Federal Communications Commission DA 14-1605 Before the Federal Communications Commission WASHINGTON, D.C. 20554 In the Matter of Applications of Comcast Corp. and Time Warner Cable Inc. For Consent To Assign or Transfer Control of Licenses and Authorizations and AT&T, Inc. and DIRECTV For Consent To Assign or Transfer Control of Licenses and Authorizations ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) MB Docket No. 14-57 MB Docket No. 14-90 ORDER Adopted: November 4, 2014 Released: November 4, 2014 By the Chief, Media Bureau: I. INTRODUCTION 1. In this Order, the Media Bureau rejects objections filed against 245 individuals that filed Acknowledgments to the Modified Joint Protective Orders as a prerequisite to reviewing Highly Confidential Information contained in the record of the above captioned proceedings. As described below, in the case of 235 individuals, the objections fail to provide any basis upon which the Acknowledgments could be rejected. In the case of 10 individuals, the objections fail properly to apply the definitions contained in the Modified Joint Protective Orders. II. BACKGROUND 2. On October 7, 2014, the Media Bureau issued an Order modifying the Joint Protective Orders in these proceedings. 1 We required potential Reviewing Parties 2 to re-sign the Acknowledgments required under the Joint Protective Orders and provided third parties a procedure by which they could object to certain individuals being permitted to review confidential information under the Modified Joint 1 See Applications of Comcast Corp. and Time Warner Cable Inc. for Consent to Assign or Transfer Control of Licenses and Authorizations and Applications of AT&T, Inc. and DIRECTV for Consent to Assign or Transfer Control of Licenses and Authorizations, Order, DA 14-1463 (MB, rel. Oct. 7, 2014) (“VPCI Order”). See also Applications of Comcast Corp. and Time Warner Cable Inc. for Consent to Assign or Transfer Control of Licenses and Authorizations, Modified Joint Protective Order, DA 14-1464 (MB, rel. Oct. 7, 2014); Applications of AT&T, Inc. and DIRECTV for Consent to Assign or Transfer Control of Licenses and Authorizations, Modified Joint Protective Order, DA 14-1465 (MB, rel. Oct. 7, 2014) (together, the “Modified Joint Protective Orders”). 2 Capitalized terms are used as defined in the Modified Joint Protective Orders. Federal Communications Commission DA 14-1605 2 Protective Orders. 3 3. Pursuant the Modified Joint Protective Orders, various individuals executed Acknowledgments and filed them with the Commission. Starting on October 15, 2014, seven third- parties (the “Content Companies”) 4 filed objections in both proceedings against every individual who sought to review Highly Confidential Information, including Video Programming Confidential Information (“VPCI”), 5 under the Modified Joint Protective Orders. 6 Nearly identical objections were filed by Discovery Communications LLC. 7 By this Order, we reject 245 of these objections. 8 4. The Content Companies’ objections list the individuals to whom they are objecting either in the body of the objection or in an attached appendix. Between the two dockets, the companies object to 266 separate individuals. 9 As to 235 of these individuals, however, the Content Companies provide no specific basis for objection. Rather, using almost identical language in each pleading, the Content Companies “reiterate their objection to permitting any individual to access their highly confidential carriage agreements” with the Applicants. They state that none of the signatories “has made a particularized, good-faith showing as to why each needs access” to the information and conclude: “The substance of this objection is set forth more fully in the Application for Review filed by the Content Companies in the captioned proceeding on October 14, 2014.” 5. Cogent Communications Group Inc. (“Cogent”) filed a response to the Content Companies’ 3 VPCI Order at ¶¶ 9-10. 4 The self-styled Content Companies are: CBS Corp.; Scripps Networks Interactive, Inc.; The Walt Disney Co,; Time Warner Inc.; Twenty First Century Fox, Inc.; Univision Communications Inc.; and Viacom Inc. 5 Video Programming Confidential Information is defined in the Modified Joint Protective Orders as an agreement or any part thereof for distribution of any video programming (including broadcast programming) carried by an Applicant’s (i) MVPD service and/or (ii) OVD service; a detailed description of one or more provisions of such an agreement, including, but not limited to, price terms; and information relating to the negotiation of such an agreement. 6 Objection to Request for Access to Highly Confidential Information and Video Programming Confidential Information [hereinafter Objection], MB Docket No. 14-57 (filed Oct. 15, 2014) (joined in by Discovery Communications LLC and TV One, LLC); Objection, MB Docket No. 14-90 (filed Oct. 15, 2014) (joined in by Discovery Communications LLC and TV One, LLC); Objection, MB Docket No. 14-57 (filed Oct. 15, 2014); Objection, MB Docket No. 14-57 (Oct. 16, 2014); Objection, MB Docket No. 14-90 (Oct. 16, 2014) (joined in by Discovery Communications LLC); Objection, MB Docket No. 14-57 (Oct. 20, 2014); Objection, MB Docket No. 14-57 (Oct. 20, 2014); Objection, MB Docket No. 14-90 (Oct. 20, 2014); Objection, MB Docket No. 14-57 (Oct. 21, 2014); Objection, MB Docket No. 14-57 (Oct. 22, 2014); Objection, MB Docket No. 14-90 (Oct. 21, 2014); Objection, MB Docket No. 14-57 (Oct. 23, 2014) (joined in by Discovery Communications LLC); Objection, MB Docket No. 14-90 (Oct. 23, 2014); Objection, MB Docket No. 14-57 (Oct. 24, 2014) (joined in by Discovery Communications LLC). 7 Objection, MB Docket No. 14-57 (Oct.16, 2014); Objection, MB Docket No. 14-57 (Oct. 20, 2014); Objection, MB Docket No. 14-90 (Oct. 20, 2014); Objection, MB Docket No. 14-57 (Oct. 21, 2014); Objection, MB Docket No. 14-90 (Oct. 21, 2014); Objection, MB Docket No. 14-57 (Oct. 22, 2014); Objection, MB Docket No. 14-90 (Oct. 23, 2014). 8 We will address the objections to the remaining 20 individuals in future orders. This Order does not address any individuals filing Acknowledgments to whom objections were not due on or before October 31, 2014. 9 The Content Companies object to 184 individuals in Docket No. 14-57 and 112 individuals in Docket No. 14-90, 30 of whom they also objected to in Docket 14-57. Over two-thirds of these (104 in Docket No. 14-57 and 80 in Docket No. 14-90) are counsel or consultants for the applicants. None of the counsel or consultants for any of the applicants has filed acknowledgments in the other proceeding; each is participating only in its own. Federal Communications Commission DA 14-1605 3 objections on October 21, 2014. 10 DISH Network Corporation (“DISH”) and Monumental Sports and Entertainment (“Monumental Sports”) each filed a separate response on October 24, 2014. 11 Cogent argued that the individuals who signed the Acknowledgments as Cogent representatives do not have “competitive decision-making” authority and that the Content Companies and Discovery have no basis to believe that Cogent’s outside counsel and consultants would not adhere to the requirements of the Modified Joint Protective Orders. 12 DISH argued that the objections were a pretext for a collateral attack on the Commission’s decision to make the Content Companies’ Video Programming Confidential Information available under the Modified Joint Protective Orders and that the objections were made for the purpose of delaying implementation of the orders. 13 DISH noted that each signatory of an Acknowledgment certified that he or she was not involved in Competitive Decision-Making and argued that the objections were frivolous. 14 Monumental Sports stated that their counsel also had signed the Acknowledgments and were not involved in Competitive Decision-Making and that the Content Companies did not specify the basis for their objection. Rather, Monumental Sports argued, the Content Companies “assert an overly broad, general objection against disclosure of all” confidential information. 15 6. The Content Companies filed Comments regarding Cogent’s Response on October 22, 2014. 16 The comments focus on Cogent’s proposal that its representatives be permitted to have access to Highly Confidential Information in which the Content Companies and Discovery do not have a confidentiality interest. Nowhere do the comments address Cogent’s argument about, nor provide further information regarding, why the specific individuals representing Cogent should not be entitled to review Highly Confidential Information pursuant to the Modified Joint Protective Orders. III. DISCUSSION 7. Under the Modified Joint Protective Orders, persons are eligible to review Highly Confidential Information (potential Reviewing Parties) only if: they are Outside Counsel or Outside Consultants who are not engaged in Competitive Decision-Making, as those terms are defined in the Modified Joint Protective Order, and they sign the Acknowledgment certifying, among other requirements, that these facts are true. Paragraph 8 of the Modified Joint Protective Orders provides parties who have a confidentiality interest in information being submitted pursuant to the Protective Order the opportunity to object to the disclosure of that information to any potential Reviewing Party. 8. With regard to 235 of the individuals who signed the required Acknowledgments, the Content 10 Response to Objections to Request for Access to Highly Confidential Information and Video Programming Confidential Information, MB Docket Nos. 14-57, 14-90, filed by Cogent Communications Group Inc. (Oct. 21, 2014). 11 Amended Response to Objections to Request for Access to Highly Confidential Information and Video Programming Confidential Information, MB Docket Nos. 14-57, 14-90, filed by DISH Network Corporation (Oct. 24, 2014); Response to Objections to Request for Access to Highly Confidential Information and Video Programming Confidential Information, MB Docket No. 14-57, filed by Monumental Sports and Entertainment (Oct. 24, 2014). 12 Cogent’s Response at 2. 13 DISH’s Amended Response at 3. 14 Id. at 2-3. 15 Monumental Sport’s Response at 2. 16 Content Companies’ Comments Regarding Cogent Communication Group’s Response to Objections to Request for Access to Highly Confidential Information and Video Programming Confidential Information, MB Docket Nos. 14-57, 14-90 (Oct. 22, 2014). Federal Communications Commission DA 14-1605 4 Companies provide no reason for concluding that the individuals at issue are not entitled under the terms of the Modified Joint Protective Orders to review Highly Confidential Information, including the Content Companies’ Video Programming Confidential Information. Rather than providing information specific to any of these individuals, over two-thirds of whom are counsel or consultants for the various applicants, 17 the Content Companies simply refer to their objections to the Modified Joint Protective Orders themselves and state that the individuals have not provided a “particularized, good-faith showing” as to why he or she needs access to the information. Contrary to their argument, there is no requirement under the Modified Joint Protective Orders that qualified Reviewing Parties provide a “particularized, good- faith showing” as to why they need access to the information. It is sufficient that they are participating in good-faith in the proceeding. 18 We take the Content Companies’ pleadings as indicating that they have no objection to any of these particular individuals; instead, their argument is that information in which they have a confidentiality interest should not be available under the Modified Joint Protective Orders in these proceedings at all. 9. The objection procedure contained in the Modified Joint Protective Orders does not, however, serve as a method to collaterally attack the propriety of those orders. Rather, its purpose is to allow entities whose confidential information may be disclosed to object to specific individuals on the ground that those persons are not eligible to review the information. This would most typically be on the ground that a potential Reviewing Party is, indeed, engaged in competitive decision-making, at least with regard to the entity making the objection. If a party wishes to object to the issuance of a protective order, on the grounds that the information should not be released at all, the proper procedure is to file an Application for Review, which, indeed, the Content Companies have done. Today, the Bureau issued an Order on Reconsideration re-affirming and explaining more fully its decision to adopt the Modified Joint Protective Orders to allow for a very limited release of Confidential and Highly Confidential Information in these proceedings, subject to stringent protections. Thus we find that, for the 235 individuals against whom no specific objections have been raised, the Content Companies have failed to provide any basis whatsoever on which their objections could be granted. Accordingly, we deny the Content Companies’ objections under paragraph 8 of the Modified Joint Protective Orders as to those 235 individuals, listed in the Appendix to this Order. 10. The Content Companies also raise objections in their pleadings to 10 other individuals on the ground that they are not “Outside Counsel” or “Outside Consultants” and thus are not entitled to have access to Highly Confidential Information under the Modified Joint Protective Orders, because they are employed directly by the participating party (that is, they are “inside” or “in-house” counsel and consultants, not “outside”). These include employees of The Greenlining Institute, Free Press, the California Public Utility Commission, and the Maine Office of Public Advocate. 19 The Content Companies raise no other objections to these individuals. 11. The Modified Joint Protective Orders define “Outside Counsel” to include “any attorney representing a non-commercial Participant in this proceeding, provided that such attorney is not involved 17 See note 8 supra. 18 The Modified Joint Protective Orders include a number of important protections for Highly Confidential Information, including Video Programming Confidential Information. Such protections include but are not limited to: restricting any person who has access to confidential information to use that information only for participating in the particular Commission proceeding. and that each individual must sign the Acknowledgment agreeing that he or she is “bound by the Modified Joint Protective Order and that [he or she] shall not disclose or use [the information] except as allowed by the Modified Joint Protective Order.” Modified Joint Protective Order ¶ 12, Acknowledgment. 19 The Content Companies also object on this ground to other individuals whose circumstances differ. We will address those objections in a separate order. Federal Communications Commission DA 14-1605 5 in Competitive Decision-Making.” 20 Similarly, “[t]he term ‘Outside Consultant’ includes any consultant or expert employed by a non-commercial Participant in this proceeding, provided that such consultant or expert is not involved in Competitive Decision-Making.” 21 Thus, the employees of non-commercial participants who are counsel or consultants or experts fall within the definition of “Outside Counsel” or “Outside Consultants” under the Modified Joint Protective Orders. 22 Therefore, individuals in this category are entitled to review Highly Confidential Information, including VPCI, if they do not engage in Competitive Decision-Making and if they have properly executed an Acknowledgment. Accordingly, we reject the Content Companies’ objections as to the 10 individuals listed in the Appendix to whom the Content Companies objected solely on the ground that they were not Outside Counsel or Outside Experts. IV. ORDERING CLAUSES 12. Accordingly, IT IS ORDERED, that in accordance with the paragraph 8 of the Modified Joint Protective Orders, as amended, and the authority contained in sections 4(i), 214 and 310(d) of the Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 214 and 310(d), Section 4 of the Freedom of Information Act, 5 U.S.C. § 552(b)(4), 47 C.F.R. § 1.102(b)(1), and authority delegated under section 0.283 of the Commission’s rules, 47 C.F.R. § 0.283, the individuals listed in the Appendix shall have access to Confidential and Highly Confidential Information, including VPCI, five business days from the date this Order is adopted. FEDERAL COMMUNICATIONS COMMISSION William T. Lake Chief, Media Bureau 20 Modified Joint Protective Orders ¶ 2 (emphasis added). 21 Id. 22 See Response to Objections to Request for Access to Highly Confidential Information and Video Programming Confidential Information, MB Docket Nos. 14-57, 14-90, filed by Free Press (Nov. 3, 2014) at 4 (“Because they have not provided any support for the conclusion that Free Press’ attorneys and experts do not qualify as Outside Counsel or Outside Consultants, it is impossible to pinpoint exactly which term or terms in the Modified Joint Protective Order the Content Companies misunderstood. What part of relevant text possible could have proved difficult for the companies to decipher?”). Federal Communications Commission DA 14-1605 6 APPENDIX Gary Biglaiser, Outside Consultant to American Cable Association 23 Donna L. Brown, Outside Consultant to American Cable Association Brooks Harlow, Outside Counsel to American Cable Association David Lafuria, Outside Counsel to American Cable Association Leila Rezanavaz, Outside Consultant to American Cable Association Elisheva Simon, Outside Consultant to American Cable Association Alexandra Liopiros, Employee of Outside Counsel for Time Warner Cable Alexander L. Stout, Outside Counsel for Time Warner Cable Christopher J. Fawal, Outside Counsel for Time Warner Cable Kory S. Wilmot, Outside Counsel for Time Warner Cable Elizabeth R. Park, Outside Counsel for Time Warner Cable James Barker, Outside Counsel for Time Warner Cable Matthew A. Brill, Outside Counsel for Time Warner Cable David Fendig, Employee of Outside Counsel for RCN Telecom M. Renee Britt, Employee of Outside Counsel for RCN Telecom Eric J. Branfman, Outside Counsel for RCN Telecom William S. Comanor, Outside Consultant for Writers Guild of America, West Michael A. Forsley, Outside Counsel for Writers Guild of America, West Dennis Weller, Outside Consultant for Comcast Constantine Dovrolis, Outside Consultant for Comcast Michael Baurback, Outside Consultant for Comcast Fangzheng Qian, Outside Consultant for Comcast Zijun Pang, Outside Consultant for Comcast Zhichun Ying, Outside Consultant for Comcast Jenny Wu, Outside Consultant for Comcast Affonso Reis, Outside Consultant for Comcast Natasha Bhatia, Outside Consultant for Comcast Peter Akkies, Outside Consultant for Comcast Brianna Cardiff Hicks, Outside Consultant for Comcast Ilya Gaidaron, Outside Consultant for Comcast Stephanie Lee, Outside Consultant for Comcast Marshall Yan, Outside Consultant for Comcast Michael D. Topper, Outside Consultant for Comcast Gregory L. Rossten, Outside Consultant for Comcast Ben Wagner, Outside Consultant for Comcast Daniel Cherette, Outside Consultant for Comcast Ibtinal Hyder, Outside Consultant for Comcast Philip Wolf, Outside Consultant for Comcast David A. Weizkopf, Outside Consultant for Comcast Bryan Keating, Outside Consultant for Comcast Mark Israel, Outside Consultant for Comcast Michael Easterly, Outside Consultant for Comcast Russell P. Hanser, Outside Counsel for Comcast Emilie M. de Lozier, Outside Counsel for Comcast Rosemary C. Harold, Outside Counsel for Comcast 23 Names and titles and the ordering is as listed in the Objections filed by the Content Companies. Federal Communications Commission DA 14-1605 7 Bryan N. Tramont, Outside Counsel for Comcast Brian Murray, Outside Counsel for Comcast Adam D. Krinsky, Outside Counsel for Comcast J. Wade Lindsay, Outside Counsel for Comcast Natalie Roisman, Outside Counsel for Comcast Kevin T. Ryan, Outside Counsel for Comcast Jonathan V. Cohen, Outside Counsel for Comcast Lindaey T. Knapp, Outside Counsel for Comcast David B. Toscano, Outside Counsel for Comcast Arthur J. Burke, Outside Counsel for Comcast Gabriel Jaime, Outside Counsel for Comcast Esther Kim, Employee of Outside Counsel for Comcast Christopher Seck, Outside Counsel for Comcast Jon Liebowitz, Outside Counsel for Comcast Andrew DeLaney, Outside Counsel for Comcast Sagar D. Thakur, Employee of Outside Counsel for Comcast Christopher Lynch, Outside Counsel for Comcast Edith Beerdsen, Outside Counsel for Comcast Charles Shioleno, Outside Counsel for Comcast Jane McCooey, Outside Counsel for Comcast Nathaniel Hopkin, Outside Counsel for Comcast Noreen Minette Dillen, Outside Counsel for Comcast Shahira Ali, Outside Counsel for Comcast Maria Sicuranza, Outside Counsel for Comcast D. Tina Wang, Outside Counsel for Comcast Ann Staron, Employee of Outside Counsel for Comcast Kyle Mathews, Employee of Outside Counsel for Comcast Hayley Tozeski, Outside Counsel for Comcast Kristen Fraser, Outside Counsel for Comcast Mary Claire York, Outside Counsel for Comcast Eileen EHutchinson, Outside Counsel for Comcast Daniel R Bumpus, Outside Counsel for Comcast Joshua Parker, Outside Counsel for Comcast Matthew R. Jones, Outside Counsel for Comcast Melanie A. Medina, Outside Counsel for Comcast Michael D. Hurwitz, Outside Counsel for Comcast Mia Guizzetti Hayes, Outside Counsel for Comcast Michael G. Jones, Outside Counsel for Comcast David P. Murray, Outside Counsel for Comcast Johnathan A. Friedman, Outside Counsel for Comcast James L. Casserly, Outside Counsel for Comcast Francis M. Buono, Outside Counsel for Comcast Jeff Blattner, Employee of Outside Counsel for Netflix David S. Evans, Outside Consultant for Netflix Nicholas Giancarlo, Outside Consultant for Netflix Madelieine Chen, Outside Consultant for Netflix Howard Chang, Outside Consultant for Netflix Steven Joyce, Outside Consultant for Netflix Susan A. Creighton, Outside Counsel for Netflix Courtney Armour, Outside Counsel for Netflix Federal Communications Commission DA 14-1605 8 Daniel Ferrel McInnis, Outside Counsel for Entravision Barry A. Friedman, Outside Counsel for Entravision John Kwoks, Outside Consultant for Entravision E. Jane Murdoch, Outside Consultants for Discovery Communications, Inc. Michael A. Salinger, Outside Consultants for Discovery Communications, Inc. Joshua Bobeck, Outside Counsel for RCN Telecom Robert M. Cooper, Outside Counsel for Cogent Communications Group James P. Denvir, Outside Counsel for Cogent Communications Group Richard A. Feinstein, Outside Counsel for Cogent Communications Group Hershel A. Wancjer, Outside Counsel for Cogent Communications Group Nicholas Widnell, Outside Counsel for Cogent Communications Group Joshua Riley, Outside Counsel for Cogent Communications Group Martha L. Goodman, Outside Counsel for Cogent Communications Group Joseph Farrell, Outside Counsel for Cogent Communications Group Keith Waehrer, Outside Counsel for Cogent Communications Group Donald Stockdale, Outside Counsel for Cogent Communications Group Kathleen Nelis, Outside Counsel for Cogent Communications Group Brad McKeen, Outside Counsel for Cogent Communications Group Derek Ludwin, Outside Counsel for Discovery Communications Jon Riddle, Outside Consultant for Writers Guild of America, West Tom Davidson, Outside Counsel for Monumental Sports and Entertainment Lyndsey Grunewald, Outside Counsel for Monumental Sports and Entertainment Andrew Jay Schwartzman, Outside Counsel for Zoom Telephonics, Inc. Aidan Synnott, Outside Counsel for Time Warner Cable Maria H. Keane, Outside Counsel for Time Warner Cable Mark R. Laramie, Outside Counsel for Time Warner Cable Jerry A. Hausman, Outside Consultant for Time Warner Cable Carrie Apfel, Outside Counsel for Charter Communications Mary Ellen Callahan, Outside Counsel for Charter Communications Charles L. Capito, Outside Counsel for Charter Communications Micah J. Cogen, Outside Counsel for Charter Communications Caroline M. DeCell, Outside Counsel for Charter Communications David M. Didion, Outside Counsel for Charter Communications Samuel L. Feder, Outside Counsel for Charter Communications John L. Flynn, Outside Counsel for Charter Communications Mary E. Gulden, Outside Counsel for Charter Communications Esteban M. Morin, Outside Counsel for Charter Communications Luke C. Platzer, Outside Counsel for Charter Communications Elliot Sheppard Tarloff, Outside Counsel for Charter Communications Ilene Knable Gotts, Outside Counsel for Charter Communications Jeffrey A. Eisenach, Outside Consultant for Charter Communications Greg Kreischer, Outside Consultant for Charter Communications Janusz Mrozek, Outside Consultant for Charter Communications Carey Ransone, Outside Consultant for Charter Communications Victoria Jeffries, Outside Counsel for Netflix Robert Loube, Outside Consultant for Maine Office of Public Advocate Andrew W. Guhr, Outside Counsel for DISH Network Andrew Crain, Outside Counsel for CenturyLink Joshua Bobeck, Outside Counsel for RCN Telecom Jessica Feinberg Greffenius, Outside Counsel for Comcast Federal Communications Commission DA 14-1605 9 Brenna Sparks, Outside Counsel for Comcast Michael DeCesant, Outside Counsel for Comcast Daniel Schmierer, Outside Counsel for Comcast Andrew Hanebutt, Outside Counsel for Comcast Dennis Carlton, Outside Counsel for Comcast Nauman Ilias, Outside Counsel for Comcast Mary C. Albert, In-house attorney at COMPTEL Kimberly Lippi, In-house attorney at California Public Utilities Commission Niki Bawa, In-house attorney at California Public Utilities Commission Simon Litkouhi, In-house consultant at California Public Utilities Commission Sefanie Alonso-Frank, Outside Counsel to AT&T William E. Cook, Outside Counsel to AT&T Brett Farley, Outside Counsel to AT&T Scott Feira, Outside Counsel to AT&T Matthew Gessesse, Outside Counsel to AT&T Patrick J. Grant, Outside Counsel to AT&T Heather A. Hosmer, Employee to Outside Counsel to AT&T Maureen R. Jeffries, Outside Counsel to AT&T Michael K. Levin, Outside Counsel to AT&T Peter J. Levitas, Outside Counsel to AT&T Lauren E. Manning, Outside Counsel to AT&T Thomas Dallas McSorley, Outside Counsel to AT&T Wilson Mudge, Outside Counsel to AT&T Karen Otto, Outside Counsel to AT&T Stephanie M. Phillips, Outside Counsel to AT&T Mary Dixon Raibman, Outside Counsel to AT&T Brian Ribblett, Employee to Outside Counsel to AT&T Eric T. Rillorta, Outside Counsel to AT&T Richard L. Rosen, Outside Counsel to AT&T Martha San Jose, Employee to Outside Counsel to AT&T Peter J. Schildkraut, Outside Counsel to AT&T Kelly Schoolmeester, Outside Counsel to AT&T Kelly Smith Fayne, Outside Counsel to AT&T Charles Thornton, Employee to Outside Counsel to AT&T William R. Zema, Jr., Employee to Outside Counsel to AT&T Olivier Antoine, Outside Counsel to AT&T Britton D. Davis, Outside Counsel to AT&T Shawn Johnson, Outside Counsel to AT&T W R Smith, Outside Counsel to AT&T Jeanne A. Thomas, Outside Counsel to AT&T Ryan Tisch, Outside Counsel to AT&T Michael Van Ardsall, Outside Counsel to AT&T Kristen Walker, Employee to Outside Counsel to AT&T Adam J. Di Vincenzo, Outside Counsel to AT&T M. Sean Royall, Outside Counsel to AT&T G. Charles Nierlich, Outside Counsel to AT&T Jason Stavers, Outside Counsel to AT&T Jay Srinivasan, Outside Counsel to AT&T Christopher T. Shenk, Outside Counsel to AT&T James P. Young, Outside Counsel to AT&T Federal Communications Commission DA 14-1605 10 Karen Kazmerzak, Outside Counsel to AT&T Rishi P. Chhatwal, Outside Counsel to AT&T Evan Leo, Outside Counsel to AT&T Aaron M. Panner, Outside Counsel to AT&T Joseph J. Matelis, Outside Counsel to AT&T Theresa Sullivan, Outside Consultant to AT&T Eugene Orlov, Outside Consultant to AT&T Carolina Czastkiewicz, Outside Consultant to AT&T Jeffrey Raileanu, Outside Consultant to AT&T Ka Hei Tse, Outside Consultant to AT&T Alex Asancheyev, Outside Consultant to AT&T Emmett J. Dacey, Outside Consultant to AT&T Gloriana Alvarez, Outside Consultant to AT&T Aren Megerdichian, Outside Consultant to AT&T Stephanie Janin Wimer, Outside Consultant to AT&T Benjamin Xiao, Outside Consultant to AT&T Robert Bourke, Outside Consultant to AT&T Alice Kaminski, Outside Consultant to AT&T Paolo Remezzana, Outside Consultant to AT&T Robert Oandasan, Outside Consultant to AT&T Michael L. Katz, Outside Consultant to AT&T Andres V. Lerner, Outside Consultant to AT&T Michael Kellogg, Outside Counsel for AT&T Barbara Wootton, Outside Counsel for AT&T Sarretta McDonough, Outside Counsel for AT&T Brian Robison, Outside Counsel for AT&T Sara Razi, Outside Counsel for DIRECTV Adrienne Fowler, Outside Counsel for DIRECTV Kara Trivolis, Outside Counsel for DIRECTV Caitlin-Jean Juricic, Outside Counsel for DIRECTV William Wiltshire, Outside Counsel for DIRECTV Thomas Hubbard, Outside Counsel for DirecTV Joe Sims, Outside Counsel for DirecTV Bin Chen, Outside Counsel for DirecTV Jarrod Welch, Outside Counsel for DirecTV Thomas J. Forr, Outside Counsel for DirecTV Steven Salop, Outside Consultant for DirecTV Kristine Devine, Outside Counsel for DirecTV Bruce McDonald, Outside Counsel for DirecTV Kevin J. Arquit, Outside Counsel for DirecTV Federal Communications Commission DA 14-1605 11 Inside Counsel and Consultants Carmelia L. Miller, In-House Counsel for The Greenlining Institute Stephanie Chen, In-House Counsel for The Greenlining Institute Paul Goodman, In-House Counsel for The Greenlining Institute Matthew F. Wood, In-House for Free Press S. Derek Turner, In-House for Free Press Lauren M. Wilson, In-House for Free Press Helen M. Mickiewicz, In-House Counsel for California Public Utility Comm'n William C. Black, In-House Counsel for Maine Office of Public Advocate Wayne Jortner, In-House Counsel for Maine Office of Public Advocate Timothy Schneider, In-House Counsel for Maine Office of Public Advocate