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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."
 

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Not new news for those following this closely as it relates to SDV. Covered in some form in several places:
http://www.tivocommunity.com/tivo-vb/showthread.php?t=363784
http://www.tivocommunity.com/tivo-vb/showthread.php?t=357703
http://www.tivolovers.com/2007/08/27/more-hope-for-sdv-on-tivo-series3-and-tivo-hd/
and the recent most interesting find posted in 1 of the above TCF thread from Tivo support web pages:
http://customersupport.tivo.com/TiV...8de-4b74-82c1-754c3260112a/ins_Content.html#?
 

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They really hit the nail on the head:
As TiVo and others have informed the Commission, real world implementation of the Commission’s CableCARD requirements has faced numerous problems, including technical problems with the CableCARDs themselves and foot-dragging by the cable industry, reflected by inadequate information for consumers, inconsistent and inaccurate billing practices, uninformed customer service representatives, supposed supply shortages, “negative marketing,” implementation of switched digital services, and strong marketing by cable operators of their own leased DVRs.
 

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So rather than build a generic dumb java box and trying to get all the MSOs to approve and distribute a neutered TiVo experience written on the OCAP platform, TiVo is proposing instead that TiVo OS runs as normal with client/server APIs to access what they need from the MSO and as a compromise TiVo will open up a VNC-like window so the MSO can run their 2-way apps on the server side and just display in a TiVo window.
 

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What I don't understand is why TiVo kept talking about the deadline for the transition to digital television. Cable operators aren't required to transition to digital, only the OTA folks. So while I agree with the filing in principle, I am concerned the FCC will latch on that and decide TiVo doesn't know what it's talking about.
 

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Even though the OTA cutoff doesn't apply to cable there is the general theory that the overall transition will go smoother if various digital devices are interoperable between OTA and digital cable rather than needing to repurchase your hardware over and over again. There is also the feeling that by making compelling hardware available with new features, ease of use, and portability, more people will have incentive to move over to digital on their own, some of those going OTA digital, either with or without intention to go digital cable at some point because their hardware would work on either system.

There is also the theory that fewer people are complaining about the OTA cutoff because lots of people are getting their TV by cable and aren't expecting an analog cutoff. If as expected many cable companies start moving analog channels to digital, that will increase the # of people complaining.

Those are just theories of course. Maybe nobody really cares about this stuff.
 

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sfhub said:
So rather than build a generic dumb java box and trying to get all the MSOs to approve and distribute a neutered TiVo experience written on the OCAP platform, TiVo is proposing instead that TiVo OS runs as normal with client/server APIs to access what they need from the MSO and as a compromise TiVo will open up a VNC-like window so the MSO can run their 2-way apps on the server side and just display in a TiVo window.
Yes, exactly. While they don't come right out and say it directly, it's absolutely implied:

Translation:

TiVo is proposing that they should be able to use the their existing architecture (i.e., existing boxes and OS) and provide the capability for the MSO to provide their own unique application experience to provide PPV/VOD, etc.

This is a smart move and request. It would certainly be cheaper for TiVo to do this, plus provide a fuller experience. They have almost everything already built to provide this experience and I can't see why the S3 architecture wouldn't be able to accomodate it with just some additional software development.

With the HomeMediaEngine (HME) interface which is used to drive access to outside services like the Yahoo Apps, TiVoCast, Amazon Unbox, etc. In the last quarterly earnings release TiVo noted that Unbox will soon be able to stream too....while that is via IP, there's nothing stopping the ability for TiVo to present a {Your Cable Company Name Here} application & interface which would communicate two-way with the head-end and then switches the channel to an authorized VOD/PPV stream.

I have no doubt that TiVo's engineers have been dealing with the issues with OCAP and have told TiVo mgmt, this stuff is terrible and a step back in terms of flexiblity of the box architecture, UI performance, etc.
 

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The overriding point... OCAP is nothing more than a set of specifications for making a "PC" to run whatever application the cable operator sends it -- "build an OS that can run this application". This is completely opposite to the spirit (and maybe letter) of the FCC mandate. What NCTA/CableLabs/et. al. should have been working on (for over a decade now!) were the protocols (ala SNMP, HTTP, FTP) for various systems to communicate. Instead they have worked steadfast to quash innovation and keep a firm grasp on every part of the system. More than once they've completely changed the set of specifications in order to get the integration ban pushed back... OCAP being the latest. SDV is paraded around as a means to (stastically) increase capacity -- only broadcast the things people are watching. However, it quite conveniently locks everyone back to the operator's hardware. (And guess what... SDV tracks viewers; they can know exactly who is watching what. (BTW, Tivo already collects and sells just such information.) That also means they can pay less royalties because they know exactly how many people are watching any given channel. Those savings, of course, will never be passed back to subscribers.)

If cable companies weren't so blindly greedy, they'd already be talking to Tivo about OEM deals to rent Tivo HD's instead of the now banned SA8300HD's. They can't buy non-cableCARD receivers anymore. It would not take much modification to link them to a cable operator instead of tivo -- MSOs are already paying for guide data, all they need is a system to format it for the tivo; one could even feed them directly from the cable network just like DTivos. They'll never go for it, 'tho; Tivo HD's are far too expensive.

Back to SDV... As I've said before, I'm unconvinced of the need for SDV. The normal cable band is 134 channels between 54MHz and 850MHz. I've never seen a tuner willing to go above 125, and factoring in cable modems. They easily have 124 channels (2 - 125.) 256QAM pushes 38Mbps per channel which is more than enough for even the highest bit rate HD stream. So, they have space for at least 124 HD stations. (in fact, far more.) Lemme count the number of HD stations TW/Raleigh is actually broadcasting...
1 (201 UNC/PBS)
2 (211 WTVD/ABC)
3 (217 WNCN/NBC)
4 (250 WRAZ/FOX)
5 (255 WRAL/CBS)
6 (280 Discovery HD Theater)
7 (281 TNTHD -- if you wanna count their idea of "HD")
8 & 9 (285/411 HBO)
10 & 11 (286/451 SHO)
12 (290 ESPNHD)
13 (291 INHD)
14 (293 HDNet)
15 (294 HDNet Movies)
16 (295 Universal HD)
+ HD On Demand(tm)
Given they're stuffing between 10 and 16 SD stations per channel, they have PLENTY of capacity without resorting to all this SDV BS. The only thing in that list that will eat channels is the On Demand(tm) stuff. That stuff is (and should be) switched, but there's no reason to use up any of those standard cable channels. Of course, they're still "wasting" significant capacity with 76 analog channels. But dropping analog ("basic" (~20$/month) and "standard" (~50/month)) means they'd have to drop the rediculous surcharge for digital cable. How much do you think they'd claim to lose from dropping the analog tier given their "$600mil" claims due to people not renting boxes? They cannot see potential revenue from people going to cable given the choice of not renting (or even having) a settop box; all they can see is the money they're potentially not going to get from their existing customers.
 

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pkscout said:
What I don't understand is why TiVo kept talking about the deadline for the transition to digital television. Cable operators aren't required to transition to digital, only the OTA folks. So while I agree with the filing in principle, I am concerned the FCC will latch on that and decide TiVo doesn't know what it's talking about.
Comcast in Chicago is all digital and no ads. You going to have a digital tuner. So I guess that Comcast will go all digital in 2009.
 

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OCAP IMO was built with the sole purpose of allowing the MSO to spec generic dumb java boxes and have multiple vendors bid on providing the STBs thus breaking the stranglehold the head-end provider has on STBs. It had nothing to do with TiVo at first, but some brilliant guy came up with the idea that they could just wave some pixie dust and convince everyone what TiVo had to do was rewrite their OS/App in Java instead of cable opening up their platform.

Really does it make sense to rewrite windows OS in Java or to instead run Java in a browser window? I'm taking liberties with the analogy, but you get the picture.
 

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sfhub said:
OCAP IMO was built with the sole purpose of allowing the MSO to spec generic dumb java boxes and have multiple vendors bid on providing the STBs thus breaking the stranglehold the head-end provider has on STBs.
If that's the case, then OCAP is a failure. You've traded one monoply for another... sure, you no longer have to buy STBs designed for a specific headend. Instead, you're locked into the OCAP application(s) supplied for that (still proprietary) headend.

What they should've been working on is a codified standard for the entire cable network to implement instead of the proprietary mess that's been used for decades. Cablecards are one step in that direction, but they all hate it.

Imagine where the internet would be today if every vendor made their own version of TCP/IP.
 

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cramer said:
If that's the case, then OCAP is a failure. You've traded one monoply for another... sure, you no longer have to buy STBs designed for a specific headend. Instead, you're locked into the OCAP application(s) supplied for that (still proprietary) headend.
You are forgetting along with OCAP they are pushing for DCAS, which does effectively break the strangelhold. In the short term, OCAP + CableCARD does the same thing, just not as cleanly.

Again, this is from the cable company's point of view. OCAP doesn't help TiVo achieve what it wants and just creates a bunch of busy work porting the TiVo OS/App to OCAP instead of building more innovative functionality.
 

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OCAP or OCRAP, is going to let the cable companies reach up the rectum of that new HD TV or whatever consumer device that you spent a ton of money on and conveniently allow it to do whatever _THEY_ want it to do. Think of your new TV as a cell phone locked to a provider with all the cool stuff turned off. It's pretty ugly. As for cablelabs, he who has the money gets certified. That is why I'm ticked that Tivo and DirectTV parted ways... :( To get HD on the Tivo requires me to go to my cable company. So far I'm not experiencing the whoas that some people are, but I'm keeping my fingers crossed.
 

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sfhub said:
Again, this is from the cable company's point of view. OCAP doesn't help TiVo achieve what it wants and just creates a bunch of busy work porting the TiVo OS/App to OCAP instead of building more innovative functionality.
It's worse than that - they can't just then load the TiVo OCAP applications onto their boxes, they'd have to deal with *every* cable MSO, and get them to carry the TiVo OCAP applications, and customers would likely have to pay the MSO more to get the TiVo software instead of the generic cableco OCAP software load. So not only do you pay for your TiVo, and your TiVo service, you get to pay your cableco more for the privilege (on top of the CableCARDs). It just gets better and better.
 

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Discussion Starter · #16 ·
It's even worse than that. :) The cable company would be the gatekeeper of everything that runs on the OCAP box (that you bought) and thus could dictate anything and everything about each application that's allowed to run (and of course could charge you whatever they want to allow you to run it). TiVo could well be forced to write different versions for each MSO. Individual MSOs would decide what features to require, which to remove (30-sec skip, commercial skip in general, Amazon Unbox, TiVo-To-Go...), what ads to push into the interface, how much real estate will be taken up by ads, how menus will be ordered to push higher-margin services, etc. TiVo under OCAP would not be TiVo. It would be missing features, have unwanted features added, and wouldn't even be consistent among MSOs.

OCAP (as defined today) is fundamentally incompatible with TiVo. Which is why TiVo said they'd never produce an OCAP box. Which forever cuts them out of PPV and On-Demand. Which puts them at a permanent competitive disadvantage.
 

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Saxion said:
Which forever cuts them out of PPV and On-Demand. Which puts them at a permanent competitive disadvantage.
Not really - UnBox is essentially PPV.

I'll give you OnDemand, though some would equate that to TivoCast.
 

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Discussion Starter · #18 ·
jfh3 said:
Not really - UnBox is essentially PPV.
I meant PPV as in big sporting events and such. Not having PPV and OnDemand puts TiVo at a competitive disadvantage...but they have no choice since OCAP is inconceivable for TiVo. They are really stuck here...we need FCC intervention.
 
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