The filing comes ahead of hearings at the Senate Judiciary Committee today about the deal.
Comcast's main argument is that it doesn't compete with Time Warner in any market in cable TV or in broadband, and that it faces potential competition from the likes of Google's nascent broadband service.
However, opponents believe that the increased power that the combined company will hold will hurt competition in the markets for video, television programming, broadband Internet access, and the $5B market for local cable advertising.
There are also concerns about the implications for net neutrality.
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