The regulatory game has commenced, and Comcast is quickly making the case on why the proposed merger between itself and Time Warner Cable should go forward. Comcast sent a 175-page filing to the Federal Trade Commission that formally launches the review.

Inside the filing, Comcast maintains that the merger would not detract from consumer choice, nor would the combined company take away any broadband or TV choices for customers. Comcast is using the threat posed by Google and Apple as the rationale for the merger. The company maintains that the merger will allow it to stay competitive in an increasingly disrupted video marketplace.

Reading the filing, it comes across as though Comcast is a small company that made good. It is fighting off consumer groups that have been whipped into a fury over the potential monopoly Comcast presents. Groups have said that the proposed deal will create less choice, and restrict Internet access in areas where Comcast will be the only game in town.

Of course the company is fighting off those concerns, saying that the merger will allow them to improve the customer’s experience. A cable company with great customer experience. Now there’s a unicorn. Comcast also pulled on the heartstrings of the FTC, saying the merger will allow them to increase Internet access to the poor, and make the Internet a freer place. Right, the same company that made a deal with Netflix.

They go further in the filing, saying they are the David in the room, not Goliath. The company tries to point out that companies like Netflix, Amazon, Apple, Google and Facebook are bigger than them in terms of market cap and customers. On the market cap, every one of those stocks are momentum plays, Comcast is simply not. Two, comparing customer base with the likes of Facebook and Amazon is hoping the FTC is illiterate. The companies are in vastly different verticals.

To bolster its small company cred, the company had this gem of a quote in the filing.

“Last year, Comcast celebrated its 50th anniversary,” Comcast said. “Founded as a small company in Tupelo, MS, we’ve grown through five decades to become a cutting-edge media and technology company that employs 136,000 people across the country and beyond. We’ve grown organically and through acquisitions, from a one-product company showing a few broadcast channels, to a multi-product company offering consumers nearly unlimited choices today. We’ve invested to help build a robust broadband network — and we’ve been an industry leader in product innovation.”

Maybe they can innovate away from usage caps? Until then, the company is painting a rosy picture for the FTC as it seeks to cement the $45 billion merger with Time Warner Cable.

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