In this proceeding, the Commission proposes to expand the definition of a multichannel video programming distributor (MVPD) to encompass “subscription linear” online video distributors (OVDs), defined as services that make “multiple streams of prescheduled video programming available for purchase” over the Internet. We believe this proposal is unwise as a policy matter and incorrect as a matter of statutory interpretation. Instead, we urge the Commission to affirm the Media Bureau’s Transmission Path Interpretation, which holds that an MVPD must “own or operate the facilities for delivering content to consumers.” We contend that this is the only permissible construction of the term MVPD as used in the Communications Act. The Transmission Path Interpretation also produces superior policy results. Subjecting certain OVDs to the regulatory privileges and obligations of MVPDs is not only unnecessary given today’s thriving Internet video market, but also likely to distort competition among various OVD business models.