New FCC regulations require video programming that is captioned on TV to also be captioned when distributed on the Internet. In this webinar, Netflix and Entertainment Merchants Association discuss the new and upcoming legal requirements, best practices, and standards for closed captioning entertainment and media content. The topics covered are: - FCC regulations for TV and film content distributed on the Internet - Which entities and types of programming are affected? Which are exempt? - How to petition for an exemption? - Standards for captioning and subtitling - FCC’s guidance on caption quality, video clips, and end-user control - Best practices for caption formats, certifications, frame rate, styling, and onscreen placement Panelists Dae Kim Video Engineer | Netflix Sean Bersell VP, Public Affairs | Entertainment Merchants Assoc. Josh Miller (Moderator) Co-Founder | 3Play Media Claudia Rocha Operations Manager | 3Play Media Tole Khesin (Moderator) VP, Marketing | 3Play Media

1. Closed Captioning
Best Practices and Legal
Requirements Digital Distribution
of TV & Film
April 17, 2014
Sean Bersell
Entertainment
Merchants Assoc.
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Claudia Rocha
3Play Media
Josh Miller
3Play Media
Dae Kim
Netflix

2. Agenda
‣ Captioning overview (Josh Miller)
‣ Legal update (Josh Miller)
‣ EMA best practices (Sean Bersell)
– Certifications, formats, frame rates
‣ 3Play Media best practices (Claudia Rocha)
– Standards for transcription + captioning
‣ Netflix best practices (Dae Kim)
– Styling, onscreen placement, delivery, encoding
‣ Industry trends (Dae Kim)
‣ Q&A
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3. What Are Closed Captions?
‣ Text that has been time-synchronized with the
media
‣ Captions convey all spoken content as well as
relevant sound effects
‣ Originated in the early 1980s from an FCC
mandate for broadcast TV
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4. Closed Captioning Terminology
Terminology
‣ Captioning vs. Transcription
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5. Closed Captioning Terminology
Terminology
‣ Captioning vs. Transcription
‣ Captioning vs. Subtitling
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6. Closed Captioning Terminology
Terminology
‣ Captioning vs. Transcription
‣ Captioning vs. Subtitling
‣ Closed vs. Open Captioning
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7. Closed Captioning Terminology
Terminology
‣ Captioning vs. Transcription
‣ Captioning vs. Subtitling
‣ Closed vs. Open Captioning
‣ Post Production vs. Real-Time
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8. Caption Formats
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Format Type Use Cases
SCC Broadcast, iOS, web media
SMPTE-TT Web media
CAP Broadcast
EBU.STL PAL Broadcast (Europe)
SRT YouTube and web media
DFXP Flash players
WebVTT Emerging HTML5
SAMI Windows Media
QT QuickTime
STL DVD encoding
CPT.XML Captionate
RT Real Media
SRT Example
01:02:53:14 94ae 94ae 9420 9420
01:02:55:14 942c 942c
01:03:27:29 94ae 94ae 9420 9420 94f2
SCC Example

9. Benefits
‣ Accessibility for deaf and hard of hearing
‣ For ESL viewers
‣ Flexibility to view in noise-sensitive environments
‣ Search
‣ Navigation, better UX
‣ SEO/discoverability
‣ Used as source for translation
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10. Legal Update
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CVAA
‣ Captions required for all Internet content that
aired on TV with captions
‣ Does not yet apply to video clips
‣ 13 Exemptions
ADA
‣ Title II: public entities
‣ Title III: commercial entities “places of public
accommodation”
‣ Recent case law:
– NAD v. Netflix, GLAD v. Time Warner

11. CVAA Timeline
‣ Phased In: All prerecorded programming that is
not edited for Internet distribution
‣ Phased In: Live & near-live programming
originally broadcast on television.
‣ Phased In: Prerecorded programming that is
edited for Internet distribution.
‣ Phased In : Archival programming (45 days)
‣ Mar 30, 2015: Archival programming (30 days)
‣ Mar 30, 2016: Archival programming (15 days)
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12. FCC Standards for Caption Quality
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‣ Caption accuracy
– Must match spoken words to fullest extent possible and include verbal
information
– Allows some leniency for live captioning
‣ Caption synchronization
– Must coincide with their spoken words and sounds to the greatest extent
possible
‣ Program completeness
– Captions must run from the beginning to the end of the program
‣ Onscreen caption placement
– Captions should not block other important visual content

13. FCC Guidelines for User Control
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‣ Took affect January 1, 2014
‣ Only applies to online full-length programming that previously appeared
with captions on television in the U.S.
‣ VPDs must comply with advanced closed captioning standards CEA-708
‣ End user control of font type, size, background color, opacity, character
edge style

14. FCC Exemptions for Closed
Captioning
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‣ Economically burdensome exemption
– Requires petition
‣ Self-implementing exemption
– Programming is in a language other than English or Spanish
– Programming is primarily textual
– Programming is distributed between 2 a.m. and 6 a.m.
– Interstitials, promotional and public service announcements (up to 10 mins)
– EBS (Educational Broadband Service) programming
– Locally produced and distributed non-news programming with no repeat value
– Programming on new networks for the first four years
– Primarily non-vocal musical programming
– Captioning expense in excess of 2% of gross revenues
– Revenues under $3,000,000
– Locally produced educational programming
– Programming is subject to contractual captioning restrictions

15. 15
PRESENTATION BY SEAN BERSELL

16. Transcription Standards
‣ Spelling should be at least 99% accurate.
‣ When multiple speakers are present, sometimes it is helpful to identify
who is speaking, especially when the video does not make this clear.
‣ Both upper and lowercase letters should be used.
‣ Non-speech sounds like [MUSIC PLAYING] or [LAUGHTER] should be
added in square brackets.
‣ Sound effects that are pertinent to the plot should be included.
‣ Punctuation should be used for maximum clarity.
‣ Captions can be used to preserve and identify slang or accents
(preferential)
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17. Captioning Standards
‣ Font style should be non-serif, such as Helvetica medium.
‣ Each caption frame should hold 1 to 3 lines of text onscreen at a time
‣ Each line should not exceed 32 characters.
‣ Minimum viewable duration of 1 second.
‣ Extended sound effects (like [MUSIC]) should drop off the screen after
4 to 5 seconds
‣ Each caption frame should be replaced by another caption (unless
there’s a long period of silence).
‣ All caption frames should be precisely time-synched to the audio.
‣ A caption frame should be repositioned if it obscures onscreen text or
other essential visual elements.
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18. PRESENTATION BY DAE KIM
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19. QUESTIONS?
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Resources
EMA Best Practices on Closed Captioning:
http://www.entmerch.org/digitalema/committeescouncils/closed-captioning-committee/
CVAA Captioning Requirements: http://info.3playmedia.com/wp-cvaa.html
How the ADA Impacts Captioning: http://info.3playmedia.com/wp-ada.html
FCC Ruling 2/20/2014: http://www.fcc.gov/document/closed-captioning-quality-report-and-order-
declaratory-ruling-fnprm