My comment to the FCC

My comment is most readable here:

, but if you view it here,

, then there are links on the left to view other comments and post your own.

I submitted my comment as a pdf file, and it was posted without alteration.


FCC Establishes Pleading Cycle

The proposed takeover of T-Mobile by AT&T now has a docket number, Federal Communications Commission, WT Docket No. 11-65 . The public notice is  . Petitions To Deny Are Due: May 31, 2011 .

Comments (meaning those “petitions”) can be submitted on the web using the Electronic Comment Filing System at  . The page specific to Docket 11-65 is:  .

You can “Submit a Filing (Express),” or “Submit a Filing.” The first option lets you type directly into a form, although you might want to prepare comments in a simple editor such as notepad, then paste them in. The non-express option allows you to submit a pdf or word-processing file.

Don’t delay! File your objections to AT&T’s proposal. The deadline is May 31, but the web site is open now for your comments. For ideas, read my postings and the articles linked at left.

GSM and Foreign Travel

In the US, two cell-phone technologies are in wide use, CDMA and GSM.  T-Mobile USA is a GSM carrier. In fact, among the national carriers, Verizon and Sprint use CDMA, while AT&T and T-Mobile use GSM. The takeover of T-Mobile by AT&T would reduce the number of major GSM carriers from 2 to 1.

GSM is widely used, and is the standard across Europe, where people cross borders frequently. A phone bought in Germany is technically capable of being used in France or Austria, for example. A German can visit France and his carrier will have a roaming agreement with a French carrier, and there you go, he can use his phone.

A SIM on a green background.

SIM on green background, seen actual size or a bit larger

Because GSM phones normally have a removable SIM, the German has another option, to use a French carrier, and buy some prepaid minutes from that company. SIM means Subscriber Identity Module, a tiny smart card as in the picture above. The German will buy a SIM for the French carrier, and put it in place of his normal German SIM, giving him a French phone number during his visit.

He will have other freedoms, for example to move his SIM from one phone to another, according to whim or when he gets a new phone. If the German carrier subsidized his phone, it may be locked to the one carrier, but after some delay they may give him an unlock code.

Another issue is that European phones use 900 MHz and 1800 MHz bands for voice, while USA carriers use 850 MHz and 1900 MHz. However, in the USA quad band phones are available for use as “world phones.” As new technologies come into use, new incompatibilities arise. But a quad band GSM phone can at least be used for voice calls in most of the 212 countries and territories with GSM service. A chatty but frugal American will make sure that her phone is unlocked, and buy new SIMs in the countries that she visits. Travel issues are discussed on the FCC web site.

Coming back to the issue of the proposed merger, T-Mobile has a liberal and clearly stated policy for unlocking a customer’s phone after a waiting period. AT&T is reputedly less helpful. Also, with 2 competing GSM carriers, if you believe your phone is unlocked, you can test it by borrowing a friend’s SIM for the other network.

Apart from travel, there is a bit more of a free market for GSM phones, because they are used around the world. See this search . Considering the issues of travel and of shopping for phones, having 2 GSM carriers adds to the overall freedom of USA cell phone users.

UPDATE, Sunday 2011 May 8: The Washington Post has a new article on this topic , called “Travelers, phone home — it’s so SIMple,” by Andrea Sachs.


Here are some words that I used earlier on and Howard Forums:

Wall Street Journal has had many articles on the proposed merger. I commented on several. Under the headline “Vote Now: Should Washington Approve the AT&T/T-Mobile Deal?” , I said:

o 6:52 pm March 24, 2011
o Jim Worthey wrote:

The cell industry raises unique issues. The original American Telephone and Telegraph had a monopoly of “land lines” for 75 years. Phones were said to be a “natural monopoly.” Now there are competing land lines, Competitive Local Exchange Carriers. It took years to work out that system. But for many people, cell phones give the best competition. In my household, we use a CLEC. For cellular, I have T-Mobile and in fact my son uses AT&T mobile. We are low-usage prepaid cell users, a group threatened by this takeover. After generations of the autocratic Ma Bell, and only a few years of reasonably-priced cell service, do we need a new oligopoly by former Bell System operators?

T-Mobile uses GSM technology for voice. From an engineering point of view, it may be not quite as clever as the CDMA tech used by Verizon and Sprint. But GSM normally comes with an extra dimension of freedom and competition. That is, your phone number is tied to a SIM, a Subscriber Identity Module. You can switch phones by moving the SIM. You can switch carriers by putting a different SIM in the phone. Some phones are locked, but they can be unlocked. T-Mobile is very reasonable about unlocking phones for customers. If I go to Europe or Thailand or elsewhere, I can take my phone and use a local SIM during my visit.

I think the case against the merger is pretty strong. Certainly the FCC can understand some of the issues. We had a monopoly for 75 years!

Cellphone User Forums

One benefit of cell phone competition is… there’s a lot to talk about. Users analyze phones and services on

Howard Forums .

Discussions specific to T-Mobile are grouped here

and here, .

A source for new developments is


And there’s a good discussion on T-Mobile’s own web site,


Write your Congressman?

To contact your congressman, you can begin with

Click Write Your Representative to verify who your congressman is, and to type an email.

To locate your congressman’s web page, you can start on

then choose one:

  • Fill in your 9-digit zip and click Go.
  • Find representative by name from drop-down.
  • Click Representatives on the left.

The Senate of course is simpler. Visit

and click Senators .

You can still send paper letters to your Congressman or Senator, but there is a delay while the letter is sterilized.

Don’t forget the FCC and FTC also.

Hello Reader! Welcome to my new blog.

Welcome to MobileCompete. This is my first post. This blog has a simple goal. AT&T is offering to buy T-Mobile USA from its parent company, Deutsche Telekom . You can read the announcement:

T-Mobile News Release.

I am not a lawyer or even an activist. However, such a merger is apparently subject to antitrust review by both the FCC (Federal Communications Commission) and the FTC (Federal Trade Commission). The existing major wireless carriers are Verizon Mobile, AT&T, T-Mobile and Sprint. With 4 major national firms, customers have enjoyed competition in important areas:

  • The technology for voice transmission, either GSM or CDMA.
  • Coverage area.
  • Service quality in big cities.
  • Pricing plans. For example, all 4 big carriers offer some sort of prepaid service. T-Mobile has been a leader in prepaid, with Pay As You Go plans that are a favorite of low-usage customers.
  • Customer service.

Although the national networks have grown by purchasing regional carriers, the 4 big companies have many differences, and the competition is real, not an oligopoly. If AT&T is allowed to buy T-Mobile, we will be on our way to oligopoly.

So, I am against the merger. The goal of the MobileCompete blog is modest: to organize links to published facts and opinions. If citizen A wishes to lobby Congressman B, then A can send B a link to this blog, as a brief way to build the case. Does this make sense? Please comment.

Thanks for reading and commenting!

Jim Worthey