‘6 Strikes’ Enforcement Hits RV Parks

March 22, 2013 by · 3 Comments 

Eric Stumberg

Enforcement of the “six strikes” aspect of the Copyright Alert System (CAS) has landed a Texas RV park in trouble with its cable and Internet service provider.

Brian Schaeffer

Officials with the Texas Association of Campground Owners (TACO) and TengoInternet, the firm that installed the Wi-Fi service at the Oakwood RV Resort in Fredericksburg, have come forward to help the 132-site Good Sam Park through its brush with its service provider, Time-Warner Cable (TWC), which informed the owner earlier this month that it will punish the RV park for not buying bulk rate Internet from TWC.

“Our TACO attorney has already been involved in a case on this and we are probably going to get a lot more action,” Brian Schaeffer, TACO president and CEO told Woodall’s Campground Management. “This story is far more impacting than it reads. For example, parks have bought a ‘commercial’ service for their parks thinking that covers them regarding Wi-Fi in their parks. But the fine print says they cannot distribute Internet in their parks. Almost every park in the USA has or will have this problem.”

The CAS is a private system for alerting and punishing Internet subscribing customers of AT&T, Cablevision, Time Warner, Verizon and Comcast. It monitors use via home networks that access alleged copyrighted material from a list of specific entertainment corporations and their CAS registered content. The consortium that manages the program has branded it as the six strikes program.

The system is intended to be a graduated response wherein participating Internet service providers (ISPs) send up to six electronic warnings notifying subscribers of alleged copyright infringement, as reported by a monitoring service working on behalf of participating copyright owners.

If copyright infringement is reported after a final warning, the ISPs have agreed to implement “mitigation measures,” which can include penalties such as bandwidth throttling.

Fallout from the anti-piracy program could shut down some business broadband accounts, including public Wi-Fi hotspots that are not authorized to share their bandwidth, but have nonetheless been getting away with it.

For RV parks, this can occur if the park operator maintains its Wi-Fi service on a “residential” account rather than a “business” account or the terms of service for the Internet did not include sharing, explained Eric Stumberg, president of TengoInternet. Some park owners opted for the cheaper residential account to reduce overhead expenses and have skated through detection.

Stumberg said he has heard of various violations in recent years, but the penalty has been lenient.

Now, the providers are clamping down on enforcement.

“I don’t think the sky is falling, but I do think it is a very good opportunity to review what is prudent business practice for anyone operating a shared network for their guests,” Stumberg said.

Key Points for Park Owners

The key points for park owners are to review whether they operate on a residential or business account, review their terms of service and ensure they can comply/prevent guests from downloading illegal content.

In an analogy, Stumberg likened sharing and six strikes enforcement to a person renting a car. Even though there may be several passengers in the car, only one person is authorized to drive it unless you have permission from the rental company. When terms of the agreement are violated, such as allowing unauthorized drivers, or in the case of driver behavior – speeding or drunk driving – the person no longer has the right to drive that car. Likewise, the traffic violation goes on the driver’s record, just like being caught illegally downloading movies goes on a Wi-Fi user’s record.

Once alerted by the service provider of a violation, TengoInternet is able go back in history on that given date, find out who illegally downloaded the movie and quarantine that guest from using the service again.

Jim Ganley

“We have not seen this issue yet at any of the 3,500 properties that we serve,” Jim Ganley, managing partner of CheckBox Systems, Gray, Maine, told WCM. “I am not sure if this is an isolated incident, or a coming trend, and I am not sure if it is tied to the six strikes law as much as it is the service provider’s desire to either upsell properties or push users to a wireless plan.”

The latter concerns Stumberg who wonders if the stricter enforcement of the six strikes policy is mere “saber rattling” to scare customers into buying bulk rate Internet service from the cable provider for their campgrounds.

TACO’s Schaeffer was more adamant.

He envisions “the cable company is asking parks to install boxes on every TV in every RV that enters their parks. ARE YOU KIDDING ME! When the RV drives out with these devices still on board, then the park has to buy more devices or charge the RV owners for them. I thought this might be strictly a TV provider issue but now it’s coming together as to what it really is.

“This could get really ugly really fast and it isn’t about piracy. It’s about greed and wanting every citizen to pay for every ounce of Internet and TV they use – even in RV parks.”


Wi-Fi Providers Need to Limit Liabilities

March 20, 2013 by · Comments Off on Wi-Fi Providers Need to Limit Liabilities 

The following story first appeared on and was redistributed today (March 20) in “Wednesday Morning Coffee Talk & Updates,” an online newsletter of the California Association of RV Parks and Campgrounds (CalARVC).  Jim Ames of Airwave Adventurers suggested that CalARVC share this article with its members. He has been warning clients about this for the last couple of years. He urges campground owners to make sure they have a way to limit their liability now.

The “six-strikes” Copyright Alert System (CAS) is close to launching, and fallout from the anti-piracy program could shut down some business broadband accounts, including public Wi-Fi hotspots that are not authorized to share their bandwidth but have nonetheless been getting away with it.

The CAS monitors Internet usage to detect “the inadvertent or purposeful unauthorized distribution of copyrighted content through peer-to-peer networks.” Owners of networks deemed to violate copyrights will be warned and could have their Internet access throttled or be taken to court.

The system was created by the Center for Copyright Information (CCI), which was formed in September 2011 by the Motion Picture Association of American and MPAA members, Recording Industry Association of America and RIAA members, AT&T, Cablevision, Comcast, Time Warner Cable and Verizon Communications.

Though the plan is aimed primarily at home networks, a leaked document obtained by TorrentFreak indicates that the plan as implemented by Verizon will impact business customers as well. For example, a business that receive five or six warnings because an employee used the company network to distributed copyrighted content could see its Internet connection throttled down to 256 kbps for two to three days.

Ed McFadden, a Verizon spokesman, told Ars Technica that the leaked document was a “working draft” and subject to change. He also said Verizon will distribute information to its customers about the program within the next month.

The CAS program could also impact owners of businesses, such as cafes, offering public Wi-Fi service that could be used by customers to violate CAS rules. However, McFadden said running a Wi-Fi hotspot on its own is a violation of Verizon’s terms of service as is. He told Ars Technica that the site’s discussion about the potential impact of the CAS on Internet cafes and open hotspots is thus “misleading and inaccurate to the reader on a factual basis.”

Similarly, CCI Executive Director Jill Lesser told TorrentFreak that business broadband accounts are already forbidden to share their Internet access with customers. “The terms of service on such accounts do not allow them to be used to provide free Wi-Fi or ‘hotspots’ so the hypothetical cafe owner offering public Wi-Fi will not be subject to the CAS if they are following their terms of service,” she said.

Internet advocates question the premise behind the CAS program. “This does create a scenario that discourages open Wi-Fi, which I think is a problem,” Sherwin Siy, the vice president of legal affairs at Public Knowledge, told Ars Technica. “Of course, this is one area where the rightsholders and the ISPs’ interests intersect very nicely. Verizon and its competitors want to encourage the number of paid subscribers, and the RIAA and MPAA want to have Internet connections be as identifiable as possible.”