Before the Federal Communications Commission Washington, DC 20554 In the matter of: ) ) Closed Captioning of Internet Protocol- ) MB Docket No. 11-154 Delivered Video Programming: Implementation ) Of the Twenty-First Century Communications ) And Video Accessibility Act of 2010 ) Comments of the Advanced Access Content System Licensing Administrator, LLC Bruce H. Turnbull Counsel and Co-Manager, AACS LA, LLC Turnbull Law Firm, PLLC 5335 Wisconsin Avenue, NW Washington, DC 20015 (202) 274-1801
[email protected] Donald Leake, Jr. Co-Manager AACS LA, LLC 3855 SW 153rd Drive Beaverton, OR 97006 November 4, 2013 These comments are submitted by Advanced Access Content System Licensing Administrator, LLC (“AACS LA”) in relation to the Further Notice of Proposed Rulemaking, 78 Fed. Reg. 39691 (July 2, 2013). In these comments, AACS LA brings to the Commission’s attention the reasons why analog outputs for AACS-protected motion picture content on prerecorded Blu-ray Discs are scheduled to “sunset” for Blu-ray Disc players (“BD players”) that are distributed after December 31, 2013 and why requiring analog outputs for BD players is neither necessary nor desirable. By way of background, AACS LA is a limited liability company established by eight companies (IBM, Intel, Microsoft, Panasonic, Sony, Walt Disney, Toshiba, and Warner Bros.) from three different industries – motion picture content providers, consumer electronics, and information technology – to develop and license content protection technology to protect high definition motion picture content from unauthorized reproduction and distribution. AACS LA’s technology has been applied to prerecorded Blu-ray Discs distributed in the United States and around the world since February 2006.