I.             Introduction. 

The American Cable Association ("ACA") files these Comments in response to the Commission's Notice of Inquiry seeking comment "on specific steps [the Commission] can take to unleash competition in the retail market for smart, set-top video devices (‘smart video devices') that are compatible withall multichannel video programming distributor (‘MVPD') services."

ACA fully supports innovation in the marketplace for navigation devices, and has no objection tofinding a solution that would promote competition in both the wholesale andretail markets for navigation devices or that would lower costs for multichannel video programming distributors ("MVPDs").  But ACA urges the Commission to move cautiously as it seeks to find a successor to the CableCARD, and ensure that any new regulations do not disproportionately burden smaller operators.

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2010 07 13 ACA AllVid NOI Comments FINAL.pdf	34.05 KB