November 3, 2008

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th St. SW
Washington, DC 20554

Re: In the Matter of Implementation of Section 304 of the Telecommunications Act of 1996, Commercial Availability of Navigation Devices, Compatibility Between Cable Systems and Consumer Electronics Equipment, CS Docket No. 97-80, PP Docket No. 00-67

Dear Ms. Dortch:

The undersigned public interest organizations are writing to in support of Verizon Communications' recent filing expressing concern with the cable industry's plan to use the successor to CableCARD to limit competition and reduce choice in the consumer electronics marketplace. We also reiterate our objection to a standard that stifles third party innovation in the consumer video market, and our support for a unified, open standard. A restrictive standard would be contrary to both the spirit and letter of Section 629 of the Telecommunications Act of 1996.

As the Commission is aware, several cable television providers and consumer electronics manufacturers have entered into a memorandum of understanding (MOU) to integrate tru2way technology into future consumer electronics products. We are concerned that tru2way technology will restrict third party developments and place the cable industry controlled CableLabs further into the role of gatekeeper of innovation. The recent filing by Verizon Communications5 concerning the lack of interoperability between tru2way and non-cable MVPDs clearly illustrates the pitfalls created by this closed platform.

To read the full letter, please see the attached PDF below.