The Comcast–Time Warner Cable merger is that rare proposal that’s such a bad idea that it actually brings people of all different political beliefs together. If you look at the website for Stop Mega Comcast, for instance, you’ll see both liberal groups such as Common Cause and conservative outfits such as Glen Beck’s The Blaze are both lined up in mutual opposition to the proposed deal.

And it’s not just private citizens of different political stripes who are opposed to the deal either — Comcast rival Dish Networks is understandably against the deal as well and it’s sent a new filing to the Federal Communications Commission (PDF) in which it exhaustively lists all the ways a Comcast-TWC merger would be bad for the home broadband and pay TV markets as well as for American consumers.

There are too many grievances to list them all — Stop Mega Comcast, of which Dish is a member, has counted “at least” 53 different ones — but we’ll post some of the highlights below.

“ The merger will heighten Comcast-TWC’s ability to leverage its three choke points — the last mile, interconnection, and managed services—as well as its recently acquired online ad fulfillment service.”

the last mile, interconnection, and managed services—as well as its recently acquired online ad fulfillment service.” “ The evidence shows Comcast-TWC has no basis for denying its heightened incentive to harm OVDs. To DISH’s showing that the merger will heighten Comcast-TWC’s anticompetitive incentive to harm OVDs, the Applicants counter principally that such conduct would make no sense because it would also hurt the Applicants themselves. […] Comcast-TWC will be able to destroy OVDs with impunity. And destroy them it will: DISH’s experience based on the business case for DISH World and DISH’s soon-to-be-launched domestic OTT service demonstrates that an OTT could still turn a profit if it were to suffer foreclosure at the hands of a standalone Comcast, but not if the effects of the foreclosure spread across both of the Applicants’ systems.”

To DISH’s showing that the merger will heighten Comcast-TWC’s anticompetitive incentive to harm OVDs, the Applicants counter principally that such conduct would make no sense because it would also hurt the Applicants themselves. […] Comcast-TWC will be able to destroy OVDs with impunity. And destroy them it will: DISH’s experience based on the business case for DISH World and DISH’s soon-to-be-launched domestic OTT service demonstrates that an OTT could still turn a profit if it were to suffer foreclosure at the hands of a standalone Comcast, but not if the effects of the foreclosure spread across both of the Applicants’ systems.” “ The merger will eliminate both current and future competition. Although Comcast has rested its case on its emphatic and unequivocal statement that it and TWC ‘do not compete for customers, but rather offer services in separate local markets,’ and ‘do not overlap each other,’ it turns out that Comcast itself has doubts about the veracity of that statement. Comcast is apparently ‘still working with a vendor to analyze [the situation] . . . but in case it shows that there are any consumers in census blocks that may lose a broadband choice,’ the Applicants will need to ‘nuance’ their response to the Commission.”

Although Comcast has rested its case on its emphatic and unequivocal statement that it and TWC ‘do not compete for customers, but rather offer services in separate local markets,’ and ‘do not overlap each other,’ it turns out that Comcast itself has doubts about the veracity of that statement. Comcast is apparently ‘still working with a vendor to analyze [the situation] . . . but in case it shows that there are any consumers in census blocks that may lose a broadband choice,’ the Applicants will need to ‘nuance’ their response to the Commission.” “ The merger will facilitate collusion between cable operators. Fewer people can collude among themselves with greater ease than a larger group. The merger will thus facilitate collusion, as it will reduce by one the number of smoke-filled room participants or email correspondents that are needed to reach an agreement blanketing the entire country and harming national OVDs.”

Fewer people can collude among themselves with greater ease than a larger group. The merger will thus facilitate collusion, as it will reduce by one the number of smoke-filled room participants or email correspondents that are needed to reach an agreement blanketing the entire country and harming national OVDs.” “The merger’s claimed benefits, if any, cannot outweigh the merger’s harms.”

You get the idea.

For good measure, Dish even trashes the way that Comcast has presented its arguments to both the FCC and the public, as it says that Comcast’s response to criticism has been “hectoring, high-handed, strident, shrill.” It also says Comcast has adopted an “arrogant tone” while displaying a “sense of entitlement” that Dish argues bodes ill for American consumers if Comcast is allowed to combine with TWC.

A PDF of the full Dish filing is available at the source link below.