Excerpt from a letter sent by CenturyLink, Inc. to FCC Secretary Marlene Dortch:
CenturyLink, Inc. (“CenturyLink”) addresses herein statements made in the “Fact Sheet” released on October 7, describing Chairman Wheeler’s proposal for regulating the business data services (“BDS”) marketplace and various related claims in the associated record.
In evaluating competition, the Commission does not, of course, write on a blank slate. Rather, it has long adhered to broadly accepted precepts, shared by economists and regulators alike, concerning market definition, the appropriate use of econometric analysis, and a host of other matters. The Commission should not repudiate these settled principles here, particularly not for the purpose of setting its thumb on the scale and picking market winners and losers. Rather, it should embrace long-settled tenets of competitive analysis, and amend the Fact Sheet’s conclusions in the ways detailed above.