3. Position of Applicants

Applicants assert that the data requests are relevant to the competition issues in this proceeding and, as narrowed, cannot be said to be unduly burdensome. They argue that Cox has explicitly stated that the proposed transaction will have a negative impact on competition in California. For instance, Cox in its protest stated that "[u]nless the Commission takes decisive action now," the proposed SBC/AT&T and Verizon/MCI combinations "will control and manipulate the telecom framework to the detriment of competition and consumers." (Cox Protest, at 2.) Cox also challenges Applicants' argument that "California consumers will be able to choose from a large pool of competitive providers in a post-merger world." (Cox Protest, at 3.) Cox also alleges that "[c]ombining these two companies necessarily and tangibly eliminates opportunities for competition in California." (Cox Protest, at 5.) Applicants argue that data requests 1 and 6 seek documents relevant to these allegations.