Graf gave the BBC four months to respond to criticisms that parts of its vast online service could not be justified as they did not fulfil the BBC's public service remit and were distorting the chances of commercial rivals.
He said that numerous areas were "not sufficiently distinctive from commercial alternatives, or were inadequately associated with public purpose to be justified by the remit".
The BBC has responded by pre-emptively closing five of its websites: Fantasy Football; What's On events listings; the Surfing portal; the Games portal and Pure Soap.
It claimed, however, that the closures were related to its internal public value test and not the Graf report.
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