Yesterday, economist Daniel English and I filed comments at the FCC in the cable ownership caps proceeding. (MM Docket No. 92-264)

In the filing, Daniel and I argue that because of the array of new distribution platforms and the resulting increase in outlets and competition, cable ownership caps are no longer needed. More broadly, we show how the old regulatory model for analyzing media ownership issues is obsolete in light of rapid market evolution and ongoing technological innovations. Any future market power issues that might creep up in the media sector can be better handled by relying on the nation's antitrust laws, we argue.

In our new media model, we show how media content is no longer tied to specific distribution platforms and receiving devices because of the transition to digital formats and transmission methods. The combination of ongoing digital convergence and an increase in market innovation and entry makes it nearly impossible for any media company to restrict the flow of programming in the market. Simply stated, cable ownership regulations are specifically geared towards an outdated media environment and no longer apply to today's video marketplace.

Again, the paper can be found here, and you might also be interested in this earlier filing that we did in the Comcast-Time Warner-Adelphia merger proceeding. Daniel and I also recently penned a short paper entitled "Testing 'Media Monopoly' Claims: A Look at What Markets Say" in which we evaluate the market performance of five large media stocks (Time Warner, News Corp., Clear Channel, Comcast, and Viacom) over the past five years and show that they have lost 52 percent of their market value (in terms of market capitalization). Moreover, we chart the performance of the entire Dow Jones U.S. Broadcasting & Entertainment Index and show that it is down almost 45 percent below where it stood in 2000. This is another indication that the media industry is not one big monopoly but instead subject to intensely competitive rivalry and new entry / substitutes.

Finally, I'll just put in another plug for my recent book on these issues, "Media Myths: Making Sense of the Debate over Media Ownership" as well as an important paper by media economist Bruce Owen that we recently published, "Confusing Success with Access: 'Correctly' Measuring Concentration of Ownership and Control in Mass Media and Online Services."