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					         SIDSA                                  ER-0928/1/98




STATEMENT                           SIDSA
SIDSA´s comments to the             Torres Quevedo, 1

Consultation on Interoperability
                                    P.T.M.
                                    28760 Tres Cantos
of Interactive Digital Television   SPAIN
                                    www.sidsa.com
                                    salesinfo@sidsa.com
Date: April 29th, 2004
                                    TF: +34 91 803 50 52
Attention: European Commission
                                    FX: +34 91 803 95 57




Email:
TEL:
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                                                                                   th
   SIDSA                  SIDSA´s Comments on Interoperability of iDTV      April 29 , 2004



Introduction

This paper has been written by SIDSA in consideration of the invitation by the European
Commission launched on 18.3.2004 (doc SEC(2004)346) related to the interoperability of
the digital interactive television services.

SIDSA is pleased to respectfully provide comments to the European Commission on its
vision and experiences in the manufacturing of electronic components and equipment for
interactive digital television services, particularly when conditional access technologies
are used.

SIDSA
SIDSA (Semiconductor Design Solutions), a privately owned company founded in 1992,
is today one of Europe’s established ASIC Design Centres and provider of multimedia
products. SIDSA is a fully approved ARM® design house under the ATAP scheme and
currently employ 52 highly qualified professionals.

SIDSA provides solutions from specifications to back-end ASIC design covering all steps
in ASIC methodology, including emulation. Its entire design process is ISO9001 certified.
SIDSA markets its own ARM7 and ARM9 SOC (System-on-Chip) emulation board known
as CARMeN for ASIC prototyping and software development.

The company’s DVB multimedia solutions for CI-CAM, MPEG processing and Conditional
Access are based on an ARM® based SOC (System-on-Chip) called MACtsp. To support
the customer SIDSA offers reference design platforms for all of MACtsp based multimedia
products suitable for:
       - Supporting Conditional Access systems;
       - Internet Access;
       - MPEG Home networking;
       - Datacasting;
       - Digital Television Audience metering;
       - BISS.

The SIDSA chip-set, based around MACtsp, is intended to be a relevant contribution to
foster a wide penetration of interactive digital television services, including those
implementing Conditional Access systems of several vendors, and especially orientated to
horizontally-driven business models, which seem to be particularly the digital terrestrial
television scenario. In this field, SIDSA is concerned with the lack of interoperability
reached in the development of interactive digital television services, although technology
is ready to support the pursued levels of interoperability included in the Directive 95/47.
In addition, SIDSA has also developed the necessary software to allow licensed CA
implementers to implement their CA systems onto the SIDSA chip-set and associated
hardware, aiming at offering the market attractive solutions embedding several CA
systems into a single CAM, which is the device that is strongly backed by customers.
SIDSA market success depends on the availability of suitable procedures, put in place by
CA vendors, for licensing their CA systems in accordance with EU Directives and Member
State regulations.

SIDSA´s analysis of the current situation
Since the early start of digital television in Europe, most of the services were based on
business models driven by the digital television pioneers: vertically-driven markets where
only one Conditional Access system is used in a given market. This situation was perhaps
helpful to promote the early start of services, but creates a risk for a future mature
development of digital television. Needless to say, this situation is harmful to horizontal
markets like the digital terrestrial television. There are about 5 Conditional Access

    EC                                SIDSA Statement                          Page 2 of 7
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   SIDSA                  SIDSA´s Comments on Interoperability of iDTV       April 29 , 2004


systems being used in Europe to deliver digital television through satellite, terrestrial or
cable platforms.

The advent of digital terrestrial television, more aligned to horizontal business models, is
demanding CA strategies in line with an efficient use of the Common Interface Modules
for several conditional access systems. The CAM is then converted as a simple motorway
where specific licensed cars (licensed CA software + smart card) can run in fair,
reasonable and non-discriminatory ways.

SIDSA would like to take this opportunity to also comment on the current situation of
non-transparent process from CA vendors to license to hardware manufacturers of
Conditional Access Modules. The situation in Europe is certainly irregular because the
grant of licenses of CA IPs are frequently associated to other business arrangements,
infringing in this way the spirit of the Directive 95/47.

Directives 95/47 and 98/84 of the European Parliament mandate to Intellectual Property
Right holders of conditional access systems and products, to grant licences to
manufacturers of end user equipment on the basis of equitable, fair, reasonable and non-
discriminatory conditions. In particular, these licenses, in which technical and commercial
factors are also considered, shall not be subject to conditions which prohibit, dissuade or
discourage the inclusion in the same product of a common interface allowing the
connection of different conditional access systems other than that of the holder of the
industrial property right.

The current practices of licensing procedures from CA vendors will have to be changed
moving towards an ample use of the CI possibilities and optimum use of the CAM
technology. There is a huge business potential for a CAM that supports different CA
systems, in order to simplify the operating scenario of the customer willing to have
access to several digital television services protected with different CA systems.
Therefore, more transparent procedures for licensing CA systems will have to be put in
place to ensure the compliance against the EU Directives mentioned above.

To complicate the picture a bit more, the overall broadcasting chain includes the
contribution from many players, such as:
       - Conditional Access vendor.
       - Digital TV broadcaster/Platform operator.
       - Chip-set designer/manufacturer.
       - Hardware manufacturer of Set-Top-Box.
       - Hardware manufacturer of Conditional Access Modules.
       - Software developer for Set-Top-Box and Conditional Access implementations
       - Smart Card providers (use to be the CA vendors)
       - Distributors
The business relations among the above players are multiple and diverse commercial
agreements have been put in place.

It is generally agreed that nowadays the licensing practices of CA vendors to hardware
and software manufacturers are far from being perfects concerning transparency and
non-discrimination. No clear rules have been identified on the criteria to issue such
licenses.

A strong cooperation among all players could be easily reached if a transparent process
to issue CA licenses would have been put in place, thus allowing the public identification
of who is licensed, who is not and the procedures for licensing becoming fair, equitable
and non-discriminatory.

Security

    EC                                SIDSA Statement                           Page 3 of 7
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   SIDSA                    SIDSA´s Comments on Interoperability of iDTV                  April 29 , 2004


It can be stated that the protection of a given CA system depends mainly on the
measures adopted for the specific Software of the CA and the operating strategy for the
tampering mechanism (smart card). SIDSA is committed to develop more powerful and
secure processors to support CA technology, such as the latest generation MACtsp2
technology offering the CA provider a dedicated, embedded and above all, secure
hardware platform. The MACtsp2 chip set includes a new range of security measures to
control the access to the CA software, not previously seen in CAM technology, this chip
set can also be embedded into the Receiver for those CA providers requesting security
“matching” checks between external device (CAM/Smart Card) and Receiver.

Vision of SIDSA for on interactive digital television when CAS is used
The SIDSA vision is focused on identifying technological solutions suitable to work in a
multi-functional conditional access system, assuming that there will be a number of
competing CA systems in the same markets. This approach might conflict with current
vertically integrated business models in the short term, but it seems to be a unique
viable mechanism for horizontally-driven business models, which would most likely be
the approach for Digital Terrestrial Television roll outs in most European and worldwide
markets.

Two options have been developed by the DVB to allow freedom of choice of the CA
system implementation: Simulcrypt (at platform head-end level); and Multicrypt by using
the Common Interface Module where the CA system is implemented through the
operation of a Conditional Access Module plugged into the Common Interface slot.




                       Simulcrypt vs Multicrypt
                       Head-
         1) Simulcrypt Head-End                       2) Multicrypt User Hardware


           CA1                                                 Gateway..1
                                                         CA1

           CA2                           Simulcrypt
                                                         CA2   Gateway..2
                               STB CA1                                                          CA1
                  Gateway                                                   STB/CAM CA1
                                 OR
           CA3                                                                                   CA 2
                               STB CA2                   CA3   Gateway..3 STB/CAM CA2
                                 OR
           CAn                 STB CA3                                      STB/CAM CA3          CA 3
                                 OR                      CAn
                                                               Gateway..n
                               STB CAn                                      STB/CAM CAn
                                                                                              CA n

                                             OR
                                                      Universal CAS CAM
                                                      Several Licensed CA


                                              OR
                                                      Universal CAS Embedded in STB
                                                            Several Licensed CA




The EC report on this consultation recognizes that the outcome was that Directive 95/47
required use of the common scrambling algorithm in all pay TV decoders, but did not

    EC                                     SIDSA Statement                                   Page 4 of 7
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    SIDSA                 SIDSA´s Comments on Interoperability of iDTV         April 29 , 2004


impose either simulcrypt or multicrypt, leaving the choice by implication to market
players and their business models, a position carried over to the new communications
framework. This reflected political preferences for a “market-led approach”. Moreover, a
sequence of competition cases investigated inter alia the market foreclosure risks
associated with conditional access.

The report also indicates that currently, simulcrypt is still operators’ preferred
interoperability technique, although they rarely conclude interworking agreements, as it
would diminish the exclusivity of premium content. However, the thematic channels have
used the Article 4(c) access provision to secure a presence on competing platforms,
where these have used the same delivery mechanism, thereby avoiding the demodulator
issue.

This fact requires EC intervention to re-conduct the initial spirit of the Directive by
allowing simulcrypt the same options as Multicrypt. In fact, today’s situation is that the
interoperability between digital television services when CA is used is blocked by
operators, as they do not promote Common Interface solutions and interworking through
simulcrypt has demonstrated to be almost an utopia.

SIDSA shares the views expressed in the report, although disagrees partially on the
assessment of the scenario. It is true that the initial launch of digital television services,
including interactivity, was promoted by pay-tv operators clearly embedded into a
vertical business model. According to this model, open systems are not favoured.
Therefore, operators in the vertical model have used all resorts possible to attack and
bring obstacles for the development of horizontal markets. Thus, comments associated to
security risks are frequently raised by vertical operators as artificial arguments to block
the development of competing markets for Conditional Access. It can be widely stated, to
the view of SIDSA, that the pay-tv market does not allow competition in the Conditional
Access technologies as customers become slave of the CA provider or integrated pay-tv
service operator.

Operators have never found regular mechanisms to reach interworking agreements
based on the simulcrypt concept. Cases reported belongs to very few concrete scenarios
where there use to be existing business links between operators engaged. The reason is
more than evident: the simulcrypt approach requires strong and deep agreements
between operators concerned at several levels: technical, operational, commercial, etc.,
which make these type of agreements very challenging even for well intended talks.

Common Interface is a solution
SIDSA believes that the market should allow players to decide which option they would
like to follow. In order to facilitate this free-decision process, the Commission should
review the Directive 95/47 in order to mandate the implementation of the Common
Interface. This implementation does not force operators to follow the horizontal market
approach or the mandatory development of Conditional Access Modules, but just the
facilitation that those willing to develop CAMs would not find additional obstacles, which
are currently the lack of decoders equipped with Common Interface slots. Recent studies
carried out by DVB have shown that the Common Interface would represent a cost
increase of no more than 1 or 2 % with respect to the cost of commercial decoders.
Equally, the cost of a complete typical CAM would cost the equivalent of a typical two
months pay-tv subscription, which is a negligible cost, bearing in mind the overall
business scenario. SIDSA believes there today’s technology associated to CAM is
certainly efficient and competitive to conclude on its suitability for a truly interoperable
scenario of interactive digital television services.

The implementation of Common Interface in Set-Top-Boxes does not prohibit the use of
other interoperability techniques as, for example, the ones based on the Simulcrypt
head-end interconnection. However, the deployment of STB without CI is a severe
    EC                                SIDSA Statement                             Page 5 of 7
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   SIDSA                 SIDSA´s Comments on Interoperability of iDTV      April 29 , 2004


obstacle for the implementation of the Multicrypt-based interoperability scenario. Given
the fact that Simulcrypt has demonstrated as very difficult to put in place in the real
market scenario and the fact that CI slots do represent a very marginal cost increase in a
pay-TV scenario, the use of the Common Interface should be mandated by the
Authorities.

Multiple Conditional Access scenario
The Common Interface option is also capable of providing additional benefits for
scenarios where the user does not want to change between services, but want to have
access to several CAS based services: a multi-conditional access scenario. By properly
interpreting the relevant EU Directives and their consequent implementation by Member
States, one can derive that the EU rules do not prohibit, but even promote, industry to
use the Common Interface in the most optimum manner, including the sharing of such a
resource by several conditional access systems, either by using different physical
Conditional Access Modules (which could be plugged and unplugged by the user) or using
the same CAM with the necessary licensed software tools implemented inside it to allow
the operation of the combined Set-Top-Box and CAM with several CA systems.

For obvious reasons, the implementation of an operation where the user should have to
unplug and plug the associated CAM every time he/she changes digital television
programms or services, is certainly impractical, from both the operational and
commercial points of view. Therefore, the easiest way to facilitate the operation of
several conditional access systems using the Common Interface facilities of the STB and
its associated tools is by developing the necessary hardware and software components
which would allow the effective operation of this kind of commercial implementation,
subject to proper licensing processes for the CA Software and Smart Card components.

While the Simulcrypt system has no theoretical limit on the number of different CA
systems sharing the Simulcrypt head-end, the implementation of Multicrypt approach is
severely limited because Set-Top-Boxes implement only one CI slot or, at most, two; in
this way, European markets using several CA systems could not be developed by using
only the current STB-CAM architecture (1 or 2 CI slots). Two options appear, either to
install many Common Interface slots in a single STB (completely impractical approach
due to cost implications and operational requirements) or to develop suitable solutions to
allow the use of only one Common Interface slot where a single Conditional Access
Module can be used; this CAM would hold a proper license for several CA systems.

This vision is particularly obvious and necessary in horizontal markets, such as Digital
Terrestrial Television in most of the major European markets.

Applying EU rules, which are pushing for transparent and non-discriminatory licensing
processes for CA systems to be implemented in Common Interface Modules, and
facilitating competition among CA vendors by allowing the use of multiple systems, seem
to bring a positive solution to remove technological barriers of the Multicrypt approach
and allow full competition of different CA systems and more freedom of choice for the
end users.




    EC                               SIDSA Statement                          Page 6 of 7
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   SIDSA                  SIDSA´s Comments on Interoperability of iDTV                        April 29 , 2004




                      Individual CAS vs CAS Library
                1) Single CA System Architecture                 2) SIDSA CAS Architecture


                       Single Conditional Access        CA1 CA2 CA3                    CAn
                              System,
                              System, CA1
                                        MULTICRYPT INTERFACE LEVEL
                                                                            CAS Lib
                            CI-
                            CI-STACK CA1
                                                                            CI-
                                                                            CI-STACK




                                                                                       RTOS
                             SOFTWARE
                                                                  uHAL - API


                              HARDWARE                                 MACtsp ASIC




                                                               CAS Lib      Licensed
                                                              Intelligent   CA S/W
                          Licensed                            Interface
                        CA Software                            CA S/W       Security
                                                             & CI/MPEG      IC Card
                     + Interface for CA1                      Controller     Control
                     CAM for single CAS                  CAM for Multiple CAS Systems




As seen in the figure above, the complete CA system requires the necessary hardware,
the necessary software and the tampering machine (smart card). Then, the proprietary
elements and security components of each individual CA system reside in the
combination of the specific Software components and smart card operational strategy.

SIDSA believes that standardization of CA systems is certainly not viable or necessary.
However, the current standardized interfaces (Common Interface) should exploit to its
most and its mandatory implementation should be pursued. The Common Interface
solutions:
       - does not increase the cost in an unacceptable manner;
       - allows a truly horizontal scenario where several CAS systems can share the
           same set-to-box;
       - does not interfere with the vertical model as either agreements for the subsidy
           of STB or agreements based on interworking at head-end (simulcrypt) are still
           allowed.

With respect to the CENELEC report on interoperability, SIDSA shares the views
expressed in the report and endorses the conclusions and recommendations there
contained. SIDSA comments address an additional element not covered by the CENELEC
report: the Conditional Access.

Conclusions
SIDSA greatly appreciates the opportunity presented by the Commission to comment on
the current situation of interactive digital television services. SIDSA recognizes that its
comments may be also applicable to the situation of purely broadcasting digital television
services when conditional access systems are used.



    EC                                     SIDSA Statement                                       Page 7 of 7
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   SIDSA                 SIDSA´s Comments on Interoperability of iDTV      April 29 , 2004


Here are some summary remarks about the future of the interactive digital television
services in markets where Conditional Access systems (including scenarios where
competition is promoted) are used:
       - The CA system security depends on key components of the system like HW,
          SW, Smart Card and operating strategies. More cases of hacked STBs have
          been reported than hacked CAMs. It is not true that security is compromised in
          the use of CAMs, but in the overall strategy of operators: software, smart
          card, operational procedures, etc.
       - The licensing procedures of CA IPR holders to set-top-box and CAM
          manufacturers should be fostered towards a truly transparent way and Fair,
          Reasonable and Non-Discriminatory mechanisms. It can be said that
          competition of conditional access systems in the market is far from perfect.
          Freedom of choice is certainly unduly constrained by the current practices of
          CA vendors to not license fairly to hardware manufacturers and, in particular,
          by CA vendors practices to block the real business take-up of systems based
          on CAM.
       - The implementation of the Common Interface slot should be mandatory in all
          set top boxes, as the true mechanism to ensure that the market allows the
          selection of simulcrypt or Multicrypt options. If set top boxes are not equipped
          with the CI, the options for Multicrypt implementation, as a way for true
          interoperable systems, are severely constrained.
       - Through higher transparency schemes of the CA licensing, stronger
          cooperation among all players in the business chain can be pursued.
       - New operating schemes should be promoted, like SIDSA´s vision based on the
          concept of Multi-CA systems implemented in one module, either inside the STB
          or by using the external CAM, as a practical implementation of the Multicrypt
          approach.
       - European Commission, DVB and Trade Associations should foster development
          of systems like UCAS, as of high benefit for the end user, in a manner where
          licensing procedures are well established on equitable and non-discriminatory
          terms.
       - SIDSA shares the views expressed in the CENELEC report on interoperability of
          digital interactive television services.




    EC                               SIDSA Statement                          Page 8 of 7