May 20, 2014
Chairman Tom Wheeler
Clyburn Commissioner Michael O’Rielly
Commissioner Ajit Pai
Commissioner Jessica Rosenworcel
Federal Communications Commission 445 12th Street, SW
Washington, DC 20554
Concerns about So-‐Called Competitive Mergers: A Need to Step Back in Context of Net Neutrality
Dear Chairman Wheeler and Commissioners Clyburn, O’Rielly, Pai and Rosenworcel,
This letter is written on behalf of a broad range of minority organizations that have previously filed comments expressing opposition to the proposed Comcast-‐Time Warner merger and have submitted initial comments in the past on net neutrality and spectrum auction sales in the context of the public interest. These parties have also met during the week of April 7th with four of the commissioners and/or their senior staff on net neutrality and the proposed Comcast-‐Time Warner merger, as well as on an expedited conversion, if it serves the public interest of the underserved, from landlines to wireless. The groups are the National Asian American Coalition, the Ecumenical Center for Black Church Studies, the Orange County Interdenominational Ecumenical Council, COR Community Development Corporation, COR AME Church of Irvine, Jesse Miranda Center for Hispanic Leadership, National Hispanic Leadership Conference, COR AMR Church of Irvine, Los Angeles Latino Chamber of Commerce and the Chinese American Institute for Empowerment.
The proposed AT&T acquisition of DirecTV for almost $49 billion appears to be partly motivated by a corporate perspective that (a) the proposed Comcast-‐Time Warner merger will be approved, (b) it is likely that such approval will also ensure the approval of a future Sprint-‐T Mobile acquisition and (c) a certainty that such will require other approvals of potential mergers, such as Charter Communications acquiring other cable companies.
Further, the issues surrounding net neutrality are too important to be obscured at this time by any mergers. Net neutrality decisions are likely to affect a broad range of potential competition, including the possibility that Silicon Valley companies, such as Google, Apple and Facebook, may more vigorously compete with telecommunications companies, both directly and indirectly.
We are not at this time taking any position regarding the proposed AT&T-‐DirecTV acquisition, except to note that it would be best if all pending mergers, such as the Comcast-‐Time Warner proposal, were put on the back burner. For example, a six-‐month hiatus would allow the FCC to concentrate on net neutrality issues and complete its first round on the spectrum auctions.
All of the above organizations will within the next two weeks provide initial comments on the net neutrality proposal, including, if necessary, comments on the impact of proposed net neutrality rules in the context of AT&T’s commitment on net neutrality, should it acquire DirecTV.
These comments will also be filed with the Federal Trade Commission and the antitrust division of the Department of Justice.
Most respectfully submitted,
/s/ Mark Whitlock
Executive Director, Ecumenical Center for Black Church Studies
Chair, Orange County Interdenominational Ecumenical Council
Chair, COR Community Development Corporation
Senior Minister, COR AME Church, Irvine, CA
/s/ Faith Bautista
President and CEO, National Asian American Coalition
/s/ Jesse Miranda
Founder, Jesse Miranda Center for Hispanic Leadership
Former CEO, National Hispanic Christian Leadership Conference
/s/ Sam Rodriguez
President, National Hispanic Christian Leadership Conference
/s/ Charles Dorsey
Associate Pastor (Youth and Young Adults), COR AME Church, Irvine, CA
/s/ Gilbert Vasquez
Chairman, Los Angeles Latino Chamber of Commerce
/s/ Theresa Martinez
CEO, Los Angeles Latino Chamber of Commerce
/s/ Cathy Zhang
Executive Director, Chinese American Institute for Empowerment
/s/ Robert Gnaizda
General Counsel, Aforementioned Groups
/s/ Mia Martinez
Chief Deputy, National Asian American Coalition