The Home Recording Rights Coalition (HRRC) last week called on the FCC to ban “down resolution” and preserve customary home recording and fair use rights of consumers.
The HRRC's call came in response filings to two FCC Further Notice of Proposed Rulemaking proceedings related to the DTV transition.
In its filing, the HRRC noted that no devices exist to provide "non-downres'd" signals to the almost 6 million owners of high-definition television (HDTV) and enhanced definition (EDTV) displays. The coalition said the ability of these consumers to enjoy HDTV now lies squarely in the hands of the FCC, because approval of a "downres trigger" on non-broadcast programming would disenfranchise all of these consumers.
Down resolution refers to the ability to degrade picture resolution from a higher to a lower quality, such as HDTV to SD. Scaling down the resolution of over-the-air TV is not allowed. Down resolution is seen by many high definition program distributors as a means of preventing program piracy over the Internet.
"There is no rationale for downresolution springing from denial of ability to record - all 'downres' does is cut the bandwidth of the signal that is recorded,” the group told the Commission. “Similarly, HDTV downresolution keeps nothing from the Internet, since by cutting the signal down to one-quarter its transmitted size, 'downres' effectively compresses the signal for redistribution."
The HRRC argued that true content protection solutions exist that have been designed through inter-industry collaboration. "This work undermines a core precept of downresolution - that there is no copy protection alternative to punishing innocent consumers for their early investment in HDTV," the HRRC told the FCC.
Addressing fair use and customary home recording rights, the HRRC urged the Commission to take care in defining a personal digital network environment (PDNE) to accommodate “fair use principles."
HRRC pointed out that inherent in the definition of redistribution - distribution of the content in direct and actual competition with the original commercial distribution and not as a fair use - is "the recognition that private, noncommercial fair uses are not included in the targeted area" for the broadcast flag. With copy protection excluded, there would be little incentive for anyone to circumvent these technical measures in order to exercise fair use.
Separately, the Consumer Electronics Association filed reply comments with the Commission arguing that “downresolution's primary effect will be to punish consumers for making an early investment in HDTV displays when only the 'wrong' interface was available."
For more information please visit www.ce.org
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