Before the Federal Communications Commission Washington, Dc 20554
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, DC 20554 In the Matter of ) ) Expanding Consumers’ Video Navigation ) MB Docket No. 16-42 Choices ) ) ) Commercial Availability of Navigation Devices ) CS Docket No. 97-80 COMMENTS Matthew M. Polka Barbara S. Esbin President and Chief Executive Officer Cinnamon Mueller American Cable Association 1875 Eye Street, NW Seven Parkway Center. Suite 755 Suite 700 Pittsburgh, PA 15220 Washington, DC 20006 (412) 922-8300 (202) 872-6811 Ross J. Lieberman Thomas Cohen Senior Vice President of Government Affairs Edward A. Yorkgitis, Jr. American Cable Association Kelley Drye & Warren LLP 2415 39th Place, NW 3050 K Street, NW Washington, DC 20007 Washington, DC 20007 (202) 494-5661 (202) 342-8518 Mary C. Lovejoy Jeffrey Lamken Vice President of Regulatory Affairs James Barta American Cable Association MoloLamken LLP 2415 39th Place, NW 600 New Hampshire Avenue, NW Washington, DC 20007 Washington, DC 20037 (202) 603-1735 (202) 556-2000 April 22, 2016 EXECUTIVE SUMMARY The American Cable Association (“ACA”) represents approximately 750 smaller cable operators, incumbent telephone companies, municipal utilities, and other local providers of multichannel video programming services (“MVPD services” or “pay-TV”) that serve smaller communities and rural areas or compete with much larger multichannel video programming distributors (“MVPDs”) in urban and suburban markets. In aggregate, these providers pass nearly 19 million homes and serve nearly 7 million homes – or less than 7 percent of the MVPD market. The vast majority of ACA members have fewer than 5,000 subscribers, and half have fewer than 1,000 subscribers. While their smaller size limits their ability to develop their own navigation devices for their subscribers, in recent years ACA members have been working with TiVo, Roku, and other device vendors to integrate these vendors’ devices into their systems.
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