Is Comcast-Time Warner Cable "In the Public Interest"?

On April 8, 2014, Comcast announced that it and Time Warner Cable have officially filed their joint Applications and Public Interest Statement with the Federal Communications Commission. This kicks off the formal regulatory approval process for a proposal that has garnered lots of media attention. Comcast and Time Warner Cable argue that the proposed acquisition is “pro-consumer, pro-competitive, and will generate substantial public interest benefits. This week, we take a look at the companies’ claims.

The FCC will approve a proposed ownership transaction if, after weighing “the potential public interest harms of the merger against any potential public interest benefits,” it concludes that, “on balance,” the transfer “serves the public interest, convenience and necessity.” The FCC will focus on “demonstrable and verifiable public interest benefits that could not be achieved if there were no merger.” So, does Comcast + Time Warner Cable = public interest? Here’s what the companies claim.

I. Benefits for the Combined Company

The combination of Comcast and TWC will create a world-class communications, media, and technology company significantly better positioned than either company alone to bring consumers the advanced services they want now and will need in the future and to keep America at the forefront of technology and innovation. The transaction will enable Comcast to continue to meet the challenges ahead in this increasingly dynamic, expanding, and competitive marketplace, and to ensure that customers enjoy all the benefits that Comcast and TWC have offered to date and stand ready to deploy in the future.

A few powerful economic mechanisms will drive the core competitive benefits from the transaction: (a) economies of scale, (b) expanded geographic reach, and (c) sharing of technologies and services:

• Dr. Gregory L. Rosston and Dr. Michael D. Topper argue that scale can make the difference between investing in a new product or service and not investing, and it can accelerate the introduction of products, services, and network and equipment enhancements. Since cable operators now pass the vast majority of homes in their respective franchise areas, they increasingly need to compete for customers with satellite companies, telcos, and other distributors by making investments in the development of new platforms and services and upgrading their networks, all of which have large fixed costs. Having a larger scale can accelerate investment in development and deployment of new technology [and] . . . may make it profitable to hire more developers and engineers and thereby achieve the same technological improvements in less time.
• The expanded geographic reach and additional geographic clustering made possible by a combination of firms will also increase the economic efficiencies by enhancing the ability of the combined entity to serve customers whose needs span the existing geographic footprints of the two firms.
• By combining their portfolios of products and services, the companies will be able to provide more products and services at lower cost than they would be able to do on their own. It will be more efficient for Comcast and TWC to provide these services as a combined company because the two firms use similar inputs in creating these services. In addition, each company brings proprietary technology and specialized knowledge about providing its unique mix of products and services.

The incremental scale will promote continued innovation by providing a broader base of customers across which to spread the high fixed costs of research and development. Larger scale and scope will help the combined company attract more collaborators and partners more easily throughout the ecosystem.

Comcast says it is committed to putting efficiencies and synergies of this transaction to work to forge a faster path to all-digital systems, higher broadband speeds, more advanced video and voice services, a more secure network, better system reliability, and other benefits to consumers, businesses, and the public interest generally.

II. Benefits for Consumers

A. Broadband
The additional investments and innovations that are needed now to deliver the broadband services consumers demand and need will be more rapidly, effectively, and efficiently achieved by the combined company than either company could achieve alone. Comcast says that approval would accelerate the deployment of advanced telecommunications capabilities and promote more infrastructure investment. Consumers in Time Warner Cable markets will benefit directly from the upgrades Comcast intends to make to Time Warner’s broadband service.

• While Time Warner has plans to upgrade broadband speeds to 75% of its footprint over three years, Comcast intends to extend its higher speeds to the TWC systems on an accelerated and most cost-efficient basis. The goal is to bring the TWC services up to Comcast levels.
• The transaction will enable Comcast to bring Converged Cable Access Platform-enabled Cable Modem Termination Systems to all of TWC’s customers, and more quickly than TWC could alone. Converged Cable Access Platform (CCAP) is a new technology that enables Comcast to deliver downstream speeds in excess of 250 Mbps and upstream speeds in excess of 50 Mbps.
• The CCAP technology upgrades, in turn, will facilitate the deployment of the next generation of cable modem technology -- DOCSIS 3.1 -- which Comcast expects to start deploying soon after the expected finalization of the specifications in 2015 (assuming equipment availability), ahead of any other broadband provider. DOCSIS 3.1 technology will be capable of delivering speeds of several Gigabits per second. The broader scale afforded by the larger combined company will mean that ultra-fast broadband capability made possible by DOCSIS 3.1 will be deployed not only more quickly to the acquired TWC systems than it would be otherwise, but also on a more cost-efficient basis across the combined company’s footprint.

B. Backbone
The scale and geographic efficiencies created by the transaction will facilitate Comcast’s continued investment in and deployment of its backbone and dark fiber network, and may even accelerate these efforts. By combining the companies’ core networks, the transaction will lead to additional innovations around capacity and architecture that will allow Comcast to reach more commercial customers on a single network with potentially reduced latency for national enterprise customers. The additional scale facilitated by the merger may accelerate Comcast’s contemplated upgrades to its national backbone infrastructure. Moreover, where Comcast has systems in geographic proximity to those of TWC systems, the transaction should make it profitable for Comcast to invest in new Converged Regional Access Networks (CRANs) supported by new regional data centers. Such investments would improve the quality of the network to the benefit of residential and business customers, as well as edge providers, through, among other things, improved scalability and resiliency of the network, lower latency through the deployment of more fiber, and increased points of interconnection.

C. Wi-Fi
The transaction will ensure that TWC customers enjoy access to advanced in-home Wi-Fi gateway devices which will help position the company to offer all its customers tomorrow’s upgrades. The substantial broadband infrastructure investment made possible by this transaction will also lead to greater access to many more public Wi-Fi hotspots to qualified Xfinity (Comcast) customers.

The transaction will provide a more seamless fabric of Wi-Fi connectivity across the combined company’s footprint. The combined company will enjoy the geographic reach, economies of scale, customer density, and return on investment needed to expand Wi-Fi hotspots across the combined footprint, in part because Comcast will internalize the benefits of a greater number of Wi-Fi access points to legacy Comcast customers who travel in the TWC footprint, and vice versa.

D. Advanced Video Technologies
A larger video customer base will facilitate accelerated investment by reducing the effective costs of innovation on a per-subscriber basis. According to Dr. Israel, “[b]y allowing the combined firm to amortize fixed cost investments over a larger base of customers, the transaction is likely to generate new investment and innovation that would not have been profitable absent the transaction. The economic logic behind this conclusion is simple and well established.” As a result, the combined company will be better able to take risks on developing and deploying advanced video products and services to all of its customers.

Investing in the video platform and video technologies in turn helps produce new opportunities for content providers -- by offering, for example, more video on demand (VOD) capacity, more HD opportunities, and TV Everywhere.

Improving cable services for customers -- adding channels, improving picture quality (i.e., high-definition), adding advanced features, offering faster broadband speeds -- depends on securing additional bandwidth. The transaction will allow TWC’s transition to all-digital to be accelerated, and Comcast’s substantial experience working through the various complexities of an all-digital transition in a disciplined and sustained effort will enable the transition in the TWC cable systems to take place more efficiently and with less customer disruption. As a result of these upgrades, customers on TWC systems will enjoy more innovative video products and faster broadband speeds on an accelerated basis.

The combined company will be able to invest ever more in centralized service systems and improvements and will bring a dedicated effort to improving performance in the TWC markets.

Comcast has more extensive programming rights and a broader VOD and online catalog than TWC. These rights, along with the upgrades Comcast would bring to TWC’s VOD infrastructure and broadband network, will provide customers in the TWC markets with access to more programming choices in time, particularly in terms of VOD and TV Everywhere options. Comcast will extend its broad VOD programming rights to the TWC systems as soon as its contracts permit, and as soon as the planned upgrades to the TWC systems permit the delivery of this much larger content library to customers.

The transaction will also bring the Xfinity TV Store to TWC customers. The Xfinity TV Store gives customers the ability to purchase movies and TV shows for downloading and streaming -- often weeks before they are available to rent or purchase on Blu-Ray and DVD -- and store them in the cloud. The increased scale from the transaction will allow Comcast to improve the economics of investing in significant fixed-cost programming rights (such as streaming VOD and other digital rights) to provide greater value to customers.

Greater scale and denser geographic coverage will also create marketing efficiencies that are particularly important for the roll-out of services like TV Everywhere that may require aggressive -- and expensive -- marketing campaigns to educate and attract consumers. As Drs. Rosston and Topper explain, the combined company’s added scale also will accelerate innovation by allowing Comcast to provide fully-featured apps for more third-party devices more quickly by spreading these fixed costs across a greater number of customers.

Comcast’s X1 platform gives customers unmatched interactive TV functionality featuring a user interface and other product features that “revolutionize” customers’ viewing experiences. The combined company may be able to begin deploying Comcast’s X1 entertainment operating system within the first year in certain TWC systems. And the transaction presents the opportunity for Comcast to spread the costs of developing and deploying the X1 platform among more Comcast-owned systems, which will in turn help facilitate future innovation.

The combined company will continue to invest in the IP cable transition, yielding a number of consumer and public interest benefits. IP cable:

• Enables consumers to access video services on IP-enabled devices (tablets, video game consoles);
• Shifts more of the network intelligence to the cloud, thereby allowing the combined company to rapidly roll out new functionalities to consumers;
• Reduces costs by allowing the combined company to simplify its existing distribution networks by relying on IP technology to transport all of its services and relying on innovative off-the-shelf IP-based retail devices and reducing its home equipment and inventory costs; and
• Dramatically reduces energy consumption for consumer set-top boxes.

E. Advanced Voice Services
By permitting the companies to combine the best aspects of their robust and innovative voice services, approval of this transaction will leave the merged company even better suited to offer an array of advanced voice services. The transaction will allow Comcast to integrate the best features of its voice offerings with the TWC’s best features, creating best-in-class voice service offerings. Together, the combined company’s scale and existing relationships will enable it to reach more countries for its customers, and for very reasonable rates.

III. Benefits to Broadband Competition

The transaction will spur increased competition among broadband providers and foster the virtuous cycle of innovation by edge providers.

• The transaction will make the broadband market more competitive. By making the combined company a more effective competitor against traditional and emerging broadband providers, the transaction will spur other providers to act on powerful incentives to meet competition and win consumers.
• By virtue of the better broadband speeds and services and increased competition this transaction will produce across the combined company’s footprint, the Internet ecosystem as a whole will benefit. Edge providers in particular will have better tools with which to build novel services. The last-mile improvements that the combined company will bring to customers more quickly than either company could do on its own will provide an even stronger foundation for new, powerful apps and services that are dependent upon higher-quality, reliable broadband networks and Wi-Fi gateways to reach and serve customers, such as distance learning, home security, remote healthcare, and others. Dr. Mark A. Israel argues that the improvements in broadband services that will arise from this transaction will trigger this virtuous cycle of innovation. Because edge providers are available to all ISPs, edge provider improvements that are spurred by the combined company’s broadband investments will in turn create additional incentives for other ISPs to improve their own broadband services.

IV. Benefits to an Open Internet

Comcast is now the only company legally bound by the no-blocking and non-discrimination rules in the FCC’s Open Internet Order, in the wake of the recent D.C. Circuit decision vacating these rules. It is subject as well to unique restrictions on offering, and how it offers, “specialized services.” This transaction, therefore, will spread the reach of those protections to all of TWC’s customers. The Open Internet rules were designed to establish baseline requirements to foster the virtuous cycle of innovation involving edge providers and to provide consumers and edge providers some important certainty. Accordingly, not only will this aspect of the transaction address and prevent any of the putative competitive harms certain parties may allege regarding edge providers, but application of these Open Internet rules to all of TWC’s cable systems is an immediate and substantial public interest benefit that approval of this transaction will extend to millions of additional consumers.

V. Benefits to Broadband Adoption

The combination of Comcast and TWC will demonstrably advance the goal of bringing all Americans into the digital communications age by extending Comcast’s landmark Internet Essentials broadband adoption program to TWC’s territories, and building upon TWC’s efforts. By extending and expanding the Comcast program to reach new geographic areas -- including large metropolitan and rural areas -- the transaction will help to connect many thousands of additional low-income households to today’s high-speed Internet.

Internet Essentials provides low-income households with low-cost broadband service for $9.95 a month and the option to purchase an Internet-ready computer for under $150. In addition, Internet Essentials offers multiple options for accessing free digital literacy training in print, online, and in-person – whether the individual is officially enrolled in the program or not.

Comcast’s voluntary broadband adoption commitment under the Comcast-NBCUniversal Order expires in the summer of 2014, when the program completes three full years. But Comcast recently announced that it will extend the Internet Essentials program indefinitely and enhance it. If this transaction is approved, this program will apply to all of the communities in the TWC markets, thereby extending Internet Essentials’ reach into 19 out of 20 of the nation’s largest cities. Thus, a tangible and far-reaching benefit of this transaction, effective upon approval by the FCC, will be to make the power of broadband and the Internet available to many more low-income families and help reduce the unacceptable digital divide in the country.

VI. Benefits for Businesses

The combined company could offer new options and aggressively-priced services to small, medium, and enterprise businesses across most of the country, challenging the incumbents that have dominated this marketplace for decades.

A. Benefits for Medium-Sized, Regional, Super-Regional, and Enterprise Businesses
To date, geographic constraints have hindered Comcast, TWC, and other cable companies from competing effectively against incumbent providers with national scale and scope for larger business customers that have multiple office locations in various states. The transaction will change the view that cable companies are not able to make competitive offerings by extending Comcast’s geographical reach and enhancing the combined company’s investment incentives. Economies of scale will allow the combined company to drive fiber and other high-capacity technology deeper into the network, bringing the broadband infrastructure that is needed to bring business locations “on-net.” An expanded footprint will also enable the combined company to provide an attractive unified service to regional businesses and super-regional businesses with offices adjacent to or clustered around areas previously split between the Comcast and TWC markets. The added scale and geographic reach, as well as the complementary strengths afforded by the transaction, will enhance the combined company’s ability to be a more significant player in the medium-sized business segment and beyond.

In addition to making it possible to reach and serve larger multi-site customers in a uniform fashion, the combined company’s larger scale will enhance competition in other dimensions as well. Notably, it will allow the company to build super-regional Metro Ethernet clusters, thereby further consolidating key parts of the company’s network and fostering more efficient delivery of services. Scale also will enable the combined company to spread its investments in product procurement and development over a larger potential base of customers, which will facilitate more investment and enhance the combined company’s ability to compete. The combined company will be better able than either company on their own to develop, deploy, maintain, and consistently upgrade innovative products and services for larger business customers.

The increased scale, integration, and operational efficiencies will also establish the combined company as a meaningful alternative for enterprise companies that have many locations throughout the expanded Comcast-TWC footprint. The company will be more likely to be a contender for the aggregator role because of its larger number of locations. The company can play a bigger role in ensuring quality service and reducing cost by avoiding double marginalization.

Beyond the significant benefits driven by larger scale, the combined company will be able to compete more effectively for medium-sized and enterprise business customers by combining Comcast’s and TWC’s respective product offerings into a “best of the best” service portfolio, thereby capitalizing on their complementary strengths and marketing expertise. As Drs. Rosston and Topper conclude, “[c]ombining the complementary products and services offered by Comcast and TWC under a single company will enhance competition in business services” in a way neither company can do today.

B. Wireless Backhaul
By utilizing not only TWC’s assets, but also its knowledge and expertise of the wireless backhaul business, Comcast will be better positioned to offer mobile operators the services they want in more locations. This business responds to the growing need for wireless carriers to transport wireless traffic from their cell towers on high-capacity fiber facilities to make the mobile broadband ecosystem work more efficiently and reliably.

C. Benefits for Small Business
The combined investments and network upgrades that are necessary to serve medium-sized, enterprise, and wholesale wireless backhaul customers across the combined company footprint will also inure to the benefit of small business (and residential customers as well) in a number of ways.

• Since products developed for the medium-sized or enterprise segments can often be offered to/repackaged for small businesses, new product development driven by greater competition for larger businesses will also benefit small business customers.
• Small businesses (and residential customers) will enjoy the “spillover effects” from investments and plant upgrades made to serve larger businesses.

D. Benefits for Advertisers
The transaction will accelerate the expanded deployment and adoption of next-generation advertising technologies -- notably (1) dynamic ad insertion for VOD and other platforms, and (2) addressable advertising -- that will create new benefits for advertisers, content providers, and consumers alike.

Dynamic Ad Insertion
Dynamic ad insertion transforms this platform by separating the ads from the programming stream and dynamically inserting them into VOD segments, and ultimately into other platforms. This technology thus allows advertisers to tailor their messages on this platform in a more timely manner, giving them more meaningful access to the increasingly large segment of consumers who engage in time-shifted viewing or view content using devices other than a traditional television. This transaction will help improve existing dynamic ad insertion technologies, unify measurement metrics across platforms, and unlock the real potential for this new technology for three reasons:

• First, being able to spread the costs for this new technology over an expanded customer base will allow for greater investment in enhancing and further deploying this technology across multiple platforms
• Second, the combined company’s increased scale will likely spur advertisers and ratings agencies to unite around common audience measurement and effectiveness tools for these new platforms and ad technologies. This, in turn, will create greater momentum for their adoption and deployment
• Third, the transaction will extend Comcast’s VOD and TV Everywhere platforms and digital rights to TWC’s systems, particularly in the important markets of New York and Los Angeles, creating additional cable advertising options in these areas.

Addressable Advertising
Addressable advertising allows marketers purchasing advertising spots on cable network programs to augment geographic zone targeting (i.e., advertising targeted at specific zip codes or neighborhoods) with advertising targeted to individual households based on demographics and other household-specific characteristics. Addressable advertising offers important benefits to existing advertisers who can improve the efficiency and cost-effectiveness of their marketing efforts, and may provide a new option to advertisers that might not previously have considered the cable network ads because their products appeal to narrow, niche markets rather than a mass market. The transaction will accelerate the deployment of addressable advertising not just due to the greater scale and investment potential discussed above, but also for two additional reasons:

• First, while Comcast has addressable ad technology that it is planning to roll out more widely by the end of 2014, TWC has not deployed addressable advertising on its platform. Accordingly, the transaction will extend Comcast’s addressable ad technology and plans to the TWC systems.
• Second, the expanded geographic reach of the combined entity will create attractive new options for advertisers to reach cable network audiences efficiently.

When addressable technology is combined with the dynamic ad insertion capability, the enhanced value and benefits are particularly significant. Advertisers of all types and sizes, including national advertisers, seeking to target customers with spot cable advertising in certain key markets across the country will be able to look to the combined company to insert their timely, dynamic, addressable ads in a VOD asset or other platform. Consumers will receive advertisements, promotions, and discounts that are more relevant to them and their families.

VII. Applying Comcast-NBCUniversal Obligations to Time Warner Cable Systems

Comcast and TWC claim that additional benefits and protections will arise from the extension to the acquired systems of various pre-existing obligations and other commitments developed in connection with Comcast’s acquisition of NBCUniversal. The NBCUniversal transaction contained more than 150 conditions, including substantive subparts. Comcast intends to build on its record of compliance with these conditions to bring new benefits to TWC markets. There commitments include:

Open Internet: As noted above, Comcast will extend the protections of the Open Internet rules that were rejected by D.C. Circuit to TWC customers, providing greater certainty for consumers and edge companies as the FCC considers a new legal framework. The Comcast commitment will extend the enforceable protections of the no-blocking and non-discrimination rules to millions of additional broadband customers.

Standalone Broadband: Comcast will offer consumers in TWC markets the option to procure their broadband service on a standalone basis. Customers will have the flexibility to mix and match any speed of broadband with the services of Comcast, another video provider, or no traditional video service at all.

Program Access: NBCUniversal will continue to make its programming available to pay-TV providers at fair market value and on non-discriminatory terms.

Online Video: NBCUniversal will work with online video distributors (OVDs) and develop mutually advantageous distribution deals.

Broadband Adoption: Internet essentials will be extended to TWC markets and the program has been extended indefinitely.

Broadcast Commitments: Comcast maintains separation between its cable and
broadcast businesses with respect to NBCUniversal’s negotiation of retransmission consent agreements with pay-TV providers, NBCUniversal’s negotiation of affiliation agreements with local broadcast stations, and Comcast’s negotiations of retransmission consent agreements with broadcast stations. Moreover, Comcast Cable has committed not to import distant NBC broadcast network signals into an affiliate’s market where retransmission consent negotiations have failed. These commitments will be extended to TWC markets.

Programming Commitments: Comcast will expand access to local programming and children’s VOD content, and to empowering parents in TWC markets. These include:

• Making available broadcast content in the acquired TWC systems at no additional charge on Comcast’s VOD.
• Expanding VOD programming choices that appeal to children and families.
• Providing improved on-screen program ratings icons.
• Restricting the use of “Interactive Advertising” in programming produced primarily for children.

Non-Commercial Educational (NCE) Station Carriage: Comcast is obligated to continue carrying qualified NCE and local NCE stations that had must-carry rights as of December 31, 2010 and relinquish their broadcast spectrum. NCE stations in the acquired systems will enjoy this protection as well,285 affording such broadcasters the opportunity to both participate in the FCC’s upcoming incentive auction and to continue to deliver important local programming to their local communities.

Diversity: The transaction will promote significant diversity interests in the TWC markets, because Comcast will extend its diversity program to the acquired systems and networks and will incorporate and build upon those TWC programs that would enhance Comcast’s own diversity practices. Comcast’s diversity commitments include: (1) governance, (2) workforce recruitment and retention, (3) procurement, (4) programming, and (5) philanthropy and community investment.

Within 120 days of the close of the transaction, Comcast will develop a new master strategic plan that will set forth the vision and goals for the combined company’s (including TWC’s) diversity programs, similar to the plan adopted shortly after the NBCUniversal transaction closed. The new plan, like the existing plan, will be formulated with the advice of the Joint Diversity Advisory Council. This transaction will afford Comcast the opportunity to ensure that the best and most effective approaches to governance for diversity and inclusion are deployed throughout the combined company by extending Board, executive Internal Diversity Council, and Joint Council review to TWC systems.

Comcast is prepared to extend its workforce (and other) diversity commitments to TWC properties. As part of developing the TWC master strategic plan for the company’s workforce, noted above, Comcast would, for example:

• Analyze TWC’s talent acquisition, development, and promotion, employee engagement practices and programs, and the overall workforce diversity metrics, and identify potential areas for action.
• Develop a plan to build on TWC’s positive workforce initiatives and integrate them into Comcast’s approach to practices and programs.
• Identify specific initiatives and aspirational goals, with quantifiable steps, to increase diversity in the leadership ranks and overall employee base.

The TWC systems, employees, and customers will benefit significantly from the extension of Comcast’s comprehensive diversity program.

Comcast’s vendors will have more opportunity to do business with the combined company and increase prime vendors (i.e., Tier I) spend. In addition, the combined company will be able to expand opportunity for diverse subcontractors (i.e., Tier II). In the NBCUniversal transaction, Comcast committed to expand its supplier diversity program to increase the amount spent with Tier I and to expand its Tier II program. TWC has a supplier diversity program as well, and Comcast will combine the best aspects of both companies’ programs to drive increased opportunities for diverse vendors.

Since the NBCUniversal transaction, Comcast has met its commitment to expand minority-focused programming, increasing the amount, quality, and diversity of national and local programming for its customers across its platforms. With this transaction, Comcast will commit to use its VOD and Online platforms to feature Telemundo programming and increase the number of Telemundo and mun2 VOD choices, as well as other diverse VOD content, available to customers in the acquired TWC systems, as soon as TWC’s VOD content and delivery platforms can be upgraded. NBCUniversal has also undertaken initiatives intended to increase news, information, and entertainment choices for diverse viewers.

In 2010, Comcast and NBCUniversal committed to increase aggregate cash support to minority-led and minority-serving (“MLMS”) organizations by ten percent per year in 2011, 2012, and 2013. The company significantly exceeded this commitment, increasing its cash spending to diverse communities MLMS organizations by more than 100 percent over the three-year period. To ensure that both companies’ community partners enjoy the full benefit of the transaction, Comcast’s community-focused ethos and programs will extend to the TWC markets and will honor and build upon TWC’s existing partnerships and programs.

VIII. Benefits for People with Disabilities

Following the transaction, Comcast will be able to bring its leadership to bear, building upon TWC’s strong foundation to deploy new assistive technologies and support to TWC customers. As TWC systems are integrated, technically and operationally, into Comcast’s network, customers across the newly expanded footprint will be able to enjoy the benefits of Comcast’s accessibility innovations. Comcast supplements these product development activities with regular outreach to the disability community. These activities are producing a wide range of innovative accessibility solutions.

These activities are producing a wide range of innovative accessibility solutions:

• Comcast is leveraging the X1 cloud-based platform to deliver the first “talking guide” in the MVPD industry. The talking guide feature assists a blind or visually-impaired customer in navigating around the X1 TV user interface and selecting particular services for use.
• The X1 platform will simplify the process for activating accessibility features.
• The X1 user interface also provides for simple navigation to accessibility features, including allowing the customer to activate closed captioning and video description services via the main Settings menu on the user interface and configure enhanced caption features, such as font and color, via the Closed Captioning Settings menu.

Comcast will be able to extend the benefits of these accessibility features to customers in the TWC systems as those systems are upgraded to support the X1 platform.

Comcast is providing innovative accessible solutions across other service areas as well.

• Comcast has deployed a Readable Voicemail service that converts voicemail audio into text and aids deaf and hard-of-hearing customers in accessing their
• voicemail.
• The Xfinity Connect Mobile App, which enables access to email, text, and other online services on tablets and smartphones, is screen reader-enabled for blind and low-vision users.

The company has established a dedicated customer support team of 22 agents in the new Comcast Accessibility Center of Excellence.

In addition, Comcast is deploying a number of innovative solutions to ensure that its accessibility features work properly.

• The caption compliance testing program that Comcast adopted for its set-top boxes has shortened quality control testing cycles for new box models from several weeks to a matter of days.
• Comcast has started deploying a first-of-its-kind network monitoring tool that enables it to detect remotely when cable program streams are non-compliant with industry standards for closed captioning and video description.

These equipment testing and monitoring activities can be expanded to TWC systems as those systems are integrated into Comcast’s network.

The transaction thus presents a singular -- and unparalleled -- opportunity to accelerate the deployment of accessible technology, customer care, and disability inclusion to tens of millions of consumers in the TWC footprint.

IX. Benefits for Cybersecurity

The transaction will enable the combined company to invest additional resources in cybersecurity efforts and extend the reach of Comcast’s industry-leading approach to cybersecurity and its use of advanced cybersecurity technologies. This transaction will extend the reach of Domain Name System Security Extensions, which provides an enhanced level of Internet security, and IPv6, the next generation of IP addressing with improved security elements, to all the TWC systems, thereby enhancing cybersecurity protections to more networks and to many more American consumers and businesses.

In addition to providing advanced security for the protection of broadband network assets, the transaction will benefit TWC’s broadband consumers by providing them with new, more robust tools and capabilities to protect against cyber threats. Offered free to all customers, Comcast’s Constant Guard security suite is the nation’s most advanced and comprehensive consumer-facing cybersecurity product. In addition, Comcast’s Customer Security Assurance organization assists customers with potential cybersecurity issues to ensure a safe and secure online experience. Comcast also provides separate botnet notifications to potentially infected customers, irrespective of whether they obtain Constant Guard. Further, Comcast has made additional investments in network technologies that protect consumers, deploying advanced inline malware detection that protects the network from infection by detecting and containing malicious network traffic before it traverses network components or reaches end user devices. Making these services and capabilities available to TWC’s customers and networks will strengthen their protection against cyber threats and malicious activity, thereby boosting the overall security of the broadband ecosystem.

Customers will benefit from the economies of scale and combined expertise associated with harmonizing the approaches and personnel of Comcast and TWC. By fostering stronger threat intelligence and deeper analytical resources, faster dissemination of threat information and remediation strategies, and common metrics across a broader scale of potentially affected networks and users, the integration and scaling of Comcast and TWC’s existing cybersecurity resources will improve the overall cyber defense posture of the combined entity.

This all is just to (quickly) summarize the public interest claims Comcast and Time Warner Cable are making to federal regulators. Earlier this week, the Benton Foundation published an op-ed by former FCC Chairman Michael Copps who argues the acquisition is “bad for consumers, competition, and our very democracy.” We’re closely following the review of this transaction and we invite you to join us for the ride. In the meantime, we’ll see you in the Headlines.