InfoJus     Publicaciones Periódicas     Comparative Media Law Journal     Número 6

Comparing Media Regulation Between France, the USA, Mexico and Ghana

Robert McKenzie

1. Introduction

Across the world, media organizations are regulated because of universal perceptions that media content and media operations can significantly impact economies, social policies, political debate and, above all, the lives of people. But people who travel to different countries often notice how different the media content can be from one country to the next. For example, in some countries there seems to be a fair share of violent content across television programs, while in other nations, such content is lacking. The same contrasting statements can be made about political, advertising, educational and sexual content. Often, such differences in media content are the result of legally binding regulations applied by governments or government agencies in an attempt to achieve societal goals that are consistent with prevailing philosophies for the given domestic media system.

This article compares the government regulation of media in four countries: France, the United States, Mexico and Ghana. These four countries represent a wide diversity in governmental approaches to regulating media. This particular selection also provides diversity along the following dimensions: there are two developed countries (France and the United States) and two developing nations (Mexico and Ghana); there are two North American countries (the United States and Mexico), one European country (France), and one African country (Ghana); and there are two English-speaking countries (the United States and Ghana), one French-speaking country and one Spanish-speaking country. Ultimately, this article should present some fascinating differences in the approaches to, and outcomes of, regulation in these four very different countries.

Regulation is defined in two senses in this article. In its broadest sense, regulation consists of any influences over media operations and media content —influences that are both external to and internal to media industries. The broad definition of regulation as influences conceptualizes regulations as coming not only from regulatory bodies that have a legal basis for their authority over media operations, but also from sometimes less visible entities such as the interplay between media providers, financers and users. In essence, the broad definition of regulation positions media content as being shaped by more than just government rules.

Therefore, regulation of the media can take on many forms and with varying levels of influence, ranging from hopeful suggestions by civil society groups, to binding recommendations from industry associations, to mandates from international organizations, to direct control by national governments — as well the many gradations of influence within this range. Most regulatory initiatives are aimed either at media content or media operations. Regulations aimed at media operations normally deal with technical parameters. For example, the International Telecommunication Convention (ITU) allocates radio band frequencies across the world. Regulations aimed at media content normally deal either with protecting the public from perceived harm, or with elevating the population´s knowledge or appreciation for culture.

However, because of the central role that national governments play in determining media content, regulation is also commonly defined in a more narrow sense as: the legally binding, government rules by which media organizations must operate. While the broader definition of regulation is addressed in this article in the section that defines regulatory bodies, the narrower definition of regulation is discussed in the comparisons of government regulation in the four countries. Much of the information gathered for this article comes from personal interviews I conducted with representatives of government regulators in the course of writing my book, Comparing Media from Around the World (to be published by Allyn and Bacon in September 2005). These representatives, along with their positions, are listed at the end of this article.

The rest of this article is organized according to the following sections. First, key regulatory terms are defined. Second, categories of regulatory bodies are described. Third, government regulations in each country are described. And fourth, government regulations across the four countries are summarized and compared.

2. Regulatory Terms

The discussion in this article contains three regulatory terms that are commonly used throughout the world. The first term is watershed (called `safe harbor´ in the United States), which means a specific time period late at night in which certain restrictions on content are relaxed because of the assumption that minors are not watching television or listening to radio. The second term is minutage, which means the total number of advertising minutes allowed during a prescribed segment of time (usually an hour). The third term is bumper, which is a momentary graphic image that appears on the television screen between regular programming and advertising, in order to create clear separation between the two types of content.

3. Regulatory Jurisdiction

Individual regulatory bodies rarely have exclusive influence over the operations of a media organization. In fact, different regulatory bodies sometimes exert overlapping influences on media operations. Sometimes these overlapping influences contradict each other in terms of what they expect from media organizations. To cite one specific example in the United States, the Federal Communications Commission (a government regulatory body) in the 1990s regulated that broadcasters provide a set amount of children´s programming, while the National Association of Broadcasters (an industry regulatory body) resisted the establishment of this FCC regulation on the grounds that broadcasters´ free-speech rights were being violated). These two forces led to contradicting influences for a period on the broadcaster´s content. Often, disputes between government regulatory bodies and industry regulatory bodies are resolved through a binding court system.

Nor is the authority of regulatory bodies definitive and absolute. Inevitably, as new technologies come into use and as societal expectations about media content react to the new technologies — both of which are being impacted by globalization — the authority and jurisdiction of regulatory bodies is constantly being reorganized. One particularly fascinating area of technological change involves the convergence of traditional mass media with newer personal media. Traditionally, telephony and electronic media have been regulated by separate government-related agencies. Increasingly, however, the technologies of computer, television, radio, satellite and cable are interlocking with each other in the delivery of content from global media conglomerates to different audiences, resulting in an increasing shift across countries to regulate all technologies under the same agency.

Another interesting area of change in regulation is actually the deregulation of broadcasting. In the past, electronic media have generally been regulated more strictly than print media because of a `scarcity of spectrum space´ argument. This argument posits the broadcasting bandwidth has a limited number of frequencies for use by broadcasters, which in turn limits the choices of content, which in turn implies that broadcast content has a more inescapable impact on the audience than print content. Consequently, broadcast frequencies have been allocated to companies with the provision that these enterprises fulfill certain obligations to the public in light of the privileged role they play in public discourse. In contrast, the thinking toward print media distribution has been that the space needed to distribute print media is much more elastic, which leads to a wide range of content choices, which in turn lessens the impact of a single publication on an audience. However, two technological developments are causing regulators to reexamine the scarcity-of-space paradigm that has guided regulation in the past. One is the use of electronic technology by print media to distribute content. The other is the growth of cable, satellite and web technologies to distribute content, which diminishes the importance of needing a radio or television frequency to distribute content electronically. The result of this reexamination has generally been an easing of broadcast regulation across the world.

A third notable area in which there is a general change in regulation throughout the world is the positioning or repositioning of government regulatory agencies as "independent" regulatory bodies. Such bodies are meant to be less vulnerable to direct political and governmental control by ministries, departments and powerful officials, and more inclined instead toward principles outlined in legislative and constitutional law. The positioning of regulatory bodies as independent agencies is generally accompanied by a greater role of the consumer marketplace in regulating media operations. Once again, propelling this change is the thinking that because of the proliferation mainly of electronic media outlets, it is no longer necessary for some governments to unilaterally control the output of media content.

Perhaps the most potentially expansive area for future changes in regulation will be the Internet. Because the Internet presents so many features of both broadcast and print media, and because the Internet is so global, national governments continue to struggle with the question of whether the world wide web should be regulated, whether it can be regulated and what the regulations should be. Nevertheless, as governments debate whether to bring Internet regulation under the authority of existing agencies, by default the web is being regulated in piecemeal fashion through legislation and through court cases — for example, the 2003 court ruling in France that Nazi memorabilia cannot be auctioned on French websites.

4. Categories of Regulatory Bodies

Visualizing a categorization scheme for regulatory influences across most or all countries of the world is a difficult but helpful process necessary for understanding regulations worldwide. A categorization scheme helps identify differences between significant areas of regulatory activity where important distinctions need to be made. Yet, because of the uniqueness of the cultural conditions that exist in each country, no set of regulatory influences between two or more nations is truly alike — though there are many similarities between regulatory influences in many countries.

Nevertheless, five basic categories can be used to group together the main regulatory influences in each country: government-related agencies and committees, professional (industry) associations, civic groups, advertisers and the media organizations themselves. The interplay among most of these regulatory influences was illuminated by Edward J. Epstein in News from Nowhere, a seminal book on this subject written from an inside perspective within the National Broadcasting Company (NBC) network in the United States. Below, the five main categories of regulatory bodies are distinguished along with the general reasoning for why such agencies come into existence:

    A. Government-Related Agencies

Across the world, governments establish agencies to regulate the media. In 2003, there were independent, central government-related regulatory agencies in 65 countries. Often, these regulatory agencies have more power than other regulatory influences in terms of setting the basic rules by which media must operate. Naturally, the areas of influence of a country´s government-related regulatory agency are closely linked to the nation´s culture and its prevailing philosophy for its media system.

Government-related agencies are bureaucracies that have official oversight over media operations. Sometimes, government-related agencies exercise direct control over all facets of media operations, while sometimes they are only able to offer suggested guidelines. Sometimes government-related agencies report directly to a department or branch of government, while sometimes they operate as independent agencies that interpret and administer regulatory functions required by law. A government-related regulatory agency is usually formed primarily to ensure that media organizations serve the public according to country-specific interpretations of what such functions should entail. Such interpretations of `public service´ can differ widely across cultures and countries.

Government-related agencies can engage in two main regulatory activities. One activity involves the enforcement of regulations already passed by the government. The second activity involves the development of regulations by the agency itself. These regulations are normally developed in accordance with the agency´s jurisdiction as defined by executive (president or prime minister), judicial (courts) or statutory (legislature) branch of government.

    B. Media Organizations/Professional Organizations

Media organizations regulate themselves individually and collectively. This form of regulation is known as self-regulation. Media organizations are the companies, corporations, foundations and other owners of media. In other words, media organizations are the television stations, radio broadcasters, production houses, newspapers, Internet providers, etcetera. that produce and deliver media content. Individual self-regulation is when, for example, a local radio station or a company owning many radio stations follows a policy against reporting suicides in news stories to avoid promoting copycat versions. Collective regulation is when, for example, a television station follows a policy of announcing weather alerts to meet public-service goals outlined by a professional organization to which that station belongs. Both individual and collective regulation is often implemented by media organizations in accordance with codes of ethical guidelines established by industry trade associations. Examples of such associations include the NAB (National Association of Broadcasters) in the United States and the Ghana Journalists Association.

Media organizations regulate themselves to respond to a range of conditions including competitor strategies, government mandates, civic pressure groups, interpretation of legislation and audience media use. Often media organizations negotiate with the government to engage in a kind of co-regulation where there is dialogue between the two sides to achieve mutually expected results through mutually agreed-upon regulation. This process is sometimes laborious, so media organizations regulate themselves in order to avoid government involvement in their operations. However, because of changes in technology accompanied by the rise of transnational media conglomerates, generally the power of a government to regulate media being distributed within its country borders has been diminished. For example, two television companies (TV 3 and Channel 5) have established their headquarters in London, Great Britain, so that their operations would be governed by less-restrictive British regulations compared to more-restrictive Swedish regulations (such as the prohibition against the targeting of advertising at children). TV 3 and Channel 5 are located in the United Kingdom but distribute content by satellite to viewers in Sweden.

    C. Civic Groups

Civic groups are normally assembled as non-profit organizations by activists because of a concern about various aspects of media operations. Such civic groups as the Parents Television Council (PTC) in the United States can be sophisticated and powerful organizations consisting of advisory boards, officers and millions of members. Often the primary motivating interest of a civic group is a moral commitment to prevent media operations or media content perceived as causing great harm to society. Two common areas of concern include the violation of an individual´s right to privacy by a news program and the potential of minors to be morally corrupted by content — such as cosmetic surgery and sexuality or profanity. Depending on the country, civic groups may have legal rights to assemble and voice concerns about media operations. But usually, citizens rarely have legal rights that make their recommendations automatically binding. Therefore, civic groups often attempt to exercise influence over media operations by filing legal challenges to impact on media content; questioning a station´s license renewal; contacting station programmers about content perceived to be offensive; or by making public pronouncements about purported unfair or unethical media practices in order to embarrass a media organization into compliance with the desired changes. For example, as reported on pages 1 and 48 of the September 20, 2004 Broadcasting and Cable magazine, the PTC continuously reviews prime time television shows and posts material it considers to be offensive on its website, where visitors are encouraged to fill out a complaint form online that the PTC will send to the Federal Communications Commission.

    D. Advertiser/Sponsorship Clients

In most private commercial media industries and in some state-owned non-commercial media enterprises, media organizations rely on advertisers and sponsors for significant revenue streams. When advertising or sponsorship is a major funding source for media operations, a less overt form of regulation can occur. This kind of regulation results when advertisers (or sponsors) exert implied requests or direct demands that the media organizations with which they do business refrain from delivering a certain kind of content or advertising (or sponsorship) monies will be withdrawn.

    E. Audiences

Audiences are obvious regulators of media operations. Without a viable audience, a media organization serves little purpose. To what extent the audience is relied upon to define the success of media content varies between countries and across the models that are used to finance media operations. Much of the reliance on audiences to justify content boils down to the means by which media are financed. In other words, if the primary or exclusive financial revenue stream is advertising, then the size or the financial proclivity of audiences will play a greater role in the regulation of media operations and content by perceptions of audience tastes.

Regulatory bodies seek to legitimize their authority through various combinations of legal doctrine. Civic groups generally tend to justify their sphere of influence by citing their rights of free speech, expression or opinion guaranteed by law. Professional organizations also generally justify their sphere of influence by citing their legal rights to free speech, expression and opinion, as well as their competence at responding to concerns raised by government and the public. Government-related agencies and legislative committees generally justify their sphere of influence by citing their rights to safeguard public interests through constitutional, statutory (legislative) or judicial law.

In the following section, regulation is compared across the four countries. As a reminder, government-related regulatory agencies are given a special focus in this section because of their pivotal and supreme role in shaping the boundaries of all the other kinds of regulation. Most of the information about state regulatory activity was gathered during interviews with senior government officials with the regulatory agencies mentioned in this article. This section shows that each government-related agency has a unique identity in terms of its legal foundation, its purview and its interpretation of what the domestic audience seeks or needs in terms of media content. Because there are so many government-related regulations covering a complex myriad of media operations and content, this article highlights standard and unique areas of regulation that compare across the four countries.

5. Regulation of the Media

    A. France

Most of the media law and policy in France is developed by the national government assuming a central role in the marketplace of media activity. At the heart of central government is the concept of a state. As Raymond Kuhn explains in The Media in France, the ethos of state is used to justify the central involvement of the national government in French media activities. Accordingly, the national government is not just an adjudicator of media policy, but is also a competitor in the marketplace of media consumption. The government does this by directly funding and supervising public broadcasters to provide content that meets cultural objectives. This situation in which the government regulates culture on both public and private television and for radio broadcasters is a defining feature of the media system in France.

In France, a press statute enacted in 1881 granted the print media freedom from government regulation by guaranteeing freedom of opinion and the right to publish. Similarly, the Internet is not regulated by a central government-related agency in France. However, broadcast media are actively regulated in France by the national government, though the nature of this regulatory area has changed. For decades, all broadcast media were exclusively owned, operated and regulated by the national government. But after 1982, the National Assembly enacted a law based on the principle that "freedom of communication is free". That law opened up the possibility for broadcast media to be owned and operated by private companies, and it established — as the name implies — that that broadcast companies need not pay a license fee for the right to use radio and television frequencies.

The main government-related agency for broadcast regulation in France is the CSA, or Conseil Supérieur de L´Audiovisuel (roughly translated as Supreme Audiovisual Council), which was formed in 1989 out of France´s first independent regulatory agency established in 1986. The primary oversight body for the CSA is the Culture Ministry. The governing board of the CSA consists of nine advisors: three of the advisors are nominated for the governing board by the French president; three are nominated by the president of the Senate; and three are nominated by the president of the National Assembly. Advisors come primarily from media industries or academia.

All television and radio operations — terrestrial, cable and satellite — fall under the regulatory jurisdiction of the CSA. The main authority of the CSA is to apply the law and decrees that are developed by the national government and to issue opinions to the national government about media law and policy. It is important to note that the CSA has the authority only to interpret and apply existing regulations, but not to develop new regulations — which is the prerogative only of the national government. CSA regulations cover three central arenas: renewing broadcast licenses for television and radio stations, issuing new licenses for television and radio stations, and disciplining radio and television stations for violating regulations. The licensing of media in France is mixed. Private broadcast media are licensed by the CSA. Radio stations are licensed for five years, while television stations are licensed for ten years. The licensing process is used to ensure that private broadcasters comply with public service obligations as interpreted by the CSA. However, public radio and television stations are not licensed because of the government position that broadcast frequencies are owned by the State, which means that it is not possible to license them or sell them. However, in exchange for use of the frequencies, both public and private radio and television stations have obligations to the State in terms of content. The Culture Ministry regulates those obligations by issuing decrees. Most of those regulations have to do with promoting culture. For example, one regulation stipulates that no films be shown on television on Wednesdays because films are traditionally released in cinemas that day. Public radio and television stations are funded through the government´s Department of Culture, which defines the specific public-service obligations that they are expected to meet.

In France, four areas of content regulation overseen by the CSA are particularly distinctive. The first general area of regulation is political pluralism. For example, as a precondition to the granting of a license, commercial French media are required to ensure that a wide variety of political voices are represented on television and radio. Based on this mission, the CSA awards licenses to radio stations with specific plans for program formats that add to a broad spectrum of political opinion. The result is that in France there is anarchist radio, socialist radio, extreme-right radio and many other political orientations on the air.

The second general area of government-related regulation in France is the protection of minors. In this area, there are two types of content that are prohibited before the watershed, which is defined in France as before 8pm. One area is erotic programming showing sexual penetration or sexual acts at close range. However, content depicting male and female nudity both before and after 8pm is allowed, as long as the programming is not of the erotic kind described above. Profanity in broadcasting content is not regulated by the CSA, but in general profanity is frowned upon by French people because it is considered ugly . The second area of content is violent programming, which is not allowed before the watershed if it is deemed to be gratuitous or overly graphic.

A third general area of regulation is protection of the French language through domestic content quotas. Adding to the EU policy wherein 50 per cent of all television programming must be of European origin, the French government requires that 40 per cent of this 60 per cent be of French origin. In addition, 35 per cent of songs on radio stations targeting teenagers must be of francophone origin (which includes French as well as African-French or Arab-French), while 60 per cent of songs on stations targeting seniors (aged 45 and over) must be of francophone origin.

A fourth general area of regulation is advertising minutage. A regulation stipulates that public television channels can air no more than eight minutes of advertising per hour, while private television channels can air no more than 12 minutes of advertising per hour. There are no limits on advertising minutage for radio.

The CSA uses two main powers of enforcement to elicit compliance with regulations. The primary power of enforcement is the fine, which the CSA can levy on broadcasters that violate regulations or statutory law. For example, the CSA routinely has fined radio and television stations for non-compliance with minimum quotas for French or Francophile programming. The CSA´s second power of enforcement is a mandatory admission of noncompliance. Under this power, the CSA can force a broadcaster to air a finding resulting from a CSA investigation that the broadcaster was in violation of a regulation.

    B. The USA

In the United States, media regulation is developed mainly by the Federal Communications Commission, but also by the legislative branch (the Senate and the House of Representatives) and, to some extent, the Supreme Court. Behind the design of this fragmented approach to media regulation is the notion that there should be a check and balance system between the branches of government. Media regulation in the United States follows a libertarian outlook that there should be minimal central government involved in the day-to-day operations of media organizations — where possible, the commercial marketplace should be primary influence on media operations and content. This situation of a primarily commercial marketplace of broadcasters in which there is minimal government interference is a distinctive feature of the media system in the United States.

In the United States, newspapers and the Internet are not licensed or regulated by a central government-related agency. Both newspaper and Internet content have been protected from regulation by the First Amendment, a 1788 Congressional Act creating several amendments to the Constitution. The First Amendment also serves as a guiding principle for the legal outlook toward the broadcast media, but it has not been afforded the same level of freedom as the print media. The rationale for this distinction has been that the broadcast media should be more accountable to public interests than the print media because the former is subject to less competition than the print media. This conclusion is derived from the argument that the broadcast frequency spectrum can only accommodate a finite number of radio and television channels, whereas there is virtually unlimited space to distribute print media. However, the proliferation of cable and satellite radio and television channels has diminished the "scarcity of space" argument to the extent that some regulations covering media ownership were relaxed by the Telecommunications Act of 1996.

In the United States, the main government-related agency for broadcast regulation is the Federal Communications Commission (FCC), which was formed by the Communications Act of 1934. The impetus for establishing the FCC was to create an expert agency to implement the policies and statutes of Congress, rather than have the legislature engage in a tedious process of crafting laws for every piece of media policy. Though the FCC to some degree implements court decisions, the primary oversight body for the FCC is Congress, through the Senate Committee on Commerce, Science and Transportation, and the House Committee on Energy and Commerce. Both of these committee designations make clear the view of media primarily as an activity of commerce. The governing board of the FCC consists of five commissioners, each serving a five-year term staggered with the others. The commissioners are appointed by the president and approved by the Senate. No more than three commissioners may be members of the same political party. The formation of an independent government-related regulatory agency for broadcast media symbolized by the FCC has served as a model for many countries that have sought to disassociate media regulation from control by central government. In France, for example, the CSA was modeled on some of the fundamental attributes of the FCC (though there are also certainly many major differences between the FCC and CSA).

All television and radio operations (terrestrial, cable and satellite) and all telecommunications (telephone and computer) fall under the regulatory jurisdiction of the FCC. The FCC has the authority to develop regulations grounded in existing legislation and to enforce such regulations. The FCC also has the responsibility to consult with Congress by issuing opinions about potential media legislation. Owing to a pervasive libertarian philosophy, the approach of the FCC in terms of regulatory activity is to let effective competition within the commercial marketplace have the first chance to regulate the operations of the media — especially in providing content. In other words, the FCC expects most regulation to be self-regulation by media organizations. For the most part, only when there is a widespread perception by the public, the government or the media that the marketplace is inadequately regulating the activities of broadcast media will the FCC consider developing new regulations or enforce existing regulations more strongly. FCC regulations must be based on the framework of existing legislation or court cases. Often, any new regulations will be designed specifically to stimulate effective competition as a means of regulating activities of the broadcast media.

In the United States, all broadcasters — both public and private — have to be licensed by the FCC. Radio and television stations are both licensed for a period of eight years. License renewals are staggered across the country so that they do not all come up for renewal at once. Licensing is used to ensure that both public and private broadcasters meet the public´s `interest, convenience and necessity´ — a standard that was specified in the Communications Act of 1934, and which covers both media content and media accessibility. However, the FCC does not regulate much media content, since the primary mechanism used for determining whether broadcasters are meeting this standard is the commercial marketplace.

In the United States, three areas of content regulation overseen by the FCC are particularly distinctive. One area, as indicated above, is indecency, which in the United States has a different legal definition than obscenity (the more punishable of the two activities). In the United States, the Communications Act of 1934 prohibits the broadcasting of obscenity at any time. Obscenity is defined by a three-pronged test arising out of the Supreme Court case Miller v. California, 413 U.S. 15, 24 (1973). Essentially, obscenity is defined as whether an average person, applying contemporary community standards, finds that a broadcast appeals to the prurient [appealing to unusual desire] interest. On the other hand, some indecent programming is allowed between the watershed hours (in the United States called the `safe harbor´ hours) of 10:00 pm-6:00 am. Essentially, indecency is defined by the FCC as `language that, in context, depicts or describes, in terms patently offensive as measured by contemporary community standards for the broadcast medium, sexual or excretory activities or organs´ (Infinity Broadcasting Corporation of Pennsylvania, 2 FCC Rcd 2705, 1987; see also FCC Policy Statement, 2001). Again, the barometer of what is considered to be indecent is the marketplace of consumers, which generally has reacted unfavorably towards broadcast media content containing nudity and profanity.

A second area of regulation is in the area of commercial advertising by a non-commercial broadcaster. In the United States, non-commercial broadcasters —public, college and university stations and community broadcasters— are strictly prohibited from airing advertisements. However under strict guidelines, non-commercial broadcasters are allowed to air sponsorships, which are defined by clear boundaries. Some of these guidelines include the prohibition of programming that urges the audience to buy anything, or gives a price out for or favorably describes a product or service.

A third area of content regulation emphasized by the FCC is children´s programming. Through a combination of a 1996 FCC Report and Order, along with the 1990 Congressional Children´s Television Act, a set of regulations was developed that require all television stations to provide children´s programming according to certain requirements. One requirement is that all stations must provide at least three hours per week of educational/informational programming for children — though it is left to broadcasters to define what educational and informational programming is. A second requirement is that bumpers must be aired between children´s programming and advertising. And a third requirement is that advertising minutage is limited to 10.5 minutes per hour on weekdays and 12 minutes per hour at weekends (this regulation is the only restriction on advertising minutage that broadcasters in the United States are required to follow). In addition, as part of the license renewal process, the FCC evaluates a television station´s overall commitment to children´s programming.

The FCC uses two main powers of enforcement to elicit compliance with regulations. The FCC´s first power of enforcement involves revoking a license or failing to renew a license, a rarely invoked power reserved only for cases where a broadcaster demonstrates willful and repeated disregard for the law. The second and main power of enforcement is the fine, which the Enforcement Bureau of the FCC can levy on broadcasters that violate regulations or statutory law. The FCC has some officers in the field looking mostly for technical violations. However, for violations of content-oriented regulations, the FCC relies more on receiving citizen complaints (as a function of the commercial marketplace). For example, in 2001 the FCC fined KKMG for airing unmistakably offensive sexual references from an Eminem song called `The Real Slim Shady.´ According to the Quarterly Report on Informal Consumer Inquiries and Complaints Released, in the third quarter of 2003, the FCC received 19,920 complaints relating to indecency and obscenity.

Overall, the FCC does not actively regulate broadcasting content in the United States. Rather, the default approach to influencing most media content in areas of violence, alcohol, advertising and indecency, is to let the consumer marketplace determine what is acceptable. Therefore, the FCC serves as a regulator of media content primarily when prompted by public outcry.

    C. Mexico

The federal government is directly involved in the regulation of broadcast media, though that involvement has diminished somewhat as Mexico has been in transition to an open democracy. The national government licenses all television stations and radio stations. Newspapers and the Internet are not licensed or regulated by a centralized government-related agency in Mexico. Most media in Mexico are commercial and privately owned. The Mexican federal government does not fund national television. However, state governments fund regional public television networks. The Mexican national government does partially fund a national 26-station commercial radio network carrying many different genres of programming (from rap to classical) through an organization called the IMER (Mexican Radio Institute). In addition, for one hour on Sundays, all radio broadcasters must offer their frequencies during The National Hour to transmit government information. The Mexican government owns the country´s main news agency Notimex, which distributes news information primarily to Mexican media. This situation of a primarily commercial marketplace with strong government regulation is a defining feature of the media system in Mexico.

In Mexico, newspapers were guaranteed freedom from government regulation by two articles (the 6th and 7th) of the Mexican Constitution, providing for freedom of the press and freedom of expression. There is no national association widely subscribed to by newspapers for adhering to voluntary codes of conduct in journalism; most Mexican newspapers voluntarily follow their own individual codes of conduct. However, it is necessary to explain that there has been another regulatory force for both Mexican newspapers and the broadcast news media: surreptitious intimidation. Especially prior to 1998 during the PRI´s 70-year control of government, reporters working on certain stories about government officials and activities have sometimes been prosecuted by the authorities, have received threatening anonymous phone calls, or have been subject to other forms of intimidation, ostensibly designed to persuade them to back away from certain news reports perceived to be unfairly critical. It is difficult to assess the effects of such acts of intimidation on the ensuing reports, but they have undermined the constitutional ideal that the press in Mexico is free. It remains to be determined whether 1998 marks the year in which surreptitious intimidation as a form of regulation is permanently on the wane.

The broadcast media in Mexico are strongly regulated by the government, primarily through provisions of the 1940 General Communications Law, which was updated by the Federal Radio and Television Law of 1960. In Mexico, all broadcasters have to be licensed to deliver content. The broader scope of Mexican law governing broadcasting can be described as permitting the country´s broadcast media to have general freedom in producing content, but requiring respect for government institutions. In Mexico, the greatest freedoms from media regulation are in entertainment content, while lesser freedoms exist for investigative journalism and even less for depictions either of the State or of symbols of the State (for example, the Mexican flag).

In Mexico, there are two main government ministries that regulate broadcasters, though regulatory powers over the media are distributed over several government agencies. The formation of these two ministries dates back to the 1940 General Communications Law. The heads of both of these ministries report directly to the president of Mexico.

One agency is the Communication and Transportation Ministry, which is staffed by officials who are appointed by the president. The ministry authorizes the technical licenses needed by broadcasters in order to operate. Licenses in Mexico take two forms: Concessions are licenses granted to commercial broadcasters, who have the right to air advertising. Permissions are granted to public broadcasters, who are prohibited from airing advertisements. In Mexico, the license period for all broadcasters is discretionary, with a maximum of 30 years. Typically, broadcasters are licensed for 15 years. Licensing is used to ensure that broadcasters follow government regulations.

The Communications and Transportation Ministry also coordinates the placement of government advertising in the broadcast and print media. Government advertising is placed in media through two methods. One is a commercial agreement between the government and a newspaper or a broadcaster for authorities to regularly buy airtime or newspaper space for official announcements. The second method is a tax levied on all broadcasters. This tax is payable by broadcaster to the government not in money but in airtime (as a condition for the privilege of holding a broadcast license). The scheduled airtime is an hour on Sunday evenings (called the National Hour) in which government announcements, policies and reports are broadcast.

The second government regulatory agency is the Interior Ministry (which handles internal affairs), which is also staffed by presidential appointees. The central division that regulates media within the Ministry is the Undersecretary for the Media. This division has the power to implement existing regulations emanating from Congress, but does not have the authority to develop its own regulations. It monitors radio and television broadcasts to determine whether regulations are being followed.

In Mexico, three main areas of content regulation are particularly distinctive. One area is advertising. In Mexico, public television stations are prohibited from airing any advertising. But private television stations, as well as public radio broadcasting on the government´s IMER radio network, are allowed to carry advertising. Advertising minutage across radio and television is restricted to the following amounts: six minutes per hour on cable and satellite television channels (cable and satellite television in Mexico is also known as `restricted television´); 18 per cent of total transmission time per day on television; and 40 per cent of total broadcast time per day on radio.

A second area of regulation is questionable programming on television, or programming that may communicate inappropriate values to inappropriate audiences. The Radio, Television and Cinematography division of the Undersecretary for the Media at the Interior Ministry uses a classification system to evaluate programming in accordance with the ages of the audiences that are assumed to be watching television at certain hours of the day. The Radio, Television and Cinematography division also works in conjunction with the Health Ministry to classify certain kinds of programming as unsuitable for certain audiences. The major areas of potentially inappropriate programming that are assessed under this classification system are sex, violence, addictions and language. All television programming exhibiting material in these areas must be submitted to and reviewed by the government before it can be broadcast. The classification system institutes increments of watershed time periods. For example, Classification `A´ programming is for All Audiences, and is allowed at any time of the day; while classification `B´ programming is for Teenagers 15 years old and older, and is allowed after 8 pm. One result of the classification process is that tobacco can be advertised on television, but not until 8 pm (a `B classification´ audience), and hard alcohol and prescription drugs can be advertised, but not until 10pm (a `C´ classification audience). All pharmaceutical advertisements must be submitted to the Health Ministry for approval before they are broadcast.

In the area of obscenity, terrestrial broadcasters are not permitted to broadcast nudity or profanity except in the context of a news program. In contrast, cable and satellite television broadcasters are allowed to broadcast some nudity and profanity; if they do so, they are expected to transmit such programming after 10pm. On radio, no regulations are in effect on profanity, but most broadcasters have responded to informal government requests to refrain from playing songs with profanity, or alternatively to bleep them out when they are aired.

A third area of regulation in Mexico that is distinctive is criticism of government. In the past, sharp criticism of government was not tolerated. Such criticism was met with threats from anonymous officials, prosecution of an individual by the government, or worse. But since 1998 the accelerated transition to an open democracy has paved the way for the Mexican media to be more openly critical of government actions. However, the Mexican media — including the print media — are still expected not to insult government officials and institutions, which may trigger government prosecution under criminal law.

The Undersecretary for the Media uses two main powers of enforcement to elicit compliance with regulations. First, fines can be levied for violations of any regulations. For instance, in 2003 terrestrial broadcaster Channel 40 was fined for corrupting language. However, in 2003 there was some discussion that the financial penalties no longer serve as an adequate incentive to comply with regulations since the amounts had remained the same for some 40 years. Second, the Interior Ministry´s Undersecretary for the Media can request that the Communications and Transportation Ministry revoke a broadcast license. The Undersecretary for the Media tapes programming of all television broadcasters in Mexico City, and all national television broadcasters. The monitoring is done by taping programs, and by deploying officials in the field to listen to radio stations or watch television stations.

    D. Ghana

In Ghana, the national government plays a limited role in regulating media. Regulations are passed by Parliament, but regulations and policies are administered by government-related agencies. Moreover, the pace of legislating regulations is cautious because Parliament is hesitant about unintentionally creating a media industry that leads the country back to a military dictatorship and to stalled economic development. The Ghanaian government provides some funding for a state-owned production company, which supplies programming to the state radio and television broadcasters. Furthermore, the Ghanaian government owns the Ghana News Agency (GNA), which distributes news information primarily to the country´s print and electronic media. This situation of an emerging marketplace in which state-owned media are making adjustments to the flourishing of private media, and both private and state-owned media are attempting to upgrade professionalism, is a defining feature of the media system in Ghana.

In Ghana, the 1992 Constitution guaranteed freedom and independence of both the print and electronic media. However, up until 2000, when an opposition party unseated the party that had formed the government since 1992, journalists were routinely intimidated into refraining from criticism of the authorities. For example, a common method of intimidation was for a military official to sit in the studio during a radio or television broadcast that involved news reporting or reporting on politics. In addition, journalists were imprisoned during this period under a Criminal Seditious and Libel Law if their reporting were deemed to be undermining the State. These two conditions led many journalists to engage in self-censorship. The government elected in 2000 began the process to repeal the Criminal Seditious and Libel Law, which was done in 2001.

In Ghana, two government-related bodies are responsible for regulating the media. The National Media Commission is responsible for regulating content and the National Communication Authority is in charge of the licensing of all telecommunication industries, including broadcasters. Both of these bodies were established by the 1992 Constitution.

The National Communication Authority (NCA) regulates the technical operations of all telecommunication organizations, including wireless, cable, satellite, terrestrial, telephone and the Internet. The NCA is staffed as follows: the director general is appointed by the president or a minister with presidential authority; the directors are appointed by the Board of the National Communication Authority; and the senior managers are appointed by the directors with final approval from the Board.

One of the main areas of regulation by the NCA is licensing. All telecommunications organizations — including Internet providers — have to be licensed by the NCA. In Ghana, the State owns the airwaves, which are leased to broadcasters through licensing agreements. One of the areas in which applicants for licenses are scrutinized is religion. The NCA takes great care to ensure a strict separation between Church and State. This does not mean that radio and television stations cannot provide religious programming. Rather, the intention is to avoid approving an application for a radio or television station offering programming that is dominated by proselytizing a specific religion.

In Ghana, broadcasters and Internet service providers are licensed for one year. License renewals are obtained by paying an annual fixed fee. Normally, the only circumstance in which licenses are revoked is when a company fails to pay the fee. Licensing is not used to stipulate that broadcasters or Internet service providers carry specific content. Licensing is used to approve the technical specifications with which broadcasters and Internet service providers must operate. However, if a radio broadcaster sets up a transmitter or a signal repeater to extend the transmission of content to areas outside the zone specified by the license agreement, the NCA will often ignore the infraction. Owing to a developmental philosophy for media operations, the reasoning is that such expansions are helping to develop the industry so that radio broadcasting is extended to outlying regions receiving little or no coverage.

The National Media Commission regulates media content, but does not fall directly under any government ministry. The National Media Commission was founded mainly to insulate state-owned media from government control, and on a larger scale to promote and ensure freedom and independence for the media to disseminate information. The National Media Commission is composed of 18 members nominated by various interest groups, including religious (Muslim and Christian) denominations, associations of private broadcasters, Parliament, the president, the National Association of Teachers and the National Council on Women and Development. The National Media Commission has a limited authority for regulatory oversight for both state and private media, and for both print media and electronic media (including the Internet). However, because of a lack of financial and other resources, the National Media Commission is not able to regulate the Internet. All newspapers must be registered with the Media Commission. The registration is used only to compile a database consisting mainly of how many newspapers there are, how frequently they are published and where they are based.

The National Media Commission has the authority to propose regulations to Parliament, but not to develop regulations. Instead of focusing on regulations, the National Media Commission relies on goodwill on the part of media organizations to adhere to guidelines that it set forth. The main purposes of providing these guidelines are to establish a code of conduct for ethics and professionalism in the media, and to provide a means of arbitrating complaints made by citizens about media content. The National Media Commission promotes the guidelines by publishing them in pamphlets distributed to media organizations and by conducting workshops for media workers, particularly journalists who are in the early stages of their career.

There are three areas of content guidelines that are particularly distinctive in Ghana, most of which are oriented toward developing a self-sustaining and professional media industry that contributes to a stable democracy and helps to develop the country itself. The purpose of this larger effort is to ensure that the media act as a counterbalance to any potential government efforts to assert authoritarian control. In other words, the operating assumption is that a vibrant media industry will help Ghana continue down the path of democracy.

The first area of content guidelines is political reporting. Most of the guidelines in this area are designed to ensure free and fair campaigns and elections. The guidelines include: balancing discussion of personalities with analysis of the issues; making party manifestos intelligible to the electorate; remaining impartial; refraining from activities that compromise the integrity of the journalist; and avoiding the promotion of violent or ethnic conflict. This latter guideline fits in with the national movement to encourage citizens to think of themselves as Ghanaians first, and regional or tribal communities second. When the National Media Commission wrote this guideline it was particularly mindful of the generally accepted perception that the media had inflamed ethnic divisions in the neighboring African country of Rwanda, which resulted in a bloody civil war and a prolonged campaign of ethnic cleansing. In addition to the political reporting guidelines mentioned above, one of the more strongly asserted guidelines is that the state-owned media should, under no circumstances, endorse candidates for political office.

A second area of content guidelines is rejoinders. This guideline refers to a constitutional guarantee that if media content contains a statement about or against a person, that individual has the right to require the medium to carry a rejoinder — that is, a reply by the person in question to the statement. The preface of the pamphlet detailing the Guidelines for the Publication of Rejoinders acknowledges the precarious position of the National Media Commission in relying on the goodwill of media organizations to gain compliance: "It has not been easy enforcing the constitutional demand for mandatory rejoinders. But if the Commission is to succeed in its endeavors to persuade people not to take the media to court, then their right to rejoinders must be protected".

The rejoinder guidelines are based upon the responsibility of the National Media Commission to protect the rights of individuals from abuse by the media. The guidelines specify that: the aggrieved person or his/her authorized agent can write the rejoinder; the same prominence must be given to the rejoinder as the article or news item that made the statement; it should be made clear by the medium carrying the rejoinder that it is indeed a rejoinder; that media organizations must carry a rejoinder within a reasonable amount of time; and all rejoinders must be copied to the National Media Commission. The guidelines also state that if a rejoinder contains libelous information, the matter may be referred to the National Media Commission.

A third area of content guidelines is broadcasting standards. Some of those standards revolve around promoting a national identity for Ghanaians. For example, two guidelines urge broadcasters to promote national development as a major priority; and to facilitate the participation of marginalized individuals and communities in setting national priorities. But most of the guidelines revolve around protecting Ghanaians from harmful media content. Some of the more distinctive guidelines include ensuring that documentaries about sexual themes do not make public and explicit what should be private and exclusive; presenting drunkenness and robbery only as destructive habits to be avoided or denounced; avoiding advertisements for alcohol that claim it has therapeutic qualities; avoiding the presentation of alcoholic drinks being consumed in a working environment unless it is clear that the working day has ended; avoiding language or scenes likely to incite crime or glorify war; broadcasting programs of an adult nature after 10:00 pm; and refraining from religious programming that attacks or ridicules other religions.

The National Media Commission does not have strong enforcement powers for the guidelines it promotes. The Commission does not have the power to levy fines or withdraw licenses. The main procedure for gaining compliance with the guidelines is an arbitration process headed by a Settlement Committee. This process involves the hearing of a case between the aggrieved party and representatives of the relevant media organizations. In 2003, 47 cases went before the Settlement Committee. If a judgment is reached in favor of the aggrieved party, the Settlement Committee will request that the media organization publish or broadcast a retraction, an apology, or the findings of the Committee. For example, one case involved a complaint by the ownership of a hotel against a newspaper headline titled `How Top Hotels duped Ghanaians´. This case was resolved when the newspaper published a retraction of the association of the hotel with the allegations in the story. Often the Settlement Committee sends out a press statement with the preferred wording to be published or broadcast. Though the Committee relies on the goodwill of media organizations to accede to the request, the outlets almost always comply — in large part to avoid government becoming more actively involved in media regulation. If the Committee does not find in favor of the aggrieved party, then the complainant can take the case to the Supreme Court — but not until the Settlement Committee has reached a judgment.

6. Comparative Summary

Now that government regulation of media has been described for each country, it is necessary to provide comparisons of the major areas in which the nations are similar and different. The table below summarizes the comparisons of regulatory activities in each country.

Summary Table Comparing the Regulation of Media

The first area of comparison is where the regulatory agencies across the countries are located within the government structure. Mexico locates its regulatory bodies mainly within government ministries. The country also splits regulating functions into two governmental bodies. France and the United States locate regulatory bodies in independent agencies under governmental oversight. Ghana locates a quasi-regulatory body in an independent commission.

In addition to observing where the regulation agency is found within the structure of government, it is interesting to note the larger social function that the regulation of media content is perceived to be fulfilling, as indicated by the name of the main government agency, body or committee with regulatory oversight authority. For example, France regulates media as an extension of culture. The United States largely regulates media as extension of commerce. Mexico largely regulates media as an extension of communication and transportation. Ghana largely regulates media as an extension of developing democracy.

The second area of comparison is the power enjoyed by the regulatory agencies in the different countries. The power of media regulators is determined by the total reach of a regulator across the following array of activities: the types of media operations it oversees; the ability to develop regulations in addition to enforcing them; the authority to elicit compliance with the regulations; and the propensity to be actively involved in regulation of the marketplace. The US FCC has the power to develop regulations, to regulate content and to fine violators. However, the FCC historically is reluctant to regulate content except in the area of potentially indecent material. France´s CSA has the power to enforce regulations on content (but not to develop them), and to fine violators. The areas of content that are highly regulated include culture and French-language quotas. Mexico´s Interior Ministry Undersecretary and Communication and Transportation Ministry have the power to develop and enforce regulations with the consent of higher levels of government. But Mexico is not as active in stipulating content as France or the United States, except in the area of potential denigration of the government. Ghana´s National Communication Authority and the National Media Commission have the weakest concentration of power. The National Media Commission is mainly an advisory body without the power of enforcement, and the National Communication Authority sometimes puts aside existing regulation to help encourage the development of a telecommunications infrastructure.

The third area of comparison is which of the four media outlets — newspapers, radio, television, Internet — are regulated by the countries. Most of the countries —France, the United States and Mexico — center their regulations on radio and television. Ghana has newspaper licensing, but applies minimum regulation through that process.

The fourth area of comparison includes the content areas that are targeted by regulations in the countries. All the countries in some shape or form regulate taste and decency, which often comes down to nudity and profanity. The United States strongly regulates media to prevent nudity and profanity. France has strong and specific regulations protecting children. Many of these regulations are also tied in to regulations limiting advertising, though advertising content is regulated by most of the countries for other reasons as well. France has regulations to protect national culture and/or national media production. Two of the countries — the United States and Ghana — weakly regulate advertising in terms of minutage requirements and content restrictions. Ghana has regulations limiting religious content, in response to the pervasiveness of religion in the country and the perception that the communication of religious divisions in media content may promote social instability.

Each of the four countries has government regulation of the media located in very different agencies, with different concentrations of power, and with different connections to governmental authority. Each of the four countries has government regulation that responds to a different set of conditions in each nation. It could be surmised that the main conditions impinging media regulation include: commerce in the United States, culture in France, poverty and development of national infrastructure and democracy in Mexico and similarly poverty and development of national infrastructure and democracy in Ghana. Though Mexico and Ghana display a similar set of conditions, the approaches to regulation are quite different. In the end, perhaps the biggest differences between the four countries center on where the government regulatory bodies are located in the state structure. The United States and France both have independent agencies. Mexico has two government agencies. And Ghana has one government department and one independent advisory agency.

7. Research Interviews

Ivor Agyeman-Duah, Head of Public Affairs, Ghana Embassy, Washington DC, USA.

Miguel Ángel Sánchez de Armas, Director of Radiotelevision of Veracruz, Mexico.

Abdulai Awudu, Head of Production, Television Africa, Ghana.

Angel Martinez Armengol, Website Coordinator, Diario Xalapa newspaper, Mexico.

Lydia Boakye, Editor, Ghana Broadcasting Corporation, Ghana.

Nana Essilfie-Conduah, Head of Current Affairs, TV Africa, Ghana.

Jon Henley, Paris Bureau Chief, The Guardian newspaper.

Ivonne Gutiérrez Carlin, Managing Editor for La Politica newspaper, Mexico.

Mario Lozano Carbonell, Coordinator of Information at Avan News, Mexico.

Joseph E.T. Dottey, Deputy Executive Secretary, National Media Commission, Ghana.

Waddick Doyle, Chair of the Department of International Communication, American.

University of Paris, France.

Bernard Forson, Deputy Director-General, National Communications Authority, Ghana.

Raymundo Jiménez Garcia, Columnist, Imagen de Veracruz newspaper, Mexico.

Mario Daniel Badillo González, Media Analyst for the Office of the Governor of the State of Veracruz, Mexico.

Miguel Valera Hernández, Coordinator of Information, Punta Yaparte newspaper, Mexico.

Daniel Kenu, Senior Reporter, Sports, Ghana News Agency (GNA), Ghana.

Alvaro Lozano, Legal Director for Radio, Television, Cinematography, Interior Ministry, Mexico.

Messan Mawugbe, Director of Research and Monitoring, National Media Commission, Ghana.

Isabelle Mariani, Director of International Affairs, Conseil Supérieur De L´Audiovisuel (CSA); Maitre de Confèrences à l´Institut d´Etnoles Politiques de Paris; Charges de Couter France à l´Université de Paris I, France.

Catherine Mathis, Vice President of Corporate Communications, The New York Times Company, New York.

José Ortiz Medina, Columnist, Coordinator of Information, The Local Milenio Newspaper, Mexico.

Julie McCatty, Chief Press Officer, The UK Radio Authority, UK.

Yvonne Mignot-Lefevre, Researcher, Centre National de la Recherche Scientifique, University of PARIS VII, France.

Felice Nudelman, College Marketing Manager, New York Times newspaper, New York, USA.

Carlos Antonio Ortiz, Contacto Informativo, Mexico.

Sam Quainoo, Professor of Political Science, East Stroudsburg University of Pennsylvania, USA.

Mike Perko, Chief of Office of Communications and Industry Information, Federal Communications Commission (FCC), USA.

Ebo Quansah, Editor, Evening News newspaper, Ghana.

Ekuba Quarmine, Producer, Ghana Television, Ghana.

Seth Quarmine, Public Relations/Media Coordinator, ArtRack, Ghana.

Leonel Bellido Villa, Coordinator of Engineering, Radiotelevisión de Veracruz, Mexico

Ernesto Villanueva, Coordinator of the Law and Information Department, National Autonomous University of Mexico, Mexico.

Patricia Boakye Yiadom, Editor, Ghana Broadcasting Corporation.

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