From the top, the two hit the question of how the merger will benefit consumers: (Opponents to the merger start with the opposite tack—how will it hurt consumers?) Their arguments: increased investment by getting putting NBCU under the control of media company, not a manufacturer like GE; investing in NBCU will keep/create jobs; and commitment to “quality"news, sports, and local programming.

As for competition and antitrust complaints, the two contend: “The proposed transaction is primarily a vertical combination of NBCU’s content with Comcast’s multiple distribution platforms. Antitrust law, competition experts, and the FCC have long recognized that vertical combinations can produce significant benefits.”

And, as was the case with Siriuss XM, Comcast and GE want a re-think of the term “competition.” They want NBCU to be viewed as one of myriad content providers in a growing, competitive “communications and entertainment marketplace.” Their take: 

“There are literally hundreds of national television networks and scores of regional networks. These networks compete not only with each other but also with countless other video choices – both for consumers’ attention and for distribution on various video platforms. In addition, content producers increasingly have alternative outlets available to distribute their works, free from any purported ‘gatekeeping’ networks or distributors. In this universe of content producers, with competitors such as Disney/ABC (NYSE: DIS), Time Warner (NYSE: TWX), Viacom (NYSE: VIA), and News Corp. (NYSE: NWS), the new NBCU will have the incentive and financial resources to give consumers the high-quality programming they want and no incentive – or ability – to restrict competition or otherwise harm the public interest.”

Of course, what really matters here for the proposed merger isn’t the way words are chosen in advance but how Roberts and Zucker stay on message—and how many points subcommittee members want to score.

Here’s the full statement: Roberts_and_Zucker_Testimony.pdf