cross-ownership rule. In small markets, cross-ownership is prohibited. In mid-sized markets an entity can own a newspaper and either (a) one television station and 50% of radio stations, or (b) up to 100% of the radio stations. In large markets, cross ownership is unrestricted. The FCC determined this change was the best course of action for four reasons. 1) advertisers do not consider newspapers and television as close substitutes. 2) the previous ban did not allow efficient combinations that resulted in high –quality products that ultimately supported localism. The element of localism, one in which the FCC deemed vital to public interest, was shown through statistics and empirical examples of grandfathered television stations owned by newspapers. On average, these stations had much more local content in their television news than their competitors. They also were shown to have higher quality, as judged through consumer support (ratings) and industry support (broadcasting excellence awards) 3) The FCC did not believe that it had enough evidence that ownership affected view point to the degree that a blanket ban was required. 4) The presence of other media, such as cable and internet, adequately fill the void for view point lost due to consolidation. Diversity index The FCC created this tool to help identify markets where cross-ownership limits should be retained. The index was based on the Herfindahl-Hirschman Index (HHI), which is used by the Federal Trade Commission and Department of Justice to measure market concentration. It is commonly used to assess a merger's effect on competition in a market. HHI is calculated by summing the squares of each firm's share of a given market. Therefore, a highly competitive market will have a lower score. Included in the Diversity Index are broadcast television, newspapers, radio, and internet. Based purely on popularity of each media source, the FCC assigned broadcast TV 33.8%, newspapers 20.2%, weekly periodicals 8.6%, radio 24.9%, cable internet 2.3%, and all other internet 10.2%. Within each media type, the number of outlets were assigned an equal market share. The summation of all media types for each owner was then squared and added to the index. Scores were determined for all markets with five or fewer television stations, all markets with 15 to 20 television stations, and ten randomly selected markets with between six and ten stations. The FCC then considered what would happen to scores under different ownership limit scenarios. In small sized