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Author Topic: DOJ proposes requiring closed captions and audio description Harold Hallikainen Jedi Master Film Handler Posts: 906 From: Denver, CO, USA Registered: Aug 2009 posted 08-08-2014 03:03 PM                        I've played with Google Glass a little bit (30 minutes or so). I believe it uses a Bluetooth RF link to the user's phone. It has a full motion color image in one eye. The image is high in the field of view, so we'd have "super titles" instead of "sub titles." It's quite possible to send captions or subtitles over Ethernet (we do that for debug in the USL equipment) or Wi Fi. But, we think the ease of use of IR linked captions and HI/VI makes IR a better choice (no programming required). Thus far, I don't know of anyone trying to keep the caption or subtitle stationary over the screen. The USL glasses and Sony glasses have the caption follow your head. If you WERE to want to hold it in a certain position on the screen, I think just detecting the lit rectangle of the screen would be enough to determine where the screen is. In most cases, though, the caption or subtitle takes up the entire display, so there is not room to scroll the image around following the screen as the user turns her/his head. Interesting ideas, though! Harold  |  IP: Logged Randy Stankey Film God Posts: 6539 From: Erie, Pennsylvania Registered: Jun 99 posted 08-08-2014 04:34 PM                     Do you think it is possible for Glass to receive captions via IR? You could put an IR emitter in the front of the auditorium. You wouldn't necessarily have to perform a full image superimposition. I think it would be enough to just use the IR for image stabilization. The reason I suggested using IR to track the screen is because, if the image is dark, the computer might not be able to detect the edges of the screen. I was also guessing that it would be easier for the computer to detect four discrete points instead of calculating all four edges. Again, all just conjecture.  |  IP: Logged Harold Hallikainen Jedi Master Film Handler Posts: 906 From: Denver, CO, USA Registered: Aug 2009 posted 08-09-2014 03:04 PM                        I've just finished reading the comments filed thus far in this proceeding (how are YOU spending your weekend?). Summaries and links to the individual comments are now available at http://ming.hallikainen.org/DojNprm/ . I'll update the page when new comments are filed. Harold  |  IP: Logged Frank Angel Film God Posts: 5305 From: Brooklyn NY USA Registered: Dec 1999 posted 08-09-2014 06:10 PM                        Didn't the MPAA get the local police and FBI come into a theatre and confiscate the Google Glass right off the patron's head who was using them and then throw that hapless individual to the ground and beat him with billy clubs for copyright infringment? The wife was also dragged out of the theatre and confinded in a separate room, strip-searched and interogated -- I think she may have been waterboarded as well to get her to give up the bootlegging network king-pins.  |  IP: Logged Harold Hallikainen Jedi Master Film Handler Posts: 906 From: Denver, CO, USA Registered: Aug 2009 posted 09-04-2014 07:51 PM                        Yesterday, the DOJ extended the comment period until December 1, in response to a request from NATO. My summary of comments filed so far is athttp://ming.hallikainen.org/DojNprm/ . Harold  |  IP: Logged Harold Hallikainen Jedi Master Film Handler Posts: 906 From: Denver, CO, USA Registered: Aug 2009 posted 11-25-2014 10:49 PM                        The DOJ comment deadline is approaching! Comments on the proposed rulemaking are due December 1 at 11:59 PM ET. A summary of all comments filed thus far is available at http://www.hallikainen.org/DojNprm/ . There is also a link there to the DOJ page where you can file your comments. Harold  |  IP: Logged Harold Hallikainen Jedi Master Film Handler Posts: 906 From: Denver, CO, USA Registered: Aug 2009 posted 01-02-2015 07:48 PM                        I have FINALLY finished summarizing the comments filed with the US Department Of Justice on closed captioning and audio description for movie theaters. The summaries are available at http://www.hallikainen.org/DojNprm/ . Good bedtime reading? Harold  |  IP: Logged Justin Hamaker Film God Posts: 2253 From: Lakeport, CA USA Registered: Jan 2004 posted 01-02-2015 09:35 PM                        A couple very common misconceptions I see in the comments: 1. Closed caption and descriptive audio systems would significantly add to profits. >Because we log every use of ALD, VIN, and CC equipment, I can say without doubt that the use is minimal. Primary use is for ALD, and this is most common for films skewing to a senior citizen audience. We normally have 4 headsets available and ready to use at any given time (plus more in the office if needed). In the nearly 2 years since installing the system, we have had maybe 2 instances where all 4 units were used at once. And in no case have we ever had more than 4 out at one time. In most cases we never have more than one unit in use at any given time. 2. Open captions would not distract the general public. >I think this comment is colored by the individual's desire for open captions. I have not seen any objective evidence either way on this issue. However, I believe it would detract from the enjoyment of the average moviegoer. 3. Accessibility devices are inexpensive. >The reality is the cost of equipping a multiplex to transmit and having an adequate supply of devices is rather expensive. If you look at the payoff for each device as a portion of the ticket price from each use, it's likely the payoff period will exceed the useful life of the units.  |  IP: Logged Brad Miller Administrator Posts: 17775 From: Plano, TX (36.2 miles NW of Rockwall) Registered: May 99 posted 01-02-2015 11:47 PM                     quote: Justin Hamaker 2. Open captions would not distract the general public. >I think this comment is colored by the individual's desire for open captions. I have not seen any objective evidence either way on this issue. However, I believe it would detract from the enjoyment of the average moviegoer. I couldn't watch it. I would walk out as a moviegoer. Open captions are only good when you CAN'T hear the sound, such as sitting in a restaurant or a doctor's office, because that's similar to watching a silent movie. When the sound is available to hear though, it's an immense distraction. (At least to me)  |  IP: Logged Buck Wilson Jedi Master Film Handler Posts: 894 From: St. Joseph MO, USA Registered: Sep 2010 posted 01-03-2015 12:05 AM                     I strongly agree with the last two posts  |  IP: Logged Frank Angel Film God Posts: 5305 From: Brooklyn NY USA Registered: Dec 1999 posted 01-03-2015 09:26 AM                        I firmly believe that the intention of the ADA requirements are laudable, but the ADA implementation has always been wrong-headed in how it has calculataed the arbitrary numbers needed for ADA compliance. At least in large venues like ours, the number of required devices (seats, headsets, etc) is totally out of sync with the real-time need. Here are the numbers: installed as per ADA requirement vs. MAXIMUN number of times these have actually been used during any one month of the year: Wheelchair seating with adjacent companion seats 25/2 Assisted listening devices, available from the concessions counter in the Grand Lobby 35/3 ADA-compliant parking spaces 40/8 Accessible restrooms on the Grand Lobby level 2/EVERYONE uses them because we cannot enforce compliance, i.e., we can't keep non-handicapped individuals from using these restrooms; like, have an usher standing at the door forbidding older patrons from using the very near-by ADA restrooms and forcing them to go down or up flights of stairs when there are no handicapped individuals in sight? Sure, if you want a riot and LOTS of ill-will. Large-print programs, available by request with 72 hours notice, So far, only once. It seems clear to anyone who can do math that the requirements are serious over-kill and present a unnecessary burden on a business. These new regs will be the exactly the same. They will require us to install expensive equipment in numbers well beyond the actual demand/need. Seems it would be quite easy for a theatre to track the actual real-time need for ADA required equipment and technologies over, say a year's time, the number of actual requests made by handicap persons and allow that number vs, a small percentage higher for a buffer, to be used as the requirement. The theatre could be required by ADA regs to dutifully record those yearly numbers and the requirements would be based on that data. The theatre would also have to report any time a request was made for said devices but none were available. Alternatively, the ADA equipment and technology requirements could be determined by the actual known number of handicapped persons in any given locality within a calculated distance from a theatre, this based on Census data from the Current Population Survey Annual Social and Economic Supplement (CPS ASEC) of the Census Bureau. Other Federal agencies also collect and report disability statistics. Why require a theatre to purchase and maintain 35 hearing assisted headsets if there are only 10 known persons with hearing disability within a 100 mile radius of the theatre? It seems there are legitimate and much better ways of determining how many devices a theatre needs to install that to just set an arbiturary percentage of number of seats as is done now. I'm just saying, the laws should take into account known densities of handicap individuals within a reasonable proximity of the establishment required to supply such devices. BTW, the idea that someone could possibly enjoy a movie if they had to watch the subtitles on a smartphone....what? looking up and down at the device and the screen?...is ludicrous.  |  IP: Logged Harold Hallikainen Jedi Master Film Handler Posts: 906 From: Denver, CO, USA Registered: Aug 2009 posted 01-03-2015 10:10 AM                        The NATO and others Joint Recommendations call for much lower minimums with usage tracking. Every six months, the theater would adjust the quantity of devices on hand to be at least 150% of the average weekend demand for the devices. This was submitted by NATO and several disability rights groups. Various other groups also endorsed this concept. This proposal also requires theaters to file reports every six months with the DOJ. I really don't think the DOJ wants to get into all that paperwork. But, I think they may require theaters to make the reports and have them available for the DOJ to review (which would probably be complaint driven). If a theater has reports showing they meet the 150% requirement, that could be an adequate defense. A few commenters suggested basing the requirement on census data on the number of hard of hearing individuals within a certain radius. One comment figured out that a theater needed something like 18,000 devices based on this. I think the demand-based method is more reasonable. LOTS of commenters want open captions. The Wisconsin Association of the Deaf pointed to a product from Invisivision ( http://www.invisivision.com/ ) that uses polarized filters to make onscreen captions visible. This, of course, would not work with white screens and would probably interfere with polarization-based 3D. USL demonstrated a system based on polarization and patent 4859994. A silver screen was placed below the main screen. An LCD projector without a polarizer projected captions onto the silver screen. Those with polarized glasses saw the captions. Those without the glasses saw a green box. Exhibitors did not like the green box. I suspect users would not like having to look below the screen for the captions (there are several comments in the DOJ filing about this with both caption boxes and glasses). Another method of invisible on-screen captions is covered by patent 7414698. It puts the text on the image as a positive and negative superimposing on alternate projector flashes. The eye averages these out so they are not visible to those who see all the flashes. Those wishing to see the captions would wear shutter glasses to pick up only one of the flashes. Harold  |  IP: Logged Mike Blakesley Film God Posts: 12767 From: Forsyth, Montana Registered: Jun 99 posted 01-03-2015 10:14 AM                        Since we have maybe one request for a hearing device every 2 plus years, our "average weekend demand" would be zero, so 150% of zero is still zero, so....I'm good!  |  IP: Logged Justin Hamaker Film God Posts: 2253 From: Lakeport, CA USA Registered: Jan 2004 posted 01-03-2015 11:56 AM                        There is a theatre very close to a deaf school in Washington DC, and my understanding is that even that theatre sees minimal demand for CC and VIN.  |  IP: Logged Steve Guttag We forgot the crackers Gromit!!! Posts: 12814 From: Annapolis, MD Registered: Dec 1999 posted 01-03-2015 12:00 PM                     So clearly one law professor gave an assignment or the folks in Tennessee just like reading DOJ postings for kicks! If you NEED captions of some sort, they you want Open Captions...and I can understand that. Glasses are a bust as the captions would be flying about where ever you point your head. Closed caption devices suck because it requires you to not only move your eyes off the screen for the time it takes you to read, it also requires you to refocus your eyes between near and far fields. Rear Window would work to some extent because the text would continue to be far field though placing the reflector such that it superimposed the text where desirable would likely be distracting to those behind you. I would think a viable alternative would be all-time closed captions with select days/show times to have open captions based on consumer demand. I think Justin so squarely nails the factors at play here. Furthermore, this industry does not need yet one more excuse for potential movie patrons to stay home so they don't have to "put up" with the distracting open captions. Like it or not, the overwhelming majority of the movie business is not seeking open captions and those should not be given yet another reason to stay away. Make no mistake...open captions all the time would lead to attendance decline. One need not put up with THAT at home. With the audio tracks...it would nice if the DOJ could standardize the source of the VI-N track such that all devices, consumer or pro have access to it as a discrete feed. In the home, it can be an alternate audio feed that normally means losing the Super-Duper sound track in favor of a mono/stereo track with the descriptions. I still strongly feel that it is not discrimination to not provide the actual listening/captioning devices but merely the transmitters. If I needed a hearing aid or like device, I would want to use my own rather than the nasty thing you hand me. Also on the audio side of things, the loop systems are the "favored" systems as they work with the "T-Coil" position of hearing aids. They are mostly impractical for cinemas (and most businesses) and are quite expensive. However, with a conventional receiver one can use a Neckloop to broadcast the equivalent of a loop for a LOT less money. http://www.williamssound.com/catalog/nkl-001. Instead of plugging in headphones, plug the neckloop in and away you go. Another problem with some of the systems out there is that they completely cover the ear. If you want the VI-N channel, you are also typically blocking out the regular sound of the theatre with the headset. This is another reason I think people should supply their OWN listening devices that cater to their particular needs. One shoe does not fit all feet.  |  IP: Logged

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