TiVo fighting FCC over CableCARD, Verizon's FiOS service
Legal analysis courtesy of Matt Dobbins and Zachary Sharpe, and Trevor Adler of The Columbia Science and Technology Law Review.
While our attention was diverted toward DigitalLife last week, it looks like TiVo was locking horns with the FCC behind the scenes over CableCARD deployment, the "integration ban" which led to CableCARD, and how Verizon's FiOS service might spoil everybody's fun. Since the subject matter is a little dense, we enlisted the help of The Columbia Science and Technology Law Review to make heads or tails of what's really at hand here. Running Engadget commentary will be posted in italics.
Background: the FCC's "integration ban"
The FCC's set-top box "integration ban" requires cable operators to deploy set-top boxes that meet certain criteria standards, separating proprietary encryption from basic decoding functions. More specifically, this regulation effectively forces cable operators to support CableCARD, a technology incorporated into digital TVs and DVRs (e.g., TiVo Series3) that makes such devices compatible with the cable operator's encryption scheme without a set-top box.
By separating decryption from other functions, the 'integration ban' facilitates the introduction of third-party devices that compete with and can eliminate the need for the set-top boxes leased or provided by the cable companies. As a practical matter, however, relatively few consumers have availed themselves of the CableCARD option (see ACA Comments, CSR-7012-Z, CS Docket No. 97-80). This may be due to the fact that cable companies require consumers to take special steps to acquire a CableCARD (and also because the technology is not yet incorporated into many consumer devices). The FCC, therefore, has promulgated C.F.R. 76.1204(a)(1), requiring cable operators to implement CableCARD technology into their set-top boxes, so that every box has a CableCARD slot and will need a CableCARD to operate. This eliminates the need for consumers to take any special action to obtain a CableCARD. As it should be!
Requests from cable operators to waive C.F.R. 76.1204(a)(1)
Verizon recently (late August, 2006) filed a request for the FCC to temporarily waive 47 C.F.R. 76.1204(a)(1) until an "interoperable, open downloadable conditional access ("DCAS") solution is developed and deployed," arguing that waiver is necessary to facilitate the introduction of Verizon's own FiOS TV service. Verizon argues that this DCAS solution would render CableCARDs obsolete, and making their current set-top boxes compatible with the CableCARDs would be a waste of money. By waiving the CableCARD requirement and speeding Verizon's implementation of its cable service, Verizon argues, the FCC will increase competition in the cable TV market, ultimately helping consumers. The FCC then sought comment on Verizon's request (FCC reference).
Verizon's request follows similar requests from Comcast and the National Cable & Telecommunications Association ("NCTA" is the cable companies' lobbying group), in early August, to exempt certain set-top boxes from the ban. One common argument amongst the cable companies is that the FCC should delay the July 1, 2007 commencement of the integration ban because of the changing nature of the technology. Many cable companies argue that if given more time to work on the security technology, costs will be avoided which would otherwise be passed along to consumers.
TiVo's opposition to waiver requests by cable oOperators
In the October 12 letter filed by TiVo's counsel with the FCC, TiVo reiterates its position opposing the waivers petitions filed by the various cable companies mentioned above. For the producers of CableCARD-ready equipment, such as TV manufacturers and TiVo, the need for proprietary set-top cable boxes to decode cable signals hinders the sales and marketing of their products. Thus, TiVo here urges the FCC "not to undermine the effectiveness of its rule establishing the integration ban or further delay its implementation. TiVo also urged the Commission [the FCC] to examine closely the CableCARD cost figures being cited by the cable industry, since the figures appear high and are not adequately explained in the record." What, the cable industry industry using skewed figures to undermine open standards? Perish the thought.
This latest response by TiVo is concerned, in part, with the definition of "low-end" in referring to set-top boxes. TiVo's concern is that the cable companies wish to define "low-end" so expansively as to encompass a wide variety of boxes with seemingly high-end DVR functionality that would compete with TiVo's product. Without knowing what set-top models the cable companies wish to consider "low-end" and what percentage of households with digital cable use such models, it is difficult to say what the practical implications of this question are. TiVo argues that the cable companies' definition of low-end set-top boxes encompasses so many boxes that a low-end exemption would make the integration ban into a nullity.
STLR legal commentary
Congress passed an act requiring cable companies to adopt CableCARD technology more than ten years ago. It's intent was to provide consumers with a competitive market for cable decoders. The cable companies have tried to invalidate the law in court, but have been unsuccessful (Charter Communs., Inc. v. FCC, 460 F.3d 31; General Instrument Corp. v. FCC, 341 U.S. App. D.C. 367). Since the act's passage, the FCC has extended the deadline multiple times at the request of cable operators to give the companies more time to implement the technology and develop potentially lower cost solutions.
Verizon is not asking for a general extension of the deadline for everybody (the FCC seems to be done with such requests), but rather it is asking for a specific temporary waiver of the deadline for itself. According to the act, the FCC can grant these waivers if "necessary to assist the development or introduction of a new or improved multichannel video programming." (47 C.F.R. 76.1207). So Verizon wisely has linked their waiver request to the rollout of FiOS. Verizon argues that providing a CableCARD compatible system that is able to support FiOS by the July 1, 2007 deadline is too much to ask (FCC reference). The problem, Verizon claims, is that the interactive services offered over FiOS are not compatible with current CableCARD implementations and, even if they were, developing CableCARD compatibility would take away from their development of other services. Verizon also argues that its status as a "new entrant" into the market means that it has not had the same ten years that other cable providers have had to develop CableCARD technology, and that its relatively small customer base means that the waiver will not affect many consumers. If Verizon can convince the FCC that FiOS services will be impacted if the deadline is enforced, their waiver request may be granted.
Charter Communications is also seeking a waiver, but for a different reason. Charter claims that it offers low-end cable decoder boxes that are cheaper than can ever be built using CableCARD technology. Requiring the transition to CableCARD would increase the cost to the low-end consumer "just to reduce by a few cents the $1.50 lease cost of CableCARDs that plug into high-end HDTVs" (FCC reference). This argument has met opposition from decoder box makers, like TiVo, who claim that Charter's definition of "low-end" is too expansive and would undermine the intent of the law (FCC reference). One issue with Charter's argument is that the company seems to be asking for a permanent waiver, and the FCC only has the authority to grant waivers for a limited time under 47 C.F.R. 76.1207. Also, Charter's desire to protect the low-end consumer does not fall within the statute's requirement that waivers be granted only to allow for development of "new and improved" programming.
It will be interesting to see how the courts handle these waiver requests in light of the opposing arguments promulgated by TiVo and others.
Further Engadget commentary
It wouldn't be hard to take odds on where we stand with this. We're all for FiOS, etc., but we have zero patience for this process attempting to rebuke an important open standard. Verizon and Charter are trying to get their foot in the door with the FCC over making CableCARD flexible, and as soon as that happens the flood gates will be opened for the rest of the cable industry, re-establishing the mob rule they've enjoyed for so long. CableCARD may be the one shining example of the FCC and tech companies enforcing something particularly pro-consumer on media delivery megacorps, and we can only hope a little legal gray area and a whole lot of lobbying won't send us back to the early 90s -- even if only a few hundred thousand customers have yet installed a CableCARD in their home.
While our attention was diverted toward DigitalLife last week, it looks like TiVo was locking horns with the FCC behind the scenes over CableCARD deployment, the "integration ban" which led to CableCARD, and how Verizon's FiOS service might spoil everybody's fun. Since the subject matter is a little dense, we enlisted the help of The Columbia Science and Technology Law Review to make heads or tails of what's really at hand here. Running Engadget commentary will be posted in italics.
Background: the FCC's "integration ban"
The FCC's set-top box "integration ban" requires cable operators to deploy set-top boxes that meet certain criteria standards, separating proprietary encryption from basic decoding functions. More specifically, this regulation effectively forces cable operators to support CableCARD, a technology incorporated into digital TVs and DVRs (e.g., TiVo Series3) that makes such devices compatible with the cable operator's encryption scheme without a set-top box.
By separating decryption from other functions, the 'integration ban' facilitates the introduction of third-party devices that compete with and can eliminate the need for the set-top boxes leased or provided by the cable companies. As a practical matter, however, relatively few consumers have availed themselves of the CableCARD option (see ACA Comments, CSR-7012-Z, CS Docket No. 97-80). This may be due to the fact that cable companies require consumers to take special steps to acquire a CableCARD (and also because the technology is not yet incorporated into many consumer devices). The FCC, therefore, has promulgated C.F.R. 76.1204(a)(1), requiring cable operators to implement CableCARD technology into their set-top boxes, so that every box has a CableCARD slot and will need a CableCARD to operate. This eliminates the need for consumers to take any special action to obtain a CableCARD. As it should be!
Requests from cable operators to waive C.F.R. 76.1204(a)(1)
Verizon recently (late August, 2006) filed a request for the FCC to temporarily waive 47 C.F.R. 76.1204(a)(1) until an "interoperable, open downloadable conditional access ("DCAS") solution is developed and deployed," arguing that waiver is necessary to facilitate the introduction of Verizon's own FiOS TV service. Verizon argues that this DCAS solution would render CableCARDs obsolete, and making their current set-top boxes compatible with the CableCARDs would be a waste of money. By waiving the CableCARD requirement and speeding Verizon's implementation of its cable service, Verizon argues, the FCC will increase competition in the cable TV market, ultimately helping consumers. The FCC then sought comment on Verizon's request (FCC reference).
Verizon's request follows similar requests from Comcast and the National Cable & Telecommunications Association ("NCTA" is the cable companies' lobbying group), in early August, to exempt certain set-top boxes from the ban. One common argument amongst the cable companies is that the FCC should delay the July 1, 2007 commencement of the integration ban because of the changing nature of the technology. Many cable companies argue that if given more time to work on the security technology, costs will be avoided which would otherwise be passed along to consumers.
TiVo's opposition to waiver requests by cable oOperators
In the October 12 letter filed by TiVo's counsel with the FCC, TiVo reiterates its position opposing the waivers petitions filed by the various cable companies mentioned above. For the producers of CableCARD-ready equipment, such as TV manufacturers and TiVo, the need for proprietary set-top cable boxes to decode cable signals hinders the sales and marketing of their products. Thus, TiVo here urges the FCC "not to undermine the effectiveness of its rule establishing the integration ban or further delay its implementation. TiVo also urged the Commission [the FCC] to examine closely the CableCARD cost figures being cited by the cable industry, since the figures appear high and are not adequately explained in the record." What, the cable industry industry using skewed figures to undermine open standards? Perish the thought.
This latest response by TiVo is concerned, in part, with the definition of "low-end" in referring to set-top boxes. TiVo's concern is that the cable companies wish to define "low-end" so expansively as to encompass a wide variety of boxes with seemingly high-end DVR functionality that would compete with TiVo's product. Without knowing what set-top models the cable companies wish to consider "low-end" and what percentage of households with digital cable use such models, it is difficult to say what the practical implications of this question are. TiVo argues that the cable companies' definition of low-end set-top boxes encompasses so many boxes that a low-end exemption would make the integration ban into a nullity.
STLR legal commentary
Congress passed an act requiring cable companies to adopt CableCARD technology more than ten years ago. It's intent was to provide consumers with a competitive market for cable decoders. The cable companies have tried to invalidate the law in court, but have been unsuccessful (Charter Communs., Inc. v. FCC, 460 F.3d 31; General Instrument Corp. v. FCC, 341 U.S. App. D.C. 367). Since the act's passage, the FCC has extended the deadline multiple times at the request of cable operators to give the companies more time to implement the technology and develop potentially lower cost solutions.
Verizon is not asking for a general extension of the deadline for everybody (the FCC seems to be done with such requests), but rather it is asking for a specific temporary waiver of the deadline for itself. According to the act, the FCC can grant these waivers if "necessary to assist the development or introduction of a new or improved multichannel video programming." (47 C.F.R. 76.1207). So Verizon wisely has linked their waiver request to the rollout of FiOS. Verizon argues that providing a CableCARD compatible system that is able to support FiOS by the July 1, 2007 deadline is too much to ask (FCC reference). The problem, Verizon claims, is that the interactive services offered over FiOS are not compatible with current CableCARD implementations and, even if they were, developing CableCARD compatibility would take away from their development of other services. Verizon also argues that its status as a "new entrant" into the market means that it has not had the same ten years that other cable providers have had to develop CableCARD technology, and that its relatively small customer base means that the waiver will not affect many consumers. If Verizon can convince the FCC that FiOS services will be impacted if the deadline is enforced, their waiver request may be granted.
Charter Communications is also seeking a waiver, but for a different reason. Charter claims that it offers low-end cable decoder boxes that are cheaper than can ever be built using CableCARD technology. Requiring the transition to CableCARD would increase the cost to the low-end consumer "just to reduce by a few cents the $1.50 lease cost of CableCARDs that plug into high-end HDTVs" (FCC reference). This argument has met opposition from decoder box makers, like TiVo, who claim that Charter's definition of "low-end" is too expansive and would undermine the intent of the law (FCC reference). One issue with Charter's argument is that the company seems to be asking for a permanent waiver, and the FCC only has the authority to grant waivers for a limited time under 47 C.F.R. 76.1207. Also, Charter's desire to protect the low-end consumer does not fall within the statute's requirement that waivers be granted only to allow for development of "new and improved" programming.
It will be interesting to see how the courts handle these waiver requests in light of the opposing arguments promulgated by TiVo and others.
Further Engadget commentary
It wouldn't be hard to take odds on where we stand with this. We're all for FiOS, etc., but we have zero patience for this process attempting to rebuke an important open standard. Verizon and Charter are trying to get their foot in the door with the FCC over making CableCARD flexible, and as soon as that happens the flood gates will be opened for the rest of the cable industry, re-establishing the mob rule they've enjoyed for so long. CableCARD may be the one shining example of the FCC and tech companies enforcing something particularly pro-consumer on media delivery megacorps, and we can only hope a little legal gray area and a whole lot of lobbying won't send us back to the early 90s -- even if only a few hundred thousand customers have yet installed a CableCARD in their home.
This production of the STLR Engadget Team was led by Columbia STLR student staff Matt Dobbins and Zachary Sharpe, and edited by Trevor Adler.
Reader Comments (Page 1 of 1)
Igor @ Oct 19th 2006 2:06PM
can someone sum it up? :/
Jonathan Sundy @ Oct 19th 2006 2:09PM
In another article I read somewhere, they mentioned that Pay-Per View and Video on Demand were possible features on the low end units they are mentioning. Personally VOD should take it out of the running for a bottom of the line box right off the bat.
Another point of contention, imho, is that as a newcomer Verizon is starting from scratch and as such it should be easier for them to implement Cable Cards from the start. They aren't re-engineering material, they should have been sourcing it this way from the start.
Jonathan Sundy @ Oct 19th 2006 2:14PM
Summation of article:
The FCC says all cable companies need to use CableCards in their set top boxes. A cable card is a signal encryption device that is removable (Like a SIM card in your phone). The point of this would be that if everyone from 1st partis (like Comcast and now Verizon) to 3rd parties like Tivo and whoever used the Cable Cards to handle the encryption of the signal it would make it cheaper to manufacture the Cable Cards and easier for cable customers to choose whether they wanted a 1st party set top box or a 3rd party one (which there would be more of if Cable Card takes off).
Verizon is requesting that since they're new to the market, having to comply with this and add cable card functionality to their set top boxes would slow down their rollout and that letting them introduce FIOS to more markets would save more people more money that the money their customers would save from having Cable Card in all of their boxes (boy that was a crappy sentence).
Apparenlty the Cable Card idea has been around for 10 years and the cable companies have been purpopsely avoiding implementing it. It seems the FCC is fed up.
Sam @ Oct 19th 2006 2:40PM
The cable card idea has been around much longer than 10 years. The legislation was passed over ten years ago.
Igor @ Oct 19th 2006 3:07PM
wow, thanks
Davis Freeberg @ Oct 19th 2006 2:32PM
Excellent analysis of the issues at stake. Sometimes the legal mumbo jumbo can be a little tough to make heads or tails of, so I appreciate you bringing in an expert who has more experience in looking at these issues. Like most things in life there probably isn't an easy answer to the question raised, but at least you've given good legal commentary so that readers can understand the framework of the conversation. I'd love to see more legal analysis on other tech issues in the future, but with that witty engadget style that makes this blog so enjoyable.
Trent @ Oct 19th 2006 2:42PM
Fat cats protecting their fat income at the cost of competition and customers. Say it isn't so!
Geoff @ Oct 19th 2006 2:53PM
Surely, if they've had 10 years to incorporate this technology, they have lost all rights to any waivers. How many times have they upgraded their systems in that time? From 550 MHz to 750Mhz and now to 1GHz.
Direct TV and Dish have the cablecards. My Sister in the UK has had one on her Saterlite TV system for about 10 years. You'd think by now that any new boxes produced by Motorolla and Scientific Atlanta would already have the cableCard slots built in, but that does not seem to be the case.
dcpmark @ Oct 19th 2006 2:53PM
A TiVO Series 3 combined with FIOS would be my personal nirvana when FIOS TV becomes available in my area early next year, and should be the standard by which all other services should try to live up to. PLEASE, PLEASE, PLEASE don't make me choose one over the other!! Can't we all just get along?
Leslie J. Hartley @ Oct 19th 2006 3:01PM
Comcast will issue a customer a CableCARD over the counter to anyone requesting one. There is no charge for the CableCARD, incremental to the service level delivered through the device. The only thing inhibiting the technology's market penetration is that the technology sucks. CableCARD 2.0's implementation may address this, if DRM hassles don't cripple it.
Michael Lomker @ Oct 19th 2006 3:27PM
I really like the idea of making cable companies use Cablecards in their own equipment. If the cable companies had needed Cablecard 2.0 released in order to make money on pay-per-views or offer VOD then it would have been released many years ago!
mjwedeking @ Oct 19th 2006 3:48PM
FiOS has a terible DVR box (Moto 6416) with tons of problems (They have an automated phone service to get the box reset). When most tell Verizon they want to go to TiVo S3 Verizon tells them to wait. Verizon should have a revampt software for the 6416 out first quarter 2007. FiOS TV is in a beta form and a S3 would realy help it not look so bad.
snappa @ Oct 19th 2006 4:06PM
I also plan to go HD with FIOS and Tivo early next year.
As for Verizon arguing they are exempt because they are new is BS. The fact is they should have developed their product AROUND the standard. Unlike the other cable companies who have to migrate old users to the new system, Verizon is building their system from the ground up. Therefore, no excuse for ignoring the Cablecard standards.
As for satellite TV...they DO NOT use Cablecards. I am not sure how they got around that, but it is likely related to security concerns given that everyone has access to the satellite signal. As opposed to cable (or FIOS) where you've got to have a physical wire running to your home. A wire that the cable company can disconnect manually!
GadgetGav @ Oct 19th 2006 5:05PM
While I agree that Verizon as a newcomer should have designed around the CC standard, I'm not so sure I agree with the analysis that CableCard is pro-consumer. You only have to look at the crippled feature set and DRM problems of the Tivo S3, all of which Tivo have blamed CableLabs certification for, to see that it's not really that pro-consumer. It might help to introduce a bit more competition into the marketplace, but that market will still be controlled by the corporations, not consumers.
The fact that there are so many issues around CableCard and the fact that they're already talking about CC2.0 which won't be backwards compatible means I'm keeping out of Tivo S3. It's a shame, I've had a Tivo since the first of the S1's, but I'm not prepared to take a $800 or $1000 gamble and leave the fate of it to the FCC or the cable companies. I'd rather take the rented DVR from the cable company while I weigh my options. There's already competition... I could have Comcast or DirectTV and soon I could choose Verizon, so I can't justify the hassle of Tivo.
I think Tivo can see the writing on the wall which is why they're pressing the FCC. I hope for their sake the FCC sticks to it's guns, but I'm not holding my breath.
Jonathan Sundy @ Oct 19th 2006 5:14PM
I believe, and I could be wrong, that cable card by definition should provide all the same features that the cable company would offer without it, so these issues that Tivo is blaming on it wouldn't exist once it's implemented as it was intended. Again that's just my interpretation.
Also, I doubt people will choose DirectTV vs Comcast based on the set top box options offered, so that is not the kind of competition they are talking about. Instead you should be able to goto best buy and get a DVR box for say $150 that does everything that $20 a month box from Comcast does, except does it well. I believe that is the type of competition they are trying to spur, so that cable companies aren't artificially inflating the prices of their set top boxes too much just because you wouldn't have any other choice.
Pete @ Oct 19th 2006 6:19PM
current cable cards are not 2-way, no interactive on screen guide, no VOD, no ppv. CC 2.0 will be. To develop a system on CC 1 is a waste of time, since it's like wathing cable in 1980. Why there is no CC 2.0 yet is the real story.
Rick @ Oct 20th 2006 1:48AM
I agree with Pete. I'd love to use a CableCard in my HDTV and I ould even get a non-cable company HD-DVR IF I could get an onscreen guide and access to On-Demand and Pay per View programming. Cable Card 1.0 sucks and thats why there is low use of it in the market, not because CableCard slots aren't available. Heck, even my cable company HD-DVR has an unused slot for a CableCard.
The CableCard 2.0 standard has taken too FAR long to be finalized and should have been long ago. The FCC should consider demanding it too be ready by July 2007 - WITHOUT the possibility of extension.
vudean @ Oct 20th 2006 12:16AM
hey Leslie J Hartley... stupid comcast told me it would cost me a monthly fee for a cablecard.. as much as a cable box too... thats just stupid. Where you abel to get one free?
Pete - I see your point, CC 2.0 will be great, but I still like the idea of CableCard now, if only I could just buy a tv for under $1800 that supports it. I think it would be great for my second tv (bedroom) in a small LCD (26"-32") then all I would have is the tv, and not the clutter of the box.
I don't need VOD or all that other stuff the cable companies are trying to push for more revenue... I just want HD, and my HBO... which they just took away from me on my second tv, where I don't have a DVR box, unless I get another box.. for, of course, more money per month!
John Ashby @ Oct 21st 2006 11:37AM
I'm a dedicated off-air user precisely because the cable companies are more into market control than standards. ATSC took forever to implement at least partially because of foot-dragging by cable and satellite, and CableCARD is going the same way. Their argument is a little like the early computer industry fight between USB and 1394; let buyers vote with their pocketbook. But the Cable industry isn't really about choice...they're afraid of external competition from other architectures that might offer enhanced services(e.g. IPTV) in my opinion.
Jeff L @ Jan 11th 2007 8:02PM
I bought a new Mitsubishi 1080p HDTV that has TV Guide Onscreen built in and Cable Card support. I tried out the TV Guide Onscreen with basic cable (analog) and it worked GREAT... So I saw NO reason to get another Comcast DSTB. Turns out though that once you stick a Cable Card in for the Digital Comcast channels (incl HD) it blocks the download you need from the local Public TV station for the update to TV Guide Onscreen. So, TV Guide onscreen is worthless once you stick in a Cable Card. This whole Cable Card scheme was not thought out very well that's for sure.
Laird Popkin @ Mar 10th 2007 8:09AM
"This whole Cable Card scheme was not thought out very well that's for sure."
The problem isn't Cable Cards weren't well thought out, it's that the cable companies are trying to subvert consumer's ability to avoid lock-in. So they intentionally handicapped what CC can do, and craete as many compatability problems and hassles as possible, in order to force consumers to use their proprietary boxes so that its harder to change providers.
The FCC's requirement to use CC in all set-top boxes eliminates all of the CC excuses, which is great for consumers, and which the cable companies are desparately trying to avoid.
Ed P @ Dec 26th 2007 12:30PM
I am a simple user that prefers not to have to rent equipment from my cable service provider. I jumped for joy in the early 1990's when the FCC ruled that homeowners no longer had to pay rates/outlet. We could string wire to cable-ready TV's in every room of the house, with one flat rate fee. I have taken full advantage of thatm, currently with 5 TV's in use. I have one set top digital box, and no desire for more on the lesser used TV's. But, I understand that will be inevitable when digital becomes the standard in 2009. The cable companies enjoy an incredible revenue stream from set top box rentals, and are salivating over getting an extra $20/month out of a non-premium "low end" user like me. The FCC released these behemoths on us when they deregulated in 1996 (my cable charges have tripled in 10 years), and they need to keep their many basic customers in mind. The cableCard technology seems to address this. Perhaps Verizon should slow down their rollout until their technology meets the lawful requirements.
Mike @ Jan 15th 2008 8:26PM
We just had cable cards installed in our new Tivo HD and discovered there's a large block of HD channels we cannot get unless we rent the Cox HD-DVR. I previously made the mistake of trying to use the Cox DVR and public modesty prevents my characterization of it further. I will not even consider that alternative.
The solution I am seriously contemplating is getting the integrated TiVO-HD/DirecTV receiver and telling Cox to put their RG-6 where the sun don't shine.
DirecTV has its supply of warts, but in my experience with DirecTV, they are are materially less disgusting than Cox.
I did file an official complaint with the FCC on the matter,
for whatever good that will do.
docsharp01 @ Mar 31st 2008 9:45PM
Excellent article and comments about TiVo fighting the FCC over the CableCARD.
http://www.1-satellite-tv-facts.com