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Which consumer Offerings must be reported to The MLC separately from other Offerings?

Written by Admin | Apr 9, 2025 4:25:35 PM

DSPs must report each consumer Offering separately from any other consumer Offering. 37 C.F.R. 385.21(b) provides that:

“If a Service Provider includes different Offerings, royalties must be calculated

separately with respect to each Offering taking into consideration Service Provider

Revenue and expenses associated with each Offering.”

 

This includes Family Plan and Student Plans, each of which must each be reported as separate Offerings and separately from any other Offerings. Under 37 C.F.R. 385.2:

“Family Plan means a discounted Subscription Offering to be shared by two or more family members for a single subscription price.

Student Plan means a discounted Subscription Offering available on a limited basis to students.”

 

 This also includes bundled Offerings, which must each be reported separately from any other Offering (including other bundled offerings). Provisions defining different bundled Offerings can be found in 37 C.F.R. 385.2 and 37 C.F.R. 385.21.

Consumer Offerings are described in The MLC usage reporting documentation (whether for DDEX or SURF reporting) as “Service Configurations.” Reporting Offerings separately means identifying the Offerings as distinct Service Configurations in header/summary reports and then submitting separate Service Configuration detail files for each respective offering.

The full text of federal regulations cited above is available here.