As Comcast gears up to prove its upcoming merger with Time Warner Cable doesn't violate antitrust laws, the company is rolling out a surprising argument.

In a letter from Comcast executive VP David L. Cohen, the company made the case that the cable industry has gotten more competitive since similar FCC rulings in the previous decade, due to an insurgent threat by Google Fiber projects and web TV services like Hulu. "In today’s market, with national telephone and satellite competitors growing substantially," the letter reads, "with Google having launched its 1 GB Google Fiber offering in a number of markets across the country, and consumers having more choice of pay TV providers than ever before, Comcast believes that there can be no justification for denying the company the additional scale that will help it compete more effectively."

Claiming Google Fiber as a competitor is, of course, ridiculous. Google's broadband project is currently only available in two markets, Kansas City and Austin, while Comcast will control 19 of the 20 largest markets in the US. Optimistic projections suggest Google Fiber might control as much as 2% of the broadband market by 2015. The pay TV provider claim has also drawn scrutiny, as the industry has seen immense consolidation in recent years, while web-based services like Hulu and Netflix have struggled to make meaningful inroads against the cable juggernauts.

Overall, the point is probably moot, as Comcast has already agreed to control less than 30% of the cable industry market share in accordance with a longstanding FCC guideline. Still, the argument stands as a reminder of just how dominant Comcast is in the cable space, and how far insurgents like Google Fiber have to come before they can present a meaningful challenge.