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- \u201cThe Complaint contains a number of serious factual inaccuracies and the arguments within it
are flawed. When properly tested, the Complaint fails to make out a basis for a market
- \u201cIt fails to take into account two extremely important elements of the actual context in which pay TV services in the UK are provided: (i) competition between pay TV and free to air television services; and (ii) significant and ongoing changes at almost every level of the audiovisual sector in the UK\u201d (B1.1)
- \u201cThe provision of pay TV services is treated in the Complaint as though it exists in a
hermetically sealed bubble, free from influence from, or interaction with, other services, as if
the only competition faced by providers of pay TV services is from other providers of pay TV
services.\u201d (B2.1) \u201cThis is self-evidently incorrect. All providers of pay TV services face
significant competition from, in particular, free to air television services.\u201d (B2.2).
very significant changes to the distribution and consumption of movies, including a
huge expansion in the number of movies available on free to air channels, a massive
expansion in the take-up and use of DVDs, and an increasing number of video on
demand movie services
introduction and take-up of new technologies, such as delivery of audiovisual
programming over the internet, personal video recorders, high definition (\u201cHD\u201d)
television; and mobile TV.
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