Merger opponents alert state AGs on Comcast/NBCU

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The Coalition for Competition in Media has fired off a letter to the National Association of Attorneys General warning of the dangers they see if Comcast and NBCU are allowed to go ahead with their pending merger. CCM indentified 11 markets where the dangers are the greatest.


The letter was addressed to NAAG President Roy Cooper.

“The proposed acquisition of NBC-Universal by Comcast poses a grave threat to both consumers and competition,” wrote CCM. “The merged entity will be the largest provider of cable and internet services in the nation, as well as the owner of vast amounts of content up and down the cable dial, on the web and in other entertainment sectors. This broad horizontal and vertical integration will give Comcast unprecedented means and incentive to engage in anti-competitive behaviors that would be fundamentally harmful to consumers, competitors and workers. We write to commend those Attorneys General who have dutifully scrutinized the broad implications and potential harms of this merger and to respectfully urge the remaining members of the National Association of Attorneys General to similarly take action to protect the public.”

The 11 markets are locations where the merged entity would combine extensive cable programming distribution and with it, internet access, along with significant ownership of broadcast television facilities – including NBC- and Telemundo-affiliated O&Os — and regional sports networks.

The markets identified by CCM as being particularly worrisome are mostly very large, and include Boston, Chicago, Denver, Fresno, Hartford, Houston, Miami, Philadelphia, the San Francisco Bay Area, Tucson and Washington, DC.

CCM concluded, “Comcast has argued that this merger will spark innovation. However, there is scant evidence that this sort of market dominance drives innovation; it is far more likely to stifle it. Given these looming threats, it is imperative that Attorneys General closely examine the impact this merger will have on states and the local media markets therein. Based on that analysis, action must be taken to ensure these threats are mitigated.”

CCM members include Bloomberg, Common Cause, Concerned Women for America, Free Press, Greenlining, Mabuhay Alliance, Media Access Project, National Association of Independent Networks, National Consumers League, National Organization for Women, National Telecommunications Cooperative Association, NCAAOM, New Media Rights, Organization for the Promotion and Advancement of Small Telecommunications Companies (OPASTCO), Parents Television Council, Rural Independent Competitive Alliance, Sports Fans Coalition, WealthTV, Western Telecommunications Alliance, Writers Guild of America, East and Writers Guild of America, West.

RBR-TVBR observation: There is of course no telling if this merger will fly or not, but from what we’re seeing, we’d have to say it’s edging toward getting a green light. The devil, however, will be in the details, and by that we mean the conditions.