Closed Captioning Best Practices and Legal Requirements for Digital Delivery of TV & Film


Published on

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


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

Published in: Technology, Business
1 Like
  • Be the first to comment

No Downloads
Total views
On SlideShare
From Embeds
Number of Embeds
Embeds 0
No embeds

No notes for slide

Closed Captioning Best Practices and Legal Requirements for Digital Delivery of TV & Film

  1. 1. Closed Captioning Best Practices and Legal Requirements Digital Distribution of TV & Film April 17, 2014 Sean Bersell Entertainment Merchants Assoc. 1 Claudia Rocha 3Play Media Josh Miller 3Play Media Dae Kim Netflix
  2. 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 2
  3. 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 3
  4. 4. Closed Captioning Terminology Terminology ‣ Captioning vs. Transcription 4
  5. 5. Closed Captioning Terminology Terminology ‣ Captioning vs. Transcription ‣ Captioning vs. Subtitling 5
  6. 6. Closed Captioning Terminology Terminology ‣ Captioning vs. Transcription ‣ Captioning vs. Subtitling ‣ Closed vs. Open Captioning 6
  7. 7. Closed Captioning Terminology Terminology ‣ Captioning vs. Transcription ‣ Captioning vs. Subtitling ‣ Closed vs. Open Captioning ‣ Post Production vs. Real-Time 7
  8. 8. Caption Formats 8 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. 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 9
  10. 10. Legal Update 10 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. 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) 11
  12. 12. FCC Standards for Caption Quality 12 ‣ 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. 13. FCC Guidelines for User Control 13 ‣ 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. 14. FCC Exemptions for Closed Captioning 14 ‣ 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
  16. 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) 16
  17. 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. 17
  19. 19. QUESTIONS? 19 Resources EMA Best Practices on Closed Captioning: CVAA Captioning Requirements: How the ADA Impacts Captioning: FCC Ruling 2/20/2014: declaratory-ruling-fnprm