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     ACCESS TO PROGRAMMING.  To spur the development of independent cable
programmers and competition to incumbent cable operators, the 1992 Cable Act
imposed restrictions on the dealings between cable operators and cable
programmers. Of special significance from a competitive business posture, the
1992 Cable Act precludes video programmers affiliated with cable companies from
favoring their affiliated cable operators over competitors and requires such
programmers to sell their programming to other multichannel video distributors.
This provision limits the ability of vertically integrated cable programmers to
offer exclusive programming arrangements to cable companies. Recently, there has
been increased interest in further restricting the marketing practices of cable
programmers, including subjecting programmers who are not affiliated with cable
operators to all of the existing program access requirements, and subjecting
terrestrially-delivered programming to the program access requirements.
     INSIDE WIRING; SUBSCRIBER ACCESS.  In a 1997 Order, the FCC established
rules that require an incumbent cable operator upon expiration of an MDU service
contract to sell, abandon, or remove "home run" wiring that was installed by the
cable operator in a MDU building. These inside wiring rules are expected to
assist building owners in their attempts to replace existing cable operators
with new programming providers who are willing to pay the building owner a
higher fee, where such a fee is permissible. The FCC has also proposed
abrogating all exclusive MDU service agreements held by incumbent operators, but
allowing such contracts when held by new entrants. In another proceeding, the
FCC has preempted restrictions on the deployment of private antenna on rental
property within the exclusive use of a tenant (such as balconies and patios).
This FCC ruling may limit the extent to which we along with MDU owners may
enforce certain aspects of MDU agreements which otherwise prohibit, for example,
placement of DBS receiver antennae in MDU areas under the exclusive occupancy of
a renter.
     OTHER FCC REGULATIONS.  In addition to the FCC regulations noted above,
there are other FCC regulations covering such areas as equal employment
opportunity, subscriber privacy, programming practices (including, among other
things, syndicated program exclusivity, network program nonduplication, local
sports blackouts, indecent programming, lottery programming, political
programming, sponsorship identification, children's programming advertisements,
and closed captioning), registration of cable systems and facilities licensing,
maintenance of various records and public inspection files, aeronautical
frequency usage, lockbox availability, antenna structure notification, tower
marking and lighting, consumer protection and customer service standards,
technical standards, consumer electronics equipment compatibility and Emergency
Alert Systems. The FCC recently ruled that cable customers must be allowed to
purchase cable converters from third parties and established a multi-year
phase-in during which security functions (which would remain in the operator's
exclusive control) would be unbundled from basic converter functions (which
could then be satisfied by third party vendors). The FCC has the authority to
enforce its regulations through the imposition of substantial fines, the
issuance of cease and desist orders and/or the imposition of other
administrative sanctions, such as the revocation of FCC licenses needed to
operate certain transmission facilities used in connection with cable
     COPYRIGHT.  Cable television systems are subject to federal copyright
licensing covering carriage of television and radio broadcast signals. In
exchange for filing certain reports and contributing a percentage of their
revenues to a federal copyright royalty pool (that varies depending on the size
of the system, the number of distant broadcast television signals carried, and
the location of the cable system), cable operators can obtain blanket permission
to retransmit copyrighted material included in broadcast signals. The possible