“In today’s fast paced world, Americans expect to instantly
access information at their fingertips by merely logging on to a website, conducting
a Google search, or using an app on their smart phone,” Entercom’s petition
argues. “Relying on broadcast announcements for material contest information
may have been an acceptable way to attempt to inform the public about the terms
of a contest when the Contest Rule was enacted in 1976, but it is certainly not
the case today, especially when there are superior methods that are simple to
implement.”
At present, the FCC’s “contest rule” says that the “material
terms” of the game must be explained “periodically by announcements broadcast
on the station conducting the contest.” This doesn’t mean that the station has
to explain the rules in their entirety every time, but “disclosure of material
terms in a reasonable number of announcements is sufficient.”
The gist of Entercom’s proposal is to let stations announce
the contest over the airwaves, but point listeners to the station website for
more details. As Entercom puts it:
“Entercom proposes that the Commission amend the Contest
Rule to permit broadcasters to either: (a) broadcast the material terms on the
station (as provided in the current rule); or (b) provide in written form on a
website and upon request by email, facsimile, mail or in person, provided that
the station makes periodic announcements advertising how and where the public
can gain access to the material terms of a contest.”
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