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Old 06-05-2012, 11:09 AM   #1
buscuitboy
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Angry FCC's Online media complaint form against Comcast

I am getting tired of the shenanigans & BS side charges Comcast imposes for additional cable cards for my TiVo. What should be just a straight $1.50 winds up turning into a $10 "outlet fee" and then a $2.50 equipment 'credit' for EACH card. Therefore, the true cost for each cable card is $7.45.

In the end, its bringing the monthly cost of a Tivo (without PLS) up to about the same cost of their crappy DVRs. Maybe its why they are taking advantage of this loophole; have customers try to pay them more instead of giving money to TiVo, but still a loophole and hopefully can be fixed.

I have gone ahead with this, but if anyone is interested in filing an FCC complaint against Comcast, here is a link to the online form to do it.

https://esupport.fcc.gov/ccmsforms/f...orm_type=2000E

Who knows if it will ever truly do anything (probably not), but I have copy/pasted my full complaint into a word document that is saved on my PC and plan to just file this about once per week. Hell, more if possible and time permits

Last edited by buscuitboy : 06-05-2012 at 02:39 PM.
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Old 06-05-2012, 11:49 AM   #2
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You mean $2.50 equip credit, not fee. Your net cost is correct.

Everyone on Comcast getting A/O's for cards should file complaints with the FCC.
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Old 06-05-2012, 12:03 PM   #3
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Sorry. yea, $2.50 equipment 'credit'. Sorry about that & fixed it above as needed.
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Old 06-05-2012, 05:30 PM   #4
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Yes, if they're not charging that same fee for their own boxes then it's absolutely illegal.
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Old 06-05-2012, 06:03 PM   #5
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My understanding is that they do charge the same additional outlet fee for their own boxes. Is that not the case?
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Old 06-05-2012, 06:21 PM   #6
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Those who are complaining are comparing the fee for a TiVo in an additional outlet to the free SD DTA (or a couple of dollars) that can be obtained for that same outlet.

A TiVo at any outlet will cost you ~$2.50 less than having a full-featured (e.g., HD, PPV) Comcast-owned set-top box at that outlet.

If I'm wrong I'm sure they will clarify.
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Old 06-05-2012, 06:25 PM   #7
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A TiVo at any outlet will cost you ~$2.50 less than having a full-featured (e.g., HD, PPV) set-top box at that outlet.

If I'm wrong I'm sure they will clarify.
That's my understanding as well. Although I hate the fact that additional outlet fees exist at all, I don't think it's a violation of the FCC rules.
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Old 06-05-2012, 09:10 PM   #8
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That's my understanding as well. Although I hate the fact that additional outlet fees exist at all, I don't think it's a violation of the FCC rules.
I cannot believe anyone could read bullets 2, 7 & 8 here and still think that Comcast is in compliance. HD doesn't change the rules.
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Old 06-05-2012, 09:37 PM   #9
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I cannot believe anyone could read bullets 2, 7 & 8 here and still think that Comcast is in compliance. HD doesn't change the rules.
Are you saying that they're violating one of those bullet points by charging the same additional outlet fee for a cable card as they do for a cable box? I'm not seeing it.
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Old 06-05-2012, 09:50 PM   #10
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Right, they may have other issues but if they're charging that same outlet fee for their own boxes *in addition to a charge for the box itself* then there's nothing wrong with that.
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Old 06-05-2012, 10:17 PM   #11
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Are you saying that they're violating one of those bullet points by charging the same additional outlet fee for a cable card as they do for a cable box? I'm not seeing it.
Their published fee for the first CableCARD in a device is $0/mo. Except for a $1.50/mo for the second card in the same device, no other fees are associated with CableCARDs. You can get some of the digital channels with a free or $1.99/mo DTA. Reread the below where I have extracted the relevant portions from the FCC website. Pay particular attention to the sentence in bold type. If you can still honestly state that Comcast is in compliance,you really need to give a full explanation because, IMHO, it defies logic.

From the FCC CableCARD: Know Your Rights website:

Quote:
Accurate information on the rental cost of a CableCARD from your provider. Your operator must list the cost of a CableCARD rental on its website or billing inserts and on its annual rate notice...

Receive all “linear” channels (channels other than “on-demand”) in your subscription package.

Get accurate information about services available to CableCARD subscribers.
Comcast is perfectly within their rights to charge you more for their equipment that can receive channels beyond the capabilities of the DTA. However, other than the actual fee for the CableCARD(s), they cannot charge you to enable that capability on CableCARD using equipment that you own.
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Old 06-06-2012, 07:55 AM   #12
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Your quote says that Comcast is required to provide all linear channels to cable card customers. They do. Is there a linear channel that's available on a cable box that they won't give you with a cable card? Your quote in bold has nothing to do with pricing. It doesn't say anything about additional outlet fees. Comcast charges an additional outlet fee for the second and any subsequent outlets where you have a cable card OR a cable box. What specifically does this violate? Are you saying that they should not be allowed to charge an additional outlet fee for a cable card on a second outlet even though they charge that fee for a second outlet that has a cable box?

How many cable outlets are you using in your house and what equipment are you using on each outlet? It's quite possible that you're being charged incorrectly, but I can't say if that's the case without knowing what you have.
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Old 06-06-2012, 09:07 AM   #13
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I filed two complaints regarding this issues...i.e., modest increase in 2nd Cablecard fee while getting hammered with a huge decrease in customer-owned equipment that equates to an almost 50% increase in the total cost of the Cablecard. Seriously, additional Cablecard devices rack-up an additional $7.45 in charges for the Cablecard in the form of the "Additional Digital Outlet" fee, which is almost the cost of renting an HD receiver...and that comes without VOD and PPV.

Anyway, my local franchise authority didn't want to get involved since "we don't control pricing" and the FCC sends me a form letter directing me back to the LFA; they kowtow to Comcast. Based on the letters I received from the FCC, I don't think they read one word of my complaints. In a nutshell, nobody wants to deal with this issue. Perhaps my next step is to contact the DOJ and file a racketeering complaint.

Anyway, Comcast basically offered me "good customer" unadvertised special and additional discounts upon each complaint because it was cheaper to placate me than to fix the problem of all Tivo owners getting raked-over-the-coals each month. Sure, I'm paying $79.99 a month for Premier (to inlcude HBO, SHO, MAX, STARZ, Sports, etc.) and 30 Mbps Internet...but I would rather see Comcast fairly price Cablecards. Besides getting Premier/Internet at $99.99 for 12-months, I'm also receiving two $10 "stop whining to the FCC discounts" and my 2nd Cablecard (Additional Digitial Outlet fee) waived for one year.
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Old 06-06-2012, 09:14 AM   #14
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Your quote says that Comcast is required to provide all linear channels to cable card customers. They do. Is there a linear channel that's available on a cable box that they won't give you with a cable card? Your quote in bold has nothing to do with pricing. It doesn't say anything about additional outlet fees. Comcast charges an additional outlet fee for the second and any subsequent outlets where you have a cable card OR a cable box. What specifically does this violate? Are you saying that they should not be allowed to charge an additional outlet fee for a cable card on a second outlet even though they charge that fee for a second outlet that has a cable box?

How many cable outlets are you using in your house and what equipment are you using on each outlet? It's quite possible that you're being charged incorrectly, but I can't say if that's the case without knowing what you have.
You can't take things in isolation. They have a published price for CableCARDs. They are required to provide access to all linear channels in a package to a CableCARD device. That's "in your subscription package". Not "in your subscription package if it's the primary device on the account. Otherwise, they can charge an additional fee".

Comcast has two levels of additional digital outlets - one includes a DTA for $1.99/mo. The other includes a standard definition STB for $9.95/mo. Even if the regulations allow Comcast to charge for additional outlets (that's a bit murky), they do not allow Comcast to charge the higher rate for a CableCARD device simply because it has the same linear channel capabilities as their standard box. Actually, it has more capabilities since it can receive HD channels. By your logic, Comcast would be justified in adding the "HD Technology Fee" if you have any CableCARD devices, even if you only have one and you have none of their boxes.
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Old 06-06-2012, 09:53 AM   #15
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I filed an FCC complaint and received a call from a Comcast representative here in the Boston area. She explained that the "additional outlet fee" is a charge to receive "digital services" (her term) at locations other than the primary outlet. Included in that fee is a Comcast set-top box. If you choose to use your own CableCARD-capable device (TV, TiVo, etc.) at that additional outlet you will receive a "customer-owned equipment credit", which is $2.50 in this area. If my device requires TWO CableCARDS I will be charged an additional $1.00 or so for the second CableCARD for that device. All of this information is clearly provided in the rate sheet that Comcast provided to us with our February bill.

You can complain all you want - and I personally agree that charging for extra outlets really sucks - but based on Comcast's explanation of their charges they believe they do comply with *their interpretation* of the FCC requirements. Yours obviously differs, but until you can convince some government entity to convince Comcast to change *their opinion* you're simply flogging a deceased equine.
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Old 06-06-2012, 10:10 AM   #16
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Comcast removed the $6.95/mo. A/O fee, so I'm not fighting the $2.50 credit since I don't want to open that bag of worms!
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Old 06-06-2012, 10:37 AM   #17
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Comcast is perfectly within their rights to charge you more for their equipment that can receive channels beyond the capabilities of the DTA. However, other than the actual fee for the CableCARD(s), they cannot charge you to enable that capability on CableCARD using equipment that you own.
Will you agree that your argument hinges on the difference in cost between a DTA and the CableCard in a TiVo?
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Old 06-06-2012, 10:47 AM   #18
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Not trying to pot stir here at all, but I find this discussion somewhat humorous since so many people never seemed to be bothered by the additional outlet fees that DirecTV and Dish Network charged their customers -- customers that had little or no choice at all in terms of what equipment to use. Additional outlet fees of $5 or $6 per unit, plus a household fee if any outlet in the home used a DVR, plus the up-front costs of the equipment which is almost all leased rather than owned, plus, well, whatever other charges those companies could find a way to charge their customers for....

Those companies would go out and advertise rates that looked so much less expensive when compared with the big evil cable companies which didn't charge additional outlet fees back in the days of analog cable, but when a customer got signed on and then realized that they needed multiple outlets, the costs would suddenly become much less friendly and back in the same neighborhood that the evil cable co.'s would charge.

Now that everything is digital and boxes are required everywhere the cable companies are back in the mode where they can charge for additional outlets and they are working to maximize their profits wherever possible and some people are getting up in arms over these costs.

As much as I hate the idea of these additional outlet fees, if I pay $X for a cable co. provided box and pay (after credits are applied) the same $X for the use of my own hardware, be it a TiVo box, a Ceton InfiniTV, an HD Homerun box, whatever, then I have no standing. The fee is the fee. The fact that I have to pay TiVo a monthly fee on top of that fee is not the fault of the cable co. As long as the cost per outlet is the same (ignoring any fee paid to a hardware vendor like TiVo), there's no complaint, or at least not one that the FCC is going to do a darned thing about.
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Old 06-06-2012, 11:18 AM   #19
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I filed an FCC complaint and received a call from a Comcast representative here in the Boston area. She explained that the "additional outlet fee" is a charge to receive "digital services" (her term) at locations other than the primary outlet. Included in that fee is a Comcast set-top box. If you choose to use your own CableCARD-capable device (TV, TiVo, etc.) at that additional outlet you will receive a "customer-owned equipment credit", which is $2.50 in this area. If my device requires TWO CableCARDS I will be charged an additional $1.00 or so for the second CableCARD for that device. All of this information is clearly provided in the rate sheet that Comcast provided to us with our February bill.
Did you remind them that, based on their own rate sheet, you can get limited "digital services" at "additional outlets" for $1.99/mo? That FCC regulations state that a CableCARD "Receive all “linear” channels (channels other than “on-demand”) in your subscription package."? If so, what was their response?

Quote:
Originally Posted by jadziedzic View Post
You can complain all you want - and I personally agree that charging for extra outlets really sucks - but based on Comcast's explanation of their charges they believe they do comply with *their interpretation* of the FCC requirements. Yours obviously differs, but until you can convince some government entity to convince Comcast to change *their opinion* you're simply flogging a deceased equine.
Comcast can spin it however they wish. The fact is that they are in violation. But, as I have stated before there is no real enforcement mechanism. The FCC doesn't seem to give a rodent's posterior; I guess they're too busy worrying wardrobe malfunctions and trying to reinstate the idiotic "Fairness Doctrine". And I can't even determine who my LFA is, much less how to contact them.

Comcast counts on people not knowing what the regulations actually are, getting frustrated by the spin, and giving up. IOW, that equine is far from deceased, it's just been heavily doped by Comcast's lies and obfuscation. Miracle Max would have absolutely no problem reviving it.
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Old 06-06-2012, 12:02 PM   #20
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Did you remind them that, based on their own rate sheet, you can get limited "digital services" at "additional outlets" for $1.99/mo? That FCC regulations state that a CableCARD "Receive all “linear” channels (channels other than “on-demand”) in your subscription package."? If so, what was their response?
You've posted that 3 times now and it still has nothing to do with an additional outlet fee associated with a cable card. The cable card receives all linear channels so I don't know why you keep bringing that up. It takes the place of a cable box which would also incur the AO fee.

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Comcast can spin it however they wish. The fact is that they are in violation. D
That is not a fact. That is your opinion. Nothing you've said has proven otherwise.
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Old 06-06-2012, 12:15 PM   #21
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lpwcomp will only be happy when DTAs have the same fee as a set-top box (and then he'll be miserable).
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Old 06-06-2012, 12:19 PM   #22
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Not trying to pot stir here at all, but I find this discussion somewhat humorous since so many people never seemed to be bothered by the additional outlet fees that DirecTV and Dish Network charged their customers -- customers that had little or no choice at all in terms of what equipment to use.
Since satellite companies aren't covered by CableCARD regulations and none of the CableCARD using TiVos will even work on a satellite system, how exactly is this relevant?

In order to be compliant with the FCC regulations and still get the same revenue, Comcast's rate sheet would have to read something like the folllowing:

"First CableCARD in primary outlet $0
First CableCARD in additional outlet $7.45/mo
Second CableCARD in same device $1.50
User Owned Equipment Credit (applies only to primary outlet) $2.50/mo

TiVo probably isn't interested in getting involved. If the true charges for using multiple TiVos on Comcast were known, it would make a TiVo a less attractive option.
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Old 06-06-2012, 12:31 PM   #23
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lpwcomp will only be happy when DTAs have the same fee as a set-top box (and then he'll be miserable).
That's the most inane comment you've made on this subject , and that's saying a lot. Apparently you will only be happy when everyone just lies back and enjoys it.
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Old 06-06-2012, 12:53 PM   #24
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But if the DTA cost the same as a set-top box, you'd have no argument.

You claim that Comcast thinks they've found a loophole, but others are observing that you are the one who seems to think he has found a loophole.
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Old 06-06-2012, 01:31 PM   #25
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lpwcomp, what devices do you have in your home and how much is Comcast charging you?
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Old 06-06-2012, 02:37 PM   #26
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But if the DTA cost the same as a set-top box, you'd have no argument.
Wrong again. The fee differential just makes it more obvious what Comcast is doing and gives you something to throw in their face when arguing with Comcast. It is not the basis for my argument.

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You claim that Comcast thinks they've found a loophole,...
No,buscuitboy said that Comcast found a loophole and I responded they only think they found a loophole.

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... but others are observing that you are the one who seems to think he has found a loophole.
You (and the others) have a very odd definition of loophole. I'm not trying to get around anything. I'm trying to prevent Comcast from getting around the regulations.
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Old 06-06-2012, 02:42 PM   #27
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That is not a fact. That is your opinion. Nothing you've said has proven otherwise.
Ignoring the problem of trying to prove a negative, I have stated my premise ("Comcast is in violation of FCC regulations governing CableCARDs") and have provided supporting arguments based on facts - the official Comcast rate sheet and the relevant FCC regulations as summarized by the CableCARD: Know Your Rights page. In response, all I have gotten is either "This is what Comcast says and there's nothing we can do about it so just shut up" or "That's just your opinion". Neither of those is a valid counter argument.

This is not a criminal prosecution in which there is an assumption of innocence. In the face of the evidence to the contrary, it is supposed to be up to the FCC to make Comcast prove that they are in compliance. Instead, apparently their only response to a complaint is to inform Comcast and then file it in the bitbucket.

Do you really think that the CableCARD charge that the regulations(FCC Rule 76.1205(b)(5), 76.1602(b)) require a cable operator to document isn't supposed to include the ability to actually fully utilize the card as specified in FCC Rule 76.1205(b)(4)?
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Old 06-06-2012, 03:11 PM   #28
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It's obvious that nothing anyone says will change your view. The fee in question has nothing to do with cable cards. It's a fee that's levied on the second outlet regardless of whether you have a cable card or a cable box. That's why it's not a violation. It's also why the a/o fee is not listed with the cable card fees.

Have you asked Comcast to limit the channels you receive on your cable card to ONLY the channels that you would receive with a DTA? If they did that, I could see your argument that you shouldn't pay the a/o fee because you wouldn't have to with a DTA. However, if your cable cards are getting all the channels that a cable box would get, you're going to pay the same a/o fee that a cable box would require and there's no regulation against that.

Do you have two TiVos? A TiVo and a cable box? A different mix?
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Old 06-06-2012, 03:15 PM   #29
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lpwcomp, what devices do you have in your home and how much is Comcast charging you?
I have a DCT2000 from Comcast connected to(a/v(composite)) and controlled by(serial) a TiVo 2. That is my primary outlet. I also have a THD and 2 Premieres. The second Premiere doesn't currently have a CableCARD but I plan to pick one up next Tuesday(6/12) (assuming I still consider it worth the effort after discussing my treatment options at the VAMC) and install and activate it on the following Friday(6/15) since I won't be back home until late Thursday night.

Currently, I have the following items on my bill:

Digital Starter 62.95

Digital Service 19.90
Qty 2 @ $9.95 each

Customer Owned Equipment -2.50
Adjustment

Customer Owned Equipment -2.50
Adjustment

Franchise Fees 2.64

Federal Regulatory Fee 0.08

State and Local Taxes 0.14
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Old 06-06-2012, 03:19 PM   #30
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I have a DCT2000 from Comcast connected to(a/v(composite)) and controlled by(serial) a TiVo 2. That is my primary outlet. I also have a THD and 2 Premieres.
What if you switched one of your TiVos to be your primary outlet? Then one of your a/o fees would move to the DCT2000 box. Would you see that as a violation of FCC rules?
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