As a consumer interested in protecting competition, innovation, and legitimate use of cable TV
content, I urge you to refuse requests for waivers of 47 CFR 76.1204(a)(1) by NCTA, Charter,
Verizon, and all other cable providers. The FCC's integration ban, which in effect requires cable
companies to integrate CableCARDs into their own set-top boxes, remains good policy today.
Now ten years after the Telecommunications Act of 1996, cable companies have dragged their feet
long enough on competitive alternatives to proprietary set-top boxes, thus hampering innovation and
harming consumers. The integration ban will also help market competition prevent further restrictions
on cable subscribers' ability to make legitimate use of recorded content.
By adopting content protection limits (encoding rules) in docket no. 97-80, the Commission
recognized the importance of allowing consumers to make certain uses of TV content, regardless of a
particular cable provider's or copyright holder's wishes. With competition spurred on by the integration
ban, consumers would have the freedom to choose the least restrictive cable-compatible device
available. The CableCARD standard already prescribes restrictions that harm consumers by limiting
non-infringing uses, and such restrictions will get even worse if cable providers' set-top boxes are
unchecked by competition.
Please refuse requests for waivers of 47 CFR 76.1204(a)(1).