Federal Communications Commission
Washington, D.C. 20554
May 25, 2017
PA 17-520
John T. Nakahata
Henry Shi
Harris, Wiltshire & Grannis LLP
Counsel for Telcordia Technologies, Inc. d/b/a/ iconectiv
1919 M Street NW, Eighth Floor
Washington, DC 20036
Rebekah P. Goodheart
David A. Wishnick
Jenner & Block LLP
Counsel for Francisco Partners, LP
1099 New York Ave., NW
Suite 900
Washington, DC 20001
Tara O'Neill Diaz
Executive Vice President & General Counsel
Telcordia Technologies, Inc. d/bIaI iconectiv
444 Hoes Lane
Piscataway, NJ 08854
Re: Request of Telcordia Technologies, Inc. d/b/a iconectiv to Approve Mod?flcations to the
Local Numbering Portability Administrator Code of Conduct and the Ericsson Voting Trust,
and, ?fNecessa!y, the Minority Investment by FP Icon Holdings, L.P. WC Docket Nos. 07-
149 and 09-109; CC Docket No. 95-116)
Dear Counsel,
On March 31, 2017, Telcordia Technologies, Inc. dlbla iconnectiv, and FP-Icon Holdings, L.P.,
filed a request for the Commission to approve modifications to the Local Numbering Administrator Code
of Conduct and voting trust held by Ericsson Holdings II, Inc., a subsidiary of Telefonaktiebolaget LM
Ericsson.' To permit the Commission to review this request and make the necessary neutrality and
impartiality determinations, we require additional information from parties in interest to this request.
'Request of Telcordia Technologies, Inc. dlb/a iconectiv to Approve Modifications to the Local Numbering
Portability Administrator Code of Conduct and the Ericsson Voting Trust, and, if Necessary, the Minority
Investment by FP Icon Holdings, L.P, WC Docket No. 07-149 et al at 1 (filed Mar. 31, 2017).
Accordingly, pursuant to Section 251(e)(1) of the Act, and 47 C.F.R. § 52.12, we request you
provide written responses for each Information Request set forth in the attached Information requests and,
where appropriate, amend the Application to reflect such responses. Please respond to the attached
Information and Documentation Requests by June 9, 2017.
Submit responses to these Information and Documentation Requests in both paper and electronic
form, unless only electronic form is specified. Submit responsive documents in electronic form only,
unless otherwise specified. Your responses should be filed with Marlene H. Dortch, Secretary, Federal
Communications Commission, under the following dockets: WC Docket Nos. 07-149 and 09-109, and
CC Docket No. 95-116. We also request that you provide Michelle Sclater, Michelle.Sc1atercfcc.gov,
and Neil Dellar, Neil.De1larfcc,gov, with one copy of all paper and electronic materials filed in
response to the Information Requests.
Should you have any questions regarding this matter, please contact Michelle Sc later at 202-418-
0388 or Miche1ie.Sclater@fcc.gov .
Sincerely,
is Anne Monteith
Chief
Wireline Competition Bureau
Attachment
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ATTACHMENT
INFORMATION AND DOCUMENTATION RJQUEST
1. Please identify the individual or individuals who advise and manage Francisco Partners ("FP"). With
respect to each such individual identified, please state whether they manage any other
funds/investments and, if so, whether such other funds/investments are affiliated with
Telecommunications Service Providers (each a "TSP").
2. Please identify the individual(s) who owns the General Partner/corporation that is the ultimate parent
of FP. With respect to each such individual identified, please identify their ownership interests in any
TSPs.
3. Page 5 of the Request.2 Of the 87 portfolio companies in which PP invests, please identify those that
are associated with the telecommunications industry (e.g., TSPs, equipment manufacturers, managed
service providers etc.) and the size of the investment, in percentage terms, that FP owns, if any.
4. Are any limited partners affiliated with TSPs? If so, please identify the limited partner, the TSP with
whom he is affiliated, and the amount of the investment in percentage terms.
5. Please provide a copy of the section(s) of the FP Investors' Limited Partnership Agreement that
provides for the insulation of the limited partners.
6. What is the purpose of the requirement that the Independent Directors be "reasonably acceptable" to
FP Investors?
7. The independent directors' voting power is being reduced from a simple majority to a plurality.
Please explain how this reduction in voting power improves iconectiv's neutrality (assuming that
iconectiv needs protection from the influence of Ericsson and FP).
8. Page 9 of the Request refers to FP's "broad investments." Please describe in greater detail the nature
of FP's broad investments and how they ". . . do not present any potential concerns regarding undue
influence."
9. Page 5 of the Request states that FP invested $10 billion in 87 investments. Page 10 of the Request
speaks of $4 billion invested in 43 companies. Please clarify how much FP currently has invested
and in how many investments?
Please provide a copy of the Share Purchase Agreement.
10. Please explain further how the proposed revisions to Section 1.2 of the Voting Trust allow the
Trustees to vary the composition of the Board in a way that preserves the ratio of independent
directors to other board members as stated on page 18 of the Request?
11. Please explain the purpose and intent of adding Sections 1.3 (h) and (i) to the Voting Trust? Is it
anticipated that matters falling within those Sections would be approved by the Commission prior to a
vote or is it intended that the Commission would be given notice after the vote?
2 See Request of Telcordia Technologies, Inc. d/b/a iconectiv to Approve Modifications to the Local Numbering
Portability Administrator Code of Conduct and the Ericsson Voting Trust, and, if Necessary, the Minority
Investment by FP Icon Holdings, L.P, WC Docket No. 07-149 et al at 1 (filed Mar. 31, 2017).
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