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OVERVIEW

1. The TPT proposal is ambiguous and invites defi

dispute: is internally illogical and perhaps disFutury: and if implemented, would be an expensive admin

OVERVIEW

Eu burden,

1. The language of the proposal employs terms us "dastast signal,' 'copyright qualifying broadcast 4.2,' and 'signals... not required to be retransmitted," mit eich are straightforwardly applicable, especially en the context of the FCC's complex rules on signal car*** Pren 1! these terms were precisely defined, the FCC

.: bave to undertake laborious file-by-file deter

sa to produce an accurate system-by-system compilation tempat unt qualifying broadcast signals."

.

b. The essence of the TPT proposal is that te bilities apply only to "non-network programming tocent stations." (Emphasis added.) Nevertheless, the and uses as the factor by which cable system revenues

ed for copyright purposes, the ratio of non-network e expenses to total broadcast revenues (arriving at a

of percent) rather than non-network broadcast reve*** Steerwork revenues net of commissions and discounts. Se ... kable summarizes the relevant ratios, based upon

osatcast lisancial data, that would be calculated using et des measures of revenue.

nera

viii

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