Hunt is chief technology officer at the Motion Picture Association of America, a group that represents Hollywood's seven major studios, which is gearing up for a new wave of enforcement actions against as many as 80 chip or system makers.

"I have a home theater, and I read all the home theater stuff," said Hunt. "We listen to the market, and when we sense a DVD system is not in compliance, we buy it, test it and tear it apart."

As many as a quarter of the roughly 350 companies that hold a license to the Content Scramble System (CSS) technology for DVD copy protection are not complying with its terms, the group estimates. Thirty of those companies recently received warning letters from the MPAA and another 50 are due to get letters in the next few months.

"A number of these breaches are accidental," said Dan Robbins, chief technology counsel for MPAA. "You pay such a small amount for the licenses that I think a lot of people just take a license and don't really read the compliance rules."

The nonprofit DVD Copy Control Association provides a royalty-free license to the seven CSS patents. A one-time administration fee for the license varies from $5,000 to $20,000.

Each MPAA warning letter details the model numbers of products found out of compliance and the part of the CSS license they infringed. Chip or systems companies are typically given 30 to 60 days to respond. Most do.

But some don't comply. The MPAA settled a suit last week with DVD chip maker MediaTek Inc. (Hsinchu, Taiwan). It settled separate court cases with chip makers ESS Technology Inc. (Fremont, Calif.) in April and Sigma Designs Inc. (Milpitas, Calif.) last November.

"Realistically, we know some people will fight us," said Robbins. "We were surprised by the effort from ESS, which lasted a year. That taught us we need to be prepared to fight people who don't agree with us."

ESS and MediaTek are now under court injunctions forcing them to send samples of their DVD chips to the MPAA for certification testing. In addition, both companies had to pay court costs, which amounted to $250,000 for ESS. The CSS license does not provide for recouping damages. Sigma Designs made the terms of its settlement confidential.

Among other violations, all three companies were selling chips that failed to properly code the Copy Generation Management System (CGMS) signaling into the vertical blanking interval of video streams at the point the video is converted to an analog signal.

Testing for proper CGMS coding will be a focus of the MPAA's court-mandated compliance tests. "We just received two large boxes from ESS that we have yet to make our way through," said Robbins.

"If companies are doing the right thing, they won't face the potential of court action that could lead to us needing to certify their products like this," added Hunt.

Among other compliance issues, some companies are enabling analog RGB VGA outputs on DVD devices. The outputs are prohibited because there is no standard for carrying CGMSA over them. Others are simply selling DVD chips to system makers that do not have a CSS license and are thus not obligated to implement its protection techniques.

One manufacturer actually built a dedicated DVD copying machine with a "copy DVD" button on the front. The device has two optical bays, one for the master DVD and the other for making a CD-R copy in the Super VCD format popular in China.

The MPAA is also expanding its labs and hiring at least two new technicians "in anticipation of testing for the broadcast flag and FCC plug-and-play regulations for digital cable TV," said Hunt.

Throw the flag
The FCC has approved 13 techniques for implementing a broadcast flag in protected broadcast content, starting July 1. The flag allows users to make potentially unlimited copies of content for use on a home network, but encrypts the content to prohibit mass distribution over the Web.

Hunt is quick to point out that the MPAA has activities beyond enforcement, such as an education program it is now ramping up as well as continuing engineer-to-engineer engagements.

"We are not just the heavy hand out there suing people," said Hunt. "I have a couple of engineers on staff who work with companies proactively on next-generation copy protection and security architectures for future products. For instance, we have been working closely with Microsoft on their next-generation OS and other product plans." He declined to supply details, citing a nondisclosure agreement.