TiVo urged the FCC Wed. to keep July 1, 2007, as the DTV tuner ma...

the Commission’s efforts to expedite the DTV transition” and agrees on the need for a date certain by which all TV sets are capable of receiving over-the- air DTV signals. However, advancing the deadline 6 months “will have unintended consequences of significantly disrupting the market and causing economic hardships” to TiVo and other CE makers, the company said. Making Dec. 31, 2006, the new deadline will “exponentially compound the hardships” posed by a speedier deadline because it falls at the end of the holiday selling season, TiVo said. Typifying others in the CE industry, TiVo said it “experiences a significant increase in sales during the holiday season and therefore needs to ramp up its manufacturing output to ensure that a sufficient quantity of the product is available to meet the public demand.” During the holiday season, “the sales channel is full of TiVo’s products” as a result, it said. A Dec. 31, 2006, deadline “would throw a wrench” into TiVo’s manufacturing and shipping plans, it said. “It would require TiVo not only to cope with the unpredictable and increased holiday season demand, but at the same time attempt to coordinate the timing of sales of non-DTV tuner products and DTV tuner products during these busiest consumer buying months,” the company said. To avoid being saddled with non-DTV tuner inventory that can’t be sold after the deadline, TiVo would need to ship such products well before the deadline, “which is not feasible from a practical and business standpoint,” it told the Commission. More woes would result with substantial numbers of product returns historically made after the holiday season, TiVo said. Last year, about 25% of TiVo PVRs bought by consumers during the holiday season were returned after Dec. 31, the company said. With a Dec. 31, 2006, deadline, “TiVo would be prohibited from reselling the non-DTV tuner merchandise returned post-holidays and it would be forced to take a massive loss,” it said.