Local Homeowners, Churches and Small Business Organizations Oppose Former Secretary of Treasury’s Geithner’s Speech at the Commonwealth Club

May 20, 2014

Chairman Tom Wheeler

Commissioner Mignon

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                                        

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                                          
Faith Bautista

President and CEO, National Asian American  Coalition

    /s/ Jesse Miranda                                            

Jesse Miranda

Founder, Jesse Miranda Center for Hispanic Leadership

Former CEO, National Hispanic Christian Leadership  Conference

/s/ Sam Rodriguez                                         
Sam Rodriguez

President, National Hispanic Christian Leadership  Conference

    /s/ Charles Dorsey                                         

Charles Dorsey

Associate Pastor (Youth and Young Adults), COR AME Church, Irvine, CA

 /s/ Gilbert Vasquez                                        
Gilbert Vasquez

Chairman, Los Angeles Latino Chamber of Commerce

    /s/ Theresa Martinez                                     

Theresa  Martinez

CEO, Los Angeles Latino Chamber of Commerce

  /s/ Cathy Zhang                                             
Cathy Zhang

Executive Director, Chinese American Institute for Empowerment

    /s/ Robert Gnaizda                                         

Robert Gnaizda

General Counsel, Aforementioned Groups

 /s/ Mia Martinez                                           

Mia Martinez

Chief Deputy, National Asian American Coalition

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