The Applicants maintain that "the proposed transaction presents no 'horizontal' competitive concerns" and "no cognizable threat of 'vertical' anticompetitive effects," and thus consumers and competition would not be harmed Significantly. The ACA respectfully and adamantly disagrees with both contentions. In its initial comments, the ACA demonstrated that: (1) the proposed combination of NBCU's and Comcast's programming assets would result in Significant increases in market power for the new Joint Venture, leading to higher prices both for multichannel video programming distributors ("MVPDs") purchasing this programming and for their customers; and (2) the proposed combination of NBCU's programming assets and Comcasfs cable distribution systems would result in MVPDs that compete with these cable systems paying Significantly higher prices for NBCU programming, which again would be passed on to their customers. In these comments, the ACA reinforces these conclusions based on information provided in key documents Comcast and NBCU have submitted to the Commission to date, and it demonstrates that the horizontal and vertical harms will be even more Significant and widespread than described by the ACA in its initial comments. Consequently, the Commission cannot find the proposed combination is in the public interest without first adopting complete, robust, and durable remedies to ameliorate these harms.
|2010 07 21 ACA Response to Comments FINAL (REDACTED - FOR PUBLIC INSPECTION).pdf||702.44 KB|
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