Federal Communications Commission DA 10-682 
Before the 
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Verizon Telephone Companies and
Verizon Services Corp.,
Complainants,
v. 
Madison Square Garden, L.P. and
Cablevision Systems Corp.,
Defendants.
Program Access Complaint
)
)
)
)
)
)
)
)
)
)
)
)
)
File No. CSR-8185-P
ORDER
Adopted:  April 22, 2010 Released:  April 22, 2010
By the Chief, Media Bureau:
I. INTRODUCTION
1. On March 15, 2010, Madison Square Garden, L.P. and Cablevision Systems Corp. 
(collectively “Defendants”) filed a motion requesting that the Commission enter a protective order in the 
above-captioned proceeding.1 On April 14, 2010, Defendants submitted a slightly revised version of the 
protective order, which Defendants state was agreed upon by Verizon Telephone Companies and Verizon 
Services Corp. (collectively “Verizon”) and Defendants.2 For the reasons set forth below, we adopt the 
protective order, provided in Appendix A to this order, to ensure that certain highly confidential and 
competitively sensitive documents and information that may be submitted by the parties are afforded 
adequate protection. 
II. BACKGROUND
2. We note that Defendants submitted a proposed model of a protective order for the 
Commission to use in this proceeding.  This submission, according to Defendants, is based upon the 
protective order entered by the Media Bureau in two prior proceedings involving similar circumstances.3
  
1 Motion for Protective Order, filed Mar. 15, 2010 (“Motion”).
2 See Letter from Howard J. Symons, Counsel for Defendants, to Marlene H. Dortch, Secretary, FCC (Apr. 14, 
2010) (“Letter”).
3 Motion at 2 (citing AT&T Services., Inc. and Southern New England Telephone Company d/b/a AT&T Connecticut 
v. Madison Square Garden, L.P. and Cablevision Systems Corp., Order, 24 FCC Rcd 11258 (MB, 2009); AT&T 
Services, Inc. and Pacific Bell Telephone Co. d/b/a SBC California d/b/a AT&T California v. Cox Enterprises, Inc. 
and Cox Communications, Inc., Order, 23 FCC Rcd 14176 (MB, 2008) (AT&T v. Cox)).
Federal Communications Commission DA 10-682
2
3. Defendants filed the Motion concurrently with Defendants’ Supplement in Response to 
Verizon’s Late-Filed Consumer Survey (“Defendants’ Supplement”).4 Defendants assert that 
Defendants’ Supplement contains highly confidential and sensitive business information that was 
developed in the process of conducting two consumer surveys addressing issues relevant to this 
proceeding.5 This business data includes “granular, consumer-level statistics on the importance to 
consumers of particular programming services at issue in this case.”6 Due to the highly confidential 
nature of such data, Defendants assert that they seek entry of the protective order to limit access only to 
the parties’ outside counsel and counsel’s consultants and employees.7  The revised protective order 
submitted on April 14, 2010 permits disclosure of highly confidential information to in-house counsel 
under certain circumstances.8  
4. Defendants contend that the information for which they seek enhanced protection 
constitutes highly sensitive data pertaining to Defendants’ businesses, the inadvertent or intentional 
disclosure of which “could have a significant adverse effect on Defendants’ businesses and place them at 
a competitive disadvantage.”9 Specifically, Defendants submit that sensitive data about the importance of 
the programming at issue in this proceeding to consumers could be used by third party programmers and 
distributors to enhance their competitive position, for example regarding advertising and distribution of 
the programming at issue.10 Additionally, Defendants assert that competing multichannel video providers 
may seek to use such sensitive data “to formulate subscriber acquisition strategies and target their 
marketing and promotional efforts.”11  Defendants note that the Commission has previously recognized 
that such data, which competitors or distributors potentially could seek to exploit for a competitive 
advantage, is highly sensitive.12 Defendants cite prior cases in which the Commission has limited access 
to similar competitively sensitive customer information.13 Defendants state further that they have only 
redacted competitively sensitive and otherwise proprietary or confidential information, and that any delay 
in providing Verizon’s counsel with access to the information would be slight and nonprejudicial.14
III. DISCUSSION
5. We believe that Defendants have justified their request for enhanced confidential 
treatment of the documents in this proceeding.  Defendants have provided adequate justification for their 
request, explaining with particularity why the information sought to be protected is so competitively 
sensitive that additional protection is warranted so that such information is closely guarded and not made 
available publicly.  Furthermore, the protective order has been negotiated and agreed to between 
Defendants and Verizon.  Accordingly, we will adopt the Protective Order as negotiated and proposed by 
Defendants and attached at Appendix A.  Any party seeking access to highly confidential documents 
  
4 Motion at 1.
5 Id.
6 Id. at 1-2.
7 Id. at 2.  
8 See Letter at Attachment 1, Attachment 2.
9 Motion at 2.
10 Id.
11 Id.
12 Id.
13 Id. at 2-3 (citing AT&T v. Cox; News Corp., General Motors Corp., and Hughes Electronics Corp., Order, 18 
FCC Rcd 15198 (MB, 2003); AT&T Inc. and BellSouth Corp. Applications for Approval of Transfer of Control, 
Order, 21 FCC Rcd 7282 (WCB, 2006)).
14 Id. at 3.
Federal Communications Commission DA 10-682
3
subject to this Protective Order shall request access pursuant to the terms of the Protective Order and must 
sign the Declaration provided as Attachment A to this Protective Order.
6. The attached Protective Order reflects Defendants’ desire, given the highly confidential 
nature of the information at issue, to preclude certain employees of Defendants and Verizon from access 
to such information.  This is consistent with past Commission action involving protective orders relating 
to highly confidential information.  Nevertheless, we do not intend by this Order to prejudge this issue.  If 
either party believes that it is necessary for purposes of effectively adjudicating this proceeding that 
specific employees be granted access to the highly confidential information subject to the Protective 
Order, it may file a motion to amend the Protective Order.  At a minimum, such motion should include: 
(i) the title, name, and job description for each employee for which access to the highly confidential 
information is sought; (ii) the reason why that employee’s access to the highly confidential information is 
necessary to the effective adjudication of this proceeding; and (iii) why experts and consultants outside of 
that party’s employ cannot perform the same function.  In no event will access be granted to employees in 
a position to use the highly confidential information for competitive commercial or business purposes.
7. In addition to Section 4 of the attached Protective Order, we clarify that a party filing 
documents under seal with the Commission that contain Highly Confidential Information (“Highly 
Confidential Filing”) must file one copy of the Highly Confidential Filing and, where feasible, two copies 
of the Highly Confidential Filing in redacted form (“Redacted Highly Confidential Filing”).  A Highly 
Confidential Filing must be accompanied by a cover letter stating: “HIGHLY CONFIDENTIAL 
INFORMATION – SUBJECT TO PROTECTIVE ORDER IN Verizon Telephone Companies and 
Verizon Services Corp. v. Madison Square Garden, L.P. and Cablevision Systems Corp., CSR-
8185-P before the Federal Communications Commission”, and each page of this document containing 
Highly Confidential Information shall be stamped with the same statement. Redacted Highly 
Confidential Filings must also be accompanied by a cover letter stating: “REDACTED – FOR PUBLIC 
INSPECTION”, and the cover letter should also state that the Submitting Party is filing an unredacted 
version of the same documents.
IV. ORDERING CLAUSES
8. Accordingly, we ADOPT AND ISSUE the Protective Order attached at APPENDIX A 
pursuant to Sections 4(i) and 4(j) of the Communications Act as amended, 47 U.S.C. §§ 154(i) and (j), 
Sections 0.457(d) and 76.1003(k) of the Commission’s rules, 47 C.F.R. §§ 0.457(d) and 76.1003(k), and 
Section 4 of the Freedom of Information Act, 5 U.S.C. § 552(b)(4), and such Protective Order is effective 
upon its adoption.
9. This action is taken pursuant to authority delegated by Section 0.283 of the 
Commission’s rules.15
FEDERAL COMMUNICATIONS COMMISSION
William T. Lake
Chief, Media Bureau
  
15 47 C.F.R. §0.283.
Federal Communications Commission DA 10-682
4
APPENDIX A
Before the
Federal Communications Commission
Washington, D.C.  20554
In the Matter of
Verizon Telephone Companies and
Verizon Services Corp.,
Complainants,
v. 
Madison Square Garden, L.P. and
Cablevision Systems Corp.,
Defendants.
Program Access Complaint
)
)
)
)
)
)
)
)
)
)
)
)
)
File No. CSR-8185-P
PROTECTIVE ORDER
1. This Protective Order is intended to facilitate and expedite the review of documents filed 
in this proceeding that contain trade secrets and privileged or confidential commercial or financial 
information.  It establishes the manner in which “Highly Confidential Information,” as that term is 
defined herein, is to be treated.  The Order is not intended to constitute a resolution of the merits 
concerning whether any Highly Confidential Information would be released publicly by the Commission 
upon a proper request under the Freedom of Information Act or other applicable law or regulation, 
including 47 C.F.R. § 0.442.
2. Definitions.
a. Commission. “Commission” means the Federal Communications Commission or any 
arm of the Commission acting pursuant to delegated authority.
b. Declaration. “Declaration” means Attachment A to this Protective Order.
c. Highly Confidential Information. “Highly Confidential Information” means (i) 
operational, financial, and customer data, including granular sales, cancellation, and churn data as well as 
revenue information and customer survey data; (ii) any program carriage contract or program carriage 
offer, or any part thereof; (iii) information submitted to the Commission by the Submitting Party that has 
been so designated by the Submitting Party and which the Submitting Party has determined in good faith 
constitutes trade secrets or commercial or financial information which is privileged or confidential within 
the meaning of Exemption 4 of the Freedom of Information Act, 5 U.S.C. § 552(b)(4); and (iv) 
information submitted to the Commission by the Submitting Party that has been so designated by the 
Submitting Party and which the Submitting Party has determined in good faith falls within the terms of 
Commission orders designating the items for treatment as Highly Confidential Information. Highly 
Confidential Information includes additional copies of, notes, and information derived from Highly 
Confidential Information.
Federal Communications Commission DA 10-682
5
d. Outside Counsel of Record. “Outside Counsel of Record” means the firm(s) of 
attorneys, or sole practitioner(s), as the case may be, representing either complainant Verizon Telephone 
Companies and Verizon Services Corp. (collectively “Verizon” or “Complainants”) or defendant 
Cablevision Systems Corp. (“Cablevision”) or Madison Square Garden, L.P. (“MSG”) (collectively 
“Defendants”) in this proceeding. For the avoidance of doubt, Outside Counsel of Record shall exclude 
any employee of Verizon, Cablevision, or MSG.
e. Reviewing Party. “Reviewing Party” means a person or entity participating in this 
proceeding or considering in good faith filing a document in this proceeding.
f. Submitting Party. “Submitting Party” means a person or entity that seeks confidential 
treatment of Highly Confidential Information pursuant to this Protective Order.
3. Claim of Confidentiality.  The Submitting Party may designate information as “Highly 
Confidential Information” consistent with the definition of that term in Paragraph 2.c of this Protective 
Order.  The Commission may, sua sponte or upon petition, pursuant to 47 C.F.R. §§ 0.459 and 0.461, 
determine that all or part of the information claimed as “Highly Confidential Information” is not entitled 
to such treatment, but prior to making such a determination, the Commission shall afford the Submitting 
Party notice and opportunity to comment. Any party that did not file the Highly Confidential Information 
but that has completed the attached Declaration shall have three (3) business days from the date it 
receives notice that such Highly Confidential Information has been filed to file a petition opposing such 
Highly Confidential treatment. The Submitting Party shall have three (3) business days from the date it 
receives the other party’s opposition to file its reply to such opposition.
4. Procedures for Claiming Information is Highly Confidential. Highly Confidential 
Information submitted to the Commission shall bear on the front page in bold print, “HIGHLY
CONFIDENTIAL INFORMATION – SUBJECT TO PROTECTIVE ORDER IN Verizon 
Telephone Companies and Verizon Services Corp. v. Madison Square Garden, L.P. and 
Cablevision Systems Corp., CSR-8185-P before the Federal Communications Commission.” Highly 
Confidential Information shall be segregated by the Submitting Party from all non-confidential 
information submitted to the Commission. To the extent a document contains both Highly Confidential 
Information and non-confidential information, the Submitting Party shall designate the specific portions 
of the document claimed to contain Highly Confidential Information and shall, where feasible, also 
submit a redacted version not containing Highly Confidential Information. By designating information as 
“Highly Confidential Information,” a Submitting Party signifies that it has determined in good faith that 
the information should be subject to protection under FOIA, the Commission’s implementing rules, and 
this Protective Order.
5. Storage of Highly Confidential Information at the Commission.  The Secretary of the 
Commission or other Commission staff to whom Highly Confidential Information is submitted shall place 
the Highly Confidential Information in a non-public file.  Highly Confidential Information shall be 
segregated in the files of the Commission, and shall be withheld from inspection by any person not bound 
by the terms of this Protective Order, unless such Highly Confidential Information is released from the 
restrictions of this Order either through agreement of the parties, or pursuant to the order of the 
Commission or a court having jurisdiction.
6. Permissible Disclosure. Subject to the requirements of paragraph 9, a party’s Highly 
Confidential Information may be reviewed by the other party’s Outside Counsel of Record. Subject to the 
requirements of paragraph 9, Outside Counsel of Record may disclose Highly Confidential Information 
to: (1) outside consultants or experts retained for the purpose of assisting Outside Counsel of Record in 
this proceeding, provided that such outside consultants or experts are not employees of Verizon, 
Federal Communications Commission DA 10-682
6
Cablevision, or MSG (as relevant) and are not involved in the analysis underlying the business decisions 
of any competitor of the Submitting Party and do not participate directly in those business decisions; (2) 
paralegals or other employees of such Outside Counsel of Record not described in clause 3 of this 
paragraph 6 assisting Outside Counsel of Record in this proceeding; and (3) employees of such Outside 
Counsel of Record involved solely in one or more aspects of organizing, filing, coding, converting, 
storing, or retrieving documents or data or designing programs for handling data connected with this 
proceeding, or performing other clerical or ministerial functions with regard to documents connected with 
this proceeding. Individuals who have obtained access to Highly Confidential Information in accordance 
with the provisions of this paragraph 6 and paragraph 9 may discuss and share the contents of such 
Highly Confidential Information with any other person who has also obtained access in accordance with 
the provisions of this paragraph 6 and paragraph 9, and with the Commission and its staff. Except with 
the prior written consent of the relevant Submitting Party, or as otherwise provided under this Protective 
Order, no Highly Confidential Information may be disclosed by persons executing the attached 
Declaration to any person other than the Commission, its staff, and any other person executing the 
attached Declaration. Subject to the procedures and requirements described in this paragraph 6 and 
paragraph 9, the Commission may disclose Highly Confidential Information to outside experts or 
consultants retained by the Commission to assist in this proceeding.  Notwithstanding the foregoing, 
Highly Confidential Information may be disclosed to in-house counsel who are actively engaged in the 
conduct of this proceeding and are not involved in competitive decision making (which includes, without 
limitation, programming license negotiations or activities) or rendering advice or participating in any or 
all of the Reviewing Party’s or any other person’s business decisions that are or will be made in light of 
similar or corresponding information about a competitor.
7. Protection of Highly Confidential Information. Persons described in paragraph 6 shall 
have the obligation to ensure that access to Highly Confidential Information is strictly limited as 
prescribed in this Protective Order. Such persons shall further have the obligation to ensure that: (1) 
Highly Confidential Information is used only as provided in this Protective Order; and (2) documents 
containing such Highly Confidential Information are not duplicated except as necessary for filing at the 
Commission under seal as provided in paragraph 12 below.
8. Prohibited Copying. If, in the judgment of a Submitting Party, a document contains 
information so sensitive that it should not be copied by anyone, even given its designation as Highly 
Confidential Information, it shall bear the additional legend “Copying Prohibited,” and no copies of such 
document, in any form, shall be made. Application for relief from this restriction against copying may be 
made to the Commission, with notice to Outside Counsel of Record for the Submitting Party.
9. Procedures for Obtaining Access to Highly Confidential Information. In all cases where 
access to Highly Confidential Information is permitted pursuant to paragraph 6, before reviewing or 
having access to any Highly Confidential Information, each person seeking such access shall execute the 
Declaration in Attachment A and file it with the Commission and serve it upon the Submitting Party 
through their Outside Counsel of Record, so that the Declaration is received by the Submitting Party at 
least five (5) business days prior to such person’s reviewing or having access to such Submitting Party’s 
Highly Confidential Information. Each Submitting Party shall have an opportunity to object to the 
disclosure of its Highly Confidential Information to any such persons. Any objection must be filed at the 
Commission and served on Outside Counsel of Record representing, retaining, or employing such person 
as promptly as practicable after receipt of the relevant Declaration. Until any such objection is resolved 
by the Commission and, if appropriate, any court of competent jurisdiction prior to any disclosure, and 
unless such objection is resolved in favor of the person seeking access, persons subject to an objection 
from a Submitting Party shall not have access to Highly Confidential Information. If there is no objection 
or once such objection is resolved, the Submitting Party shall serve the documents of such party 
containing Highly Confidential Information on the requesting party’s Outside Counsel of Record, or if so 
Federal Communications Commission DA 10-682
7
requested, will make such material available for review at the offices of the Submitting Party’s Outside 
Counsel of Record.
10. Requests for Additional Disclosure. If any person requests disclosure of Highly 
Confidential Information outside the terms of this Protective Order, that request will be treated in 
accordance with Sections 0.442 and 0.461 of the Commission’s rules, 47 C.F.R. §§ 0.442, 0.461.
11. Use of Highly Confidential Information. Highly Confidential Information shall be used 
solely for the preparation and conduct of this proceeding as delineated in this paragraph and paragraphs 6, 
12, and 13 herein, and any subsequent judicial proceeding arising directly from this proceeding and, 
except as provided herein, shall not be used by any person granted access under this Protective Order for 
any other purpose, including without limitation business, governmental, or commercial purposes, or in 
other administrative, regulatory, or judicial proceedings. This shall not preclude the use of any material or 
information that is in the public domain or has been developed independently by any other person who 
has not had access to the Highly Confidential Information nor otherwise learned of its contents. Should 
the Commission rely upon or otherwise make reference to the contents of any of the Highly Confidential 
Information in its decision in this proceeding, it will do so by redacting any Highly Confidential 
Information from the public version of the decision and by making the unredacted version of the decision 
available only to a court and to those persons entitled to access to Highly Confidential Information under 
this Protective Order.
12. Pleadings Using Highly Confidential Information. Persons described in paragraph 6 may, 
in any pleadings that they file in this proceeding, reference the Highly Confidential Information, but only 
if they comply with the following procedures:
a.  Any portions of the pleadings that contain or disclose Highly Confidential Information 
must be physically segregated from the remainder of the pleadings. To the extent a document contains 
both Highly Confidential Information and non-Highly Confidential Information, the Submitting Party 
shall designate the specific portions of the document claimed to contain Highly Confidential Information 
and shall also submit a redacted version not containing Highly Confidential Information.
b.  The portions of pleadings containing or disclosing Highly Confidential Information 
must be separated and accompanied by a separate letter to the Secretary of the Commission referencing 
this Protective Order.
c.  Each page of any party’s filing that contains or discloses Highly Confidential 
Information subject to this Order must be clearly marked: “HIGHLY CONFIDENTIAL 
INFORMATION – SUBJECT TO PROTECTIVE ORDER IN Verizon Telephone Companies and 
Verizon Services Corp. v. Madison Square Garden, L.P. and Cablevision Systems Corp., CSR-
8185-P before the Federal Communications Commission.”
d.  The highly confidential portion(s) of the pleading shall be served upon the Secretary 
of the Commission and the Submitting Party whose Highly Confidential Information has been included. 
Such confidential portions shall be served separately with a cover letter referencing this Order, and shall 
not be placed in the Commission’s Public File unless the Commission directs otherwise (with notice to 
the Submitting Party as set forth in paragraph 3). A Submitting Party filing a pleading containing Highly 
Confidential Information shall also file two redacted copies of the pleading containing no Highly 
Confidential Information, which copy shall be placed in the Commission’s public files. Parties should not 
provide courtesy copies of pleadings containing Highly Confidential Information to Commission staff.
Federal Communications Commission DA 10-682
8
13. Client Consultation. Nothing in this Protective Order shall prevent or otherwise restrict 
Outside Counsel of Record from rendering advice to their clients relating to the conduct of this 
proceeding and any subsequent judicial proceeding arising therefrom and, in the course thereof, relying 
generally on examination of Highly Confidential Information; provided, however, that in rendering such 
advice and otherwise communicating with such client, Outside Counsel of Record shall not disclose 
Highly Confidential Information except as provided in paragraph 6.
14. Violations of Protective Order. Should a person that has properly obtained access to 
Highly Confidential Information under this Protective Order violate any of its terms, that person shall 
immediately convey that fact to the Commission and to the relevant Submitting Party. Further, should 
such violation consist of improper disclosure or use of Highly Confidential Information, the violating 
party shall take all necessary steps to remedy the improper disclosure or use. The violating party shall also 
immediately notify the Commission and the Submitting Party, in writing, of the identity of each party 
known or reasonably suspected to have obtained the Highly Confidential Information through any such 
disclosure. The Commission retains its full authority to fashion appropriate sanctions for violations of this 
Protective Order, including but not limited to suspension or disbarment of Outside Counsel of Record 
from practice before the Commission, forfeitures, cease and desist orders, and denial of further access to 
Highly Confidential Information or other information subject to a protective order in this or any other 
Commission proceeding. Nothing in this Protective Order shall limit any other rights and remedies 
available to the Submitting Party at law or equity against any person using Highly Confidential 
Information in a manner not authorized by this Protective Order.
15. Termination of Proceeding. The provisions of this Protective Order shall not terminate at 
the conclusion of this proceeding. Within two weeks after final resolution of this proceeding (which 
includes any administrative or judicial appeals), persons described in paragraph 6 shall destroy or return 
to the Submitting Party the relevant documents containing Highly Confidential Information as well as all 
copies and derivative materials made, and shall certify in a writing served on the Commission and the 
Submitting Party that no material whatsoever derived from such Highly Confidential Information has 
been retained by any person having access thereto, except that Outside Counsel of Record may retain, 
under the continuing strictures of this Protective Order, two copies of pleadings (one of which may be in 
electronic format) submitted on behalf of a party. Any Highly Confidential Information contained in any 
copies of pleadings retained by Outside Counsel of Record to a party pursuant to this paragraph shall be 
protected from disclosure or use indefinitely in accordance with this Protective Order unless such Highly 
Confidential Information is released from the restrictions of this Protective Order either through 
agreement of the parties, or pursuant to the order of the Commission or a court having jurisdiction. The 
provisions of this paragraph 15 regarding the retention of Highly Confidential Information, any 
documents containing such information, and copies of same, shall not be construed to apply to the 
Commission or its staff.
16. No Waiver of Confidentiality. Disclosure of Highly Confidential Information as provided 
herein by any person shall not be deemed a waiver by the Submitting Party of any privilege or entitlement 
to confidential treatment of such Highly Confidential Information. Reviewing parties, by viewing these 
materials: (a) agree not to assert any such waiver; (b) agree not to use Highly Confidential Information to 
seek disclosure in any other proceeding; and (c) agree that accidental disclosure of Highly Confidential 
Information shall not be deemed a waiver of any privilege or entitlement as long as the Submitting Party 
takes prompt remedial action.
17. Subpoena by Courts, Departments, or Agencies. If a court or a federal or state department 
or agency issues a subpoena or orders production of Highly Confidential Information that a party has 
obtained under terms of this Protective Order, such party shall promptly notify in writing each Submitting 
Party of the pendency of such subpoena or order. Consistent with the independent authority of any court, 
Federal Communications Commission DA 10-682
9
department, or agency, such notification must be accomplished such that the Submitting Party has a full 
opportunity to oppose such production, which shall be at least five (5) business days prior to the 
production or disclosure of any Highly Confidential Information.
18. Additional Rights Preserved. The entry of this Protective Order is without prejudice to 
the rights of the Submitting Party to apply for additional or different protection where it is deemed 
necessary or to the rights of parties executing the attached Declaration to request further or renewed 
disclosure of Highly Confidential Information.
19. Effect of Protective Order. This Protective Order constitutes an Order of the Commission 
and an agreement between the party executing the attached Declaration and the Submitting Party.
20. Authority. This Protective Order is issued pursuant to Sections 4(i) and 4(j) of the 
Communications Act as amended, 47 U.S.C. §§ 154(i), (j), and 47 C.F.R. §§ 0.457(d) and 76.1003(k), 
and Section 4 of the Freedom of Information Act, 5 U.S.C. § 552(b)(4).
Federal Communications Commission DA 10-682
10
ATTACHMENT A
Before the
Federal Communications Commission
Washington, D.C.  20554
In the Matter of
Verizon Telephone Companies and
Verizon Services Corp.,
Complainants,
v. 
Madison Square Garden, L.P. and
Cablevision Systems Corp.,
Defendants.
Program Access Complaint
)
)
)
)
)
)
)
)
)
)
)
)
)
File No. CSR-8185-P
DECLARATION
I, _____________________________, hereby declare under penalty of perjury that I have read 
the Protective Order that has been entered by the Commission in this proceeding, and that I understand it.  
I agree to be bound by its terms pertaining to the treatment of Highly Confidential Information submitted 
by parties to this proceeding.  I understand that the Highly Confidential Information shall not be disclosed 
to anyone except in accordance with the terms of the Protective Order and shall be used only for purposes 
of the proceedings in this matter.  
Without limiting the foregoing, to the extent that I have any employment, affiliation, or role with 
any person or entity other than a conventional private law firm (such as, but not limited to, a lobbying or 
public interest organization), I acknowledge specifically that my access to any Highly Confidential 
Information obtained as a result of the Protective Order is due solely to my capacity as (1) Outside 
Counsel of Record or (2) other person described in paragraph 6 of the foregoing Protective Order, and 
that I will not use such Highly Confidential Information in any other capacity; nor will I disclose such 
Highly Confidential Information except as specifically provided in the Protective Order.
I acknowledge that it is my obligation to ensure that: (1) Highly Confidential Information is used 
only as provided in the Protective Order; and (2) documents containing Highly Confidential Information 
are not duplicated except as specifically permitted by the terms of the Protective Order, and I certify that I 
have verified that there are in place procedures, at my firm or office, to prevent unauthorized disclosure of 
Highly Confidential Information.
I acknowledge that a violation of the Protective Order is a violation of an order of the Federal 
Communications Commission.  I acknowledge that this Protective Order is also a binding agreement 
between the undersigned and the Submitting Party.  I am not in a position to use the Confidential 
Information for competitive commercial or business purposes, including competitive decision-making, 
and my activities, association, or relationship with the Reviewing Parties or other persons does not 
Federal Communications Commission DA 10-682
11
involve rendering advice or participating in any or all of the Reviewing Parties’ or other persons’ business 
decisions that are or will be made in light of similar or corresponding information about a competitor. 
(signed) ___________________________________________________
(printed name) ______________________________________________
(representing) _______________________________________________
(title) _____________________________________________________
(employer) _________________________________________________
(address) ___________________________________________________
(phone) ____________________________________________________
(email) ____________________________________________________
(date) _____________________________________________________