Viacom International Inc. v. Federal Communications Commission

672 F.2d 1034, 50 Rad. Reg. 2d (P & F) 1641, 8 Media L. Rep. (BNA) 2005, 1982 U.S. App. LEXIS 21936
CourtCourt of Appeals for the Second Circuit
DecidedFebruary 9, 1982
Docket227
StatusPublished
Cited by1 cases

This text of 672 F.2d 1034 (Viacom International Inc. v. Federal Communications Commission) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Viacom International Inc. v. Federal Communications Commission, 672 F.2d 1034, 50 Rad. Reg. 2d (P & F) 1641, 8 Media L. Rep. (BNA) 2005, 1982 U.S. App. LEXIS 21936 (2d Cir. 1982).

Opinion

672 F.2d 1034

8 Media L. Rep. 2005

VIACOM INTERNATIONAL INC., Petitioner,
v.
FEDERAL COMMUNICATIONS COMMISSION and United States of
America, Respondents,
CBS Inc., American Broadcasting Companies, Inc., National
Broadcasting Company, Inc., RCA Corporation,
Overseas Tele Video Corporation, Intervenors.

No. 227, Docket 81-4119.

United States Court of Appeals,
Second Circuit.

Argued Nov. 5, 1981.
Decided Feb. 9, 1982.

Daniel M. Armstrong, Associate Gen. Counsel, Washington, D. C. (Stephen A. Sharp, Gen. Counsel, C. Grey Pash, Jr., Lisa B. Margolis, Washington, D. C., of counsel), for respondent F.C.C.

George H. Shapiro, Washington, D. C. (Marilyn D. Sonn, Arent, Fox, Kintner, Plotkin & Kahn, Washington, D. C., of counsel), for petitioner.

Scott H. Robb, New York City, for intervenor Overseas Tele Video Corp.

Timothy Dyk, Washington, D. C. (J. Roger Wollenberg, Thomas W. White, Wilmer, Cutler & Pickering, Joseph DeFranco, Mark W. Johnson, Washington, D. C., of counsel), for intervenor CBS Inc.

James A. McKenna, Jr., Washington, D. C. (Thomas N. Frohock, Dennis P. Corbett, McKenna, Wilkinson & Kittner, Washington, D. C., of counsel), for intervenor American Broadcasting Co.

Bernard G. Segal, Philadelphia, Pa. (Jerome J. Shestack, Schnader, Harrison, Segal & Lewis, Peter S. Greenberg, Deena Jo Schneider, Philadelphia, Pa., of counsel), for intervenors National Broadcasting Co. and RCA Corp.

Before WATERMAN, OAKES and MESKILL, Circuit Judges.

OAKES, Circuit Judge:

This administrative law case, occurring in an era of deregulation, presents several interesting questions concerning regulations of the television industry which were several years in the adopting and which have been in effect for a decade. The three national television networks obtained from the Federal Communications Commission (FCC) on June 23, 1981 a declaratory ruling that the "financial interest" rule, 47 C.F.R. § 73.658(j)(1)(ii), does not prohibit them from acquiring rights to "nonbroadcast" uses of independently produced television programs-e.g., on cable television, video cassettes, and video discs. Memorandum Opinion and Order, Request by CBS Inc., for a Declaratory Ruling, 87 F.C.C.2d 30 (1981). Viacom International, Inc. (Viacom), joined by intervenor Overseas Tele Video Corporation (Overseas), petitions for review of that FCC ruling. The four arguments they make on review are (1) that the ruling was not an interpretation but an amendment of the financial-interest rule, requiring the rule-making procedures of the Administrative Procedure Act; (2) that the Commission improperly relied on an internal staff memorandum; (3) that the Commission improperly failed to disclose publicly the content of ex parte communications, denying interested parties an opportunity to respond; and (4) that in any event the Commission's ruling was arbitrary, capricious, and an abuse of discretion. While the case is not without difficulty, we believe the Commission acted within its statutory and regulatory powers in compliance with the Administrative Procedure Act and did not abuse its discretion. We therefore deny the petition to review.

BACKGROUND

I. The Regulatory History

The financial-interest rule was one of three rules proposed by the FCC on March 22, 19651 after a six-year study of the lack of competitive sources of television programming.2 After lengthy proceedings with comments from many parties, including a report prepared for the networks by Arthur D. Little, Inc. (Little Report) setting forth detailed data on industry program practices, the Commission adopted the three rules on May 4, 1970:3 the "syndication" rule eliminating networks from domestic syndication and from foreign distribution of independently produced programs;4 the "financial interest" rule prohibiting networks from acquiring additional rights to independently produced programs other than a license for network exhibition;5 and the "prime time access" rule limiting the time allotted network programs during prime time.6

The three rules, the parties agree, were intended to operate together to promote diversity and competition in television programming. Each rule was targeted at a separate aspect of network domination of the television industry. The prime-time-access rule, note 6 supra, prohibited network-affiliated television stations in the fifty largest television markets from devoting more than three of the four hours of evening prime time to network programs or programs formerly on network television. By ensuring that such stations had at least one hour available each night to broadcast nonnetwork programs, the Commission sought to give independent program producers, including local stations, greater access to prime-time television.

The syndication rule, note 4 supra, prohibited the networks from distributing (i.e., syndicating) television programs to domestic television stations for nonnetwork exhibition, distributing programs of which the network was not the sole producer for exhibition outside the United States, or participating in profit-sharing arrangements involving those distribution activities. Network programming is typically broadcast simultaneously by network-affiliated stations which are compensated by the network for presenting the programs. Nonnetwork or syndicated programming, by contrast, is generally licensed to individual stations which pay the syndicator for rights to independent exhibition. The syndication rule was imposed to keep the networks out of the syndication business, and thus to increase opportunities for independent producers to provide programs for nonnetwork exhibition.

The financial-interest rule prohibited networks from acquiring subsidiary rights or profit shares in independently produced programs. As finally adopted, the financial-interest rule provides in pertinent part that no network shall

acquire any financial or proprietary right or interest in the exhibition, distribution, or other commercial use of any television program produced wholly or in part by a person other than such television network, except the license or other exclusive right to network exhibition within the United States and on foreign stations regularly included within such television network....

47 C.F.R. § 73.658(j)(1)(ii). In the Report and Order announcing the rules' adoption, the Commission stated that the financial-interest rule would limit the networks' potential for competitive restraint by limiting the advantage they would otherwise have in the syndication market from their existing relations with affiliates. Report and Order, supra note 3, 23 F.C.C.2d at 398.

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672 F.2d 1034, 50 Rad. Reg. 2d (P & F) 1641, 8 Media L. Rep. (BNA) 2005, 1982 U.S. App. LEXIS 21936, Counsel Stack Legal Research, https://law.counselstack.com/opinion/viacom-international-inc-v-federal-communications-commission-ca2-1982.