>>> selling authors,” “[s]upports children’s books,” and “[l]ending
> >>>>>>>>> [l]ibrary.”
> >>>>>>>>> Reader, all nine bullets at the top of the page
> >>>>>>>>> describing the device contain phrases
> >>>>>>>>> referring to
> >>>>>>>>> books or reading, including “lighter than a
> >>>>>>>>> paperback,” “for easier reading,” “[r]eads
> >>>>>>>>> like paper,”
> >>>>>>>>> “[d]ownload books,” “[h]olds over 1,000 books,”
> >>>>>>>>> “[m]assive book selection,” “books
> >>>>>>>>> by best-
> >>>>>>>>> selling authors,” “[s]upports children’s books,” and “[l]ending
> >>>>>>>>> [l]ibrary.”
> >>>>>>>>> Reader, all nine bullets at the top of the page
> >>>>>>>>> describing the device contain phrases
> >>>>>>>>> referring to
> >>>>>>>>> books or reading, including “lighter than a
> >>>>>>>>> paperback,” “for easier reading,” “[r]eads
> >>>>>>>>> like paper,”
> >>>>>>>>> “[d]ownload books,” “[h]olds over 1,000 books,”
> >>>>>>>>> “[m]assive book selection,” “books
> >>>>>>>>> by best-
> >>>>>>>>> selling authors,” “[s]upports children’s books,” and “[l]ending
> >>>>>>>>> [l]ibrary.”
> >>>>>>>>> Reader, all nine bullets at the top of the page
> >>>>>>>>> describing the device contain phrases
> >>>>>>>>> referring to
> >>>>>>>>> books or reading, including “lighter than a
> >>>>>>>>> paperback,” “for easier reading,” “[r]eads
> >>>>>>>>> like paper,”
> >>>>>>>>> “[d]ownload books,” “[h]olds over 1,000 books,”
> >>>>>>>>> “[m]assive book selection,” “books
> >>>>>>>>> by best-
> >>>>>>>>> selling authors,” “[s]upports children’s books,” and “[l]ending
> >>>>>>>>> [l]ibrary.”
> >>>>>>>>> Reader, all nine bullets at the top of the page
> >>>>>>>>> describing the device contain phrases
> >>>>>>>>> referring to
> >>>>>>>>> books or reading, including “lighter than a
> >>>>>>>>> paperback,” “for easier reading,” “[r]eads
> >>>>>>>>> like paper,”
> >>>>>>>>> “[d]ownload books,” “[h]olds over 1,000 books,”
> >>>>>>>>> “[m]assive book selection,” “books
> >>>>>>>>> by best-
> >>>>>>>>> selling authors,” “[s]upports children’s books,” and “[l]ending
> >>>>>>>>> [l]ibrary.”
> >>>>>>>>> Reader, all nine bullets at the top of the page
> >>>>>>>>> describing the device contain phrases
> >>>>>>>>> referring to
> >>>>>>>>> books or reading, including “lighter than a
> >>>>>>>>> paperback,” “for easier reading,” “[r]eads
> >>>>>>>>> like paper,”
> >>>>>>>>> “[d]ownload books,” “[h]olds over 1,000 books,”
> >>>>>>>>> “[m]assive book selection,” “books
> >>>>>>>>> by best-
> >>>>>>>>> selling authors,” “[s]upports children’s books,” and “[l]ending
> >>>>>>>>> [l]ibrary.”
> >>>>>>>>> Reader, all nine bullets at the top of the page
> >>>>>>>>> describing the device contain phrases
> >>>>>>>>> referring to
> >>>>>>>>> books or reading, including “lighter than a
> >>>>>>>>> paperback,” “for easier reading,” “[r]eads
> >>>>>>>>> like paper,”
> >>>>>>>>> “[d]ownload books,” “[h]olds over 1,000 books,”
> >>>>>>>>> “[m]assive book selection,” “books
> >>>>>>>>> by best-
> >>>>>>>>> selling authors,” “[s]upports children’s books,” and “[l]ending
> >>>>>>>>> [l]ibrary.”
> >>>>>>>>> 13 Amazon Kindle 5th Generation E-Ink Product Listing,
> >>>>>>>>> <http://www.amazon.com/gp/product/B007HCCNJU/>
> http://www.amazon.com/gp/product/B007HCCNJU/
> >>>>>>>>> (last
> >>>>>>>>> visited May 16, 2013).
> >>>>>>>>> 14 Id.
> >>>>>>>>> 15 Kobo Aura HD Overview,
> >>>>>>>>> <http://www.kobo.com/koboaurahd>http://www.kobo.com/koboaurahd
> >>>>>>>>> (last visited May 16, 2013).
> >>>>>>>>> 16 Sony Reader,
> >>>>>>>>> <https://ebookstore.sony.com/reader/>
> https://ebookstore.sony.com/reader/
> >>>>>>>>> (last visited May 16, 2013).
> >>>>>>>>> 17 Sony Reader Product Listing,
> >>>>>>>>> <
> http://store.sony.com/webapp/wcs/stores/servlet/CategoryDisplay?catalogId=10551&storeId=10151&langId=-
> >
> http://store.sony.com/webapp/wcs/stores/servlet/CategoryDisplay?catalogId=10551&storeId=10151&langId=-
> >>>>>>>>> 1&identifier=S_Portable_Reader
> >>>>>>>>> (last visited May 16, 2013).
> >>>>>>>>> 18 Ofcom, Communications Market Report 2012, at 7 (July 18,
> 2012),
> >>>>>>>>> <
> http://stakeholders.ofcom.org.uk/binaries/research/cmr/cmr12/CMR_UK_2012.pdf
> >
> http://stakeholders.ofcom.org.uk/binaries/research/cmr/cmr12/CMR_UK_2012.pdf
> >>>>>>>>> .
> >>>>>>>>> Not surprisingly based on this design and
> >>>>>>>>> marketing, e-readers are used overwhelmingly
> >>>>>>>>> for reading. An Ofcom analysis on the
> >>>>>>>>> communications marketplace in the U.K. states
> >>>>>>>>> that
> >>>>>>>>> “almost all consumers use their e-reader to read books.”
> >>>>>>>>> 18
> >>>>>>>>> Indicative of the utility of e-readers
> >>>>>>>>> for reading, multiple studies show that reading
> >>>>>>>>> electronically on an e-reader increases
> >>>>>>>>> the amount
> >>>>>>>>> of time individuals spend reading.
> >>>>>>>>> for reading, multiple studies show that reading
> >>>>>>>>> electronically on an e-reader increases
> >>>>>>>>> the amount
> >>>>>>>>> of time individuals spend reading.
> >>>>>>>>> for reading, multiple studies show that reading
> >>>>>>>>> electronically on an e-reader increases
> >>>>>>>>> the amount
> >>>>>>>>> of time individuals spend reading.
> >>>>>>>>> 19 See id. (“E-readers have a positive impact on
> >>>>>>>>> the amount people read.”); Lee Rainie
> >>>>>>>>> et al., Pew Internet &
> >>>>>>>>> American Life Project, The Rise of E-Reading, Apr. 4, 2012,
> >>>>>>>>> <http://libraries.pewinternet.org/2012/04/04/the-rise-of->
> http://libraries.pewinternet.org/2012/04/04/the-rise-of-
> >>>>>>>>> e-reading/
> >>>>>>>>> (“On any given day 56% of those who own e-book
> >>>>>>>>> reading devices are reading a book,
> >>>>>>>>> compared with
> >>>>>>>>> 45% of the general book-reading public who are
> >>>>>>>>> reading a book on a typical day.”);
> >>>>>>>>> Geoffrey A. Fowler & Marie C.
> >>>>>>>>> Baca, The ABCs of E-Reading, Wall St. J., Aug. 24, 2010,
> >>>>>>>>> <
> http://online.wsj.com/article/SB10001424052748703846604575448093175758872.html
> >
> http://online.wsj.com/article/SB10001424052748703846604575448093175758872.html
> >>>>>>>>> (explaining that a study of
> >>>>>>>>> 1,200 e-reader owners by Marketing and Research
> >>>>>>>>> Resources Inc. concludes that “[p]eople
> >>>>>>>>> who buy e-readers tend
> >>>>>>>>> to spend more time than ever with their nose in a book.”).
> >>>>>>>>> 20 Bensinger, supra note
> >>>>>>>>> 8
> >>>>>>>>> .
> >>>>>>>>> 21 Piotr Kowalczyk, These 12 Questions Will Help
> >>>>>>>>> You Choose Between Tablet and E-reader,
> >>>>>>>>> eBook Friendly (Apr.
> >>>>>>>>> 8, 2013),
> >>>>>>>>>
> >>>>>>>>> <
> http://ebookfriendly.com/2013/04/08/tablet-or-ereader-questionnaire/>
> http://ebookfriendly.com/2013/04/08/tablet-or-ereader-questionnaire/
> >>>>>>>>> (“E-paper screens are not meant for
> >>>>>>>>> active usage – their refresh rate is too low.”).
> >>>>>>>>> 22 Bensinger, supra note
> >>>>>>>>> 8
> >>>>>>>>> (stating that, unlike e-readers, “ever cheaper
> >>>>>>>>> tablet computers can be used . .
> >>>>>>>>> . as Web
> >>>>>>>>> browsers, game consoles and cameras”).
> >>>>>>>>> 23 See, e.g., Kindle 5th Generation E-Ink, supra note
> >>>>>>>>> 13
> >>>>>>>>> (comparing hard drive capacities of Kindle e-reader versus
> >>>>>>>>> tablet devices).
> >>>>>>>>> 24 See, e.g., id.
> >>>>>>>>> B. E-Readers Are Not Designed or Marketed for ACS
> >>>>>>>>> E-readers are not general-purpose devices and
> >>>>>>>>> lack the features and broad capabilities
> >>>>>>>>> of
> >>>>>>>>> tablets. Instead, as discussed above, they are
> >>>>>>>>> optimized only for reading and obtaining
> >>>>>>>>> reading
> >>>>>>>>> material. Features common to tablets that e-readers consistently
> lack
> >>>>>>>>> include:
> >>>>>>>>> • Color screens;
> >>>>>>>>> 20
> >>>>>>>>> • Screens with fast refresh rates sufficient for interaction and
> video;
> >>>>>>>>> 21
> >>>>>>>>> • Cameras;
> >>>>>>>>> 22
> >>>>>>>>> • High-capacity storage sufficient for multimedia files;
> >>>>>>>>> 23
> >>>>>>>>> and
> >>>>>>>>> • Higher-powered CPU processors and GPU processors for
> accelerated
> >>>>>>>>> graphics.
> >>>>>>>>> 24
> >>>>>>>>> Additionally, e-readers typically do not possess
> >>>>>>>>> microphones or quality speakers.
> >>>>>>>>> Examination of an e-reader establishes that
> >>>>>>>>> these devices are not designed with
> >>>>>>>>> ACS as
> >>>>>>>>> an intended feature, even on a secondary basis.
> >>>>>>>>> These purposeful hardware limitations
> >>>>>>>>> drive e-
> >>>>>>>>> readers’ primary purpose: reading. As a result,
> >>>>>>>>> e-readers cannot display videos at
> >>>>>>>>> an acceptable
> >>>>>>>>> quality, and most cannot generate audio output or record audio
> input.
> >>>>>>>>> readers’ primary purpose: reading. As a result,
> >>>>>>>>> e-readers cannot display videos at
> >>>>>>>>> an acceptable
> >>>>>>>>> quality, and most cannot generate audio output or record audio
> input.
> >>>>>>>>> readers’ primary purpose: reading. As a result,
> >>>>>>>>> e-readers cannot display videos at
> >>>>>>>>> an acceptable
> >>>>>>>>> quality, and most cannot generate audio output or record audio
> input.
> >>>>>>>>> readers’ primary purpose: reading. As a result,
> >>>>>>>>> e-readers cannot display videos at
> >>>>>>>>> an acceptable
> >>>>>>>>> quality, and most cannot generate audio output or record audio
> input.
> >>>>>>>>> readers’ primary purpose: reading. As a result,
> >>>>>>>>> e-readers cannot display videos at
> >>>>>>>>> an acceptable
> >>>>>>>>> quality, and most cannot generate audio output or record audio
> input.
> >>>>>>>>> readers’ primary purpose: reading. As a result,
> >>>>>>>>> e-readers cannot display videos at
> >>>>>>>>> an acceptable
> >>>>>>>>> quality, and most cannot generate audio output or record audio
> input.
> >>>>>>>>> readers’ primary purpose: reading. As a result,
> >>>>>>>>> e-readers cannot display videos at
> >>>>>>>>> an acceptable
> >>>>>>>>> quality, and most cannot generate audio output or record audio
> input.
> >>>>>>>>> 25 Staples, Tablet Versus eReader,
> >>>>>>>>> <http://www.staples.com/sbd/cre/marketing/technology-research->
> http://www.staples.com/sbd/cre/marketing/technology-research-
> >>>>>>>>> centers/tablets/tablets-versus-ereaders.html
> >>>>>>>>> (last visited May 16, 2013) (“Tablets give you far more options
> for
> >>>>>>>>> multimedia as well. They can upload and play
> >>>>>>>>> audio and of course video . . . .”).
> >>>>>>>>> 26 See, e.g., Kowalczyk, supra note
> >>>>>>>>> 21
> >>>>>>>>> (“You can use [tablets] for other
> >>>>>>>>> [non-reading] purposes, like emails, social
> >>>>>>>>> media, web browsing, video, games.”).
> >>>>>>>>> 27 Bensinger, supra note
> >>>>>>>>> 8
> >>>>>>>>> (stating that e-readers have “more-limited
> >>>>>>>>> capabilities, which often include monochrome
> >>>>>>>>> screens and rudimentary Web surfing” while
> >>>>>>>>> “[t]ablet computers . . . have . . . full
> >>>>>>>>> Web browsing.”).
> >>>>>>>>> 28 See, e.g., Kindle 5th Generation E-Ink, supra note
> >>>>>>>>> 13
> >>>>>>>>> ; Kobo Aura HD, supra note
> >>>>>>>>> 15
> >>>>>>>>> ; Sony Reader Product
> >>>>>>>>> Listing, supra note
> >>>>>>>>> 17
> >>>>>>>>> . Kindle e-readers offer a feature by which
> >>>>>>>>> users and their pre-approved contacts
> >>>>>>>>> can e-mail
> >>>>>>>>> pre-existing document so that the documents can
> >>>>>>>>> be read on the Kindle. However, this
> >>>>>>>>> is a feature to facilitate
> >>>>>>>>> reading of pre-existing documents in an E-Ink
> >>>>>>>>> format; it is not marketed as or useful
> >>>>>>>>> as a tool for real-time or near
> >>>>>>>>> real-time text-based communication between
> >>>>>>>>> individuals. See Kindle 5th Generation
> >>>>>>>>> E-Ink, supra note
> >>>>>>>>> 13
> >>>>>>>>> .
> >>>>>>>>> E-readers are not marketed based on their
> >>>>>>>>> ability to access ACS. The webpage listings
> >>>>>>>>> for e-readers do not mention or describe any ACS
> >>>>>>>>> features such as e-mail, instant
> >>>>>>>>> messaging,
> >>>>>>>>> calling, VoIP, or interoperable video conferencing (or video at
> all).
> >>>>>>>>> 28
> >>>>>>>>> That is consistent with the
> >>>>>>>>> fact that e-readers are marketed as devices for
> >>>>>>>>> reading, not for general-purpose
> >>>>>>>>> use. In fact,
> >>>>>>>>> many view the absence of robust communication
> >>>>>>>>> tools on e-readers as a welcome break
> >>>>>>>>> from
> >>>>>>>>> distraction rather than as a limitation. For
> >>>>>>>>> instance, Paul Reynolds of Consumer
> >>>>>>>>> Reports
> >>>>>>>>> explains that “I read with fewer interruptions
> >>>>>>>>> (so more rapidly) on a reader--since
> >>>>>>>>> I can’t as
> >>>>>>>>> easily distract myself by checking e-mail or
> >>>>>>>>> news headlines with a tap or two.”
> >>>>>>>>> many view the absence of robust communication
> >>>>>>>>> tools on e-readers as a welcome break
> >>>>>>>>> from
> >>>>>>>>> distraction rather than as a limitation. For
> >>>>>>>>> instance, Paul Reynolds of Consumer
> >>>>>>>>> Reports
> >>>>>>>>> explains that “I read with fewer interruptions
> >>>>>>>>> (so more rapidly) on a reader--since
> >>>>>>>>> I can’t as
> >>>>>>>>> easily distract myself by checking e-mail or
> >>>>>>>>> news headlines with a tap or two.”
> >>>>>>>>> many view the absence of robust communication
> >>>>>>>>> tools on e-readers as a welcome break
> >>>>>>>>> from
> >>>>>>>>> distraction rather than as a limitation. For
> >>>>>>>>> instance, Paul Reynolds of Consumer
> >>>>>>>>> Reports
> >>>>>>>>> explains that “I read with fewer interruptions
> >>>>>>>>> (so more rapidly) on a reader--since
> >>>>>>>>> I can’t as
> >>>>>>>>> easily distract myself by checking e-mail or
> >>>>>>>>> news headlines with a tap or two.”
> >>>>>>>>> many view the absence of robust communication
> >>>>>>>>> tools on e-readers as a welcome break
> >>>>>>>>> from
> >>>>>>>>> distraction rather than as a limitation. For
> >>>>>>>>> instance, Paul Reynolds of Consumer
> >>>>>>>>> Reports
> >>>>>>>>> explains that “I read with fewer interruptions
> >>>>>>>>> (so more rapidly) on a reader--since
> >>>>>>>>> I can’t as
> >>>>>>>>> easily distract myself by checking e-mail or
> >>>>>>>>> news headlines with a tap or two.”
> >>>>>>>>> many view the absence of robust communication
> >>>>>>>>> tools on e-readers as a welcome break
> >>>>>>>>> from
> >>>>>>>>> distraction rather than as a limitation. For
> >>>>>>>>> instance, Paul Reynolds of Consumer
> >>>>>>>>> Reports
> >>>>>>>>> explains that “I read with fewer interruptions
> >>>>>>>>> (so more rapidly) on a reader--since
> >>>>>>>>> I can’t as
> >>>>>>>>> easily distract myself by checking e-mail or
> >>>>>>>>> news headlines with a tap or two.”
> >>>>>>>>> many view the absence of robust communication
> >>>>>>>>> tools on e-readers as a welcome break
> >>>>>>>>> from
> >>>>>>>>> distraction rather than as a limitation. For
> >>>>>>>>> instance, Paul Reynolds of Consumer
> >>>>>>>>> Reports
> >>>>>>>>> explains that “I read with fewer interruptions
> >>>>>>>>> (so more rapidly) on a reader--since
> >>>>>>>>> I can’t as
> >>>>>>>>> easily distract myself by checking e-mail or
> >>>>>>>>> news headlines with a tap or two.”
> >>>>>>>>> many view the absence of robust communication
> >>>>>>>>> tools on e-readers as a welcome break
> >>>>>>>>> from
> >>>>>>>>> distraction rather than as a limitation. For
> >>>>>>>>> instance, Paul Reynolds of Consumer
> >>>>>>>>> Reports
> >>>>>>>>> explains that “I read with fewer interruptions
> >>>>>>>>> (so more rapidly) on a reader--since
> >>>>>>>>> I can’t as
> >>>>>>>>> easily distract myself by checking e-mail or
> >>>>>>>>> news headlines with a tap or two.”
> >>>>>>>>> 29 Reynolds, supra note
> >>>>>>>>> 5
> >>>>>>>>> .
> >>>>>>>>> 30 Falcone, supra note
> >>>>>>>>> 9
> >>>>>>>>> . Another reviewer states, “I’m not interested
> >>>>>>>>> in the tablet e-readers; I want a
> >>>>>>>>> dedicated
> >>>>>>>>> reading device without the distraction of
> >>>>>>>>> Twitter or games or email. I want the contrast
> >>>>>>>>> and readability of e Ink. I
> >>>>>>>>> want access to the best and most varied content.
> >>>>>>>>> I want a battery life the length
> >>>>>>>>> of War and Peace (months). I want a
> >>>>>>>>> device that is light in the hand . . . .” Laura
> >>>>>>>>> Jane, This is My Next: Kindle Paperwhite,
> >>>>>>>>> The Verge (Sept. 6, 2012),
> >>>>>>>>> <
> http://www.theverge.com/2012/9/6/3298500/this-is-my-next-kindle-paperwhite
> >
> http://www.theverge.com/2012/9/6/3298500/this-is-my-next-kindle-paperwhite
> >>>>>>>>> .
> >>>>>>>>> 31 John Cook, Kobo Opens a New Chapter,
> >>>>>>>>> Introduces ‘Touch’ To E-reader, Geekwire
> >>>>>>>>> (May 23, 2011),
> >>>>>>>>> <
> http://www.geekwire.com/2011/chapter-electronic-readers-kobo-introduces-touch-electronic-readers/
> >
> http://www.geekwire.com/2011/chapter-electronic-readers-kobo-introduces-touch-electronic-readers/
> >>>>>>>>> .
> >>>>>>>>> IV. THE REQUESTED WAIVER WILL ADVANCE THE PUBLIC INTEREST
> >>>>>>>>> Rendering ACS accessible on e-readers would
> >>>>>>>>> require fundamentally altering the devices
> >>>>>>>>> and it may not be possible to meet that
> >>>>>>>>> requirement and maintain e-readers as inexpensive
> >>>>>>>>> mobile reading devices, and yet the necessary
> >>>>>>>>> changes, if they were made, would not
> >>>>>>>>> yield a
> >>>>>>>>> meaningful benefit to individuals with
> >>>>>>>>> disabilities. As described above, e-readers
> >>>>>>>>> are not
> >>>>>>>>> designed to provide ACS features and
> >>>>>>>>> applications. Any consumer who uses a browser
> >>>>>>>>> on an e-
> >>>>>>>>> reader to access ACS would have a very
> >>>>>>>>> low-quality experience. Rendering ACS accessible
> >>>>>>>>> for
> >>>>>>>>> disabled persons on e-readers would impose
> >>>>>>>>> substantial and ongoing engineering, hardware,
> >>>>>>>>> and
> >>>>>>>>> licensing costs because the devices would first
> >>>>>>>>> have to be redesigned and optimized
> >>>>>>>>> for ACS. It
> >>>>>>>>> would be necessary to add hardware such as
> >>>>>>>>> speakers, more powerful processors, and
> >>>>>>>>> faster-
> >>>>>>>>> refreshing screens. It also would be necessary
> >>>>>>>>> to revise the software interface in
> >>>>>>>>> e-readers to
> >>>>>>>>> build in infrastructure for ACS and then render
> >>>>>>>>> that infrastructure accessible. In
> >>>>>>>>> short, the
> >>>>>>>>> mandate would be to convert e-readers into
> >>>>>>>>> something they are not: a general purpose
> >>>>>>>>> device.
> >>>>>>>>> It is not merely cost but the very nature of a
> >>>>>>>>> specialized e-reader device that
> >>>>>>>>> is at issue.
> >>>>>>>>> Adding a substantial range of hardware and new
> >>>>>>>>> software changes the fundamental nature
> >>>>>>>>> of e-
> >>>>>>>>> reader devices. A requirement to make these
> >>>>>>>>> changes would alter the devices’ form
> >>>>>>>>> factor,
> >>>>>>>>> weight, and battery life and could undercut the
> >>>>>>>>> distinctive features, advantages,
> >>>>>>>>> price point, and
> >>>>>>>>> viability of e-readers. In particular, the
> >>>>>>>>> higher power consumption necessary to
> >>>>>>>>> support a faster
> >>>>>>>>> refresh rate necessary for high-interaction
> >>>>>>>>> activities such as email would put e-reader
> >>>>>>>>> power
> >>>>>>>>> consumption on par with that of a tablet,
> >>>>>>>>> whereas today the lower power consumption
> >>>>>>>>> and
> >>>>>>>>> resulting far-longer battery life of e-readers is a key selling
> point.
> >>>>>>>>> As a result of all of these changes, e-readers
> >>>>>>>>> would be far more similar to general-purpose
> >>>>>>>>> tablets in design, features, battery life, and
> >>>>>>>>> cost, possibly rendering single-purpose
> >>>>>>>>> devices
> >>>>>>>>> redundant. Today, many Americans choose to own
> >>>>>>>>> both a tablet and an e-reader. According
> >>>>>>>>> to a
> >>>>>>>>> recent Pew study, as of November 2012, 19% of
> >>>>>>>>> Americans age 16 and older own an e-reader,
> >>>>>>>>> 25% own a tablet, and 11% own both an e-reader and a tablet.
> >>>>>>>>> 32
> >>>>>>>>> Consistent with this purchasing
> >>>>>>>>> pattern, Gizmodo warns its readers, “don’t
> >>>>>>>>> assume that because you have [a tablet],
> >>>>>>>>> you don’t
> >>>>>>>>> 32 Lee Rainie & Maeve Duggan, E-book Reading
> >>>>>>>>> Jumps; Print Book Reading Declines,
> >>>>>>>>> Pew Internet & American
> >>>>>>>>> Life Project, Dec. 27, 2012,
> >>>>>>>>> <
> http://libraries.pewinternet.org/2012/12/27/e-book-reading-jumps-print-book-reading-
> >
> http://libraries.pewinternet.org/2012/12/27/e-book-reading-jumps-print-book-reading-
> >>>>>>>>> declines/
> >>>>>>>>> .
> >>>>>>>>> need [an e-reader].”
> >>>>>>>>> need [an e-reader].”
> >>>>>>>>> need [an e-reader].”
> >>>>>>>>> need [an e-reader].”
> >>>>>>>>> need [an e-reader].”
> >>>>>>>>> need [an e-reader].”
> >>>>>>>>> need [an e-reader].”
> >>>>>>>>> 33 Barrett, supra note
> >>>>>>>>> 5
> >>>>>>>>> . As explained below, this quote does not apply
> >>>>>>>>> to individuals who are blind or have
> >>>>>>>>> low
> >>>>>>>>> vision, for whom e-readers do not provide
> >>>>>>>>> additional functionality that is not available
> >>>>>>>>> from a more versatile
> >>>>>>>>> smartphone or tablet.
> >>>>>>>>> 34 Innovations developed for e-readers in recent
> >>>>>>>>> years include that “[t]he devices
> >>>>>>>>> looked sleeker, they were easier to
> >>>>>>>>> read, they weighed less, their pages turned
> >>>>>>>>> faster, and they held more books. Wireless
> >>>>>>>>> capability allowed users to
> >>>>>>>>> download novels, magazines and newspapers
> >>>>>>>>> wherever they were, whenever they wanted,
> >>>>>>>>> and now the devices
> >>>>>>>>> allow for reading in the dark.” Bensinger, supra note
> >>>>>>>>> 8
> >>>>>>>>> . More recently, “[t]here have also been major improvements
> >>>>>>>>> in e-readers, including touch-screen technology
> >>>>>>>>> and self-lighting screens.” Id.
> >>>>>>>>> 35 The Commission has recognized that “if the
> >>>>>>>>> inclusion of an accessibility feature
> >>>>>>>>> in a product or service results in a
> >>>>>>>>> fundamental alteration of that product or
> >>>>>>>>> service, then it is per se not achievable
> >>>>>>>>> to include that accessibility
> >>>>>>>>> function.” ACS Report and Order, 26 FCC Rcd at
> >>>>>>>>> 14610. The House Report similarly
> >>>>>>>>> states that “if the inclusion
> >>>>>>>>> of a feature in a product or service results in
> >>>>>>>>> a fundamental alteration of that
> >>>>>>>>> service or product, it is per se not
> >>>>>>>>> achievable to include that feature.” H.R. Rep.
> >>>>>>>>> No. 111-563, at 24-25 (2010) (“House
> >>>>>>>>> Report”). While the
> >>>>>>>>> achievability and primary purpose waiver
> >>>>>>>>> analyses differ, this demonstrates that
> >>>>>>>>> Congress and the Commission
> >>>>>>>>> recognize that requiring a fundamental
> >>>>>>>>> alteration is not in the public interest or
> >>>>>>>>> consistent with the CVAA.
> >>>>>>>>> 36 House Report at 26; S. Rep. No. 111-386, at 8 (2010).
> >>>>>>>>> In enacting the CVAA, Congress did not intend
> >>>>>>>>> to mandate the effective elimination
> >>>>>>>>> of a
> >>>>>>>>> niche product primarily designed for non-ACS
> >>>>>>>>> uses merely because of the presence
> >>>>>>>>> of an
> >>>>>>>>> ancillary browser purpose-built to support
> >>>>>>>>> reading activities on some devices within
> >>>>>>>>> the class.
> >>>>>>>>> As both the Senate and House Reports explained
> >>>>>>>>> in describing the primary purpose
> >>>>>>>>> waiver
> >>>>>>>>> provision embodied in Section 716(h), “[f]or
> >>>>>>>>> example, a device designed for a purpose
> >>>>>>>>> unrelated
> >>>>>>>>> to accessing advanced communications might also
> >>>>>>>>> provide, on an incidental basis,
> >>>>>>>>> access to such
> >>>>>>>>> services. In this case, the Commission may find
> >>>>>>>>> that to promote technological innovation
> >>>>>>>>> the
> >>>>>>>>> accessibility requirements need not apply.”
> >>>>>>>>> 36
> >>>>>>>>> The example of e-readers is just the “incidental
> >>>>>>>>> basis” ACS that Congress intended for the waiver provision to
> encompass.
> >>>>>>>>> Finally, rendering e-readers accessible would
> >>>>>>>>> not substantially benefit individuals
> >>>>>>>>> with
> >>>>>>>>> disabilities. Persons with disabilities,
> >>>>>>>>> including individuals who are blind and
> >>>>>>>>> wish to access e-
> >>>>>>>>> books and other electronic publications, would
> >>>>>>>>> have a poor ACS experience even on
> >>>>>>>>> accessible
> >>>>>>>>> e-reader devices. Because of the inherent
> >>>>>>>>> limitations of browsers in e-readers, a
> >>>>>>>>> fact that will not
> >>>>>>>>> change without a wholesale redesign of
> >>>>>>>>> e-readers, the ACS experience on such devices
> >>>>>>>>> is
> >>>>>>>>> suboptimal whether a user has disabilities or not.
> >>>>>>>>> Further, individuals with disabilities have
> >>>>>>>>> accessible options today, and these
> >>>>>>>>> options will
> >>>>>>>>> soon expand significantly even if the waiver is
> >>>>>>>>> granted. For the niche purpose of
> >>>>>>>>> reading, high-
> >>>>>>>>> quality free alternatives to e-readers are
> >>>>>>>>> available. The free Kindle Reading, Sony
> >>>>>>>>> Reader, and
> >>>>>>>>> Kobo eReading apps, which provide access to the
> >>>>>>>>> same range of e-publications available
> >>>>>>>>> to the
> >>>>>>>>> owners of the respective companies’ e-readers
> >>>>>>>>> (and in some cases a greater range),
> >>>>>>>>> are available
> >>>>>>>>> for free on an array of mobile phones, tablets, PCs, and Macs.
> >>>>>>>>> 37
> >>>>>>>>> Makers of tablets, smartphones,
> >>>>>>>>> and computers are working actively to make their
> >>>>>>>>> general-purpose audio-enabled devices
> >>>>>>>>> accessible, consistent with the CVAA. As
> >>>>>>>>> required by the CVAA, ACS will be accessible
> >>>>>>>>> on
> >>>>>>>>> these devices, all of which have integrated
> >>>>>>>>> audio, speakers, high computing processing
> >>>>>>>>> power,
> >>>>>>>>> and applications that are optimized for ACS.
> >>>>>>>>> Moreover, the accessibility that is
> >>>>>>>>> required by the
> >>>>>>>>> CVAA will ensure that many of the “layers” of
> >>>>>>>>> these devices will support and provide
> >>>>>>>>> accessibility features and capabilities that are
> >>>>>>>>> of value beyond the purely ACS context.
> >>>>>>>>> 38
> >>>>>>>>> Put
> >>>>>>>>> simply, individuals with disabilities have
> >>>>>>>>> better ACS options on devices other than
> >>>>>>>>> e-readers.
> >>>>>>>>> 37 Falcone, supra note
> >>>>>>>>> 9
> >>>>>>>>> . Additionally, users can read books via the Web
> >>>>>>>>> on all of the services but Sony
> >>>>>>>>> Reader. Id.
> >>>>>>>>> 38 See ACS Report and Order, 26 FCC Rcd at
> >>>>>>>>> 14584-85 (identifying eight key “layers”
> >>>>>>>>> of devices and explaining
> >>>>>>>>> that “[f]or individuals with disabilities to use
> >>>>>>>>> an advanced communications service,
> >>>>>>>>> all of these components may
> >>>>>>>>> have to support accessibility features and capabilities”).
> >>>>>>>>> A waiver of the Commission’s rule is justified
> >>>>>>>>> because, in contrast to other classes
> >>>>>>>>> of
> >>>>>>>>> equipment for which temporary waivers have been
> >>>>>>>>> granted, e-readers are a well-established
> >>>>>>>>> class
> >>>>>>>>> that is not experiencing “convergence” toward becoming a
> multipurpose
> >>>>>>>>> device.
> >>>>>>>>> that is not experiencing “convergence” toward becoming a
> multipurpose
> >>>>>>>>> device.
> >>>>>>>>> that is not experiencing “convergence” toward becoming a
> multipurpose
> >>>>>>>>> device.
> >>>>>>>>> that is not experiencing “convergence” toward becoming a
> multipurpose
> >>>>>>>>> device.
> >>>>>>>>> that is not experiencing “convergence” toward becoming a
> multipurpose
> >>>>>>>>> device.
> >>>>>>>>> that is not experiencing “convergence” toward becoming a
> multipurpose
> >>>>>>>>> device.
> >>>>>>>>> that is not experiencing “convergence” toward becoming a
> multipurpose
> >>>>>>>>> device.
> >>>>>>>>> 39 Cf. Waiver Order, 27 FCC Rcd at 12977-78,
> >>>>>>>>> 12981, 12990-91 (describing possibility
> >>>>>>>>> of convergence in classes of
> >>>>>>>>> devices for which waivers were granted).
> >>>>>>>>> 40 Moreover, it is generally expected that
> >>>>>>>>> demand for e-readers will continue well
> >>>>>>>>> into the future. One study by the
> >>>>>>>>> Market Intelligence & Consulting Institute
> >>>>>>>>> projects 23.0 million units of e-reader
> >>>>>>>>> sales worldwide in 2016. See
> >>>>>>>>> eMarketer, Ereader Shipments on the Rise (Nov. 8, 2012),
> >>>>>>>>> <http://www.emarketer.com/Article/Ereader-Shipments->
> http://www.emarketer.com/Article/Ereader-Shipments-
> >>>>>>>>> on-Rise/1009471
> >>>>>>>>> . A different study by IHS iSuppli projects
> >>>>>>>>> worldwide sales of e-readers at 7.1 million
> >>>>>>>>> units in
> >>>>>>>>> 2016. See Barrett, supra note
> >>>>>>>>> 5
> >>>>>>>>> . Assessing the more pessimistic of these
> >>>>>>>>> studies, Gizmodo concludes that e-readers
> >>>>>>>>> are “great, they’re cheap, and they're not going anywhere.” Id.
> >>>>>>>>> 41 Accordingly, a waiver that extends across
> >>>>>>>>> multiple generations is justified. See
> >>>>>>>>> ACS Report and Order, 26 FCC
> >>>>>>>>> Rcd at 14640.
> >>>>>>>>> * * *
> >>>>>>>>> For the reasons set forth above, and
> >>>>>>>>> consistent with Section 716 of the Act and
> >>>>>>>>> the
> >>>>>>>>> Commission’s rules, the Coalition requests that
> >>>>>>>>> the Commission grant the e-reader
> >>>>>>>>> class waiver,
> >>>>>>>>> as is consistent with the public interest.
> >>>>>>>>> Respectfully submitted,
> >>>>>>>>> Gerard J. Waldron
> >>>>>>>>> Daniel H. Kahn
> >>>>>>>>> COVINGTON & BURLING LLP
> >>>>>>>>> 1201 Pennsylvania Avenue NW
> >>>>>>>>> Washington, D.C. 20004-2401
> >>>>>>>>> (202) 662-6000
> >>>>>>>>> Counsel for <http://Amazon.com/>Amazon.com, Inc.; Kobo Inc.;
> >>>>>>>>> and Sony Electronics Inc.
> >>>>>>>>> May 16, 2013
> >>>>>>>>> Displaying 2 comments.
> >>>>>>>>>
> >>>>>>>>> <http://www.blindbargains.com/view.php?u=1260>jcast yesterday
> 11:53 PM ET:
> >>>>>>>>>
> >>>>>>>>> To me, there seems to be no excuse for leave
> >>>>>>>>> accessibility out of these devices. The claim
> >>>>>>>>> that incorporating accessibility will make the
> >>>>>>>>> e-book readers heavier and have less battery
> >>>>>>>>> life is utterly ridiculous. There are so many
> >>>>>>>>> examples of accessible mobile devices these days
> >>>>>>>>> which work perfectly and for which accessibility
> >>>>>>>>> is transparent or not even known to those not
> >>>>>>>>> needing it. Amazon and Sony, do what you wish,
> >>>>>>>>> but your actions will reflect equally on you.
> >>>>>>>>> <http://www.blindbargains.com/view.php?u=1260>jcast today 2:25
> PM ET:
> >>>>>>>>>
> >>>>>>>>> You must be logged in to post comments.
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>> Share this Post
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>> ----------
> >>>>>>>>> <http://www.blindbargains.com/b/9286>
> http://www.blindbargains.com/b/9286
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>> Scott
> >>>>>>>>>
> >>>>>>>>> Sent from my iPhone
> >>>>>>>> _______________________________________________
> >>>>>>>> nfbcs mailing list
> >>>>>>>> nfbcs at nfbnet.org
> >>>>>>>> http://nfbnet.org/mailman/listinfo/nfbcs_nfbnet.org
> >>>>>>>> To unsubscribe, change your list options or get your account info
> for
> >>>>>>>> nfbcs:
> >>>>>>>>
> http://nfbnet.org/mailman/options/nfbcs_nfbnet.org/cannona%40fireantproductions.com
> >>>>>>>
> >>>>>>> _______________________________________________
> >>>>>>> nfbcs mailing list
> >>>>>>> nfbcs at nfbnet.org
> >>>>>>> http://nfbnet.org/mailman/listinfo/nfbcs_nfbnet.org
> >>>>>>> To unsubscribe, change your list options or get your account info
> for nfbcs:
> >>>>>>>
> http://nfbnet.org/mailman/options/nfbcs_nfbnet.org/jbar%40barcore.com
> >>>>>>
> >>>>>> _______________________________________________
> >>>>>> nfbcs mailing list
> >>>>>> nfbcs at nfbnet.org
> >>>>>> http://nfbnet.org/mailman/listinfo/nfbcs_nfbnet.org
> >>>>>> To unsubscribe, change your list options or get your account info
> for nfbcs:
> >>>>>>
> http://nfbnet.org/mailman/options/nfbcs_nfbnet.org/kfjelsted%40gmail.com
> >>>>>
> >>>>>
> >>>>> _______________________________________________
> >>>>> nfbcs mailing list
> >>>>> nfbcs at nfbnet.org
> >>>>> http://nfbnet.org/mailman/listinfo/nfbcs_nfbnet.org
> >>>>> To unsubscribe, change your list options or get your account info
> for nfbcs:
> >>>>>
> http://nfbnet.org/mailman/options/nfbcs_nfbnet.org/jbar%40barcore.com
> >>>>
> >>>> _______________________________________________
> >>>> nfbcs mailing list
> >>>> nfbcs at nfbnet.org
> >>>> http://nfbnet.org/mailman/listinfo/nfbcs_nfbnet.org
> >>>> To unsubscribe, change your list options or get your account info for
> nfbcs:
> >>>>
> http://nfbnet.org/mailman/options/nfbcs_nfbnet.org/kfjelsted%40gmail.com
> >>>
> >>>
> >>> _______________________________________________
> >>> nfbcs mailing list
> >>> nfbcs at nfbnet.org
> >>> http://nfbnet.org/mailman/listinfo/nfbcs_nfbnet.org
> >>> To unsubscribe, change your list options or get your account info for
> nfbcs:
> >>>
> http://nfbnet.org/mailman/options/nfbcs_nfbnet.org/theblindtech%40gmail.com
> >>
> >> _______________________________________________
> >> nfbcs mailing list
> >> nfbcs at nfbnet.org
> >> http://nfbnet.org/mailman/listinfo/nfbcs_nfbnet.org
> >> To unsubscribe, change your list options or get your account info for
> nfbcs:
> >> http://nfbnet.org/mailman/options/nfbcs_nfbnet.org/jbar%40barcore.com
> >
> > _______________________________________________
> > nfbcs mailing list
> > nfbcs at nfbnet.org
> > http://nfbnet.org/mailman/listinfo/nfbcs_nfbnet.org
> > To unsubscribe, change your list options or get your account info for
> nfbcs:
> >
> http://nfbnet.org/mailman/options/nfbcs_nfbnet.org/theblindtech%40gmail.com
>
> _______________________________________________
> nfbcs mailing list
> nfbcs at nfbnet.org
> http://nfbnet.org/mailman/listinfo/nfbcs_nfbnet.org
> To unsubscribe, change your list options or get your account info for
> nfbcs:
> http://nfbnet.org/mailman/options/nfbcs_nfbnet.org/sgermano%40asu.edu
>