Loading...
HomeMy WebLinkAboutCivil Action 92-2494 Time Warner Entertainment Company LP against Federal Communications Commission and United States of America DUNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) TIME WARNER ENTERTAINMENT COMPANY, ) L.P., ) ) Plaintiff, ) ) -against- ) Civil Action 9';)_-- a L/ g y ) ) FEDERAL COMMUNICATIONS COMMISSION, ) ) and ) ) UNITED STATES OF AMERICA, ) Defendants. ) ) ) AFFIDAVIT OF E. THAYER BIGELOW STATE OF CONNECTICUT) ss: COUNTY OF FAIRFIELD ) E. Thayer Bigelow, being duly sworn, deposes and states as follows: 1. I am President and Chief Executive Officer of Time Warner Cable Programming ("TWCP"), a division of Time Warner Cable ("TWC"), which itself is an unincorporated division of Time Warner Entertainment Company, L.P. ("TWE"). I have been involved in the cable industry since 1970. Indeed, at various times I have served as President of Home Box Office, Inc. and Manhattan Cable Television. I make a this affidavit in support of TWE's motion for a preliminary injunction. 2. TWC is a cable operator with cable programming interests. The accompanying affidavit of Joseph J. Collins discusses TWC generally in its role as a cable operator and the injuries that the Cable Act will inflict on TWC and its divisions, primarily in their roles as cable operators. I will discuss TWC in its role as a programmer and the injuries that the Cable Act will inflict on TWC and its divisions, primarily in their roles as programmers. The accompanying affidavit of Jeffrey Bewkes discusses HBO, which is also an unincorporated division of TWE, and the injuries that the Cable Act will inflict on HBO, a programmer. Programming Background 3. Many cable programmers produce their own programming, devoted to such diverse subjects as news and political events, religious subjects, education; music and general entertainment. Such programming reflects its originator's distinctive approach and point of view. In addition, when they make use of programming created by others, programmers exercise substantial editorial discretion in determining what to include --and what not to include --in the programming services that they offer. Cable programmers also decide, as any speaker does, where, when, by what means, to whom and on what terms they wish to communicate the news, information and entertainment that they offer. 4. Producing new programming is a very expensive and risky endeavor. Recent programming ventures have required expenditures of as much as $75 to $100 million before achieving profitability. This is a substantial amount of money in its own right. However, combined with the unpredictability and changing tastes of the television viewing public, it is even more of an investment risk. 5. To attract carriage of new programming, programmers, including Courtroom Television Network, a cable programmer managed and partially owned by TWC, have offered exclusive licensing agreements to cable operators. Exclusive licensing agreements are crucially important in the distribution of news, information and entertainment. Each media speaker, whether a newspaper, a broadcast television station, or a cable operator, strives to differentiate itself from other sources of news, information and entertainment by entering into exclusive license agreements to ensure that the material it offers will not be duplicated by other outlets. An example of the benefits that may be derived from advocating a strong policy of exclusivity is the success of Turner Network Television ("TNT"). Time Warner Inc., an affiliate of TWE, and TWE are investors in Turner Broadcasting Co., which operates TNT, and therefore I am generally familiar with its development. It is my belief that a portion of the great success that TNT has enjoyed is due to its policy of entering into exclusive license agreements with cable operators. 6. Exclusive agreements are also valuable in spurring the development of new programming services. Such licenses assure a prospective distributor that others will not "free ride" on the distributor's efforts to promote and sell the new service. They also encourage distributors to make a greater investment in promotional and sales efforts by holding out the possibility of greater returns that exclusive distributorship of a popular product may. permit. 7. Exclusive licensing agreements are attractive to cable operators because they allow them to differentiate their programming from that of their competitors, whether they be other cable operators, broadcasters, satellite master antenna television ("SMATV") systems, multichannel, multipoint distribution systems ("MMDS") or direct broadcast satellite ("DBS") systems. Exclusive licensing agreements are attractive to programmers because they not only allow programmers to attract investors, but also to maximize their profits.. Courtroom Television Network has entered into exclusive licenses for such reasons. As the United States Department of Commerce found: "Both buyer and seller can benefit from the availability and enforceability of exclusive rights. For the buyer, exclusivity may differentiate the programming, making it more marketable. For the seller, by using exclusivity as a concept to divide the range of possible licensees into different markets, the seller can arrange a sequence of distribution that will maximize revenue from the licensing of that product through several uses." U.S. Department of Commerce, Video Program Distribution and Cable Television: Current Policy Issues and Recommendations, NTIA Report 88-233, at 109-10 (1988) (relevant pages attached hereto as Exhibit A). 8. TWC cable systems are themselves active production of original programming that is offered to local subscribers. In New York City, the Time Warner in the their New York City Cable Group recently launched a 24-hour all -news channel, called "New York 1", which offers continuous coverage of local news and events in New York City. The TWC systems located in Ithaca and Rochester, New York, also produce and offer local news programs to their subscribers. Several TWC systems also offer local news segments produced exclusively for them by others, including local broadcasters. Many of TWC's cable systems also engage in the creation and production of other original programming to some extent. The Must Carry and Retransmission Consent Provisions of the 1992 Cable Act and the PEG and. Leased Access Provisions of the 1984 Cable Act I. The Statutory Scheme A. The Must -Carry and Retransmission Consent Provisions of the 1992 Cable Act 9. Sections 4 and 5 of the 1992 Cable Act amend the Communications Act of 1934 by creating, respectively, new Sections 614 and 615 (the "must carry provisions"). Sections 614 and 615 impose upon cable operators onerous "must carry" obligations which require operators to offer to their subscribers certain commercial and noncommercial broadcast television stations, regardless of whether operators wish to carry such stations or their subscribers wish to receive them. Under Section 6 of the 1992 Cable Act, which amends Section 325 of the. Communications Act of 1934, cable operators must negotiate with commercial television stations for retransmission consent. If they choose not to, commercial television stations may elect to have their signals carried under the must carry provisions. If they make such an election, cable operators must carry these stations on the same channel on which they are broadcast over the air, unless a station requests otherwise under the statute. In addition, Section 614 prohibits the cable operator from receiving "valuable consideration" for carrying a station's signal even though the cable operator does not wish to carry the signal and even though normal negotiations might have resulted in the station paying to have its stations signal retransmitted, as television networks pay to broadcast their programming. B. The PEG Provisions of the 1984 Cable Act 10. Section 611 of the 1984 Cable Act (codified at 47 U.S.C. § 531) permits municipal franchising authorities to require the cable operators they regulate to set aside channel capacity for public, educational or governmental ("PEG") uses (the "PEG provisions"). There is no statutory limitation upon the number of PEG channels that a franchising authority may require. C. The Leased Access Provisions of the 1984 Cable Act 11. Section 612 of the 1984 Cable Act (codified at 47 U.S.C. § 532) requires cable operators to set aside a substantial portion --up to 15 percent --of their channels for lease to unaffiliated programmers (the "leased access provisions"). II. Injury As a Result of the Must Carry. PEG, and Leased Access Provisions of the Cable Acts 12. Individually and together, the must carry, retransmission consent, PEG and leased access provisions threaten especially severe and irreparable injury to Comedy Central, Courtroom Television Network and other recently developed non -premium program services in which TWE has an interest. Such services obtain revenues from license fees paid by distributors such as cable operators for the right to exhibit the programming to their subscribers and from fees paid by advertisers who sponsor programs on the service. Because license fees and advertising revenues depend upon the number of persons who are able to view the service, it is crucial to the viability of such a service that it persuade as many operators as possible to offer the service to their subscribers. 13. Since they were launched. in April and July 1991, respectively, Comedy Central has attracted approximately 22 million and Courtroom Television Network has attracted approximately 6.2 million subscribers. Each needs millions of additional subscribers to attain economic viability. By requiring cable operators to devote to must -carry broadcast stations, PEG channels and leased access programming substantial channel capacity that would otherwise be available to Comedy Central, Courtroom Television Network and/or other non -premium programming services in which TWE has an interest, the challenged legislation deprives such services of vital opportunities to gain additional distribution. By giving broadcast television stations preferred status both as to coverage and as to channel position, the must -carry provisions will also deprive such services of opportunities to gain additional advertising revenues, and they will instead divert such revenues to broadcast interests. The Standardized Terms and Conditions Provisions, Exclusive License and Vertically Integrated Service Provisions of the 1992 Cable Act I. The Statutory Scheme A. The Standardized Terms and Conditions Provisions 14. Section 19 of the 1992 Cable Act amends the Communications Act of 1934 by creating a new Section 628 (the "standardized terms and conditions provisions"). Among other things, Sections 628(b) and (c) purport to require the FCC to establish regulations to govern the licensing of programming by programmers in which a cable operator has an attributable interest. These standardized terms and conditions provisions and the regulations they require do not apply to other programmers. 15. The regulations to be promulgated by the FCC pursuant to Section 628 would deprive cable programming vendors that are affiliated with cable operators of the ability to freely determine the prices, terms and conditions on which they will disseminate their programming; would subject such prices, terms and conditions to extensive federal regulations; and could potentially require them to sell their services to cable operators and other distributors even if they do not wish to sell their services to, or offer their services to subscribers through, such persons. Neither Section 628(b) nor the regulations that the FCC is directed to promulgate apply to a satellite cable programming vendor that is unaffiliated with a cable operator. B. The Exclusive License Provisions 16. Section 628 also directs the FCC to prohibit a programmer in which any cable operator has•an attributable interest from entering into an exclusive agreement with any cable operator, except that if the programming is to be distributed to areas currently receiving cable, they may enter into such an agreement if the FCC finds that it is in the "public interest". C. The Vertically Integrated Service Provisions 17. Section 11(c) of the 1992 Cable Act amends Section 613 of the Communications Act of 1934 by adding subsection 613(f)(1). Section 613(f)(1)(B) directs the FCC to conduct a proceeding "to prescribe rules and regulations establishing reasonable limits on the number of channels on a cable system that can be occupied by a video programmer in which a cable operator has an attributable interest" (the "vertically integrated service provision"). 18. However ultimately framed by the FCC, the rules and regulations required to be promulgated under Section 613(f)(1) will limit the ability of cable operators to offer particular programming services to their subscrib- ers merely because a cable operator has an "attributable interest" in such programming service. They will also limit the ability of cable programming services in which a cable operator has an "attributable interest" to disseminate their program services to cable operators and their subscribers who would otherwise be willing and able to receive such communications. II. Injury to TWE as a Result of the Standardized Terms and Conditions Provisions, Exclusive License and Vertically Integrated Services Provisions 19. TWE is a vertically integrated programmer in that it owns both cable systems and programming services. However, many of TWE's principal competitors in the production and distribution of video programming are not vertically integrated. For example, The Disney Channel, Arts & Entertainment, CNBC, ESPN, The Nashville Network, the Playboy Channel and USA Network are all popular programming services owned by companies which, as indicated by publicly available data, do not have any corporate affiliation with any cable operator within the meaning of the Cable Act. See Cable Network Ownership Chart, Cable TV Programming (April 30, 1992) (attached hereto as Exhibit B). Such programmers will be able to compete with the program services that TWE owns or in which it or an affiliate has an interest (including Sunshine Network, Black Entertainment Television ("BET"), Turner Broadcasting System (TNT, CNN, Headline News), Comedy Central, Courtroom Television Network (managed by TWCP), the Cinemax Service, the Home Box Office Service, and E! Entertainment Television) free of the challenged restrictions and will thereby gain competitive advantages over such services, irreparably injuring TWE. 20. The vertically integrated services provisions will irreparably injure TWC (i) by creating uncertainty, pending the conclusion of the mandated FCC rulemaking, as to the extent to which cable operators, including those that do not have any corporate affiliation with TWE, may carry HBO and other TWE services simply because they are offered by a vertically integrated programmer; (ii) once FCC rules are promulgated, by limiting the ability of cable operators to continue to offer, or to add to their line-ups, the programming services offered by HBO and other TWE affiliated program services; (iii) by creating uncertainty, pending the conclusion of the mandated FCC rulemaking, as to the extent to which TWC's cable systems may do business with vertically integrated services (whether or not such services have any corporate affiliation with TWC); and (iv) once FCC rules are promulgated, by limiting the ability of TWC's cable systems to continue offering, or to add to their channel line-ups, services of vertically integrated programmers, including program services of, or affiliated with, TWE. 21. The exclusive license provisions will irreparably injure TWC. In particular, the requirement of FCC approval will impair Courtroom Television Network's ability to use exclusive licenses. In addition, the exclusive license provisions may abrogate some of Courtroom Television Network's existing contracts, all to its and TWE's irreparable injury. Rate Rectulation Provisions of the 1992 Cable Act I. The Statutory Scheme 22. Section 3 of the 1992 Cable Act amends Section 623 of the Communications Act of 1934. As amended, Section 623 submits cable operators not subject to "effective competition" to FCC and municipal regulation of the rates they may charge for their most widely subscribed to service tier, basic cable service. II. Injury toTWC as a Result of the Rate Regulation Provisions 23. During the interim period between the 1984 Cable Act deregulation and the 1992 Cable Act reregulation, cable operators could offer new programming with the expectation that they could adjust their rates to reflect the cost of that programming if necessary. This expectation resulted in a burst of creation of new programming services. Renewed rate regulation will most certainly chill the creation of new programming services and further investment in existing programming services because the ability of cable operators and programmers to profit from such expressive activities will be determined by the governments' views of what are reasonable profits rather than the open-ended potential rewards of the marketplace. Indeed, in the new Cable Act, Congress seems to have chosen to fulfill its purpose of halting broadcasters' decline in the marketplace by using regulation to cripple their cable competitors' ability to continue to create new programming and new programming formats. 24. The rate regulation provisions will also discourage cable operators from investing in new programming •for• the same reasons. Since operators face limits in their ability to recoup their investment costs, they will be reluctant to invest in new programming. This reluctance is heightened by the vertical integration provisions, which would subject cable programming services to their restrictions as soon as cable operators invest in them. Sworn to before me this `T th day of November, 1992. Notary Public State of Connecticut County of Fairfield On this 4th day of November, 1992, Elyse Egleston, the undersigned officer, personally appeared E. Thayer Bigelow, known to me to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. In witness whereof I hereunto set my hand. ELYSE S. EGLESTON Notary Public My Commission Expires Aug. 31, 1997 e r NTIA REPORT 88-233 Video Program Distribution and Cable Television: Current Policy Issues and Recommendations ANITA WALLGREN Project Manager U.S. DEPARTMENT OF COMMERCE C. William Verity, Secretary Alfred C. Sikes, Assistant Secretary for Communications and Information JUNE 1988 109 importance of exclusivity for broadcasters/ and, increasi gly, for cable networks and program distributors as well. Problems arise when technologies -are -capable of shifting programming from one geographic region to another, from one time period to another, and from one media to another. The holder of exclusive rights may find "its" program being viewed on another outlet in the same market. Usually, activities which violate contractual rights can and are enforced through lawsuits.324/ In the case of satellite and cable retransmission, or "secondary transmission" of broadcast programming, however, certain provisions in the copyright law I have precluded copyright owners and licensees from usual enforcement powers, as described more fully below. Both buyer326/ and seller327/ can Denefit from the 322/ "WTNH-TV New Haven Socks Fox With Suit Over 'Mash' Contract", Variety, Sept. 18, 1985, at 68. Communications Daily., March 4, 1988, at 6-7 [PBS trying to arrest "migration" of public TV shows to non -PTV outlets.] 222/ Communications Daily., Oct. 9, 1986, at 10; "Pay Cable Emphasizing Exclusivity in Schedules," Electronic Media, Sept. 22, 1986, at N18; "USA Aims at Ratings Increase with $30 million Program Buy," Cablevision, Aug. 4, 1986, at 16. Multichannel News, May 12, 1986, at 1; Sept. 15, 1986, at 13. 324 Exclusive rights to syndicated TV programsdo not violate antitrust laws: "Although restraint may be the 'essence' of every contract, under the rule of reason standard only those agreements that unreasonably restrain trade violate the Sherman Act." Ralph C. Wilson Industries. Inc. v. Chronicle Broadcasting, 794 F.2d 1359, 1363 (9th Cir. 1986)(citation omitted). • 325/ Under the Copyright Act of 1909, cable system retransmission of broadcast signals was not held to be a "performance." Fortnightly Corp. v. United Artists Corp., 392 U.S. 390 (1968); Teleprompter Corp. v. Columbia Broadcasting System. Inc., 415 U.S. 394 (1974). In 1976, the Congress imposed copyright liability for cable retransmissions, 17 U.S.C. 5 111 (1982 and Supp. III 1985). 326/ e.g., broadcaster, cable networks, videocassette distributor, etc. 110 availability and enforceability of exclusive rights. For the buyer, exclusivity may differentiate the programming, making it more marketable. For the seller, by using exclusivity as a concept to divide the range of possible licensees into different markets, the seller can arrange a sequence of distribution that will maximize revenue from the licensing of that product through several uses. In fully competitive markets, these benefits should be passed on to consumers. The exclusive rights concept is central to the copyright scheme established in the Constitution. Article I, Sec. 8, empowers the Congress "[t]o promote the progress of science and useful arts, by securing for limited times to authors and inventors the exclusive right to their respective writings and discoveries." 28 The. copyright to any work is composed of a bundle of exclusive rights defined by statute to include the right to reproduce the work in copies or phonorecords, to prepare derivatives, to distribute copies or phonorecords, and to control the public display or public performance of the work.329/ Most rights acquired in the video distribution fields are performance rights.330/ The Communications Act also gave enforcement power to broadcasters to control retransmissions of their signals.331/ In 1979, NTIA proposed the FCC extend this "retransmission 327/ e.g., motion picture studio, television syndicator, sports league, etc. 328/ U.S. Const. art. I, 0 8. 329/ 17 U.S.C. 4 106 (1982). 330/ The Copyright Act of 1976, Pub. L. 94-553, 90 Stat. 2541 ("the Act" or "the 1976 Act") made significant changes in the definition of "public performance", eliminating any reference to a "for profit" element. Prior to the 1976 Act, whether a use of the work was a public performance sometimes turned on whether the use was "for profit." Today performance rights must be "cleared" or acquired for any public performance of a copyrighted work (with some statutory exceptions.) 331/ ("[No] broadcasting station [shall] rebroadcast the program or any part thereof of another broadcasting station without the express authority of the originating station.") See 47 U.S.C. S 325(a) (1982). Network Amer CABLE NETWORK OWNERSHIP t Ownership Meteoric ANC Liberty Nadi' Corp. (a) Cablevision Systems NUC Reerst/AIC Video Enterprises NBC Radio City Music Mall Productfoas BET Robert Johmsan Liberty Wells Corp. (a) Time Vetoer Stockholders with Less then 51 Breve Cabl.vlsl.s Systems .NBC Clouse' Timm Warmer Cowdry Music Oprylad USA Croup W Satellite Comm. CNBC NBC Comedy Centre' Timm Warssr Simeon CNN Turner 0rosdeastlsg (b) Court TV Liberty M.d1. Corp. (a) Timm Wares: Ceblevtaloe Systems SOC C -SPAN Coble operator-supportsdl000proflt Discovery Ch. TCI Development Corp. Co' Nemeban s.0 Jobe Needrteks Disney Walt Disney Co. Incors Liberty Media Corp. (e) John S1. 11! Intent. TV American TV & Comm. (Ti.. Werner) SOD Clime Werner) Werner Cable (Tires Verger) Werner Co.r(Tine Warner) Comcast ileweksnnels 50.01 25.0 25.0 66.7 20.9 12.5 56.2 21.5 17.0 4.5 50.0 50.0 100.0 50.0 50.0 100.0 50.0 50.0 100.0 33.3 33.3 16.7 16.7 41.0 24.0 24.0 4.0 100.0 00.0 10.0 10.5 10.5 10.5 10.5 10.5 10.5 011192 Piaui Ragan Associates, owner t ormarskt El Intent. T ESPN 1131 FemllyNet los wet C.levisioa needling N... 110 UU Intni .tiomel Learning Ch. Lifetime Mind !amnion Univ. (d) Monitor Ch. Wavle Chamn.l MTr NSR/MAN Nostalgia Prem Cold. QVC Con Continrntsl United Cable N etwork founder & some otitles, employees Capital Citl.s/A1C beret Corp. International Family Intert.lssesI Liberty Media Corp. (a) Radio and Television Commission Fos 1roadeasttas Co. Cr.po Televise Termer pro.deasting (b) Thee Warner N ome !lopping Network Inc. (e) Intercontinental Television Croup TCI Dsv.lopmaat Corp. Cos NswCMans.ls. John 0endricks Capital Cities/A1C bsrst Corp. rlaoom Jones Ed.c.tlen Retwrk Fac. ionise Spae.liak Clea Joss First Merck of Christ. Scientist Viacom Viacom Viacom Officers & directors (13) Public & stockholders ender 51 Belted Video Scripps inward Liberty Media Carp Concept Time Vernet • Ino. Compiled by PRA tress °obis network Iota. (a) 10.5E 10.S 10.5 5.5 10.0 20.0 11.0 17.0 100.0 100.0 . 100.0 100.0 100.0 100.0 100.0 10.0 24.0 24.0 4.0 33.3 33.3 33.3 67.0 10.0 15.0 100.0 100.0 100.0 100.0 59.9 41.1 70.0 22.0 20.0 14.0 10.0 • (continued o.. not' peas) CABLE NETWORK OWNERSHIP (continued Network QVC QVC Fashion Ch.en.1 Showtime TNS 1171 Omar fro, P. 2) Other ILSOs under 52 Naeasa.smt 1 shareholders under 52 Liberty Media Corp. (.) Conceit Time Werner Other 190s under 52 Nasagasmat I shareholders under 52 Viacom Turner Uraadcastiag (b) Opryland USA * Own.rddp 16.02 72.0 26.0 14.0 10.0 16.0 32.0 100.0 100.0 100.0 NateorA Owner TIP Trani Ch. USA VD -1 Video Jukebox Weather Ch. Turner Droodcastivg (b) Leafs/ark Comm. NCA Paramount Viacom VJN Cenral Partners (s) N ora. Asset 1l.magamwt L iberty Media Corp. (.) Others smear S2 Lsni ark Comm. * Owrl.rablp 100.02 100.0 50.0 50.0 100.0 50.5 15.7 11.2 22.6 100.0 (a) Owreradlps Capital Croup Inc. 77.54*, John Malone 20.542. Barris Assocs. LP 12.02%, gob Magness 7.416. SCI Sas a preferred stook investment. (h) Ownership' Tad Turner 26.37%, ICJ 21.471, flies *Werner 10.61*, other 090'a 5.40*. Publics shares 21.20*, others 20.14*. (al A group of 27 executive offIcnra i directors rens 14.102. Several rift have ag.1ty stabile ceder 51. (di Janes Intl. Indirect), awns 200*. (el Partners include Rick Nlasae2s. Louis Wolfson Irl. the &lamb family and R.wCSaanals Corp. aaae/Neemck 1 oun.rehtx CAEL IVIDION STST!ffi Bravo American N ovia Classics Court TV CtIICAST QVC Network QVC P..hlon Clausal 11 Intertalsasnt TV CO2 Discovery Channel Learning Channel 11 latartain.mnt TV LANDIMAN( 00201. Travel Channel weather chilliest 50.02 25.0 16.7 14.02 14.0 10.S 24.02 244 10.5 100.02 MULTIPLE-11MM ORM Q NKA/Netwark 3 ownership OIIWAft/Natra,A 2 Ovnerahle 11s10117 ILIA 000P. Rococo Americas Mari. Clastics Court TV QVC Network QVC Fashion Chanel DIT FAN Video Jukabom Network NINCNANNELS Diawvary Charnel [earning Channel 11 11tertaiamett TV 01ITIAND Country Music TV TNN T11S WARM 90.02 Cinemax 50.0 191D 33.1 Cady Central 2.4.0 Court TV 26.0 Ll Int.rtalnm.nt 21.3 CON 17.0 Deadline News 11.2 TBS TNT DIT 24.07 QVC Network 24.0 QVC Fashion Channel 10.5 100.02 100.0 50.0 33.3 TV 31.5 10.6 16.6 19.6 10.6 17.8 10.0 10.0 50.02 100.0 NSC CDDC Bravo Americas AIN Court TV 100.02 50.0 Novi& Classics 25.0 20.0 16.7 01UWA.trorA 1 pmprahlp TCI DBVI1DIIWIT OO11. Discovery Chose! Learning Chancel CNN Wad11.s Nays 105 TNr VLACOII 1lovi. Channel NtV Nickaladeo./Hick Mita Shoatiam 011-1 Candy Central Lifetime 100.0 CAPITAL CITIOLAUC ISPO Lifetime AAR 411092 Paul Kagan Aesociat.o, Inc. Compiled by PICA from cable network data. 46.02 48.0 23.5 23.5 23.5 23.5 100.02 100.0 110.0 100.0 100.0 50_0 33.3 10.02 37.1 33.3 8 3o E 'd/C66T 'or