Over the past several years, major content owners and Internet Service Providers (ISPs) have come together to try to find a supportive and customer-friendly way to educate Internet users about lawful access to and use of copyrighted online content.  The effort led to the creation of the Center for Copyright Information (CCI) whose members include the Motion Picture Association of America (MPAA), the Recording Industry Association of America (RIAA) and some independent producers in their fields, as well as five major ISPs including Comcast, Verizon, Time Warner Cable, Cablevision and AT&T.  Alan Lewine, from Comcast Cable’s Legal Department, has played an instrumental role for us and served on the Executive Board for the CCI from its inception until launch. 

The CCI, and each of its members, have launched a new program called the Copyright Alert System (CAS), which began rolling out this week.  This program is designed to educate consumers – ISPs’ customers and content owners’ fans – about accessing and sharing copyrighted content online, like music, TV shows and movies. 

A few key points:  First, we expect the vast majority of our customers will never receive any Copyright Alerts; however, we believe that informed awareness about copyrights will help our customers make knowledgeable choices about using copyrighted content online.  Second, termination of a customer’s Internet service is not part of the CAS.  Third, our customers’ privacy is extremely important to us, and we worked closely with the CCI, and all of the other ISPs, to ensure the CAS was designed so that content owners will not have access to any customer’s personal information. 

Starting today, Comcast will begin to implement a six-step approach designed to notify and educate customers about allegations of copyright infringement occurring over their Internet service.  These progressive alerts will start out as informational and then evolve into "mitigation alerts" that require customers to call a Comcast representative to review educational information about copyright and acknowledge that they have understood it.Below is an outline of our plan.  All alerts will be sent by both email and an in-browser alert. 

  • Alerts 1 & 2: Information-focused alerts will provide customers with details about the alleged infringement.  Customers will be able to click on and dismiss the first in-browser notice by themselves.  For the second alert, any household member with a comcast.net user ID will have to log in to acknowledge and remove the in-browser alert.

  • Alerts 3 & 4: Warning-focused alerts make the language about the repeated allegations of copyright infringement more pronounced and urgent.  The household’s primary account holder must acknowledge receipt of these alerts by logging in to his or her Comcast account.

  • Alerts 5 & 6: Mitigation-focused alerts are aimed at engaging the customer in addressing the repeated alleged infringements by providing the customer with a 14-day window to submit an appeal to the American Arbitration Association (AAA). If the customer believes the alerts were served in error, the customer can file for an independent review. If the customer does not file the appeal, after 14 days a mitigation alert is applied in the form of a persistent in-browser alert that requires a customer to call our Comcast Security Assurance (CSA) team.  The CSA team provides further education and information about copyright infringement and only they have the ability to remove the in-browser alert from the customer’s web browser. If an appeal is filed, then the transmission of alerts is suspended until the review is complete. If the appeal prevails, then the alert history is reset, and all previous alerts are removed. If the appeal does not prevail, the mitigation alert is applied to the customer’s service, and a call is required to CSA.

For more information on the way that Comcast is implementing the CAS, please visit http://www.comcast.com/copyrightalerts. 

For more information on the CCI and the copyright alerts system generally, please visit: http://www.copyrightinformation.org/.