From: frank.kennedy@u2u.lonestar.org (Frank Kennedy) 
Newsgroups: rec.video.satellite
Subject: FCC Docket           1/15
Date: 4 Jan 93 22:32:00 GMT
Distribution: world
Organization: USER-TO-USER PCBoard (214)492-6565 (USR DS v32bis)
Reply-To: frank.kennedy@u2u.lonestar.org (Frank Kennedy) 








                                              )
          In the Matter of                    )
                                              )   FCC Docket No. 92-234
          Inquiry into Encryption Technology  )
          for Satellite Cable Programming     )



          TO: THE COMMISSION




                                   COMMENTS OF THE
                             CONSUMER SATELLITE COALITION

               The Consumer Satellite Coalition (CSC) respectfully submits

          these comments in the above-captioned proceeding.

               The Consumer Satellite Coalition is a national, grassroots,

          nonprofit organization representing close to four million home

          satellite dish (HSD) owners, the great majority of whom live in

          rural areas of the United States.  The CSC's mandate is to seek

          policies that protect the Home Satellite Dish consumer's

          investment and further the public interest in equitable access to

          programming and reception technology.


          I.   CSC's INTEREST IN THIS PROCEEDING

               CSC and a growing number of television viewers are keenly

          aware that a new satellite television order is dawning.  It is one

          that will make satellite transmission more essential and include

          a greater proportion of subscription television.  However, CSC is

          concerned that, without FCC policies and interface standards that

          promote competition, this new television order will simply





          intensify dish owners' struggle to obtain stability and fair

          pricing in the sale of equipment and programming.

               In 1991, CSC submitted a PETITION FOR INQUIRY/HEARING to the

          commission which requested an opportunity to provide information

          demonstrating the need for government action to limit the General

          Instrument Corporation's (GIC) control over encryption

          technology.1  In its petition, CSC stated: "there's hardly

          anything in the TVRO industry that is not directly impacted by

          the de facto monopoly that the VideoCipher represents."

               To this day, GIC's control of the last link into the

          satellite dish owner's home stands in the way of a robust,

          competitive marketplace.  For this reason, CSC strongly disagrees

          with the Commission's conclusion that marketplace developments

          "have rendered moot" the problems raised by CSC and respectfully

          requests that the information contained in its PETITION be

          considered alongside its comments in this proceeding.

              CSC is also concerned about other marketplace developments

          which raise important issues of public access to programming and
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