Comcast, NBCU and GE say 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
That came in a 300-plus-page filing at the FCC (and that was the
redacted version) responding to those who petitioned the FCC to deny or otherwise
criticized the deal (the deadline for replies was July 21).
The bottom line from Comcast is that 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 and deserves a
As for issues like network neutrality, media consolidation and
program access, Comcast calls them extraneous, pre-existing and industry-wide,
and says they are properly addressed, and are already being addressed, in other
proceedings. "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," they said. "In any event, any allegations of rule
violations in the instant record are without merit."
Comcast says that the deal has significant public interest
benefits, including from the "marrying of content and distribution,"
which it says will spur innovation and competition, and from the "tangible
and verifiable voluntary commitments" the company has made to diversity,
localism and other public interest goals.
Comcast argues 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."