I. Introduction and Summary. 

The American Cable Association ("ACA") files these comments in response to the Commission's National Broadband Plan Public Notice seeking comment on video device competition and innovation.
Neither small and medium-sized cable operators nor their customers have realized any meaningful benefit from the Commission's ban on integrated set top boxes. Therefore, in these Comments, ACA addresses the following:

• The problems facing small and medium-sized cable operators in the marketplace under the current set-top box rules and regulations; and

• The solutions that the Commission can implement that would encourage the development of competition and innovation in the market without causing undue harm to smaller video distributors and their customers.