SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND THE CAVALIERS OPERATING COMPANY, LLC

C. ACCESSIBILITY FOR DEAF AND HARD OF HEARING PATRONS

29. Within 30 days of the Effective Date of this Agreement, the Cavs shall provide effective real-time communication with individuals using auxiliary aids and services, including text telephones (TTYs).  The Cavs may use relay services in place of direct telephone communication for receiving or making telephone calls incident to its operations.  The Cavs shall respond to telephone calls from a telecommunications relay service established under title IV of the ADA in the same manner that it responds to other telephone calls. 

30. ​Within 30 days of the Effective Date of this Agreement, the Cavs shall provide contemporaneous equivalent visual messaging on the scoreboards and video monitors (“Captioning”) at Quicken Loans Arena which provide deaf patrons equal and meaningful access to all safety and emergency information provided over the public address system during all events at Quicken Loans Arena.  The Cavs shall provide deaf patrons equal and meaningful access to all aural information provided over the public address system during all events at Quicken Loans Arena (“Aural Information”) by October 1, 2013.  Notwithstanding the foregoing, if after due diligence into the technology, cost, and feasibility of providing Captioning for all Aural Information, the Cavs believe it would be an undue burden to do so, they shall inform the United States.  The Parties shall then work together to ensure that within 60 additional days, as much Aural Information as possible is captioned without being unduly burdensome. 

31. Within six months of the Effective Date of this Agreement, the Cavs shall have 233 fully functional receivers for assisted listening systems available for patrons with a hearing disability, as required by Standards § 219 (“Assisted Listening Devices”).  The Cavs shall ensure that the Assisted Listening Devices remain in good working order and any defects or issues are resolved expeditiously.  The Cavs shall also ensure that it provides the appropriate signage at Quicken Loans Arena at entrances and ticket windows notifying patrons of the availability of Assisted Listening Devices, in compliance with Standards § 216.10.