Comcast, NBC Universal and GE maintain that critics of the proposed $30 billion joint venture should have offered up "facts,logic, and rational argument" to support claims of transition-specific harms, not "the hyperbole, speculation, and
even character assassination that several opponents employ."
Their positions were stated in a 300-plus page filing at the Federal Communications Commission (and that was the redacted version) responding to those that petitioned the agency to deny or otherwise criticized the deal. The deadline for replies was July 21.
The bottom line from Comcast: the deal is a primarily vertical meld between companies that will not "possess market power in any relevant market," a pro-consumer, pro-competition deal that deserves a thumbs up.
As for issues like network neutrality, media consolidation, and program access, Comcast called them extraneous, pre-
existing and industrywide, noting that they are properly addressed, and are already being addressed, in other
"To the extent that the commenters allege that Comcast or NBCU has violated any rule, the commission's existing complaint processes are the proper place for such allegations to be considered," the parties said. "In any event, any allegations of rule violations in the instant record are without merit."
Comcast said that the deal has significant public-interest benefits, including those derived from the "marrying of content and distribution," which will spur innovation and competition. Moreover there will also be "tangible and verifiable voluntary
commitments" the company has made to diversity, localism and other public-interest goals.
Comcast argued that the three economic reports, hundreds of thousands of pages of documents, answering more than 150 questions, and reams of supportive comments from fans of the companies, "the overwhelming weight of the factual, legal, and economic evidence shows that the transaction is pro-competitive, pro-consumer, and in the public-interest. Accordingly, the commission should approve it expeditiously."
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