As I mentioned in my previous post, the cable industry has deployed switched digital video (SDV) as a means of conserving bandwidth, allowing us to provide better and more services to our customers.  As the FCC examines the future of set-top boxes and the current CableCARD regime, TiVo has raised a question about whether the Tuning Adapter (which it helped develop) is a satisfactory approach to enable consumers with TiVo one-way devices to access cable programming delivered via SDV.

We’ve already responded via filings of our own  – making the points that Tuning Adapters are generally working and the TiVo proposed “fix” doesn’t withstand scrutiny  – but I wanted to take some time to explain where we think TiVo gets it wrong. (Coverage of this battle of filings can be found at Multichannel News and Light Reading.)

TiVo has proposed that, in lieu of the Tuning Adapter solution, the government should require the cable industry to engineer a new Internet pathway to cable headends that will handle SDV signaling from third-party devices. It’s probably worth noting that this IP backchannel approach, targeted at getting rid of the Tuning Adapters, would not eliminate CableCARDs which serve a different function – enabling UDCPs (Unidirectional Digital Cable Ready Products) to access scrambled cable programming.

I must first point out that this proposed alternative is meant to replace the Tuning Adapters that TiVo itself helped develop (as described in my previous post and on TiVo’s website) and despite the fact that TiVo has admitted publicly that “there are no known issues with Tuning Adapters.” In addition, ARRIS (the manufacturer of Moxi, the second-leading CableCARD-enabled retail device) reports that Tuning Adapters “work in providing Moxi customers with access to SDV channels and give them the experience and functionality they expect from the UDCP.”

The Issue of Size

TiVo complained about the size of a Tuning Adapter and showed a picture of a Cisco Tuning Adapter sitting on top of a larger TiVo.

However, the Motorola Tuning Adapter is smaller than Cisco’s and is much smaller than the TiVo device, as can be seen in this photo (Also shown above). Also, TiVo actively markets a Western Digital Hard Drive for its customers to use whose size is comparable to the Cisco Tuning Adapter, as shown in this side-by-side photograph (Also seen to the right).

The fact that Tuning Adapters work is much more important than their size. The reason they are their current size is because they have not been needed in sufficient volume for manufacturers to justify the cost of designing a smaller form factor.

It’s important to note that only a tiny percentage of cable customers need a Tuning Adapter. Thus, one key advantage of the Tuning Adapter is that it is scaled precisely to its purpose: It is deployed only to those customers who 1) use UDCPs with a USB port and the necessary firmware, 2) subscribe to a system deploying SDV, and 3) wish to receive SDV channels.

Should all cable systems be reengineered in order to accommodate this small number of TiVo users when it has always been clear that UDCP devices could not receive two-way services and there is already a means for them to access SDV programming?

The Not-Ready-For-Primetime Proposal

Unlike the Tuning Adapter, TiVo’s IP proposal is not ready for primetime and would impose unnecessary costs on the vast majority of cable subscribers who don’t need this additional functionality.

For starters, TiVo’s IP proposal doesn’t address what’s to be done about security and authentication or how new standards and protocols should be established that will address the wide variety of equipment used in the field.

The FCC also asks whether TiVo’s solution would result in unnecessary costs, acting as a disincentive for investment by the cable industry in switched digital. This is a reasonable question, because what TiVo’s proposal seeks is to force cable operators to engineer and deploy a new pathway to their headends to accept communication from one-way retail devices when a satisfactory solution already exists. As TiVo has said in another context, “if Congress or the Commission chooses a particular technological implementation over other technically feasible alternatives, innovation will be choked off.”

TiVo brushes off concerns about development costs, claiming, “No technical problems need to be ‘solved’ for the Commission to move forward with these reforms – just some choices, involving existing technologies, to be made.” However, Cisco’s comments estimate that 30-42 months would be required to implement TiVo’s proposal, and even that schedule assumes resolution of the technical uncertainties that now exist. In its filing, ARRIS warned, “Any alternative approach would need to be evaluated for the incremental investment it demands of operators and suppliers alike, along with operator implementation costs and risks.”

Instead, we think there is a better way forward for consumers. As we say our filing:

There may well be creative IP solutions and technological designs for interactive services, but they should be addressed for all MVPDs on an AllVid basis in the NOI, not in this short-term cable-centric proceeding.

Read this blog post from NCTA President & CEO Kyle McSlarrow, in which he argues that “the only way a retail video device marketplace can fully work for consumers is if all MVPDs participate.” That’s the path forward that will offer the greatest return.