Putting TV or cable programming onto the Internet may soon not be as easy as it once was, as the FCC has just issued its Notice of Proposed Rulemaking on the captioning requirements for online video. The proposals advanced by the Commission are summarized in our firm's Advisory on the subject, here. These rules are proposed pursuant to a Congressional mandate that requires captioning of television programming that has already been captioned pursuant to an FCC rule, when that programming is later shown on the Internet. This obligation was adopted as part of the 21st Century Communications and Video Accessibility Act ("CVAA") which, among other things, looks to make Internet video programming accessible to the hearing impaired. Programming that has run on TV stations or cable systems, and is later delivered through the Internet, will apparently be under the captioning obligations, subject to any exceptions adopted by the FCC in this proceeding. The legislation requires that rules be adopted in January, and that implemention begin 6 months thereafter. Thus, there is a very quick comment period - with comments due 20 days after the NPRM is published in the Federal Register, and replies 10 days later.