Time Warner Cable (TWC) has mistreated its customers for decades and should face a wide-ranging investigation as part of its proposed merger with Comcast, a new complaint to the Federal Communications Commission says.

Telecom analyst Bruce Kushnick of New Networks Institute, who recently petitioned the FCC to investigate Verizon for perjury, is now taking aim at TWC’s billing practices and customer service.

“We call for the halt of the proposed Time Warner Cable-Comcast merger, but more importantly, this Petition for Investigation & Complaint calls for the immediate start of a series of investigations,” Kushnick and Audit Director Tom Allibone of telecom customer advocacy group Teletruth write in a complaint. It was filed with the FCC two weeks ago and is being filed today with New York state officials, who are also examining the merger.

Kushnick and Allibone point out that Comcast and TWC are two of the most hated companies in the US, according to the American Customer Satisfaction Index, and they lay out five areas the FCC should investigate. One of those is related to Kushnick’s own experience in which his Time Warner Cable service was advertised at $89.99 per month and shot up to $190.77 less than two years later.

Kushnick and Allibone write:

1) Time Warner’s “Triple Play” bill exposed questionable business practices and charges including ‘made up fees’, billing errors, as well as deceptive and possible Truth-in-Billing and Truth-in-Advertising violations. These problems are not restricted to Time Warner but are industry-wide. 2) Time Warner & Comcast’s “Social Contract” with the FCC. In 1995 an actual agreement called the “Social Contract” was put in place to have the cable companies upgrade their networks and provide broadband and Internet services to schools in their territories. The FCC allowed ‘temporary’ rate increases of up to $5.00 a month; ‘temporary’, as the Contract expired at the end of 2000. Time Warner (at least) never stopped charging customers the extra fee nor is there evidence that the Company wired the schools as required. Moreover, Time Warner and Comcast’s profit margins for “high-speed Internet” was 97% in 2013; the “Social Contract” additions became pure profits, but cost every cable subscriber hundreds of dollars. 3) A recently filed consumer protection action was filed with the Albany New York Supreme Court against Time Warner and it reveals multiple issues, including customer service problems, selling broadband/Internet services that were not delivered, among other harms to customers industry-wide. These problems are not restricted to Time Warner but are industry-wide. 4) 22 Years of Continuous Rate Increases Means There has been No ‘Effective Competition’. Using actual bills, we found that Time Warner’s Brooklyn New York prices for ‘regular’ cable service increased 306% from 1992-to-November, 2014, from $22.95 a month to $93.16 a month. The “Triple Play” bill shows that this was from made up fees, deregulation of the set-top box (with no alternative), pass-through taxes, and simply because there are no other options; at best, some markets have a ‘duopoly’ which is ineffective for controlling prices or problems with service. 5) Multiple Cross-Ties with Verizon’s Wireline and Verizon Wireless, and with Time Warner and Comcast Need Immediate Attention. The FCC and DOJ allowed Verizon Wireless to create a marketing deal with both cable companies to bundle the wireless service with the cable service in areas Verizon has refused to upgrade to FiOS. But what was unexamined is the fact that Verizon Wireless has a sweetheart deal with Verizon wired companies, such as Verizon New York, for use of the networks—as Title II. This means that the wired, wireless, and cable companies are colluding to control almost ALL communications services.

That point about the "sweetheart deal" refers to Verizon using its status as a common carrier under Title II of the Communications Act to build out fiber for both its wireline and cellular networks.

Here's a look at the Time Warner Cable bill Kushnick detailed:

Time Warner Cable said the allegations are without merit, but the company declined to answer them specifically.

“These allegations are so full of holes and lacking in facts that we will decline to further comment,” a TWC spokesperson told Ars.

We’ve also asked Comcast for comment but haven’t heard back yet.

Comcast announced its deal to buy Time Warner Cable for $45.2 billion in February 2014, joining the nation’s two largest cable companies. Comcast has said it expects to close the deal in early 2015, but it could be blocked by the FCC or Department of Justice.