Dish Network plans to participate in the upcoming...

officials encouraged the FCC to impose separate bidding eligibility, activity waivers, and auction stopping rules for the different spectrum bands to be sold in the AWS-3 auction -- the 1695-1710 MHz and 1755-1780/2155-2180 MHz bands. “Given that the licenses for the two bands are not substitutes, there is no legitimate, pro-competitive reason for the Commission to combine bidding eligibility, activity waivers, and auction stopping rules,” Dish said. Ergen also asked the FCC to reject Comcast’s proposed buy of Time Warner Cable. The deal “presents serious competitive concerns for the broadband and video marketplaces and therefore should be denied,” Dish said. “There do not appear to be any conditions that would remedy the harms that would result from the merger.” Comcast/TWC would be able to “choke” competitor OTT services at several points in the broadband pipe, Dish said. It would be able to “exercise its enormous size to leverage programming content in anti-competitive ways,” Dish said. That could include extracting lower prices from programmers, which could lead to those programmers charging higher rates to companies like Dish to make up lost revenue, the filing said. Comcast/TWC would also have incentive to restrict programmers’ ability to grant digital rights to competing pay-TV and OTT services, Dish said. Dish also raised concerns about the proposed AT&T/DirecTV deal. “Among other things, AT&T and DIRECTV will also be able to combine their market power to leverage programming content, to the potential detriment of consumers,” the filing said. Ergen also met with the four other commissioners Monday, the filing said.