Category Archives: Regulatory Filings

Citizen Petition Requesting the FDA to Withdraw Approval of Adjuvant ACT Chemotherapy for BRCA1 Breast Cancer Patients (November 15, 2012)

Summary – This Petition provides the basis for the FDA to modify the industry-wide practice of administering ACT chemotherapy to BRCA1, triple-negative breast cancer victims because: a) there is little to no factual evidence to support its purported efficacy for this distinct subgroup; 2) there is reason to believe that it is disproportionately harmful to this subgroup of patients and 3) there are alternatives readily available for this subgroup with better results in clinical studies.

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Comments to the Federal Communications Commission on the Telecommunications Industry Structure (October 20, 2009)

Summary – Given the dominance of AT&T and Verizon in the telecommunications industry, unbundling, open-access and non-discrimination are necessary but not sufficient conditions to ensure a competitive broadband infrastructure market.

The Commission should supplement these regulatory requirements with a long-term comprehensive plan to develop a competitive broadband infrastructure market that would include acquisition guidelines, a dedicated antitrust watch-guard organization, and benchmarks for a competitive broadband market.

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Petition to the Federal Communications Commission for Structural Relief (September 4, 2009)

Summary – As AT&T and Verizon gobbled up direct and potential competitors over the past decade, they committed to meet certain pro-competitive provisions. But they have failed to do so, instead seeking to thwart competition through every available means.

The FCC should initiate a formal investigation into Verizon’s and AT&T’s practices. If AT&T and Verizon are found to have willfully violated the law or the FCC’s merger conditions, the Commission should find that they are unfit to hold mobile wireless licenses. This structural relief would break the stranglehold of collusion currently dominating the industry, and would unleash two new powerful companies with the incentive and ability to compete vigorously in all segments of the telecommunications market.

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Reply Comments to the Federal Communications on the Wireless Industry Dynamics (October 5, 2009)

Summary – Verizon’s expert witness has provided irrefutable evidence that the dominant carriers are colluding on price. As a result of this price collusion, AT&T’s and Verizon’s wireless profits are extraordinarily high and growing rapidly. Extrapolating the current revenue trends, consumers will be overcharged by up to $1 Trillion over the next decade relative to what the prices would be in a fully competitive mobile services market. The FCC should conduct a formal investigation into AT&T’s and Verizon’s pricing and market entry strategies – or refer the matter to the Department of Justice.

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