Before the
Federal Communications Commission
Washington, D.C. 20554


In the Matter of
 
Compatibility Between Cable Systems And
Consumer Electronics Equipment

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PP Docket No. 00-67


REPORT AND ORDER

   Adopted:  September 14, 2000	Released: September 15, 2000

By the Commission:  Commissioner Ness is issuing a statement.






I. INTRODUCTION
1. The Commission opened this proceeding to resolve outstanding issues regarding the 
compatibility of cable television systems, digital television receivers, set-top boxes, and other equipment 
used by consumers to receive and enjoy the ever-increasing array of programming and other services 
available over cable television systems.   The Notice raised two primary issues:  (1) requirements for a 
DTV receiver to be labeled cable-compatible, and (2) licensing terms for copy protection technology.  
We noted with approval that the industry parties had been negotiating about these and other 
compatibility issues and had reached agreement on some of them.   We expressed the hope and belief 
that comprehensive market-driven solutions were attainable and would be superior to a regulatory 
approach.  Because the industries had not resolved these two issues, we reluctantly initiated the 
present rulemaking.
2. Since the Notice was issued, the cable and consumer electronics industries accelerated the 
pace of their labeling discussions and, indeed, filed a joint letter announcing an agreement on two 
specific labels,  but this announcement proved premature. Subsequent representations by the Consumer 
Electronics Association and by consumer electronics retailers  made it clear that this letter did not 
embody the type of consensus required to resolve the labeling issue.   In the absence of a clear consensus 
among all relevant parties, the Commission today adopts three labels for digital television (DTV) 
equipment.
3. With regard to copy protection, the question that emerged in the comments relates to the 
Commissions navigation devices rules.   Specifically, in order for a commercially available navigation 
device to display programming that has been encrypted, the navigation device must interface with a 
security module, known as a POD (point-of-deployment) device.  Manufacturers of commercially 
available navigation devices need a technology license in order to build the interface, and some parties to 
this proceeding questioned whether copy protection measures could be included in this technology 
license. Since the question involves our navigation devices rules, we will resolve it in a companion item 
that we adopt today, the Further Notice of Proposed Rulemaking and Memorandum Opinion & 
Order/Declaratory Ruling in Implementation of Section 304 of the Telecommunications Act of 1996
Commercial Availability of Navigation Devices. As detailed therein, we find that our navigation devices 
rules do permit some amount of copy protection to be included in commercially available navigation 
devices and in the technology license that manufacturers obtain in order to build the POD-host interface. 
4. The Notice  in this proceeding also raised questions relating to scrambling channels on the 
basic service tier and our rules requiring cable operators to offer supplemental equipment to 
subscribers.  Moreover, at least one commenter provided follow-up information on implementation of 
the February 22, 2000 agreement between CEA and NCTA on technical standards and PSIP.   This 
Report and Order reviews these matters, but no rule changes are adopted. 

II. LABELING OF DTV EQUIPMENT
A. Comments 
5. In the Notice, we sought comment on whether a DTV receiver without an IEEE 1394 
connector should be labeled cable ready.   In negotiations, the cable industry had taken the position 
that every cable-ready DTV should include the 1394 connector, while the consumer electronics industry 
opposed a blanket requirement for all cable ready DTVs to have one.  Indeed, the consumer electronics 
industry wanted the option of producing a less expensive DTV without the 1394 connector.  We noted 
that we were not wedded to the term cable ready, and that different types of DTV receivers could be 
capable of accessing different combinations of cable services.  We said that, in practical terms, the issue 
is how to best indicate to consumers the capability of television receivers to operate with cable television 
systems. 
6. The May 24 letter from CEA and NCTA included labels for two types of DTV receivers.  
One type of receiver, labeled Digital Television: Cable Connect, could be directly connected to a cable 
system offering digital service and receive digital basic and premium cable programming, with a POD 
from the cable operator required to access encrypted programming.  This type of receiver would not 
include a 1394 connector and would not have interactive (two-way) capability using cable facilities.  
The Digital Television:  Cable Connect receiver would also carry a disclaimer indicating that it is not 
equipped with a 1394 digital connector, noting that users of the receiver may not receive the cable 
operators advanced and interactive digital services and High Definition programming, such as impulse 
pay-per-view, video-on-demand, enhanced program guide, and data-enhanced television services, and 
suggesting that the consumer contact the cable operator for service and programming options.  The 
second type of receiver, designated as Digital TelevisionCable Interactive, would include the same 
direct connection features as the first type of receiver, and would also feature a 1394 connector.  The 
proposed description indicates that this receiver could be connected to a digital set-top box via the 1394 
connector and thus access any advanced and interactive services that the cable operator offered via the 
set-top box.
7. In commenting on the May 24 letter, Circuit City made the point that the 1394 connector is 
not the only means of providing interactive services, and suggested that the draft labels were misleading 
to the extent that they implied otherwise.   Circuit City also pointed out that the 1394 connector might 
be useful for functions other than connecting a DTV (digital television) receiver to a cable set-top box.  
And Circuit City also alleged that the cable industry was behind schedule in completing a specification 
for an integrated bidirectional DTV, i.e., a receiver that integrated advanced and interactive functions and 
could be directly connected to a cable system, without need for a set-top box.
8. Subsequent communications from industry parties demonstrate the May 24 labels do not 
represent industry-wide consensus.  In a July 5 letter to Chairman Kennard, the president of the 
Consumer Electronics Association noted that this proceeding has stimulated a new and broader interest 
in the labeling issue, refers to the objections registered by the retail community to the proposed 
labels, and states that CEA will very shortly be meeting with other interested parties to discuss the 
matter and establish a timetable for the expeditious completion of a comprehensive labeling program.  
Interested parties  have  informed us that no agreement has been reached yet.
9. Some commenters who oppose the May 24 labels have suggested alternative approaches.  
For example, NAB/MSTV asserts that the FCC must immediately mandate IEEE 1394/5C interfaces for 
all DTV sets and set-top boxes (STB) for todays STB environment. (emphasis in original)   
NAB/MSTV argues that the 1394 connector is needed in order to transport HDTV signals from the cable 
STB to the DTV receiver and because consumers will need a consumer-friendly ubiquitous connector 
for all digital television devices.  NAB/MSTV endorses the idea of a direct connection DTV receiver as 
well but suggests that DTVs with the 1394 will be on the market earlier than direct connection receivers. 
10. Several satellite industry commenters expressed concern that the proposed labels are too 
cable-centric and could leave consumers uncertain about whether their equipment can display satellite-
delivered programming.   These commenters worry that the labels could tilt the competitive balance in 
favor of cable and against satellite delivery.  Echostar suggests alternative designations which are 
delivery system neutral, such as digital ready and/or digital compatible to identify the functionality 
of new digital television receivers and other consumer equipment.  NRTC proposes the terms Digital-
TV Interactive and/or Digital-TV Non-Interactive to identify the functionality of new digital 
television receivers and other consumer equipment. 
11. Additionally, the Consumer Electronics Retailers Coalition (CERC)  proposes a labeling 
scheme.   It suggests the following.

Cable InteractiveFeatures two-way communication facility for receipt of advanced 
and interactive cable services via this receivers remote control.  Cable security card 
required for receipt of encrypted programming.

Cable DirectFeatures direct receipt of cable programming.  Two-way communication 
not available via remote control.  Cable security card required for receipt of encrypted 
programming.

12. MPAA urges that [A]ny designation that states or implies that the receiving apparatus is 
cable-ready should be restricted to receivers that provide effective content protection.  The MPAA  
criteria for effective content protection are as follows.  The receiver would need to incorporate a POD 
module that employs encryption and authentication to protect content across the POD-host interface.  
The POD module would also need to be subject to licensing that imposes content protection obligations 
on the host device with which the POD is used.
B. Discussion
1. General Considerations
13. We agree that consumers will likely want what Circuit City refers to as a box-to-box 
connector to link digital appliances within the home and that a 1394 connector  fulfills this function.  
However, Section 624A of the Communications Act authorizes us to adopt regulations requiring 
compatibility of cable systems with televisions receivers and videocassette recorders and not, e.g., DTV 
connections to a DVD player.   Moreover, some consumers may want to use one or more of their 
television receivers solely to receive broadcast and cable programming.  Those receivers would not 
necessarily need a 1394 connector to receive such signals.  Additionally, it is not clear that DTV 
receivers with 1394 connectors will reach the market earlier than direct connection one-way receivers.   
For these reasons, we decline to require all cable-ready DTV receivers or, indeed, all DTV receivers, 
to have a 1394 connector.  We are confident that the consumer electronics industry will respond to 
consumer demand and provide DTV receivers with the features that consumers desire, and that the 
labeling scheme we adopt today will permit consumers to make well-informed decisions about DTV 
equipment purchases based on a clear understanding of the capabilities of receivers with different labels.
14. We recognize the concerns of the satellite industry regarding cable-centric labels, but 
decline to adopt their suggestions for alternative nomenclature.  First, the statute authorizes us 
specifically to require labeling of cable compatibility.  Second, the cable and consumer electronics 
industries have agreed on technical standards for connection of certain types of DTV receiver 
(unidirectional) to cable systems.   We are not aware of any comparable agreement between the 
consumer electronics industry and the direct-to-home satellite industry.  Indeed, we are not aware of any 
agreement on transmission standards among the various satellite providers (e.g., DirecTv, Echostar, C-
band).  For these reasons we decline to adopt the suggested labels.  We do note, however, that our 
navigation device rules make clear that no one can prohibit the inclusion of satellite reception capability 
in navigation devices, should a manufacturer wish to include this capability.   Moreover, we note that, in 
response to satellite industry concerns, CEA has stated that it views these issues as important and will 
work with the DBS industry to establish appropriate labeling standards with respect to satellite 
equipment and to resolve any compatibility concerns.   We encourage the consumer electronics and 
satellite industries to work toward a consensus on such standards.
15. With regard to MPAAs argument that any cable ready receiver should provide effective 
copy protection, DTV receivers that connect directly to a cable system will, as the labels described below 
make clear, require a POD to receive encrypted programming. As our companion Declaratory Ruling 
makes clear, the host device license lawfully may include copy protection provisions.   Such provisions 
may be used to ensure that content does not flow out of the host device via an unprotected output.  The 
same regime applies to cable set-top boxes.  These set-top boxes (STBs) will require a POD in order to 
access encrypted programming.  The STB will then connect to a DTV via an interface such as the 1394.  
Copy protection provisions incorporated in the host device license will be able to ensure that content 
delivered in encrypted form does not exit the STB via an unprotected output, including via the 1394 
output.  Hence, copy protection capability will be one of the characteristics of a receiver that is labeled 
cable ready.  We recognize that the content and consumer electronics industries have not yet agreed on 
licensing terms for a copy protection technology to protect the 1394 interface.  However, one such 
technology, the so-called 5C technology, has been developed and standardized, and the industries are 
negotiating over terms to use it.   For these reasons, we decline to include specific copy protection 
language in our labels.
16. We believe that a significant number of cable subscribers will choose to access cable 
programming via a digital STB and we believe that, at least initially, the 1394 interface will be the 
preferred connector for STBs and DTV receivers.  These beliefs led us to ask specifically about labels for 
DTV receivers with and without the 1394 connector.  Because the CERC labels do not address 1394 
connectors at all, we decline to adopt them.
17. The comments make clear that the labeling question centers on two characteristics of DTV 
equipment.  One is interactivitythere is a distinction between equipment that is unidirectional (can 
only receive one-way services from the cable system) and equipment that is bidirectional (can both 
receive one-way services and allow the subscriber to communicate back to the cable system to access 
additional or advanced services).  The second characteristic is connectivityconsumers may want to 
connect their DTV receiver to other equipment. (Circuit City refers to this as box-to-box connectivity.) 
Although the industry has not agreed on a specification for it yet, many commenters anticipate the 
development of an integrated, bidirectional DTV receiver, with no 1394 connector, but with the ability to 
access interactive (two-way) services via direct connection to the cable system without the need for a set-
top box.  For example, CEA states that it is anxious to continue to work with NCTA to create open 
standards required for the direct connection to cable systems by receivers that possess full two-way data 
transmission and reception capability, and which support advanced and interactive services without the 
need for any set-top box, and notes that the CEA Cable Compatibility Committee (R-8) has initiated 
work on standards for two-way operation.   For its part, NCTA states that an integrated bi-directional 
DTV set can be developed based on the specifications for the bi-directional set-top box which are 
available and indicates that [F]urther discussions are expected between the two industries on 
developing the specifications for the bi-directional (interactive) DTV sets which retailers are justifiably 
eager to sell.  Although a bidirectional DTV receiver would not need a 1394 connector to access a 
cable STB, the owner of the receiver might want a 1394 connector in order to connect the DTV to other 
equipment in the home, perhaps a digital VCR or DVD player on the input side as well as on the output 
side to a VCR.
18. A subscriber with the device described in the May 24 letter as Digital TVCable 
Interactive, i.e., a unidirectional DTV receiver equipped with a 1394 connector, could access advanced 
and interactive services via a set-top box.  To the extent that cable operators are continually developing 
new services, and to the extent that some of those services may require capabilities not available in 
earlier models of DTV receiver, one can imagine a subscriber wanting a 1394 connector as an insurance 
policy.  Rather than replacing his or her DTV receiver in order to upgrade the capability to access 
advanced  services, the subscriber might prefer to purchase an upgraded set-top box and connect it to the 
DTV using a 1394 connector.  
19. Several commenters also point out that digital interfaces in addition to the 1394 are likely to 
become available.  For example, Matsushita Electric Corporation of America MECA) states that its 
commitment to the copy-protected 1394 interfacehas never been intended to be exclusive of utilization 
of, and support for, other present and future interfaces and anticipates that, ultimately, OpenCable 
documents and specifications will support such other interfaces as well.   Sony notes that [O]ther 
interfaces and means of delivering a signal already exist.  Others no doubt will emerge.  The labels 
ultimately adopted must take this into account.    For its part, Fox states that, in addition to working 
with the 5C group, it is working on other copyright-compliant digital technologies with Victor 
Company of Japan Ltd. (JVC).   Additionally, ATI refers to the DVI (with HDCP or some other form 
of copy protection as an alternative to 1394. 
20. These considerations lead us to establish labels for three types of DTV receivera 
unidirectional receiver capable of direct connection to the cable system, a unidirectional receiver capable 
of direct connection but that also includes a 1394 connector, and a bidirectional receiver capable of direct 
connection to the cable system and of accessing interactive services using that direct connection.  As 
suggested above, some consumers may want a DTV receiver that is both bidirectional and has a 1394 
connector, and we assume that some manufacturers will cater to this preference. We wish to reemphasize 
that the 1394 connector is by no means the only digital connector that is, or will become available.  DTV 
receivers and other devices that incorporate the 1394 connector may well also incorporate an additional 
digital connector or connectors.   And, of course, manufacturers, retailers, and others are free to provide 
information to the consuming public about these connectors.  We recognize that, at some point, 
technological developments may lead to an environment in which, for at least some consumers, another 
digital connector would be used in place of the 1394 connector.  At that point in time, we would, of 
course, be able to consider adding to our list of labels.
21. Additionally, because specifications for the bidirectional direct connection receiver have not 
yet been finalized, and because other digital interfaces that are suitable for connecting a cable set-top box 
to a DTV receiver may be developed, we will keep this docket open and require periodic reports from the 
cable and consumer electronics industries on the development of the specifications, approved by an 
accredited standards body, that we anticipate will be adopted.  In paras. 35 and 36 infra, we impose 
limited reporting requirements on the industries with respect to issues that were substantially but not 
completely resolved by the February 22, 2000 agreements.  We adopt a single timetable for the reports 
on all of these matters, requiring the cable and consumer electronics industries to report to us by October 
31, 2000 and every six months thereafter until October 2002 on progress in developing standards to 
implement the integrated bidirectional receiver.  By keeping this docket open and imposing these 
reporting requirements, we preserve the option of incorporating into our rules the formal standards that 
we expect will result from continuing industry efforts to implement the February 22, 2000 agreements 
and to develop specifications for a bidirectional direct connection digital television receiver.
22. Because our statutory labeling authority specifically mentions the terms cable ready and 
cable compatible, and because we do not wish to constrain unduly the marketing flexibility of 
manufacturers and retailers, we will base our labels on the term cable ready.  We recognize that 
manufacturers and retailers may wish to use additional terminology to describe DTV receivers and, 
consistent with the rules we adopt today, they may do so. 
23. Section 624A of the Communications Act, as amended (Act) provides, in part that [T]he 
regulations prescribed by the Commission under this section shall include such regulations as are 
necessary (A) to specify the technical requirements with which a television receiver or video cassette 
recorder must comply in order to be sold as cable compatible or cable ready.   Section 624A also 
provides that [T}he Commission shall periodically review and, if necessary, modify the regulations 
issued pursuant to this section in light of any actions taken in response to such regulations and to reflect 
improvements and changes in cable systems, television receivers, video cassette recorders, and similar 
technology.   These provisions were adopted in 1992, prior to the authorization of digital television 
service.  At that time, analog cable systems incorporated a limited number of technical capabilities, so a 
single category of television receivers that could be called cable ready was appropriate.  Today, cable 
television systems provide a more varied mix of services than before and that variety is likely to increase 
over time.  Consequently, and consistent with the comments cited in this section, we believe it is 
appropriate to adopt labels for more than one type of DTV receiver.  In addition to our Section 624A 
authority referenced earlier in this paragraph, Section 336  of the Act also provides us the authority to go 
beyond the cable ready/not cable ready dichotomy.  That section, which addresses the transition from 
analog to digital television, reads, in pertinent part:  [I]n prescribing the regulations required by 
subsection (a), the Commission shall (4) adopt such technical and other requirements as may be 
necessary or appropriate to assure the quality of the signal used to provide advanced television services, 
and may adopt regulations that may stipulate the minimum number of hours per day that such signal 
must be transmitted; and (5) prescribe such other regulations as may be necessary for the protection of 
the public interest, convenience, and necessity. 
2. Label Definitions
24. We will define Digital Cable Ready 1 as follows: A consumer electronics TV receiving 
device capable of receiving analog basic, digital basic and digital premium cable television programming 
by direct connection to a cable system providing digital programming. This device does not have a 1394 
connector or other digital interface. A security card (or POD) provided by the cable operator is required 
to view encrypted programming. 
25. We will define Digital Cable Ready 2 as follows: A consumer electronics TV receiving 
device capable of receiving analog basic, digital basic and digital premium cable television programming 
by direct connection to a cable system providing digital programming. This receiving device will 
incorporate all features defined in Digital Cable Ready 1 and will also include the 1394 digital interface 
connector. A security card/POD provided by the cable operator is required to view encrypted 
programming. (Note:  The 1394 connector may be used for attaching the receiving device to various 
other consumer appliances, including a digital cable set-top box that incorporates the 1394 connector.  
Connection of a Digital Cable Ready 2 receiver to a digital set-top box may support advanced and 
interactive digital services and programming delivered by the cable system via the set-top box.) 
26.  We will define Digital Cable Ready 3 as follows: A consumer electronics TV receiving 
device capable of receiving analog basic, digital basic and digital premium cable television 
programming.  This device will incorporate all features defined in Digital Cable Ready 1 and will also 
receive advanced and interactive digital services by direct connection to a cable system providing digital 
programming and advanced and interactive digital services.  A security card/POD provided by the cable 
operator is required to view encrypted programming.   
27.  Consumer electronics manufacturers currently are marketing DTV receivers capable of 
receiving off-the air digital terrestrial broadcasts.  We note, however, that a DTV receiver could, in 
principle, comply with our Digital Cable Ready labeling requirements and not have the capability of 
receiving off-the-air digital signals.  In the analog context consumers have the expectation that television 
sets they purchase to work with their cable systems will also receive over-the-air broadcast signals.  We 
expect that in the digital world this will continue.  If, however, manufacturers produce receivers that 
consumers can use with their digital cable systems, but that will not receive digital broadcast signals, we 
expect that they would be labeled as such to avoid consumer confusion.
28.   Additionally, we wish to reiterate that manufacturers may choose to build television 
receiving devices that incorporate both the Digital 2 and Digital 3 standards, because the 1394 connector 
may be used for purposes other than connecting a television receiving device to a cable set-top box (e.g., 
to connect a television receiving device and a DVD player or a digital recorder).   Moreover, we wish to 
note that agreed-upon industry specifications for the Digital 3 set do not yet exist.  We know that the 
consumer electronics manufacturers are interested in building such a receiver, the retailers are interested 
in marketing such a receiver, and the cable industry has expressed its willingness to complete the 
specifications.   We encourage the interested parties to work together to complete the relevant 
specifications promptly.
29. In the Notice, we framed the labeling issue as how to best indicate to consumers the 
capability of television receivers to operate with cable television systems.   We continue to believe that 
avoiding consumer confusion is an important goal.  This is consistent with our decision in the Equipment 
Compatibility First Report and Order to require cable operators to provide subscribers a consumer 
education program on compatibility issues, a requirement that is still in effect.   In Section 624A, 
Congress expressed the concern that compatibility problems might reduce consumer demand for and 
manufacturer willingness to supply television receivers and video cassette recorders with new and 
innovative features and functions.   Although the specific reference was to receiver features that were 
disabled due to cable encryption implementation, the Congressional concern for fostering the availability 
of equipment with new and innovative features and functions is clear.  Along the same lines, when 
discussing standards for digital cable transmissions, the Commission proclaimed the necessity of 
avoiding compatibility problems in order to allow the mass production of economical consumer 
equipment that is compatible with cable digital services.  Moreover, in the Notice, we also pointed out 
that [W]ithout resolution of outstanding compatibility issues, the transition from analog to digital 
broadcasting will be slowed, and the reclamation and reallocation of portion of the spectrum now 
allocated for analog television service will be delayed.   These considerations--avoiding consumer 
confusion and helping to speed the digital transitionlead us to take an additional step in labeling 
requirements.  Based on our authority under Sections 624A, 336, and 4(i), we will require that television 
receiving devices that provide any of the three sets of functions described above must indicate this by a 
notation of the form Meets FCC labeling standard Digital Cable Ready x, referencing the applicable 
designation or designations.  The physical placement of the labels shall be governed by the terms of 47 
C.F.R. 2.925(d) and (e).
III. OTHER MATTERS
30. The Notice sought comment on current cable industry practices with respect to digital 
services , including whether these services are ever provided on the basic service tier, whether they are 
generally scrambled, and whether we should permit scrambling of nonbroadcast digital channels on the 
basic tier.  We also noted that the question of whether retransmitted local digital broadcast signals must 
be provided on the same tier that includes local analog broadcast signals is open in the digital must carry 
 proceeding.  With regard to current practice, NCTA notes that 
It is premature at this early stage of the digital transition to forecast what services will be 
encrypted in the future and which will not.  As for cables current practice, as a 
general rule, and based on very limited experience, all digital serviceswith the 
exception of retransmitted non-encrypted local broadcast signalsare encrypted to 
provide for basic signal security.  These digital services are provided on separate cable 
programming service (CPS) digital tiers, not the basic tier.  

Time Warner Cable suggests that the Commission should decline to consider issues relating to 
scrambling and tier positions of digital broadcast stations in this proceeding, deferring them instead to 
the pending Digital Must Carry proceeding.   On the other hand, the Home Recording Rights Coalition 
suggests that a prohibition on scrambling basic services is not needed in the digital domain, provided 
that such scrambling is not used to deny viewing to consumers as a clumsy form of copy protection. 
(emphasis in original). 

31. Joint comments from the four largest commercial broadcasting networks assert their belief in 
the critical importance of adequate copy protection for broadcast television, not only for the rapid 
implementation of DTV but for the future of our medium.   The networks express concern at the 
possibility of unfettered Internet retransmission of their programming and go on to state that
The Commission should not preclude any digital program service, including broadcast 
programming, from being carried on the basic programming tier simply because it is 
encryptedThe ability to encrypt need not affect the universality of broadcast television 
nor its status as a free to the consumer program service.  Because it may well be 
necessary to require conditional access in order to utilize available copy protection 
technology, broadcasters and other digital programming services should be afforded the 
flexibility to encrypt their signals.  Accordingly, the Commission should adopt a flexible 
approach, and should not impose or retain any regulation that would preclude any digital 
programming service (broadcast or non-broadcast) from being included in a basic 
programming tier simply because such digital programming service is delivered on a 
conditional access basis. 

Time Warner Cable opines that [B]roadcasters should not be permitted to demand that cable operators 
encrypt their retransmitted signals if such signals are not also encrypted when delivered over-the-air.   
CEA asserts that it has received indications from certain large MSOs that they plan to scramble all 
channels, including the broadcast signal on all systems and argues that cable operators should be 
required to provide in the clear all over-the-air broadcast and basic cable programming channels that are 
generally not subject to scrambling in the analog cable environment.  

32. We agree that this proceeding is not the proper venue for resolving issues related to 
scrambling of digital broadcast signals and their placement on cable service tiers.  Tiering and signal 
carriage issues are more properly considered in our pending digital must carry proceeding.   To the 
extent that commenters such as the Broadcast Networks, Fox Entertainment Group, and the Professional 
and Collegiate Sports Leagues  are raising issues relating to encryption of over-the-air DTV 
transmissions by broadcast licensees, we believe that the record is insufficient to come to a conclusion. 
33. The Notice also sought comment on whether the transition to digital necessitates any 
amendment to our requirements for cable operators to offer supplemental equipment to subscribers, to 
enable them to use special features of their digital television receivers. (citation omitted)   Examples of 
special features include picture in picture and the ability to view one channel while taping a program 
on another.  Our rules currently require cable operators that scramble any of their signals to provide 
supplemental equipment that will enable the simultaneous reception of multiple signals.   No 
commenter suggested modifying our rules and only one commenter addressed the issue.  CEA notes that

Currently, a subscriber to digital cable service would find it impossible to fully utilize 
the picture-in-picture, channel-shift consecutive recording, and record-while watch 
functionalities of digital consumer electronics equipment without the provision of  one 
or more operator-supplied set-top boxes.  In a modular security environment, two or 
more PODs and complementary POD interfaces on the host devices will be necessary to 
effect these functions, because PODs are capable of passing only one channel at a time 
for display. 

This situation is parallel to what exists now in the analog domain, and 47 C.F.R. 76.630(c) reflects this 
situation.  We see no need to impose different requirements for digital television at this time. Hence we 
will not modify our supplementary equipment rules.

34. A few commenters provide opinions on the two compatibility issues that are the subject of 
the February 22, 2000 agreement between CEA and NCTA , issues on which comment was not sought 
in the Notice.  One issue addressed in the February 22 agreement is provision of tuning and program 
schedule information to support the navigation function of DTV receivers, including on-screen program 
guides.  This information is generally referred to as PSIP (Program and System Information Protocol) 
information.  The February 22 agreement outlined a series of steps that the industries need to take in 
order to ensure provision of this information to DTV receivers.  CEA notes that while significant 
progress has been made between the cable and consumer electronics industries regarding electronic 
program guides (EPGs), there remain several issues regarding implementation of the February 22, 
2000 agreement. CEA goes on to specify two matters relating to PSIP, noting that program producers 
must insert guide...information into each program before it is delivered to cable for distribution and the 
cable industry must implement the technical means to ensure that each programs PSIP information is 
delivered to the DTV set with out corruption, through any and all cable plants.  CEA urges the 
Commission to support and help promote industry efforts on both actions, each of which will take some 
time to implement reliably, even as terrestrial broadcasters and their program suppliers have been 
learning to do over time.    Thomson opines that the PSIP agreement reflects very significant 
progress, but notes that further work is needed in terms of filling in important details.    NAB/MSTV 
notes that the PSIP agreement is not  complete and asserts that the Commission must establish quick 
deadlines for completing the standard and implementation.   
35. As noted, the Notice did not propose Commission action with respect to PSIP.  Moreover, 
the parties to the agreement express some confidence in their ability to finalize it and do not seek FCC 
intervention.  Nevertheless we are eager to see the agreement finalized and become the basis for actual 
DTV equipment.  Moreover, we indicated our continuing interest in the development of EPGs in our 
Navigation Devices Report and Order.   We anticipate that the implementation of the PSIP agreement 
will result in the adoption of  certain standards by an accredited standards organization or organizations.  
Since we are keeping this docket open, we will require the cable and consumer electronics industries to 
report to us by October 31, 2000 and every six months thereafter until October 2002 on progress in 
implementing the PSIP agreement.  
36. NAB/MSTV also expressed concern about implementation of the February 22, 2000 
agreement on technical requirements for direct connection of digital television receivers to digital cable 
systems, complaining that the agreement is embodied in not one but two separate RF interconnection 
standards.   In order to monitor the completion of the agreement, which we expect will lead to standards 
adopted by an accredited standards organization, we will require the cable and consumer electronics 
industries to report to us on progress in implementing the technical requirements agreement, according to 
the same schedule established for tracking progress on the PSIP agreement.   These reporting 
requirements, along with our decision to keep this docket open, will give the Commission the option of 
incorporating into our rules any formal standards that the industries adopt with respect to  technical 
connection requirements and/or PSIP.
37. Several commenters also raised issues in connection with closed captioning, another issue 
that was not part of the Notice in this proceeding.  These matters are the subject of another Commission 
proceeding in which a Report and Order was recently adopted.   Hence this decision will not address 
closed captioning.  
IV. PROCEDURAL MATTERS
38. In order to provide manufacturers sufficient lead time to incorporate the new labels into their 
DTV product lines, the new labeling rules will take effect on July 1, 2001.
39. Final Regulatory Flexibility Certification.  A Final Regulatory Flexibility Certification, see 5 
U.S.C. 605 , is contained in Appendix C.
V. ORDERING CLAUSES
40. Ordering Clauses.  IT IS ORDERED that, pursuant to Sections 1, 4(i) and (j), 336, and 
624A of the Communications Act of 1934, as amended, 47 U.S.C.  151, 154(i) and (j), 336, and 544a, 
the Commissions rules ARE AMENDED, as set forth in Appendix A.
41. IT IS FURTHER ORDERED that the Consumer Information Bureau, Reference 
Information Center, SHALL SEND a copy of this Report & Order, including the Final Regulatory 
Flexibility Certification, to the Chief Counsel for Advocacy of the Small Business Administration.


Federal Communications Commission



Magalie Roman Salas
Secretar

APPENDIX A


Part 15 of Title 47 of the Code of Federal Regulations is amended as follows:

47 C.F.R. 15.3(aa) is amended adding at the end of the last sentence the following.
and the provisions of 15.19(d).

47 C.F.R. 15.19(d) is amended by redesignating the text as 47 C.F.R. 15.19(d)(1) and adding a new 47 
C.F.R. 15.19(d)(2) as follows.

(d)(2)(i) Consumer electronics TV receiving devices, including TV receivers, videocassette recorders, 
and similar devices, that include digital video signal processing capability and incorporate features 
intended to be used with digital cable television service, but do not provide one or more of the feature 
sets described in 15.19(d)(2)(ii) of this Chapter, shall not be marketed with terminology that describes 
the device as cable ready or cable compatible or otherwise conveys the impression that the device is 
fully compatible with digital cable service.  Devices marketed as digital cable ready or digital cable 
compatible or otherwise conveying the impression that the device is fully compatible with digital cable 
service must offer one or more of the feature sets (i.e., Digital Cable Ready 1, Digital Cable Ready 2, 
Digital Cable Ready 3) specified in  15.19(d)(2)(ii) of this Chapter and carry the corresponding 
descriptive label or labels.  With respect to their analog signal processing capabilities, these devices must 
also comply with the technical standards for cable ready equipment set forth in  15.118 of this Chapter. 
Devices not marketed as digital cable ready or digital cable compatible may be accompanied by 
factual statements about the various features of the devices that are intended for use with digital cable 
service and/or the quality of such features, provided that such statements do not imply that the devices is 
fully compatible with digital cable service.  Statements relating to product features are generally 
acceptable where they are limited to one or more specific features of a device, rather than the device as a 
whole. 

(d)(2)(ii) Descriptive Labels for consumer electronics TV receiving devices with digital signal 
processing capability.

Digital Cable Ready 1 refers to a consumer electronics TV receiving device capable of receiving analog 
basic, digital basic and digital premium cable television programming by direct connection to a cable 
system providing digital programming. This device does not have a 1394 connector or other digital 
interface. A security card (or POD) provided by the cable operator is required to view encrypted 
programming.  

Digital Cable Ready 2 refers to a consumer electronics TV receiving device capable of receiving analog 
basic, digital basic and digital premium cable television programming by direct connection to a cable 
system providing digital programming. This receiving device will incorporate all features defined in 
Digital Cable Ready 1 and will also include the 1394 digital interface connector. A security card (or 
POD) provided by the cable operator is required to view encrypted programming. 

Digital Cable Ready 3 refers to a consumer electronics TV receiving device capable of receiving analog 
basic, digital basic and digital premium cable television programming. This device will incorporate all 
features defined in Digital Cable Ready 1and will also receive advanced and interactive digital services 
by direct connection to a cable system providing digital programming and advanced and interactive 
digital services and programming.  A security card (or POD) provided by the cable operator is required 
to view encrypted programming. 


(d)(2)(iii) Consumer electronics TV receiving devices, including TV receivers, videocassette recorders, 
and similar devices, that include digital video signal processing capability and that provide one or more 
of the feature sets (i.e., Digital Cable Ready 1, Digital Cable Ready 2, Digital Cable Ready 3)described 
in  15.19(d)(2)(ii) of this Chapter, must carry the label or labels from 47 C.F.R. 15.19(d)(2)(ii) that 
describe the feature sets offered by the device.  The format of the label or labels shall conform to the 
provisions of   2.925(d) and (e) of this Chapter.

(d)(2)(iv) The requirements of this section apply to consumer TV receivers, videocassette recorders and 
similar devices manufactured or imported for sale in this country on or after July 1, 2001.

47 C.F.R. 15.118(a) is amended by adding the following sentence at the end.


Until such time as generally accepted testing standards are developed, 15.118(c) and (d) of this 
Chapter will apply only to the analog portion of covered consumer electronics TV receiving equipment

APPENDIX B
COMMENTERS

Association of Local Television Stations, Inc.
ATI Technologies
5C Digital Transmission License Administrator
Broadcast Networks (ABC,CBS, Fox, NBC)
Cable Networks (Turner, HBO, Disney, Fox Cable Networks, MTV Networks)
Circuit City Stores
Consumer Electronics Association
Echostar Communications Corporation
Fox Entertainment Group, Inc.
Home Recording Rights Coalition
Information Industry Technology Council
Julio Loza, Private Citizen
Media Access Group at the WGBH Educational Foundation
Metro Goldwyn Mayer Studios Inc.
Motion Picture Association of America
Motorola, Inc.
National Association of Broadcasters and the Association for Maximum Service
  Television, Inc.                                     
National Cable Television Association (Comments plus separate letter)
Office of Advocacy, US Small Business Administration
Philips Electronics North America Corporation
Professional and Collegiate Sports Leagues
Satellite Broadcasting and Communications Association
Thomson Consumer Electronics
Time Warner Cable
Viacom, Inc.


REPLY COMMENTERS

Association of Local Television Stations, Inc.
Circuit City Stores
Consumer Electronics Association
Consumer Electronics Retailers Association
Digital Transmission Licensing Administrator
Echostar Communications Corporation
Fox Entertainment Group, Inc.
Home Recording Rights Coalition
Matsushita Electric Corporation of America
Motion Picture Association of America
National Association of Broadcasters and the Association for Maximum Service
  Television, Inc.
National Cable Television Association
National Rural Telecommunications Cooperative
Sony Electronics Inc.
Thomson Consumer Electronics, Inc.
Time Warner Cable
Zenith Electronics Corporation

APPENDIX C
FINAL REGULATORY FLEXIBILITY CERTIFICATION


1. The Regulatory Flexibility Act (RFA)  requires that an agency prepare a regulatory 
flexibility analysis for notice-and-comment rulemaking proceedings, unless the agency certifies that "the 
rule will not, if promulgated, have a significant economic impact on a substantial number of small 
entities."   The Notice of Proposed Rulemaking (Notice)  in this proceeding proposed rules to resolve 
outstanding compatibility issues between cable television systems and consumer electronics equipment, 
in particular, requirements for labeling digital television (DTV) receivers to describe their capabilities to 
operate with digital cable television systems, and questions regarding licensing terms for copy protection 
technology.  Out of an abundance of caution, the Commission published an Initial Regulatory Flexibility 
Analysis (IRFA) in the Notice, even though the Commission was reasonably confident that any economic 
effect on small entities would be minimal. The IRFA sought written public comment on the proposed 
rules and our tentative conclusions in the IRFA. We received one written comment in response to the 
IRFA, from the U.S. Small Business Administration (SBA). 

2. As noted, the Notice in this proceeding raised two issues -- labeling of digital television 
receivers and copy protection technology licensing terms.  The second issue has now been moved to 
another proceeding and resolved therein via a declaratory ruling.  The present Report and Order 
addresses only the labeling of  consumer electronics TV receiving devices, including TV receivers, 
videocassette recorders, and similar devices, that include digital video signal processing capability and 
incorporate features intended to be used with digital cable television service.  The impact of the rules 
adopted is thus on manufacturers of consumer electronics TV receiving devices.  The rules do not 
mandate any particular design or set of features for this equipment. They merely require manufacturers 
to attach specified labels to receiving devices that provide certain sets of features.  Of course, 
manufacturers of consumer electronics TV receiving devices already package and label their products 
with various descriptive captions.  Moreover, we believe that manufacturers generally find it in their 
interest to ensure that consumers understand the capabilities of the product being offered for sale.  
Hence, manufacturers actually have commercial incentives to label their products clearly.  
(Concomitantly, consumers also benefit from the information in product labels.)  For these reasons, and 
for reasons we discuss additionally below, we certify, pursuant to the RFA, that the labeling 
requirements adopted in the present Report and Order will not have a significant economic impact on a 
substantial number of small entities.

3. On the labeling issue as described in the IRFA, the SBA stated, The Commission   . . . 
asserts that its labeling rules would have a minimal impact, because labeling would be standardized, 
costs would be spread over sufficient quantities of goods as to be insubstantial, and manufacturers could 
pass costs on to their subscribers.  But this ignores the differences in output or customer base that may 
exist between a small company and a large company.  A business with less output or fewer customers 
might find its per unit costs are higher.  The Commission should explore any such potential cost 
discrepancies based on business size, not simply dismiss them as minimal.  As described in the Report 
and Order, pursuant to the new rule, manufacturers must label the pertinent products with labels that 
meet the requirements of Section 2.925 of the Commissions Rules, 47 C.F.R.  2.925.  Manufacturers of 
transceivers must already label their equipment to demonstrate compliance with the Commissions 
equipment authorization rules.  Such labels must be permanently affixed to the equipment and . . . be 
readily visible to the purchaser at the time of purchase.  Section 2.925(d).  The manufacturer may 
choose the means to make the label permanent, including using a nameplate (of material of the 
manufacturers choosing) fastened to the equipment with a permanent adhesive.  While we do not wish 
to favor one type of labeling choice over another, we note that use of an adhesive label containing the 
additional information at issue should not create a significant economic impact for any manufacturer, and 
in fact probably represents an insignificant economic impact.  The cost of paper labels with adhesive, 
containing brief information specified by rule, would appear to be minimal.  Finally, the rules permit 
manufacturers to request alternative means of labeling.  Section 2.925(e).

4. The Commission will send a copy of the present Report and Order, including a copy of this 
final certification, in a report to be sent to Congress pursuant to the Small Business Regulatory 
Enforcement Fairness Act, see 5 U.S.C.  801(a)(1)(A). In addition, the Commission will send a copy of 
the Report and Order, including a copy of this final certification, to the Chief Counsel for Advocacy of 
the SBA. In addition, a copy of the Report and Order (or a summary thereof) and this final certification 
will be published in the Federal Register.  See 5 U.S.C.  605(b).

APPENDIX D

Sample Comparison Chart for Digital Cable Ready TV Receiving Devices



Digital Cable Ready 1
Digital Cable Ready 2
Digital Cable Ready 3
Receives analog
basic cable
service via direct
connection
?
?
?
Receives digital
basic cable service 
via direct
connection
?
?
?
Receives digital
premium cable
service via direct
connection
?
?
?
Requires a
security card (or
POD) to receive
encrypted
programming
?
?
?

Includes the 1394 
connector



?


Not Required

Supports 
interactive and 
two-way services 
over cable

?
?
Direct Connection to 
cable for interactive 
and two-way 
services


?

NOTES:
(1) The Cable Ready Digital 2 receiving device may incorporate other digital interfaces in addition 
to the 1394 connector.  The Cable Ready Digital 3 connector may incorporate the 1394 digital 
connector and/or other digital interfaces.

(2) The 1394 connector may be used for attaching the receiving device to various other consumer 
appliances, including a digital cable set top box that incorporates the 1394 connector

Separate Statement of Commissioner Susan Ness


In Re: Compatibility Between Cable Systems and
Consumer Electronics Equipment
(PP Docket No. 00-67)

While I support this item as a necessary step to further the digital transition, I am concerned 
that our new labeling regime  which is intended to protect consumers -- will not do so.  

Consumers today fully expect to have the capability to receive analog over-the-air signals 
when they purchase a television set.  The same will be true of consumers buying integrated 
digital TV sets in the future.  They will naturally expect a digital TV set to be capable of 
receiving a digital over-the-air signal, even if they initially intend to connect it to the cable 
system. 

Manufacturers may be designing digital TV sets that, under the rules we adopt today,  will 
bear the digital cable ready label but are unable to receive an over-the-air digital signal.  In 
other words, what will look like a TV set actually will be incapable of ever receiving an over-the-
air digital signal.  

Our cable compatibility labels should not exacerbate this problem.  By placing the FCC 
imprimatur on a device that, while cable compatible, is incapable of receiving a digital over-the-
air signal, we add to consumer confusion  and consternation.  In my opinion, a digital television 
receiver that carries a label blessed by the Federal Communications Commission should be able 
to receive an over-the-air digital signal.

The marketplace works best when consumers can make informed choices.  They should have 
the opportunity to buy a cheaper TV set if they want to; but they should be told if that set cannot 
perform the basic function that consumers have grown up to expect. 

We can solve this problem.  Any integrated, cable-compatible digital television receiver that 
is incapable of receiving an over-the-air signal should bear a warning to that effect.  Consumers 
then will be alerted at the point of sale whether the costly device they are about to buy has the 
functionality they expect.

To do otherwise is inconsistent with our duty to the American public and inconsistent with 
our desire to ensure a smooth transition from analog to digital that works for the American 
public.

       I intend to work with my colleagues, along with the consumer electronics, cable, and 
broadcasting industries over the next few weeks to address what I believe is a critical issue in the 
transition to digital broadcasting.  Hopefully, we can forge an agreement to address this problem; 
otherwise I am prepared to take further FCC action to protect the American consumer.






   Notice of Proposed Rulemaking in PP Docket No. 00-67, 15 FCC Rcd 8776 (2000) (Notice)
  See Notice at 8776-77.  The Commission  noted therein that agreements between the Consumer Electronics 
Association and the National Cable Television Association in February 2000 had resolved two of the four major 
compatibility issues then outstandingtechnical requirements for direct connection of digital television receivers 
to digital cable systems, and provision of  tuning and program scheduling information to support the navigation 
function of digital television receivers, including on-screen program guides.  The other two issues, labeling and 
copy protection technology licensing, were addressed in the Notice.
   See Letter from Robert Sachs, President and CEO, National Cable Television Association and Gary Shapiro, 
President and CEO, Consumer  Electronics Association to William Kennard, Chairman, FCC (May 24, 2000) 
(May 24 Letter).
  See Consumer Electronics Association Reply Comments at 2-7, Letter from Michael Petricone to Magalie R. 
Salas, Federal Communications Commission, Office of the Secretary (June 27, 2000) in PP Docket No. 00-67 
(asserting that as  practical matter, implementation of labels by manufacturers over retailer opposition would be 
difficult.), Consumer Electronics Retailers Coalition Reply Comments at 2 (asserting that the CEA/NCTA labels 
would mislead consumers, would impede competition, and would undermine, rather than strengthen, the crucial 
OpenCable initiative that it was intended to support.), Circuit City Stores, Inc. Reply Comments at 1-4. 
    We note that NCTA regards the May 24 agreement as responsive to the Commissions call in  the Notice and 
stands by the agreement.   See Letter from Robert Sachs, President and CEO, National Cable Television 
Association to William Kennard, Chairman, FCC (June 13, 2000).
  47 C.F.R. 76.1200-1210.
  We incorporate by reference all comments and reply comments in PP Docket No. 00-67 into CS Docket No. 97-
80.
  See Letter from Robert Sachs, President and CEO, NCTA and Gary Shapiro, President and CEO, CEA to 
William Kennard, Chairman FCC (Feb. 22, 2000) (February 22 Letter)The letter and its two appendices detail 
agreements on technical requirements for direct connection of digital television receivers to digital cable systems 
and on provision of tuning and program scheduling information to support the navigation function, including on-
screen tuning guides.  The term PSIP stands for Program and System Information Protocol.  PSIP is a set of 
specifications for how to transmit tuning, scheduling, and related information about programs.
  Appendix B contains a list of comments and reply comments.
  See Notice at 8783-84.  The IEEE 1394 standard describes a two-way  bus connector capable of carrying a 
compressed digital video bitstream. 
    See Notice at 8781 (ftn. 34).
  For example, a cable subscriber with such a receiver could not use cable facilities to order a pay-per-view 
movie.  Depending on the capabilities of the cable system, however, the subscriber might be able to perform this 
function using his/her telephone line.
   See Letter from Robert Sachs, President and CEO, National Cable Television Association and Gary Shapiro, 
President and CEO, Consumer  Electronics Association to William Kennard, Chairman, FCC (May 24, 2000), 
Attachment.
  Circuit City Reply Comments at 3
  Letter from Gary Shapiro, President and CEO, Consumer Electronics Association to William Kennard, 
Chairman, FCC (July 5, 2000).  See also Reply Comments of CERC at 8 (if there are to be any further FCC 
industry consultations with respect to this proceeding, CERC members would like to be included.)
  NAB/MSTV Comments at ii.  See also Julio Loza Reply Comments at 4.  The term 5C refers to a copy 
protection technology developed by Intel, Matsushita, Sony, Hitachi, and Toshiba.  See Comments of the 5 
Digital Transmission License Administrator. 
   See Satellite Broadcasting and Communications Association Comments at 4, Echostar Communications 
Corporation Comments at 3-4, National Rural Telecommunications Cooperative Reply Comments at 4-5.. 
    CERC Reply Comments at 7.
   See MPAA Comments at 4-5. details the criteria for effective content protection.  The receiver would need to 
incorporate a POD module that employs encryption and authentication to protect content across the POD-host 
interface.  The POD module would also need to be subject to licensing that imposes content protection obligations 
on the host device with which the POD is used. 
   see 47 U.S.C. 544a(b)
 See Audio Notes in Audio Week Vol. 12, # 24 (June 12, 2000). 
 See February 22 Letter.
  See 47 C.F.R. 76.1204(c).
  CEA Reply Comments at 3.
   To deploy the POD module, the host device must have an appropriate interface, and, to build that interface, the 
manufacturer of the host device will need a license for the necessary technology. 
  The 5C technology is a cryptographic protocol for protecting audio/video entertainment content from 
unauthorized copying, intercepting and tampering as it traverses high performance digital interfaces.  See 
Comments of the 5C Digital Transmission License Administrator at 2.
  CEA Reply Comments at 8.  See also Sony Reply Comments at 3 (noting that the May 24 labeling 
recommendation does not address the appropriate label that should accompany a fully integrated DTV:  one with 
a built-in receiver, monitor, and navigation device functionality, capable of supporting advanced and interactive 
digital cable services through direct connection to the cable system.  Given consumer desire for simplicity in 
consumer electronics products, as well as the expected attractiveness of such services, we anticipate that the 
market for such television receivers will be significant.) and Philips Comments at 6, ftn 8 (defining only two 
levels of cable-ready may not be sufficient to effectively inform the consumer of all the different possibilities 
and limitations of the different combinations of DTV receivers, analog TV receivers and STBs.)
   See Status Report in CS Docket 97-80 at 10-11 (filed July 7, 2000 by NCTA et al.). See also Time Warner 
Cable Reply Comments at 3 (raising the possibility that when the bidirectional receiver has been invented, then 
a label for it might refer to interactive functions).
  Matsushita Electric Company of America Comments at 3.
  Sony Comments at 3.
  Fox Comments at 3.  See also JVC Announces Copy Protection System for Digital VHS (JVC News Release, 
www.jvc-victor.co.jp/english/products/vcr/D-security.html (noting that Fox has endorsed for its own HD content a 
copy protection system including Intels HDCP (High-bandwidth Digital Content Protection) and DVI (Digital 
Visual Interface) technologies for delivering and copy-protecting uncompressed digital signals.)
  ATI Comments at 2.  In fact, ATI argues that a high resolution display device should only be labeled cable 
compatible if it includes either a YPrPb or DVI (with HDCP or some other form of copy protection) connector.  
This will enable consumers to take full advantage of their high resolution display devices by displaying high 
resolution computer graphics data in addition to high resolution video data.  DVI , or Digital Video Interface is 
a high-speed digital baseband interface that can pass through uncompressed high definition video content.  HDCP, 
or High-Bandwidth Digital Content Protection is a copy protection technology suitable for implementation over 
DVI.  We believe that our statutory mandate does not extend to labeling high resolution display devices to 
describe their ability to display computer graphics data.  The question of how high resolution content is delivered 
to computer monitors is one that should be left to the marketplace.
    See, e.g., Letter from Marc Berejka and Nicos Tsilas, Microsoft Corporation, to Magalie R. Salas, Federal 
Communications Commission, Office of the Secretary (Sept. 7, 2000), referring to other standards, such as the 
Digital Visual Interface (DVI), Universal Serial Bus (USB), or Internet Protocol (IP) standard that could 
facilitate the offering of advanced digital services to American consumers. (ftn omitted).
  47 USC 544a(c)(2)
  47 USC 544a(d)

  47 USC336)(a)(4), (a)(5).
   See Appendix D for a Sample Comparison Chart for Digital Cable Ready TV Receiving Devices.
   Equipment meeting both the Digital 2 and Digital 3 standards should carry both labels.
  See Sony Reply Comments at 3, Circuit City Comments at 5-10,  Status Report in CS Docket 97-80 at 10-11 
(filed July 7, 2000 by NCTA et al.).
  Notice at 8781 (ftn. 34).
  See Equipment Compatibility First Report and Order, 9 FCC Rcd 1981, 1993 (We continue to believe that a 
requirement for cable operators to provide their subscribers a consumer education program at regular intervals is 
necessary and desirable to inform subscribers of compatibility issues and solutions).  See also  47 C.F.R. 
76.630(d).
  17 U.S.C. 544a(a)(2).
  Equipment Compatibility First Report and Order, 9 FCC Rcd at 2005.
  Notice at 8777-78.
  Notice at 8783.
  NCTA Comments at 25.
   Time Warner Cable Comments at iv.
  Home Recording Rights Coalition Comments at 9, ftn 24.
   Broadcast Networks Comments at 2.
   Id. at 3-4.  See also Fox Entertainment Group Comments at 5 (employment of encryption and other content 
protection measures by broadcasters should not affect the availability of free, over-the-air television, and digital 
broadcasts should be allowed on the basic tier even if they are delivered on a conditional access basis.)  The 5C 
Digital Transmission Licensing Administrator raises some technical implementation issues with respect to 
applying 5C encryption to broadcast TV content.  See Reply Comments of the 5C Digital Transmission 
Licensing Administrator at 3-4.
  Time Warner Cable Reply Comments at ii.
  CEA Comments at 20.
    See Carriage of the Transmissions of Digital Television Broadcast Stations CS Docket No. 98-120, 13 FCC 
Rcd 15092 (1998).
   See Comments of the Professional and Collegiate Sports Leagues at 2-4.
    We note that, in our Subscription Video decision, we addressed the difference between broadcast and non-
broadcast services, finding generally that services available without subscription fee or the need for specialized 
equipment are broadcasting.  We stated that the encryption of programming to make it unusable by the public is 
an indicia of the intent to limit access to the signal. (emphasis added).  See Report and Order in Gen. Docket No. 
85-305, 2 FCC Rcd 1001, 1006 (1987).  
   Notice at 8783. 
   47 C.F.R. 76.630(c).
   CEA Comments at 4.
    Letter from Robert Sachs, President and CEO, NCTA and Gary Shapiro, President and CEO, CEA to William 
Kennard, Chairman FCC (Feb. 22, 2000).
  CEA Comments at iii.  See also Philips Comments at 2, ftn. 2 (the NCTA/CEA agreement in principle on 
carriage of PSIP data will require additional work regarding its implementationwork that is already underway.  
Philips is confident these efforts will proceed swiftly and urges the Commission to remain involved in ensuring 
that industry-developed solutions are reached as quickly as possible and without a need for formal government 
involvement.).
  CEA Comments at iii.
   Thomson Comments at 4.
  NAB/MSTV Comments at 14.
  Report and Order in CS Docket No. 97-80, 13 FCC Rcd 14775 (1998) at para. 116. 
   NAB/MSTV Comments at 12-13.
  See, e.g. Comments of Motorola, Inc., Comments of the Media Access Group at the WGBH Educational 
Foundation, and CEA Comments at 4-5.
   See Report and Order in ET Docket No. 99-254 and MM Docket No. 95-176, adopted July 31, 2000.
   The RFA, see 5 U.S.C.  601 et seq., has been amended by the Contract With America Advancement 
Act of 1996, Pub. L. No. 104-121, 110 Stat. 847 (1996) (CWAAA). Title II of the CWAAA is the Small 
Business Regulatory Enforcement Fairness Act of 1996 (SBREFA).
   See 5 U.S.C.  605(b).
   Notice of Proposed Rulemaking, Compatibility Between Cable Systems and Consumer Electronics Equipment, 
PP Docket No. 00-67, FCC 00-137 (rel. April 14, 2000); see also 65 Fed.Reg.. 24671 (April 27, 2000). 
   Comment by the Office of Advocacy, SBA, dated May 24, 2000.  
   See Further Notice of Proposed Rulemaking, Memorandum Opinion & Order, and Declaratory 
Ruling in CS Docket No. 97-80,  Implementation of Section 304 of the Telecommunications Act of 
1996Commercial Availability of Navigation Devices, FCC 00-341, adopted Sept. 14, 2000.
 
(Continued from previous page)   
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