Cablecard

Shopping on line can be easy, simple and save you lots of money. It can also take a lot of your time, frustrate you, and result in unwanted purchases. Now the same can be said for regular high street shopping, but with the vast opportunity presented by the Internet it will pay you to spend a few minutes reading this and understanding how to better optimize your Cablecard shopping experience:

1. Compare - without doubt the biggest advantage that the Cablecard offers shoppers today is the ability to compare thousands of Cablecard at a time. This is a great thing, but not necessarily all the time! Too much can be daunting at times so take advantage of the great comparison sites and where possible let them do the hard work for you.

2. Research - if it has been said it will be on the internet. Ignorance is no longer a justifiable reason for buying the wrong thing. Take the time to research in detail everything that you could possible want to know about

3. Testimonials - don't know anybody that has bought a Cablecard? Wrong! If the Cablecard is good the internet will let you know. Use the Internet as a friend and get testimonials before you buy.

4. Questions - Got a question about Cablecard then search the Forums, FAQ's, Blogs etc. Don't be afraid to ask .....

5. Reputation - Never heard of the company selling Cablecard? Don't worry, no reason why you should know every company in the world, but you know someone that does! Use the internet to find out what people are saying about Cablecard and build up a picture of their reputation for sales, returns, customer service, delivery etc.

6. Returns - still worried that even after all of the above your Cablecard wont be what you want? Check out the returns policy. There is so much competition now that someone, somewhere is bound to offer the terms that you are comfortable with.

7. Feedback - happy with your Cablecard then let people know, after all you are depending on others people input in your buying decision, so why not give a little back.

8. Security - check for the yellow padlock on the Cablecard site before you buy, and the s after http:/ /i.e. https:// = a secure site

9. Contact - got a question about Cablecard, or want to leave a comment then check out the sites contact page. Reputable companies have them and respond.

10. Payment - ready to pay for your Cablecard, then use your credit card or PayPal! Be aware of companies that don't accept them, there may be genuine reasons but given the huge amount of choice you have when buying online there is no reason at all not to buy via credit card or PayPal.

CableCARD is a plug-in card approximately the size of a credit card that allows consumers in the United States to view and record digital cable television channels on digital video recorders, personal computers and televisions without the use of other equipment such as a Set-top boxes (STB) provided by a cable television company. The card, provided by the local company for a nominal monthly fee, is a PC card and looks exactly like those used with laptops. In technical contexts, "CableCARD" refers more broadly to a set of technologies created by the cable television in the United States industry in response to requirements by federal government's Telecommunications Act of 1996 that cable companies allow non cable company provided devices to access their networks. Use of the term CableCARD can be confusing, because some technologies refer not to the physical card, but to a device ("Host") that uses the card. Some CableCARD technologies can be used with devices that have no physical CableCARDs.

Background The portion of the 1996 Telecom law which resulted in the creation of CableCARDs is known as Section 629, instructing the Federal Communications Commission (FCC) to:"...assure the commercial availability to consumers of multichannel video programming and other services offered over multichannel video programming systems, of converter boxes, interactive communications equipment, and other equipment used by consumers to access multichannel video programming and other services offered over multichannel video programming systems, from manufacturers, retailers, and other vendors not affiliated with any multichannel video programming distributor."Multichannel video programming refers to cable or satellite television. A driving motivation of this passage was to foster the kind of consumer choices that resulted after the Federal government landmark Carterfone ruling requiring telephone companies to allow consumers to purchase third party telephones for attachment to the phone company network. The thought was that consumers would benefit from wider choices due to competition between consumer electronics (CE) manufacturers unaffiliated with cable companies.

The FCC was charged with working with industry to carry out the directives of the 1996 law. On June 11, 1998, after securing proposals and recommendations from interested parties, the FCC ordered that cable companies would provide a separable security access device by July 1, 2000 which could be used by third-party devices to access digital cable networks. One important issue was the concern that cable companies might not be motivated to provide efficient security access mechanisms for competitor companies to use. To address this, the FCC directed that the cable companies would by January 1, 2005 also have to use a separable access device that was also available to third parties. The cable company would be banned from providing devices that relied on a security access mechanism integrated with the device after the 2005 deadline. This rule is usually referred to as the "integration ban", and has been unsuccessfully challenged in the courts and in FCC petitions by the cable companies. The deadline has been shifted forward twice and went into effect July 1, 2007.

The separable security device was referred to in FCC regulations as a "Point of Deployment" (POD) module. After many requests for delay from the cable industry, the first CableCARD devices became available from third party manufacturers in August 2004.

CableCARDs may be used to access both Standard-definition television and High-definition television channels. CableCARDs are not necessary for viewing unscrambled digital cable channels if the user has a QAM tuner — a feature in some televisions and Digital video recorders. CableCARD support is most common on higher end televisions that include a special slot for the CableCARD and a built-in cable tuner. The card acts like a unique "key" to unlock the channels and services which the cable customer has subscribed to, and the television's remote-control will also control the cable channels. Televisions that support CableCARD should be labeled by the manufacturer as "digital cable ready", or DCR.

Existing CableCARD Standard and Certification Procedures Cable providers in the United States are required by the FCC to support the CableCARD standard. The specification for devices conforming to this standard is known as CableCARD 1.0, and allows access to all the features that consumers most commonly use, but cannot access services which require two-way communication with the cable company servers. The specification was developed by CableLabs, a research group run by a consortium of cable companies. Devices that use CableCARDs are known as "Hosts" and must be certified as compliant with the specification by CableLabs. The certification process can take significant amounts of time and is performed in batches on a regular cycle every 3 months.

With rare exceptions, all cable companies in the United States are required to provide CableCARDs conforming to this specification, and must correct incompatibilities between their networks and certified CableCARD devices. The FCC requests that complaints be made directly to the FCC concerning problems with cable companies refusing to offer CableCARDs, or providing poor support for them. The FCC may be reached here.

The current CableCARD standard was born out of an adversarial process between two main groups: cable companies represented by the National Cable & Telecommunications Association (NCTA) and consumer electronics companies represented by the Consumer Electronics Association (CEA). The portion of the CableCARD specs that could be agreed on describe how one-way services work, and so only this portion gained FCC support. Most of the remainder of the specs were swept into Cablelabs' proposal for the enhancement of the CableCARD standard known as CableCARD 2.0.

Although an Fiber-optic communication service, Verizon FiOS is classified as a cable service and must by FCC rules also support the CableCARD standard. No cable providers in Canada currently support CableCARD. Video providers in Europe must conform to the DVB standard which is a more comprehensive open standard governed by independent standards bodies.

CableCARD also supports non-television functions. It can also act as a cable modem controller, again with the host providing modulation and demodulation functions, and the card providing decoding and Internet Protocol routing functionality; however this feature is rarely used, and depends on the cable provider.

Physical CableCARDs The physical CableCARD that is inserted into the host device is a PC card type II card which handles decryption of video, and making sure that only people that have paid for the channel may view it. This is also known as "conditional access module" function.

There are two kinds of physical CableCARDs:

An "SCard", or "single stream" card, can decode a single channel at a time. All currently available cards are SCards and were specified in the CableCARD 1.0 set of specifications.
An "MCard", also known as "MS-CableCARD" or "multiple stream" card, can decode up to six channels simultaneously. MCards were specified in 2003 but have been frequently delayed. They became available prior to July 2007, when the integration ban took effect.

MCards are sometimes referred to as CableCARD 2.0 cards, although they do not themselves provide any of the CableCARD 2.0 features, such as interactivity. MCards are Backward compatibility with current CableCARD devices. To older CableCARD devices that do not support multiple streams, the card appears to be a single stream card. CE companies have long wanted MCards for their CableCARD 1.0 host devices in order to compete with Cable company devices that use multiple tuners. This is important for products such as Sony & TiVo CableCARD Digital video recorders, televisions with Picture-in-picture and CableCARD-equipped Personal computers, which need to be able to record one show while the user is watching another. Without MCards, these products must rely on two SCards, and installation and support is more error-prone. Simple availability of MCards is insufficient if MCards are not supported on cable company servers by a specified date. No such date exists, and so CE companies are uncertain when they will be able to sell products that rely on MCards.

A common misconception is that there is a CableCARD 2.0 physical card that will provide two way services and will not be compatible with CableCARD 1.0 certified devices. This is not the case. CableCARD 2.0 host devices will only use either SCards or MCards that also work with CableCARD 1.0.

Interactive CableCARD 2.0 features rely on additional circuitry in the CableCARD Host device, not on the physical card. There is no directionality about the cards. This makes the name "CableCARD 2.0" extremely misleading, since it mostly has nothing to do with the physical CableCARDs.

CableCARD Manufacturers As of January, 2007, two manufacturers have M-Cards (multi-stream cards) qualified by CableLabs: Motorola and Scientific Atlanta (recently purchased by Cisco). Three manufacturers have S-Cards (single-stream cards) qualified: Motorola, Scientific Atlanta and NDS Group.

Proposals for CableCARD's next version Two proposals exist for enhancing the CableCARD standard. Both are designed to add support for two-way features whose operation details the CE and cable company representatives could not agree on in time for inclusion in the CableCARD 1.0 specification. These two-way features include ordering Pay-per-view via remote, Video on demand, advanced Electronic program guide information, and Switched Video services. These features are not supported by CableCARD 1.0, and so are not available with current CableCARD-enabled products.

The CableCARD 2.0 proposal is a set of formal specifications advocated by the cable companies. The CableCARD 2.0 proposal does not specify a standard protocol for interacting with cable company servers, as is usually done with Client-server architectures. Instead, the proposal specifies that the host machine provide a Java (programming language) environment capable of running OpenCable Application Platform programs downloaded from the cable company. Cable companies generally advocate this position so that they can be sure that moneymaking interactive services may be reliably supported for each of the CE vendor machines without requiring each vendor to write custom software. CE vendors, on the other hand, argue the specification goes far beyond the requirement of a separable security device, and intrusively specifies the internal operations of their devices. This, they argue, turns their products into non unique commodities that no CE companies will be able to make profits on. Current CableCARD 2.0 negotiations remain at an impasse. Cable companies have said they will not be changing the specification substantively. Equipment with CableCARD 2.0 support is expected in 2007, since cable companies are going ahead without FCC approval and are commissioning Samsung, LG, and Panasonic to build devices to the specification.

CE and computer companies advocate a different proposal, which modifies the CableCARD 2.0 spec. This proposal was presented to the FCC on November 7, 2006 and has the goal of persuading the FCC to support a standard less aligned with cable company interests. Specifically, they have advocated that OpenCable Application Platform be dropped as a requirement for simple interactive services such as Video on Demand, interactive television listings and Pay-Per-View. This proposal would require that some additional functionality be added to MCards with support on most servers available by January 1, 2008. Further, they have requested that consumers should "be allowed to save content to a Digital video recorder, to move content to a second or third TV, to a PC or to a portable device, subject only to the rules and limits set by the content provider and not subject to artificial and arbitrary limitations set by the cable operator." To this end, they have requested that the FCC order that the CableCARD Host Licensing Agreement (CHILA) be immediately modified to accept all output protection technologies approved by Digital Living Network Alliance (DLNA). Another proposal is that the CableLabs certification process be streamlined into that a standardized test suite, so that CE companies can self-certify devices without needing to wait for CableLabs approval.

A portion of the CableCARD 2.0 proposals that will be available prior to approval of the remainder of the specification regards the multistream cards (MCards). Some digital video recorder manufacturers have held off on integrating CableCARD slots into their machines until MCards are available. Others, such as Sony, TiVo and Microsoft bypassed the MCard delays and record two channels by using two SCards. MCards are expected in the spring of 2007.

Issues with CableCARDs

Ineffective enforcement after one decade: The FCC stated that it was "clear from the record that the market for equipment used in conjunction with the distribution of digital cable video programming presently remains a nascent market."{{cite web | date=2006-12-26 |url= http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-05-76A1.pdf|title= Second Report and Order, 20 FCC Rcd 6808

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Although 3.8 million televisions in the United states have CableCARD slots, it has been estimated that only three percent of the compatible televisions sold to consumers were actually being used with CableCARDs.{{cite web | date=2006-08-18 ], [2006,|format= |publisher=US District Court of Appeals, (DC Cir.) |accessdate=2006-12-26--> This is cited as evidence that the FCC has not fulfilled its obligation to carry out the will of Congress expressed in the 1996 telecom law. The NCTA asserts that cable companies have complied with onerous FCC regulations and procedures, and has behaved lawfully.

Higher Cost, Less Choice due to Cable's monopolist practices with Cable boxes: CE companies contend consumers pay higher monthly costs and have limited choice because Cable companies have been allowed by the FCC to avoid compliance with the 1996 Telecom Law. Vertical integration of services and access devices mean that third party vendors are effectively locked out of providing competitive access devices because the methods for access devices. It was this imbalance that Congress sought to correct the 1996 telecom law. Cable companies counter that 5 million CableCARD devices are on the market, and so it cannot be contended that they have a monopoly on access devices. The fact that the CableCARD functions are not used on these devices is evidence of CableCARD's commercial failure. Cable companies contend that the 1996 law was not intended to guarantee the commercial success of these devices, just their availability.

Poor support from cable companies: Consumer electronics companies have documented to the FCC that consumers have experienced persistent problems between CableCARDs and cable company servers, resulting in dropped or unavailable channels, error-prone installation, unfair charging for unnecessary technician visits, and double-charging for services used by devices using multiple SCards. Cable companies contend the number of problems are exaggerated, and that they are paying the support costs of poorly engineered third-party devices. Cable companies ask that CE devices be subjected to more rigorous testing in order to reduce the cable companies' burdensome support costs for CableCARD equipment.{{cite web | date=2006-08-18 ], 2004 cited in Ruling: Charter Communications, Inc. v. FCC (DC Cir.) 05-1237 August 18, [2006,

|format= |publisher=US District Court of Appeals, (DC Cir.) |accessdate=2006-12-26--> The CEA summed their position up thusly: "The CE industry's experience with MSO support for unidirectional CableCARD-enabled products has provided ample evidence that the cable operators' commitment to CableCARD and, indeed, to complying with the Commission's rules, has been halfhearted at best.".{{cite web | date=2006-08-18 ], 2006,|format=PDF |publisher=FCC |accessdate=2006-12-26-->

No agreement on standard for two-way communication The one-way limitation of current generation CableCARDs means that certain interactive features, such as Video on demand and Switched Video Channels, are not available to users, as there is no way for the host device to communicate with the cable provider. To get other features such as Electronic program guide, and Pay-per-view movies, the user has other alternatives, such using the guide of a Digital Video Recorder or the non-interactive guide familiar to most other cable customers. Pay-per-view may be ordered via the internet or phone. Lastly, there is no way for the cable provider to remotely determine if the CableCARD is functioning properly, requiring a tech visit or call to customer support to report and resolve problems. Cable users relying on analog or older cable company equipment also do not have any of these two-way features; but, because third-party devices are required to have full access to cable company networks, there must be a public specification for how third parties may access such services.

Satellite companies unfairly exempted: Cable companies argue that, although section 629 of the Telecom act applies to all multichannel video program distributors, Direct broadcast satellite (DBS) services have been exempted from requirements for a separable security access device. This is claimed to provide an unfair advantage to DBS companies such as Directv and Dish Network.

Non-level playing field CE companies argue that cable companies should not have the power to arbitrarily delay new competitor devices through use of the CableLabs certification process, or take competitive advantage of advance warning of these new products. Cable companies answer that they must certify products because they have a right and duty to their customers to protect the integrity and reliability of their network.

Downloadable Conditional Access System ineligible to replace CableCARDs? The 1998 FCC order stated that the security access module must be separable. Although the downloaded software is removable, the current Downloadable Conditional Access System proposal relies on a custom ASIC chip which is soldered onto the Host's circuit board. Since this chip is integral to the security access function, and since it is not removable from the host, some parties argue that DCAS does not meet federal requirement for a separable security access module, and therefore cannot replace separable CableCARDs that carry their circuitry on them.

Freezing protocols freezes innovation by Cable The NTCA argues that the November 2006 CEA proposal for two-way CableCARD support will retard Cable's ability to innovate. The argument is that the freezing of formats and protocols means that cable companies will be unable to change them in response to new more innovative solutions to the same features. It was precisely this potential impact of major standards decisions to freeze technological development that led the FCC to be reluctant to follow the course of Europe, which mandated a comprehensive open standard known as DVB. After prolonged impasses between warring parties, the agency has appreciated that technical standards reduce confusion among consumers and manufacturers and that sometimes there needs to be regulatory intervention to reduce the tendency of different stakeholders to squabble among themselves, thus holding back the development of the market.

CE companies want to unbundle an integrated product Cable companies make the case that new technology allows video and interactive services to become an aggregate experience that constitutes a single product, and that CE companies should not "disaggregate" video from navigation and other elements of this aggregate experience.{{cite web | date=2005-03-24 ], 2005

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No Tuner Access When TV is Off When CableCARD technology is integrated into a television set, the TV tuner cannot be operated without powering on the TV. This prevents 3rd party DVR machines (such as a pre-Series 3 or HD TiVo) from being able to record programs since they have no control of the signal. DVRs normally control a set-top box without needing to power on the television, but eliminating the set-top box in favor of the CableCARD effectively disables early TiVo models. Only the Series 3 and HD TiVo lines support CableCARD and over-the-air ATSC. This is moot however, as it is possible to combine a CableCARD supported set-top box with a non cable-card supported DVR, effectively allowing any older DVR to operate with CableCARD technology.

Future directions Some cable companies state that they will support CableCARD 2.0 when the equipment becomes available. It is thought that many cable companies do not intend to put features such as OpenCable Application Platform in lower end STBs. There are some in the cable industry who are advocating that physical CableCARDs be dropped entirely. These cable companies prefer to move away from physical cards, and have proposed that a downloadable security component known as Downloadable Conditional Access System (DCAS) be used instead. As for cable company advanced proposals, neither CableCARD 2.0 nor DCAS has been approved by the FCC, and what form they will eventually take is a matter of considerable debate and speculation.

CE companies advocate their proposal for more unfettered access to cable company networks, with CableLabs' role reduced to addressing only cable company interests of maintaining network stability and security.

Technical Overview CableCARD is a term trademarked by CableLabs for the Point of Deployment (POD) module defined by standards including SCTE 28, SCTE 41, Consumer Electronics Association-679 and others. The CableCARD is physically a PCMCIA type II PC card, supplied by the cable company, which is inserted into a slot in the host (typically a digital television set or a set-top box) in order to identify and authorize the customer, and to provide proprietary decoding of the encryption digital cable signal without the need for a set-top box. The cable tuner and Quadrature Amplitude Modulation modulation themselves are part of the host device, as is the MPEG decoder. The role of the card is to perform any conditional access and decryption functions. This results in an MPEG-2 transport stream, which is decoded by the host. The card also receives messages sent over the out-of-band signaling channel by the cable company's Head end servers and forwards them to the host.

Cards from major providers such as Comcast, Cox Communications, and Time Warner Cable in some regions currently require on-site installation by a technician, who reports the unique ID numbers pre-assigned to both the CableCARD and the digital television to the company headquarters, where they are updated to the customer's account. Because of this, CableCARDs cannot be moved from one device to another without a visit from a cable company installer. Some regions (such as Time Warner Houston) do allow customer installs, and actually provide special phone support for CableCARDs. The card is inserted as users do for laptop PCMCIA cards. The CableCARD identification numbers are given to the operator who then sends the CableCARD an out of band Entitlement Management Message (EMM), which remotely programs the CableCARD, authorizing it to decode for the specific host only those shows and services which the user is authorized to view.

CableCARDs with personal computers: See OpenCable Unidirectional Receiver.

Existing integrated cable set-top boxes perform four basic functions:

Enable receiving and selecting digital and analog cable channels

Uniquely identify the customer and authorize the features they have subscribed to

Decode scrambled digital channels and premium programming such as movie channels

Provide interactive 2-way communications for:

Electronic program guide

Pay-per-view

Video on demand

Switched video

New digital televisions and other devices that are labeled DCR "Digital cable ready" contain:

built-in support for receiving digital cable channels (via an internal QAM tuner)
a slot for the current version of CableCARD ( see photo here), which allows decryption of encrypted digital channels. Current CableCARDs do not support any of the interactive, two-way communication functions listed above.

The CableCARD 2.0 specification proposed by cable companies includes support for #1-4, interactive two-way communications; however it is unknown exactly when CableCARD 2.0 hosts and compatible servers will become available (possibly 2007 or 2008 in some cities). Future devices which support CableCARD 2.0 are expected to be labeled iDCR "Interactive digital cable ready". Among other requirements, CableCARD 2.0 hosts will be required to provide the OpenCable Application Platform (OCAP), to run programs downloaded from the cable company.

An alternative to CableCARD 2.0, most recently advocated by the U.S. cable television industry, uses Downloadable Conditional Access System (DCAS) in place of physical CableCARDs. In this proposal, a custom security chip must be soldered into every compliant host; if a security scheme is compromised, a new security program can be downloaded to the host device.

Because the conditional access system is in software, it can be sent with the video as a form of Digital Rights Management (DRM). The CableCARD Host Licensing Agreement (CHILA) and the Downloadable Conditional Access System agreement restrict the technologies that CE companies may use for distributing video from host devices. CE companies object to this expanding the notion of CableCARD network security issues to also include content protection issues. They prefer to deal with content owners directly with their standards and regard cable company protocols and formats as a transport only. CE companies wish to communicate video inside the home network using their own protected protocols and formats.

The OpenCable Application Platform (OCAP) is a Java-based platform intended for use either with any security access scheme — whether it is CableCARD 2.0 devices or future downloadable security schemes. OpenCable Application Platform was tied to CableCARDs because, as it was imagined by CableLabs, the additional processing necessary for managing the communication with the cable company server would be performed, not on the cable company provided equipment (the CableCARD), but on the consumer electronics device — known as the CableCARD "Host". CE companies objected that OpenCable Application Platform is unnecessary for the simple task of managing two-way communications on the cable networks. The CEA perspective is that Java (programming language) is not efficient for CE devices, and that cable companies are passing to CE manufacturers the costs of a software platform which they didn't need, and which won't run on their existing hardware architectures.

The consumer electronics industry proposed in November 2006 that the CableCARD 2.0 specification be upgraded to include the provision for modified MCards that would support the communications necessary for VOD, PPV, and Switched Video. This card would be backward compatible with older cards, and support would be required for them on cable company servers by January 2008. These modified MCards would not allow two-way communication using current OCURs, which, by definition, are unidirectional. This so-called "OpenCable Application Platform-less" proposal was rejected by the National Cable & Telecommunications Association for a variety of reasons elaborated on in the issues segment of this article. The technical advantage is that much less is assumed about the computing capability of the host, allowing the manufacturing cost to be significantly reduced. The disadvantage is that the MCard will be slightly more expensive, but the host will not necessarily be able to support the envisioned ecommerce and banking applications. CE companies argue that such a card fulfills the 1996 law's requirement that cable companies allow two-way communication on their networks, and that OpenCable Application Platform fulfills technical goals far in excess of those necessary for such two-way communications.

References See also

Conditional access module (CAM)
Downloadable Conditional Access System (DCAS)
Digital Cable Ready (DCR)
Digital Living Network Alliance (DLNA)
Digital Rights Management (DRM)
Digital video recorder (DVR)
Entitlement Management Message (EMM)
Interactive digital cable ready (iDCR )
National Cable & Telecommunications Association (NCTA)
OpenCable Application Platform (OCAP)
Open cable unidirectional receiver (OCUR)
PC card (originally PCMCIA card)
QAM (QAM)
Quadrature phase-shift keying (QPSK)
Set-top boxes (STB)

External links

{{cite web | date=2007-06-22 |url=http://www.engadgethd.com/2007/06/22/cablecard-2-0-is-ready/

|title=CableCARD 2.0 is ready |format= |publisher=engadgethd |accessdate=2007-07-06-->

{{cite news

Document may be retrieved by visiting the FCC document search site, and entering "Consumer Electronics Association" in field 4. In field 7, enter 11/07/2006 in the From and To: dates. Appendix A is the 3rd document.

An "SCard", or "single stream" card, can decode a single channel at a time. All currently available cards are SCards and were specified in the CableCARD 1.0 set of specifications.
An "MCard", also known as "MS-CableCARD" or "multiple stream" card, can decode up to six channels simultaneously. MCards were specified in 2003 but have been frequently delayed. They became available prior to July 2007, when the integration ban took effect.

Ineffective enforcement after one decade: The FCC stated that it was "clear from the record that the market for equipment used in conjunction with the distribution of digital cable video programming presently remains a nascent market."{{cite web | date=2006-12-26 |url= http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-05-76A1.pdf|title= Second Report and Order, 20 FCC Rcd 6808

Higher Cost, Less Choice due to Cable's monopolist practices with Cable boxes: CE companies contend consumers pay higher monthly costs and have limited choice because Cable companies have been allowed by the FCC to avoid compliance with the 1996 Telecom Law. Vertical integration of services and access devices mean that third party vendors are effectively locked out of providing competitive access devices because the methods for access devices. It was this imbalance that Congress sought to correct the 1996 telecom law. Cable companies counter that 5 million CableCARD devices are on the market, and so it cannot be contended that they have a monopoly on access devices. The fact that the CableCARD functions are not used on these devices is evidence of CableCARD's commercial failure. Cable companies contend that the 1996 law was not intended to guarantee the commercial success of these devices, just their availability.

Poor support from cable companies: Consumer electronics companies have documented to the FCC that consumers have experienced persistent problems between CableCARDs and cable company servers, resulting in dropped or unavailable channels, error-prone installation, unfair charging for unnecessary technician visits, and double-charging for services used by devices using multiple SCards. Cable companies contend the number of problems are exaggerated, and that they are paying the support costs of poorly engineered third-party devices. Cable companies ask that CE devices be subjected to more rigorous testing in order to reduce the cable companies' burdensome support costs for CableCARD equipment.{{cite web | date=2006-08-18 ], 2004 cited in Ruling: Charter Communications, Inc. v. FCC (DC Cir.) 05-1237 August 18, [2006,

No agreement on standard for two-way communication The one-way limitation of current generation CableCARDs means that certain interactive features, such as Video on demand and Switched Video Channels, are not available to users, as there is no way for the host device to communicate with the cable provider. To get other features such as Electronic program guide, and Pay-per-view movies, the user has other alternatives, such using the guide of a Digital Video Recorder or the non-interactive guide familiar to most other cable customers. Pay-per-view may be ordered via the internet or phone. Lastly, there is no way for the cable provider to remotely determine if the CableCARD is functioning properly, requiring a tech visit or call to customer support to report and resolve problems. Cable users relying on analog or older cable company equipment also do not have any of these two-way features; but, because third-party devices are required to have full access to cable company networks, there must be a public specification for how third parties may access such services.

Satellite companies unfairly exempted: Cable companies argue that, although section 629 of the Telecom act applies to all multichannel video program distributors, Direct broadcast satellite (DBS) services have been exempted from requirements for a separable security access device. This is claimed to provide an unfair advantage to DBS companies such as Directv and Dish Network.

Non-level playing field CE companies argue that cable companies should not have the power to arbitrarily delay new competitor devices through use of the CableLabs certification process, or take competitive advantage of advance warning of these new products. Cable companies answer that they must certify products because they have a right and duty to their customers to protect the integrity and reliability of their network.

Downloadable Conditional Access System ineligible to replace CableCARDs? The 1998 FCC order stated that the security access module must be separable. Although the downloaded software is removable, the current Downloadable Conditional Access System proposal relies on a custom ASIC chip which is soldered onto the Host's circuit board. Since this chip is integral to the security access function, and since it is not removable from the host, some parties argue that DCAS does not meet federal requirement for a separable security access module, and therefore cannot replace separable CableCARDs that carry their circuitry on them.

Freezing protocols freezes innovation by Cable The NTCA argues that the November 2006 CEA proposal for two-way CableCARD support will retard Cable's ability to innovate. The argument is that the freezing of formats and protocols means that cable companies will be unable to change them in response to new more innovative solutions to the same features. It was precisely this potential impact of major standards decisions to freeze technological development that led the FCC to be reluctant to follow the course of Europe, which mandated a comprehensive open standard known as DVB. After prolonged impasses between warring parties, the agency has appreciated that technical standards reduce confusion among consumers and manufacturers and that sometimes there needs to be regulatory intervention to reduce the tendency of different stakeholders to squabble among themselves, thus holding back the development of the market.

CE companies want to unbundle an integrated product Cable companies make the case that new technology allows video and interactive services to become an aggregate experience that constitutes a single product, and that CE companies should not "disaggregate" video from navigation and other elements of this aggregate experience.{{cite web | date=2005-03-24 ], 2005