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Robyn Polashuk

Robyn Polashuk is co-chair of the firm's Entertainment and Media Industry Group. She focuses her practice on the licensing and distribution of television networks and programming content across a variety of platforms, including cable and satellite, IPTV, mobile, and Internet streaming. These transactions span the business models available to consumers, such as subscription linear, ad-supported, subscription and transactional video-on-demand, electronic sell-through, and interactive applications. As part of this work, she also negotiates retransmission consent agreements on behalf of broadcast stations.

Robyn has extensive experience in digital distribution in the areas of “over the top” (OTT), TV Everywhere (TVE), and direct-to-consumer (DTC) structures. She handles a variety of agreements in this space, including traditional network and program distribution, premium subscription content licenses, app placement, revenue sharing, dynamic ad insertion arrangements, as well as content licensing for metaverse platforms. Robyn’s practice also extends to due diligence and contractual analysis in connection with media-related corporate transactions, most favored nations review and interpretation, and guidance for distribution-related disputes and litigation. Robyn works closely with Covington’s tech transactions, litigation and regulatory attorneys to provide multi-faceted support for programming clients’ distribution businesses.

In this practice, Robyn represents leading media groups, film and television studios, sports leagues and emerging networks, in general entertainment, national and regional sports and specialized programming genres, as well as both major and emerging technology, and Internet companies. These include AMC Networks, The Walt Disney Company, Paramount Global, NFL Network, Ovation, Pac-12 Networks, PBS, TV One, and TelevisaUnivision.

She has negotiated on behalf of content owners with all the traditional television distributors, such as DIRECTV, Charter/Spectrum, Comcast, DISH Network and Verizon, as well as streaming distributors and platforms, such as DIRECTV Stream, FuboTV, Roku, Sling TV, Twitter, YouTube TV and Xumo.

The Federal Communications Commission (FCC) has issued a Notice of Proposed Rulemaking (NPRM) in which it proposes satellite television “market modification” rules to implement Section 102 of the Satellite Television Extension and Localism Act Reauthorization Act of 2014 (STELAR).  STELAR amends the Communications Act and the Copyright Act to give the FCC authority to modify a commercial television broadcast station’s local television market for purposes of satellite carriage rights.  The FCC previously had such authority to modify markets only in the cable carriage context.  The FCC also proposes to change the factors relevant to the market modification process.  Below, we list some of the tentative conclusions and interpretations on which the FCC seeks comment.

The main effect of a market modification is to expand or contract the areas in which a station may elect mandatory carriage under the must-carry rules.  To the extent that a station’s network affiliation or other agreements authorize a station to grant retransmission consent only in the station’s Nielsen DMA, a market modification petition granted by the FCC would not alter the boundaries of that DMA.   However, for stations that have elected retransmission consent, a market modification may have implications with respect to the areas in which such stations’ signals may be carried as “local” signals under the copyright laws.Continue Reading FCC Releases NPRM Regarding STELAR’s Market Modification Provisions

On December 19, the FCC released a Notice of Proposed Rulemaking (NPRM) relating to the designation of certain online video programming distributors as “multichannel video programming distributors” (MVPDs) under the Communications Act.  This NPRM raises important and complex issues for the content community and has implications for other statutory regimes as well as existing program licensing and distribution agreements.
Continue Reading FCC Tentatively Concludes that Certain Online Video Distributors are MPVDs