An Open Appeal to the FCC: Call for Media Regulation Reassessment

Tue Nov 04 2025 21:23:15 GMT+0200 (Eastern European Standard Time)

In an open letter to FCC Chairman Brendan Carr, H.E. Alkiviades David urges for a regulatory review to safeguard public interest in media ownership and ensure fair competition.

H.E. Alkiviades David, Ambassador-at-Large for the Green Economy, addresses FCC Chairman Brendan Carr in an open letter, highlighting concerns over the concentration of media ownership and urging a review of regulatory practices to support independent broadcasters. The letter outlines historical context, key issues from recent court cases, and specific actions requested to improve transparency and accountability in media regulation.

An Open Appeal to the FCC: Call for Media Regulation Reassessment

By H.E. Alkiviades David — Ambassador-at-Large for the Green Economy (Antigua & Barbuda) | Founder – FilmOn | Hologram USA | SwissX Sovereign Wealth Fund

FCC Chairman Brendan Carr — official portrait (Shockya Media 2025)

Statement of Purpose

This open letter is submitted in the spirit of transparency and accountability. The Federal Communications Commission safeguards a public resource—the airwaves—and must ensure they serve the public good. Where concentration or regulatory inertia undermines that mandate, citizens and innovators have a duty to request review.

For over a decade, my companies, including FilmOn, have engaged with the FCC and U.S. courts to define how lawful online broadcasters may coexist with legacy media. Critical issues around market access and competition now play out in the Eastern Caribbean Supreme Court and the King’s Bench Division.

Historical Background — FCC NPRM and Independent Innovation

In 2014, the FCC initiated MB Docket No. 14-261, a Notice of Proposed Rulemaking on promoting diverse sources of video programming. FilmOn was cited for delivering linear programming in line with the Communications Act, marking a pivotal moment in media competition policy.

Resistance from established networks delayed the rule's implementation, sidelining independent OTT operators while the largest conglomerates expanded their control. This highlighted the need for enforcement reflected in international litigation.

The FilmOn v. DoubleVerify case defined the digital-media landscape, affirming that advertising database classifications could constitute defamation, reinforcing technology vendors' responsibility for accurate labeling.

Grounds for Regulatory Review

Ongoing concentration of ownership among four U.S. broadcast conglomerates.

Unresolved issues in NPRM MB Docket 14-261 regarding modern MVPD definitions.

Need for coordinated efforts against advertising fraud and online exposure of harmful content.

Clarification of foreign ownership limits and public-access obligations.

Supporting Evidence & Exhibits

Exhibit B — Screenshot illustrating advertising system irregularities referenced in FCC oversight discussions.

Exhibit C — Feature showcasing cooperation among leaders on media reform initiatives.

Requested Actions by the FCC

Reconsider MB Docket No. 14-261 and update guidance for online MVPD operators.

Ensure advertising platforms do not monetize illegal content.

Clarify ownership transparency rules for cross-border media holdings.

Uphold public-access broadcasting as a core civic service.

Closing Statement

This letter accompanies legal documents filed in international courts. Allegations mentioned are drawn from public records. The aim is to foster lawful regulatory review and cooperation.

Respectfully submitted for consideration by the FCC, allied agencies, and oversight bodies.

H.E. Alkiviades David

Ambassador-at-Large for the Green Economy

Founder – FilmOn | Hologram USA | SwissX Sovereign Wealth Fund

investors@swissx.com | www.shockya.com | www.filmon.com