[sfhub]

Coming on the heels of TiVo's filing here, all I can say is:

Let the OCAP Wars of 2007 Begin!

Looks like after a couple of years of playing nice, the gloves are off.

TiVo's filing
http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6519613037
Discussion
http://www.tivocommunity.com/tivo-vb/showthread.php?t=364521

NCTA's filing
http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6519723080

Excerpts provided by vegggas on AVS:
http://www.avsforum.com/avs-vb/showpost.php?p=11595969&postcount=1
---
Monday's (9/10/07) filing by NCTA about commercial availability of navigation devices and compatibility between cable systems and CEA specifying OpenCable platforms, Tivo and other stuff.
Good, but long read located at:
http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6519723080
Excerpts:

Table Of Contents
I. THE OPENCABLE PLATFORM PROPOSAL IS THE ONLY REALISTIC MEANS OF
ASSISTING THE BROADCAST DIGITAL TRANSITION.............................5
A. The OpenCable Platform Helps Migrate Consumers into the Digital Transition. 7
B. The OpenCable Platform Is Being Commercially Deployed Today ............ 9
C. The OpenCable Platform Is Ready for Retail ....... 10
D. Content Providers Agree That the OpenCable Platform Provides the Environment
Required to Bring Better Programming to Consumers........... 12
E. TiVo Displays a Profound Misunderstanding of the OpenCable Platform .... 14
II. THE OPENCABLE PLATFORM IS THE ONLY SOLUTION THAT GIVES ALL
PARTIES THE FREEDOM TO INNOVATE ........ 16
A. Networks Must Continue to Innovate and Rapidly Deploy Enhanced Services to
Consumers.............. 17
B. The Proposed OpenCable Platform Rules Allow All Parties to Continue
 to Innovate Rapidly.......... 19

II. THE OPENCABLE PLATFORM IS THE ONLY SOLUTION THAT GIVES ALL
PARTIES THE FREEDOM TO INNOVATE ....................... 16
A. Networks Must Continue to Innovate and Rapidly Deploy Enhanced Services to 
Consumers......... 17
B. The Proposed OpenCable Platform Rules Allow All Parties to Continue to
 Innovate Rapidly......... 19

III. THE CEA PROPOSAL IS NOT A PRACTICAL SOLUTION FOR THE DIGITAL
BROADCAST TRANSITION ......... 21
A. The CEA Proposal Would Create Consumer Confusion and Limit New and
 Enhanced Service Offerings, with No Real Cost Savings.......... 22
B. The CEA Proposal Leaves Creative Content and Other Intellectual Property
 Bereft of Adequate Protection and Vulnerable to Illegal Use and Distribution.26
C. By Refusing to Offer Any Firm Commitment Whatsoever to Make DCR+ 
Equipment, CEA has Renounced All Responsibility for Its Risky Proposal ...... 28
D. The CEA Proposal Does Not Promote Competition......... 29
E. The CEA Proposal Sacrifices Innovation for Premature Standardization ..... 32
F. The CEA Proposal is Based on “Standards” That Do Not Exist and is Otherwise 
Technically Deficient in Ways that Would Hamper Innovation, Compromise Cable
Network Security, and Thwart Law Enforcement Activities.........34
G. Even Under the Most Generous Assumptions, the CEA Proposal Could Never Make a
Timely Contribution to the Broadcast Digital Transition........ 37
H. The CEA Proposal is Not Carterfone for Cable ........ 40
I. Why Not Adopt Both? Because DCR+ is a Consumer “Minus”......... 42

IV. THE COMMISSION SHOULD EXPAND ITS VISION TO AN “ALL-MVPD-READY”
SOLUTION TO FULFILL THE GOALS OF SECTION 629 ..... 45
Exhibits
A. Top Ten Technical Failings of CEA’s Proposal
B. DMAs with OpenCable – December 2008
C. Proposed Regulations
D. Critique of CEA’s Proposed Licenses

The OpenCable Platform is the only clear and practical path for achieving retail availability of bi-directional digital cable devices in time for the broadcast digital transition. It is the only solution on which committed consumer electronics (“CE”) manufacturers, the cable industry, and content suppliers agree. Through OpenCable, consumers can enjoy not only videoon-demand (“VOD”) and electronic program guides, but existing interactive services such as Start Over™, Quick Clips, news and information tickers, Caller ID on TV, DVR programming via cell phone, instant polling/voting, games, interactive programming, interactive advertising, shopping, and future television enhancements on leased and retail devices, including the possibility of first-run movies in early release windows.
OpenCable is being commercially deployed in headends and new interactive products today. Comcast, Time Warner, Cox, Cablevision and Advance-Newhouse will have completed the rollout of OpenCable to headends in all of their systems in time for the holiday 2008 season and ahead of the February 2009 broadcast digital transition. Taken together, this would represent over 91 million homes passed in 145 Designated Market Areas (“DMAs”) that will be able to access the OpenCable Platform.

There are a great couple of pages (15/16 of PDF) about Tivo, but I'm having a problem posting that split format, maybe someone else can do a better job.

vegggas

 

[moyekj]

Interesting that Tivo is proposing HME as a short-term alternative to OCAP:

V. TIVO PROPOSES AN INTERIM TWO-WAY SOLUTION THAT WILL BRING TO CONSUMERS THE BENEFITS OF COMPETITION WITHOUT FURTHER DELAY
Given the choice between the current OCAP regime proposed by NCTA and CEA’s November 7th proposal, TiVo has to support the CEA proposal since, as explained above, the current OCAP regime simply does not allow TiVo to build a competitive bidirectional product. As explained above, the current OCAP regime is no choice at all since the technical provisions of OCAP and the additional terms that are in effect via CableLabs licensing agreements prevent TiVo from dictating the design and functionality of its product. Although the purity of its offering may suffer to some extent, however, TiVo believes that some concessions may be necessary for consumers to realize the benefits of competition as promised by Section 629 in the near term, which in turn will promote the sale of digital cable ready devices and the DTV transition.

TiVo thus proposes an interim solution below that reflects a compromise that would assure that all parties’ interests are adequately met in today’s market.
TiVo has created an efficient network-based client-server protocol using open standards for hosted applications. This protocol, which TiVo calls the Home Media Engine (“HME”) protocol, supports efficient rendering of modern multimedia user interfaces on remote devices, reporting remote control and other events back to a server running an application. The HME protocol is efficient, agile, thin and scalable. While HME was designed for graphics-rich multimedia applications served over unmanaged IP networks, the protocol will operate over any suitable network transport interface, such as bi-directional CableCARD. Applications can be quickly modified, upgraded and tested on the server without changing the code on the client (i.e., set-top box). Client requirements are minimal, simply displaying text, pictures, audio, video and graphical elements as dictated by the server application. Perhaps most importantly, TiVo already uses HME servers today to support millions of HME clients.

TiVo believes 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 such as HME that allows individual MSOs to run their proprietary bidirectional applications — such as VOD and PPV — remotely on their servers. Such two-way applications could be invoked on the competitive box through its native user interface. In this way, each MSO could control the presentation of their bidirectional applications without having to redesign the cable architecture and without needing the competitive set-top box manufacturer to do any development work. Under this proposal, cable operators can use OCAP for their leased boxes if they so desire; however, CE manufacturers’ devices can but need not run OCAP. This solution is both quick and fair — it can be deployed by February 2009 transition date; it addresses the cable industry’s concern about controlling the presentation of their proprietary bidirectional applications such as VOD and PPV; and it lets MSOs run their own applications without interfering with CE manufacturers ability to design competitive navigation devices. Such a solution would ensure that consumers finally are able to benefit from competition and innovation in the market for navigation devices as intended by Section 629. Were the Commission to favor this proposal, TiVo would promptly work with appropriate standards bodies to evolve HME into a suitable industry standard for creating such applications.
This proposed solution is “interim” because it would not result in retail boxes that support all interactive operator services. A fully-functional bidirectional retail set-top box would either require substantial modifications to OCAP and its licensing regime, or implementation of the CEA proposal. While TiVo wishes to create such a fully-functional bidirectional box in the future, we recognize that neither of these approaches would yield a retail device that could be deployed by Christmas 2009, much less the February 2009 transition date.

 

[moyekj]

Here's pages 15/16 of the PDF hard to copy/paste because of split screen table format:

TIVO: TiVo claims that testing and certifying retail devices would be too difficult. It claims that the current CableCARD specification is insufficiently complete to ensure thorough testing.
CABLE: Comprehensive testing is a necessary solution, not a problem. OpenCable Platform testing has already certified both Samsung and LG digital televisions for retail manufacture and sale. Every cable modem ever sold has been certified after testing. Current UDCP testing is too limited, which has resulted in consumer problems with UDCP devices. The remedy is more comprehensive testing, not less testing as suggested by TiVo. CEA recognized this fact in the one-way MOU where the parties agreed that two-way devices would require additional testing considerations. Navigation Devices FNPRM, 18 FCC Rcd at 548.

TIVO: TiVo contends that the OpenCable Platform was not designed or developed to support multifunction devices with non-cable related features.
CABLE: CE and cable collaborated to resolve these precise issues. The product of that collaboration is included in version 1.1 of the OpenCable Platform specification.

TIVO: TiVo claims that OpenCable licensing requirements prevent or interfere with the range of functions that competitive set-top boxes could otherwise offer to consumers.
CABLE: TiVo has it backwards: retail devices are invited to innovate. But they are also required to present cable services and protect cable networks.

TIVO: TiVo claims that the OpenCable specifications allow the cable operator, and not the CE manufacturer, to control the user interface and functionality of the retail devices used with their systems.
CABLE: This is not true. The OpenCable Platform permits the cable guide to appear, but it does not prevent the operation of competing guides. A Series 3 TiVo guide could appear on a retail device exactly as it does in retail TiVo devices today.

TIVO: TiVo claims that the OpenCable Monitor Application ensures that only programs authorized by the cable operator will run on an OpenCable-enabled device.
CABLE: This is not true. TiVo has presented no evidence of such a practice, and version 1.1 of the OpenCable Platform specification provides exactly the opposite, allowing for Cable, CE, and crossover-mode functionality.

TIVO: TiVo claims that the OpenCable licensing requirements lock out any program or innovation by a device manufacturer unless the manufacturer has a separate agreement with every cable operator. TiVo claims that VOD would be unavailable to a retail device.
CABLE: This is not true. CE manufacturers may innovate as much as they like as long as they also preserve the cable experience. VOD services are available to retail devices through the OpenCable Platform. The cable industry is already running multiple VOD applications today that can be available to CE devices through OpenCable.

TIVO: TiVo claims that OpenCable is not a complete or sufficient solution for device manufacturers to access cable services.
CABLE: CE devices may access cable services through the OpenCable Platform.

TIVO: TiVo claims that the present OpenCable specification omits critical technical elements needed for the design of competitive set-top boxes with two-way functionality.
CABLE: Two CE retail manufacturers have already made OpenCable DTVs which have been certified for retail manufacture and sale. The OpenCable Platform is completely sufficient to enable CE devices to access interactive cable services. Many innovative cable services are implemented in specific ways by specific cable operators. Their features, functionality, and therefore their user, network, and billing interfaces are particular to a cable system, and therefore must be supported at the application level. OpenCable solves this by abstracting those differences. If TiVo is seeking data internal to program guides, specific and standardized applications for IPPV, VOD, or switched digital, TiVo’s claim is just another way of asking for DCR+ protocols, and it is missing the technical point. These are all non-standard applications from a wide variety of vendors that are abstracted through OpenCable in order to make the services available to OpenCable-enabled devices.

TIVO: TiVo claims that through OpenCable, the cable company controls the performance of the retail device, and a manufacturer cannot differentiate its product.
CABLE: Manufacturers differentiate their products through a wide variety of features, resources, processing speed, etc. OpenCable adds one more feature to such devices. It does not remove their differentiation.

 

[CharlesH]

CABLE: This is not true. CE manufacturers may innovate as much as they like as long as they also preserve the cable experience.

Translation: as long as they fundamentally maintain our user interface, CE manufactures can "innovate" by adding various bells and whistles.

TIVO: TiVo claims that the OpenCable Monitor Application ensures that only programs authorized by the cable operator will run on an OpenCable-enabled device.
CABLE: This is not true. TiVo has presented no evidence of such a practice, and version 1.1 of the OpenCable Platform specification provides exactly the opposite, allowing for Cable, CE, and crossover-mode functionality.

Someone is, ummm.. doing some serious "spinning" here. The descriptions of OCAP we have seen in this forum indicate that the cable company has pretty much full control over what will run, over the UI, and can override pretty much anything they want.

 

[bdraw]

Yeah, that's the best line ever, I'll rephrase it: CE manufacturers may innovate as much as they like as long as they also preserve the same terrible experience.

Seriously, this really says it all doesn't it. Cable just doesn't understand that some people think that the "cable experience" is a bad experience.

Whatever you say cable, you're right, I paid $800 for a Series3 and $10/mo because I like the way the STB looks in my rack and the remote is neat. What would make it even better is if I could somehow get SA sara software to run on my TiVo.
What a joke.

 

[wmcbrine]

I don't see why VOD and PPV should be treated as "applications" at all. Just define a protocol for them and be done with it.

 

[ah30k]

TiVo employees must have steam coming out of their ears after reading this! Can you imagine Pony and his team around the conference table going through these responses?

 

[moyekj]

What's really funny about this however is that Tivo is using the OCAP interface for the Comcast/Tivo software are they not? According to Tivo OCAP would not be sufficient to design things how they would like, so does this mean they have already admitted before rollout the Tivo/Comcast solution is not adequate? The other way to look at it - it's taken 2+ year for the Tivo/Comcast solution to be developed and still no production release. So maybe that does point to real problems/limitations with OCAP Tivo has been trying to work around. Either way it does not seem to be in Tivo's best interest to make a successful OCAP product since it would contradict a lot of what they are saying to the FCC.

 

[ZeoTiVo]

Either way it does not seem to be in Tivo's best interest to make a successful OCAP product since it would contradict a lot of what they are saying to the FCC.

but that box is specific to Comcast. Basically Comcast hired TiVo to make a better interface and better performance on their motorolla hardware. No one has seen this working in the wild yet so doubts do remain as to how well it is working.

What is backwards about a wide cable card 2 OCAP spec is that each cable company gets a lot of control of the interface and TiVo has to figure out a generic framework that can allow for that AND present the TiVo interface most of us would rather have.

So TiVo turned that around and said we already have our interface and also we have this HME app that many have used to present their own application/interface within this HME framework. Gives the cable companies what they claim they want while allowing Tivo to continue down its own interface path.

can anybody post anything that is FCC commenting on all this spin fest

 

[moyekj]

but that box is specific to Comcast.

There is also a contract with Cox which likely uses the same base software and there were plans mentioned to get it working on SA boxes as well. I don't know for sure if the solution is fully OCAP or some intermediate non-standard format, but for Tivo's sake I would hope it's the latter.

 

[ajwees41]

http://www.tivolovers.com/2007/01/09/tivo-for-comcast-and-cox-and-a-brief-summary-of-other-things/

Looks like it will be OCAP for the Comcast/Cox Tivo.

http://www.tivolovers.com/2007/01/09/tivo-for-comcast-and-cox-and-a-brief-summary-of-other-things/

 

[megazone]

Apples and oranges. The Comcast/Cox software is a TiVo application written to run ON OCAP as the application. What TiVo has problems with is being the host FOR OCAP and not being able to control the interface on a TiVo-branded box (S2, S3, HD, etc). Those are two different issues.

 

[CharlesH]

Apples and oranges. The Comcast/Cox software is a TiVo application written to run ON OCAP as the application. What TiVo has problems with is being the host FOR OCAP and not being able to control the interface on a TiVo-branded box (S2, S3, HD, etc). Those are two different issues.

Agreeing: The Comcast box with TiVo software will have whatever TiVo functionality that Comcast wants it to have. Functionality that they feel is against their interests will not be there; things like MRV, TTG, TiVoCast, Unbox come to mind as possibilities in this category.

 

[mattack]

I only skimmed this thread, but the first one

TIVO: TiVo claims that testing and certifying retail devices would be too difficult. It claims that the current CableCARD specification is insufficiently complete to ensure thorough testing.
CABLE: Comprehensive testing is a necessary solution, not a problem. OpenCable Platform testing has already certified both Samsung and LG digital televisions for retail manufacture and sale. Every cable modem ever sold has been certified after testing. Current UDCP testing is too limited, which has resulted in consumer problems with UDCP devices. The remedy is more comprehensive testing, not less testing as suggested by TiVo. CEA recognized this fact in the one-way MOU where the parties agreed that two-way devices would require additional testing considerations. Navigation Devices FNPRM, 18 FCC Rcd at 548.

Cable is totally ignoring what Tivo has said. Tivo has said that the testing *CANNOT BE DONE* because the specification is incomplete.. Not because they're too lazy to test it, is how I infer the cable's response.

 

[vman41]

I only skimmed this thread, but the first one

Cable is totally ignoring what Tivo has said. Tivo has said that the testing *CANNOT BE DONE* because the specification is incomplete.. Not because they're too lazy to test it, is how I infer the cable's response.

Plus, saying the OCAP TVs have been certified doesn't garantee they'll work in the field.

 

[MickeS]

Plus, saying the OCAP TVs have been certified doesn't garantee they'll work in the field.

Or that they'll ever even reach market.

 

[BobCamp1]

I only skimmed this thread, but the first one

Cable is totally ignoring what Tivo has said. Tivo has said that the testing *CANNOT BE DONE* because the specification is incomplete.. Not because they're too lazy to test it, is how I infer the cable's response.

Actually, I think they are refering to Tivo's filing, footnote#18, page 33. See the first post for the link. (Why do lawyers love to jab other companies in footnotes?)

In the first half of this footnote, I agree with NTCA. No spec. is ever complete no matter how detailed it is, and testing to that spec. certainly doesn't uncover every bug. Do you really want to spend five more years developing the spec.? Do you really want a 12-month long test event every time you modify the box or add a new feature? Wouldn't that delay your next-gen box, and wouldn't that drive its price up?

I agree with Tivo on the second point. Since Motorola and SA are not subcontractors for Tivo, and CableCards are not money-makers, they cannot put any pressure on Motorola and SA to fix the bugs in the CableCards. So Tivo is having to update their software to work around the bugs.

Tivo's last statement is, "consequently, there is no mechanism for a CE company to build a retail device that can be tested to ensure it will perform adequately in the field." There is, it's called beta testing, and Tivo has done a poor job of it recently. Have it pass the CableLabs test first, as this allows access to the cable networks. THEN do EXTENSIVE beta testing on the several major cable networks, fix any bugs, THEN release the product.

As a side note, the NTCA is just "ticked off" at Tivo, but really p*ssed at Sony. Can anyone find Sony's filing?

 

[mrmike]

Tivo's last statement is, "consequently, there is no mechanism for a CE company to build a retail device that can be tested to ensure it will perform adequately in the field." There is, it's called beta testing, and Tivo has done a poor job of it recently. Have it pass the CableLabs test first, as this allows access to the cable networks. THEN do EXTENSIVE beta testing on the several major cable networks, fix any bugs, THEN release the product.

I think you have a major misunderstanding of the homogenity (Is that a word) of cable plant configurations. Just because something works with TWC of Podunk doesn't mean it will work with TWC of BlahBlah. Even among a single cable system you may see several different CableCard configurations and several different firmware revisions on the cards themselves. And none of this is under your control. The testing plan would be a nightmare. There are functional network and protocol standards out there, they just don't tend to be single sourced by an organization with a vested interest in making it difficult for outsiders to work with their hardware.

 

[kmill14]

Considering Tivo has said publicly that they are aligning themselves with Cable, it is very frustrating to see both sides in such heated public disagreement over this topic.

 

[BobCamp1]

I think you have a major misunderstanding of the homogenity (Is that a word) of cable plant configurations. Just because something works with TWC of Podunk doesn't mean it will work with TWC of BlahBlah. Even among a single cable system you may see several different CableCard configurations and several different firmware revisions on the cards themselves. And none of this is under your control. The testing plan would be a nightmare. There are functional network and protocol standards out there, they just don't tend to be single sourced by an organization with a vested interest in making it difficult for outsiders to work with their hardware.

No, no misunderstanding here. This is exactly why the NTCA didn't like CableCards. They warned that it wouldn't work, but obviously didn't state why: their cable systems are a non-uniform mess. CableCard simply exposes how badly the systems are maintained, and gives them a whole new set of problems to poorly maintain. They can barely get the boxes they already have to work. At least with one DVR, they only have one set of problems to poorly maintain.

With regards to beta testing, the plan isn't as complicated as you seem to think. Just hit the major markets. Beta testing isn't going to catch everything, but it should catch when for example, both brands of CableCards don't work well with your new product. Having two emergency software updates within 60 days after your product launch is a sign you're not doing something right.

Tivo is throwing up its hands saying, "we can't sell products like this." And the NTCA is saying, "I told you so."

Edit: Here comes the post, "well if they maintained their systems better there wouldn't be as many problems." To which I say, "that'll be $10 more per month, please." And then someone will post how that price increase is outrageous, and the monopolistic cable companies need to kept under control, blah blah blah.