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ATTORNEYS AT LAW

7 February 2014

BY ELECTRONIC SUBMISSION

Mr. Stanford K. McCoy Assistant U.S. Trade Representative for Intellectual Property and Innovation Office of the United States Trade Representative 1724 F Street, N.W. Washington, D.C. 20508

Re: United States Trade Representative’s Special 301 Review, Docket No. USTR– 2013–0040—Submission by DIRECTV Latin America, LLC

Dear Mr. McCoy:

Through its counsel, DIRECTV Latin America, LLC (“DIRECTV”) hereby submits its comments for consideration in the 2014 Special 301 Review of the United States Trade Representative (“USTR”).1 DIRECTV is a leading satellite television provider and significant investor in Latin America, with operating subsidiaries or significant investments in Argentina, Brazil, Chile, Colombia, Ecuador, Mexico, Peru, Puerto Rico, Uruguay, and Venezuela. DIRECTV remains concerned that pay-television piracy continues to constrain the growth of the telecommunications and media industry in Latin America and to diminish investment in technology and innovation across the region. Today, DIRECTV’s most formidable competitor in each country is a “free” pirated service rather than another satellite or cable company. Increasingly, such services are offered through the use of devices called “free-to-air decoders”— devices that purport to receive unencrypted cultural or educational off-air broadcast signals, but that are actually designed to decrypt encrypted satellite or cable signals without authorization.2

1 2014 Special 301 Review: Identification of Countries Under Section 182 of the Trade Act of 1974: Request for Public Comment and Announcement of Public Hearing, 79 Fed. Reg. 420 (Jan. 3, 2014).

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In Brazil and Chile—markets on which DIRECTV commented in the 2013 review3—the governments have proposed certain measures to combat pay-television piracy. DIRECTV applauds these efforts but emphasizes that in order to be sufficient, these efforts must be sustained and the relevant laws enforced.

• Chile. The Chilean Executive and Legislative branches recently agreed to introduce legislation to implement the anti-piracy provisions in the U.S.-Chile Free Trade Agreement (“FTA”). This legislation would criminalize the sale, importation, distribution, and installation of pirate satellite decoders, and the distribution for profit of pirated pay-television satellite signals. DIRECTV has long advocated for such legislation and very much appreciates this development. The legislation, however, has yet to be enacted. In the meantime, piracy still accounts for at least twenty percent of the pay- television market.

• Brazil. The Brazilian Senate passed legislation that would criminalize the reception and interception of pirated pay-television signals. This legislation now awaits consideration by the Brazilian House of Representatives. Brazilian courts and law enforcement authorities have also increased efforts to shut down pirate servers and destroy illegal pirate decoders. Even these efforts, however, do not yet match the scope of piracy in Brazil. Prior estimates suggest that piracy costs legitimate pay-television providers more than US $100 million each month. New figures, due out soon, will almost certainly be higher.

In Colombia—a market about which DIRECTV did not comment in 2013—pervasive and complex pay-television piracy continues. While the Colombian Government has made recent regulatory advances, it has not yet undertaken effective enforcement actions.

• Colombia. The Colombian Government recently acceded to the Brussels Convention Relating to the Distribution of Programme-Carrying Signals Transmitted by Satellite, as required by the U.S.-Colombia FTA. Colombia’s television regulator also issued regulations to address piracy by community cable television operators, many of which create their own “service” by redistributing DIRECTV’s and other pay-television providers’ signals without authorization. Colombia, however, has yet to undertake investigations or enforcement actions against community cable television operators in order to comply effectively with its obligations under the Brussels Convention and the FTA. Market data estimate that piracy is more pervasive in Colombia than it is in Chile and Brazil.

3 United States Trade Representative’s Special 301 Review, Docket No. USTR–2012–0022– Submission by DIRECTV, LLC, at 4-6 (Feb. 8, 2013) (“2013 Special 301 Comments”).

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DIRECTV presents comments on all three markets in the 2014 review, including information related to Brazil and Chile that is new since last year’s review.

USTR should urge these governments to enforce their existing laws, adopt new legislation and regulations, and allocate sufficient resources to anti-piracy initiatives. DIRECTV encourages USTR to pursue these objectives in bilateral and regional initiatives, identifying where possible areas of mutual interest with these countries. Finally, USTR should urge Chile and Colombia to comply with their existing commitments in their FTAs with the United States.

I. Chile

DIRECTV’s Chilean subsidiary, DIRECTV Chile Televisión Limitada (“DIRECTV Chile”), has offered satellite television services in Chile since 1994 (and as part of DIRECTV since 1996). DIRECTV Chile now serves approximately 230,000 subscribers. DIRECTV Chile employs 600 people directly and more than 800 people indirectly, principally as third-party installers and dealers.

DIRECTV reported in its 2013 comments that DIRECTV Chile had lost numerous subscribers to pirated pay-television service.4 Pirates typically do not steal DIRECTV Chile’s signals because DIRECTV Chile uses comparatively robust encryption. Instead, pirates steal the signals of DIRECTV’s pay-television competitors, creating an illicit free option that erodes DIRECTV Chile’s subscriber base.5 Such piracy increasingly relies on “free-to-air” decoders that have been specifically designed to steal pay-television satellite signals.6 These decoders— which are easily identifiable by make and model—contain features unnecessary for the reception of legitimate free-to-air programming, such as unencrypted cultural or educational channels.7 Such devices now operate using “key sharing” technology, which exploits a weakness in the software that protects many providers’ encryption keys in order to share in real time decrypted keys obtained from a legitimate pay-television smartcard.8

4 Id. at 1-2. 5 Id. at 6-7. 6 Id. at 4. 7 Id. 8 Id. at 5-6.

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A. Chilean Government Considers New Legislation to Combat Piracy

In the past year, the Chilean Government proposed new measures to combat piracy— measures that would implement some of Chile’s obligations under the U.S.-Chile FTA. Most importantly, the Sub-secretary of Telecommunications (“SUBTEL”) proposed legislation for consideration by the Chilean National Congress that, consistent with the U.S.-Chile FTA,9 would criminalize the sale of pirate satellite decoders and the distribution for profit of pirated pay- television signals. On December 2, 2013, Senator Hernán Larraín Fernández introduced the legislation as an amendment to Chile’s Telecommunications Law, then under consideration by the Committee on Transportation and Telecommunications.10 On January 28, 2014, that Committee amended the draft bill to criminalize the importation, distribution, and installation (in addition to the sale) of pirate satellite decoders.11 DIRECTV Chile anticipates that the bill will be considered by the Chilean Senate Finance Committee in March and will then be brought to a vote.

This legislation would provide DIRECTV Chile and DIRECTV with the legal basis to seek the prosecution of pirate pay-television services. While DIRECTV eagerly anticipates the enactment of this legislation, it cautions that the Chilean National Congress has not yet approved the bill. The Chilean Government must also provide the necessary resources to ensure that the new law is enforced.

B. Pervasive Piracy Nevertheless Persists in Chile

Despite the government’s recent efforts, pay-television piracy remains a pervasive problem in Chile. An estimate provided by Business Bureau, a specialized Argentine market

9 United States-Chile Free Trade Agreement, U.S.-Chile, art. 17.8, June 6, 2003, 42 I.L.M. 1026, available at http://www.ustr.gov/trade-agreements/free-trade-agreements/chile- fta/final-text. 10 See Boletín N° 8.034-15, Indicaciones Formuladas Durante la Discusión en General del Proyecto de Ley, en Segundo Trámite Constitucional, que Crea la Superintendencia de Telecomunicaciones (Dec. 2, 2013), available at http://www.senado.cl/appsenado/templates/tramitacion/index.php?boletin_ini=8034-15 (follow the link entitled “Indicación” under the date Dec. 3, 2013). 11 See Oficio N° 4/TT/2014 (Jan. 28, 2014), available at http://www.senado.cl/appsenado/templates/tramitacion/index.php?boletin_ini=8034-15 (follow the link entitled “Oficio” under the date Jan. 28, 2014).

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research company,12 suggests that 300,000 Chilean subscribers now use pirated service, representing roughly ten percent of the pay-television market. This estimate, however, includes only “in-home piracy” (that is, the diversion of legitimate service to a non-paying customer, such as through the use of cable splitter). Unofficial reports indicate that an additional ten percent of the Chilean pay-television market use free-to-air decoders to receive pirated pay-television service.13

Piracy harms Chile and the Chilean Government as well. To begin with, pirate organizations pay neither taxes nor customs duties. DIRECTV Chile estimates that the Chilean Government loses at least US $3 million each year as a result of pay-television piracy. Nor do pirate organizations fund or distribute Chile-specific cultural or educational programming. Nor, for that matter, do they contribute to charitable and other public interest organizations. Pirate services do, however, fund illegal enterprises.

C. DIRECTV Chile Continues to Devote Substantial Resources to Combat Piracy

As in previous years, DIRECTV Chile expended substantial time and resources this year in combatting pay-television piracy. It met repeatedly with the Ministry of Transport and Communications and SUBTEL to discuss the pending anti-piracy legislation. DIRECTV Chile also discussed this legislation with numerous Chilean Congressional officials over the past year. DIRECTV also met with USTR staff, as well as the Chilean Embassy in Washington.

In addition to efforts related to pending legislation, DIRECTV also worked with the Alianza contra Piratería de Televisión Paga (“Alianza”)14 and other pay-television providers and programmers to initiate investigations and judicial claims against pirate pay-television services. DIRECTV also conducted training sessions with the Chilean Police, customs authority, and

12 More information about Business Bureau’s market research capabilities can be found at BUSINESS BUREAU, http://www.businessbureau.com.ar/marketing/index.html#marketsearch. 13 See Laura Iriarte, Industria de TV de pago inicia apagón de decodificadores de señales ilegales, EL MERCURIO, Oct. 2, 2012, available at http://www.economiaynegocios.cl/noticias/noticias.asp?id=101097 (last accessed Feb. 7, 2014). (Please note that this estimate assumes a smaller Chilean pay-television market than does Business Bureau, so the “ten percent” cited in El Mercurio equals a lower actual number than the “ten percent” estimated by Business Bureau.) 14 For a full description of the Alianza, please see DIRECTV’s 2013 Special 301 Comments at 11-12.

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Economic Ministry related to piracy, as well as several specialized sessions with front-line customs officials. DIRECTV will continue these efforts in 2014.

II. Brazil

DIRECTV’s Brazilian subsidiary, SKY Brasil Servicos Limitada (“SKY Brasil,” of which DIRECTV owns ninety-three percent) has offered services in Brazil since 1996 (as part of DIRECTV since 2005). SKY Brasil serves more than 5.3 million subscribers. It employs 2,416 people directly and approximately 45,000 indirectly.

As DIRECTV noted in its 2013 comments, SKY Brasil faces a slightly different set of issues than does DIRECTV Chile. DIRECTV Chile has a more robust encryption protocol than its Chilean competitors, so its signal is stolen less frequently. In Brazil, both SKY Brasil and its primary competitors use the same type of encryption. Therefore, all are equally vulnerable to signal theft.15 SKY Brasil is thus, in effect, a double-victim of piracy. Pirate services steal SKY Brasil’s signal and SKY Brasil loses subscribers to pirate services that offer the stolen signals of SKY Brasil and other legitimate providers.

A. Brazilian Government Adopts and Implements New and More Substantial Measures to Combat Piracy

The Brazilian Government has also made strides this year to combat pay-television piracy. In December 2013, the Brazilian Senate passed legislation criminalizing the unauthorized reception and interception of encrypted pay-television satellite signals.16 The legislation now awaits consideration by the Brazilian House of Representatives.

Unlike Chile, moreover, Brazil already prohibits the importation, advertisement, and sale of known brands of illicit decoders.17 The Brazilian Government markedly increased its enforcement of these laws against pirate decoder retailers and service operators this year. In cooperation with SKY Brasil, Brazilian authorities obtained several search and seizure warrants for the inspection of retailers selling pirate decoders in São Paulo, Brasília, and Porto Alegre. In addition, after a meeting held between SKY Brasil, DIRECTV, and the Brazilian authorities at

15 Id. at 10-11. 16 Senado Federal, Projeto de Lei do Senado, N° 186, de 2013, Altera a Lei no 8.977, de 6 de janeiro de 1995, para estabelecer a sanção aplicável ao ilícito penal consistente na interceptação ou recepção não autorizada dos sinais de TV por assinatura, available at http://www.senado.gov.br/atividade/materia/getPDF.asp?t=128023&tp=1. 17 2013 Special 301 Comments at 13.

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the Brazilian embassy in Washington, D.C., the Brazilian Customs authorities based in Foz do Iguaçu seized and destroyed 12,000 pirate decoders. SKY Brasil, in cooperation with Brazilian authorities, also obtained a court order to shut down a key-sharing server in Curitiba.

B. Pervasive Piracy Nevertheless Persists in Brazil

While DIRECTV is grateful for the Brazilian Government’s enforcement efforts, the government still needs to adopt and implement additional measures to match the scale and complexity of the problem. Many local enforcement authorities in Brazil still lack the resources to respond adequately to pay-television piracy. Moreover, pirate decoders continue to enter the country illegally, especially from notorious pirate markets like Ciudad del Este in neighboring Paraguay.18

Indeed, Brazil maintains one of the highest piracy rates in the region. In its 2013 comments, DIRECTV cited figures from the Association of Brazilian pay-television providers, Associação Brasileira de Televisão por Assinatura (“ABTA”), estimating that Brazilian consumers today use over one million illegal decoders to pirate encrypted pay-television signals.19 This figure represents approximately 10 percent of all pay-television users in the country, and accounts for a loss to the pay-television industry of US $100 million each month.20 New ABTA figures are expected to be released shortly, and the expectation is that they will be substantially higher.

This piracy harms Brazil and the Brazilian Government. Piracy reduces tax and customs revenue available to the Brazilian Government. Based on last year’s ABTA figures, SKY Brasil estimates that piracy costs the Brazilian government approximately US $450 million annually in lost tax revenue. Piracy also reduces the funding of Portuguese-language programming and public-interest projects, and leads to the funding of illegal enterprises, as stated by the General Secretary of the Brazilian National Council against Piracy.21

18 Id. 19 Id. at 10 (citing Rosangela Capozoli, Aparelhos irregulares de TV a cabo têm declínio, VALOR ECONÔMICO, Apr. 25, 2012; ABTA participa de aliança contra pirataria na TV por assinatura na América Latina, ADNEWS, Jan. 28, 2013). 20 Id. (citing Justiça Federal proíbe importação e venda de aparelhos que permitem pirataria de sinal de TV por Assinatura, ABTA (Dec. 2011)). 21 Ministério da Justiça, Pirataria está conectada ao crime organizado, Dec. 4, 2012, available at http://portal.mj.gov.br/main.asp?View={61EDAA11-AF6B-43B2-BC4E- 85B7B960DAB6}&BrowserType=NN&LangID=pt- br¶ms=itemID%3D%7B6D0DC665%2D1BE4%2D4FB0%2DA71C%2DE1619DDDC

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C. SKY Brasil Continues to Devote Substantial Resources to Combat Piracy

DIRECTV and SKY Brasil, in coordination with the ABTA and Alianza, continue to work with the Brazilian government on anti-piracy issues. As described above, SKY Brasil collaborated with Brazilian law enforcement agencies to shut down pirate servers and to prosecute those who sell pirate decoders. SKY Brasil has also consulted extensively with the Brazilian Government. In 2013, SKY Brasil met with the manager of inspections at ANATEL, Brazil’s telecommunications regulator, to discuss the problem of pirate decoders, as well as with top officials at the Undersecretary of Customs and International Relations of the Brazilian Federal Revenue Office. DIRECTV also met with officials at the Embassy of Brazil in Washington, D.C. DIRECTV will continue these efforts in 2014.

III. Colombia

DIRECTV’s Colombian subsidiary, DIRECTV Colombia Limitada (“DIRECTV Colombia”) commenced service in 1996. DIRECTV Colombia serves more than 800,000 subscribers. It employs 3,977 people directly and more than 3,650 indirectly.

Pirate pay-television providers in Colombia offer their services through illegitimate free- to-air decoders, just as they do in Chile and Brazil. Colombia, however, also presents an entirely different set of piracy concerns.

In Colombia, comunitarias (local community cable television operators) steal pay- television signals.22 Some of these operators illegally use DIRECTV Colombia’s signals as an input for their own services, without paying either DIRECTV Colombia or the programmers it carries. Consequently, they offer their subscribers below-cost service. Naturally, many Colombians prefer below-cost “DIRECTV” to legitimate DIRECTV service.

Over 750 small comunitarias operate in Colombia.23 Many of them illegally distribute DIRECTV Colombia’s signals. In 2013, DIRECTV Colombia asked Business Bureau to audit

7B7%7D%3B&UIPartUID=%7B2218FAF9%2D5230%2D431C%2DA9E3%2DE780D3E6 7DFE%7D. 22 See ET Canal el Tiempo, La Pirateria en la TV por Suscripcion en Colombia (posted Aug. 18, 2011), available at http://www.dailymotion.com/video/xklb80_la-pirateria-en-la-tv-por- suscripcion-en-colombia_news#.UVG1XReG1BM (last accessed Feb. 7, 2014). 23 Autoridad Nacional de Televisión, Usuarios TV comunitaria cerrada sin ánimo de lucro 2011, available at http://www.antv.gov.co/informacion-sectorial/usuarios-tv-comunitaria- cerrada-sin-animo-de-lucro-2011 (last accessed Feb. 7, 2014).

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more than 700 television providers, most of them comunitarias. At least seven percent of them redistributed DIRECTV Colombia’s signal without authorization. (Many more undoubtedly redistribute the signals of DIRECTV’s competitors.)

A. Colombian Government Implements the Brussels Convention and Begins to Investigate Comunitarias

Like Chile and Brazil, Colombia has recently taken steps to address pay-television piracy. Most importantly, Colombia recently acceded to the Brussels Convention Relating to the Distribution of Programme-Carrying Signals Transmitted by Satellite.24 DIRECTV looks forward to the full implementation of the Convention.

Moreover, Colombian authorities (assisted by DIRECTV Colombia) achieved the first criminal conviction in Latin America for the violation of encryption protocols, copyright violation, and illegal access to telecommunications.25 This case involved a provider of free-to- air decoders used for pirate pay-television services.26

DIRECTV is also encouraged that Colombia’s television regulator, La Autoridad Nacional de Televisión (“ANTV”), recently began to investigate the unauthorized operations of comunitarias.27 As described in more detail below, however, ANTV closed a significant number of investigations against pirate pay-television services without a decision on the merits because the period to act elapsed without action by ANTV.

24 World Intellectual Property Organization, WIPO-Administered Treaties, Contracting Parties, Brussels Convention, available at http://www.wipo.int/treaties/en/ShowResults.jsp?lang=en&treaty_id=19 (last accessed Feb. 7, 2014). 25 See Carlos Arturo Gómez, Primera condena por piratería en comunicaciones en Colombia, W Radio (Apr. 5, 2013), available at, http://www.wradio.com.co/noticias/actualidad/primera-condena-por-pirateria-en- comunicaciones-en-colombia/20130405/nota/1873254.aspx (last accessed Feb. 7, 2014); Freddy Naranjo, Primera condena por piratería de televisión paga, CM& (Apr. 9, 2013), available at http://www.cmi.com.co/?n=103300 (last accessed Feb. 7, 2014). 26 Id. 27 These actions build on regulations issued by ANTV’s predecessor, La Comisión Nacional de Televisión (“CNTV”).

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B. Pervasive Piracy Nevertheless Persists in Colombia

While DIRECTV acknowledges and appreciates the Colombian Government’s efforts to address piracy, much work remains to be done. To begin with, Colombia has yet to implement Article 16.8 of the U.S.-Colombia FTA, which requires Colombia to criminalize not only the sale of pirate decoders, but also their manufacture, modification, importation, and exportation. Article 16.8 also requires Colombia to criminalize the reception and distribution of pirated satellite signals.28 Colombia also has not implemented Article 16.7.9 of the FTA, which requires Colombia to prohibit the retransmission of television signals over the Internet without authorization.29 Compliance with its FTA obligations is critical to Colombia’s efforts to address the activities of pirate services that retransmit DIRECTV Colombia’s programming without authorization.

In Colombia, moreover, the laws that do exist often go unenforced. This is a particular concern with respect to piracy by comunitarias because ANTV has failed to enforce regulations that could greatly reduce the scope of piracy committed by such entities. Under ANTV’s regulations, comunitarias must: (1) broadcast no more than seven encrypted signals;30 (2) provide cultural and educational programming;31 (3) operate on a not-for-profit basis;32 and (4)

28 Article 16.8 requires each party to: (1) make it a criminal offense to manufacture, import, export, or sell piracy-enabling satellite decoders; and (2) to receive or distribute a program- carrying satellite signal with knowledge “that it has been decoded without the authorization of the lawful distributor of the signal.” United States-Colombia Free Trade Agreement, U.S.- Colombia, art. 16.8, Nov. 22, 2006 (“U.S.-Colombia FTA”). 29 Id. art. 16.7.9. 30 Resolución 433 de 2013 de la ANTV, Por la cual se Regulamenta Parcialemente el Servicio de Televisión Comunitaria Cerrada sin Ánimo de Lucro, Art. 24, numeral 8 available at http://www.antv.gov.co/sites/default/files/resolucion_433_2013.pdf (“Resolución 433”). 31 Ley 182 de 1995, Diario Oficial No. 41.681 de 20 de enero de 1995, Comisión Nacional de Televisión, art. 37, numeral 4, available at http://www.secretariasenado.gov.co/senado/basedoc/ley_0182_1995.html (last accessed Feb. 7, 2014). 32 Resolución 433, art. 24, numeral 5.

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obtain a permit and comply with copyright law in the transmission of any encrypted satellite signals.33 As far as DIRECTV is aware, very few comunitarias abide by these rules.

Between 2011 and 2013, DIRECTV Colombia has initiated at least seventy-three formal requests before different local authorities to investigate and sanction different comunitarias. So far, only one action has been decided and charges imposed against the defendant. DIRECTV Colombia hopes that ANTV takes effective action against the piracy practices exposed in the filings brought before it and sanctions comunitarias that infringe intellectual property rights.

Government inaction has led to piracy rates in Colombia even higher than those in Chile and Brazil. Business Bureau estimates that more than two million Colombian viewers use illegal services, corresponding to 27 percent of pay-television households. As in Chile and Brazil, however, this number includes only “in-home” piracy, and does not include piracy using free-to- air decoders, the fastest-growing form of piracy. DIRECTV Colombia is aware of the importation of at least 600 such decoders in 2013 through illegal means, and expects that many thousands more were imported illegally.

As in Chile and Brazil, piracy in Colombia harms both Colombian citizens and its Government. Pirate services using free-to-air decoders create all of the problems described above related to taxes, customs duties, Colombia-specific programming, and the funding of illegal enterprises. Pirate services offered by comunitarias also cause some of these problems, as comunitarias neither report nor pay taxes on these services.

C. DIRECTV Colombia Continues to Devote Substantial Resources to Combat Piracy

DIRECTV Colombia has worked diligently with Colombian and U.S. Government officials in connection with these issues. As noted above, DIRECTV Colombia assisted Colombian prosecutors to obtain the conviction of a retailer and installer of pirate decoders. DIRECTV Colombia, through the Alianza, also filed civil, criminal, and administrative claims against providers that illegally retransmit its signal. These are currently under investigation by local authorities.

DIRECTV Colombia, through the Alianza, also conducted several training sessions with local Colombian authorities to share relevant knowledge regarding anti-piracy efforts. As a result of such trainings, Colombian customs officials this year conducted several ex officio raids

33 Id. art. 22, numeral 5. Moreover, under Colombia Annex 1 of the U.S.-Colombia FTA, community television operators may not serve more than 6,000 subscribers. U.S.-Colombia FTA, Colombia Annex 1 at 25.

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on pirated equipment. DIRECTV has also discussed the full range of its concerns in Colombia with Colombian authorities, USTR, and with the Colombian embassy in Washington.

IV. Remedies

USTR should urge the Chilean, Brazilian, and Colombian Governments to enforce their existing laws, adopt new legislation and regulations, and allocate sufficient resources to anti- piracy initiatives. DIRECTV encourages USTR to pursue these objectives in bilateral and regional initiatives, identifying, where possible, areas of mutual interest with these countries. Finally, USTR should urge Chile and Colombia to comply with their existing commitments in their FTAs with the United States.

With respect to the 2014 Special 301 report specifically, DIRECTV respectfully requests that USTR continue to list Chile as a Priority Watch List country for 2014, and that USTR continue to urge the Chilean Government to implement the protections for encrypted program- carrying satellite signals required by the U.S.-Chile FTA by passing the proposed amendment to Chile’s Telecommunications Act.

DIRECTV also respectfully requests that USTR continue to list Brazil as a Watch List country for 2014. USTR should continue to urge the Brazilian Government to pass the proposed amendment to Brazil’s penal code which would clearly criminalize the theft of pay-television satellite signals. DIRECTV also requests that USTR continue to list Ciudad del Este, Paraguay as a Notorious Market in USTR’s separate Notorious Markets Review, as many illegal pirate decoders continue to make their way onto the Brazilian black market through Ciudad del Este.

Finally, DIRECTV respectfully requests that USTR continue to identify Colombia as a Watch List country for 2014. It requests that USTR urge the Colombian Government to ensure that the existing laws and regulations governing comunitarias are enforced.

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* * * *

Should you have any questions regarding this submission, please contact Kent Bressie by telephone at +1 202 730 1337 or by e-mail at [email protected].

Respectfully submitted,

Kent D. Bressie Michael D. Nilsson Danielle J. Piñeres Counsel to DIRECTV Latin America, LLC

cc: Kira Alvarez Catherine Hinckley Jonathan McHale Todd Nissen Eleanor Shea Joseph Whitlock Daniel Lee Bennett Harman