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Third Party Information Request to Verizon Wireless

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Released: December 21, 2012
Federal Communications Commission
Washington, D.C. 20554
December 21, 2012
Via e-mail
Tamara L. Preiss
Verizon
1300 I Street, NW
Suite 400 West
Washington, DC 20005
Re:
Request for Information Concerning Applications of GCI Communication Corp. and
ACS License Sub Inc., ACS of Anchorage License Sub, Inc., and UNICOM, Inc.,
Assignment of Licenses to The Alaska Wireless Network, LLC (WT Docket 12-187)
Dear Ms. Preiss:
On June 18, 2012, GCI Communication Corp. (“GCI”), its wholly-owned subsidiary Unicom,
Inc., and ACS Wireless License Sub, Inc. and ACS of Anchorage License Sub, Inc. (together, the
“Applicants”), filed four separate applications pursuant to Section 310(d) of the Communications Act of
1934, as amended (the “Act”),1 seeking consent to assign spectrum licenses to a newly formed wholly-
owned subsidiary of GCI Wireless Holdings, LLC,2 The Alaska Wireless Network, LLC (“AWN”). In
order for the Commission to complete its review of the applications and make the necessary public
interest findings under the Act, we require written responses and supporting documentation, as applicable,
for each request set forth in the Attachments from Verizon Wireless, as an entity against which the
Applicants may compete.
Accordingly, pursuant to sections 4(i), 4(j), and 403 of the Act,3 we request that you provide
written responses as set forth in the Attachments. Each response or document should clearly indicate the
specific question or request to which it responds, and each page should be marked with a corporate
identification and consecutive document control numbers as specified in the attached instructions. Your
response will be treated as Highly Confidential pursuant to the Protective Orders issued in WT Docket
No. 12-187.4 We would appreciate receiving your response no later than January 11, 2013.
Sincerely,
Ruth Milkman, Chief
Wireless Telecommunications Bureau


1 47 U.S.C. § 310(d).
2 GCI Wireless Holdings, LLC is a wholly-owned subsidiary of GCI.
3 47 U.S.C. §§ 154(i), 154(j), 403. See generally FCC v. Schreiber, 381 U.S. 279 (1965).
4 Applications of GCI Communication Corp., ACS Wireless License Sub, Inc., ACS of Anchorage License Sub,
Inc., and Unicom, Inc. For Consent To Assign Licenses to The Alaska Wireless Network, LLC, WT Docket No. 12-
187, Protective Order, DA 12-1061 (rel. July 3, 2012); Applications of GCI Communication Corp., ACS Wireless
License Sub, Inc., ACS of Anchorage License Sub, Inc., and Unicom, Inc. For Consent To Assign Licenses to The
Alaska Wireless Network, LLC, WT Docket No. 12-187, Second Protective Order, DA 12-1060 (rel. July 3, 2012).

WT Docket Number 12-187

INFORMATION AND DISCOVERY REQUEST FOR

Verizon Wireless

1. Describe in detail whether the Company offers or has any plans to offer any Relevant Wireless
Product or Relevant Wireless Service in the Relevant Area. If the Company has entered or plans
to enter the Relevant Area, provide a timeline detailing the timing and location, by census area
and type of Relevant Wireless Product or Relevant Wireless Service offered or to be offered, of
the Company’s entry into the Relevant Area. Provide documents/marketing plans/projections/
technology plans/presentations sufficient to demonstrate in as much detail as exists the
Company’s current or planned entry, or its decision not to enter into the Relevant Area.
2. Describe whether the Company has attempted to negotiate, is currently negotiating, has plans to
negotiate, or has obtained a roaming agreement from any mobile wireless service provider for any
Relevant Wireless Service in the Relevant Area. Submit one complete copy of each agreement
and any attachments, exhibits or amendments thereto, whether formal or informal, or letter of
understanding and all documents relating to negotiation of any agreement. Explain and provide
documents sufficient to demonstrate whether the Company’s entry into the Relevant Area is
impacted in any way by voice or data roaming.

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 “Verizon” means Cellco Partnership d/b/a Verizon Wireless, 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.
2. The terms “and” and “or” have both conjunctive and disjunctive meanings.
3. 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.
4. 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.
5. 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.
6. 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.

7. The term “relating to” means in whole or in part constituting, containing, concerning, discussing,
describing, analyzing, identifying, or stating.
8. The term “Relevant Area” means, and information must be provided separately for, each Cellular
Market Area in the state of Alaska, and the State of Alaska as a whole.
9. The term “Relevant Wireless Product” means, and information must be provided separately for,
any of the mobile wireless services and using any of the following formats: CDMA, EV-DO,
EV-DO Rev. A, LTE, GSM, EDGE, UMTS only, HSPA, and HSPA+:
1) feature mobile devices: wireless handset devices that are cable of supporting voice
services as well as text services;
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 hotspots 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.
10. The term “Relevant Wireless Service means, and information must be provided separately for,
any of the services identified below and using any of the following formats: CDMA, EVDO,
EVDO Rev. A, LTE, GSM, EDGE, UMTS only, HSPA, and HSPA+:
1) mobile wireless voice services;
2) mobile wireless text services;
3) mobile wireless data services;
4) mobile wireless applications; and
5) fixed wireless services.
2

Instructions

1. Unless otherwise specified, all Information and Document Requests cover the period from
January 1, 2010 through the present.
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. 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.
6. For each document or statement submitted in response to the requests, indicate by number the
request to which it is responsive and, for documents, identify the Person(s) from whose files the
document was retrieved (i.e., custodian). 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 with Instructions
for Submission of Electronic Documents.
7. 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.

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 a 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.

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

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. 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

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.
(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. 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.
7. 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.
4

D.

Sample Submission Prior to Full Production
In consultation with Commission staff, the Company may 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.
5

FIELD LISTING FOR SUMMATION METADATA LOAD FILE

TYPE OF RECORD(S) TO WHICH EACH FIELD APPLIES

Spreadsheets and

Other E-Docs (all Attachments, Calendar

Field Name

Field Description

Field Type

Hard Copy

E-Mail

Presentations

Appts, Loose Files

Production volume number (e.g.,
Note Text
ABC001)

SUBMISSION#

x
x
x
x
Request(s) to which the document is
Multi-Entry
responsive

REQUEST#

x
x
x
x
Start Bates (including prefix) -- do not
Note Text
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 number

BEGDOC#

x
x
x
x
End Bates (including prefix) -- do not
Note Text
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 number

ENDDOC#

x
x
x
x

EPROPERTIES

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

PRIV

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

PO1

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

PO2

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

DATEAPPTSTART

Start date of calendar appointment -
Date
YYYYMMDD
x

TIMEAPPTSTART

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

DATEAPPTEND

End date of calendar appointment -
Date
YYYYMMDD
x

TIMEAPPTEND

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

FILESIZE

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

FILEEXTENSION

File extension of native electronic file
Fixed Length 5
chars
x
x
x

FILEPATH

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

HASHMD5

MD5 hash value (used for
Note Text
deduplication or other processing)
x
x
x

HASHSHA

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

SEARCHVALUES

List of search terms used to identify
Multi-Entry
record as responsive (if used)
x
x
x
x

COMPANIES

Company submitting data
Multi-Entry
x
x
x
x

CUSTODIAN

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

DOCID

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

NUMPAGES

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

PARENTID

records)
Note Text
x
x
x
x
Child document list: BEGDOC# of
each child (populated ONLY in parent

ATTACHMENTIDS

records)
Multi-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

BATESRANGE

group - otherwise, remains empty
Note Text
x
x
x
x
Author of the e-mail or loose
electronic file (as formatted on the

FROM

original)
Note Text
x
x
x
Recipients of the e-mail (as formatted

TO

on the original)
Multi-Entry
x
2

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

CC

the original)
Multi-Entry
x
Names of the individuals who were
blind-copied on the e-mail (as

BCC

formatted on the original)
Multi-Entry
x
E-mail or calendar subject, or

SUBJECT

electronic file's 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

TIMESENT

indicators cannot be included)
Time
x
Date e-mail was received -

DATERECEIVED

YYYYMMDD
Date
x
Time e-mail was received -- HH:MM

TIMERECEIVED

am/pm
Time
x
The internet header information for e-

HEADER

mail sent through the internet;
Note Text
x
Internet message identification

INTERNETMSGID

number
Note Text
x
Unique system identification number

MESSAGEID

for the e-mail message
Note Text
x
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 DATEAPPTSTART for

DOCDATE

calendar appointments - 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

APPLICATION

(e.g., Excel, Outlook, Word)
Note Text
x
x
x
Current file path location to the native

DOCLINK

file (on the delivery medium)
Note Text
x
3

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

FOLDER

folder/binder title/label
Note Text
x
x
4

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