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Tom Maxwell

homebaset
June 11, 2013

Homecare Homebase 6688 North Central Expressway, Suite 1200 Dallas, TX 75206

Chief Operating Officer

The Honorable Lisa R. Barton Acting Secretary

U.S. INTERNATIONALTRADE COMMISSION

500 E Street, S.W. Washington, DC 20436

Re:

Certain Electronic Digital Media Devices and Components Thereo

Inv. No. 337~TA-796

Dear Acting Secretary Barton:

Homeeare Homebase, LLC (HCHB) is a market leader in providing fully integrated homecare
and hospice software to caregivers and patients. This software is currently used by nearly 40,000
caregivers who serve more than 190,000 patients each day. By 2015, HCHB expects to add 80,000

additional caregivers serving more than 400,000 patients each day.

HCHB respectfully submits these comments out of concern for the potential harm to IICHBs
business, its caregivers, and the patients they serve if the Commission issues an exclusion order covering
Samsungs mobile devices.

l.

ABOUT HCHB
HCHB was founded in 2000 and came to market in 2002. For several years, HCHB developed

software for devices running Windows Mobile operating systems. With the introduction of Windows
Phone '7in 2010, however, HCHB was forced to investigate alternative operating systems given the

incompatibility between Windows Mobile and Windows Phone 7. After evaluating multiple platforms,
including iOS, Windows Phone 7, and Android, HCHB determined that the Android operating system
6688 N. CENTRAL EXPRESSWAY, SUITE 1200 DALLAS,TEXAS 75206 214.239.6700 P 214.239.6582

provided the optimal platform for HCHBs software and users. HCHB determined that iOS and
Windows Phone 7 were not suitable for HCHBs desired goals because they lacked adequate security
features and did not allow for native code to be added to the device. In particular, iOS users were

required to create an iTunes account to register the device, which created a security risk for the
caregivers and patients. HCHB chose to develop exclusively for Android and partnered with Samsung

to offer HCHBs PointCare Manager software package on Samsung mobile devices, including the
Galaxy Tab. HCHB is proud to have earned the 2010, 2011, and 2012 KLAS Awards for Homecare:
Software and Services.

Nearly 40,000 homecare and hospice caregivers currently rely on HCHBs software solutions.

These caregivers provide daily service to more than 190,000 homebound patients, including many
seniors. These patients suffer from ailments such as diabetes, chronic obstructive pulmonary disease,
and congestive heart failure. 78% of the caregivers who utilize the HCHB platform daily run the HCHB
software on a Samsung mobile device.l In particular, more than 25,000 caregivers utilize HCHB
software on the Samsung Galaxy Tab 7.0, making it the most popular device.

HCHB services and the PointCare Manager software package provide multiple benets for
patients, caregivers, and the healthcare system. First, home healthcare services and products, such as

those provided by HCHB, help provide patients the option of receiving quality, cost~effective care in

their homes, as opposed to costly stays in the hospital? Second, software that includes electronic
medical records, like PointCare Manager, helps caregivers access information and critical alerts about

each patient quickly and efficiently. The synchronization of these records with a central database
effectively automates multiple processes necessary to provide home health services, which increases the
I Certied devices are available through AT&T, Sprint, T-Mobile and U.S. Cellular. A list of these devices can be found on the HCHB Website (https1//www.hchb.com/hornccare/ pocdevices/Defaultaspx). Samsung is the only certied device manufacturer available on all four carriers.

2 For the cost ofa single night in the hospital, HCHB allows for approximately 60 days of homecare.
6688 N. CENTRAL EXPRESSWAY, SUITE 1300 DALLAS,TEXAS 75206 214.239.6701 P 214.239.6582 F

efficiency and efcacy of the services. Third, using advanced devices like Samsungs Galaxy Tab helps

reduce fraud on the system by, for example, ensuring that caregivers actually visit their homebound
patients by tracking their location with GPS. This reduced fraud results in less waste and greater cost
effectiveness.

II.

EFFECT OF AN EXCLUSION ORDER

HCHBs fully-integrated homecare and hospice software was developed exclusively to operate

on the Android operating system because Android provides the optimal experience for HCHBs
customers, caregivers, and the patients they serve. Exclusion of the most popular Android devices from
the United States the ones on which HCHBs users overwhelmingly rely ~ would have a major impact

on the availability of HCHBs services and disrupt the care provided to the patients whose caregivers
depend on HCHB. HCHB does not believe that suitable alternative devices exist to ll the void that

would be left by thc exclusion of Samsungs products. Switching to another platform, such as Windows
Mobile or iOS, is not a viable option because these platforms do not adequately support HCllBs fully

integrated software suite. Even if these other platforms could be made compatible with HCHBs
software, converting I*lCHBssoftware to run on them would be a costly and time-consuming process.

For example, HCHB has estimated that it would take at least nine months to convert its software to run
on Windows Phone 8 tablets. This expense and delay would be harmful to HCIIB and the patients it

serves. For these reasons, the exclusion of Samsungs devices would have an adverse impact on

IICHBs business, customers, and the patients they serve.

Thank you for your careful attention to these comments. Please do not hesitate to contact me with any questions regarding this submission.

Sincerelyfi
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/" Chief Strategy Officer Ilomecare Homebase LLC

6688 N. CENTRAL EXPRESSWAY, SUITE 1300

DALLAS,TEXAS 75206

214.239.6701 P 214.239.6582 F