The FCC should adopt consistent and straightforward online video captioning...

distributors (VPDs) or video programming providers (VPPs) to monitor online video to determine whether content is a video clip ... or whether it is full-length programming, subject to captioning requirements is unduly burdensome,” Google said. “As captioning video clips becomes a necessary feature, the tools for editing will improve and adapt to offer accurate editing and time coding of videos,” it said in response to some earlier comments in the docket that captioning clips would be difficult and expensive. Google also urged the commission to deny TVGuardian’s request that the FCC require VPDs and VPPs pass through captioning data through all outputs capable of connecting to a recording device, Google said. DirecTV also opposed TVGuardian’s request (http://xrl.us/bnb9k9). In the same docket, the CEA urged the FCC to reject accessibility advocates’ arguments against the CEA’s request to narrow the scope of the requirements. The FCC rules were wrong to equate “apparatus ‘capable of’ playing back video programming with apparatus ‘designed to’ receive, play back or record video programming,” the CEA said (http://xrl.us/bnb9kc). Under CEA’s vision the rules would be limited to features or apps that are designed to play “video programming,” rather than simply “video,” the CEA said. “Inclusion of a video programming app or feature in a product at the time of sales should be taken as an indication of the manufacturer’s intent that it be used for accessing video programming, while the absence of such a feature should be taken to indicate the opposite,” it said. The CEA also again urged the commission to clarify that the Jan. 1, 2014, compliance deadline refers to when devices are manufactured, not the date devices are imported to the U.S., it said. “Manufacturers would not be able to ‘determine a hard deadline'” as accessibility advocates had suggested, “for manufacturing based on the date a product is available for sale simply by determining the average time it takes for a product to work its way through retail chains,” it said. Accessibility advocates including Telecommunications for the Deaf and Hard of Hearing wrote again in support of its petition for reconsideration that the commission include video clips in the online captioning rule (http://xrl.us/bnb9mo). They also wrote in support of a separate petition for reconsideration seeking to expand the rules to require “apparatus manufacturers” to comply with captioning synchronization provision (http://xrl.us/bnb9ni).