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BY sperling
The following message was posted to the ISDCF reflector on January 22, 2015 by Harold Hallikainen. It pertains to the 421 comments filed in response to the DOJ Notice of Proposed Rulemaking titled "Movie Theaters; Captioning and Audio Description: Nondiscrimination on the Basis of Disability by Public Accommodations" (DOJ-CRT-2014-0004-0001):

As mentioned at the January ISDCF meeting, my summary of the comments filed on closed captions are at http://ming.hallikainen.org/DojNprm/ . My summary of the summary, which was presented at the meeting, is below.
  1. The deaf really want open captions.
  2. NATO and others (several hearing loss associations) in a joint filing have proposed lower minimums on caption devices (4 units for single screens to 12 units for 16 or more screens) and then have the quantity adjusted for each theater to 150% of average weekend demand for that theater. Reports on demand to be filed with DOJ every six months. NATO also proposes that equipment be ordered within 6 months of effective date of rule, be installed within six months after receipt or within two years of the effective date of the rule, whichever occurs first. This was endorsed by several commenters.
  3. There are various complaints about closed captioning. These include: glasses are too heavy, glasses or cup-holder devices identify person as deaf (invasion of privacy), font size and color needs to be adjustable, cannot see captions over movie image, need to change view between caption box and screen is tiring, device shows captions for wrong movie or connection fails, batteries die, captions missed, system does not work (either device or transmitter not working).
  4. The DOJ proposed that theaters only need to show captions if they exist in the source content. They are not required to create captions. A few commenters asked what happens if a theater plays DVD or BD. These may have closed captions, but cinema closed caption equipment cannot play these captions.
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