
Sky has submitted the research by consultants PricewaterhouseCoopers to Ofcom, which is consulting on the pay TV market after rivals complained Sky was too dominant.
The satellite broadcaster's submission also attacks Ofcom's decision to continue the investigation after earlier finding that the pay TV market "delivered significant benefits to consumers".
Companies' submissions are expected to be released in coming days but Sky's statement has been leaked to the media.
"As a fair and open-minded regulator, Ofcom should have concluded that, on the basis of the evidence in the consultation document alone, the sector is functioning effectively and delivering strong consumer benefits," it says.
"It would have been perfectly reasonable for Ofcom... to have made its initial assessment a firmer conclusion and to have decided that no further action is required."
Sky's submission continued: "...The investigation has inevitably become a quasi-adversarial process in which Sky is the defendant and the complainants the claimants”.
"Ofcom... must be wary of putting Sky in a position in which the burden of proof is reversed and in which Sky must comprehensively disprove wide-ranging and fanciful allegations by the complainants."
Complaints from BT, Setanta, Top Up TV and Virgin Media focused on Sky's ownership of a huge proportion of sports and premium movie rights. When it opened the consultation in December, Ofcom said it would look specifically at the availability of, and competition for, premium content.
Several media reports predict Ofcom will support regulatory changes aimed at forcing Sky to provide rights to competitors on a wholesale basis.
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