TLPC Files Comments on Behalf of Accessibility Coalition Before FCC on Interoperable Video Conferencing Services

Today, the TLPC filed comments on behalf of its client, Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), and a coalition of more than 20 accessibility advocacy and research organizations before the Federal Commmunications Commission. The comments urge the FCC to proceed with ensuring the accessibility and usability of video conferencing services by finalizing a decade-long pending rulemaking on the scope of “interoperable video conferencing services” governed by the FCC’s rules under the Twenty-First Century Communications and Video Accessibility Act.

TLPC Files Comments in Colorado Privacy Act Pre-Rulemaking

TLPC student attorneys Rebecca Gruber, Richard Koch, and Stacey Weber, with the aid of Professor Margot Kaminski, developed comments responding to the Attorney General’s Pre-Rulemaking Considerations for the Colorado Privacy Act. Their response to the considerations, filed in anticipation of formal rulemaking in the fall, discusses several areas for potential rulemaking that closely impact the strength and effect of consumer privacy rights and company obligations in handling consumer data. The submission can be downloaded below.

TLPC Develops White Paper Surveying U.S. Law on AI-Based Assistive Technology

TLPC student attorney and now-Colorado Law graduate Monica Bunnay authored a white paper surveying the state of AI-based assistive technology tools under U.S. disability law. Developed in collaboration with colleagues at Gallaudet University, the paper explains that U.S. disability law typically regulates AI-based assistive technology only indirectly by imposing requirements on users of the technology, and not the vendors who develop it.

TLPC Submits Comments and Reply Comments at FCC on Behalf of Accessibility Coalition

With the assistance of John Jang, Peter Troupe, and Victoria Venzor, the TLPC filed comments and reply comments on behalf of our client, Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI) and a broad coalition of accessibility advocacy and research organizations urging the FCC to require improvements to the accessibility of closed captioning display settings. The comments and reply comments can be downloaded below.

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Technology and Intellectual Property Clinical Law Professors File Comments on Law Student Participation in Copyright Claims Board Proceedings

With the assistance of TLPC Student Attorneys Cameron Benavides, Sam Retter, and Garrett Janney, a coalition of thirteen technology and intellectual property clinical law professors filed comments with the Copyright Office on the Office’s recent Notice of Proposed Rulemaking on law student participation in Copyright Claims Board (CCB) proceedings under the Copyright Alternative in Small-Claims Enforcement (CASE) Act. CCB proceedings allow the adjudication of copyright “small claims” disputes. The professors highlighted a range of concerns, centered on the CASE Act’s opt-out mechanism, that likely will limit their willingness and ability to participate in CCB proceedings. The comments can be downloaded below.

The Constitutionality of Library E-Book Licensing Legislation

cross-posted from Authors Alliance

The following blog post was authored by Becca Lynch, a student clinician with the Samuelson-Glushko Technology Law & Policy Clinic at University of Colorado Boulder under the supervision of Professor Blake Reid, as part of an Authors Alliance student clinic project on library e-book licensing legislation.

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TLPC Files Amicus Brief on Behalf of Accessibility, Security, and Repair Fair Users Urging DC Circuit to Strike Down Controversial Copyright Law as Unconstitutional

Led by Colorado Law student attorneys John Jang, Victoria Venzor, and Peter Troupe, the TLPC today filed an amicus brief with the U.S. Court of Appeals for the District of Columbia Circuit on behalf of a coalition of accessibility, security, and repair individuals and organizations, supporting the lawsuit of security researcher Dr. Matthew Green and others, represented by the Electronic Frontier Foundation, over a controversial copyright law. The brief urged the court to conclude that Section 1201 of Title 17 of the U.S. Code, added by the Digital Millennium Copyright Act of 1998, violates the First Amendment by chilling fair uses aimed at making copyrighted works accessible to people with disabilities, researching security vulnerabilities in computer software, and repairing software-enabled vehicles and devices. Section 1201 prohibits the circumvention of technological protection measures (TPMs) on copyrighted works, requiring accessibility, security, and repair organizations to pursue exemptions in a burdensome triennial rulemaking conducted by the U.S. Copyright Office of the Library of Congress. The brief details the substantive and procedural harms of Section 1201 and the rulemaking to the First Amendment rights of people with disabilities, disability services organizations and libraries, security researchers, and ordinary consumers and repair professionals.

TLPC Submits Comments on Carceral Communications Accessibility for Accessibility Coalition

(by Cameron Benavides, TLPC Student Attorney)

In consultation with HEARD and on behalf of our client Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI) and a coalition of numorous deaf and hard of hearing advocacy and research organizations, the TLPC filed comments and reply comments in the Federal Communications Commission’s pending proceeding on addressing the accessibility of communications systems in carceral facilities.

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TLPC Releases Policy Brief on Access to Colorado Law and the Government Edicts Doctrine

(by Stacey Weber, TLPC Student Attorney)

The TLPC is pleased to release a policy brief detailing the state of free and open public access to the law in Colorado under the government edicts doctrine. At the request of Carl Malamud, President of Public.Resource.Org., the TLPC took a deep dive into the legal and practical realities of access to the law in Colorado. The brief details our findings, noting that Colorado demonstrates leadership with its open government framework but still has important work to do to preserve access to justice and foster innovation.

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TLPC Advocates Before the FCC for Equal Access to Communications and Video Programming

(by Dakotah Hamilton, TLPC Student Attorney)

On June 7th, the TLPC and the Communications and Technology Law Clinic (CTLC) at Georgetown Law filed a comment on behalf of 22 accessibility advocacy and research organizations, including TLPC and CTLC client Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), in response to the Federal Communications Commission’s public notice to revisit many of its rules under the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA). The comment, drafted by Professor Blake E. Reid, TLPC Director, and Professor Laura Moy, CTLC Director, with assistance from TLPC student attorneys Dakotah Hamilton, Rachel Hersch, and Scott Goodstein and CTLC staff attorney Michael Rosenbloom and student attorney Ellen Gardiner, comprehensively reviewed the past decade of FCC proceedings implementing the CVAA as well as some dating back to the Telecommunications Act of 1996, spanning more than two dozen dockets.

The comment identifies numorous specific priorities the FCC should consider for the accessibility of video programming, communications, and hearing device accessibility, including bolstering the availability of interpretation and captioning for video conferencing platforms and expanding captioning requirements for video distributed online. The comment also calls for dedicated inquiries into accessibility barriers facing people who are deaf or hard of hearing and have multiple disabilities, older people who are deaf or hard of hearing, and people who are deaf or hard of hearing and living on rural or tribal lands or in U.S. territories. The comment also urges the Commission to emphasize supervised multistakeholderism, centering the civil rights of people with disabilities, vigorous enforcement, and reporting to Congress.