Circuit City Files Additional Box Comments

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Circuit City Inc. filed a second batch of ex parte comments
to the Federal Communications Commission last Monday, suggesting parameters for
interoperable set-top terminals, or what it calls "navigational devices."

The National Cable Television Association sent its response
to the FCC last Thursday, emphasizing that analog and "hybrid" analog/digital
boxes should be separated from any proposed rulings.

In its comments, Circuit City wrote, in draft form, an
addition to Part 76 of the cable rules that defines equipment provisioning,
interoperability issues and how waivers would be handled.

The NCTA's comments reasoned that cable operators
"must have the ability to provide boxes with embedded security" to subscribers.
The group suggested that if the FCC adopts rules that mandate separation of security
functions, the availability of a separate security module shouldn't be required until at
least 21 months after the OpenCable specifications for separate security modules are made
public.

Circuit City suggested that a 12-month phase-in would be
sufficient for cable to "cease the installation of cable-system terminal
devices," except for equipment subject to waiver rules.

One cable engineer tracking the process, who asked not to
be named, said he found Circuit City's filing "troublesome," because several of
the comments referenced proposed standards that "aren't even nearly complete" as
a panacea for the tricky process of getting interoperable set-tops to the retail market
while keeping premium-cable signals secure from would-be pirates.

The FCC is expected to announce rules related to equipment
interoperability and set-top boxes by the middle of this month.

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