Douglas Crockford




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December 2004


The V-chip was a compromise brokered by the FCC between broadcasters (who wanted to show popular programs) and Congress (which was being pressured by religious groups who wanted censorship). The V-chip (also known as the Violence chip) enforces a ratings system similar to MPAA's rating system for movies. The FCC issued a Report and Order (FCC 98-36) on March 13, 1998 mandating the inclusion of content based blocking functions in Televisions beginning July 1, 1999. Since 2000, the V-chip has been required in all sets of 13 inches or greater. Many people felt that the V-chip should have been an optional technology; people who want it should buy special V-chip TVs or V-chip set top boxes.

The ratings are described at

V-chip (with different ratings codes) was used first in Canada, where French TV uses different ratings than English TV. What a country.

V-chip will receive little actual use. Most families either won't have need of it, or will find that the operational inconvenience is too great. Only a small number of homes will actually use it. "Almost everyone has it. Almost nobody uses it," says Dave Arland, a spokesman for Thomson/RCA. Researcher Amy Jordan of the University of Pennsylvania calls it a "multi-system failure." Some TV manuals have nine pages of instruction for the chip. "Ironically, the V-chip is used more as a tool to block out pressure from Congress," says Jeff Chester, executive director of the Center for Digital Democracy, a show-business watchdog group in Washington.

In analog systems, the V-chip codes are inserted into scanline 21. Line 21 is also used for closed caption information. CEA-608 is the standard for the formatting of line 21. Line 21 is not normally seen because it is in the VBI (Vertical Blanking Interval). The V-chip decodes line 21, and will block the video display if the program rating exceeds the current setting.

Digital television receivers shall react in a similar manner as analog televisions when programmed to block specific rating categories. Digital systems of course do not waste time on VBI, so instead the V-chip rating is transmitted in PSIP. This is specified in ATSC A/65B (the same document containing the Broadcast Flag's redistribution control).

The FCC's rules require that program blocking occur as soon as a program rating packet is received, that when a program is blocked the program's audio must be muted, the video must go black or be otherwise indecipherable, and program captions must be eliminated. In addition, the FCC is requiring that receivers have the capability to block programming using the age based ratings, the content based ratings, or a combination of the two, and that once a rating has been selected for blocking, a consumer will have the ability to automatically block programs with more restrictive ratings, and to override the automatic blocking selections.

The FCC said in its approval of the V-chip technology standards: "We recognize the possibility of existing patents, but we find that this does not inherently conflict with the rules adopted in this proceeding since no evidence has been presented of unreasonable royalty or licensing policies. At this time, we intend to allow the market to decide or innovate which implementation technologies will be used." This is strange because the FCC is not allowing the market to decide.


On September 7, 2004, the FCC released Report & Order 04-192. It modifies and clarifies some of the FCC's rules on DTV. It is mostly concerned with channel allocation and numbering issues. Sections 154 thru 159 are concerned with V-chip.

The FCC adopts the PSIP Specification, including RRT which implements Open V-chip. They give manufacturers 18 months to conform to the new rules.

We therefore require that broadcasters fully implement PSIP to the extent that ATSC A/65B requires. According to A/65, the PSIP mandatory tables are: Master Guide Table (MGT); Terrestrial Virtual Channel Table (TVCT); Event Information Tables (EIT-0 to EIT-3); System Time Table (STT); Rating Region Table (RRT). According to A/65, the RRT is not mandatory for the U.S. region (0x01). Transmission of the RRT is not necessary where the content advisory ratings table is fixed, as is the case now in the U.S. If the ratings system were to change, however, or an addition to the ratings system were to be adopted, broadcasters would have to transmit a new RRT in order to transmit the new or additional ratings information.

As requested by CEA, we are adopting by reference EIA-766 U.S. and Canadian Rating Region Tables (RRT). We note that the adoption of the standard will not preclude manufacturers from incorporating additional blocking standards or techniques into receivers. Therefore, additional blocking techniques that are dependent only on inputs such as the date, time of day, or television channel, may be incorporated into television receivers as manufacturers see fit.

Additionally, we are adopting our proposal to apply v-chip rules to digital television receivers with displays in the 16:9 aspect ratio that are 7.8 inches or greater in height. Furthermore, we are requiring that v-chip technology be included in all digital television receivers with integrated 4:3 displays measuring at least 13 inches diagonally. Similar to our requirements for closed caption capabilities in digital television receivers, the rules will also be applicable to DTV tuners which are sold without an associated display device.

Our existing requirement that digital television receivers react in a similar manner as analog televisions when programmed to block specific rating categories ensures that digital receivers will continue to respond to v-chip information during the phase-in period. Therefore, we believe it is reasonable to provide an 18 month transition period. After the transition period, all digital television receivers will be required to provide v-chip functions following the regulations that we adopt in this proceeding.


The FCC invited comment on its Report and Order. CEA filed a Petition for Clarification and/or Reconsideration. CEA asserts that the new FCC V-chip mandate was a "surprise", that the FCC regulation and industry standards are not specific enough for television manufacturers to build DTV receivers in a consistent manner and that the FCC should consider a clarification in the new V-chip rules. The CEA requested that the Commission clarify or amend its newly adopted rule regarding the functioning of the V-chip in digital television receivers. The CEA claims that, in its current form, the regulations are not specific enough for television manufacturers to build DTV sets in a consistent manner. I think CEA wants FCC to drop support for RRT.

The CEA also asked that the Commission examine the intellectual property issues related to the implementation of the new requirement to include an "open" V-chip in digital receivers. It requested that the Commission study this issue to ensure that the
licensing terms that Tri-Vision offers comply with the Commission's long-standing precedent that its rules not sanction a monopoly or other competitive abuse through the patent process. The CEA pointed out that the Commission has always required that patents necessary to permit receivers to be in compliance with its rules be granted: (1) on a non-exclusive basis; (2) to all responsible parties; and (3) at reasonable royalties.


Tri-Vision has responded with press releases on November 10 and November 24, met with the FCC on November 19, and filed an Opposition to CEA's Petition on November 20 in which it is claimed that the license rates on the V-Chip IP are fair and reasonable.

At issue is patent 5828402 issued on October 27, 1998: Method and apparatus for selectively blocking audio and video signals. The inventor was Tim Collings of Tri-Vision. The patent describes the Open V-Chip system which is the basis of the RRT. It allows for multiple, changeable rating schemes.

The FCC will have to respond to CEA's Petition and Tri-Vision's Opposition. Ideally, FCC will drop the manditory V-chip requirement. It lacks the political courage to do that. Instead, I expect that FCC will make Tri-Vision very wealthy.