Thread Subject: Narrow Delineated Use
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From: Diane Golden
Date: Fri, Mar 21 2008 10:45 AM
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Just FYI the Narrow Delineated Use exception is in the Annex although I have
to admit I don't remember the group deciding to move it there during the Jan
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Peter Korn
Sent: Thursday, March 20, 2008 7:50 PM
To: TEITAC Committee
Cc: Rebecca Schwartz
Subject: Re: [teitac-committee] FONT SIZE 1-G
Hi Mary, fellow TEITAC members,
I think the issues Mary is raising really go to the heart of why our
unconsensed (and perhaps lost?) provision on Narrow, Delineated Use is
important. It doesn't make sense to have all devices like cell phones
contain buttons whose text meets 1-G - that would mean that the small
feature phones with QWERTY keyboards I see many of my blind friends using
with MobileSpeak and TALKS software couldn't be procured under 508.
Maybe what would make sense is to put forth two versions of 1-G, one of
which links to the Narrow Delineated Use provision to say that so long a
variety of devices - including those with buttons and text of sufficient
size to meet 1-G - are available commercially and made available to
individuals who need them, it is OK to procure others of this class for
personal use that do not.
Sun Microsystems, Inc.
I have received substantial input from TIA members on the proposed
provsion 1-G The provision, as written, represents a significant shift in
the requirements when applied to all devices with a physical keyboard since
the text size and style are not user adjustable or selectable.
Below are some of the responses I received.
a.. Pixel resolution differs between mobile phone vendors, and even
between models manufacturered by the same vendor. As such, 10 point on
product A is not necessarily going to be displayed the same as it would be
displayed on product B.
b.. I just checked my PC keyboard and my telephone buttons, and both are
less than 10 points for the text.
c.. If this applies to the letters of the alphabet on the telephone
numeric keypad--and the phone is mounted in a public place--it would have to
be a "big button" telephone to have 14 point text for the alphabet letters!
d.. Alpha designators (ABC, etc.), as well as many of the function
labels would not meet the proposed size requirements
e.. Having 10 point font by default is not possible on all mobile
phones. It is possible on some devices, on some platforms, but it is not a
f.. This requirement generally could not be met by the growing number of
mobile devices that have QWERTY keyboards, especially since the number pad
for phone dialing and the alpha characters are required to share the same
g.. Larger text size on the buttons (and on graphics surrounding the
buttons) would force a much larger product, especially cordless handsets.
One proposed alternative is to rely upon other provisions - both the FPC
for limited vision and Subpart D 2C - Accessible configuration which puts
the burden on the agency to configure the product to enable operation for
persons with low vision.
Another proposed alternative is to delete Notes 5 and 6. Note 5 narrows
the focus of legibility to font height according to one specific means of
defining font size. TIA views the combination of font size, font style,
including thinkness, and color contrast on the keyboard lettering as all
important variables to achieve legibility for a particular user. In this
respect, the essence of the requirement is captured in the FPC requirement
for limited vision.
Note 6 sets up a requirement that screen size be larger than 4.5 inches
measured diagonally. This greatly limits design of small mobile devices
which may display video but also are used for other purposes, including
Given the breadth of product concerns that have been voiced,even adding a
limitation that 1-G not apply to mobile devices would not be something that
TIA could agree with. While this would address some concerns, it would not
I would also note that the larger the keypad and device and the larger
the characters are on a screen in a public place, the greater the
opportunity for violations of privacy.
Mary Brooner, TIA representative to the TEITAC
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