I agree they could try to use weasel words to interpret the ruling that way, but I think the FCC’s intent is pretty clear and they wouldn’t take kindly to MSOs playing ‘rules lawyer’ and trying to get around the intent by contorting the meaning.  I get the feeling the FCC can be a pretty vengeful GM when the players act like jerks.  (It doesn’t say anywhere in the rule book that grenades can only be used once, so I can keep using the same grenade over and over…)

As to the problems – oh yeah, I don’t expect this to go smoothly.  MSOs may apply for extensions and waivers if they’re having problems getting the kinks worked out.  We’ll see in the next couple of weeks.  Though I’m betting most of them just do the usual and flip the switch, ready or not, and we end up with a lot of pain for a while as everyone tries to figure out how to make the new system work.

It really *shouldn’t* be hard.  All the installers generally do is call in the numbers off the card and the host device.  MSOs could just give consumers the same kind of phone access.  But, even better would be web activation because it could check the format of the data and provide pretty pictures of the cards pointing out where the numbers are, etc., to help reduce consumer confusion.

How this actually plays out is anyone’s guess at this point.