The FCC shouldn’t ‘underestimate the massive challenge’ faced by ...

doesn’t crash TVs, Sony Electronics said in a letter to the Commission. “Such problems result from the pervasiveness of OCAP in the host device, and the complexity of testing the almost infinite number of combinations of device hardware, device software, OCAP middleware implementations, MSO headend hardware, and downloadable OCAP applications,” Sony said. It said it’s “deeply concerned that the OCAP approach will be incapable of scaling beyond application to cable’s own leased set-top boxes. The cable industry’s resistance to solving the application/receiver testing challenges is evidence of this.” Neither cable nor CE disputes that OCAP, as envisioned, “will manage all of the functionality of the host device when that device is legally receiving and displaying cable programming,” Sony said. “In short, when a consumer inserts a CableCARD or, presumably, attaches the device to a system having software downloadable security, OCAP will become the intelligence of the CE product and the ‘face’ of the product to the consumer.” If an MSO’s downloaded OCAP guide application fails in a device, “the consumer will lose entirely the ability to receive and display cable programming with that device, notwithstanding the consumer’s legal entitlement to receive that programming,” Sony said. “In short, meeting consumer expectations about adequate device operation in an OCAP world presents a significant, perhaps insurmountable, problem for CE manufacturers and cable providers.” Sony said the task for CE and cable is to develop a testing regimen “sufficiently robust to manage this risk and complexity.” But no such agreement has been reached, Sony said. In a joint response, CableLabs and NCTA said they've explained many times to CE manufacturers and the FCC that CE makers shouldn’t face any “control” problem with OCAP, let alone one that’s “insurmountable… This is evidenced by the CE manufacturers who have agreed to use OCAP in their 2-way devices, including Samsung, whose two-way digital cable ready DTV was shown at this year’s CES… In fact, OCAP is based on the European MHP standard and Sony’s MHP boxes are deployed in Europe today.” OCAP doesn’t give cable “pervasive control of product functionality,” as Sony alleges, “only control over the cable service we are providing to cable subscribers… Until Sony’s filing, we had thought that we were in productive private discussions about a workable testing regime,” CableLabs and NCTA said: “We are disappointed that Sony has chosen to suggest otherwise with mischaracterizations and exaggerations that are designed for dramatic effect, rather than to advance the process.”