Consumer Coalition for Competition in Satellite Radio (known as C3SR) has made a petition to deny the merger, and has also filed several (18) separate exhibits with the FCC. To date C3SR has made 24 filings with the FCC. This organization has made claims to advocate on behalf satellite radio consumers. Do you share their opinion on the merger? You should let your stance be known.

C3SR has been shown to have been financially supported by the National Association of Broadcasters. In addition, the founder of C3SR is employed by Williams Mullens Strategies, which handles lobbying for the William Mullen Law Firm. This law firm's communications practice is headed by former NAB Assistant General Council Julian Shepard. Williams Mullen is the firm, and Julian Sheppard is the attorney that is listed in all C3SR filings. Thus, a former power player with the NAB has an employee who has created C3SR, and C3SR claims to advocate on behalf of satellite radio consumers.

I have posed many times a few key questions relating to C3SR, and have some additional ones as well:

1. When C3SR was created they claimed to be an advocate on behalf of satellite radio consumers, and already had a position against the merger. How can you already be an advocate on behalf of a group if you have not established the opinion of the group?

2. Membership roles at C3SR seem to be a secret. How many people have actually signed on in support of their activities? How many of those members are satellite radio subscribers?

3. C3SR has never offered a poll on their website to obtain the pulse and opinion of satellite radio subscribers. Again, how can you claim to advocate on behalf of a group of people unless you understand the collective opinion of those people?

4. The C3SR website has a blog with the latest post being on March 20, 2007. It has been nearly 4 months since that was updated. I have personally tried to comment a pro merger stance on many of the posts, yet those comments go unpublished. Are pro-merger comments censored by this group? Readers can try for themselves to express their opinion on the C3SR blog. Let us know if you have success getting a pro-merger opinion expressed.

5. The Industry News section of the C3SR site is packed full of merger related news….as long as it is against the merger. Any Pro-Merger news items do not seem to make the page.

6. How much of C3SR’s funding came from the National Association of Broadcasters?

7. Is C3SR really advocating, or are they dictating?

I take no exception with an organization acting on behalf of a group IF that is what is happening. In the case of C3SR, I think that satellite radio consumers can raise some legitimate questions as to who’s interest C3SR is acting on, and until such clarity is established by answering some basic questions, there may well be a cloud associated with any opinion expressed by C3SR. At a minimum, C3SR should rescind their claim to be an advocate for the entire group. If they want to claim advocate status for anti-merger satellite radio subscribers, it would be more representative of what seems to be transpiring.

Now that the FCC has established a reply period, perhaps this is the opportunity for satellite radio consumers to let the FCC know whether or not C3SR is truly representative of your opinion. If C3SR will not give the clarity, perhaps the FCC replies directed towards the C3SR filings will.

Readers can easily submit their reply regarding C3SR comments and petitions to the FCC by visiting or Remember to cite the specific filing(s) you are replying to. Here are the C3SR filings (type in 07-57 for the proceeding box, and Mullen in the law firm box.

Position - Long Sirius, Long XM -IMOJB-