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REDACTED – FOR PUBLIC INSPECTION 1776 K STREET NW December 23, 2015 WASHINGTON, DC 20006 Meredith Singer PHONE 202.719.7000 202.719.7507 FAX 202.719.7049 [email protected] 7925 JONES BRANCH DRIVE VIA ECFS MCLEAN, VA 22102 PHONE 703.905.2800 FAX 703.905.2820 Marlene H. Dortch, Secretary Federal Communications Commission www.wileyrein.com 445 12th St., S.W. - The Portals Washington, D.C. 20554 Re: Verizon’s First Supplemental Response to FCC’s Information and Data Request dated October 9, 2015, MB Docket No. 15-149 Dear Ms. Dortch: Pursuant to the instructions set forth in the Commission’s Information and Data Request dated October 9, 2015 (“Request”)1 and the Protective Order adopted in this proceeding, enclosed please find Verizon’s First Supplemental Response to the Request (“Verizon’s Response”). Verizon’s Response contains confidential and highly confidential information subject to the Protective Order in this proceeding.2 At the direction of the Request and the Protective Order, one copy of the “Confidential” version and one copy of the “Highly Confidential” version of Verizon’s Response are being filed with the Secretary’s Office. Two copies of each are being hand delivered to Ms. Vanessa Lemmé of the Media Bureau’s Industry Analysis Division. Finally, one copy of the “Redacted” version of Verizon’s Response is being filed electronically through the Commission’s Electronic Filing Comment System (“ECFS”). Please direct any questions concerning this letter to Nancy J. Victory (at 202.719.7344 or [email protected]) or to the undersigned. 1 In the Matter of Applications of Charter Communications, Inc., Time Warner Cable Inc., and Advance/Newhouse Partnership for Consent to Transfer Control of Licenses and Authorizations, MB Dkt. 15-149, Letter from William T. Lake, Chief, Media Bureau to William H. Johnson, Esq. (Oct. 9, 2015). 2 In the Matter of Applications of Charter Communications, Inc., Time Warner Cable Inc., and Advance/Newhouse Partnership for Consent to Transfer Control of Licenses and Authorizations, MB Dkt. 15-149, Order, FCC 15-110 (rel. Sept. 11, 2015). REDACTED – FOR PUBLIC INSPECTION First Supplemental Response to Information Request December 23, 2015 Page 2 Best regards, /s/ Meredith Singer Meredith Singer Attachments cc: Vanessa Lemmé Ty Bream Elizabeth McIntyre Adam Copeland Jim Bird REDACTED – FOR PUBLIC INSPECTION December 23, 2015 Verizon’s First Supplemental Responses to the Media Bureau’s October 9, 2015 Information Request Request No. 4: Produce one copy of each agreement between the Company and any other persons that contain provisions relating to peering, paid peering or settlement free interconnection. Verizon’s Internet interconnection agreements typically include confidentiality provisions. Verizon requested permission from the relevant parties to file copies of its Internet interconnection agreements relating to peering, paid peering, or settlement-free interconnection for the time period from June 2012 through October 9, 2015. Subject to a request that these agreements be treated as Highly Confidential Information under the September 11, 2015 Protective Order, Verizon previously filed copies of all responsive agreements in its possession except for agreements with two parties who had withheld their permission. Those responsive documents were produced at Bates numbers VZ00001–VZ001581 and were designated as Highly Confidential Information. Verizon has received permission to produce the previously-withheld agreements and hereby produces them at Bates numbers VZ001582–VZ002476. These additional agreements are designated as Highly Confidential Information and are subject to a request that they be treated as Highly Confidential Information under the September 11, 2015 Protective Order. Request No. 5: Describe, and provide and identify documents sufficient to show, how the Company responds to competitors’ pricing behavior and product offerings for each relevant service. Verizon hereby supplements its previous response to this Request by producing responsive information at Bates numbers VZ002477–VZ002565. This information is designated as Highly Confidential Information and is subject to a request that it be treated as Highly Confidential Information under the September 11, 2015 Protective Order. Request No. 6: Produce, in both (a) PDF and (b) ESRI Shapefile format, a map showing the location of each system owned by, operated by, managed by, or attributed to the Company for the states of California, Nevada, Hawaii and New York. Responsive maps are attached at Bates numbers VZ002566–VZ002569. These documents are designated as Highly Confidential Information and are subject to a request that they be treated as Highly Confidential Information under the September 11, 2015 Protective Order. These maps show the boundaries of wire centers where there is at least one address qualifying for Fios video service. Inclusion of a wire center in the maps does not mean that every address in the wire center qualifies for Fios video service. Verizon’s First Supplemental Responses to Oct. 9, 2015 Information Request REDACTED – FOR PUBLIC INSPECTION Request No. 7: Identify, as of June 30, 2012, December 31, 2012, June 30, 2013, December 31, 2013, June 30, 2014, December 31, 2014 and June 30, 2015, each system owned by, operated by, managed by, or attributed to the Company in the states of California, Nevada, Hawaii and New York, and for each system in these states identify the nature of the Company's interests, and state and identify the following in CSV format files: a. the Company’s data as specified in Attachment A, which seeks data relating to geographic identifiers associated with each system; Responsive information is attached in Exhibits 7.a.1 through 7.a.8, which are described below. Exhibits 7.a.1 – 7.a.7: These exhibits show each census block in which Verizon Fios video service was open for sale in the specified states, along with zip code, Common Language Location Identifier, wire center code, and the municipality, as of June 30, 2012; December 31, 2012; June 30, 2013; December 31, 2013; June 30, 2014; December 31, 2014; and June 30, 2015. Exhibits 7.a.1 – 7.a.7 are designated as Confidential Information and are subject to a request that they be treated as Confidential Information under the September 11, 2015 Protective Order. Exhibit 7.a.8: This exhibit contains the Community Unit Identifiers (“CUIDs”) and Physical System Identifiers (“PSIDs”) for Verizon’s cable systems in the specified states. b. the facilities-based competing providers of Internet access service and MVPD service (excluding private cable and wireless cable operators), separately identified by service and provider, and the distribution technology used by the competing provider (e.g., wireless, fiber optic cable, hybrid fiber optic cable, or satellite) for each zip code served; In California, Verizon’s primary wireline competitor for voice, video, and internet services is Time Warner Cable. In New York, Verizon’s primary wireline competitors for voice, video, and internet services are Time Warner Cable and Cablevision. We believe that Time Warner Cable and Cablevision use hybrid fiber-coax networks to deliver the aforementioned services to their subscribers. c. the central offices serving each system, their physical locations, and the number of telecommunications services subscribers served by each central office; and Exhibits 8.c.1 and 8.c.3, which are described below, contain responsive information. d. the channel lineups associated with each channel lineup identifier provided in Request 7(a). Responsive information is produced at Bates numbers VZ002570–VZ002649. Verizon’s First Supplemental Responses to Oct. 9, 2015 Information Request 2 REDACTED – FOR PUBLIC INSPECTION Request No. 8: For each zip code identified in Request 7(a) and for the Company as a whole, separately for residential subscribers, bulk residential, and non-residential subscribers, and for each month for the period beginning June 2012, through August 2015 in the states of California, Nevada, Hawaii and New York provide the following: a. the Company’s data as specified in Attachment B, which seeks subscriber data relating to each of the Company’s service plans; Exhibit 8.a.1 provides the number of Fios subscribers at the end of each month for Verizon’s individual services and double-play and triple-play bundled services from June 2012 through August 2015. References in Exhibit 8.a.1 to “DTV” are to DIRECTV. Verizon acts as an agent for DIRECTV video services in its wireline footprint. Verizon markets DIRECTV and DIRECTV bundles with Verizon voice and DSL services outside of its Fios footprint. Inside the Fios footprint, Verizon will sell DIRECTV bundles with Fios services at the customer’s request, but does not actively market this bundle to customers. Exhibit 8.a.1 is designated as Highly Confidential Information and is subject to a request that it be treated as Highly Confidential Information under the September 11, 2015 Protective Order. b. a complete description of all services that were included in the Company’s response to the “Marginal Recurring Revenue”, “Recurring Core Service Plan Revenue”, and “Recurring and Non-Recurring Revenue Per Subscriber” fields in the “Service Plan” table mentioned in subpart (a); Verizon does not maintain the information sought by the specified fields in the “Service Plan” table in the ordinary course. Verizon’s response to Request 10.a. provides Verizon’s Fios profitability per unit calculation, Fios voice-only profitability