Outland Sports, Inc.                             
P.O. Box 220
4500 Doniphan Drive
Neosho, MO  64850-220
(417) 451-4438
Fax (417) 451-2576

September 23, 1999

Federal Communications Commission
Cable & Services Division
c\o Closed Captioning Requirement
2033 M. Street N.W., Room 406
Washington, D.C. 20554

Dear Federal Communications Commission,

This letter is in response to the F.C.C.'s Closed Captioning
requirement effective January 1, 2000.  Please accept this letter as
a petition for exemption on the basis of undue burden.

  (i) The nature and cost of closed captions for the programming.

Outland Sports Inc. produces a half hour weekly show, OUTDOOR
TRADITIONS, which airs each week on The Outdoor Channel.  The current
cost of airing this show each week is ($1,000) one thousand dollars.
After obtaining quotes from three different captioning providers, we
found the cost per show ranges from $417 to $475. (Quotes enclosed)
That is an additional cost of 40 plus percent just for us to provide
closed captioning.  OUTDOOR TRADITIONS is a hunting show with very
limited scripting because most of the show's audio are natural
sounds.

(ii) The impact on the operation of the provider or program owner.

Most shows are shot and then aired within a few days time.  Having to
adjust are deadlines in order for the show to be captioned would be
nearly if not impossible.

(iii) The financial resources of the provider or program owner.

As with all companies, Outland Sports operates on a budget.  An
increase in cost (40%+) such as the one it will take to meet the
F.C.C.'s requirement could result in the end of the show.

(iv) The type of operations of the provider or program owner.

Outland Sports, Inc. is a company that manufactures a wide variety of
hunting accessories.  The television show is a means of promoting
these accessories and is not a money maker for Outland Sports.  The
additional cost of adding closed captioning to the show would make it
more difficult to justify the show's existence.

In addition, The Outdoor Channel network, which airs "Outdoor
Traditions" is a new network not beginning full time operation until
June 1994.  Therefore, I believe making it exempt from the FCC's
closed captioning requirements until 2002.  But not taking any
chances, we still wish to petition for an exemption.

Warren Rose
Promotions & Video Production Manager
Outland Sports, Inc.

Encl: Quotes, VHS-TV show

VITAC CORPORATION
"Vital Access thru Captioning"
Los Angeles  Pittsburgh  Tampa  Washington, D.C.

Southpointe 
101 Hillpointe Drive 
Canonsburg, PA 15317-9503

Voice (724) 514-4000 
TTY (724) 514-4100 
Fax (724) 514-4111 
http://www.vitac.com

August 11, 1999

SENT BY FAX: 417-455-1914

Mr. Warren Rose
Outland Sports
4500 Doniphan Drive
Neosho, MO 64850

Warren,

As promised, please find attached more detailed information regarding VITAC's 
closed captioning services for your "Outdoor Traditions" program.  We'd 
welcome the opportunity to serve as a resource for your programming.  I truly 
appreciate this time to show you how an investment in captioning will make 
your programs accessible to countless more viewers while complying with cable, 
network and government captioning requirements. 

VITAC is a thirteen-year-old national firm headquartered in Pittsburgh, with 
additional facilities in Los Angeles, Tampa, and Washington, D.C. We are 
recognized as a leader in this industry and have a top reputation of providing 
high-quality, accurate, affordable services.  On a daily basis, we provide 
real-time captioning for ABC, NBC, CBS and CNN "Headline News." For your 
review, I've enclosed a complete list of our current programming. 

U.S. Department of Education figures estimate that captions are used by more 
than 130 million Americans  including 28 million deaf and hard of hearing 
individuals, 27 million adults improving literacy skills, 45 million 
people learning English as a second language and 28 million elementary 
schoolchildren learning to read.  In addition, consider other viewers who use 
captions to watch TV late at night or when household appliances drown 
out the audio, along with thousands of bars, restaurants and health clubs 
across the country, and you can see the powerful impact that captioning can 
have.

As we discussed, many networks are requiring, program producers to deliver 
programs closed captioned in response to the FCC regulations that will require 
most shows to be captioned over the next six years.  VITAC understands and 
appreciates the production costs involved for producers/distributors and has 
pledged to offer the most accurate, quality captions at the most affordable 
rate.  In addition, VITAC has vowed to work closely with clients to identify 
all available funding options to reduce captioning costs. 

In order for the audience to see closed captions, they have to be encoded 
with the master tape somehow.  On prerecorded shows, caption text is usually 
merged with the original master tape ahead of time to create a captioned 
master.  The captioned master is then used for airing or duplication purposes.  
You have the option of selecting two methods of captioning -- pop-on style or 
roll-up.  Pop-on style is similar to movie subtitles, whereby the captions pop 
on a sentence or more at a time contemporaneous with the dialogue.  Each 
caption is time coded so that it appears synchronous with the dialogue.  
Because the pop-on process is much more time consuming (eight man hours per 
30:00 program), the cost to do pop-on is slightly higher. 

We can also caption a show in roll-up mode, which is similar to the style used 
in news captioning, soap operas, interview programs and many entertainment 
shows.  Captions scroll up a line at a time from the bottom or top of the 
screen to usually three full rows.  As each new row rolls up, the top row 
disappears, and the text is timed to still be synchronous with the dialogue.  
Since there isn't as much placement involved, the rate for roll-up is slightly 
lower. 

The following rates are for pop-on caption preparation:

Length Rate
30:00  $450
60:00  $800

The following rates are roll-up caption preparation:

Length Rate
30:00  $250
60:00  $390

For your purposes, roll-up style captions would probably serve your 
programming well, but choose the style that suits your budgetary and aesthetic 
preference.  Encoding and blank tape stock shows are not included in the 
figures above, but here are some averages for your reference (rates remain the 
same regardless of pop-on or roll-up captions): 

Length Rate   Tape stock
30:00  $138   BetaSP $29, Digital Beta $47, D2/D3 $71
60:00  $187   BetaSP $39, DigitalBeta $66, D2/D3 $105

In addition to providing the highest-quality captioning and the best customer 
service in the industry, here are some additional features that VITAC provides 
at no additional cost to you: 

-Full technical support via phone or e-mall from our staff of experienced 
captioners and engineers 

-Public Relations assistance to get the word out that your programs are now 
captioned 

-Caption Sponsorship -- working to educate your sales staff to offer a value-
added opportunity 

As far as caption sponsorship goes, we've had success in matching up 
advertisers who pay a fee to cover the cost of captioning a program in return 
for a caption credit within the show, and usually a 5 or 10-second billboard 
in the form of a graphic and/or voice over, or inclusion in the final credits.  
Often times, you'll be able to cover captioning costs and even generate 
additional revenue depending on the ratings for the show.  We encourage your 
staff to handle this area simply because they have relationships with existing 
sponsors, but we'd be glad to help out if needed. 

Lastly, I'll be forwarding information on a revolutionary technology called 
Interactive Crossover Links for WebTV.  Here's how it works -- we can add web 
address information to the closed caption data stream, which will direct your 
viewers who are WebTV subscribers to designated websites while they're still 
watching and listening to your program.  Rates to add links to a 30:00 show 
are only an additional $50, while 60:00 shows are only an additional $100.  
The exciting potential of WebTV helps your viewers give you instant feedback 
on a program, allows them to order products, send in ideas for shows, and 
qualify themselves for more information, among other applications. 

When you combine the audience-building power of captioning and the interactive 
aspects of links, it's easy to see how an investment in these additional 
services will set your programs apart from others.  In closing, please keep in 
mind that our main goal is to make you feel comfortable and confident in our 
captioning services. When comparing VITAC's rates, services and quality to 
other vendors, please be sure that you're comparing apples to apples.  We are 
confident that nobody in the industry can match the quality and experience of 
VITAC's work.  You invest thousands of dollars into the highest production 
values for your shows so why settle for anything but the best in captioning to 
compliment your programs? 

  Warren, thank you for your time and consideration of VITAC for your 
captioning services.  We would love to help expand the viewing audience for 
all of your programs through captioning.  I will follow up with you on Friday 
to make sure you've received this information, along with the forthcoming 
FedEx packet.  If you have questions before then, please call me at (724) 514-
4081 or 1-800-278-4822. 

Sincerely,

Darryn Cleary
Account Executive

CLOSED CAPTIONING SERVICES
Suite 18
2215 Oak Industrial Dr., N.E. 
Grand Rapids, MI 49505 
VOICE/TDD 616-456-6794 
FAX 616-458-6855
CHICAGO 312-245-9900   TORONTO 416-598-4613

August 16, 1999

Warren Rose
Outland Sports
4500 Doniphan Drive
Neoshow, MO 64850

RE: Closed Captioning

Dear Warren:

Thanks for the call back, I appreciate it.  As I discussed with you, CCS will 
caption, encode and deliver back to you, on Beta SP, your half hour shows for 
the finished price of $450 per program. 

As I mentioned to you, we can provide you with a 3 day turnaround, however it 
would be better to figure 5 business days.  I understand that you do not have 
scripts with the programming.  We would ask that you could help us get in 
touch with the people that can give us accurate names, etc. about the shows 
content. 

If this proposal works for you I would need to know as soon as possible.  We 
are very busy in the off-line department and I would need to get this 
programming scheduled in to our production cycle.  I look forward to working 
together.  Let me know if there is anything I can help you with. 

Sincerely,

Charles H. Leonard, Executive Vice President
Closed Captioning Services, Inc.

CAPTIONMAX
530 North Third Street
Minneapolis, Minnesota 55401
voice/TDD 612 341-3566
fax 612 341-2345

August 11, 1999

Warren Rose
Outland Sports
4500 Doniphan Drive
Neosho, Missouri 64850

Dear Punky:

Thank you for your call today. CaptionMax would be delighted to have the
opportunity to caption Outdoor Traditions.

CaptionMax offers two kinds of captioning services. I believe roll-up captions 
would be a good choice for Outdoor Traditions but I will provide information 
for both services.  Please allow 4 - 5 days for the captioning and encoding. 

ROLL-UP CAPTIONS
Three lines of captions typically appear in the lower left portion of the 
screen. Captions "paint" on the screen one line at a time: as the top line of 
captions appears, the bottom line "erases." Roll-up captions are effective for 
news, magazine-style and documentary programs. Rate: $300 per half hour $595 
per hour 

POP-ON CAPTIONS
Captions "pop" on and off the screen using the individual time code of each 
program. Captions are placed to cue the viewer to different speakers, music 
and sound effects.  Pop-on captions are essential for dramatic or comedic 
programs. where the timing and placement of each caption is important. Rate: 
$400 per half hour $795 per hour 

The rates quoted above are for the preparation of the caption data.
CaptionMax's rates for the encoding package (worktape, encoding and new tape
stock) is $175 per half hour and $275 per hour.

To accommodate a January 2000 air schedule, I would like to begin to caption
your series in November/December. I hope we have a chance to work together.

Sincerely,

Donna Horn
Vice President, New Business Development