FCC Record, Volume 28, No. 5, Pages 3700 to 4038, Supplement (March 2013) Page: 3,756
iii, 3700-4038 p. ; 28 cm.View a full description of this book.
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Federal Communications Commission
First, not all providers assign telephone numbers to the mobile devices on their networks. Thus, the
NRUF data do not include connections of Clearwire (which does not assign telephone numbers to its
devices) that are not also Sprint connections, and Clearwire is not counted as a separate provider in the
Report's HHI calculations.'76 Second, some data-only mobile devices are assigned telephone numbers by
some providers, but some providers do not assign telephone numbers to many of these data-only devices.
The inconsistent application of telephone numbers by different providers to the same or similar data-only
devices may decrease a provider's number of connections (in the NRUF data) relative to the provider's
publicly-reported number of connections. This may cause variation across providers' market shares that
would not be present if a consistent accounting of devices were available at the sub-national level.
57. Wholesale customers are included with the customers of their hosting facilities-based
providers, except for the wholesale customers of Clearwire, virtually all of whom are already included in
Sprint's connections.'" Therefore, market shares of MVNOs are not quantified separately in the Report's
concentration metrics."7 Leading industry analyst reports on the mobile wireless industry also include
wholesale subscribers with retail subscribers when they calculate market concentration metrics.'"
58. A national weighted average HHI across EAs is obtained by averaging the HHIs of all
172 EAs, with more (less) importance attached to EAs that have a higher (lower) population.'80 Although
we calculate the HHI on an EA geographical market for this Report, as shown in Table 14 and Chart 1,
we do not conclude that EAs are the appropriate geographic market for other purposes.'"' The value of
the HHI depends on the assumed geographical market. Basing the HHI on broader (narrower) geographic
markets will generally result in lower (higher) HHI values. Calculating the HHI at the level of a CMA,
for example, which is the geographic market typically used in the Commission's review of transfers and
assignments of mobile wireless licenses, would generally result in an average market HHI that is higher
than one based on EAs. Calculating the HHI based on a single nationwide geographical market would
result in a national HHI that is lower than for a national weighted average HHI across EAs, because the
total number of providers in the entire United States far exceeds the number of providers that compete in
any single local area. Applying the HHI to a single nationwide geographical market would assume that
every American is able to choose from more than one hundred facilities-based providers.'"
59. Current HHI Values. As shown in Table 14 and Chart 1, the weighted average of the
176 Based on publicly available information about Clearwire's customers, see Section III.D.2 supra, its exclusion is
not likely to have a material effect on the HHI estimates.
'" See Table 1, n. 122. See Section III.D.I. Market Shares. supra, for a discussion of how service providers do not
follow the same reporting conventions for wholesale connections.
'" See Section III.B.2, Resale and MVNO Providers, supra, for a discussion of the degree to which the
competitiveness of the mobile wireless market is increased by the presence of resellers and MVNOs relative to a
market scenario in which they are absent.
'" See. e.g., Glen Campbell, Get Ready for the Wireless Revenue Bounce, Bank of America, Global Wireless Matrix
4Q09, Dec. 13, 2009, at 10, 198 (Bank ofAmerica Global Wireless Matrix 4Q09); John C. Hodulik, et al., US
Wireless 411, Version 43.0, UBS, UBS Investment Research, Mar. 7, 2012 at 18 (US Wireless 411 4Q11).
'80 Letting P, be the population in the ith EA, P be the total population in all 172 EAs, and Hi be the HHI in the ith
EA, then the population weighted HHI is given by (P, H,+ P2 H2+... P172 H,2)/P.
"' Although the Commission typically uses 734 CMAs and 354 Component Economic Areas (CEAs) to calculate
the HHI screen in evaluating mobile wireless transactions, we use 172 EAs to calculate HHIs in this Report. We use
EAs in this Report to maintain continuity with past Reports and to avoid compromising the confidential information
found in the NRUF data.
* As discussed in Section II.A, the consumer searches for a mobile wireless provider in the local area where he
lives, works, and travels. In 2009, for example, MetroPCS's and Leap Wireless's networks had very little
overlapping coverage, and MetroPCS and Leap Wireless were not competitors in the same geographic areas. See
22, infra.3756
FCC 13-34
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United States. Federal Communications Commission. FCC Record, Volume 28, No. 5, Pages 3700 to 4038, Supplement (March 2013), book, March 2013; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc177415/m1/67/: accessed April 24, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.