Comcast Outlines Program-Access Philosophy to Regulators

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Washington -- Programming executives from Comcast met with
representatives of the Federal Communications Commission and Justice Department
here late last week to talk about how the operator makes its programming
available on the air and online, including assuring regulators that it does not
require carriage of any of its owned networks as a condition of access to any
other.

That's according to an ex parte filing with the FCC, as
Comcast continues to provide information to the two agencies vetting its
proposed NBC Universal joint venture with General Electric.

Comcast

Comcast reiterated that it has no plans to migrate online
delivery of NBC programming to the "TV Everywhere" subscription model.

According to the MSO, Comcast Programming Group president Jeff
Shell told the staffers, in answer to a question, that Comcast may discount the
price of one network to expand distribution of another, but it does not
condition carriage of one channel on carriage of another, saying that the
cost-benefit analysis of that strategy does not add up.

On the issue of access to online programming -- which appears
to be of interest to both the FCC and DOJ -- Comcast "envisioned" making online
video available to competing cable, satellite and telco distributors, said
Shell.

He said that to the extent that Comcast makes its or new
NBCU content available online to Comcast-authenticated subs, it "intends" to
make it available on reasonable terms to the authenticated customers of other
distributors. Comcast's Xfinity TV model makes online versions of its programming available to those who can
authenticate they are a subscriber.

Shell also reiterated that Comcast has "no intention" of
changing NBC's decision to make some of its content available for free on
co-owned site Hulu and "expects" that the NBC programming now available on the
site will not migrate elsewhere.

The reason for the conditional language is that the company
doesn't want to foreclose possibilities in a fast-moving and changing marketplace.

"Of course, while Comcast has no plans to change current
practices, the dynamism of the online video sector makes it unwise to set in
stone any plans with respect to putting content online in any particular
fashion," Shell told his audience according to a summary of the conversation in
the filing. "Comcast and the new NBCU will need to preserve the freedom to innovate
and change distribution methods as business models evolve, as has occurred with
Hulu even during the pendency of this transaction."

Hulu launched subscription service Hulu Plus earlier this year, which offers more content, additional
HD content and more support for smart devices for a fee of $9.99 month.

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