Federal Communications Commission DA 08-846
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Vizio, Inc
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File No. EB-07-SE-255
Acct. No. 200832100031
FRN No. 0017646886
ORDER
Adopted:  April 9, 2008  Released: April 10, 2008
By the Chief, Enforcement Bureau: 
1. In this Order, we adopt the attached Consent Decree entered into between the 
Enforcement Bureau (“Bureau”) and Vizio, Inc. (“Vizio”).  The Consent Decree terminates an 
investigation by the Bureau against Vizio for possible violations of section 330(c) of the Communications 
Act of 1934, as amended (the “Act”),1 and section 15.120(d)(2) of the Commission’s rules,2 regarding the 
interstate shipment, after March 15, 2006, of digital television receivers that do not comply with the V-
Chip technology requirements because they lack the ability to adapt to new rating systems. 
2. The Bureau and Vizio have negotiated the terms of the Consent Decree that resolve this 
matter.  A copy of the Consent Decree is attached hereto and incorporated by reference.  
3. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree and terminating the 
investigation.
4. In the absence of material new evidence relating to this matter, we conclude that our 
investigation raises no substantial or material questions of fact as to whether Vizio possesses the basic 
qualifications, including those related to character, to hold or obtain any Commission license or 
authorization.    
5. Accordingly, IT IS ORDERED that, pursuant to section 4(i) of the Communications Act 
of 1934, as amended,3 and sections 0.111 and 0.311 of the Commission’s Rules,4 the Consent Decree 
attached to this Order IS ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigation IS 
TERMINATED.
  
1 47 U.S.C. § 330(c).
2 47 C.F.R. § 15.120(d)(2).
3 47 U.S.C. § 154(i), 503(b).
4 47 C.F.R. §§ 0.111, 0.311.
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7. IT IS FURTHER ORDERED that all third-party complaints against Vizio before the 
Bureau related to the above-captioned-investigation as of the date of this Consent Decree ARE 
DISMISSED.
8. IT IS FURTHER ORDERED that Vizio shall make its voluntary contribution to the 
United States Treasury, as specified in the Consent Decree, by credit card through the Commission’s 
Revenue and Receivables Operations Group at (202) 418-1995, or by mailing a check or similar 
instrument payable to the order of the Federal Communications Commission, to Federal Communications 
Commission, P.O. Box 979088, St. Louis, MO 63197-9000.  Payment by overnight mail may be sent to 
U.S. Bank – Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
63101.  Payment by wire transfer may be made to ABA Number 021030004, receiving bank 
TREAS/NYC, and account number 27000001.  For payment by credit card, an FCC Form 159 
(Remittance Advice) must be submitted.  When completing the FCC Form 159, enter the Account number 
in block number 23A (call sign/other ID), and enter the letters “FORF” in block number 24A (payment 
type code).  
9. IT IS FURTHER ORDERED that Vizio will file reports with the Commission ninety 
days after the Effective Date, twelve months after the Effective Date, and twenty four months after the 
Effective Date.  Each report shall include a compliance certificate from an officer, as an agent of Vizio, 
stating that the officer has personal knowledge that Vizio has established operating procedures intended to 
ensure compliance with this Consent Decree, together with an accompanying statement explaining the 
basis for the officer’s compliance certification.  All reports shall be submitted to the Chief, Spectrum 
Enforcement Division, Enforcement Bureau, Federal Communications Commission, 445 12th Street, 
S.W., Washington, D.C. 20554.
10. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first class mail and certified mail, return receipt requested, to Michael Hurey, Kleinberg & Lerner, 
LLP, 2049 Century Park East, Suite 1080, Los Angeles, California 90067-3112 and Rob Brinkman, Vice 
President, Vizio, 39 Tesla, Irvine, CA 92618.
FEDERAL COMMUNICATIONS COMMISSION
Kris Anne Monteith
Chief, Enforcement Bureau
Federal Communications Commission DA 08-846
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Vizio, Inc.
)
)
)
)
)
File No. EB-07-SE-255
Acct. No. 200832100031
FRN No. 0017646886
CONSENT DECREE
The Enforcement Bureau (“Bureau”) and Vizio, Inc. (“Vizio”), by their authorized representatives, hereby 
enter into this Consent Decree for the purpose of terminating the Bureau’s investigation into whether 
Vizio violated section 330(c) of the Communications Act of 1934, as amended (the “Act”),1 and section 
15.120(d)(2) of the Commission’s rules,2 regarding the interstate shipment, after March 15, 2006, of 
digital television receivers that do not comply with the V-Chip technology requirements because they lack 
the ability to adapt to new rating systems.
I. DEFINITIONS
1. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended, 47 U.S.C. § 151 et seq.
(b) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(c) “Commission” and “FCC” mean the Federal Communications Commission and all 
of its bureaus and offices.  
(d) “Complaints” means third-party complaints that may have been received by, or are 
in the possession of, the Commission or Bureau alleging violations of V-Chip 
technology requirements.
(e) “Compliance Plan” means the program described in this Consent Decree at 
paragraph 8.
(f) “Digital Television Receivers” or “DTV Receivers” means (i) digital television 
broadcast receivers with display screens in the 4:3 aspect ratio measuring 13 inches 
or larger diagonally, (ii) digital television broadcast receivers with display screens in 
the 16:9 aspect ratio measuring 7.8 inches or larger vertically, and (iii) devices with 
digital television broadcast tuners sold without an accompanying display device, 
such as DVR recorders.
(g) “Effective Date” means the date on which the Bureau releases the Adopting Order.
  
1 47 U.S.C. § 330(c).
2 47 C.F.R. § 15.120(d)(2).
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(h) “Investigation” means the investigation commenced by the Bureau’s August 7, 2007 
Letter of Inquiry3 regarding whether Vizio violated section 330(c) of the Act, and 
section 15.120(d)(2) of the Rules, by shipping interstate television receivers that do 
not comply with the V-Chip technology requirements because they lack the ability 
to adapt to new rating systems.4  
(i) “Vizio” means Vizio, Inc. and its predecessors-in-interest and successors-in-interest.
(j) “Order” or “Adopting Order” means an Order of the Bureau adopting the terms of 
this Consent Decree without change, addition, deletion, or modification.
(k) “Parties” means Vizio and the Bureau.
(l) “Rules” means the Commission’s regulations found in Title 47 of the Federal 
Regulations.
II. BACKGROUND
2. Section 303(x) of the Act directs the Commission to prescribe rules requiring that 
television receivers shipped in interstate commerce or manufactured in the United States be equipped with 
a feature designed to enable viewers to block the display of all programs with a common rating.5 Section 
330(c) of the Act provides that no person shall ship in interstate commerce or manufacture in the United 
States television receivers that do not comply with rules prescribed by the Commission pursuant to 
section 303(x).6 The Commission adopted program blocking capability requirements for both analog and 
digital television (“DTV”) receivers in 1998.7 In 2004, the Commission adopted specific technical 
standards to implement V-Chip functionality for DTV receivers (“V-Chip technology requirements”).8  
The DTV V-Chip technology requirements provide that, effective March 15, 2006, digital television 
receivers with picture screens 13 inches or greater that are shipped in interstate commerce must be 
equipped with V-Chip technology to allow blocking of the display of programming based on its content 
and be able to respond to changes in the content advisory rating system.9  
3. On August 9, 2007, the Bureau issued a letter of inquiry (LOI) to Vizio.10 The August 9, 
2007 LOI directed Vizio, among other things, to submit a sworn written response to a series of questions 
  
3 See Letter from Kathryn S. Berthot, Chief Spectrum Enforcement Division, Enforcement Bureau to Vizio 
(“August 7, 2007 LOI”).
4 47 U.S.C. § 330(c); 47 C.F.R. § 15.201(d)(2). 
5 47 U.S.C. § 303(x).
6 47 U.S.C. § 330(c).
7 In the Matter of Technical Requirements to Enable Blocking of Video Programming Based on Program Rating, 
Implementation of Sections 551(c), (d), and (e) of the Telecommunications Act of 1996, Report and Order, 13 FCC 
Rcd 11248 (1998).
8 In the Matter of Second Periodic Review of the Commission’s Rules and Policies Affecting the Conversion to 
Digital Television, Report and Order, 19 FCC Rcd 18279 (2004).  The V-Chip technology requirements also apply 
to devices sold without an accompanying display device.  Id. at 18348.
9 47 C.F.R. § 15.120(d)(2).
10 See August 7, 2007 LOI.  
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relating to the interstate shipment of television receivers that did not comply with the Commission’s 
requirements that they be able to respond to changes in the content advisory rating system.   Vizio 
initially responded to the August 9, 2007 LOI on September 11, 2007 and provided supplemental 
responses on November 19, 2007 and January 18, 2008.11
III. TERMS OF AGREEMENT
4. Adopting Order.  The Parties agree that the provisions of this Consent Decree shall be 
subject to final approval by the Bureau by incorporation of such provisions by reference in the Adopting 
Order without change, addition, modification, or deletion.
5. Jurisdiction. Vizio agrees that the Bureau has jurisdiction over it and the matters 
contained in this Consent Decree and has the authority to enter into and adopt this Consent Decree.
6. Effective Date; Violations.  The Parties agree that this Consent Decree shall become 
effective on the date on which the Bureau releases the Adopting Order.  Upon release, the Adopting Order 
and this Consent Decree shall have the same force and effect as any other Order of the Bureau.  Any 
violation of the Adopting Order or of the terms of this Consent Decree shall constitute a separate violation 
of a Bureau Order, entitling the Bureau to exercise any rights and remedies attendant to the enforcement 
of a Commission Order.
7. Termination of Investigation.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
terminate its investigation and dismiss the Complaint.  In consideration for the termination of said 
investigation and dismissal of the Complaint, Vizio agrees to the terms, conditions, and procedures 
contained herein.  The Bureau further agrees that in the absence of new material evidence, the Bureau will 
not use the facts developed in this investigation through the Effective Date of the Consent Decree, or the 
existence of this Consent Decree, to institute, on its own motion, any new proceeding, formal or informal, 
or take any action on its own motion against Vizio concerning the matters that were the subject of the 
investigation.  The Bureau also agrees that it will not use the facts developed in this investigation through 
the Effective Date of this Consent Decree, or the existence of this Consent Decree, to institute on its own 
motion any proceeding, formal or informal, or take any action on its own motion against Vizio with 
respect to Vizio’s basic qualifications, including its character qualifications, to be a Commission licensee 
or hold Commission authorizations.  
8. Compliance Plan. For purposes of settling the matters set forth herein, Vizio agrees to 
create within 60 days and maintain a Compliance Plan related to future compliance with the Act, the 
Commission’s Rules, and the Commission’s Orders.  The Plan will include, at a minimum, the following 
components: 
(a) Customer Notification. Vizio will notify all customers who have registered their purchase 
of VIZIO brand digital television receivers that do not comply with section 15.120(d)(2) that 
the receivers can be upgraded to respond to changes in the content advisory rating system.  
Vizio also will post this information on its website.  
  
11 See Letter from Michael Hurey, Kleinberg & Lerner, LLP, to Neal McNeil, Spectrum Enforcement Division, 
Enforcement Bureau (September 11, 2007); Letter from Michael Hurey, Kleinberg & Lerner, LLP, to Neal McNeil, 
Spectrum Enforcement Division, Enforcement Bureau (November 19, 2007); and Letter from Michael Hurey, 
Keinberg & Lerner, LLP, to Neal McNeil, Spectrum Enforcement Division, Enforcement Bureau (January 18, 
2008).
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(b) Receiver Upgrades.  Vizio will provide on its website an on-line, or downloadable form 
whereby customers may request a software upgrade that permits V-Chip technology to 
respond to changes in the content advisory ratings system, and will make such form available 
for a period of five years.  In the alternative, Vizio will make such software upgrades 
available for download directly from its website, and provide instructions to its customers for 
the process of downloading the appropriate software and installing it on the receiver.  In the 
event Vizio makes the software available for download and a customer is not able to 
download the software, Vizio will offer to provide a device (such as a compact disc) at no 
charge that the customer can use to install the upgrade.  For a period of 90 days from the 
Effective Date, on request from a customer, Vizio will provide an appropriate hardware 
dongle which permits the software upgrade to be installed on the receiver without charge to 
the customer.  After 90 days from the effective date, on request from a customer Vizio will 
provide an appropriate hardware dongle which permits the software upgrade to be installed 
on the receiver at Vizio's cost, plus actual shipping and handling charge.  Vizio will make the 
hardware dongle available for a period of five years.
(c) Compliance Officer. Vizio will appoint its Vice President of Product Development as the 
Compliance Officer who will oversee the Compliance Plan and enforce the applicable FCC 
requirements within Vizio.
(d) Compliance Measures. To ensure future compliance, Vizio will implement compliance 
policies and procedures which will: (1) require specifications for the purchase of products and 
components to include specific reference to applicable FCC standards; (2) include 
compliance with FCC requirements in the company’s internal and external product design 
review process; (3) conduct training for key personnel, including its chief operations officer 
and engineering management at least semi-annually regarding FCC statues, regulations and 
rules that relate to the design, manufacture and sale of television receivers; (4) prepare a 
compliance manual regarding FCC statues, regulations and rules that relate to the design, 
manufacture and sale of television receivers to be distributed to the personnel described in (3) 
above; (5) establish procedures for and conduct periodic product testing with respect to 
compliance with applicable FCC standards; (4) and identify, segregate, and track to 
resolution design and product issues specifically affecting the ability of a product to comply 
with FCC standards.
(e) Compliance Reports. Vizio will file compliance reports with the Commission ninety days 
after the Effective Date, twelve months after the Effective Date, and twenty-four months after 
the Effective Date.  Each compliance report shall include a compliance certificate from an 
officer, as an agent of Vizio, stating that the officer has personal knowledge that Vizio has 
established operating procedures intended to ensure compliance with this Consent Decree, 
together with an accompanying statement explaining the basis for the officer’s compliance 
certification.  All compliance reports shall be submitted to Chief, Spectrum Enforcement 
Division, Enforcement Bureau, Federal Communications Commission, 445 12th Street, S.W., 
Washington, D.C. 20554.  
(f) Termination Date.  Unless stated otherwise, the requirements of this Consent Decree will 
expire twenty-four months after the Effective Date.
9. Voluntary Contribution.  Vizio agrees that it will make a voluntary contribution to the 
United States Treasury in the amount of $370,000.  Vizio shall make such contribution in the form of 18 
equal payments in the amount of $20,555.56, paid monthly, commencing with the execution of this 
Consent Decrees. The payment must be made by check or similar instrument, payable to the Order of the 
Federal Communications Commission.  The payment must include the Account Number and FRN 
Number referenced in the caption to the Adopting Order.  Payment by check or money order may be 
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mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.  Payment 
by overnight mail may be sent to U.S. Bank – Government Lockbox #979088, SL-MO-C2-GL, 1005 
Convention Plaza, St. Louis, MO 63101. Payment by wire transfer may be made to ABA Number 
021030004, receiving bank TREAS/NYC, and account number 27000001.  For payment by credit card, 
an FCC Form 159 (Remittance Advice) must be submitted.  When completing the FCC Form 159, enter 
the Account number in block number 23A (call sign/other ID), and enter the letters “FORF” in block 
number 24A (payment type code).  
10. Waivers.  Vizio waives any and all rights it may have to seek administrative or judicial 
reconsideration, review, appeal or stay, or to otherwise challenge or contest the validity of this Consent 
Decree and the Order adopting this Consent Decree, provided the Bureau issues an Order adopting the 
Consent Decree without change, addition, modification, or deletion.  Vizio shall retain the right to 
challenge Commission interpretation of the Consent Decree or any terms contained herein.  If either Party 
(or the United States on behalf of the Commission) brings a judicial action to enforce the terms of the 
Adopting Order, neither Vizio nor the Commission shall contest the validity of the Consent Decree or the 
Adopting Order, and Vizio shall waive any statutory right to a trial de novo.  Vizio hereby agrees to waive 
any claims it may otherwise have under the Equal Access to Justice Act, 5 U.S.C. § 504 and 47 C.F.R. § 
1.1501 et seq., relating to the matters addressed in this Consent Decree.
11. Severability. The Parties agree that if any of the provisions of the Adopting Order or the 
Consent Decree shall be invalid or unenforceable, such invalidity or unenforceability shall not invalidate 
or render unenforceable the entire Adopting Order or Consent Decree, but rather the entire Adopting 
Order or Consent Decree shall be construed as if not containing the particular invalid or unenforceable 
provision or provisions, and the rights and obligations of the Parties shall be construed and enforced 
accordingly.  In the event that this Consent Decree in its entirety is rendered invalid by any court of 
competent jurisdiction, it shall become null and void and may not be used in any manner in any legal 
proceeding.
12. Subsequent Rule or Order. The Parties agree that if any provision of the Consent 
Decree conflicts with any subsequent rule or Order adopted by the Commission (except an Order 
specifically intended to revise the terms of this Consent Decree to which Vizio does not expressly 
consent) that provision will be superseded by such Commission rule or Order.
13. Successors and Assigns. Vizio agrees that the provisions of this Consent Decree shall 
be binding on its successors, assigns, and transferees.  
14. Final Settlement. The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties.  The Parties further agree that this Consent Decree does 
not constitute either an adjudication on the merits or a factual or legal finding or determination regarding 
any compliance or noncompliance with the requirements of the Act or the Commission’s Rules and 
Orders.  
15. Modifications. This Consent Decree cannot be modified without the advance written 
consent of both Parties.
16. Paragraph Headings. The headings of the Paragraphs in this Consent Decree are 
inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent 
Decree.
17. Authorized Representative.  Each party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.
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18. Counterparts. This Consent Decree may be signed in any number of counterparts 
(including by facsimile), each of which, when executed and delivered, shall be an original, and all of 
which counterparts together shall constitute one and the same fully executed instrument.
_______________________________
Kris Anne Monteith
Chief
Enforcement Bureau 
________________________________
Date
________________________________
Rob Brinkman
Vice President
Vizio, Inc.
________________________________
Date