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    An Application to the CRTC on behal o Sun News Network

    Supplementary Brie

    CanadianTvFirst.ca

    May 30, 20

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    96o original Canadian television content/hours week

    Sun News Network produces

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    CanadianTvFirst.ca

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    Table O Contents

    1. Introduction ........................................................................... 1

    2. Proudly Canadian ................................................................. 3

    3. Canadians Want More Voices .............................................. 4

    4. Carriage Chaos ..................................................................... 6

    5. Location Matters ................................................................... 8

    6. Seeing Is Believing .............................................................. 10

    7. Distribution + Dial Position = Ratings ................................. 12

    8. Fair Is Fair ............................................................................ 14

    9. Strong Role For The CRTC................................................. 16

    10. Financial Considerations .................................................... 18

    11. Sun News Meets All Criteria ............................................... 19

    12. Our Ask ............................................................................... 20

    13. About Us ............................................................................. 21

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    The theory of the free press

    is not that the truth will be

    presented completely orperfectly in any one instance,

    but that the truth will emerge

    from free discussion.- Walter Lipmann

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    1.1 In July 2010, Groupe TVA and Sun Media made

    an application to the CRTC or a license or a

    new English language national news specialty

    service Sun TV News.

    1.2 In that application we stated our intent to:

    i Produce and broadcast 100%

    Canadian television.

    ii Cover stories and issues ignored by

    others in the Canadian news media.

    iii Broaden the range o opinion in the

    Canadian media.

    1.3 Ater one year on air, we have delivered on these

    commitments in spades.

    1.4 We are a Canadian content powerhouse. Not

    including elections and other news specials, we

    produce 96 hours/week o Canadian content.

    Our news is o, by and or the Canadian people.

    1.5 We are punching above our weight when it

    comes to news - whether it is breaking stories

    about wanted war criminals roaming our streets,

    being the exclusive broadcaster o the Trudeau/Brazeau Fight or the Cure, or by being the

    only national cable news network to have live

    coverage o election nights in Saskatchewan

    and Manitoba.

    1.6 Gone are the days o boring talking heads

    and tired talking points. Debate on Sun News

    has lived up to its promise o being raw and

    edgy. Love them or hate them, our hosts and

    commentators swing or the ences every night.

    1.7 In our initial application, we requested mandatory

    distribution or Sun News or a period o three

    years.

    1.8 This was in recognition that the all-news marketthat we were launching into was a mature

    market. Moreover, our competitors had enjoyed

    highly preerential rules compared to the rules

    we were being asked to operate under. CTV

    News Channel and CBC News Network had

    enjoyed mandatory distribution, preerential dial

    placement and mandated subscription ees or

    13 and 21 years respectively.

    1.9 Sun News on the other hand, is distributed like

    a third-rate oreign news service available inonly 4 out o 10 households with major BDUs like

    Telus and MTS not even oering it. This situation

    is unsustainable.

    1.10 The CRTC indicated it was not considering

    mandatory distribution or any channels at the

    time o our initial application, but would have

    a process opening in 2012 under which such

    requests would be considered. (Broadcasting

    Regulatory Policy CRTC 2010-629)

    1.11 It is through this process that Sun News is

    applying for mandatory distribution

    on analog and digital basic service in

    Canada.

    1. Introduction

    1

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    Eight in ten Canadians, surveyed by Abacus Data, agreed that all Canadians

    should have access to every Canadian cable all-news channel.

    FIGURE 2.1:

    Fig 5.0. p 19. Cable News and the Cable and Satellite Industry. Abacus Data Inc. 2012 ABACUS DATA

    Caryn Lieberman,

    Host o Right Now

    2

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    2.1 Sun News is 100% Canadian (and proud o it).

    Not only is our content Canadian, but so is our

    ownership. More than any other private network,

    our parent companies TVA and Quebecor have

    been on the oreront o producing original,

    Canadian television. Moreover, LCN produces

    98 hours o original Canadian news

    programming every week.

    2.2 And Sun News contributes to that strong

    tradition. We are producing 11 unique shows

    that oer 96 hours/week o original television

    programming every second o it Canadian.

    2.3 Sun News produces more Canadian content

    than almost any other network in the Canadian

    specialty service universe. (Figure 2.2)

    2.4 As proud Canadians, we agree with the CRTCthat Canadian content matters. That Canadian

    news o, by and or Canadians needs to have

    a place at the centre o our television landscape.

    2.5 And so do Canadians. (Figure 2.1).

    2. Proudly Canadian

    FIGURE 2.2: ESTIMATED WEEKLY HOURS OF CANADIAN CONTENT BY NETWORK

    Based on website and program guide analysis or the week o May 14, 2012. First-run programming only.

    Sun News is a Canadian Content Powerhouse

    OWNOUTBRAVO APTNDISCOVERY SUN

    100

    1 2.5 4.57

    96

    16.5

    0

    Hoursoforig

    inallyproducedCanadianconte

    ntperweek Thats91.5hour

    s

    morethanOprah!

    3

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    3.1 Since beore its launch, Sun News has promised to

    shake up the media consensus - to bring to the oreront

    new voices and views that are oten ignored by others.

    We believe our programming has lived up to that

    promise.

    3.2 Our desire or more diversity in Canadian media is

    shared by the public. A large majority o Canadians

    believe the media is dominated by a ew voices that all

    think alike (Figure 3.1). And an overwhelming majority

    wants to see more voices in the media1.

    3.3 This desire by Canadians or more voices conrms

    Walter Lippmans amous observation that: The theory

    o the ree press is not that the truth will be presented

    completely or perectly in any one instance, but that the

    truth will emerge rom ree discussion.

    3.4 It is our belie that no single media source, or news

    channel, will ever be able to perectly refect the views

    and news interests o a country as diverse as Canada.

    And Sun News is improving our media by adding to its

    diversity and ensuring stories ignored by other media

    outlets are given air voice.

    THE NEWS

    MEDIA IN

    CANADA ISDOMINATED

    BY A FEW

    VOICES WHO

    ALL THINK

    ALIKE.

    57% OF CANADIANS AGREE

    23% OF CANADIANS DISAGREE

    23%

    57%

    3. Canadians Want More Voices

    FIGURE 3.1:

    Fig 2.0. p 5. Cable News and the Cable and Satellite

    Industry. Abacus Data Inc. 2012 AB ACUS DATA

    1. p 5. Cable News and the Cable and Satellite Industry. Abacus Data Inc. 2012

    AB ACUS DATA

    AB ACUS DATA

    4

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    Ensure that prime time television in French and in English iswritten, directed, stars, and is about Canada and Canadians.

    Jack Layton on the role of the CRCNDP.CA - http://www.ndp.ca/press/layton-will-restore-unding-arts

    Alex Pierson, Co-Host o AM Agend

    interviews Jack Layton and Olivia Chow on Sun New

    5

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    4.1 Despite this strong thirst or news alternatives in

    the market, Sun News has encountered enormous

    resistance rom Canadian cable and satellite

    providers when it comes to making the channel

    available to Canadians. In act, Sun News is only

    available in 4 out o 10 households. (Figure 4.1)

    4.2 What is even more concerning is distribution has

    declined since its launch. Until October 2011, Sun

    News was still operating its over the air broadcast

    towers in Ontario, which compelled Rogers,

    Bell Fibe and Cogeco to carry Sun News on

    analog digital basic cable service in most Ontario

    markets. Since shutting down our towers, Rogers

    has replaced Sun News on Channel 15 with

    their own all-news channel (City News Channel).

    Ironically, the ratings or City News Channel are

    signicantly less than those Sun News was getting

    when it occupied that dial placement. (Figure 4.2)

    4.3 While Sun News has chosen not to pursue an

    undue preerence complaint against Rogers or

    this action, it speaks strongly to the challenges

    we have aced when dealing with major Canadian

    cable and satellite providers.

    4.4 Even more surprising, BDUs like MTS and Telus

    are not oering Sun News at all! In case you were

    wondering, both Telus and MTS oer Al Jazeera,

    BBC World News and other oreign

    all-news channels.

    4. Carriage Chaos

    FIGURE 4.1:SUN NEWS IS ONLY IN 4 OF 10 CANADIAN HOUSEHOLDS

    5.1 Million6.7 Million11.6 Million

    TOTAL MARKET(CBCS NEWS CHANNEL

    DISTRIBUTION)

    SUN ON ANALOG

    & FREE PREVIEW

    SUN TODAY

    4/10

    HOUSE

    HOLDS

    CANADIANHOUSEHOLDS

    6

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    SOURCE: BBM: AMA, 2+, M - F, 5PM - 11PM, Ontario

    Average Minute Audience

    2,600

    16,400

    FIGURE 4.2:SUN NEWS PERFORMS BETTER THAN CITY NEWS CHANNEL IN ONTARIO

    APR18,

    2011-

    OCT31,

    2011

    OCT31,

    2011-

    DEC31,

    2011

    Krista Erickson,

    Host o Canada Live

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    5.1 Where Sun News is oered, it is oten done so

    in a manner which makes marketing the channel

    particularly dicult. For instance there are three

    dierent channel locations or Shaw customersdepending on which service they have signed up or.

    5. Location Matters

    FIGURE 5.1:NATIONAL VARIATIONS IN SUN NEWS CHANNEL PLACEMENT

    8

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    41%22%

    34%

    34% 22%

    26%

    FIGURE 5.2:SUN NEWS REGIONAL AWARENESS IS GREATEST IN FORMER ANALOG MARKETS

    In Ontario, awareness of the Sun News network was 57%overall but higher in Ottawa (60%), oronto (59%), andin the Greater oronto Area (61%) than in the rest of the

    province (50%).Abacus Report, pg. 33

    57%

    61%

    Awareness2to3

    times

    greaterwhereSun

    News

    hadanalogdistri

    bution!

    g 6.1. p 28. Cable News and the Cable and Satellite Industr y. Abacus Data Inc. 2012 AABBAACCUUSS DDATATAA 9

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    6.1 We are proud to be ollowing in the ootsteps o

    Canadian broadcasting legends like Moses Znaimer

    by oering viewers radically dierent approaches to

    news television. Our hard news and straight talk is ahuge departure rom the sae, traditional approach

    to news taken by our competition.

    6.2 While Sun News is not or everyone, it is or many

    o the Canadians that are rustrated with the lack o

    diversity in the current news options.

    6.3 Our research shows that seeing is believing. Once

    these discontent news viewers have been exposed

    to our approach to news, they like it.

    6. Seeing Is Believing

    FIGURE 6.1:SUN NEWS VIEWER DEMOGRAPHICS

    Demographic Group Sun News Viewership

    Male 66%

    Female 34%

    18 to 29 9%

    30 to 44 21%

    45 to 59 39%

    60 and over 31%

    Income less than $50k 39%

    Income $50k to $100k 40%

    Income over $100k 21%

    Specic Subgroups

    Low Income Seniors 12%

    Despite being inthe typical Sun News

    viewer demographic,most focus groupparticipants had neverheard of the Sun NewsNetwork prior to thefocus group session.When shown threeclips from variousprime time programs,almost all said theywould watch SunNews if they could getaccess to it.

    Table 6.0. p 29. Cable News and the Cable and Satellite Industry. Abacus Data Inc. 2012 AABBAACCUUSS DDATATAA

    p 30. Cable News and the Cable and Satellit

    Industry. Abacus Data Inc. 2012 AABBAACCUUSS DDAA

    Likelyanalog

    cablecustomers

    !

    Ezra Levant, Host o The Source

    10

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    Much o Sun News audience is lower income,and is heavily oriented to elderly Canadians onfxed incomes. Tese viewers are more likely tobe analog cable subscribers or reasons o cost

    and resistance to new technology.

    11

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    7.1 When you look at Sun News ratings over its rst year, it

    is easy to see the eect that distribution and dial positionhave on ratings perormance.

    7.2 When Sun News went rom 6.7 million households to

    5.1 million households it had a dramatic, negative eect

    on ratings, because the channel was no longer carried

    on analog and digital basic service. They went rom an

    average o 27,400 beore to 13,000 ater (Figure 7.2) 2+

    prime-time rom launch until December 31, 2011.

    7.3 The move rom Channel 15 on Rogers to Channel 142

    had a particularly negative impact.

    7.4 None o this is surprising. You cant watch a channel you

    dont get, and you are less likely to watch a channel that

    is in the stratosphere than one that is lower on the dial.

    7.5 With all o this in mind, it is not a mystery that Sun News

    is not well known in the market place. Just over one in

    three Canadians have even heard o Sun News. Less

    than hal that number has watched.

    7. Distribution + Dial Position = Ratings

    FIGURE 7.1:

    NATIONAL NETWORK AWARENESS

    38%

    89%96%

    Fig 6.0. p 27. Cable News and the Cable and Satellite Industry. Abacus

    Data Inc. 2012 AABBAACCUUSS DDATATAA

    Brian Lilley,

    Host o Byline

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    SunNewsNetworkWeeklyAudience

    FIGURE 7.2:DECLINE OF SUN NEWS AUDIENCE AFTER LOSS OF ANALOG SIGNAL

    13,000

    Apr 18 2011 - Oct 31 2011 Jan 2012 - May 2012

    BBM, 2+, 5P - 11P M-F

    27,400WITH ANALOG

    WITHOUT ANALOG

    13

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    8.1 None o these challenges existed or Sun News

    competitors when they launched. When CBC

    Newsworld was granted a license in 1987, it was given

    mandatory distribution in every Canadian household,

    and dial placement that was superior to that o its main

    competitor, the American news channel CNN. CTV

    News Channel had similar advantages when it launched

    in 1997.

    8.2 This preerential treatment continued or 21-years

    or CBC News Network and 13-years or CTV News

    Channel. That was the decision o the CRTC at the

    time, and it was the right decision. Without ensuring

    access to the market, cable news in Canada would have

    continued to be dominated by American news channels.

    8.3 The challenges o launching a new Canadian cable

    news channel have evolved, but they have notdiminished over the years. A larger television universe

    means Canadian channels need to compete with a host

    o oreign news channels Fox News, MSNBC, HLN,

    Bloomberg, CNBC, BBC World News, etc.

    8.4 When it comes to the amount BDUs pay or Canadian

    cable news services, a urther discrepancy exists.

    Cable and satellite providers paid CBC Newsworld

    $0.63/month per subscriber. It is worth noting the

    CBC amount was over and above the existing taxpayer

    subsidies paid to the state broadcaster.

    8. Fair Is Fair

    1987

    FIGURE 8.2:THE CANADIAN ALL NEWS LANDSCAPE

    2012

    63

    18

    CBC NEWS NETWORK SUN NEWS NETWORK

    PROPOSAL

    FIGURE 8.1:BDU CARRIAGE FEES

    14

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    66%

    10%

    NOYES

    When CBC Newsworld was granted a licence in 1987the CRC cited the need to maintain our

    Information sovereignty. Tat need continues today

    Decision CRC 87-904

    Do you think that new Canadian television all-news channels should

    be given a similar advantage to allow them to compete with CBC Newsand CV News?

    FIGURE 8.3:

    Fig. 5.7 p 25. Cable News and the Cable and Satellite Industry. Abacus Data Inc. 2012 AABBAACCUUSS DDATATAA

    15

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    9.1 The challenges o launching new Canadian channels

    has not diminished, nor has the important role the CRTC

    plays in ensuring Canadian content nds a place on

    Canadian television. As Pierre Juneau said: Canadian

    broadcasting should be Canadian.

    9.2 While the CRTC does not rule on the basis o public

    opinion, it is worth noting there is strong public support

    or the Commissions core mandate o ensuring original

    Canadian programming does not get sidelined

    (Figure 9.1).

    9.3 Opinion research also demonstrates the public is

    skeptical about Cable and Satellite providers when it

    comes to oering a choice o channels (Figure 9.2).

    9.4 In the past the CRTC has not only demonstrated

    steadast support or original Canadian content, but in

    ensuring new Canadian entrants have an opportunity

    to enter the market thus enhancing choice and

    competition. The most recent example would be the

    Canadian Government`s decision to reserve a portion

    the wireless spectrum or new entrants to the marke

    9.5 A lot has changed since 1987 when the CRTC granted

    license to CBC Newsworld with mandatory distributio

    The cable news market today is crowded with oreign

    cable news channels particularly American news

    channels.

    9.6 The one thing that has not changed is the importance

    that Canadian news channels be made available to ALCanadians.

    Very Important Somewhat Important

    Not that important Not at all important Unsure

    3%7%36%51% 3%

    How important is the CRC in ensuring Canadian cable and satellitesubscribers have access to Canadian television programming?

    9. Strong Role For The CRTC

    FIGURE 9.1

    Fig. 4.0 p 13. Cable News and the Cable and Satellite Industry. Abacus Data Inc. 2012 AABBAACCUUSS DDATATAA

    16

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    FIGURE 9.2:

    It is a highly competitive marketgiving consumers like you choiceand fair prices.

    It is an uncompetitive market where a

    few companies can limit choice andcharge high prices to consumers.

    Which of the following statements describes the cable and satellitetelevision Industry in Canada?

    Fig. 3.0 p 11. Cable News and the Cable and Satellite Industry. Abacus Data Inc. 2012 AABBAACCUUSS DDATATAA

    71%

    18%

    17

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    10.1 The business model or Sun News is similar to that

    o other all-news channels. Approximately 72%

    o our expenses are directly related to the cost o

    producing 96 hours/week o original television content

    everything rom salaries or news coverage across

    the country to technical production sta and the cost

    o operating our studios. Our revenues come rom two

    sources: distribution ees paid by cable and satellite

    providers (BDUs) and advertising revenues.

    10.2 The current distribution agreements Sun News has

    with cable and satellite providers are inadequate

    to support the channel, both in terms o price

    and penetration rate (only oered in 4 out o 10

    households). Additionally, the distribution challenges

    also negatively impact advertising revenues. As a

    result we project an operating loss o $17 million in2012, with urther losses going orward. This is clearly

    unsustainable.

    10.3 Should Sun News be successul in obtaining a

    mandatory distribution order, the CRTC would be

    responsible or setting the distribution ees paid

    by cable and satellite providers. For instance: in

    the past the distribution ee or CBC Newsworld in

    the anglophone market has been $0.63/month per

    subscriber.

    10.4 While it is an amount less than 1/3 what CBC

    Newsworld was granted, we believe Sun News can

    be nancially viable with mandatory distribution to allanalog and digital households with a distribution ee

    o $0.18/month per subscriber.

    10.5 Sun News, and its parent companies, will continue

    to assume a great deal o risk in this project. Our

    projections show that i we are able to achieve

    our aggressive advertising goals, Sun News will

    generate a modest operating margin o 2.9% in 2014,

    increasing to just over 9 % in 2017 (year ve). Due to

    the large capital investments needed to start up a new

    television network, we would not achieve a positivenet income until 2020 (year 7).

    10.6 Should the cable and satellite providers choose to

    pass the ull cost o Sun News to their customers,

    the nancial impact on the basic service would be

    negligible only $2.16/year per household.*

    *The cost would be $1.08/year per

    rancophone households.

    10. Financial Considerations

    FIGURE 10.1:

    New Canadian all-news channels should get the same advantages thatchannels before them received in terms of placement on the dial andsubscription fees.

    Fig. 5.0 p 19. Cable News and the Cable and Satellite Industry. Abacus Data Inc. 2012 AABBAACCUUSS DDATATAA

    71%AGREE

    9%DISAGREE

    18

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    11. Sun News Meets All Criteria

    11.1 Sun News actively and enthusiastically contributes

    to the goals laid out in the Broadcasting Act.

    Perhaps the most important demonstration o this is

    the sheer volume o original Canadian broadcasting

    we are producing 96 hours per week.

    11.2 We serve, saeguard, enrich and strengthen the

    political, social, cultural and economic abric o

    Canada by oering voice to a wide range o views

    rom Ezra Levant to Warren Kinsella and every

    point o view in between!

    11.3 In addition we are among Canadas most outspoken

    advocates or reedom o speech, which helps to

    ensure every point o view has an opportunity to

    be shared, regardless o ashion or controversy.

    We believe ree speech and a ree, diverse mediaare the oundation on which a stable, vibrant

    democracy is built.

    11.4 We are all about Canadian points o view. Our

    programming highlights the best o Canadian talent

    with hosts, commentators and contributors that

    refect the diversity o this great country be it

    by gender, race, region or religion. We are proud

    to promote the multicultural, multiracial nature o

    Canadian society and the special place o aboriginal

    peoples within that society.

    11.5 As a subsidiary o Quebecs largest media

    company, we appreciate the importance oCanadas linguistic duality. In act we live it every

    day as we work with our colleagues in TVA and

    Quebecor Media to share stories with our audience

    rom coast to coast and in both ocial languages.

    11.6 And we celebrate the values that make Canada

    great. Not just those laid out in the Broadcasting

    Act, but others that go beyond that; such as:

    hard work, patriotism, strong amilies and healthy

    communities.

    As Pierre Juneau said:

    Canadian broadcastingshould be Canadian.

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    12.1 In keeping with its proud history, we

    encourage the CRTC to rearm its role as

    the champion o original Canadian television

    content. To this end we request:

    i. Mandatory distribution o Sun News on all

    analog and digital basic service in Canada,

    rom January 1, 2013 until December 31,

    2017. Ater this ve-year period has ended,

    Sun News would be treated like other

    Category C services.

    ii. The rate paid to Sun News by Canadian

    BDUs would be set at $0.18/month

    per subscriber. *

    iii. Distribution in a lower dial placement than

    American and other oreign news channels.

    12.2 We strongly believe Sun News meets all the

    criteria laid out in the commission policy or

    channels seeking mandatory distribution

    on the basic service. The approach we are

    recommending passes other tests as well:

    12.3 i Canadian TV First

    Virtually no channel on cable today can

    compete with Sun News when it comes

    to generating 100% original Canadian

    programming. We are making 96 hours/week

    o new content that is o, by and or Canadians.

    And we are doing it without receiving a dime o

    taxpayer money. Not bad, eh?

    ii Fairness

    Our plan would allow Sun News to establish an

    audience under similar rules and regulations

    to those aorded CBC Newsworld and CTV

    News Channel or 21 and 13 years respectively.

    We dont begrudge our competitors in any

    way, we simply want the same rules that they

    enjoyed at least or the next 5-years

    iii Diversity

    Sun News greatly enhances news diversity in

    Canada. We expand debate, cover dierent

    news stories, and bring new Canadian voices

    to our public discourse. And all o that is

    healthy or our media and or our democracy.

    iv Precedence

    We also believe our plan is in keeping with the

    approach taken by the Canadian Government

    in allowing dierent rules or new entrants in

    the wireless spectrum auction. The Canadian

    Government made the right decision to bring

    new wireless players into the market then, andthey would be right now to do the same or

    Canadian all-news channels!

    *The rate would be $0.09/month or French

    language households.

    12. Our Ask

    CanadianTvFirst.ca

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    13. About Us

    13.1 Quebecor Media Inc.is a subsidiary o Quebecor

    Inc. (TSX:QBR.A) (TSX:QBR.B), one o Canadas

    most important holding company operating in the

    telecommunications and media businesses. Withmore than 16,000 employees, Quebecor Media

    Inc., through its subsidiary Videotron Ltd., is an

    integrated communications company engaged in

    cable television, interactive multimedia development,

    Internet access services, cable telephone services

    and mobile telephone services.

    13.2 Through Sun Media Corporation, Quebecor Media

    Inc. is the largest publisher o newspapers in

    Canada. It also operates Canoe.ca and its network

    o English and French language Internet propertiesin Canada. In the broadcasting sector, Quebecor

    Media Inc. operates, through TVA Group Inc., the

    number one French language general interest

    television network in Qubec, a number o specialty

    channels and the SUN News English language

    channel. Another subsidiary o Quebecor Media Inc.,

    Nurun Inc., is a major interactive technologies and

    communications agency with oces in Canada, the

    United States, Europe and Asia. Quebecor Media

    Inc. is also active in magazine publishing (TVAPublishing Inc.), book publishing and distribution

    (Sogides Group Inc. and CEC Publishing Inc.), the

    production, distribution and retailing o cultural

    products (Archambault Group Inc. and TVA Films),

    video game development (BlooBuzzStudios Inc.),

    DVD, Blu-ray disc and videogame rental and

    retailing (LeSuperClub Vidotron Ltd), the printing

    and distribution o regional newspapers and fyers

    (Quebecor Media Printing Inc. and Quebecor

    Media Network Inc.), news content production and

    distribution (QMI Agency), multiplatorm advertisingsolutions (QMI Sales) and the publishing o printed

    and online directories, through Quebecor Media

    Pages TM.

    SUN NEWS HAS BUREAUS IN

    Vancouver

    Calgary

    Edmonton

    Regina

    Winnipeg

    TorontoOttawa

    Montreal

    Moncton

    Washington, DC

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