Telephone company Qwest has applied to the Federal Communications Commission (FCC) to receive forbearance from some regulatory requirements. One of the factors the FCC considers in forbearance decisions is the degree of competition in wireline telephone services. In its measure of Qwest’s share, the FCC has included households that have ‘cut the cord’—i.e., households that have mobile wireless telephone service but no wireline service. Kent W Mikkelsen was retained by several competitive local exchange carriers (CLEC) who provide local telephone service in areas served by Qwest. In a paper submitted to the FCC (“Mobile Wireless Service to “Cut the Cord” Households in FCC Analysis of Wireline Competition,” April 21, 2008), Mikkelsen explained the principles that should be used to define the relevant market in which to measure competition in wireline telephone services. The FCC has not demonstrated that mobile wireless telephone service is in the same relevant market with wireline telephone service, and there is considerable evidence indicating that it is not. Without such a determination, the Commission’s procedure does not accord with normal practices in assessing competition and tends to overstate the extent of competition.