•	Numerous commenters including independent programmers, diversity organizations, local businesses and community leaders support the transaction.

•	Almost all of those who have criticized the transaction are seeking conditions rather than outright denial.

•	The transaction will increase competition in broadband, video, enterprise service and wireless markets.

•	New Charter will more quickly innovate, transition to all-digital and deploy consumer friendly broadband speeds and policies across all TWC and BHN markets.

◦	TWC’s announced plans to bring faster service apply only to some areas it serves, and even with those upgrades, the minimum broadband speeds offered by Charter are still faster.

◦	Charter’s commitment to upgrade all TWC and BHN customers to digital will advance the rollout of its cloud-based Spectrum Guide and innovative Worldbox, enabling New Charter to offer improved video services at more competitive prices.

•	The transaction will spread consumer-friendly and OVD-friendly broadband practices to over 14 million homes.

◦	Industry leading interconnection practices, no data caps or usage based billing, and faster minimum broadband speeds will be enshrined across the New Charter footprint, expanding the reach of these policies almost fourfold.

•	With greater geographic reach and denser regional footprints, as well as its $2.5 billion commitment to expanded build-out, New Charter will be able to deliver improved services and lower prices to businesses across the country.

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•	New Charter will increase competition in the wireless market and enable its broadband customers to purchase less expensive, lower-data packages from wireless carriers, by deploying over 300,000 out-of-home Wi-Fi access points.

◦	The transaction will give the company scale to justify partnering with a holder of licensed spectrum for a Wi-Fi first service or buying spectrum to add a wireless service to its existing triple play bundle.

•	Broadband subscribership will be the leading driver of growth; the popularity of OVDs makes consumers appreciate our fast speeds.

•	New Charter will have no national programming interests and does not gain by favoring its video business over its broadband business, and thus no incentive to harm OVDs.

•	Charter views over-the-top content as complimentary to its MVPD service, allowing it to better compete against satellite and other video providers.

◦	Charter developed a state-of-the-art, cloud-based Spectrum Guide which could enable OVD content to be accessed along with Charter’s video offerings as part of a seamless viewing experience.

◦	Charter’s Spectrum TV App is available on Roku, which enables consumers to avoid needing a set top box from Charter.

•	Charter’s history predicts a future of friendliness with OVDs.

◦	New Charter will bring its current practices to the merged company: settlement-free peering, fast minimum broadband speeds, no data caps, no usage-based billing, no modem or early termination fees.

•	New Charter will create thousands of U.S.-based jobs by returning TWC and BHN call center jobs to the U.S and hiring customer facing employees for call centers and field technician operations located throughout the country.

◦	Charter’s in-sourced workforce is better trained, incentivized and equipped to serve customers.

◦	New Charter is committed to supporting diversity, skill-building and retention in its workforce.

•	New Charter will expand Bright House Networks’ low-income broadband service to the current Charter and TWC footprint, increase the speed, expand eligibility, and continue to offer the service at a significant discount.

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•	The broadband market is dynamic with multiple providers competing to deliver faster and better broadband.

◦	In its recent AT&T-DirecTV order, the FCC considered speeds down to 10 Mbps, rather than 25 Mbps and above, as relevant to AT&T’s market share.

◦	New Charter will serve 21 percent of wireline broadband customers, which is less than Comcast and only slightly more than AT&T. New Charter would serve less than 30 percent of broadband subscribers getting 25 Mbps and above.

◦	AT&T, CenturyLink and Google are strong competitors and all have plans to grow significantly within New Charter’s footprint.

•	New Charter will have no significant national programming and will serve only 17 percent of video subscribers, fewer than AT&T and Comcast.

◦	In its review of the AT&T-DirecTV merger, the FCC determined that the company’s minor programming interests raised “few, if any, vertical integration concerns.” The same is true for New Charter.

•	Liberty’s programming interests do not present any anti-competitive threat.

◦	New Charter will have no incentive to benefit programming interests that it does not own and for which it receives no benefit.

◦	As our detailed economic report shows, Dr. Malone will have no incentive to use New Charter to benefit his cable programming interests or vice versa; nor will he have the ability given New Charter’s strict governance rules and applicable FCC rules.

•	Programming cost savings will benefit New Charter’s customers in the form of more competitive subscriber fees and increased investment in infrastructure and innovation.

•	The transaction will not increase programming costs for smaller providers.

◦	Programmers have already bargained for the maximum fees they can get from smaller distributors.

◦	In the AT&T-DirecTV transaction, the FCC said to the extent volume discounts are a problem, the issue is not transaction specific and would be better addressed in an industry-wide proceeding.

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•	New Charter is taking on debt for good reason; to finance two mergers that will increase competition.

•	New Charter’s debt levels will not be unusual and will be lower than some of its peers.

•	New Charter’s plans to deleverage rely on EBITDA and cash flow growth, not rate increases.

•	New Charter is differently situated than Comcast.

◦	Charter’s broadband customer practices are intentionally designed for online video.

◦	New Charter does not have significant programming interests to protect.

◦	Charter wants to provide its video subscribers with access to OVD content, which it views as complementary.

◦	Charter has chosen to develop a cloud-based delivery system - as opposed to a CPE centric one like Xfinity - which will enable us to partner more cost effectively with OVDs.