JOINT CONCURRING STATEMENT OF 
COMMISSIONERS ROBERT M. MCDOWELL AND MEREDITH ATTWELL BAKER 
Re:  Applications of Comcast Corporation, General Electric Company and NBC Universal, Inc. 
For Consent to Assign Licenses and Transfer Control of Licensees, MB Docket No. 10-56
Combining assets of Comcast Corporation (Comcast) and NBC-Universal, Inc. (NBCU) 
is a complex and significant transaction that has the potential to bring exciting benefits to 
consumers that outweigh potential harms.
However interesting and intricate the issues raised by the combination of Comcast and 
NBCU may be, as a matter of law, our role at the Commission is limited to ensuring that the 
transaction complies with all applicable statutory provisions, such as ensuring that the license 
transfers are in the public interest.  Our analysis should only include a thorough examination of 
the potential benefits and harms of the transaction.  Any proposed remedies should be narrow 
and transaction specific, tailored to address particular anti-competitive harms.  License transfer 
approvals should not serve as vehicles to extract from petitioners far-reaching and non-merger 
specific policy concessions that are best left to broader rulemaking or legislative processes.
The Commission’s approach to merger reviews has become excessively coercive and 
lengthy.  This transaction is only the most recent example of several problematic FCC merger 
proceedings that have set a trend toward more lengthy and highly regulatory review processes 
that may discourage future transactions and job-creating investment.
In this instance, our review exceeded its limited statutory bounds.  Many of the 
conditions in the Memorandum Opinion and Order (Order) and commitments outlined in 
separate letter agreements were agreed to by the parties.  The resulting Order is a wide-ranging 
regulatory exercise notable for its “voluntary” conditions that are not merger specific.  The 
same is true for the separate “voluntary” commitments outlined in Comcast’s letter of 
agreement dated January 17, 2011.  While many of these commitments may serve as laudable 
examples of good corporate citizenship, most are not even arguably related to the underlying 
transaction.  In short, the Order goes too far.
More significantly, the Order has the potential to shape the future of entire industries, 
including the nascent online video market, on the basis of a record that is by necessity limited 
to facts pertaining only to the two parties.  At a time of innovation and experimentation that is 
both dynamic and disruptive, the Order fails to recognize that the contours of our collective 
video future are best shaped outside the Beltway.
To secure approval of the underlying transaction, we therefore concur.