Fiber Optic Competition in Puerto Rico

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FTI Fiber Inspection Results

April 20, 2020

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FTI Qualifications

FTI’s team of telecommunications professionals have a vast amount of experience performing field inspections in a wide variety of investigations.

Steven Turner is a Senior Managing Director in FTI’s TMT practice with over 30 years of telecommunications experience including, among other things, planning, engineering, constructing, operating and maintaining fiber optic communications networks. – Mr. Turner has over ten years of experience in Puerto Rico, including performing diligence on fiber construction and testifying in multiple proceedings before the Telecommunications Regulatory Board of Puerto Rico on issues related to engineering and operations.

Brian Pitkin is a Senior Managing Director in FTI’s TMT practice with over 20 years of telecommunications experience including, among other things, modeling telecommunications networks for a wide variety of due diligence, operations improvement and regulatory matters. – Mr. Pitkin has over 20 years of experience working in Puerto Rico, serving as Senior Vice President of Business Operations for a Puerto Rican competitive telecommunications carrier and testifying in multiple proceedings before the Telecommunications Regulatory Board of Puerto Rico.

Steven Turner and Brian Pitkin have performed competition assessments and infrastructure analysis in numerous matters including, among others: Paniolo’s restructuring of its fiber infrastructure, Zayo’s sale to Digital Colony, Windstream’s acquisition of EarthLink, Level 3 Communications’ acquisition of Global Crossing, and AT&T’s mergers with SBC and BellSouth.

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Table of Contents

OVERALL CONCLUSIONS APPROACH TO FIBER INSPECTIONS SUMMARY OF RESULTS

APPENDIX A: SUMMARY OF TERMS AND EXPLANATION OF ANALYSIS APPENDIX B: IDENTIFICATION OF PROVIDERS APPENDIX C: EXPLANATION OF SUPPORTING DOCUMENTATION APPENDIX D: FIBER EVIDENCE SUPPORTING DOCUMENTATION APPENDIX E: FTI TEAM LEADERS REDACTED – FOR PUBLIC INSPECTION

Overall Conclusions REDACTED – FOR PUBLIC INSPECTION

Liberty – AT&T Fiber Inspection Assignment

Determine the presence of fiber cable used to provide communications services at locations where information from Liberty and AT&T indicate potential overlapping fiber infrastructure.

Information Provided: – Matrix provided to FTI a list of customer names, addresses and geocoordinates for buildings where both Liberty and AT&T appeared to serve customers with fiber (HC “Algorithmic Overlaps”). – This list was initially prepared based on Liberty and AT&T fiber-fed buildings being within 100 feet of each other. – The Algorithmic Overlaps were located in San Juan and other urban areas of the island (such as Aguadilla, Mayaguez, Ponce, and Fajardo), with less frequent overlaps in relatively rural areas of Puerto Rico. FTI Assignment: – FTI personnel traveled to each of these Algorithmic Overlaps with several specific objectives: 1. Photograph the Liberty fiber building associated with the customer name, address and geocode information; 2. Remove Algorithmic Overlaps where the AT&T fiber building was not a true “overlap” of the Liberty building (HC “Non-Overlaps”); 3. Confirm and photograph the presence of Liberty and AT&T fiber at or around remaining overlaps (HC “Overlap Sites”); 4. Locate, identify and photograph any additional fiber providers (“Competitive Fiber Providers) within close proximity (generally 0.2 and 0.5 miles) to the Overlap Site. – FTI was asked to create an accurate record of fiber providers (Liberty, AT&T, and Competitive Fiber Providers) in or near the HC Overlap Sites (“Fiber Evidence Locations”). Before COVID-19, FTI performed field inspections at HC of the HC Overlap Sites (92.2%). – Field inspections confirmed the presence of both Liberty and AT&T fiber within 0.5 miles for 99.2% of those Overlap Sites visited and within 0.2 miles for 98.3% of those Overlap Sites visited (“Confirmed Overlaps”).

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FTI Conclusions on Competition

Field inspections demonstrate that substantial fiber competition exists across Puerto Rico.

– Competitive Fiber Providers are prevalent across Puerto Rico. – Competitive Fiber Providers exist within 0.5 miles of Confirmed Overlaps at least 99.3% of the time and within 0.2 miles at least 97.7% of the time. – At least two Competitive Fiber Providers exist within 0.5 miles of Confirmed Overlaps at least 88.0% of the time and within 0.2 miles at least 83.4% of the time.

– Fiber competition is facilitated by the extensive presence of aerial fiber in Puerto Rico.

– Aerial fiber is prevalent at Confirmed Overlaps across the island and among all providers. – Aerial fiber is substantially less costly to install than underground fiber, making it more economic for providers to justify building to serve customers in excess of 0.2 miles from existing fiber facilities. – Given the prevalence of lower-cost aerial fiber across Puerto Rico, existing facilities within 0.5 miles or further enable a provider to effectively compete.

– FTI’s statistics are related to fiber only. While PRTC/Claro also has a copper network, FTI has considered only the fiber facilities that PRTC/Claro has deployed at Confirmed Overlaps across Puerto Rico. – Other types of facilities (copper, coaxial, HFC, and wireless) are not addressed in this report.

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FTI Conclusions on Competition (continued)

– Competition is found throughout the island, not just in San Juan. – In the San Juan/Bayamon/Caguas MSA, there was at least one Competitive Fiber Provider within 0.5 miles for 99.7% of the Confirmed Overlaps and within 0.2 miles for 98.4% of the Confirmed Overlaps. – In the remainder of the MSAs across Puerto Rico, there was at least one Competitive Fiber Provider within 0.5 miles for 98.0% of the Confirmed Overlaps and within 0.2 miles for 95.5% of the Confirmed Overlaps.

San Juan Not Aguadilla San Bayamon Assigned Isabela Arecibo Guayama Mayaguez Ponce German Caguas Yauco To an MSA Total

Confirmed Overlaps HIGHLY CONFIDENTIAL Competitive Fiber Provider within 0.5 Miles % Confirmed Overlaps with Competitive Fiber Provider 96.7% 100.0% 90.9% 100.0% 98.1% 88.9% 99.7% 100.0% 100.0% 99.3%

Confirmed Overlaps HIGHLY CONFIDENTIAL Competitive Fiber Provider within 0.2 Miles % Confirmed Overlaps with Competitive Fiber Provider 96.7% 100.0% 81.8% 93.0% 98.0% 77.8% 98.4% 100.0% 100.0% 97.7%

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Approach to Fiber Inspections REDACTED – FOR PUBLIC INSPECTION

Approach to Fiber Inspections

FTI performed direct field inspections of the fiber and documented the presence and identity of underground and aerial fiber at each of the Confirmed Overlaps.

Field Inspections – Photographs: – For each Confirmed Overlap, FTI conducted a field review to collect information on both aerial and underground fiber optic infrastructure in the surrounding area and take photographs to document the findings. – This effort resulted in thousands of detailed photographs illustrating fiber in close proximity to the Confirmed Overlaps, which were then organized into Fiber Evidence Locations – geographic points where photographs were taken of fiber providers (such as a single aerial fiber pole, cabinet, or underground fiber protection vault). – Field review teams encountered situations where the fiber was inaccessible or clear photographs were hard to obtain. – Field review teams were often required to take photographs after climbing aerial poles 15-20 feet tall. – Fiber Evidence Locations may have been in restricted access areas, preventing further investigation. – To address these challenges, the review teams were able to identify common identifiers used by local providers (e.g., colors and symbols on fiber cables, markers, tags, and manhole covers) so that they could accurately record provider information at each Fiber Evidence Location even if the photographs were not sufficiently detailed. Field Inspections – Data Analysis: – These field reviews were sufficient to identify the operators, including Liberty and AT&T, that offered fiber optic services at or near the Confirmed Overlaps. – Photographs were geotagged with GPS coordinates to facilitate geospatial analysis and to enable mapping of the Fiber Evidence Locations relative to the Confirmed Overlaps. – Data for each Fiber Evidence Location and each photo was entered into a spreadsheet for statistical analysis.

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Map of Overlap Sites Across Puerto Rico

Geographic distribution of Overlap Sites.

HIGHLY CONFIDENTIAL

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Map of Fiber Evidence Locations across Puerto Rico

FTI identified and documented fiber at HC locations (poles, manholes, etc.) across Puerto Rico.

HIGHLY CONFIDENTIAL

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Summary of Results REDACTED – FOR PUBLIC INSPECTION

Summary of Results

There is substantial fiber-based competition across the entire island of Puerto Rico.

Overall Conclusions: – 99.3% of the Confirmed Overlaps are also served by at least one Competitive Fiber Provider within 0.5 miles, and 97.7% of the Confirmed Overlaps within 0.2 miles. – 88.0% of the Confirmed Overlaps are also served by at least two Competitive Fiber Providers within 0.5 miles, and 83.4% of the Confirmed Overlaps within 0.2 miles.

Competitor and Geographic Conclusions: – PRTC/Claro and PREPA are the most frequent Competitive Fiber Providers, each serving roughly three-quarters of the Confirmed Overlaps (80.8% and 72.2%, respectively as measured for Confirmed Overlaps within 0.5 miles). – The geographic distributions of PRTC/Claro and PREPA fiber across Puerto Rico were roughly in line with Liberty’s and AT&T’s distributions. – 58.3% of the Confirmed Overlaps within 0.5 miles were in the San Juan metro area (defined as the area between latitudes 18.3 through 18.5 and longitudes -65.9 through -66.2) and 77.4% were in the San Juan/Bayamon/Caguas MSA. – 55.6% of PRTC/Claro’s fiber at Confirmed Overlaps within 0.5 miles was in metro San Juan (75.9% in the San Juan/Bayamon/Caguas MSA). – 63.1% of PREPA’s fiber at Confirmed Overlaps within 0.5 miles was in metro San Juan (79.3% in the San Juan/Bayamon/Caguas MSA).

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Map of Competition within 0.5 Miles of Confirmed Overlaps

HIGHLY CONFIDENTIAL

Note: 14 HC There are additional Confirmed Overlaps at the 0.5 mile threshold than at the 0.2 mile threshold. REDACTED – FOR PUBLIC INSPECTION

Map of Competition within 0.2 Miles of Confirmed Overlaps

HIGHLY CONFIDENTIAL

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Overall Summary Statistics (by # of Competitive Fiber Providers)

99.3% of Confirmed Overlaps also have at least one other Competitive Fiber Provider within 0.5 miles, with 97.7% having a Competitive Fiber Provider within 0.2 miles.

Competitive Fiber Provider Competitive Fiber Provider Within 0.5 miles Within 0.2 miles

Site % Confirmed Overlaps Site % Confirmed Overlaps Count Discrete Cumulative Count Discrete Cumulative

HIGHLY HIGHLY Confirmed Overlaps CONFIDENTIAL 100.0% CONFIDENTIAL 100.0% 5+ Competitive Fiber Providers 34.0% 34.0% 22.5% 22.5% 4 Competitive Fiber Providers 9.8% 43.8% 6.8% 29.3% 3 Competitive Fiber Providers 15.2% 58.9% 16.5% 45.7% 2 Competitive Fiber Providers 29.0% 88.0% 37.7% 83.4% 1 Competitive Fiber Provider 11.4% 99.3% 14.3% 97.7% 0 Competitive Fiber Providers 0.7% 100.0% 2.3% 100.0%

Note: The difference between the HC sites with Liberty and AT&T fiber located within 0.5 miles and the HC within 0.2 miles HC is the sites where Liberty and AT&T fiber were both found within 0.5 miles but at least one was not found within 0.2 miles.

16 REDACTED – FOR PUBLIC INSPECTION Most Competitive Fiber Providers Are Much Closer than 0.2 Miles

Distance from Confirmed Overlaps to Evidence of Nearest Unaffiliated Fiber Competitor HIGHLY CONFIDENTIAL 100% Percent of Confirmed Overlaps 90% within distance thresholds: <= 0.05 Miles = 59.4% 80%

<= 0.10 Miles = 85.2% 70% <= 0.20 Miles = 97.7% <= 0.50 Miles = 99.4% 60%

50%

40% Few situations where closest Number of Confirmed Overlaps Confirmed of Number

Competitive Fiber Provider is 30% Overlaps of Confirmed Total Percent greater than 0.2 miles from a

Confirmed Overlap: 20% – HC Confirmed Overlaps 10% – All are within 1.0 mile

– Average for those greater 0% than 0.2 miles is 0.42 miles <= 0.10 Mile <= 0.20 Mile <= 0.30 Mile <= 0.40 Mile <= 0.50 Mile <= 0.60 Mile <= 0.70 Mile <= 0.80 Mile <= 0.90 Mile <= 1.00 Mile Distance to Nearest Unaffiliated Competitor

Count of Confirmed Overlaps Percent of Confirmed Overlaps

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Competitive Fiber Providers by MSA

Competition from Competitive Fiber Providers is evident across MSAs.

Competition from Competitive Fiber Providers within 0.5 Miles

San Juan Not Aguadilla San Bayamon Assigned Isabela Arecibo Guayama Mayaguez Ponce German Caguas Yauco To an MSA Total

Confirmed Overlaps 5+ Competitive Fiber Providers HIGHLY CONFIDENTIAL 4 Competitive Fiber Providers 3 Competitive Fiber Providers 2 Competitive Fiber Providers 1 Competitive Fiber Provider 0 Competitive Fiber Providers

Competition from Competitive Fiber Providers within 0.2 Miles

San Juan Not Aguadilla San Bayamon Assigned Isabela Arecibo Guayama Mayaguez Ponce German Caguas Yauco To an MSA Total

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Overall Summary Statistics (by Provider & Geography)

PRTC/Claro and PREPA have the most fiber, each serving roughly three-quarters of the Confirmed Overlaps.

Competition from Competitive Fiber Providers within 0.5 Miles Competition from Competitive Fiber Providers within 0.2 Miles

Outside Outside Metro San % in Metro Metro San % in Metro Metro San Total Metro San Total Juan San Juan Juan San Juan Juan Juan

Confirmed Overlaps 58.6% PRTC / Claro HIGHLY CONFIDENTIAL 55.7% PREPA 63.1% OSNet / FiberX 85.8% WorldNet 87.1% Critical Hub (CHN) 97.9% AeroNet 100.0% Data Access 78.2% Everyday Data 0.0% Other 73.9%

Notes: 1 OSNet and FiberX are two different companies that appear to share facilities. 2 These statistics report only the relative presence of identifiable competing fiber providers within 0.5 or 0.2 miles of a Confirmed Overlap. 3 These observations are not intended to represent the relative size of competing fiber providers. 4 PRTC/Claro has deployed fiber at Confirmed Overlaps across Puerto Rico. FTI's analysis does not include PRTC/Claro copper.

19 REDACTED – FOR PUBLIC INSPECTION Analysis of the Relatively Few Areas with One Competitive Fiber Provider

A Confirmed Overlap with One Competitive Fiber Provider almost always: (1) has competition from PRTC/Claro or PREPA, or (2) is in the San Juan MSA where substantial fiber exists.

– PRTC/Claro or PREPA is the Competitive Fiber Provider 89.1% of the time within 0.5 miles (94.4% within 0.2 miles). HIGHLY CONFIDENTIAL

Orange areas represent Census Block Groups where the provider’s fiber was located for Confirmed Overlaps (shown at 0.2 miles).

– PRTC/Claro or PREPA fiber exists within 0.5 miles Competitive Fiber Providers Competitive Fiber Providers for HC out of HC Confirmed Overlaps (90.5%) Within 0.5 Miles Within 0.2 Miles outside of the San Juan/Bayamon/Caguas MSA (95.8% within 0.2 miles). Competitive Fiber HIGHLY CONFIDENTIAL

– Most of the Confirmed Overlaps (HC ) Confirmed Overlaps without PRTC/Claro or PREPA fiber within 0.5 miles Aguadilla-Isabela are in the San Juan/Bayamon/Caguas MSA (HC Arecibo Guayama HC within 0.2 miles). Mayaguez Ponce – The average Confirmed Overlap in the San Juan San German MSA has HC Competitive Fiber Providers within San Juan-Bayamon-Caguas 0.5 miles (HC at 0.2 miles). Yauco Not Assigned to an MSA

Note: 20 PRTC/Claro has deployed fiber at Confirmed Overlaps across Puerto Rico. FTI's analysis does not include PRTC/Claro copper. REDACTED – FOR PUBLIC INSPECTION Competitive Heat Map of Confirmed Overlaps in Puerto Rico Using 0.5 Mile Threshold for Competition – Business Density

Data illustrates significant competition in areas with higher business density. HIGHLY CONFIDENTIAL

Note: 21 The underlying business density heat map is more easily seen on the following map. REDACTED – FOR PUBLIC INSPECTION Competitive Heat Map of Confirmed Overlaps in Puerto Rico Using 0.2 Mile Threshold for Competition – Business Density

Data illustrates significant competition in areas with higher business density. HIGHLY CONFIDENTIAL

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Appendix A

SUMMARY OF TERMS AND EXPLANATION OF ANALYSIS REDACTED – FOR PUBLIC INSPECTION

Summary of Terms

Term Description The original list of buildings where Liberty and AT&T are both likely to have fiber optic cable Algorithmic Overlaps using the algorithms described in the Matrix Report. There are HC Algorithmic Overlaps. Algorithmic Overlaps that field inspections determined are not in the same building. There Non-Overlaps are HC Non-Overlaps. Algorithmic Overlaps remaining after the removal of Non-Overlaps. There are HC Overlap Overlap Sites Sites. Overlap Sites where field inspections were able to confirm fiber for both Liberty and AT&T within a threshold distance. The number of Confirmed Overlaps will therefore differ by Confirmed Overlaps threshold distance. There are HC Confirmed Overlaps within 0.5 miles and HC Confirmed Overlaps within 0.2 miles. Uninspected Overlap Sites Overlap Sites where field inspections were not performed due to COVID-19. Locations where FTI obtained photographic evidence of fiber providers in or near Confirmed Fiber Evidence Locations Overlaps. Communications companies (other than Liberty and AT&T) whose fiber optic cable was Competitive Fiber Providers observed at Fiber Evidence Locations. Other types of facilities (copper, coaxial, HFC, wireless) are not considered.

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Explanation of Analysis

FTI visited 92.2% of the Overlap Sites before COVID-19 interrupted the field inspections.

FTI’s statistics are based on those sites visited and were found to be Confirmed Overlaps. – FTI’s field investigations identified that HC of the Algorithmic Overlaps identified by Matrix were “false positives” – Liberty and AT&T were not serving the same buildings. – FTI performed field investigations at HC of the HC Overlap Sites (in addition to the HC “false positives”). – The field inspections were able to confirm fiber for both Liberty and AT&T within 0.5 miles for HC of those HC Confirmed Overlaps (99.2%). – The field inspections were able to confirm fiber for both Liberty and AT&T within 0.2 miles for HC of those HC sites (98.3%). HC – The sites where both Liberty and AT&T fiber could not be identified within 0.5 miles (or HC sites at 0.2 miles) are excluded from the statistics because identifying and counting Competitive Fiber Providers in these areas would bias the results. – These areas tend to have underground structure where FTI could not access manholes to confirm a fiber presence.

Competitive Fiber Provider Competitive Fiber Provider Within 0.5 miles Within 0.2 miles

Algorithmic Overlaps Identified by Matrix HC

Overlap Sites HC

Overlap Sites Reviewed by FTI HC

Confirmed Overlaps HC HC

Analysis of Uninspected Overlap Sites

Available evidence does not indicate that Uninspected Overlap Sites differ systematically from Confirmed Overlaps.

There are HC Overlap Sites where FTI was unable to perform field investigations due to COVID-19 (identified in red below).

Overlap Sites Description Count Overlap Sites HC HIGHLY CONFIDENTIAL Reviewed by FTI HC Uninspected Overlap Sites HC

Based on 0.5 Miles Based on 0.2 Miles

Overlap Avg. Overlap Avg. Geographic Area Levels Site Fiber Site Fiber (US Census Designations) Count Competitors Count Competitors Census Block (CB) HC 3.3 HC 2.4 Census Block Group (CBG) 2.7 2.2 Census Tract Level 2.6 2.2 County 3.2 2.8 Total County Level or Below

Note: HC of the Uninspected Overlap Sites could not be analyzed at the 0.5 mile threshold (HC at the 0.2 mile threshold) because there were no Confirmed Overlaps in those counties.

Evaluation is based on the average number of Competitive Fiber Providers. – For example, a CBG could have four different Competitive Fiber Providers, but only average two Competitive Fiber Providers at each Confirmed Overlap. – The geographic areas with Uninspected Overlap Sites exhibit a similar level of competition (within a few percentage points) as the Confirmed Overlaps. – This is true whether measured at 0.5 or 0.2 miles or when evaluating competition with either at least one or at least two Competitive Fiber Providers. 26 REDACTED – FOR PUBLIC INSPECTION

Appendix B

IDENTIFICATION OF PROVIDERS REDACTED – FOR PUBLIC INSPECTION

Practical Limitations of Photographic Evidence

FTI personnel performed detailed field inspections, although photographic evidence can be hard to obtain.

Primary Objective: – FTI’s primary objective was to identify providers at Fiber Evidence Locations. – Obtaining photographs at these locations was mandatory, but image quality was not the primary goal. – Our field teams were provided with reasonable safety instructions. Aerial Limitations: – Employees were instructed not to climb higher for the sole purpose of getting a better photograph. – Employees were told not to reclimb poles to obtain better. photographs once the provider was identified. – Employees were not asked to review photographs while on ladders. – Height, backlighting (sun behind the subject), ground stability, wind, and label positions were all factors that could result in less than ideal photographs. Underground Limitations: – Employees were instructed not to open electrical manholes. – Employees were instructed not to climb into manholes.

– Fiber location, depth, water, mud, and label positions were 28 all factors that could result in less than ideal photographs. REDACTED – FOR PUBLIC INSPECTION

Limitations of Using Geographic Proximity to Customer Location There are situations where the property boundaries preclude obtaining fiber evidence within 0.2 miles (or sometimes 0.5 miles) of the geocoded location even though fiber is present nearby. Description: – Hospitals, malls, resorts and warehouses are complexes that have consolidated access points for providers to reach customers. – Illustrated below are two Overlap Sites in the same complex with different results because of the size of the complex: Competitive Fiber Provider within 0.2 miles Competitive Fiber Provider outside of 0.2 miles HIGHLY CONFIDENTIAL

– The distance analysis has been manually adjusted, based on FTI’s field surveys for specific cases, to reflect distances from the perimeter of the property rather than specific geocodes (i.e., included in the 0.2 mile or 0.5 mile threshold used in this report and the supporting documents).

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Identification of Providers

The field reviews allowed FTI to identify common identifiers (e.g., colors and symbols on fiber cables, markers, tags, and manhole covers) for various providers. Common Providers: – The most prevalent Competitive Fiber Providers at the Overlap Sites were PREPA (including AE Power), PRTC/Claro, OSNet/FiberX, WorldNet, Critical Hub (CHN), AeroNet, Data Access, and Everyday Data. – Some of these entities use standardized markers to identify fiber, but others may have used multiple markers over time or have acquired fiber from other entities. Marker Differences: – FTI designed a template to identify common markers by entity that would allow field teams to identify the fiber provider by sight even if a label could not be clearly captured (e.g., a white label with blue lettering and a blue logo with white swishes is Columbus Networks). – Some markers included the provider name. Others did not include a name but only a phone number (see, for example, PREPA). – In some situations, our field teams could identify fiber in a provider’s structure, but the fiber itself was not labeled. That fiber could often be traced along a route to identify the provider (i.e., following the fiber cable until a label was shown). Other and Unidentifiable: – In situations where fiber was located but the provider was not on the preidentified list of providers, the field teams noted that fiber provider as “Other.” – In situations where fiber was located but there was nothing to indicate the provider, the field teams noted that fiber provider as “Unidentifiable.” – Fiber identified as “Other” or “Unidentifiable” is included in this presentation but is not counted as a Competitive Fiber Provider.

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Identification Markers for Liberty Cablevision

Associated Phone Numbers: Primary Fiber Tag Examples 787-657-3060

Multiple Fiber Tag Designs (Y/N)? Y

Primary Fiber Tag Description: Tag is orange in color (some fade to lighter/greyer color) with black lettering that reads “CAUTION | FIBER OPTIC CABLE| LIBERTY CABLEVISION| TEL: 787-657-3060.” Alternative Fiber Tag Examples

1. 2. Alternative Fiber Tag Description(s): 1. Tags that are orange and blank with no text are often Liberty tags but typically confirmed through other evidence on site.

2. Variations include orange tags that read “FIBER OPTIC 3. CABLE” or “FIBER OPTIC CATV.”

3. There are also yellow tags that read “FIBER OPTIC CABLE| CABLE TV OF GREATER SAN JUAN| 2507780 7660909” which are Liberty owned.

(Continued)

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Identification Markers for Liberty Cablevision (continued)

Alternative Fiber Tag Examples (Continued) Alternative Fiber Tag Description(s) (Continued):

4. There are instances where the fiber optic cable is labeled “LIBERTY CABLEVISION OF PUERTO RICO.” 4.

5. The fiber optic cable is labeled “CABLE TV OF GREATER SAN JUAN.”

6. Tags reading “FIBER OPTIC CABLE| TELEPONCE CABLE TV | 848-5550” are also part of Liberty. 5.

7. Fiber reading “Onelink 787-766-0909” are also part of Liberty.

32 REDACTED – FOR PUBLIC INSPECTION Identification Markers for Liberty Cablevision (Columbus Networks)

Associated Phone Numbers: Primary Fiber Tag Examples 787-304-5303

Multiple Fiber Tag Designs (Y/N)? Y

Primary Fiber Tag Description: Tag is white in color with blue lettering that reads “COLUMBUS NETWORKS| FIBER OPTIC CABLE | 787- 304-5303.” There is also a company logo that is a blue circle with a curved C in two white lines. Alternative Fiber Tag Examples Alternative Fiber Tag Description(s): 1. Older design has a blue tag with black lettering that reads “FIBER OPTIC CABLE | COLUMBUS NETWORK | 1. (787) 379-3164.”

2. Columbus Networks inside communications rooms are often identified by a sticker that reads “Columbus business solutions.”

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Identification Markers for AT&T (AT&T Mobility)

Associated Phone Numbers: Primary Fiber Tag Examples 787-717-9900

Multiple Fiber Tag Designs (Y/N)? Y

Primary Fiber Tag Description: Tag is royal blue in color with white lettering that reads “ATT Mobility | 787-717-9900 | Fiber Optic Cable.”

Alternative Fiber Tag Description(s): Alternative Fiber Tag Examples 1. In some instances the fiber itself is labeled “AT&T 787-717-9900.” 1. 2. Inside communications rooms there are stickers and labels for AT&T.

(Continued)

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Identification Markers for AT&T (AT&T Mobility) (continued)

Alternative Fiber Tag Description(s) (Continued): Alternative Fiber Tag Examples (Continued)

3. In cases where the fiber is underground the vault is often labeled with “AT&T” on the cover and has an orange and white post accompanying it.

4. Lambda Comm is also an AT&T Company.

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Identification Markers for AT&T (Centennial)

Associated Phone Numbers: Primary Fiber Tag Examples 787-717-9900

Multiple Fiber Tag Designs (Y/N)? Y

Primary Fiber Tag Description: Tag is light blue in color with white lettering that reads “CENTENNIAL DE PUERTO RICO | 787-717-9900 | FIBER OPTIC CABLE.” The blue is lighter than that of AT&T Mobility. In some cases the white lettering fades so that the text is in a darker color. Alternative Fiber Tag Examples

Alternative Fiber Tag Description(s): 1. The fiber itself is labeled “CENTENNIAL PR 787-717- 1. 9900.”

2. In cases where the fiber is underground the vault is often labeled with “CENTENNIAL” (sometimes with the phone number) on the cover and has an orange and yellow post accompanying it. 2. (Continued)

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Identification Markers for AT&T (Centennial) (continued)

Alternative Fiber Tag Description(s) (Continued): Alternative Fiber Tag Examples (Continued)

3. There are also tags in blue with white lettering that read “CENTENNIAL DE P.R. | FIBER OPTIC | CABLE | 717 9900.” 3.

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Identification Markers for PRTC/Claro

Associated Phone Numbers: Primary Fiber Tag Examples 787-792-8484

Multiple Fiber Tag Designs (Y/N)? Y

Primary Fiber Tag Description: Tag is orange in color with black letering that reads Alternative Fiber Tag Examples “PRTC CABLE DE FIBRA OPTICA | EMERGENCIAS 787-792- 8484.” This tag, if faded, could also appear grey. 1.

Alternative Fiber Tag Description(s): 1. White tags with red lettering that read “CABLE DE FIBRA OPTICA | PRTC/CLARO | EN CASO DE EMERGENCIA | LLAMAR 787-792-8484.”

2. Orange Tags with black lettering that read “CABLE DE 2. FIBRA OPTICA | PRTC | EN CASO DE EMERGENCIA | LLAMAR 787-792-8484.”

3. Orange Tags with black lettering that read “Puerto Rico Telephone | Cable Fibra Optica.” Faded tags can also appear grey.

(Continued) 3.

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Identification Markers for PRTC/Claro (continued)

Alternative Fiber Tag Examples (Continued) Alternative Fiber Tag Description(s) (Continued):

4. Fiber optic cable found underground in a “Puerto Rico Telephone Company” manhole. The fiber in this manhole is often unmarked. The manhole may also read “PRTC.” 4. 5. Newer vaults have covers that read “Claro” and are accompanied by a red post with “Claro” as the signage.

6. The fiber cable itself may read “PRTC” or “Propiedad de Claro.”

7. Older manhole covers that read “AUT. DE COMUNICACIONES DE P.R.” belong to PRTC. 5. 8. Fiber inside communications rooms with a “CLARO” sticker

8. 7.

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Identification Markers for PREPA

Associated Phone Numbers: Primary Fiber Tag Examples 787-625-9950; 787-705-9950; 787-289-4224

Multiple Fiber Tag Designs (Y/N)? Y

Primary Fiber Tag Description: Tag is yellow (often faded to white) in color with black lettering that reads “PRECAUCION | CABLE DE FIBRA OPTICA | (787) 625-9950 | (787) 705-9950 | PREPA NETWORKS.” This label appears in multiple fonts. Alternative Fiber Tag Examples Alternative Fiber Tag Description(s): 1. Yellow (often faded to white) tags with black 1. lettering that read “PRECAUCION | CABLE FIBRA OPTICA | (787)289-4224 | (787) 625-9950.” This label does not say PREPA anywhere, also reads “cable fibra optica” not “cable de fibra optica.”

2. Same text as the primary fiber tag but in red.

(Continued)

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Identification Markers for PREPA (continued)

Alternative Fiber Tag Examples (Continued) Alternative Fiber Tag Description(s) (Continued):

3. Magenta, rectangular hangtag that reads “PRECAUCION | Cable de Fibra Optica | PREPA Networks | (787) 705-9950.” 3.

4. Manholes that have PREPA on the cover and fiber underground.

5. The fiber cable itself may read “PREPA NETWORKS (787)625-9950.”

6. This older PREPA tag reads “TEL (787) 860-7270” This phone number no longer pertains to PREPA currently. 4.

(Continued)

6. 5.

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Identification Markers for PREPA (continued)

Alternative Fiber Tag Examples (Continued) Alternative Fiber Tag Description(s) (Continued):

7. PREPA is also known as Autoridad de Energia Electrica. Older tags in orange with black lettering 7. read “CABLE DE FIBRA OPTICA | AUTORIDAD DE | ENERGIA ELECTRICA.”

8. This variant of the PREPA tag has the two phone numbers side by side instead of on separate lines.

9. Fiber cable found inside communications rooms will have a PREPA Networks sticker. 8. 10. Prysmian Optical is a less common fiber cable manufacturer regularly used by PREPA.

10. 9.

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Identification Markers for OSNet / FiberX

Associated Phone Numbers: Primary Fiber Tag Examples 787-705-6999

Multiple Fiber Tag Designs (Y/N)? N

Primary Fiber Tag Description: Tag is bright green in color with black lettering that reads “Osnet/FiberX | 787-705-6999.” There is no other company with this color tag.

Alternative Fiber Tag Description(s): N/A

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Identification Markers for WorldNet

Associated Phone Numbers: Primary Fiber Tag Examples 787-705-5500

Multiple Fiber Tag Designs (Y/N)? Y

Primary Fiber Tag Description: Tag is baby blue in color with black lettering that reads “CABLE DE FIBRA OPTICAS | WORLDNET | 787-705-5500.” Tag is smaller in both length and diameter compared to most other fiber tags. The font is also smaller.

Alternative Fiber Tag Description(s): Inside communications rooms it is common to see WorldNet stickers. Alternative Fiber Tag Examples

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Identification Markers for Critical Hub Networks (CHN)

Associated Phone Numbers: Primary Fiber Tag Examples 787-957-6111

Multiple Fiber Tag Designs (Y/N)? N

Primary Fiber Tag Description: Tag is orange/red in color with black lettering that reads “CAUTION FIBER OPTIC CABLE | CHN 787-967- 6111.” The tag tends to be thinner in diameter compared to other providers. Sometimes the tag can be faded to a lighter color.

Alternative Fiber Tag Description(s): There are boxes that read “Property of Critical Hub Alternative Fiber Tag Examples Network | 787-957-6111 | CAUTION | FIBER OPTIC CABLES INSIDE.”

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Identification Markers for AeroNet

Associated Phone Numbers: Primary Fiber Tag Examples 787-273-4143

Multiple Fiber Tag Designs (Y/N)? N

Primary Fiber Tag Description: Tag is white in color and rectangular with blue lettering that reads “AeroNet Broadband | 787-273-4143 | Cable de Fibra Optica | ⚠ No Contiene Cobre ⚠.” It is very common to see the tag partially torn or damaged.

Alternative Fiber Tag Description(s): N/A

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Identification Markers for Data Access

Associated Phone Numbers: Primary Fiber Tag Examples 787-977-8025

Multiple Fiber Tag Designs (Y/N)? N

Primary Fiber Tag Description: Tag is black in color with red lettering that reads “Data Access | Telephone 787-977-8025 | FIBER OPTIC CABLE.”

Alternative Fiber Tag Description(s): N/A

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Identification Markers for Everyday Data Inc.

Associated Phone Numbers: Primary Fiber Tag Examples 787-840-6190

Multiple Fiber Tag Designs (Y/N)? N

Primary Fiber Tag Description: Tag is red in color with white lettering and reads “EVERYDAY DATA INC. | 787-840-6190.”

Alternative Fiber Tag Description(s): N/A

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Appendix C

EXPLANATION OF SUPPORTING DOCUMENTATION REDACTED – FOR PUBLIC INSPECTION

Explanation of the Fiber Evidence Supporting Documentation

After analyzing the information collected in the field inspections, FTI produced standardized documentation for each Confirmed Overlap to facilitate review.

Outputs – Site Summaries: – Site documentation was organized around the Liberty Site IDs, which served as a unique identifier for data provided to FTI. – The first slide for each unique Liberty Site ID is a “Site Summary” that contains a map of the Overlap Site associated with the Liberty Site ID along with image(s) of the building front(s) where Liberty and/or AT&T fiber is located. The Site Summaries also show the aggregated provider statistics at the site level, derived from the images and data collected during the field reviews. – On the Site Summaries, a red X denotes the geocoded location of the Liberty fiber building (one per Site ID), while a blue X denotes the corresponding AT&T fiber building(s) (which could be one or many) in close proximity to the Liberty fiber building. These maps also identify the individual Fiber Evidence Locations, signified by the green diamonds. Outputs – Fiber Evidence Locations: – The slides following the Site Summary contain data gathered at each Fiber Evidence Location associated with that Overlap Site, where a red ring indicates the specific Fiber Evidence Location for that slide. – The Fiber Evidence Location slides include the photographic images captured and analyzed at that location, as well as more granular location-specific information (i.e., providers identified, fiber structure type) derived from the field reviews. – All of the indicators (red X, blue X, green diamonds) remain the same as on the Site Summaries.

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HC Site Summary Example – Site

Site ID corresponding to Liberty Building ID Geographic location of Liberty provided by Matrix. building with Site ID HC (Red X) and corresponding AT&T building (Blue X). HC HIGHLY CONFIDENTIAL

Photo image of the structure where Liberty Building ID HC is located.

Fiber Evidence Locations around Site ID HC (green diamonds).

Additional Notes for Site ID HC .

Site-level provider summary statistics (based on aggregated Fiber Evidence Location data). HIGHLY CONFIDENTIAL

51 REDACTED – FOR PUBLIC INSPECTION Evidence Location Example – Site HC Location 1 (Liberty)

Site ID corresponding to Liberty Building number provided.

HC HIGHLY CONFIDENTIAL Photo Image(s) of fiber evidence from an aerial fiber cable near Site ID HC .

Area where this aerial fiber was found (Location 1).

Data for provider and structure type found at this location.

HIGHLY CONFIDENTIAL

52 REDACTED – FOR PUBLIC INSPECTION Evidence Location Example – Site HC Location 2 (AT&T)

Site ID corresponding to Liberty Building number provided.

HIGHLY CONFIDENTIAL

Photo Image(s) of fiber evidence from an aerial fiber cable near Site ID HC .

Area where this aerial fiber was found (Location 2).

Data for provider and structure type found at this location.

HIGHLY CONFIDENTIAL

53 REDACTED – FOR PUBLIC INSPECTION Evidence Location Example – SiteHC Location 3 (PRTC/Claro)

Site ID corresponding to Liberty Building number provided.

HC HIGHLYHIGHLY CONFIDENTIAL Photo Image(s) of fiber evidence from an underground CONFIDENTIAL manhole near Site ID HC .

Area where this underground fiber was found (Location 3).

Data for provider and structure type found at this location.

HIGHLY CONFIDENTIAL

54 REDACTED – FOR PUBLIC INSPECTION Evidence Location Example – Site HC Location 4 (PREPA)

Site ID corresponding to Liberty Building number provided.

HC HIGHLY CONFIDENTIAL

Labeled fiber that was able to be traced back to within 0.2 miles.

Photo Image(s) of fiber evidence from an aerial pole near Area where this pole (Location 4) Site ID HC . was found.

Location 4 within 0.2 miles to which Data for provider labeled fiber was and structure type able to be traced. found at this location.

HIGHLY CONFIDENTIAL

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Appendix D

FIBER EVIDENCE SUPPORTING DOCUMENTATION REDACTED – FOR PUBLIC INSPECTION

Fiber Evidence Supporting Documentation

Provided in a separate file. (HIGHLY CONFIDENTIAL INFORMATION IN ITS ENTIRETY)

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Appendix E

FTI TEAM LEADERS REDACTED – FOR PUBLIC INSPECTION Steven E. Turner +1 202.312.9176 Senior Managing Director [email protected]

Steven Turner is a Senior Managing Director in the Telecom, engineering, financial, and industry expertise to advise Insert Professional Media and Technology (“TMT”) industry practice and is Co-Leader stakeholders on company strategy, acquisitions, divestitures, Portrait (Headshot) of the TMT Dispute Advisory group. He has over 30 years of synergies and due-diligence. experience providing expert testimony in a broad range of technical and financial areas covering the engineering and Mr. Turner worked at AT&T from 1987 to 1996 and held a variety operations of integrated communications networks, of engineering, operations and management positions overseeing transportation systems and transaction investigations. Mr. Turner the switching, transport and signaling disciplines. Prior to the leads many of TMT’s due-diligence and performance improvement passage of the Telecom Act of 1996, Mr. Turner worked in the LOCATION engagements related to technology, engineering and network McLean, U.S.A. organization responsible for AT&T’s re-entry strategy into the local operations, with his work covering the breadth of the TMT infrastructure market and developed models evaluating AT&T’s EDUCATION industries. potential entry alternatives through switch and fiber builds, hybrid B.Sc., Electrical fiber-coax service, broadband fixed wireless, and others. Mr. Engineering, Auburn University In telecommunications, he and his team provide specific expertise Turner was ultimately responsible for developing AT&T’s market M.B.A., Finance, in the wireline (copper, coaxial, fiber, HFC), wireless (4G and 5G) entry network plan for the Southwestern Region along with the Georgia State University and integrated communications arenas as both industry experts regulatory issues associated with the unbundling of local exchange and testifying experts in the U.S. and internationally. Mr. Turner company networks. has extensively worked in implementing, developing and evaluating business plans for wireline and wireless networks In 1997, Mr. Turner founded Kaleo Consulting, a boutique across the United States. Mr. Turner has led many network consulting firm specializing in providing expert testimony in the engineering engagements including ones requiring designs for engineering and operations of integrated communications switching, fiber builds, broadband builds, and wireless access networks and market entry strategic consulting services. Mr. networks for clients. Turner’s projects involved issues related to contractual terms and conditions between telecommunications service providers, the Mr. Turner has testified in nearly 150 separate proceedings on costs for network elements including interoffice transport, behalf of many of the largest integrated communications carriers, collocation, customer access networks, switching, and signaling. toll roads and other service providers in a variety of jurisdictions Mr. Turner also developed and/or evaluated numerous models on matters related to class certification under Federal Rule 23, pertaining to the development of network component costs. industry practices, regulatory compliance, contract interpretation, cost-of-service and pricing, damages, fraud, lost profits, network Mr. Turner holds a B.S. in electrical engineering from Auburn performance and technical standards and capabilities. Outside of University and an M.B.A. in finance from Georgia State University. litigation, Mr. Turner leverages his unique combination of

59 REDACTED – FOR PUBLIC INSPECTION Brian F. Pitkin +1 703.625.2140 Senior Managing Director [email protected]

Brian Pitkin is a Senior Managing Director in the Telecom, Media In the legal arena, Mr. Pitkin has more than 25 years of dispute and Technology (“TMT”) practice and is the Co-Leader of the TMT resolution experience, serving law firms and general counsel with Dispute Advisory group. His expertise is in assisting general a wide range of services, including expert testimony and non- counsel, outside counsel and boards of directors in evaluating a testifying expert advisory services. He has testified in over 60 wide range of strategic priorities, preparing for settlement proceedings, including in U.S. federal court, arbitrations, the negotiations and understanding the risks of litigation. He has Federal Communications Commission and more than 25 states’ worked extensively in matters across TMT, including integrated public utility commissions. In commercial litigation, he has communications platforms, media content, distribution and focused on disputes relating to industry practices, cost-of-service LOCATION transportation systems. and cost-based pricing in multi- product firms, as well as class McLean, U.S.A. certification under Federal Rule 23, contract terms and conditions, EDUCATION Mr. Pitkin has over twenty years of experience in the damages, fraud, interconnection and intercarrier compensation. B.S., Finance and communications industry, much of it focused on data analytics, In the regulatory arena, he has provided extensive expert Management financial modeling, and geospatial analysis. He has provided testimony around the country on policy, modeling methodologies, Information Systems, compliance issues and financial analysis. University of Virginia extensive expert testimony on telecommunications regulation, modeling methodologies and financial analysis in numerous proceedings around the country. Mr. Pitkin is a recognized expert Prior to joining FTI Consulting, Mr. Pitkin worked as a in the modeling of complex networks, including detailed Management Consultant focused on acquisitions, strategic geospatial analyses, and has testified on costing and pricing issues initiatives and intercarrier relations. In industry, he served as before the FCC, numerous state regulatory commissions, Senior Vice President of WorldNet Telecommunications, Inc., administrative law judges and courts. where he led the business analysis, product development, marketing, sales, finance and regulatory departments. Mr. Pitkin has worked on a variety of matters related to regulatory review of mergers, both pre- and post- closing. He continues to assist clients with their most complex and data intensive modeling Mr. Pitkin holds a B.S. in finance and management information efforts, managing a variety of due diligence, restructuring and systems from the University of Virginia. integration projects that focus on operational and infrastructure synergy scenarios on behalf of companies and/or external investors. He also has extensive experience evaluating transaction operations, costs, and pricing related to taxes, fees, and charges in telecommunications, cable television, and toll roads, and including investigations by the Consumer Financial Protection Bureau.

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EXPERTS WITH IMPACT ™