Public Interest and Civil Rights Groups Verizon/TracFone Filing

April 6, 2021

Acting Chair Jessica Rosenworcel

Federal Communications Commission
45 L Street NE
Washington, DC 20554

Re: File No. ITC-T/C-20200930-00173
GN Docket No. 21-112

Dear Acting Chair Rosenworcel:

On behalf of the undersigned groups we submit these comments in response to the Federal
Communications Commission’s (“FCC” or “Commission”) Public Notice regarding Verizon
Wireless Communications Inc.’s (“Verizon”) application to acquire TracFone Wireless, Inc.,
(“TracFone”) (collectively, “Applicants”).2 On March 30, 2021, the Acting Chief of the Wireless
Competition Bureau issued a Public Notice opening a permit-but-disclose docket for this
proceeding.3 The transaction presents potential public interest harms to Lifeline subscribers and
competition in the wireless market, impacting the ability of low-income communities to access
critical communications services. For these reasons, the undersigned groups strongly urge the
Commission, should this merger be approved, to impose strict enforceable conditions on the
transaction that will protect Lifeline customers and preserve the wireless reseller marketplace. At
a minimum, the Commission must issue a Request for Information to obtain information
sufficient to make the necessary public interest determinations and provide answers to the
questions that have been raised in the record.