ANA Joins Reply Comments on Zevo-3 Petition

Yesterday, ANA and a group of industry associations including the 4A’s, AAF and MPAA, filed reply comments with the FCC calling on the Commission to reject a petition from the Campaign for a Commercial Free Childhood (CCFC) seeking a declaratory judgment that the Zevo-3 program created by Skechers Entertainment is a “program length commercial” that violates the advertising limits of the Children’s Television Act. 

Our comments contend that that the Zevo-3 program complies with the Children’s Television Act and existing FCC rules and policies, such as those regulating program length commercials and on “host-selling” by a program’s talent or characters.  We also argue that many of the comments the FCC received in support of CCFC’s petition either ignore existing FCC policy or distort the FCC’s prior holdings.  The filing also goes into more depth on the constitutional issues involved. 

If you have any questions, you can reach Dan Jaffe in ANA's Washington office at 202-296-2359 or at