Implementation of Section 103 of the STELA Reauthorization Act of 2014, Totality of the Circumstances Test

In this document, the Commission seeks comment on potential updates to the ``totality of the circumstances test'' for evaluating whether broadcast stations and multichannel video programming distributors (``MVPDs'') are negotiating for retransmission consent in good faith. The document seeks comment generally on the totality of the circumstances test, including whether and how the Commission should update that test. The document also seeks comment on whether there are specific practices that the Commission should identify as evidencing bad faith under the totality of the circumstances test.