Closed Captioning

Legal Requirements, Best Practices

and Workflows for Media &

Entertainment

November 19, 2014

Tim Sale

Dir Tech Sales

thePlatform

1

Lily Bond

Content Mgr

3Play Media

Mo Zhu

Software Engr

3Play Media

Josh Miller

VP Bus Dev

3Play Media

Agenda

‣ Intro (Lily Bond)

‣ Legal Requirements (Josh Miller)

‣ Best practices (Josh Miller)

‣ Closed captioning with thePlatform (Tim Sale)

‣ Demo of thePlatform captioning workflow (Mo Zhu)

‣ Q&A

2

Presentation by

Josh Miller (3Play Media)

3

About 3Play Media

4

‣ Closed captioning + subtitling + transcription

‣ MIT spinout in 2007

‣ 1,000+ customers in media & entertainment

enterprise, education, and government

What Are Closed Captions?

‣ Text that has been time-synchronized

with the media

‣ Closed captions convey all spoken

content as well as relevant sound

effects

‣ Originated in the early 1980s from an

FCC mandate for broadcast TV

5

Caption Formats

6

Format Type Use Cases

SCC Broadcast, iOS, web media

SMPTE-TT Web media

CAP Broadcast

EBU.STL PAL Broadcast

DFXP Flash players

SRT YouTube and web media

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

Legal Requirements

7

CVAA

‣ Closed captions required for all Internet content

that aired on TV with captions

‣ Applies to video clips

‣ Applies to English and Spanish

‣ 13 Exemptions

‣ Content owner bears responsibility of providing

captions

‣ Content distributor must pass captions through

ADA

‣ Title III: commercial entities “places of public

accommodation”

‣ Recent case law:

– Netflix, Time Warner, FedEx

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)

8

New FCC Regulations

9

‣ Video clips

– January 1, 2016: Single excerpt clips from

captioned television programs

– January 1, 2017: Montages from captioned

television programs

– July 1, 2017: Time sensitive video clips,

live, and near-live programming

‣ Spanish and bilingual programming

– January 1, 2010: All new Spanish-language programming

– January 1, 2012: 75% of pre-existing Spanish-language content

– Bilingual English/Spanish programming treated the same as Spanish

– Other languages don’t require captions

New FCC Standards for Caption Quality

10

‣ Caption accuracy

– Must match spoken words to fullest extent

– 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

FCC Exemptions for Closed Captioning

11

‣ 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

Transcription Best Practices

‣ 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)

12

Captioning Best Practices

‣ 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.

13

Presentation by

Tim Sale (thePlatform)

14

© 2014 thePlatform for Media, Inc

thePlatform

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‣ Integrated closed-captioning with support for multiple caption formats

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Information

Visit our website at thePlatform.com for more

information on our services.

p. +1 206.436.7900f. +1 206.213.0606

sales@theplatform.com1000 Second Avenue, Suite 1000Seattle, WA 98104

Presentation by

Mo Zhu (3Play Media)

25

QUESTIONS?

26

Resources

White Papers: http://www.3playmedia.com/how-it-works/white-papers/

3Play Media + thePlatform captioning integration:

http://www.3playmedia.com/services-features/tools/integrations/theplatform/

thePlatform captioning resources: http://theplatform.com/about/partners/type/subtitles-closed-captioning/