Legal Analysis – FCC

Overview

Below is an summary of my involvement in addressing a newly imposed FCC Mandate which impacted the VUIT! Platform and it’s Members (NCTC Member Cable Companies). I conducted indepth technical research, defended findings, and presented cost models to both legal and executive level staff at multiple organizations.

Note: This project is related to NCTC’s VUIT Platform (Click for More), of which I am principally responsible for. Follow the link to learn more about my management role in this business offering, it’s federated API architecture, and it’s B2B customer base of NCTC Member Cable Operators.

  • Formal FCC Mandate
    • Accessible TV and Set-Top Box Controls
    • This mandate requires cable operators providing video service to include features which allow a visually impair person to successfully execute a variety of functions related to the device providing delivery of that content without the use of sight.
  • This mandate required immediate action from all parties involved. I was directly involved in all aspects of the activities below.
    • Interpretation of the FCC Mandate as it applied to the VUIT specific set of technologies
    • Contract and Legal analysis to new and existing contractual agreements, including both direct and pass-through
    • Cost Modeling on the financial impact to both the NCTC and VUIT members
    • Exploring various technical & product options
    • Lead operational execution of solution, including, testing, billing, deployment, and training

Details

  • Worked directly with TiVo, NCTC and ACA legal, and VUIT customers on the execution, interpretation, and financial impacts of the Mandate
  • Produced various options presented to the ACA (American Cable Association) to provide adherence to the mandate while keeping overall cost to VUIT Customers and the NCTC low
    • This included detailed discussions about feature parity across TiVo’s Hardware as well as Over-Top-Apps (such as Native VOD Solutions, Hulu, Amazon Prime, and Netflix)
    • Technical defense and analysis to various legal parties as to why such options are viable while still adhering to the new FCC Mandate
  • Research on cost implications on a variety of options with corresponding financial models
  • Contractual analysis related to cost implication to customers, specifically the conflicting classifications across various pass-through agreements which did not account for the federated nature of the VUIT Platform’s customers which potentially would cause an undue financial burden, this matter was resolved in favor of the VUIT customers
  • Oversight of feature deployment, testing, and SOW execution for all VUIT customers
  • Lead various webinars for VUIT customers discussing the FCC Mandate implications (technology, cost, and legal) as it applied to the VUIT platform