Call for Fair Media Regulation: An Open Letter to the FCC



FCC


Statement of Purpose


This letter is submitted to promote transparency and accountability in media regulation. The FCC has the responsibility to safeguard public resources like the airwaves for the benefit of all citizens. Citizens and innovators must request a review where existing concentration or regulatory stagnation endangers this goal.


Over the past decade, our companies, including FilmOn, have engaged with the FCC and court systems to clarify how lawful online broadcasters coexist with traditional media. Key matters concerning fair market access and accurate classification are currently in discussion before the Eastern Caribbean Supreme Court (ANUHCV 2025/0149) and King’s Bench Division (KB-2025-001991).




Historical Context


In 2014, the FCC initiated MB Docket No. 14-261, addressing the need to promote diverse and independent video programming sources. FilmOn was acknowledged as a key player in this developing space, representing a turning point in media competition policy.


Resistance from major networks stalled implementation, resulting in unprotected independent operators while the largest conglomerates extended their control. This lack of decisive regulation highlighted the need for reform, especially as underscored by the FilmOn v. DoubleVerify case in 2019, which emphasized truthful classification in advertising.


This context highlights the necessity for updating regulations to treat independent broadcasters as partners rather than competitors in the evolving communications ecosystem.




Request for Regulatory Review



  • Ongoing concentration of media ownership among four major U.S. broadcasting conglomerates.

  • Need for progress on NPRM MB Docket 14-261 and precise definitions for modern MVPDs.

  • Inter-agency collaboration required to combat advertising fraud and protect online users.

  • Clarification needed on ownership limits and public access obligations.




Requested Actions by the FCC



  • Review and update MB Docket No. 14-261 for online MVPD regulations.

  • Collaborate with DOJ and FTC to ensure advertising systems do not endorse illegal content.

  • Clarify ownership transparency rules for cross-border media holdings.

  • Reestablish public-access broadcasting as a fundamental civic function.




Conclusion


This communication accompanies legal filings with the Eastern Caribbean Supreme Court and the High Court of Justice. All allegations mentioned are founded on public records and filings. Our goal is to foster lawful regulatory oversight and better coordination across agencies.


Submitted respectfully for the Federal Communications Commission and independent media stakeholders for consideration.


H.E. Alkiviades David
Ambassador-at-Large for the Green Economy (Antigua & Barbuda)
investors@swissx.com | www.shockya.com | www.filmon.com