TiVo's Aug 24 comments to the FCC can be found here. In it, TiVo aggressively defends its right to design the user interface of its own boxes, and elegantly lays out a simple compromise with CableLab's current draconian OCAP terms. "In adopting a two-way compatibility solution, the Commission should ensure that CE manufacturers are able to build two-way devices that use their own distinct user interface to display cable programming." "Unfortunately, a solution based on the current OCAP regime will not serve the competition and consumer choice goals of Section 629. [...] Because they allow cable operators to dictate device design and curtail the freedom of CE manufacturers to design innovative competitive boxes, OCAP and the associated CableLabs license agreements currently are inconsistent with the goals of Section 629 and are insufficient to bring about the true benefits of two-way compatibility and competition in the navigation devices market." "TiVo proposes that competitive CE manufacturers should be permitted to build non-OCAP bidirectional boxes that receive all programming channels offered by MSOs provided on a per channel basis and include a presentation engine that allows individual MSOs to run their proprietary bidirectional applications such as VOD and PPV remotely on their servers."