I. Introduction.

In its initial Comments, the American Cable Association (“ACA”) put forth evidence showing the challenges that smaller cable operators face in obtaining the right to retransmit the signals of broadcasters at fair and reasonable prices, terms, and conditions. ACA files this Reply to highlight additional evidence demonstrating the broken retransmission consent marketplace. In addition, ACA underscores how programmers’ tiering and penetration requirements increase the cost of cable operators’ lowest priced tiers and reduce consumer choice. Finally, ACA adds to this record information about the public interest harms of video content providers coercing operators into accepting “closed Internet” business models.