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The FCC review of Comcast’s planned buy of...

The FCC review of Comcast’s planned buy of Time Warner Cable should focus on transaction-specific issues rather than general consolidation, Comcast Executive Vice President David Cohen told FCC General Counsel Jonathan Sallet and several other members of the commission’s task…

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force overseeing the transaction, said an ex parte filing in docket 14-57 Thursday (http://bit.ly/1pPNJL5). The combined Comcast/TWC won’t harm broadband and won’t have a 50 percent of the national broadband market as critics maintain, Comcast said. Recent data show that the combined company would have a 35.5 percent share of fixed broadband connections, and 15.5 percent if wireless broadband is included, said Comcast. National broadband market share is irrelevant anyway, because Comcast and TWC serve distinct geographic areas and mostly don’t compete for Internet service, Comcast said. “The transaction will change nothing about competition for such services.” The deal also doesn’t pose competitive concerns in the video programming market, Cohen said. The commission’s review shouldn’t focus on “the claims of programmers intent on using this proceeding to secure new or different business arrangements,” the filing said. Comcast’s per-subscriber programming costs increased more than 120 percent between 2004 and 2013, a sign that content providers have strong bargaining leverage, Cohen said. The deal doesn’t pose a competitive threat to advertising markets where Comcast’s cable systems and NBCUniversal’s stations overlap because “cable spot advertising and broadcast advertising are not close substitutes and, therefore, constitute two separate product markets,” Comcast said. Cable doesn’t have a strong role in the ad market, and only 7 percent of local ad revenue goes to cable, Comcast said. The deal will also have the benefit of facilitating the deployment of addressable ad technology that will be compatible with Comcast’s X1 platform and existing Comcast digital set-top boxes, Cohen said. Comcast has a number of successful initiatives connected to diversity “enhanced over the past three years by a variety of voluntary commitments Comcast made in connection with the NBCUniversal transaction,” Cohen said. “Comcast is a demonstrated leader in this area and stands by its ongoing efforts and partnerships, which will extend to the acquired systems,” the filing said. “Beyond that,” the initiatives connected to Comcast/NBCUniversal should not be linked to Comcast/TWC, Cohen said.