3. Position of Applicants

Applicants assert that the data request is relevant to the competition issues in this proceeding. They argue that Cox has explicitly stated that the proposed transaction will have a negative impact on competition in California. Cox also has challenged Applicants' assertion that intermodal competitors such as cable companies will permit California consumers to choose from a large pool of competitive providers in a post-merger world. (Cox Protest, at 3.) Applicants state that they have sought FCC Form 477s from several intervenors in an attempt to show the relative size of cable and wireless operations in the state. Applicants state that only Cox has refused to provide the information.