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DOC-324046A2

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WT Docket 13-193

INFORMATION AND DISCOVERY REQUEST FOR AT&T



1. Provide a current organization chart and personnel directory for the Company as a whole and for each
of the Company‟s facilities or divisions involved in any activity relating to any relevant product or
any relevant service.

2. Provide, as of the date of this request, a csv format list, by county in each relevant area, of each
spectrum license that can be used in the provision of mobile wireless services that the Company
holds, leases, has an interest in through a joint venture or other business arrangement, manages, plans
to sell, has contracted to acquire, or is in negotiations to acquire. For each license, identify the: (a)
FIPS Code; (b) county; (c) state; (d) market name; (e) market number (in the case of CMA, MTA, or
BTA); (f) spectrum type; (g) spectrum block; (h) amount of spectrum; (i) the wireless technology
format deployed or planned (e.g., GSM, EDGE, CDMA, EV-DO, EV-DO Rev. A, UMTS, HSPA,
HSPA+, LTE); and (j) whether the Company: (i) holds; (ii) has an interest in through a joint venture
or other business arrangement; (iii) leases to or from another person; (iv) manages; (v) plans to sell;
(vi) has contracted to acquire; or (vii) is in negotiations to acquire.

3. Provide, as of the date of this Request, polygons in an ESRI shapefile format representing geographic
coverage in each relevant area for each mobile broadband network technology (e.g., GSM, EDGE,
CDMA, EV-DO, EV-DO Rev. A, UMTS, HSPA, HSPA+, LTE) deployed in each frequency band
(e.g., 700 MHz, Cellular, AWS-1, PCS, BRS/EBS). Provide all assumptions, methodology (e.g.,
propagation, projection, field measurements), calculations (including link budgets), tools (e.g.,
predictive and field measurements) and data (e.g., terrain, morphology, buildings) used in the
production of the polygons, and identify the propagation tool used, the propagation model used within
that tool, including but not limited to, the coefficients used in the model and any additions,
corrections or modifications made to the model.

4. Provide all merger simulations, econometric modeling, or similar analyses, including those regarding
market concentration or pricing, that have been undertaken by the Company or any consultant or
expert hired by the Company to analyze the effect of the Proposed Transaction, including all
documents and data used in these analyses.

5. Provide full and complete copies of the merger agreement and any side or letter agreements or other
related agreements (and all amendments and attachments) that AT&T and Leap have entered into that
relate to the Proposed Transaction.

6. Provide all presentations to management committees, executive committees, boards of directors,
investors, investor analysts, and industry analysts concerning the Proposed Transaction, including but
not limited to the effect of the Proposed Transaction on AT&T‟s spectrum needs and business plans.

7. Provide all documents discussing the valuation of Leap‟s assets and AT&T‟s decision to acquire
Leap, including but not limited to, documents discussing the LTE Roaming Agreement and the
License Purchase Agreement for the Specified Assets (the so-called “Sunrise” market spectrum)
discussed in Section 8.5(c) of the Agreement and Plan of Merger between Leap Wireless International
Inc., AT&T Inc., Laser, Inc., and Mariner Acquisition Sub Inc., dated as of July 12, 2013.

8. The Applicants state, “As a condition to AT&T‟s obligation to consummate the merger, Leap is
required to dispose of its ownership interests in PR Wireless, LLC and Flat Wireless, LLC, in which
case such interests would not be acquired by AT&T.” (Public Interest Statement, page 2, n. 7).
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Provide a detailed description explaining this condition and provide all documents discussing this
condition. Provide all documents discussing this condition and any correspondence with these
entities concerning this condition, and provide all documents and agreements relating to Leap‟s
interests in these entities and any other person.

9. Explain in detail, and provide documents sufficient to support this explanation, the contingent value
right (“CVR”) relating to the Lower 700 MHz A Block license in Chicago (“Chicago License”).
Include in your explanation (a) the reasons for the CVR, (b) its intended purpose, (c) the anticipated
process to sell the Chicago License and AT&T‟s involvement therein, (d) the specific responsibilities
of the stockholders‟ representative and how the stockholders‟ representative will exercise de facto
control over the license, (e) the effect on AT&T of holding the Chicago License in this subsidiary on
AT&T‟s rights and obligations, and (f) AT&T‟s rights to sell the Chicago License and the proceeds of
any such sale in the event the shareholders‟ representative fails to sell the Chicago License under the
terms of the CVR. Provide all agreements and documents relating to the creation and operation of the
CVR.

10. Provide all plans, analyses, and reports discussing the Company‟s or any other person‟s pre-
transaction and post-transaction plans relating to any relevant service, or relevant product, including,
but not limited to, business plans; short-term and long-range strategies and objectives; budgets and
financial projections; presentations to management committees, executive committees, and boards of
directors; expansion plans; research and development efforts; plans to reduce costs, to improve
services or products, to improve service quality, to improve capacity to transmit mobile wireless
services, or to introduce new services or products, including but not limited to, the deployment of
LTE (utilizing AWS-1 spectrum and/or PCS spectrum), any plans to offer, after the closing of the
Proposed Transaction, to postpaid and prepaid customers AT&T‟s LTE and HSPA+ data services
with different terms (e.g., speed of service, data throttling), and whether, as a result of the Proposed
Transaction, prepaid customers would be offered LTE service at the same data rates as AT&T
postpaid subscribers. For regularly prepared budgets and financial projections, AT&T need only
submit one copy of final year-end documents for 2011 and 2012 and cumulative year-to-date
documents for 2013.

11. The Applicants contend that Leap is currently using “about 42 percent of its spectrum in the markets
in which it offers facilities-based service.” (Public Interest Statement, page 14). The Applicants
assert that in the areas where AT&T currently anticipates it will already be utilizing AWS-1 spectrum
for LTE service at the time of closing, AT&T “preliminarily has determined that it will be able to
deploy Leap‟s unused, contiguous AWS spectrum in as little as 60 to 90 days.” AT&T also estimates
that “it will be able to deploy the unused, contiguous Leap spectrum in many additional areas within
12 months after the close of this transaction.” (Public Interest Statement, page 15). Further, AT&T
asserts that “the AWS and PCS spectrum to be transferred here can be readily integrated into AT&T‟s
LTE network.” (Public Interest Statement, page 15).
a. Describe the methodology used to determine that Leap is currently using 42 percent of its
spectrum, and provide documents sufficient to show the application of that methodology.
b. Provide a complete list of CMAs in which AT&T expects to deploy Leap‟s contiguous AWS-
1 spectrum for LTE service in as little as 60-90 days after closing. Provide a detailed
explanation of the steps that AT&T would take to deploy this spectrum in the stated
timeframe. Further, provide all plans, analyses, and reports relating to this deployment.
c. Provide a complete list of CMAs in which AT&T expects to deploy Leap‟s contiguous
spectrum for LTE service within 12 months after closing, and identify the type and band of
spectrum that will be deployed in each CMA. Provide a detailed explanation of the steps that
AT&T would take to deploy this spectrum in that stated timeframe. In addition, provide all
plans, analyses, and reports relating to this deployment.
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d. Provide a complete list of CMAs in which AT&T plans to deploy Leap‟s PCS spectrum for
LTE service. Provide a detailed explanation of the steps that AT&T would take to deploy
this spectrum, including the expected timeframe. Further, provide all plans, analyses, and
reports relating to this deployment.
e. For each relevant area, explain in detail and provide all documents discussing, how AT&T‟s
planned utilization of Leap‟s AWS-1 and PCS spectrum is superior for AT&T‟s LTE
deployment, compared to any other spectrum considered by AT&T.
f. Describe in detail how the availability of backhaul services affects AT&T‟s ability to provide
LTE at a particular rate of speed, and identify each CMA where AT&T plans to use spectrum
acquired from Leap to support LTE and where AT&T anticipates backhaul services to
support LTE at a desired rate of speed will be unavailable.

12. The Applicants maintain that AT&T would be able to “refarm Leap spectrum into AT&T‟s LTE
network even before the full customer migration and network integration is completed.” (Public
Interest Statement, page 16). The Applicants further assert that the remaining Leap spectrum would
be available for redeployment on AT&T‟s LTE network “shortly after AT&T completes the
migration of Leap customers to AT&T‟s networks, which is expected within 18 months.” (Public
Interest Statement, page 16).
a. Describe in detail, provide a timeline, and provide all plans, analyses, and reports, explaining
AT&T‟s plans to refarm Leap‟s AWS-1 and PCS spectrum into AT&T‟s LTE network,
specifically addressing how refarming will be accomplished before, during, and after full
customer migration and network integration.
b. Provide a detailed explanation of AT&T‟s plans for Leap‟s LTE network and provide
documents sufficient to support this explanation.
c. For each relevant market, provide all plans, analyses, and reports, including any
documentation, methodologies, and assumptions used in any underlying models, discussing
the implementation and buildout of AT&T‟s LTE network and proposed LTE service, plans,
devices and roaming plans: (1) absent the Proposed Transaction; and (2) with the Proposed
Transaction.

13. The Applicants assert that the Proposed Transaction would allow “more efficient use of the Leap
spectrum than was possible on the Leap network.” (Public Interest Statement, page 16). The
Applicants contend that Leap‟s spectrum would allow AT&T to deploy LTE services in “larger, more
robust, contiguous 10x10 MHz (or greater) blocks of spectrum and put the spectrum to “efficient and
intensive use.” (Public Interest Statement, pages 13, 17).
a. Explain and describe in detail how contiguous spectrum in the relevant markets enables more
spectrally efficient deployments, including but not limited to, any analyses comparing the
spectral efficiency, user performance, and capacity characteristics of a 5x5 megahertz LTE
deployment with a 10x10 megahertz LTE deployment for existing cell site types and
locations, spectrum and specific peak hour demand. Provide all documents relied on in
preparing the response.
b. Explain and describe in detail how non-contiguous spectrum in both the AWS-1 and PCS
bands could improve spectrum utilization based on AT&T‟s current and planned site
configuration, network configuration, user equipment offerings and technology evolution for
both HSPA+ and LTE technologies.
c. Provide all plans, analyses, and reports, including any documentation, methodologies,
underlying spreadsheets, and assumptions used in any underlying models, discussing how
Leap‟s network assets would be complementary to AT&T‟s network and would result in
improved network experience for AT&T and Leap customers.

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14. Provide all plans, analyses, and reports, and any underlying spreadsheets, which relate to or discuss
problems or difficulties providing any relevant service in any relevant areas including, but not limited
to:
a. spectrum utilization and efficiency;
b. how AT&T evaluates and monitors capacity and capacity utilization, including the amount of
spectrum, speed of connection, and facilities (including cell site configuration and backhaul)
that are required to meet consumer demand;
c. AT&T‟s estimates of the spectrum required to support each relevant service and projections
of when AT&T will exhaust its available spectrum in each relevant area;
d. any spectrum capacity constraints AT&T is currently facing or the Company is projected to
face in the future;
e. dropped and/or blocked calls;
f. speed and other quality measures of data services;
g. the amount of spectrum needed for the Company to provide mobile wireless services for each
technology deployed in the AT&T network;
h. the impact the availability of backhaul services has on AT&T‟s ability to provide data
services at a particular rate of speed; and
i. repurposing spectrum, including the transition of subscribers from the repurposed spectrum;
and alternative solutions to any spectrum constraint problems, including enhanced network or
user equipment features, changing prices, or use of small cells or other network
reconfiguration options.

15. The Applicants assert that “AT&T expects that many Leap customers can be seamlessly migrated to
AT&T‟s network as they select their new devices” and that “as AT&T learns more about Leap‟s
customer base, it may formulate offers designed to further encourage Leap‟s customers to migrate to
AT&T‟s network within 18 months of merger close.” (Applicants Aug. 20 Amendment, pages 2-3).
a. Describe in detail AT&T‟s plans to migrate current Leap customers to AT&T, including:
i. any plans relating to AT&T‟s expectation that “many Leap customers can be
seamlessly migrated to AT&T‟s network as they select their new devices, and the
length of time Leap‟s current customers would be able to use their existing devices
after the closing of the Proposed Transaction”;
ii. any plans to “formulate offers designed to further encourage Leap‟s customers to
AT&T‟s network within 18 months of merger close”;
iii. any plans for relevant services and devices to be offered to Leap‟s current customers,
including but not limited to (a) a detailed description of AT&T‟s plans to provide
Leap‟s customers with devices that can be used on AT&T”s network and any
associated charges to a Leap customer who is required to acquire such a device, and
(b) the data rates, service plans and pricing to be offered to Leap‟s customers,
specifically identifying the rate plans that will appeal to value conscious customers;
and
iv. any plans for Leap‟s customers to retain their current service plans and if so, the
length of time existing Leap customers can remain enrolled under their existing
service plans, and the period during which new Leap customers would be able to
select one of Leap‟s current service plans after the closing of the Proposed
Transaction. Include in your explanation a detailed discussion of all the different
types of prepaid/no-contract plans (e.g., daily, monthly all-you-can-eat, and pay as
you go) currently available to Leap‟s customers.
b. Describe in detail the transition of Leap‟s existing customers, including
i. a projected timeline for the transition of all of Leap‟s customers;
ii. how Lifeline customers would be transitioned;
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iii. how Muve Music customers would be transitioned and whether the service would
continue to be offered; and
iv. the transition of Leap‟s customers enrolled under the MVNO arrangement with
Sprint.
c. Provide all plans, analyses, and reports discussing customer migration and transition of
Leap‟s current customers to AT&T.
d. Identify all CMAs where Leap has ETC status on tribal lands. Describe in detail AT&T‟s
plans for allowing those customers to continue participating in the Lifeline program after the
transaction.
e. For each handset that would be offered to Leap‟s customers after the closing of the Proposed
Transaction, provide a description of the features of that handset and the services (e.g.,
HSPA+, LTE) supported by that handset.

16. The Applicants state that “AT&T generally has not aimed to match the offerings of prepaid/no-
contract companies such as Cricket and others,” although they also state that “AT&T has been
marketing prepaid services under the „AT&T GoPhone‟ brand for many years” and “recently
launched standalone prepaid brand called “Aio Wireless.” (Public Interest Statement, page 12). The
Applicants contend that by combining “Leap‟s established Cricket brand . . . with AT&T‟s
nationwide 4G LTE/HSPA+ network, advanced devices and services, and financial resources, the
combined company more quickly will bring customers nationwide a higher-quality, more robust, and
competitive prepaid offering.” (Public Interest Statement, pages 12-13).
a. Explain in detail and provide documents sufficient to support your explanation, of AT&T‟s
post-transaction plans to achieve such prepaid/no-contract offerings that would “bring
customers nationwide a higher-quality, more robust, and competitive prepaid offering.”
Include in your response the details regarding the different types of prepaid offerings (e.g.,
daily, monthly all-inclusive, and pay-as-you-go). Provide a detailed description of the
Company‟s plans for GoPhone and Aio Wireless.
b. Provide all documents discussing the development of new prepaid mobile wireless service
offerings, or the expansion, improvement or reduction of existing prepaid mobile wireless
service offerings, or any other changes to the company‟s current prepaid mobile wireless
services offerings (sold under the GoPhone and Aio Wireless brands), including but not
limited to, brand development or elimination, retail expansion and distribution, promotions,
and device offerings.
c. Explain in detail and provide documents sufficient to support your explanation, AT&T‟s
plans after the closing of the Proposed Transaction, to integrate Leap‟s Cricket brand, with
AT&T‟s current and future prepaid mobile wireless services, including any plans to expand
the Cricket brand into any new geographic areas.
d. Provide all plans, analyses, and reports discussing how the combined company would
compete with other mobile wireless services providers, including, but not limited to, prepaid
advertising plans and strategies, prepaid service plans and promotions, and devices offered
under both the AT&T and the Cricket brands.

17. Provide all plans, analyses, and reports discussing AT&T‟s pricing decisions for any relevant service
in any relevant market and the United States as a whole, including, but not limited to discussions of:
(1) pricing plans; (2) pricing policies; (3) pricing forecasts; (4) pricing strategies; (5) pricing analysis;
(6) introduction of new pricing plans or promotions, including local promotions and their
determinants and expected or actual impact; (7) tiered pricing, including its relationship to data
forecasts and profitability and expected or actual impact; and (8) pricing decisions relating to each
relevant service and relevant product.

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18. Provide all plans, analyses, and reports (including any surveys conducted by AT&T or any third
party) discussing how customers view and value AT&T‟s network quality, service plans, pricing, and
promotions (including local promotions), including any changes by competitors as a result of service
offerings by AT&T, and any contemplated or actual competitive changes to AT&T‟s service plans,
pricing, or promotions as a response to other service providers‟ offerings.

19. Provide all documents discussing AT&T‟s analysis of, response to, or competitive positioning of
AT&T and other mobile wireless service providers in the provision of each relevant service or
relevant product in each relevant area, including but not limited to, discussions of perceptions of
customer service, spectrum holdings, network quality, offering services at a particular rate, the impact
of not offering particular wireless services or devices, the entry of a new wireless service provider,
the introduction by a rival service provider of any new relevant product or relevant service (such as
Wi-Fi, VoIP, or access to Hotspots), roaming, and the ability to use products internationally.

20. The Applicants assert that “Leap generally has only a modest presence even in the areas where it does
offer facilities-based service” and that “AT&T and Leap are not close competitors.” (Public Interest
Statement, page 32). Dr. Israel contends that “Leap customers are „unlikely to prefer the nationwide
providers‟ like AT&T, this means that the potential for substitution from Leap to AT&T is not likely
to be large.” (Public Interest Statement, Israel Declaration, ¶ 24). Provide all documents that Dr.
Israel relied on to make statements concerning Leap and its competitors, and in particular, AT&T and
Leap as competitors.

21. Provide all documents relating to the loss of customers to other mobile wireless services providers
and any attempts to win customers from other mobile wireless services providers or stem losses of
customers, including but not limited to:
i.
churn data and any analyses or reports thereof, including but not limited to, analyses on the
correlation of churn with quality, length of contract commitments, and price or other factors;
ii.
data or studies indicating that a customer left the company or switched to the company
because of pricing, network quality, customer service, or the absence or availability of
particular services or devices (including, but not limited to, figures on subscribers lost or
gained); and
iii.
documents relating to AT&T‟s experience or success in obtaining customers through
marketing or promotions targeted at particular mobile wireless services providers, particular
geographic areas, particular demographic groups, or particular wireless devices, or types of
customers (including but not limited to, the offers made and the amount spent on the
marketing effort, the number of new subscribers gained, average churn rates for such
subscribers and revenue realized by the company).

22. The Applicants contend that the Proposed Transaction would result in “significant savings in network
and operating costs and other synergies.” (Public Interest Statement, page 7).
a. Describe in detail all of the claimed savings and synergies that are projected by the
Applicants to result from the Proposed Transaction.
b. Provide all plans, analyses, and reports, models, assumptions, and spreadsheets, relating to
the estimates of savings in network and operating costs and all synergies referred to in the
Applicants‟ filings in the record, including all documents discussing the projected impact of
the synergies on employment after the closing of the Proposed Transaction.
c. In particular, describe in detail, and provide all documents relating to, how the Applicants
plan to achieve “substantial savings” in customer support functions, while maintaining a
“high level of support.”
d. For each operational savings or cost synergy identified by the Applicants in determining their
total savings and annual savings referred to in the Public Interest Statement and the
6


supporting declarations: (i) provide a quantification of the operational savings or cost
synergy and an explanation of how the quantification was calculated; and (ii) state the steps
that AT&T anticipates taking to achieve that operational savings or cost synergy, and the
estimated time and costs required to achieve it.
e. For each cost saving, state whether it is a fixed cost saving or a variable cost saving and
explain the reasoning. State separately the one-time fixed cost savings, recurring fixed cost
savings, and variable cost savings (in dollars per subscriber and dollars per year).

23. The Applicants assert that the integration of Leap‟s spectrum would result in “greater spectral
efficiencies, including improvements in throughput speeds, peak data rates, and latency.” (Public
Interest Statement, page 18). The Applicants maintain that “[m]any of Leap‟s cell sites will be
productively integrated into our network to increase capacity.” (Public Interest Statement, page 8).
In Mr. Hogg‟s Declaration, he contends that network performance would improve for both
companies. (Hogg Declaration, ¶ 10).
a. Explain and describe in detail how AT&T would be able to integrate many existing Leap cell
sites into its network, resulting in the claimed benefits for both companies as described in the
record. Include the estimated net cost savings of decommissioning any redundant cell sites
and any expected impact from the recent cell-tower transaction with Crown Castle
International Corp.
b. Describe in detail and provide all plans, analyses, reports, models, and methodologies relating
to the integration by AT&T of Leap‟s spectrum that would result in “greater spectral
efficiencies,” including current and projected performance, upload and download speed,
latency, and deployment configuration.
c. Provide all plans, analyses, and reports discussing how the combined company would integrate
networks, technologies, switching facilities, and cell sites. Identify the Leap cell sites to be
integrated into the AT&T network, including the criteria to be used to consolidate cell sites and
a timeline for the integration, and identify, by CMA, the number and location of the cell sites
that the combined company would own, share, or decommission.

24. Provide all documents discussing any Leap CDMA or LTE roaming or buildout agreement in any
relevant area, including all documents discussing AT&T‟s plans to renew, extend, or cancel these
agreements. Explain AT&T‟s plans relating to these agreements, including whether, and for how long,
the company would honor these agreements. Discuss any penalties that would occur if these contracts
were cancelled. Explain whether: (1) AT&T will provide CDMA roaming services at the current rates,
terms, and conditions until Leap‟s CDMA network is shut down; (2) AT&T has any plans to raise
roaming rates or change other terms and conditions prior to shutting down Leap‟s CDMA network; and
(3) whether AT&T plans to renew, extend, or sign new roaming agreements prior to shutting down
Leap‟s CDMA network.
25. Provide the Company‟s data as specified in Attachment A, which includes data on subscribers,
handsets, plans, porting, revenue, sites, deployment, and traffic.

26. For the dates January 1 and July 1 in the years 2011, 2012, and 2013, and for each brand under which
AT&T sells mobile wireless services, identify the ten best-selling mobile wireless services pricing plans
for the United States as a whole, as measured by subscribers. For each pricing plan identified, state the
number of total subscribers to each plan and the number of new subscribers added in the prior six
months, and describe the price of and all features and services encompassed in the plan, including but
not limited to, the number of included minutes and data services, whether mobile wireless services can
be shared with others, any promotions offered to attract new subscribers to the plan, and any charges for
usage in excess of the maximum allowed under the plan. Additionally, identify by line number, the
place where data on each plan identified is provided in response to Request 25 above.

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27. Provide all documents relied upon or referred to by Mr. Hogg, Mr. Hutcheson, Mr. Moore, and Mr.
Strickland in making the statements contained in their Declarations submitted to the Commission in
connection with the Proposed Transaction. In addition, provide all documents provided to, reviewed by,
relied upon, or referred to by Dr. Israel in making the statements contained in his Declarations
submitted to the Commission in connection with the Proposed Transaction.

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Attachment A

Format of Data

All data should be submitted in a .csv (comma-delimited) format. The sheets in the workbook provide a template for how the tables should be designed.
The required format for the entries in each column/field is indicated in the instructions for each sheet.
All entries in Text fields must be in quotation marks (e.g. "AT&T", "Leap Wireless").
Column entries in bold red indicate that the party should enter only one of the possible entries listed for that column. No other entries should be entered.
Data for all of the tables should be submitted on a periodic basis as specified in the instructions in individual tables.
Page 1 of 21

"Subs Data" Table
For each month beginning 01/01/2011 and extending through 09/30/2013, please provide subscriber data requested in the "Subs Data" table.
In general, this table is intended to provide data on the number of subscribers (subs) by CMA, business unit, and service type.

Column

Variable Name

Format

Possible Entries/Example Entries

Description

A
Date
Text - YYYY_MM
2011_01 to 2013_06
The month for which the data is being collected.
B
CMA
Number - Integer
1 to 734
This field represents the standard market number of the CMA in which subs are located.
This field represents the business unit, subsidiary, or brand which carries the handset. Applicants should
"AT&T Wireless", "GoPhone", Aio Wireless", "MVNO",
provide data for each business unit separately as well as for the total across all business units. Entries
C
Business Unit
Text
"Total", etc.
aggregating total data should be labeled "Total."
"Consumer Postpaid", "Consumer Prepaid",
This field denotes type of service being used by subscribers. Enterprise and M2M subscribers may be
D
Service Type
Text
"Lifeline", "Wholesale", "Other"
grouped into "Other."

Voice Only Subscribers


This field identifies the number of voice activations from the beginning of the time period specified in
Column A to the beginning of the following period, who DO NOT also activate a mobile broadband service
E
Voice Only Activations
Number - Integer
2435, 12102, etc. (N/A if not applicable)
or a text messaging plan.
This field identifies the total cost per gross activation for voice activations from the beginning of the time
period specified in Column A to the beginning of the following period, who DO NOT also activate a mobile
F
Voice Only CPGA
Number - Integer
broadband service or a text messaging plan.
This field identifies the number of voice deactivations from the beginning of the time period specified in
Column A to the beginning of the following period, who DO NOT also deactivate a mobile broadband
G
Voice Only Deactivations
Number - Integer
2435, 12102, etc. (N/A if not applicable)
service or a text messaging plan.
This field identifies the number of voice subs who DO NOT subscribe to a mobile broadband service or a
H
Voice Only Subs
Number - Integer
24359, 31025, etc. (N/A if not applicable)
text messaging plan at the end of the time period specified in Column A.
Number - 2 decimal
This field indicates the average revenue per user for voice subs who DO NOT subscribe to a mobile
I
Voice Only ARPU
points
broadband service or a text messaging plan for the time period specified in Column A.
Number - 2 decimal
This field identifies the cash cost per user (exclusive of CPGA) for voice subs who DO NOT subscribe to a
J
Voice Only CCPU
points
mobile broadband service or a text messaging plan for the time period specified in Column A.

Voice and Text Only Subscribers


This field identifies the number of voice activations from the beginning of the time period specified in
Column A to the beginning of the following period, who DO NOT also activate a mobile broadband service
K
Voice and Text Only Activations
Number - Integer
2435, 12102, etc. (N/A if not applicable)
(with the exception of text messaging).
This field identifies the total cost per gross activation for voice activations from the beginning of the time
period specified in Column A to the beginning of the following period, who DO NOT also activate a mobile
L
Voice and Text Only CPGA
Number - Integer
broadband service (with the exception of text messaging).
This field identifies the number of voice deactivations from the beginning of the time period specified in
Column A to the beginning of the following period, who DO NOT also deactivate a mobile broadband
M
Voice and Text Only Deactivations
Number - Integer
2435, 12102, etc. (N/A if not applicable)
service (with the exception of text messaging).
This field identifies the number of voice subs who DO NOT subscribe to a mobile broadband service (with
N
Voice and Text Only Subs
Number - Integer
24359, 31025, etc. (N/A if not applicable)
the exception of text messaging) at the end of the time period specified in Column A.
Number - 2 decimal
This field indicates the average revenue per user for voice subs who DO NOT subscribe to a mobile
O
Voice and Text Only ARPU
points
broadband service (with the exception of text messaging) for the time period specified in Column A.
This field identifies the cash cost per user (exclusive of CPGA) for voice subs who DO NOT subscribe to a
Number - 2 decimal
mobile broadband service (with the exception of text messaging) for the time period specified in Column
P
Voice and Text Only CCPU
points
A.

Mobile Broadband Only Subscribers


This field identifies the number of mobile broadband activations (with the exception of text messaging)
from the beginning of the time period specified in Column A to the beginning of the following period, who
Q
Mobile Broadband Only Activations
Number - Integer
2435, 12102, etc. (N/A if not applicable)
DO NOT also activate a voice service.
This field identifies the total cost per gross activation for mobile broadband activations (with the exception
of text messaging) from the beginning of the time period specified in Column A to the beginning of the
R
Mobile Broadband Only CPGA
Number - Integer
following period, who DO NOT also activate a voice service.
This field identifies the number of mobile broadband deactivations (with the exception of text messaging)
from the beginning of the time period specified in Column A to the beginning of the following period, who
S
Mobile Broadband Only Deactivations
Number - Integer
2435, 12102, etc. (N/A if not applicable)
DO NOT also deactivate a voice service.
Subs Data Instructions

"Subs Data" Table
This field identifies the number of mobile broadband subs (with the exception of text messaging) who DO
T
Mobile Broadband Only Subs
Number - Integer
24359, 31025, etc. (N/A if not applicable)
NOT subscribe to a voice service at the end of the time period specified in Column A.
Number - 2 decimal
This field indicates the average revenue per user for mobile broadband subs (with the exception of text
U
Mobile Broadband Only ARPU
points
messaging) who DO NOT subscribe to a voice service for the time period specified in Column A.
This field identifies the cash cost per user (exclusive of CPGA) for mobile broadband subs (with the
Number - 2 decimal
exception of text messaging) who DO NOT subscribe to a voice service for the time period specified in
V
Mobile Broadband Only CCPU
points
Column A.

Voice, Text and Mobile Broadband Subscribers


Voice, Text and Mobile Broadband
This field identifies the number of voice, text and mobile broadband activations from the beginning of the
W
Activations
Number - Integer
2435, 12102, etc. (N/A if not applicable)
time period specified in Column A to the beginning of the following period.
This field identifies the total cost per gross activation for voice, text and mobile broadband activations from
X
Voice, Text and Mobile Broadband CPGA Number - Integer
the beginning of the time period specified in Column A to the beginning of the following period.
Voice, Text and Mobile Broadband
This field identifies the number of voice, text and mobile broadband deactivations from the beginning of the
Y
Deactivations
Number - Integer
2435, 12102, etc. (N/A if not applicable)
time period specified in Column A to the beginning of the following period.
This field identifies the number of voice, text and mobile broadband subs at the end of the time period
Z
Voice, Text and Mobile Broadband Subs
Number - Integer
24359, 31025, etc. (N/A if not applicable)
specified in Column A.
Number - 2 decimal
This field indicates the average revenue per user for voice, text and mobile broadband subs for the time
AA
Voice, Text and Mobile Broadband ARPU points
period specified in Column A.
Number - 2 decimal
This field identifies the cash cost per user (exclusive of CPGA) for voice, text and mobile broadband subs
AB
Voice, Text and Mobile Broadband CCPU points
for the time period specified in Column A.

Total Subscribers


This field identifies the total number of activations from the beginning of the time period specified in
Column A to the beginning of the following period, including subs who activate voice, text and mobile
AC
Total Activations
Number - Integer
2435, 12102, etc. (N/A if not applicable)
broadband, or any combination of these services.
This field identifies the total cost per gross activation for all activations, including those who activate voice,
text and mobile broadband, or any combination of these services from the beginning of the time period
AD
Total CPGA
Number - Integer
specified in Column A to the beginning of the following period.
This field identifies the total number of deactivations from the beginning of the time period specified in
Column A to the beginning of the following period, including subs who deactivate voice, text and mobile
AE
Total Deactivations
Number - Integer
2435, 12102, etc. (N/A if not applicable)
broadband, or any combination of these services.
This field identifies the total number of subs, including those who subscribe to voice, text and mobile
AF
Total Subs
Number - Integer
24359, 31025, etc. (N/A if not applicable)
broadband, or any combination of these services at the end of the time period specified in Column A.
Number - 2 decimal
This field indicates the average revenue per user across all subs, including those who subscribe to voice,
AG
Total ARPU
points
text and mobile broadband, or any combination of these services for the time period specified in Column A.
This field identifies the cash cost per user (exclusive of CPGA) across all subs, including those who
Number - 2 decimal
subscribe to voice, text and mobile broadband, or any combination of these services for the time period
AH
Total CCPU
points
specified in Column A.
Total Volume of voice calls in Minutes of Use in a month per subscriber for the time period specified in
AI
Voice Volume MoU
Number - Integer
Column A.
AJ
Text Volume MB
Number - Integer
Total Volume of text equivalent in MB in a month per subscriber for the time period specified in Column A.
Total Volume of data exclusive of text usage in MB in a month per subscriber for the time period specified
AK
Mobile Broadband Data Volume MB
Number - Integer
in Column A.
Subs Data Instructions

Mobile

Mobile

Voice, Text Voice, Text

Voice, Text

Voice, Text Voice, Text Voice, Text

Mobile

Voice and Voice and Voice and Text Voice and Voice and Voice and Broadband

Mobile

Broadband

Mobile

Mobile

Mobile

and Mobile and Mobile
and Mobile
and Mobile and Mobile and Mobile

Text

Broadband

Business

Voice Only Voice Only

Voice Only

Voice Only Voice Only Voice Only

Text Only

Text Only

Only

Text Only Text Only Text Only

Only

Broadband

Only

Broadband Broadband Broadband Broadband Broadband

Broadband

Broadband Broadband Broadband

Total

Total

Total

Total Total Total Voice Volume Volume Data Volume

Date CMA

Unit

Service Type Activations

CPGA

Deactivations

Subs

ARPU

CCPU

Activations

CPGA

Deactivations

Subs

ARPU

CCPU

Activations Only CPGA

Deactivations

Only Subs

Only ARPU Only CCPU Activations

CPGA

Deactivations

Subs

ARPU

CCPU

Activations CPGA Deactivations Subs ARPU CCPU

MoU

MB

MB

Subs Data Template

"Plans Data" Table
Please provide plan data requested in the "Plans Data" table for plans that are offered to consumers 1/1 and 7/1 beginning H1 2011 and extending through H2 2013. In general, this table
is intended to provide data on available plans nationwide.

Column

Variable Name

Format

Possible Entries/Example Entries

Description

A
Date
Text - YYYY_HH
2011_H1 to 2013_H1
The half year for which the data is being collected.
"AT&T Wireless", "GoPhone", Aio Wireless",
B
Business Unit
Text
"MVNO", etc.
This field represents the business unit, subsidiary, or brand which offers the plan.
C
Plan Name
Text
The name or description of the plan as used in the billing system
D
Date First
Text - YYYY_MM
2010_06
The year and month the plan was first offered to new subscribers
E
Date Last
Text - YYYY_MM
2012_03
The year and month the plan was last offered to new subscribers
"Consumer Postpaid", "Consumer Prepaid",
"Consumer Mobile Broadband-Only",

The plan subscriber type. Note: Include small business subscribers but not MVNO,
F
Plan Type
Text
"Consumer Other"
M2M or enterprise customers in any calculations or plan definitions.
G
Voice Share
Text
"Y" or "N"
Whether the minutes of the plan are shared across multiple lines (i.e. family plan).
H
National
Text
"National", "Regional/Local"
An indicator of whether the plan's home calling area is national or local/regional.
I
Minutes Any
Number
The number of anytime minutes included in the plan. If unlimited code as 9999.
The number of megabytes included in the plan (if any). If unlimited code as 9999. If
J
Data
Number
none plan code as 0.
The name or description of the data plan as used in the billing system. If no data,
K
Data Name
Text
code as N/A.
Whether data included in the plan can be shared across multiple lines (i.e. mobile
L
Data Share
Text
"Y" or "N"
share plan). If no data, code as N/A.
An indicator for whether the data plan is available to smartphone devices. If no
M
Smart Data
Text
"Y" or "N"
data, code as N/A.
The number of text messages included in the plan (if any). If unlimited code as 9999.
N
Texts
Number
If no plan, code as zero.
O
Primary Access Charge
Number
The monthly recurring access charge for the primary line.
The monthly recurring access charge per additional line on the account. If not
P
Additional Access Charge
Number
applicable, code as 9999.
The per-minute overage rate for anytime minutes in excess of the minutes included
Q
Overage Anytime
Number
in the plan.
R
Text Monthly
Number
The monthly recurring charge for the text messages included in the plan.
The per-text overage rate for text messages in excess of the text messages included
S
Overage Text
Number
in the plan. If no plan provide a la carte rate.
T
Data Monthly
Number
The monthly recurring charge for the megabytes of data included in the plan.
The per-megabyte overage rate for data in excess of the megabytes included in the
U
Overage Data
Number
plan. If no plan provide a la carte rate.
V
Simple Pricing
Text
"Y" or "N"
Listed prices include all taxes and fees.
W
Unlimited Music
Text
"Y" or "N"
Plan provides an option for unlimited music downloads (i.e., Muve)
Plans Data Instructions

Primary Additional

Business Plan

Voice

Minutes

Data

Data Smart

Access

Access

Overage

Text

Overage

Data

Overage

Simple

Unlimited

Date

Unit

Name Date First Date Last Plan Type Share National

Any

Data Name Share

Data

Texts Charge

Charge

Anytime Monthly

Text

Monthly

Data

Pricing

Music

Plans Data Template

"Ports Out Data" Table
For each month beginning 01/01/2011 and extending through 09/30/2013, please provide porting data requested in the "Port Out Data" table.
In general, this table is intended to provide data on the ports from AT&T to other providers.

Column

Variable Name

Format

Possible Entries/Example Entries

Description

A
Date
Text - YYYY_MM
2011_01 to 2013_06
The month for which the data is being collected.
B
CMA
Number - Integer
1 to 734
This field represents the standard market number of the CMA from which subs port.
The name of the competing service provider to which AT&T subscribers port during the time period
C
Ports To
Text
specified in Column A.
D
Postpaid Ports Out
Number - Integer
The number of postpaid subscribers who port from AT&T.
E
Prepaid Ports Out
Number - Integer
The number of prepaid subscribers who port from AT&T.
Ports Out Instructions

Postpaid

Prepaid

Date CMA Ports To Ports Out Ports Out

Ports Out Template

"Ports In Data" Table
For each month beginning 01/01/2011 and extending through 09/30/2013, please provide porting data requested in the "Ports In Data" table.
In general, this table is intended to provide data on the ports to AT&T from other providers.

Column

Variable Name

Format

Possible Entries/Example Entries

Description

A
Date
Text - YYYY_MM
2011_01 to 2013_06
The month for which the data is being collected.
B
CMA
Number - Integer
1 to 734
This field represents the standard market number of the CMA to which subs port.
The name of the competing service provider whose subscribers port to AT&T during the time period
C
Ports From
Text
specified in Column A.
D
Postpaid Ports In
Number - Integer
The number of subscribers who port in order to become postpaid subscribers of AT&T.
E
Prepaid Ports In
Number - Integer
The number of subscribers who port in order to become prepaid subscribers of AT&T.
Ports In Instructions

Ports

Postpaid

Prepaid

Date CMA

From

Ports In

Ports In

Ports In Template

"Revenue Data" Table
For each month beginning 01/01/2011 and extending through 09/30/2013, please provide revenue data requested in the "Revenue Data" table.
In general, this table is intended to provide data on the revenue and average revenue per user by CMA and source of revenue.

Column

Variable Name

Format

Possible Entries/Example Entries

Description

A
Date
Text - YYYY_MM
2011_01 to 2013_06
The year and month for which the data is being collected.
B
CMA
Number - Integer
1 to 734
This field represents the standard market number of the CMA where revenues are earned.
This field represents the business unit, subsidiary, or brand which earns the revenue.
"AT&T Wireless", "GoPhone", Aio Wireless",
Applicants should provide data for each business unit separately as well as for the total
C
Business Unit
Text
"MVNO", "Total", etc.
across all business units. Entries aggregating total data should be labeled "Total."
"Consumer Prepaid", "Consumer Postpaid",
This field indicates the particular line of business from which revenue is being earned.
D
Business Line
Text
"Total"
Enterprise and M2M revenues may be grouped into "Other."
"Service Revenue" (excluding "High Cost USF",
This field indicates a broad class of revenue encompassing each revenue source. Entries in
E
Revenue Class
Text

Lifeline", "Other USF"), "Total"

this field should exclude "High Cost USF", "Lifeline", and "Other USF".
F
Revenue
Number
This field indicates the total revenue from each revenue source.
Number - 2
G
ARPU
decimal points
This field indicates the average revenue per user for each revenue source.
This field indicates the total revenue from each revenue source for the whole US (including
H
Revenue US
Number
Puerto Rico).
Number - 2
This field indicates the average revenue per user for each revenue source for the whole US
I
ARPU US
decimal points
(including Puerto Rico).
Revenue Instructions

Business Business Revenue

Revenue_

Date CMA

Unit

Line

Class

Revenue ARPU

US

ARPU_US

Revenue Template

"Site Data" Table
The following data descriptions apply to the columns of the "Site Data" table. The "Site Data" table should contain one row for every site utilized or planned for
construction by Applicant. The site IDs in this table should correspond to the site IDs entered in the other requested tables. In the event that Applicant does not
own the site utilized and information regarding Columns M-R is unavailable, N/A may be written.

Column

Variable Name

Format

Possible Entries/Example Entries

Description

A
Date
Text - YYYY_MM
2013_06
The latest month for which data is available.
B
Site ID
Text
A unique site ID for the site to which this data record applies.
C
Site Planned
Text
"Y" or "N"
Yes if the site does not currently exist or operational, but planned for construction or operation.
D
Number of Sectors
Number - Integer
1, 2, 3, etc. (N/A for planned site)
This field provides an integer representing the number of sectors this site utilizes.
Number - At least 6
E
Latitude
decimal places
41.756847, 29.633847, etc.
This field is the latitude (NAD 83) of the site in decimal form to at least six significant digits.
Number - At least 6
F
Longitude
decimal places
-87.467568, -95.267568, etc.
This field is the longitude (NAD 83) of the site in decimal form to at least six significant digits.
This field is the five-digit FIPS code - based on 2010 designations - of the county in which the
G
County FIPS
Text
"17031", "51700", etc.
site is located.
H
CMA
Number - Integer
1 to 734
This field represents the standard market number of the CMA in which the site is located.
This field indicates the type of site to which the record applies using one of the possible entries
I
Site Type
Text

Possible Entries Below

listed below.
"Macro_Tower"
An outdoor macrocell mounted on a monopole, guyed tower, or free standing tower
"Macro_Building"
An outdoor macrocell mounted on a building
"Macro_Other"
An outdoor macrocell that does not fit the previous categories (silo, water tower, etc.)
"Microcell"
An outdoor cell classified by the vendor as a microcell
"Outdoor Pico"
An outdoor cell classified by the vendor as a picocell
"Indoor Pico"
An indoor cell classified by the vendor as a picocell
"Outdoor Small Cell"
An outdoor cell classified by the vendor as a 3GPP compliant small cell
"Indoor Small Cell"
An indoor cell classified by the vendor as a 3GPP compliant small cell
"Outdoor DAS"
An outdoor Distributed Antenna System
"Indoor DAS"
An indoor Distributed Antenna System
"Repeater"
A cell that repeats/boosts the signal of another cell
"Other"
A cell that does not meet any of the above descriptions
This field indicates the morphology of the area that the site serves using one of the possible
entries listed below. Please provide a description of the methodology used to determine these
J
Site Geographic Classification
Text
"Urban", "Suburban", "Rural"
classifications in a separate attachment.
Site Data Instructions

Column

Variable Name

Format

Possible Entries/Example Entries

Description

The current operator of the site to which this data record applies. In cases where a Leap
Wireless site and AT&T site share the same tower or other supporting structure, each site
K
Current Operator
Text
"Leap Wireless", "AT&T"
should be entered separately.
L
Company Owned: "Y" or "N"
Text
"Y" or "N"
Is the location of the site owned by the operator?
This field indicates whether the tower, antenna structure, or other facility on which the site is
located is owned by a wireless operator (or its affiliate), or whether it is owned by an
"AT&T", "Leap Wireless", "Verizon
independent entity. If the structure is owned by a wireless operator or its affiliate, include the
M
Site Structure Ownership
Text
Wireless", "independent entity"
name of the wireless operator.
N
Expected to be Decommissioned
Text
"Y" or "N" (N/A for planned site)
This field indicates if the site is currently planned for decommission.
This field indicates the date when it was determined that a site was scheduled for
O
Date Decommission Decided
Text - YYYY_MM
2013_06 (or N/A)
decommissioning.
P
Date of Decommission
Text - YYYY_MM
2014_09 (or N/A)
This field indicates the date set for this site to be decommissioned.
This field indicates whether or not AT&T expects to decommission the site in question in the
Q
Decommission by AT&T Planned
Text
"Y" or "N" (N/A for planned site)
event the proposed transaction is consummated.
This field indicates the type of technology supporting the connection between a cell site type and
R
Backhaul
Text

Possible Entries Below

a backhaul point of presence
"TDM"
Time division multiple access
"Fiber"
Lit fiber to tower
"Microwave"
Point to point or point to multipoint fixed microwave system
"Other"
Backhaul that does not fall into the above categories
Site Data Instructions

Site

Company

Date

Decommission

Site

Number of

County

Geographic

Current

Owned:

Site Structure

Expected to be

Decommission

Date of

by AT&T

Date Site ID Planned

Sectors

Latitude Longitude

FIPS

CMA Site Type Classification Operator "Y" or "N"

Ownership

Decommissioned

Decided

Decommission

Planned

Backhaul

Site Data Template

"Deployed Carriers" Table
The following data descriptions apply to the columns of the "Deployed Carriers" table (where "carriers" refers to channels or portions of spectrum used
in the network rather than operators or service providers). In general, this table should contain one row for each carrier/channel deployed
at each AT&T sector. Because sites and sectors can include multiple carriers/channels, the same site/sector ID may appear in multiple rows.

Column

Variable Name

Format

Possible Entries/Example Entries

Description

The month for which the data is being collected. Submit data on a quarterly basis
A
Date
Text - YYYY_MM
2011_01 to 2013_06
from March 2011 to September 2013 as of the second week of the month.
B
Site ID
Text
A unique site ID for the site to which this data record applies.
C
Band
Text

Possible Entries Below

The frequency band in which the channel/carrier in this data record operates.
"Cellular"
The Cellular 850 MHz band (824-859 MHz and 869-884 MHz)
"PCS"
The PCS 1900 MHz band (1850-1910 MHz and 1930-1990 MHz)
"AWS"
The AWS-1 band (1710-1755 MHz and 2110-2155 MHz)
"Lower_700"
The Lower 700 MHz band
This field indicates the technology standard used by the channel/carrier described
D
Technology of Carrier
Text

Possible Entries Below

in this record.
"GSM"
A carrier/channel that only supports GSM (GMSK modulation)
"GPRS"
A carrier/channel that supports GSM and GPRS
"EDGE"
A carrier/channel that supports GSM, GPRS and EDGE
"WCDMA"
A wideband CDMA carrier conforming to Release 4 or earlier
"HSDPA"
A wideband CDMA carrier conforming to UTRA Release 5
"HSUPA_HSPA"
A wideband CDMA carrier conforming to UTRA Release 6
"HSPA+"
A wideband CDMA carrier conforming to UTRA Release 7
"LTE"
An LTE carrier conforming to E-UTRA Release 8 or later
"Other"
A carrier that does not conform to one of the technologies listed above
E
Carrier BW_MHz
Number

Possible Entries Below

This field contains the bandwidth in MHz of the carrier described in this record
0.2
Carrier = GSM
0.2
Carrier = GPRS
0.2
Carrier = EDGE
5
Carrier = WCDMA
5
Carrier = HSDPA
5
Carrier = HSPA
5
Carrier = HSPA+
1.4
Carrier = LTE (Contiguous, Single Band)
Deployed Carriers Instructions

Column

Variable Name

Format

Possible Entries/Example Entries

Description

3
Carrier = LTE (Contiguous, Single Band)
5
Carrier = LTE (Contiguous, Single Band)
10
Carrier = LTE (Contiguous, Single Band)
20
Carrier = LTE (Contiguous, Single Band)
# (Other Number)
Carrier = Other
This field contains the unrounded center frequency in MHz of the downlink carrier
F
Center Freq_MHz
Number
1937.5, 2142.625, etc.
described in this record.
G
Carrier Active
Text

Possible Entries Below

This field is used to indicate whether a carrier is actively carrying customer traffic.
Indicates that the carrier is carrying commercial traffic generated by paying
"Y"
customers
Indicates that the carrier is not yet deployed, used for test or trial purposes, or
"N"
turned off
Deployed Carriers Instructions

Technology of

Carrier

Center

Carrier

Date

Site ID

Band

Carrier

BW_MHz

Freq_MHz

Active

Deployed Carriers Template

"Traffic" Table
The following data descriptions apply to the columns of the "Traffic" table. In general, this table is intended to provide data on the average busy
hour voice and data traffic at each AT&T site/sector, by technology group and by spectrum band. All busy hour data shall be the
average bouncing busy hour (BBH) over the 5-day business week period (Mon-Fri) in the second week of the month for the last
month of each quarter from Q1 2011 to Q3 2013. The BBH is the one-hour period during the day in which the highest usage is measured,
starting on the hour or half hour, and the highest usage hour may vary from day to day.
In the column headings, "G" indicates traffic carried by on a GSM/GPRS/EDGE network, "H" indicates traffic carried on a
WCDMA/HSPA/HSPA+ (UTRA) network, and "L" indicates traffic carried on an LTE network.

Column

Variable Name

Format

Possible Entries/Example Entries

Description

The month for which the data is being collected. Submit data on a quarterly basis from March
A
Date
Text - YYYY_MM
2011_01 to 2013_06
2011 to September 2013 as of the second week of the month.
B
Site ID
Text
A unique site ID for the site to which this data record applies.
700 MHz Band - GSM/GPRS/EDGE
C
700_G_Avg BBH Voice Traffic_Erlangs
Number
BBH voice traffic in Erlangs carried by GSM/EDGE carriers in the 700 MHz band
D
700_G_Avg BBH Data Traffic Downlink_MB
Number
BBH base to mobile data traffic in MB carried by GSM/EDGE carriers in the 700 MHz band
E
700_G_Avg BBH Data Traffic Uplink_MB
Number
BBH mobile to base data traffic in MB carried by GSM/EDGE carriers in the 700 MHz band
700 MHz Band - WCDMA/HSPA/HSPA+
F
700_H_Avg BBH Voice Traffic_Erlangs
Number
BBH voice traffic in Erlangs carried by UTRA carriers in the 700 MHz band
G
700_H_Avg BBH Data Traffic Downlink_MB
Number
BBH base to mobile data traffic in MB carried by UTRA carriers in the 700 MHz band
H
700_H_Avg BBH Data Traffic Uplink_MB
Number
BBH mobile to base data traffic in MB carried by UTRA carriers in the 700 MHz band
700 MHz Band - LTE
I
700_L_Avg BBH Data Traffic Downlink_MB
Number
BBH base to mobile data traffic in MB carried by LTE carriers in the 700 MHz band
J
700_L_Avg BBH Data Traffic Uplink_MB
Number
BBH mobile to base data traffic in MB carried by LTE carriers in the 700 MHz band

Cellular Band - GSM/GPRS/EDGE

K
Cell_G_Avg BBH Voice Traffic_Erlangs
Number
BBH voice traffic in Erlangs carried by GSM/EDGE carriers in the Cellular band
L
Cell_G_Avg BBH Data Traffic Downlink_MB
Number
BBH base to mobile data traffic in MB carried by GSM/EDGE carriers in the Cellular band
M
Cell_G_Avg BBH Data Traffic Uplink_MB
Number
BBH mobile to base data traffic in MB carried by GSM/EDGE carriers in the Cellular band

Cellular Band - WCDMA/HSPA/HSPA+

N
Cell_H_Avg BBH Voice Traffic_Erlangs
Number
BBH voice traffic in Erlangs carried by UTRA carriers in the Cellular band
O
Cell_H_Avg BBH Data Traffic Downlink_MB
Number
BBH base to mobile data traffic in MB carried by UTRA carriers in the Cellular band
P
Cell_H_Avg BBH Data Traffic Uplink_MB
Number
BBH mobile to base data traffic in MB carried by UTRA carriers in the Cellular band

Cellular Band - LTE

Q
Cell_L_Avg BBH Data Traffic Downlink_MB
Number
BBH base to mobile data traffic in MB carried by LTE carriers in the Cellular band
R
Cell_L_Avg BBH Data Traffic Uplink_MB
Number
BBH mobile to base data traffic in MB carried by LTE carriers in the Cellular band
Traffic Instructions

Column

Variable Name

Format

Possible Entries/Example Entries

Description

PCS Band - GSM/GPRS/EDGE

S
PCS_G_Avg BBH Voice Traffic_Erlangs
Number
BBH voice traffic in Erlangs carried by GSM/EDGE carriers in the PCS band
T
PCS_G_Avg BBH Data Traffic Downlink_MB
Number
BBH base to mobile data traffic in MB carried by GSM/EDGE carriers in the PCS band
U
PCS_G_Avg BBH Data Traffic Uplink_MB
Number
BBH mobile to base data traffic in MB carried by GSM/EDGE carriers in the PCS band

PCS Band - WCDMA/HSPA/HSPA+

V
PCS_H_Avg BBH Voice Traffic_Erlangs
Number
BBH voice traffic in Erlangs carried by UTRA carriers in the PCS band
W
PCS_H_Avg BBH Data Traffic Downlink_MB
Number
BBH base to mobile data traffic in MB carried by UTRA carriers in the PCS band
X
PCS_H_Avg BBH Data Traffic Uplink_MB
Number
BBH mobile to base data traffic in MB carried by UTRA carriers in the PCS band

PCS Band - LTE

Y
PCS_L_Avg BBH Data Traffic Downlink_MB
Number
BBH base to mobile data traffic in MB carried by LTE carriers in the PCS band
Z
PCS_L_Avg BBH Data Traffic Uplink_MB
Number
BBH mobile to base data traffic in MB carried by LTE carriers in the PCS band

AWS Band - GSM/GPRS/EDGE

AA
AWS_G_Avg BBH Voice Traffic_Erlangs
Number
BBH voice traffic in Erlangs carried by GSM/EDGE carriers in the AWS band
AB
AWS_G_Avg BBH Data Traffic Downlink_MB
Number
BBH base to mobile data traffic in MB carried by GSM/EDGE carriers in the AWS band
AC
AWS_G_Avg BBH Data Traffic Uplink_MB
Number
BBH mobile to base data traffic in MB carried by GSM/EDGE carriers in the AWS band

AWS Band - WCDMA/HSPA/HSPA+

AD
AWS_H_Avg BBH Voice Traffic_Erlangs
Number
BBH voice traffic in Erlangs carried by UTRA carriers in the AWS band
AE
AWS_H_Avg BBH Data Traffic Downlink_MB
Number
BBH base to mobile data traffic in MB carried by UTRA carriers in the AWS band
AF
AWS_H_Avg BBH Data Traffic Uplink_MB
Number
BBH mobile to base data traffic in MB carried by UTRA carriers in the AWS band

AWS Band - LTE

AG
AWS_L_Avg BBH Data Traffic Downlink_MB
Number
BBH base to mobile data traffic in MB carried by LTE carriers in the AWS band
AH
AWS_L_Avg BBH Data Traffic Uplink_MB
Number
BBH mobile to base data traffic in MB carried by LTE carriers in the AWS band
Traffic Instructions

AWS_G_Avg

AWS_G_Avg

AWS_H_Avg

AWS_H_Avg

AWS_L_Avg

AWS_L_Avg

700_G_Avg BBH 700_G_Avg BBH 700_G_Avg BBH 700_H_Avg BBH 700_H_Avg BBH 700_H_Avg BBH 700_L_Avg BBH 700_L_Avg BBH Cell_G_Avg BBH Cell_G_Avg BBH Cell_G_Avg BBH Cell_H_Avg BBH Cell_H_Avg BBH Cell_H_Avg BBH Cell_L_Avg BBH Cell_L_Avg BBH PCS_G_Avg BBH PCS_G_Avg BBH PCS_G_Avg BBH PCS_H_Avg BBH PCS_H_Avg BBH PCS_H_Avg BBH PCS_L_Avg BBH PCS_L_Avg BBH

AWS_G_Avg

BBH Data

BBH Data

AWS_H_Avg

BBH Data

BBH Data

BBH Data

BBH Data

Voice

Data Traffic

Data Traffic

Voice

Data Traffic

Data Traffic

Data Traffic

Data Traffic

Voice

Data Traffic

Data Traffic

Voice

Data Traffic

Data Traffic

Data Traffic

Data Traffic

Voice

Data Traffic

Data Traffic

Voice

Data Traffic

Data Traffic

Data Traffic

Data Traffic

BBH Voice

Traffic

Traffic

BBH Voice

Traffic

Traffic

Traffic

Traffic

Date Site ID

Traffic_Erlangs

Downlink_MB

Uplink_MB

Traffic_Erlangs

Downlink_MB

Uplink_MB

Downlink_MB

Uplink_MB

Traffic_Erlangs

Downlink_MB

Uplink_MB

Traffic_Erlangs

Downlink_MB

Uplink_MB

Downlink_MB

Uplink_MB

Traffic_Erlangs

Downlink_MB

Uplink_MB

Traffic_Erlangs

Downlink_MB

Uplink_MB

Downlink_MB

Uplink_MB

Traffic_Erlangs

Downlink_MB

Uplink_MB

Traffic_Erlangs

Downlink_MB

Uplink_MB

Downlink_MB

Uplink_MB

Traffic Template

Definitions


In this Information and Document Request, the following terms shall have the following meanings (such
meanings to be equally applicable to both the singular and plural forms of the terms defined):


1. The terms “Company” or “AT&T” mean AT&T, Inc., its domestic and foreign parents, predecessors,
divisions, subsidiaries, affiliates, partnerships, and joint ventures, and all directors, officers, employees,
agents, and representatives of the foregoing. The terms “parents,” “subsidiary,” “affiliate,” and “joint
venture” refer to any person in which there is partial (10 percent or more) or total ownership or control
between the company and any other person.

2. The term “Leap” means Leap Wireless International, Inc., its parents, predecessors, divisions,
subsidiaries, affiliates, partnerships and joint ventures, and all directors, officers, employees, agents, and
representatives of the foregoing. The terms “parent,” “subsidiary,” “affiliate,” and “joint venture” refer
to any person in which there is partial (10 percent or more) or total ownership or control between the
company and any other person.

3. The terms “and” and “or” have both conjunctive and disjunctive meanings.

4. The word “any” shall be construed to include the word “all,” and the word “all” shall be construed to
include the word “any.” The word “each” shall be construed to include the word “every,” and the word
“every” shall be construed to include the word “each.” All words used in the singular should be
construed to include the plural, and all words used in the plural should be construed to include the
singular.

5. The term “Applicants” means AT&T and Leap, collectively.

6. The term “Application” means the applications submitted by AT&T and Leap on August 1, 2013, with
the lead file number for the wireless radio services listed as 0005860676.

7. The term “BTA” means Basic Trading Area.

8. The term “CDMA” means Code Division Multiple Access technology.

9. The term “CMA” means Cellular Market Area.

10. The term “competitor” includes any actual or potential competition from any partnership, corporation
(including a business trust), joint stock company, trust, unincorporated association, joint venture, limited
liability company, or other entity in any relevant area for any relevant product.

11. The term “discussing” when used to refer to documents means analyzing, constituting, summarizing,
reporting on, considering, recommending, setting forth, or describing a subject. Documents that contain
reports, studies, forecasts, analyses, plans, proposals, evaluations, recommendations, directives,
procedures, policies, or guidelines regarding a subject should be treated as documents that discuss the
subject. However, documents that merely mention or refer to a subject without further elaboration
should not be treated as documents that discuss that subject.

12. The term “documents” means all computer files and written, recorded, and graphic materials of every
kind in the possession, custody, or control of the Company. The term “documents” includes, without
limitation, drafts of documents, copies of documents that are not identical duplicates of the originals,
and copies of documents the originals of which are not in the possession, custody, or control of the


Company. The term “documents” includes, without limitation, materials of every kind in the
possession, custody, or control of the Company whether created internally or externally. In addition, the
term “documents” includes without limitation any amendments, side letters, appendices, or attachments.
The term “computer files” includes without limitation information stored in, or accessible through,
computer or other information retrieval systems. Thus, the Company should produce documents that
exist in machine-readable form, including documents stored in personal computers, portable computers,
workstations, minicomputers, mainframes, servers, backup disks and tapes and archive disks and tapes,
and other forms of offline storage, whether on or off the Company’s premises. Electronic mail
messages should also be provided, even if only available on backup or archive tapes or disks. Computer
files shall be printed and produced in hard copy or produced in machine-readable form (provided that
Commission staff determine prior to submission that it would be in a format that allows the Commission
to use the computer files), together with instruction and all other materials necessary to use or interpret
the data. Unless otherwise specified, the term “documents” excludes bills of lading, invoices, purchase
orders, customs declarations, and other similar documents of a purely transactional nature and also
excludes architectural plans and engineering blueprints. Where more than one identical copy of a
requested document exists, the Company shall only submit one representative copy.

13. The term “EDGE” means Enhanced Data rates for GSM Evolution technology.

14. The term “EvDO” or “EvDO Rev. A” means Evolution-Data Optimized or Evolution–Data Optimized
Revolution A technology.

15. The term “GSM” means Global System for Mobile Communications technology.

16. The term “HSPA” or “HSPA+” means High Speed Packet Access or High Speed Packet Access +
technology.

17. The term “identify,” when used with reference to a document, means to state the date, author, addressee,
type of document (e.g., the types of document, as described above), a brief description of the subject
matter, its present or last known location, and its custodian, who must also be identified.

18. The term “including” shall be construed as including, but not limited to, and indicates examples for the
Applicants to address. The term should not be construed as to limit the response to only those examples
listed.

19. The term “LTE” means Long Term Evolution technology.

20. The term “mobile wireless application,” also referred to as “application software” or “app,” means a
computer system that enables one or more function on a mobile wireless device running a mobile
operating system (e.g., Android, iOS).

21. The term “mobile wireless telephone number,” means the 10-digit telephone number assigned to an end-
user to access mobile wireless services.

22. The term “mobile wireless data services” means any data communications service using radio
transmission between mobile or fixed stations and a network providing communication of packet data
information, including but not limited to, broadband data, video, remote file access, status reporting,
facsimile, and internet/intranet access. Mobile wireless data services include non-interconnected Voice
over IP but exclude mobile wireless voice and text services, as defined herein.


2



23. The term “mobile wireless services” includes mobile wireless voice services, mobile wireless text
services, mobile wireless data services, and mobile wireless applications.

24. The term “mobile wireless text services” means any communications service using radio transmission
between mobile or fixed stations and a network providing communication of numeric or alphanumeric
messages, such as multi-media messaging, short messaging, and short codes. Mobile wireless text
services exclude e-mails.

25. The term “mobile wireless voice services” means interconnected voice communications services
provided using radio transmission between mobile or fixed stations on a wireless basis to customers,
other than fixed wireless services. Mobile wireless voice services include interconnected Voice over IP.

26. The term “MTA” means Major Trading Area.

27. The term “Person” includes the Company, and means any individual, partnership, corporation
(including a business trust), joint stock company, trust, unincorporated association, joint venture, limited
liability company or other entity, or a government or any political subdivision or agency thereof.

28. The term “plans” means tentative and preliminary proposals, recommendations, or considerations,
whether or not finalized or authorized, as well as those that have been adopted.

29. The term “plans, analyses, and reports” means business plans, strategic plans, written policies, budgets,
analyses, reports, presentations (including quantitative presentations), and similar documents, including
all appendices and attachments thereto, (a) prepared for, presented to, reviewed by, discussed by, or
considered by the Company’s board of directors or the Company’s executive management, or any
member thereof, and (b) in the files of any person whose files are to be reviewed and searched to locate
documents responsive to this Information Request, even if the plan, analysis and report has not been
reviewed by, discussed by, or considered by the Company’s board of directors or the Company’s
executive management, or any member thereof. The term “plans, analyses and reports” includes
without limitation copies of plans, analyses and reports that are not identical duplicates of the originals,
and copies of plans, analyses and reports, the originals of which are not in the possession, custody, or
control of the Company, but does not include drafts of plans, analyses and reports, but only the final
version or the latest draft if the final version does not exist or is not in the possession, custody, or
control of the Company.

30. The term “POPs” means total aggregate population.

31. The term “Proposed Transaction” means the proposed acquisition of Leap by AT&T filed on August 1,
2013, with the lead application file number for the wireless radio services listed as 0005860676.

32. The term “Public Interest Statement” refers to the document filed by the Applicants on August 1, 2013
entitled “Description of Transaction, Public Interest Showing, and Related Demonstrations.”

33. The term “relevant area” means a) each CMA, and b) the United States as a whole (including Puerto
Rico), and information must be provided separately for, each CMA.

34. The term “relevant product” means (and information must be provided separately for, any of the mobile
wireless services and using any of the following formats: GSM, EDGE, CDMA, EV-DO, EV-DO Rev.
A, UMTS only, HSPA, HSPA+, and LTE):
1) feature mobile devices: wireless handset devices that are cable of supporting voice services as
well as text services;

3



2) smartphones: wireless handset devices other than iPhones, with advanced computing capability
and connectivity sufficient to run complete mobile operating system software (e.g., Android,
Research in Motion Ltd. Blackberry, Windows phone) to support all mobile wireless services,
including broadband data and video applications as well as voice, photographic cinematic, and
audio-visual media player services (including books, periodicals, movies, music, games);
3) iPhones: smartphones designed and marketed by Apple Inc.;
4) tablet PCs (includes netbook PCs): portable devices (other than iPads) with touch screen and/or
a QWERTY keyboard input, and advanced computing capability and connectivity sufficient to
run complete operating system software (e.g., Android, Windows) to support broadband data
and video applications as well as photographic, cinematic, and audio-visual media player
services (including books, periodicals, movies, music, games);
5) iPads: tablet PCs designed by Apple Inc.;
6) e-readers: portable personal computing devices with a display size of 6" to 10" typically, with
advanced computing capability and connectivity sufficient to enable users to shop for, purchase,
download, and display text, designed primarily for the purpose of reading books, newspapers,
and periodicals;
7) “air cards” (also referred to as “laptop cards”): portable wireless modems that enable personal
computing devices to connect to a mobile wireless network in order to support and deliver
voice, data, and video services;
8) mobile hotspot devices: network routing devices that enable portable, Wi-Fi enabled handset
and personal computing devices to connect to a mobile wireless network in order to support and
deliver voice, data, and video services; and
9) other mobile wireless devices not listed above. Describe the other devices included in this
category.

35. The term “relevant service” means (and information must be provided separately for, (a) any of the
services identified below and using any of the following formats: GSM, EDGE, CDMA, EV-DO, EV-
DO Rev. A, UMTS only, HSPA, HSPA+, and LTE), and (b) post-paid and pre-paid mobile wireless
services:
1) mobile wireless voice services;
2) mobile wireless text services;
3) mobile wireless data services; and
4) mobile wireless applications.

36. The term “sales” means net sales in units or dollars, i.e., total sales after deducting discounts, returns,
allowances, and excise taxes. “Sales” includes sales of the relevant service or product whether provided
or manufactured by the company itself or purchased from sources outside the company and resold by
the company in the same form as purchased.

37. The term “subsidiary” as to any Person means any corporation, partnership, joint venture, limited
liability company, or other entity of which shares of stock or other ownership interests having ordinary
voting power to elect a majority of the board of directors or other managers of such corporation,
partnership, joint venture, limited liability company or other entity are at the time owned, or the
management of which is otherwise controlled, directly or indirectly, through one or more intermediaries,
or both, by such Person.

38. The term “UMTS” means Universal Mobile Telecommunications System technology.

39. “United States” or “U.S.” means the United States, its possessions, territories, and outlying areas.


4



Instructions



1. Unless otherwise specified, all Information and Document Requests cover the period from January 1,
2011 through the date of the Request.

2. Corporations and other entities, including affiliated or subsidiary entities, shall be identified by the
Central Index Key (“CIK”) assigned by the Securities and Exchange Commission (“SEC”). A unique
identifier should be used for each entity that has not been assigned a CIK by the SEC.

3. Submit responses to Information Requests in both paper and electronic form, unless an electronic form
is specified (e.g., electronic spreadsheet). Submit responses to Document Requests (including materials
containing Highly Confidential or Confidential Information) in electronic form only in a manner that is
fully compatible with the Commission’s Summation Enterprise software database, as set forth in the
Instructions for Submission of Electronic Documents. The Commission does not require the submission
of paper copies of these documents at this time, but reserves the right to require their submission at a
later time.

4. Each requested document shall be submitted in its entirety, even if only a portion of that document is
responsive to a request made herein. This means that the document shall not be edited, cut, or
expunged, and shall include all appendices, tables, or other attachments, and all other documents
referred to in the document or attachments. All written materials necessary to understand any document
responsive to these requests shall also be submitted. Provide final versions of each document; however,
if a final version does not exist, provide one copy of the latest draft of the document.

5. Those documents written in a language other than English must be translated into English; automated or
machine translations are not permitted. Submit the foreign language document, with the English
translation attached thereto.

6. Unless otherwise specified, provide data and interrogatory responses separately for prepaid, post-paid,
wholesale, and all mobile wireless services. The Company should provide a separate response for
interrogatory, data, and documents (i.e., please do not submit the Company’s interrogatory and data
responses on the same discs).

7. Data provided in response to this Request should include a list of all parameters/assumptions on which
the data are based.

8. Unless otherwise agreed to by the Commission, requests for the production of documents (and any
particular type of document) require the production of all responsive documents in the possession,
custody, or control of the Company.

9. For each document or statement submitted in response to the requests, indicate, by number and
subsection, the request to which it is responsive and, for documents, identify the Person(s) from whose
files the document was retrieved (i.e., custodian). Group submitted materials according to the request
number to which they are responsive and then, within each of those request-number groupings, by the
appropriate custodian. If a document is responsive to more than one request, submit the document in
response to the first request to which it is responsive, and, in accordance with the Instructions for
Submission of Electronic Documents below, indicate in the metadata accompanying the document’s
electronic record all subsequent requests to which it also is responsive. If any document is not dated, if
known, state the date on which it was prepared. If any document does not identify its author(s) or
recipient(s), provide, if known, the name(s) of the author(s) or recipient(s) as metadata in accordance

5



with Instructions for Submission of Electronic Documents. The Company must identify with reasonable
specificity all documents provided in response to these requests. Where more than one identical copy of
a requested document exists, the Company may submit only one representative copy, but in all cases all
metadata, including without limitation all custodians who possessed identical documents withheld, must
be provided in accordance with the provisions of Instructions for Submission of Electronic Documents.

10. If search terms were used to conduct all or any part of a search conducted in response to this
Information Request, provide a list of search terms used, along with a glossary of industry and company
terminology. In addition, describe the search methodologies and the applications used to execute the
search.

11. The specific requests made herein are continuing in nature. The Company is required to produce in the
future any and all documents and information that are responsive to the requests made herein but not
initially produced at the time, date, and place specified herein. In this regard, the Company must
supplement its responses (a) if the Company learns that, in some material respect, the documents and
information initially disclosed were incomplete or incorrect or (b) if additional responsive documents or
information are acquired by or become known to the Company after the initial production.

12. Any documents that are withheld in whole or in part from production based on a claim of privilege shall
be assigned document control numbers (with unique consecutive numbers for each page of each
document). For any page of any Document that the Company has designated to be withheld as entirely
privileged, the Company shall submit a substitute, placeholder page that lists only the Document ID of
the page that was withheld in entirety as privileged and a statement indicating that the page has been
withheld in entirety as privileged. For any document withheld as entirely privileged, it is sufficient to
supply one substitute, placeholder page for that document, so long as the range of Document IDs for the
entire document is listed on the placeholder page and each Document ID for each page of the document
is reflected in metadata. The placeholder pages must be OCR’d as any other paper record, as described
above. For each document withheld as privileged, whether in entirety or in part, the Company shall
code the substitute document submitted as specified in and provide as metadata the information in the
attached MetaData Table of Requested Fields.

13. For each Document identified on the Company privilege log:

1) Provide the document control number(s);
2) Identify all authors of the document;
3) Identify all addressees of the document;
4) Identify all recipients of the document or of any copies of the document, to the extent not
included among the document’s addressees;
5) Provide the date of the document;
6) Provide a description of the subject matter of the document;
7) State the nature or type of the privilege that the Company is asserting for the document (e.g.,
“attorney-client privilege”);
8) Provide the number(s) of the Request to which the document is responsive;
9) Provide the document control number(s) of any attachments to the document, regardless of
whether any privilege is being asserted for such attachment(s); and
10) State whether the document has been produced in redacted form, and include the range of
Document ID labels for those produced documents.


6



14. The Company’s privilege log shall also conform with all of the following requirements:

1) Provide a separate legend identifying each author, addressee, and recipient identified on the
Company’s privilege log.
2) Identify on the privilege log, and denote with an asterisk, all attorneys acting in a legal capacity
with respect to the withheld document or communication.
3) The description of the subject matter of each document shall describe the nature of the
document in a manner that, though not revealing information that is itself privileged, provides
sufficiently detailed information to enable the Commission to assess the applicability of the
privilege claimed.
4) For each document withheld under a claim that it constitutes or contains attorney work product,
also state whether the Company asserts that the document was prepared in anticipation of
litigation or for trial and, if so, specify the anticipated litigation or trial upon which the assertion
is based.
5) Produce all nonprivileged portions of any responsive document (including nonprivileged or
redactable attachments) for which a claim of privilege is asserted, except where the only
nonprivileged information in the document has already been produced. Note where any
redactions in the document have been made.
6) The privilege log shall be produced in both hardcopy and electronic form, the electronic form of
which shall be both searchable and sortable.
7) Documents sent solely between counsel, including in-house counsel acting solely in a legal
capacity, and documents authored by the Company’s outside counsel that were not directly or
indirectly furnished to any third party, such as internal law firm memoranda, may be omitted
from the privilege log. However, any attachments to such documents must be included on the
privilege log (if a privilege is applicable to such materials), unless such attachments are
addressed and sent solely to counsel.

7



Instructions for Submission of Electronic Documents


A. Form of Production


1.
Electronic documents shall be produced in Summation Enterprise load files as images and/or
native format files with extracted text and related metadata and bibliographic information. A list of metadata
fields that must be populated, as relevant, is attached. Specific requirements for different types of documents
are discussed below. Please contact Commission staff for further technical specifications, including the image
and text file specifications and the load file configuration, and for a sample load file set.

2.
Each Summation submission must be on a physical media, either a portable hard drive or DVD-
ROM.

3.
Each physical media provided must have a label affixed. The label shall state: (a) the name of
the party submitting the data, (b) the date of the submission, (c) the volume number of production (see below),
and (d) the range of documents contained on the media.

4.
Each Summation submission must have a volume number associated with it. On the root of the
media, the top-level folder must be named for the volume. This volume number should also be indicated on the
physical label of the media. The volume naming scheme should start with a 2 or 3 letter prefix (identifying your
company) followed by a 3-digit counter (e.g., ABC001). Load file volumes may not contain more than 25,000
records each (but multiple file volumes may be included on one hard drive).

5.
Under the volume folder, the production should be organized in 3 subfolders:

a)
IMAGES (may contain subfolders, with no more than 5,000 image files per folder) and
FULLTEXT (may contain subfolders, with document-level text files). No file may be more than 25
megabytes.

b)
DOCLINK (documents in native format, including all spreadsheets and presentations)

c)
LOADFILES (the metadata, EDII, and LST information should be contained in one
file, and the custodian append information in a separate file)

6.
Each submission shall be accompanied by an spreadsheet (production index), in hard copy and
electronic form, detailing what has been produced, by custodian and document identification number, and
containing statistical information about each volume.

7.
If a password is used, the same password must be used for all submissions. If encryption is
used, only Truecrypt software may be used.

8.
To minimize any delay in loading your submissions, each submission shall be as large as
practical under these specifications, while also maintaining a timely and rolling production.

9.
Subsequent submissions shall not include information produced in previous submissions, unless
specifically requested by the Commission. However, if an error occurs in loading, the entire load must be
resubmitted, maintaining the original volume number(s). For example, if a hard drive contains volumes
ABC005 – ABC 009, and there is an error with volume ABC006, ABC006 must be corrected and the entire
submission ABC005 – ABC009 must be resubmitted on a new hard drive.


8



B. Document Types



1.
Hard-copy (or paper) documents.

(a)
Except as otherwise agreed, hard-copy documents shall be produced as image files with
related searchable OCR text and bibliographic information.

(b)
Some documents may more appropriately and efficiently be produced in hard-copy form
(e.g., maps).

(c)
Special care should be taken to properly unitize documents, maintain attachment
relationships, and indicate file folder or binder labels, consistent with the Definitions and Instructions.

2.
E-mail and Other Electronic Messages.

(a)
E-mail and other electronic messages (e.g., instant messages (“IMs”)) shall be produced
as image files with related searchable text and metadata and bibliographic information.

(b)
Each IM conversation shall be produced as one document.

(c)
E-mail metadata shall include the folderpath (“folder” field) information for e-mail file
folders into which a custodian’s e-mail messages have been organized. Be sure to preserve and produce
this information as specified. Beware of copying e-mails into an electronic repository or forwarding
them to a central e-mail box, as such processes may destroy this information. See also infra Section
C(2) regarding custodian metadata.

(d)
Depending on how the Company’s systems represent names in e-mail messages or IMs,
the Commission may require a table of names or contact lists.

3.
Spreadsheets shall be produced in native format (e.g., .XLS files) with the first page imaged and
with related searchable text and metadata and bibliographic information.

4.
Presentations.

(a)
Presentations shall be produced as images that show the full slide images and speaker
notes, with related searchable text and metadata and bibliographic information.

(b)
Presentations shall also be produced in native format (e.g., .PPT files).

5.
Word processing and other electronic documents not specifically addressed elsewhere in this
letter shall be produced as image files with related searchable text and metadata and bibliographic information.

6.
Databases.


(a)
This letter does not address enterprise databases which may be responsive to the
Information and Document Requests and should be the subject of a separate discussion once you have
identified them.

(b)
Smaller databases (e.g., Microsoft Access) that are responsive should be produced, but
not as part of the load-file production. Such databases should be produced separately.


9



7.
Company Intranets and Social Networking Sites.

(a)
If the Company’s intranet or company social networking content (e.g., Facebook, Twitter)
contains responsive information, production of these items should be the subject of a separate
discussion.

(b)
Depending on the nature of the information, it may be appropriate to provide the
Commission direct access to the Company’s intranet via a secure Internet connection, but significant
technical issues are often involved.

8.
Embedded files with no substantive content (e.g., corporate logos, executive
“head-shot” photographs, stationery address blocks), which would appear in the production as an otherwise
blank and therefore unresponsive “TIFF” image, should not be produced.


C. General Issues



1.
Attachments and their parent documents are a “family” of documents. Families of documents
(e.g., a cover e-mail with multiple attachments) must all be produced in full. If one member of the family is
responsive, the entire family is considered responsive, and individual documents in the family cannot be
withheld on grounds of being “non-responsive.”

2.
The required metadata for each electronic document includes “custodian” information
(typically, the name of the human person from whose files the document was gathered) and “filepath”
information for directory/server folders into which a custodian’s documents have been organized. Ensure that
this information is collected when collecting responsive documents. If the Company stores documents in a
repository that does not maintain personal custodian or filepath information (e.g., that “journals” e-mails), it
shall be required to stipulate to custodian identities for purposes of using documents.

3.
In certain circumstances, a custodian may be a shared resource (e.g., shared drive or server,
shared filing cabinet). Materials gathered from such repositories, to which multiple people have access, shall be
produced as separate custodians. The Company shall provide a brief description of each shared resource that
includes a list of the employees who have access to that shared resource. The documents in shared resources
should otherwise be produced as described in the rest of this letter. (Personal share or server drives are not
shared resources and shall be produced as part of each human custodian’s files.)

4.
Native Format Files

(a)
If any native files will be produced that cannot be viewed using the standard configuration
of Microsoft Office 2007, Adobe Acrobat Reader 9, WordPerfect X4, or Internet Explorer 7, you will
need to notify the Commission so it can determine whether it has the appropriate software and licenses
to view those files. If it does not, it may be necessary for the Company to provide that software.

(b)
Any encryption or password protection shall be removed from all native format files
produced.

5.
Images and Text Files

(a)
Images of the produced electronic documents shall conform with any further
specifications provided by the Commission.


10



(b)
Searchable OCR and extracted text from the produced electronic documents shall
conform with any further specifications provided by the Commission.

(c)
Care should be taken to ensure that the text files will properly format and wrap.

(d)
If any document cannot be interpreted in image/text format (e.g., color, Microsoft
Project), the Commission may request that it be produced natively, or the Company can contact the
Commission to discuss producing them natively. As noted above in C(4)(a), the Company may need to
provide the appropriate software in order for the Commission to view these documents.

6.
Deduplication

(a)
The Company shall deduplicate vertically within each custodian’s files.

(b)
The Commission prefers that the Company also deduplicate horizontally across all
custodians’ files, but only if:

(i)
the deduplication methodology preserves information on BCC recipients of e-
mail;

(ii)
custodian information from suppressed duplicates can be preserved and produced
as a custodian append file; and

(iii) the Company, prior to beginning its production, provides a written description its
deduplication methodology, including how custodial and BCC information shall be preserved
and produced, to which the Commission agrees.

(c)
The Company must produce all members of a family of documents (see C(1)) and cannot
suppress attachments to other documents. In other words, the integrity of families of documents must
be maintained, except as limited by any claim of privilege. For example, and in particular, the
deduplication process may not remove attachments to e-mails that are being produced because the
attachment is produced elsewhere. Improper dedeuplication may require the resubmission of a
production set.

(d)
The Company agrees not to raise any objections to the Commission’s use of the produced
duplicate in relation to whether it was in the files of the custodians who had the suppressed duplicates in
their files or were the sender or recipients of any e-mail.

7.
Privilege Designations

(a)
Documents redacted pursuant to any claim of privilege shall be designated “Redacted” in
the Properties field in the metadata and bibliographic information provided. The Company shall
provide appropriately redacted related searchable text, metadata, and bibliographic information for these
documents.

(b)
Documents withheld pursuant to any claim of privilege that are part of a document family
shall include a designation of “Family Member of Priv Doc” in the Properties field in the metadata and
bibliographic information provided for all the other documents in its family. A placeholder image with
a document identification number should be provided in place of the document.


11



(c)
Both redacted and withheld documents shall appear on the privilege log. Each withheld
document from a family shall include the family document identification number range in its entry on
the privilege log.

8.
Document Identification Numbering

(a)
A consistent format for document identification numbering shall be used across the entire
production. Document identification numbers should contain no more than three segments – e.g., a
company identifier, a middle segment (e.g., custodian identifier), and a sequence of 6-8 digits (the
number of digits should be consistent across the entire production).

(b)
Document identification numbers should not contain embedded spaces (“ ”), slashes (“/”),
backslashes (“\”), or underscores (“_”). Document identification numbers may contain hyphens (“-”).

(c)
Native format files should be assigned a document identification number; if images have
been produced with a native format file, the beginning document identification number of the images
should be the native format file’s document identification number.

9.
These instructions do not address or endorse any search method the Company may use to
identify responsive electronic documents.

10.
In order to ensure the Company’s full technical and procedural compliance with these
instructions, the Company shall make its Information Technology personnel and those of its vendors available to
Commission staff for consultation and coordination before, during, and after its production of materials
responsive to the requests.


D. Sample Submission Required Prior to Full Production



In consultation with Commission staff, the Company shall submit a test submission to ensure proper
configuration of data for uploading into the Commission’s Summation Enterprise database server before the
Company “ramps up” production. To minimize the likelihood of encountering problems during full production,
the sample must be representative of an actual production, including multiple types of documents, documents
with attachments (“families”), document families from which an item has been removed pursuant to privilege
(and replaced with a document identification -numbered, placeholder image), redacted documents with
appropriately related searchable text, and presentation documents with speaker notes.

12





FIELD LISTING FOR SUMMATION METADATA

TYPE OF RECORD(S) TO WHICH EACH

LOAD FILE

FIELD APPLIES

Other E-
Docs (all

Spreadsheet

Attachment

Hard E-

s and
s, Calendar

Field

Field

Cop

Mai

Presentation

Appts,

Field Name

Description

Type

y
l
s

Loose Files

Production
Note Text
volume number

SUBMISSION#

(e.g., ABC001)
x
x
x
x
Request(s) to
Multi-
which the
Entry
document is

REQUEST#

responsive
x
x
x
x
Start Bates
Note Text
(including prefix)
-- do not use
commas,
underscores,
ampersands,
slashes, spaces,
characters not
allowed in
Windows file
names or any
character used
as a delimiter in
the load files as
part of this

BEGDOC#

number
x
x
x
x
End Bates
Note Text
(including prefix)
-- do not use
commas,
underscores,
ampersands,
slashes, spaces,
characters not
allowed in
Windows file
names, or any
character used
as a delimiter in
the load file as
part of this

ENDDOC#

number
x
x
x
x

EPROPERTIES

Indicate All That
Multi-
x
x
x
x

13


Apply :
Entry
Record Type:
Loose File, E-
mail, Attachment,
Hard Copy,
Calendar Appt
Privilege
Notations:
Redacted,
Privileged,
Family Member
of Priv Doc

PRIV

Privileged (Y/N)
Note Text
x
x
x
x

PO1

Subject to First
Note Text
Protective Order
(Y/N)
x
x
x
x

PO2

Subject to
Note Text
Second
Protective Order
(Y/N)
x
x
x
x

DATEAPPTSTA

Start date of
Date

RT

calendar
appointment -
YYYYMMDD



x

TIMEAPPTSTAR

Start time of
Time

T

calendar
appointment -
HH:MM am/pm



x

DATEAPPTEND

End date of
Date
calendar
appointment -
YYYYMMDD



x

TIMEAPPTEND

End time of
Time
calendar
appointment --
HH:MM am/pm



x

FILESIZE

File size (numeric Integer
value only - do
not include unit of
measure)

x
x
x

FILEEXTENSION

File extension of
Fixed
native electronic
Length 5
file
chars

x
x
x

FILEPATH

File path to
Note Text
native file as it
existed in original
environment

x
x
x

HASHMD5

MD5 hash value
Note Text
(used for
deduplication or

x
x
x

14


other processing)

HASHSHA

SHA1 hash value Note Text
(used for
deduplication or
other processing)

x
x
x

SEARCHVALUE

List of search
Multi-

S

terms used to
Entry
identify record as
responsive (if
used)
x
x
x
x

COMPANIES

Company
Multi-
submitting data
Entry
x
x
x
x

CUSTODIAN

Custodian(s) /
Multi-
source(s) --
Entry
format: Last, First
or ABC Dept
x
x
x
x

DOCID

Must equal the
Note Text
value appearing
in the BEGDOC#
field
x
x
x
x

NUMPAGES

Page count
Integer
x
x
x
x
Parent record's
BEGDOC#,
including prefix
(populated ONLY

PARENTID

in child records)
Note Text
x
x
x
x
Child document
list: BEGDOC# of
each child

ATTACHMENTID

(populated ONLY Multi-

S

in parent records) Entry
x
x
x
x
BEGDOC# value
of the parent
record and
ENDDOC# value
(including prefix)
of the last child
record (for
example, ABC-
001 - ABC-020);
populated for all
documents in the
group -
otherwise,

BATESRANGE

remains empty
Note Text
x
x
x
x
Author of the e-
mail or loose
electronic file (as

FROM

formatted on the
Note Text

x
x
x

15


original)
Recipients of the
e-mail (as
formatted on the
Multi-

TO

original)
Entry

x


Names of the
individuals who
were copied on
the e-mail (as
formatted on the
Multi-

CC

original)
Entry

x


Names of the
individuals who
were blind-copied
on the e-mail (as
formatted on the
Multi-

BCC

original)
Entry

x


E-mail or
calendar subject,
or electronic file's

SUBJECT

document title
Note Text
x
x
x
Date the e-mail
was sent -

DATESENT

YYYYMMDD
Date

x


Time e-mail was
sent -- HH:MM
am/pm (e.g.,
09:32 am;
Timezone
indicators cannot

TIMESENT

be included)
Time

x


Date e-mail was
received -

DATERECEIVED

YYYYMMDD
Date

x


Time e-mail was
received --

TIMERECEIVED

HH:MM am/pm
Time

x


The internet
header
information for e-
mail sent through

HEADER

the internet;
Note Text
x


Internet message

INTERNETMSGI

identification

D

number
Note Text
x


Unique system
identification

MESSAGEID

number for the e-
Note Text
x



16


mail message
Date electronic
file was created -

DATECREATED

YYYYMMDD
Date


x
x
Date electronic
file was last
modified -

DATESAVED

YYYYMMDD
Date


x
x
Populate with:
DATESAVED for
electronic files
(loose files and
e-mail
attachments) ;
DATESENT for
e-mails; or
DATEAPPTSTA
RT for calendar
appointments -

DOCDATE

YYYYMMDD
Date
x
x
x
x
File name of an
e-mail, e-mail
attachment, or
loose electronic

ATTACHTITLE

document
Note Text
x
x
x
Application used
to create native
file (e.g., Excel,

APPLICATION

Outlook, Word)
Note Text

x
x
x
Current file path
location to the
native file (on the

DOCLINK

delivery medium)
Note Text

x

E-mail folder path
(sample:
Inbox\Active); or
Hard Copy
folder/binder

FOLDER

title/label
Note Text
x
x
















17

Document Outline

  • ATT-Leap Information Request for ATT 11 8 13 FINAL
  • ATT-Leap Data Request 11_8_2013 AT&T
  • ATT-Leap Definitions ATT 11 8 FINAL

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