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22 March 2007


[Federal Register: March 21, 2007 (Volume 72, Number 54)]

[Notices]               

[Page 13286-13288]

From the Federal Register Online via GPO Access [wais.access.gpo.gov]

[DOCID:fr21mr07-60]                         





[[Page 13286]]



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FEDERAL TRADE COMMISSION



[File No. 062 3019]



 

Sony BMG Music Entertainment; Analysis of Proposed Consent Order 

To Aid Public Comment



AGENCY: Federal Trade Commission.



ACTION: Proposed consent agreement.



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SUMMARY: The consent agreement in this matter settles alleged 

violations of federal law prohibiting unfair or deceptive acts or 

practices or unfair methods of competition. The attached Analysis to 

Aid Public Comment describes both the allegations in the draft 

complaint and the terms of the consent order--embodied in the consent 

agreement--that would settle these allegations.



DATES: Comments in response to this notice must be received on or 

before March 23, 2007.



ADDRESSES: Interested parties are invited to submit written comments. 

Comments should refer to ``Sony BMG Music, File No. 062 3019,'' to 

facilitate the organization of comments. A comment filed in paper form 

should include this reference both in the text and on the envelope, and 

should be mailed or delivered to the following address: Federal Trade 

Commission, Office of the Secretary, Room 135-H, 600 Pennsylvania 

Avenue, NW., Washington, DC 20580. Comments containing confidential 

material must be filed in paper form, must be clearly labeled 

``Confidential,'' and must comply with Commission Rule 4.9(c). 16 CFR 

4.9(c) (2005).\1\ The FTC is requesting that any comment filed in paper 

form be sent by courier or overnight service, if possible, because U.S. 

postal mail in the Washington area and at the Commission is subject to 

delay due to heightened security precautions. Comments that do not 

contain any nonpublic information may instead be filed in electronic 

form as part of or as an attachment to e-mail messages directed to the 

following e-mail box: consentagreement@ftc.gov.

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    \1\ The comment must be accompanied by an explicit request for 

confidential treatment, including the factual and legal basis for 

the request, and must identify the specific portions of the comment 

to be withheld from the public record. The request will be granted 

or denied by the Commission's General Counsel, consistent with 

applicable law and the public interest. See Commission Rule 4.9(c), 

16 CFR 4.9(c).

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    The FTC Act and other laws the Commission administers permit the 

collection of public comments to consider and use in this proceeding as 

appropriate. All timely and responsive public comments, whether filed 

in paper or electronic form, will be considered by the Commission, and 

will be available to the public on the FTC Web site, to the extent 

practicable, at http://www.ftc.gov. As a matter of discretion, the FTC 



makes every effort to remove home contact information for individuals 

from the public comments it receives before placing those comments on 

the FTC Web site. More information, including routine uses permitted by 

the Privacy Act, may be found in the FTC's privacy policy, at http://www.ftc.gov/ftc/privacy.htm

.





FOR FURTHER INFORMATION CONTACT: Matthew Daynard (202/326-3291), Bureau 

of Consumer Protection, 600 Pennsylvania Avenue, NW., Washington, DC 

20580.



SUPPLEMENTARY INFORMATION: Pursuant to section 6(f) of the Federal 

Trade Commission Act, 38 Stat. 721, 15 U.S.C. 46(f), and Sec.  2.34 of 

the Commission Rules of Practice, 16 CFR 2.34, notice is hereby given 

that the above-captioned consent agreement containing a consent order 

to cease and desist, having been filed with and accepted, subject to 

final approval, by the Commission, has been placed on the public record 

for a period of thirty (30) days. The following Analysis to Aid Public 

Comment describes the terms of the consent agreement, and the 

allegations in the complaint. An electronic copy of the full text of 

the consent agreement package can be obtained from the FTC Home Page 

(for January 30, 2007), on the World Wide Web, at http://www.ftc.gov/os/2007/01/index.htm.

 A paper copy can be obtained from the FTC Public 



Reference Room, Room 130-H, 600 Pennsylvania Avenue, NW., Washington, 

DC 20580, either in person or by calling (202) 326-2222.

    Public comments are invited, and may be filed with the Commission 

in either paper or electronic form. All comments should be filed as 

prescribed in the ADDRESSES section above, and must be received on or 

before the date specified in the DATES section.



Analysis of Agreement Containing Consent Order To Aid Public Comment



    The Federal Trade Commission has accepted, subject to final 

approval, an agreement containing a consent order from Sony BMG Music 

Entertainment (``Sony BMG'' or ``respondent'').

    The proposed consent order has been placed on the public record for 

thirty (30) days for receipt of comments by interested persons. 

Comments received during this period will become part of the public 

record. After thirty (30) days, the Commission will again review the 

agreement and the comments received, and will decide whether it should 

withdraw from the agreement or make final the agreement's proposed 

order.

    This matter involves respondent's use of content protection 

software, also known as Digital Rights Management (DRM) software, 

embedded on its music CDs and the use of a proprietary media player on 

many of these CDs that must be used to listen to them. When played on a 

Windows-based computer, Sony BMG's DRM software is installed on 

consumers' computers and restricts the use of the audio files and other 

digital material on the CDs. In addition, the ``XCP'' and ``MediaMax 

5.0'' versions of respondent's DRM software create security 

vulnerabilities on consumers' computers, and, when consumers' computers 

are connected to the Internet, the media player monitors users' 

listening habits and sends back relevant advertisements.

    According to the FTC complaint, Sony BMG engaged in unfair and 

deceptive practices in distributing its content-protected CDs. The 

complaint contains two unfairness charges. The first count alleges that 

it was unfair for respondent to cause its DRM software, which exposed 

consumers' to security risks, to be installed on consumers' computers 

without adequate notification and consent. As alleged in the complaint, 

respondent's ``XCP'' DRM software contains cloaking technology that 

hides the existence of the software from the Windows Operating System. 

The cloaking technology creates a security vulnerability because 

malicious software that enters users' computers can exploit the 

cloaking technology to conceal itself from the computers' security 

software. In addition, respondent's ``MediaMax 5.0'' DRM software 

creates a ``privilege escalation vulnerability'' that could allow third 

parties who gain physical access to the computer but who have lower-

privilege access to exercise full control over a consumer's computer 

running the Windows Operating System. Consumers could not reasonably 

prevent this injury because they did not know of the DRM software's 

existence or its harmful effects. The complaint therefore alleges that 

respondent's practices caused, or were likely to cause, substantial 

consumer injury that consumers could not reasonably avoid and which was 

not outweighed by countervailing benefits to consumers or competition.

    The complaint further alleges as unfair respondent's practices in 

causing its DRM software that made computers insecure to be installed 

without providing a reasonable means to locate and/or remove it. As 

alleged in the



[[Page 13287]]



complaint, Sony BMG's use of cloaking technology and the failure of the 

``XCP'' and ``MediaMax 5.0'' software to appear in the Windows ``Add/

Remove'' utility hid the existence of the software from consumers and 

their operating systems. In addition, respondent failed to make an 

uninstall tool readily available. The complaint alleges that, as a 

result, consumers incurred substantial costs in locating and removing 

the DRM software from their computers and in stopping its harmful 

effects. Thus, the complaint alleges that respondent's practices in 

failing to provide a reasonable means to locate and remove its DRM 

software caused, or were likely to cause, substantial consumer injury 

that could not be reasonably avoided by consumers and did not provide 

countervailing benefits to consumers or competition.

    In addition, the complaint challenges, as deceptive, Sony BMG's 

failure to disclose adequately that its music CDs install onto 

computers software that materially limits their use by limiting the 

number of disc-to-disc copies that consumers can make, and by 

restricting consumers'' ability to transfer to and play music on 

digital playback devices other than Sony BMG and Microsoft devices. 

Finally, the proposed complaint alleges as deceptive respondent's 

undisclosed inclusion of its media player, which monitors the artists 

that consumers listen to on their computers and displays advertising.

    The proposed consent order contains provisions designed to enhance 

and expand upon respondent's programs to provide refunds to consumers 

and includes injunctive relief to protect against future consumer 

injury from similar acts and practices.

    Part I of the proposed order requires Sony BMG to include on the 

front cover of the packaging for any content-protected CD a clear and 

prominent disclosure that important consumer information regarding 

limits on copying and use can be found on the rear of the product 

packaging. This provision also requires respondent to disclose more 

fully on the back cover that the CD will install software, if that is 

the case; has copying limits; and can only be used on certain playback 

devices. Part II bars Sony BMG from installing content protection 

software from a CD without consumers' authorization. Specifically, 

before such software can be installed, respondent must disclose on the 

consumer's computer screen the information required by Part I and the 

consumer must have signaled her consent by clicking on a properly 

labeled button or taking a similar action. Further, in cases where Sony 

BMG conditions consumers' use of its CDs on their installing content 

protection software onto their computers, Part III requires that 

respondent clearly and prominently disclose this requirement on the 

product packaging.

    Regarding ``enhanced connectivity'' CDs (CDs containing 

respondent's proprietary media player that transmits non-personally 

identifiable information from consumers' computers to respondent and 

displays promotional messages on consumers' computers), Part IV of the 

proposed order, which applies to enhanced connectivity CDs that Sony 

BMG sells prior to the date that this order becomes final, prohibits 

respondent from using any information it collects through enhanced 

connectivity CDs for any marketing purpose and requires respondent to 

destroy such information within three days of receipt. Part IV also 

prohibits Sony BMG from using any such information to deliver 

advertising or marketing messages. Part V, which applies to enhanced 

connectivity CDs that Sony BMG sells after the order becomes final, 

requires that if, to use a CD on a computer, consumers must agree to 

have information collected about them, Sony BMG must disclose this 

condition clearly and prominently on the product packaging. Further, 

Part V prohibits Sony BMG from collecting any information using its 

enhanced connectivity CDs, unless it first discloses that the CD will 

collect information and/or send back advertising to the computer and 

obtains consumers' consent to do so.

    In connection with the marketing, advertising, or distributing of 

any CD, Part VI prohibits Sony BMG from installing content protection 

software that prevents consumers from readily locating or removing the 

software from the computer. This prohibition includes, but is not 

limited to, hiding, cloaking, using misleading or random names for, and 

misrepresenting the purpose or effects of any file, folder, or 

directory associated with such software.

    Part VII requires that respondent provide a reasonable and 

effective means to uninstall its content protection software. Part VII 

also provides that Sony BMG is not required to uninstall the 

``counter'' file of its software that determines whether the consumer 

has exceeded the permitted number of copies on the computer, as long as 

respondent discloses on consumers' computer screens, prior to 

installing the content protection software, that this file will not be 

removed and the file does not impair, hinder, or otherwise adversely 

affect the computer's operation. Part VII further requires that Sony 

BMG, for a period of two years from the date that the order becomes 

final, continue to provide free uninstall tools and patches for XCP and 

MediaMax 5.0 and to disclose the existence of these tools on its Web 

site. In addition, Part VII of the order requires that Sony BMG notify 

consumers of the XCP and MediaMax 5.0 vulnerabilities and how to fix 

their computers, by extending its existing program of purchasing key 

words on search engines to one year after the date the order becomes 

final, and also by publishing a notice through its Web site.

    Part VIII of the proposed order makes clear that all purchasers, 

prior to December 31, 2006, of XCP and MediaMax CDs are eligible to 

participate in its ongoing compensation program. Part VIII also 

requires Sony BMG to extend the period for accepting exchanges to six 

months after December 31, 2006. Further, Part VIII of the order 

requires that Sony BMG reimburse consumers up to $150 of their costs to 

repair computer damage resulting from their attempts to remove the XCP 

content protection software before respondent made an uninstall tool 

readily available. Finally, Part VIII requires Sony BMG to publish 

notices on its Web site informing consumers about the extended period 

for exchanging CDs and the ``repair reimbursement'' program.

    Part IX of the proposed order requires that, before selling 

MediaMax CDs from its inventory, Sony BMG must make applicable 

disclosures about copying and use restrictions on the product 

packaging. In the case of MediaMax 5.0 CDs, Sony BMG also must disclose 

on the packaging that, if used on a computer, these CDs will create 

security vulnerabilities that consumers can eliminate with a patch that 

they can download, free of charge, from respondent's Web site, and 

establish an Internet connection through which Sony BMG will collect 

information from, and send back advertising to, the computer. Also, 

with respect to MediaMax 5.0 CDs that Sony BMG has sold to retailers, 

Part IX requires that it offer retailers the same financial incentives 

to return these CDs as those for XCP CDs. Further, Sony BMG must offer 

these incentives for two years after the date the order becomes final.

    Parts X through XIII of the proposed order are record-keeping and 

reporting provisions. Part XIV provides that the order will terminate 

after twenty (20) years under certain circumstances.

    The purpose of this analysis is to facilitate public comment on the 

proposed order, and it is not intended to constitute an official 

interpretation of



[[Page 13288]]



the agreement and proposed order or to modify in any way their terms.



    By direction of the Commission.

Donald S. Clark,

Secretary.

 [FR Doc. 07-1403 Filed 3-20-07; 8:45 am]



BILLING CODE 6750-01-P