Comcast 2012 Annual Report Download - page 24

Table of Contents
right to interconnect directly with them, we have prevailed in all of these challenges, and no such challenges are currently pending.
That said, if a regulatory or judicial authority were to deny our ability to interconnect through one of our CLECs, our ability to provide
voice services and compete in the area in question would be negatively impacted. In December 2012, the FCC sought comment on
two petitions that raise issues concerning the interconnection obligations for IP voice providers, and it also formed a task force to
coordinate the FCC’s efforts on issues related to the transition of networks from circuit-switched to packet-
switched technology,
including the issue of IP interconnection. We cannot predict what, if any, proposals might be adopted or what effect they might have
on our business. In November 2011, the FCC issued an order clarifying the entire intercarrier compensation regime, which governs
the arrangements by which telecommunications carriers compensate one another for exchanged traffic, whether it be for local,
intrastate or interstate traffic, or VoIP. The FCC order affirmed the right of CLECs to collect intercarrier compensation when providing
interconnection for VoIP providers. However, the FCC’
s order is currently under appeal with the U.S. Court of Appeals for the Tenth
Circuit.
Other Cable Services Regulations
State and Local Taxes
Some states and localities have imposed or are considering imposing new or additional taxes or fees on the cable services we offer,
or imposing adverse methodologies by which taxes or fees are computed. These include combined reporting or other changes to
general business taxes, central assessments for property tax, and taxes and fees on video, high-
speed Internet and voice services.
We and other cable industry members are challenging certain of these taxes through administrative and court proceedings. In
addition, in some situations our DBS competitors and other competitors that deliver their services over a high-
speed Internet
connection do not face similar state tax and fee burdens. Congress has also considered, and may consider again, proposals to bar
states from imposing taxes on DBS providers that are equivalent to the taxes or fees that we pay.
Cable Networks
Program Access
The Communications Act and FCC regulations generally prevent cable networks affiliated with cable operators, other than
terrestrially-
delivered programming networks, from favoring affiliated cable operators over competing multichannel video providers,
such as DBS providers and phone companies that offer multichannel video programming services. In addition, the Communications
Act and FCC regulations had limited the ability of cable
-
affiliated cable networks to offer exclusive programming contracts to a cable
operator. In October 2012, the FCC allowed a preemptive restriction on exclusive contracts to expire but reaffirmed that any such
exclusive contract could be reviewed on a case-by-
case basis in response to a complaint alleging violation of the Communications
Act
’
s prohibition against unfair methods of competition or unfair or deceptive acts or practices that hinder significantly or prevent
competitors from providing programming to customers. This case-by-
case process already allowed multichannel video providers to
file program access complaints to try to show that their lack of access to a terrestrially-
delivered programming network had hindered
significantly their ability to deliver video programming to subscribers. In addition, the FCC is considering proposals to establish
presumptions that would make it easier for multichannel video providers to succeed with complaints involving exclusive contracts
and to make it easier for them to use buying groups and for such buying groups to pursue complaints under the rules. It is uncertain
whether the FCC will act on these proposals and, if adopted, what impact these proposals would have on our cable networks.
The FCC launched a rulemaking in 2007 to consider whether companies that own multiple cable networks should be required to
make each of their networks available to multichannel video providers on a stand-alone or “unbundled”
basis when negotiating
distribution agreements, although it has not further acted on that
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Comcast 2012 Annual Report on Form 10-
K