The auction, which starts January 16th, has several other rules that corporations have complained about, such as a ban on wholesale frequency reselling. This is absolutely essential for smaller businesses to participate in the auction, Frontline says. "Wholesaling is also the only model a new nationwide wireless network operator could realistically afford to adopt," its petition reads, "given the massive costs associated with providing retail service -- consider Verizon's 2,300 retail outlets and its $1.9 billion annual advertising budget."

"Small" businesses are further restricted by the bidding reserve for two blocks of spectrum, Frontline charges. Acquiring 10MHz of spectrum, along with another 12MHz for emergency response, will cost at least $1.3 billion; another 22MHz of open-access spectrum will cost $4.6 billion. "Open-access" means allowing connections from devices on rival networks, and maintaining neutrality; Verizon has opposed this part in particular, claiming it violates the Administrative Procedures Act and even the US Constitution.