Our Antitrust and Merger Advocacy

Opposition to Mergers

• November 2021: The FCC issued an order implementing OTI’s recommendations for strong Verizon/Tracfone merger conditions.
• August 2021: Sarah Morris, Joshua Stager, and Amir Nasr joined Common Cause in meeting with acting FCC Chairwoman Jessica Rosenworcel’s advisors via telephone to voice our concerns about the effects the proposed Verizon/Tracfone merger could have on Lifeline subscribers, emphasizing the importance of ensuring that conditions are strictly enforced and of sufficient duration. We covered this letter across two legislative and regulatory filings posts.
• August 2021: Sarah Morris met with acting FCC Chairwoman Jessica Rosenworcel’s advisors via telephone to voice our concerns about the effects the proposed Verizon/Tracfone merger could have on Lifeline subscribers, reiterating how important it is for the FCC to impose strong, consumer-friendly conditions with rigorous, independent enforcement mechanisms on any such merger.
• July 2021: Joshua Stager met with acting FCC Chairwoman Jessica Rosenworcel, staff, and advisors via telephone to voice our concerns about the effects the proposed Verizon/Tracfone merger could have on Lifeline subscribers, emphasizing that the FCC must, at a minimum, “impose strong conditions” with “rigorous enforcement mechanisms” so as to “protect low-income consumers from price increases and ensure TracFone remains a supportive Lifeline participant.” We covered this letter in a legislative and regulatory filings post.
• April 2021: OTI responded to the FCC’s public notice asking for input on the Lifeline marketplace by submitting How to Revive the FCC’s Lifeline Program: A Blueprint to Build Back Better After Four Years of Neglect and Regulatory War, a report in which OTI urged the FCC to “aggressively police consolidation in the Lifeline market,” including the consolidation that the proposed Verizon/Tracfone merger would entail.
• April 2021: OTI joined a coalition of advocates in sending a letter to acting FCC Chairwoman Jessica Rosenworcel, voicing our concerns about the effects the proposed Verizon/Tracfone merger could have on Lifeline subscribers and competition in the wireless market, urging the FCC to “impose strict enforceable conditions on the transaction that will protect Lifeline customers and preserve the wireless reseller marketplace,” should the merger be approved. We covered this letter in a legislative and regulatory filings post.
• March 2021: OTI joined Public Knowledge, Access Humboldt, the Benton Institute for Broadband and Society, and Next Century Cities in submitting comments to the FCC, emphasizing the need for the FCC to request more information from the parent companies of Verizon and Tracfone, open a docket for the Verizon/Tracfone proceeding to better facilitate public input, and engage its Transaction Team to better understand the impacts of the proposed Verizon/Tracfone merger on the wireless market and value-conscious consumers, including Lifeline subscribers. We covered these comments in a legislative and regulatory filings post.
• December 2020: OTI joined Public Knowledge, the California Center for Rural Policy, Next Century Cities, Access Humboldt, Tribal Digital Networks, and the Benton Institute for Broadband and Society in submitting comments to the FCC, noting that the application for the proposed Verizon/Tracfone merger “raises serious questions about the public interest harms and ostensible public interest benefits of the transaction” and recommending that the FCC request more information from the parent companies of Verizon and Tracfone.
• October 2020: OTI joined Public Knowledge and the Benton Institute for Broadband & Society in submitting a reply to the parent companies of Verizon and Tracfone, reiterating our opposition to their petition for streamlining and our motion to dismiss their application as incomplete. We covered this reply in a legislative and regulatory filings post.
• October 2020: OTI joined Public Knowledge and the Benton Institute for Broadband & Society in submitting a filing to the FCC, opposing the petition for streamlining made by the parent companies of Verizon and Tracfone and motioning to dismiss their application as incomplete. We covered this filing in a legislative and regulatory filings post.

• February 2020: OTI condemned a federal court’s decision to approve the proposed T-Mobile/Sprint merger in a press release, with Joshua Stager noting that “markets don’t recover from mergers like this one—they turn into oligopolies marked by high prices, collusion, and inequality.” His remarks were covered by by Axios.
• December 2019: OTI applauded a congressional probe into the FCC’s review of proposed T-Mobile/Sprint merger in a press release, with Joshua Stager remarking that the FCC “did not evaluate this merger in an honest and fair manner.”
• October 2019: OTI denounced the FCC’s decision to approve the proposed T-Mobile/Sprint merger—along with a secretly-negotiated side deal with Dish Network—in a press release, with Joshua Stager calling the decision “a slap in the face to the American people” that “will raise prices, kill jobs, and worsen the digital divide.”
• October 2019: OTI joined Public Knowledge, Consumer Reports, and the Electronic Frontier Foundation in submitting comments to Scott Scheele, the Chief of the Telecommunications and Broadband Section of the Department of Justice’s Antitrust Division, emphasizing how allowing DISH to use T-Mobile infrastructure to provide a new wireless service and replace Sprint as the fourth competitor in the market “violates many, if not all, of the Justice Department’s guiding principles for merger remedies.” We covered these comments in a press release.
• October 2019: OTI joined Communications Workers of America, Consumer Reports, NTCA - The Rural Broadband Association, the Institute for Local Self-reliance, The Greenlining Institute, Open Markets Institute, and Public Knowledge in filing a supplement to the Rural Wireless Association’s Petition to Deny the proposed T-Mobile/Sprint merger, urging the FCC to pause its review of the merger “while important issues related to Sprint’s apparent Lifeline fraud are more fully investigated by the Commission,” as well as seek public comment on the DISH waiver requests, the July 26 commitments to the Commission, and related developments, including the DOJ Consent Decree.
• October 2019: Joshua Stager and Amir Nasr met with FCC Commissioner Geoffrey Stark’s special advisor to voice our concerns about the proposed T-Mobile/Sprint merger.
• August 2019: Amir Nasr joined Communications Workers of America, Public Knowledge, Consumer Reports, and Free Press in meeting with FCC Commissioner Geoffrey Starks and his advisor, urging the FCC to seek public comment on the DISH waiver requests, the July 26 commitments to the Commission, and related developments, including the DOJ Consent Decree.
• August 2019: Amir Nasr joined Communications Workers of America, Public Knowledge, Consumer Reports, and Free Press in meeting with FCC Commissioner Michael O’Rielly and his advisor, urging the FCC to seek public comment on the DISH waiver requests, the July 26 commitments to the Commission, and related developments, including the DOJ Consent Decree.
• August 2019: OTI condemned the announcement of the FCC’s order to approve the proposed T-Mobile/Sprint merger—along with a secretly-negotiated side deal with Dish Network—in a press release, with Joshua Stager calling the move “a massive, convoluted scheme that would dramatically upend the wireless market, raise consumer prices, and kill jobs.”
• August 2019: Joshua Stager joined the Communications Workers of America, Public Knowledge, NTCA – The Rural Broadband Association, Free Press, and Common Cause in meeting with advisors to FCC Commissioners Brendan Carr and Jessica Rosenworcel to voice our concerns about the proposed T-Mobile/Sprint merger.
• July 2019: OTI opposed the Department of Justice’s complex scheme to approve the proposed T-Mobile/Sprint merger in a press release, with Joshua Stager calling the agency’s response “half-baked” and “needlessly convoluted.”
• June 2019: OTI applauded the states that joined a lawsuit to block the proposed T-Mobile/Sprint merger in a press release, with Joshua Stager praising them for “stepping up to protect their people and their markets from a brazenly anticompetitive deal.”
• May 2019: OTI’s Michael Calabrese was quoted by Fierce Wireless about the push back against the T-Mobile/Sprint merger, remarking that the commitments announced by T-Mobile, Sprint, and Chairman Pai “do not add up to real 5G services for rural and small town America.”
• May 2019: Becky Chao joined the 4Competition Coalition in meeting with FCC Commissioner Jessica Rosenworcel’s wireless and international legal advisor to voice our concerns about the proposed T-Mobile/Sprint merger.
• May 2019: Becky Chao and Joshua Stager joined the 4Competition Coalition in meeting with FCC Commissioners, staff, and advisors to voice our concerns about the proposed T-Mobile/Sprint merger.
• April 2019: OTI joined 23 other organizations in sending a letter voicing our concerns about the proposed T-Mobile/Sprint merger to FCC Chairman Ajit Pai.
• March 2019: Sarah Morris joined Free Press in meeting with FCC Commissioner Jessica Rosenworcel, staff, and advisors to voice our concerns about the proposed T-Mobile/Sprint merger.
• February 2019: Kevin Bankston, Sarah Morris, Eric Null, Joshua Stager, Becky Chao, and Amir Nasr met with FCC Commissioner Geoffrey Starks and his advisors to voice our concerns about the proposed T-Mobile/Sprint merger.
• February 2019: Becky Chao and Michael Calabrese joined the 4Competition Coalition in meeting with FCC staff and advisors to voice our concerns about the proposed T-Mobile/Sprint merger.
• December 2018: Joshua Stager and Amir Nasr joined Public Knowledge, Free Press, Common Cause, Open Markets Institute, Consumer Reports, and Writers Guild of America in meeting with members of the FCC’s Transaction Team to voice our concerns about the proposed T-Mobile/Sprint merger.
• October 2018: OTI submitted reply comments to the FCC, emphasizing how the record shows that the proposed T-Mobile/Sprint merger would destroy jobs, that T-Mobile and Sprint’s prior mergers strengthen the case for rejecting this transaction, and that the record does not support T-Mobile and Sprint’s 5G claims. We covered these comments in a legislative and regulatory filings post.
• August 2018: OTI joined Common Cause, Consumers Union, Public Knowledge, and the Writers Guild of America West in filing a Petition to Deny the proposed T-Mobile/Sprint merger, arguing that it is anticompetitive and would harm the public interest. We covered this petition in a press release.
• August 2018: OTI joined Communications Workers of America, Rural Wireless Association, NTCA – The Rural Broadband Association, Public Knowledge, Consumers Union, The Greenlining Institute, Common Cause, Writers Guild of America West, Free Press, and Benton Foundation in filing a motion to stop the clock or otherwise extend time for the proposed T-Mobile/Sprint merger review until T-Mobile and Sprint supplement their public interest statement to adequately describe the extensive spectrum aggregation that will result from the proposed transaction.

• August 2020: OTI submitted comments to the European Commission, noting that the proposed Google/Fitbit merger “would harm user privacy and limit interoperability of competing wearable devices.” We covered these comments in a press release.
• July 2020: OTI joined a coalition of advocates in releasing a common statement voicing our concerns about the proposed Google/Fitbit merger. We covered this statement in a press release.

• May 2019: Becky Chao wrote an article for OTI on the importance of not only ensuring that sufficient checks and balances exist to prevent the politicization of antitrust, but also bolstering the accountability of the institutions we rely on for its enforcement, referencing the AT&T/TW merger.
• July 2018: OTI applauded the Department of Justice’s decision to appeal a June ruling that allowed the AT&T/TW merger to move forward in a press release, with Joshua Stager remarking that “the Justice Department was right to challenge it on antitrust grounds.”
• June 2018: OTI condemned a federal judge’s decision to allow the AT&T/TW merger to move forward (despite the Department of Justice’s argument that the merger violates antitrust law) in a press release, with Joshua Stager referring to it as “a loss for consumers and the American economy.”
• July 2017: OTI joined a coalition of advocates in sending a letter voicing our concerns about the proposed AT&T/TW merger to Attorney General Jeff Sessions.
• November 2016: OTI joined a coalition of advocates in sending a letter voicing our concerns about the proposed AT&T/TW merger to presidential candidates Donald Trump and Hillary Clinton.
• October 2016: Joshua Stager appeared on Wisconsin Public Radio’s The Kathleen Dunn Show to voice our concerns about the proposed AT&T/TW merger.

• October 2016: Joshua Stager joined Public Knowledge in meeting with members of the FCC’s Wireline Competition Bureau and Office of General Counsel to voice our concerns about the proposed Verizon/XO merger.
• May 2016: OTI submitted comments to the FCC, noting that the proposed Verizon/XO merger “threatens” public interest priorities—such as robust networks, competitive markets, and consumer protection—and therefore “warrants the Commission’s highest level of scrutiny.”

• April 2016: Joshua Stager joined the Stop Mega Cable Coalition in meeting with members of the FCC’s Office of General Counsel to voice our concerns about the proposed Charter/Time Warner Cable merger.
• March 2016: Joshua Stager joined the Stop Mega Cable Coalition in meeting with FCC Commissioner Mignon Clyburn’s chief of staff and media policy advisor to voice our concerns about the proposed Charter/Time Warner Cable merger.
• February 2016: OTI’s Michael Calabrese joined the Stop Mega Cable Coalition in meeting with FCC Commissioner Mignon Clyburn’s acting media legal advisor to voice our concerns about the proposed Charter/Time Warner Cable merger.
• February 2016: Joshua Stager and Michael Calabrese joined the Stop Mega Cable Coalition in meeting with FCC staff, advisors, and Transaction Team members to voice our concerns about the proposed Charter/Time Warner Cable merger.
• October 2015: OTI submitted comments to the FCC, urging the Commissioners to “closely examine” the potential for the proposed Charter/Time Warner Cable merger to “actually foster an oligopoly in the pay TV and broadband markets.” We covered these comments in a press release.

• July 2015: OTI praised the FCC in a statement for considering imposing conditions that protect consumers onto the companies involved in the proposed AT&T/DIRECTV merger, but continued to express concerns about how the transaction may leave consumers vulnerable.
• July 2015: OTI signed onto a letter urging the FCC to impose a new interconnection policy on AT&T as a condition of the proposed AT&T/DIRECTV merger.
• June 2015: Joshua Stager met with FCC staff via telephone to discuss how forthcoming M-Lab data would “underscore the need to protect AT&T customers from interconnection abuse in the proposed DIRECTV transaction.”
• May 2015: Joshua Stager joined Free Press and Public Knowledge in meeting with FCC Commissioner Mignon Clyburn’s advisors to voice our concerns about the proposed AT&T/DIRECTV merger.
• May 2015: Joshua Stager joined Free Press and Public Knowledge in meeting with FCC Commissioner Jessica Rosenworcel’s policy advisor to voice our concerns about the proposed AT&T/DIRECTV merger.
• May 2015: Joshua Stager joined Free Press and Public Knowledge in meeting with other representatives, Commission staff, and the Transaction Team to voice our concerns about the proposed AT&T/DIRECTV merger.

• April 2015: OTI praised the collapse of the proposed Comcast/Time Warner Cable merger in two press releases, with Joshua Stager referring to it as “a tremendous victory for consumers, innovators, and the future of the Internet.”
• April 2015: OTI joined a coalition of advocates in sending a letter opposing the proposed Comcast/Time Warner Cable merger to FCC Chairman Tom Wheeler.
• March 2015: OTI joined the Stop Mega Comcast Coalition in submitting an ex parte to the FCC, providing “additional evidence of Comcast’s anti-competitive behavior with respect to rival services.”
• January 2015: Joshua Stager joined the Stop Mega Comcast Coalition in meeting with FCC staff and advisors to voice our concerns about the proposed Comcast/Time Warner Cable merger.
• January 2015: Joshua Stager joined the Stop Mega Comcast Coalition in two meetings with FCC Commissioners, staff, and advisors to voice our concerns about the proposed Comcast/Time Warner Cable merger.
• January 2015: Joshua Stager joined the Stop Mega Comcast Coalition in meeting with FCC Commissioner Michael O’Rielly, staff, and advisors to voice our concerns about the proposed Comcast/Time Warner Cable merger.
• December 2014: OTI joined Public Knowledge in filing a reply to the parent companies of Comcast and Time Warner Cable, which opposed our petition to deny the proposed Comcast/Time Warner Cable merger.
• September 2014: OTI joined Consumers Union, Public Knowledge, Free Press, and Common Cause in meeting with FCC staff and advisors to voice our concerns about the proposed Comcast/Time Warner Cable merger.
• September 2014: OTI joined Consumers Union, Free Press, and Public Knowledge in meeting with FCC Commissioner Jessica Rosenworcel and her policy director to voice our concerns about the proposed Comcast/Time Warner Cable merger.
• August 2014: OTI joined 64 other organizations in sending a letter voicing our concerns about the proposed Comcast/Time Warner Cable merger to FCC Chairman Tom Wheeler.
• August 2014: OTI joined Public Knowledge in filing a joint petition for the FCC to deny the proposed Comcast/Time Warner Cable merger.

• June 2011: OTI joined Center for Media Justice, Consumers Union, Media Access Project, and Writers Guild of America West in filing a reply to the parent companies of AT&T and T-Mobile, which opposed our petition for the FCC to deny the proposed AT&T/T-Mobile merger.
• May 2011: OTI joined Center for Media Justice, Consumers Union, Media Access Project, and Writers Guild of America West in filing a joint petition for the FCC to deny the proposed AT&T/T-Mobile merger.
• May 2011: OTI’s Michael Calabrese joined other member organizations of the Media and Democracy Coalition in meeting with FCC Commissioners, staff, and advisors to voice our concerns about the proposed AT&T/T-Mobile merger.
• April 2011: OTI joined Free Press, Media Access Project, Public Knowledge, and Consumers Union in sending a letter to FCC Chairman Julius Genachowski, highlighting “the relationship between the proposed T-Mobile transaction and AT&T’s other pending acquisition of nationwide and regional 700 MHz spectrum licenses from Qualcomm.”

• January 2011: OTI joined a coalition of advocates in sending a letter opposing the Comcast/NBCU merger to FCC Chairman Julius Genachowski.
• December 2010: OTI joined Free Press and Media Access Project in sending a letter to Assistant Attorney General Christine A. Varney and the FCC Commissioners, calling on them to investigate Comcast’s interconnection practices.
• November 2010: OTI joined Free Press, Media Access Project, and Public Knowledge in sending a letter to FCC Chairman Julius Genachowski, calling on the FCC to “take Comcast’s anticompetitive behavior into account” when reviewing the Comcast/NBCU merger.

Other Antitrust Topics

• May 2022: OTI issued a press release congratulating Professor Alvaro Bedoya, the founding director of Georgetown University’s Center on Privacy & Technology, for being confirmed to the FTC, with Joshua Stager describing Bedoya as “​​an accomplished scholar with a proven record as an institution-builder and a consensus-builder.”
• April 2022: OTI filed comments urging the Department of Justice and the FTC to strengthen antitrust enforcement, arguing that lax enforcement in the telecommunications sector has contributed to the unaffordable cost of internet service and exacerbated the digital divide. We covered these comments in a press release.
• September 2021: OTI welcomed the FTC’s vote to rescind its flawed vertical merger guidelines in a press release, with Joshua Stager remarking that the rescinded guidelines “glossed over critical issues, ignored key harms in digital markets, and denied public participation.”
• July 2021: In an OTI blog post, Meaghan Donahue reviewed key takeaways concerning the FTC’s enforcement of privacy law from the July 28 hearing held by the House Energy and Commerce Committee Subcommittee on Consumer Protection and Commerce.
• July 2021: OTI hailed President Biden’s executive order on promoting competition in the U.S. economy in a press release, with Joshua Stager calling the order “a big step forward for competition and consumer protection.”
• June 2021: OTI applauded the confirmation of Lina Khan to the FTC in a press release, with OTI’s Joshua Stager calling Commissioner Khan “a proven thought leader who has helped jolt antitrust enforcement out of stagnant 1970s thinking.”
• December 2020: OTI's Christine Bannan wrote for Slate Future Tense’s Future Agenda series, arguing the FTC should use its authority to define “unfair methods of competition” for tech platforms.
• July 2020: OTI condemned the FTC and DOJ’s June 2020 guidelines for reviewing vertical mergers in a press release, with Joshua Stager remarking that these guidelines “gloss over critical issues and ignore the risks of vertical mergers, particularly in digital markets.”
• February 2020: OTI and Public Knowledge filed comments urging the FTC and the DOJ to update their internal guidelines for reviewing vertical mergers. We covered these comments in a press release.
• May 2019: OTI submitted comments to the FTC, describing the lack of transparency from America’s internet service providers and urging the FTC to improve the federal government’s broadband data and consumer privacy protections. We covered these comments in a press release.
• May 2019: OTI submitted comments to the FTC, arguing for the inclusion of company obligations and user rights under the FTC’s privacy regime and urging the FTC to improve the federal government’s broadband data and consumer privacy protections. We covered these comments in a press release.
• May 2019: Becky Chao wrote an article exploring how greater transparency might nurture the independence and accountability of antitrust enforcement agencies.
• February 2019: Becky Chao wrote an article on how antitrust laws affect consumer privacy.
• January 2019: Becky Chao wrote an article assessing the FTC’s Hearings on Competition and Consumer Protection in the 21st Century, reflecting on how the agency can regain public trust.
• October 2018: OTI hosted a panel event offering a closer look into the FTC’s Hearings on Competition and Consumer Protection in the 21st Century.
• October 2018: Becky Chao authored an article exploring the relationship between the merger review process and diversity in media representation.
• August 2018: OTI submitted comments to the FTC, exploring how the broadband market lacks competition and is prone to consumer abuse. We covered these comments in a blog post.
• August 2018: OTI submitted comments to the FTC, emphasizing how important it is to strengthen consumer data control through broad access to data portability tools and interoperable services. We covered these comments in a blog post.
• August 2018: OTI submitted comments to the FTC, emphasizing the importance of intellectual property in encouraging competition. We covered these comments in a blog post.
• August 2018: OTI submitted comments to the FTC, exploring how the Digital Standard can aid FTC enforcement. We covered these comments in a blog post.

• November 2021: OTI submitted comments to the FCC, urging the Commission to take action on improving broadband competition in multi-tenant environments. We covered these comments in a press release.