1. This submission begins with a section intended to put the main body of the submission into context, it covers competition in telecommunications, cable telephony, the long term prospects for the cable companies, and competition in television services. The main body of the submission starts by considering the relevant market. It then goes on to analyse Sky's market position and whether there are also significant barriers to entry. In the light of these it considers whether Sky might be considered as dominant in one or more of these markets. The submission then goes on to address the issues concerning access to networks; the rate card, security of supply and other contractual terms, and channel packaging issues. It ends with our conclusion and summary of the suggestions on remedies which are included at the end of the relevant sections. The Annex deals with a number of further issues raised in the issues paper.

2. There are a number of issues where we have not felt in the position to offer views. (In some case we are aware of concerns but have not ourselves received evidence or complaints). These are:

• comparative retail prices in other countries and whether the operation of the wholesale market might be resulting in UK consumers paying higher prices than consumers in other countries;
• to what extent arrangements between Sky and the producers of programming such as film studios might be having an effect on the UK market or prices to UK consumers (or both) - either by inhibiting the availability of outlets for UK and other European film producers or by increasing royalty payments compared with levels in the US or other European countries;
• Sky's dealings with programme suppliers wishing to gain access to the UK market.

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