Back up FCC: Closed Captioning over IP (IPCC) 2012/5/141Confidential

Summary of Report & Order for IPCC Released: January 13, 2012 – Covers implementing Sections 202 and 203 of the Communications and Video Accessibility Act of 2010 (“CVAA”). Compliance Date: January 1, 2014 – Expects manufacturers begin efforts 30 days after the Report & Order is published. Grace Period : Two years (approximately) Technical Requirements: SMPTE TT :2010: “Timed Text Format – This is a safe harbor interchange & delivery format – Expects manufacturers will adopt use of SMPTE-TT,” RP (2010) for conversion of CEA-608 caption data. – Expects a similar recommended practice regarding the conversion of CEA-708 data to SMPTE-TT to be developed Final Rules released 13 January 2012 Compliance Date: 1 January /5/142Confidential

Summary of Report & Order for IPCC Covered Devices: Internet connected televisions, and any video player, including Blu-Ray and other removable media devices – Interfaces All video outputs of covered apparatus shall be capable of conveying from the source device to the consumer equipment the information necessary to permit or render the display of closed captions. HDMI complies since the law allows pass-through of open captions. – Encourages HDMI LLC to update specifications to carry caption data to sink devices Exempt Devices: “Display-Only” devices, e.g., computer displays; professional video equipment, movie theater equipment); Third-Party Software: – Manufacturers of covered apparatus not responsible for third-party software downloaded by users Achievability: The Order uses the ACS Order’s four-part test of achievability Waivers: Only unique, fact specific waivers and denies blanket waivers Penalties: $10,000 Forfeiture for Violations of the IP Captioning Rules: – Adopts a flexible, case-by-case approach to forfeitures and declines to adopt either a baseline or minimum forfeiture amount Complaints: Adopts a simpler consumer-oriented process – Administered by Consumer and Governmental Affairs Bureau 2012/5/143Confidential

IPCC Status: The carriage mechanism for IPCC is not defined – The FCC deferred this to a future industry standard – Companies involved in the VPAAC are expected to lead a joint standardization activity between CEA and SMPTE. This is define the carriage mechanism for SMPTE TT. The date and project schedule has NOT been announced. The FCC is not involved in the standardization activity. – The FCC will not “bless” a particular standard. This is according to language in the FCC’s Report & Order for IPCC. Industry will promote the standard as the “preferred” carriage mechanism – No guarantee that all service providers will use the standard 2012/5/144Confidential

VPAAC Working Groups WG 1 – Closed Captioning Over IP National Association of the Deaf, Disney co-chairs Report submitted 11 July SEL Government Affairs 2012/5/14Confidential

IP Closed Captioning – Definitions Video programming owner (VPO) licensor Video programming distributor (VPD) makes programming available to end-user “Full-length” video programming only Rules do not apply to “clips” or “outtakes” Rules do not apply to “consumer generated media” Rules do not apply to programming shown only on foreign channels 6 SEL Government Affairs 2012/5/ 14 Confidential

IP Closed Captioning – Obligations of Video Programming Owners and Distributors Obligations of VPOs (Content Providers) Establish “mechanism” for identifying covered programming with VPDs Send program files to VPDs with captions, according to schedule Quality must equal television captions Interchange “safe harbor” – SMPTE TT 2010 Obligations of VPDs (Content Providers/Authoring studios providing BD-Live network services) Establish “mechanism” for identifying covered programming with VPOs Render or pass through all required captions to end user Maintain quality of captions Make available contact information for consumer complaints 7 SEL Government Affairs 2012/5/ 14 Confidential

IP Closed Captioning – VPO + VPD Deadlines 8 SEL Government Affairs If the video programming is...It must be delivered via IP with captions if it is shown on television with captions on or after... pre-recorded programming that is not edited for Internet distribution 30 September 2012 live or near-live programming (performed and recorded less than 24 hours prior to the time it was first shown on television) 30 March 2013 pre-recorded programming that is edited for Internet distribution (substantial edits required) 30 September /5/ 14 Confidential

IP Closed Captioning – VPO + VPD Deadlines Library content video programming that is already in the VPD’s library before it is shown on television with captions 9 SEL Government Affairs If the video programming is shown on television with captions... It must be delivered via IP with captions within... on or after 30 March 2014 and before 30 March days after it is shown on television with captions on or after 30 March 2015 and before 30 March days after it is shown on television with captions on or after 30 March days after it is shown on television with captions 2012/5/ 14 Confidential

IP Closed Captioning – Hardware/Software, plug-in Clients deployed by VPDs Deadline Clients deployed by VPDs Software, plug-in, or hardware Must render or pass through closed captions if deployed new or updated after 30 September 2012 Various affected parties (Apple, Amazon, Microsoft, Dish Network, DirecTV) are considering an appeal of this obligation Appeal must be filed by 30 April SEL Government Affairs 2012/5/ 14 Confidential

IP Closed Captioning – Hardware/Software Clients not deployed by VPDs Deadline Hardware/software client compliance deadline – 1 January 2014 Physical devices designed to receive or play back video programming transmitted simultaneously with sound, along with any integrated software Includes Set-top boxes, PCs, smartphones, tablets, and televisions – if IP-enabled Removable media players (DVD, Blu-Ray) Recording devices No exemption based on screen size – unless not “achievable” Does not Include Display-only monitors Professional or commercial equipment, including movie projectors Interfaces All outputs must “convey” captions – open or closed HDMI complies 11 SEL Government Affairs 2012/5/ 14 Confidential

IP Closed Captioning – CEA Appeals CEA will appeal two elements of the hardware rules Rules should not apply to every device capable of playing back video programming Still or video camera with removable media Rules should not apply to playback-only removable media players Playback-only DVD or Blu-Ray players Appeal will be submitted by 30 April 2012 Decision is unlikely before 31 August 2012, perhaps longer 12 SEL Government Affairs This only includes local playback of content, and does not include BD-Live downloaded/streamed content. 2012/5/ 14 Confidential