August 20, 2023

FTC Comments on Corporations

In April 2022 and August 2023, the Federal Trade Commission (the U.S. government agency tasked with ensuring fair business practices) announced a public comment period related to antitrust policy. I learned about this from The BIG Newsletter from Matt Stoller, and I thought I would submit comments to the docket, on the matter of my area of expertise -- that of media policy and media ownership concentration. I felt this this marks, or could potentiall mark, a change in policy from the past four decades of neoliberalism and lax enforcement of antitrust. I repost below my comments on the two rounds of comments on the docket.

COMMENT - FIRST ROUND: April 20, 2022

On June 3, 1992, I found out about the issue of American media concentration when I watched a news magazine on a public access cable channel in Michigan that discussed the issue. I had just graduated from high school two weeks before I watched this broadcast, and watching this was hugely revelatory, and hugely enraging. I had considered myself a reasonably well-informed individual, and yet I had never heard of the issue before. I felt like I had been robbed; where had this been all my life? (Incidentally, this June will mark the 30th anniversary of the broadcast, which is online here:

Upon reflection, it makes sense — the media are the only industry which command the ability to control wider awareness of their own politics. I felt so deeply about being deprived of such an important matter that I myself got involved for more than a decade in organizing to oppose media concentration and to raise awareness of the issue more widely, working with independent media productions as well as with community and national activist efforts for a better media. I even helped found a group devoted to the matter, Chicago Media Action (

The reasons why media concentration is bad, as chronicled by Ben Bagdikian and Robert McChesney among may others, are legion. To quote from a talk I gave in 2011 ( "[Media concentration leads to] increased commercialism, less journalism, less independence from the bottom-line, more conflicts of interest, fewer diverse perspectives, and even life-or-death situations, as was the case in the city of Minot, North Dakota, which in 2002 saw a chemical leak from a train derailment cause hundreds to be hospitalized and when local police tried to get on the radio to alert the public, they found six of the seven Minot radio stations controlled from a single Clear Channel office which was unstaffed at the time of the leak." Just this week, I found out about another post which outlined additional concerns (, and it’s easy to go on.

It might be seen as misplaced to bring this matter to the attention of the FTC rather than the FCC, but then again perhaps not — the media are corporations, many corporate media mergers require FTC approval in addition to FCC approval, and corporations can be broken up or otherwise hobbled by FTC action. I am heartened that the FTC is finally interested in taking seriously its role as a critic of mergers, and I encourage the FTC to continue in this regard.

COMMENT - SECOND ROUND: August 13, 2023

I have long been involved with a Chicago-based community group called Chicago Media Action (CMA), online at

CMA has worked on improving media in Chicago and nationwide, and as a result CMA agrees to the notion that increasing corporate consolidation of media results in worse media. Hence, CMA has actively opposed corporate consolidation and has in particular worked on campaigns related to media corporations. In this comment I would like to share some of my experiences with CMA regarding corporate consolidation. I refer you to two examples -- one against corporate consolidation more broadly, one focused on a specific instance of consolidation.

Example One: From September 2002 through September 2003, CMA was involved in the campaign to stop the Federal Communications Commission from gutting its media ownership rules that would have increased media concentration to unparalleled levels. CMA members drove to Richmond, Virginia, to participate in the only official FCC public hearing on the issue. CMA members helped organize the Midwest Forum on Media Ownership, held in downtown Chicago. CMA members organized a Halloween-themed protest in downtown Chicago, at McCormick Place during a conference of cable TV executives, and at Tribune Tower on the day a court blocked the FCC's rule rewrite. I can tell you, as someone involved with many of these efforts, the corporate media gave these CMA efforts a grand total of zero coverage. What coverage we got was entirely outside the mainstream -- neighborhood newspapers, college radio stations, public access television, and the pre-social-media internet; we were grateful for what coverage we got but it was a serious effort to get any coverage at all.

Example Two: On July 13, 2010, Northwestern University Law School in downtown Chicago held a Public Forum, organized again by the FCC, on the then-proposed merger of Comcast and NBC Universal. CMA released an analysis of the 69 people who signed up and spoke at the forum, which I am attaching as a PDF document to this forum. These 69 individuals were divided almost evenly between those in favor of the merger and those opposed, but a strong majority of those in favor (29 of 35 speakers, by my count) were from various Chicago non-profits that received Comcast support, none of whom offered any reasons as to why the merger should be approved. Meanwhile, the remainder represented a variety of groups and individuals and offered ample reasons and concerns to oppose the merger -- including increased layoffs, reduced media diversity, reduced diversity of opinion, increased omission of important issues, network neutrality, First Amendment rights, and Comcast's dismal record on consumer rights, among others. Despite this panoply of valid concerns, Comcast was able to win its buyout of NBC Universal.

I support the FTC's increased scrutiny of corporate consolidation, which is necessary for a better media and a better economy. I encourage the resurrection of a robust antitrust tradition in the FTC and in American government, in opposition to the neoliberal regime we've had for the past four decades. And the FTC's mandate not unrelated to CMA's media work -- many media mergers require FTC approval in addition to FCC approval.