FCC Record, Volume 25, No. 17, Pages 13916 to 14803, October 4 - October 22, 2010 Page: 14,661
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premises installation of the card is required." But this is not the case with devices purchased at retail.
CableCARDs for use in retail devices must be installed in the home, and many cable operators require
professional installation by the cable operator. Unfortunately, the record reflects poor performance with
regard to subscriber premise installations of CableCARDs in retail devices."' This could be a
consequence of the fact that only 1 percent of the total navigation devices deployed are purchased at retail
and require an actual CableCARD installation,"9 which may have made it difficult to train the cable
installers properly. It could also reflect either indifference or reluctance by cable operators to support
navigation devices purchased at retail in competition with their own set-top boxes. Regardless of the
cause, these serious installation problems further undermine the development of a retail market.
6. A consumer using a unidirectional device cannot take advantage of two-way services
offered by a cable operator. The Commission anticipated that the parties to the MOU would negotiate
another areement to achieve bidirectional compatibility, using either a software-based or hardware-based
solution. Unlike one-way devices, which can only receive communication from cable headends,
bidirectional devices can send requests to the cable headend, which enables those devices to receive
services like cable operator-provided interactive programming guides, cable-operator provided video-on-
demand and pay-per-view, and other interactive programming services. When the Commission realized
in June 2007 that negotiations were not leading to an agreement for bidirectional compatibility between
consumer electronics devices and cable systems, it released a Third Further Notice of Proposed
Rulemaking, seeking comment on competing proposals for bidirectional compatibility and other related
issues.2 In the wake of the Two-way FNPRM, the six largest cable operators and numerous consumer
electronics manufacturers negotiated an agreement for bidirectional compatibility that continues to rely
and builds on CableCARDs by using a middleware-based solution called "tru2way."n
7. The National Broadband Plan, released in March of this year, recommended changes in
the CableCARD rules to provide benefits to consumers who use retail CableCARD devices without
7 See, e.g., MOTOROLA DCX700 SPEC SHEET, available at
http ~/www.motorola.com/staticfi les/Business/Products/TV%20Video%20Distribution/Customer%2DPremises%20E
tops/DCX700/_Document/static_files/DCX700%20spec%20sheet.pdf?localeld=33 (featuring a "Pre-installed M-
Card"); SCIENTIFIC ATLANTA, IMPLEMENTING SEPARABLE SECURITY in a DBDS at 13, available at
c%20implementing%20separable%20security%20in%20a%20dbds.pdf (explaining that set-top boxes with factory-
installed CableCARDs are called "Separable Security Combination" boxes).
" See, e.g., Letter from Neal M. Goldberg, Vice President and General Counsel, National Cable and
Telecommunications Association, to Marlene H. Dortch, Secretary, Federal Communications Commission, CS
Docket No. 97-80, at 3-13 (June 23, 2010).
19 See FEDERAL COMMUNICATIONS COMMISSION, CONNECTING AMERICA: THE NATIONAL BROADBAND PLAN 51
(rel. March 16, 2010).
20 Implementation of Section 304 of the Telecommunications Act of 1996: Commercial Availability of Navigation
Devices, 18 FCC Red 7924, 7925-6, 4-5 (2003); Implementation of Section 304 of the Telecommunications Act of
1996: Commercial Availability of Navigation Devices, 20 FCC Red 6794, 6811-2, 34 (2005).
21 Implementation of Section 304 of the Telecommunications Act of 1996: Commercial Availability of Navigation
Devices, 22 FCC Red 12024 (2007) ("Two-way FNPRM").
22 See Letter from Joel Wiginton, Vice President and Senior Counsel, Sony Electronics Inc., and Kathryn A.
Zachem, Vice President, Regulatory Affairs, Comcast Corporation to Monica Desai, Chief, Media Bureau, Federal
Communications Commission at Attachment at 1 (June 10, 2008).
Federal Communications Commission
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United States. Federal Communications Commission. FCC Record, Volume 25, No. 17, Pages 13916 to 14803, October 4 - October 22, 2010, book, October 2010; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc39304/m1/760/: accessed May 28, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.