Regulatory Comments

ICLE Comments to FCC RE: MB Docket No. 17-318 – National Television Multiple Ownership Rule

On behalf of the International Center for Law & Economics (ICLE), I respectfully submit the attached article by Eric Fruits, “Media-Ownership Regulations in a Streaming World: Time to Change the Channel” (Mar. 5, 2025), for inclusion in the record of the above-captioned proceeding.

As the Commission considers refreshing the record in the National Television Multiple Ownership Rule proceeding, Fruits’ analysis highlights the significant changes that have occurred in the video marketplace since the prior comment cycle closed. The article explains how the rise of streaming services, shifts in consumer behavior, and technological convergence render legacy ownership rules increasingly mismatched with competitive realities.

By comparing the regulatory treatment of broadcast, cable, and streaming platforms, Fruits underscores the distortions created by disparate ownership restrictions and suggests that a technology-neutral framework grounded in competition principles would better serve consumers and the public interest. We believe this perspective provides valuable insight to the Commission’s consideration of whether to retain, modify, or eliminate the national audience-reach cap and the related UHF discount.

Please include the attached article in the record of MB Docket No. 17-318.