General Information Request Regarding the AT&T/Qualcomm Transaction
Questions for Qualcomm
WT Docket No. 11-18
May 20, 2011
1. Provide an organization chart and personnel directory in effect since January 1, 2009, for 
Qualcomm as a whole and for each of Qualcomm’s facilities or divisions involved in any 
activity relating to any relevant product or relevant service.
2. On page 6 of the Public Interest Statement, the Applicants state that “the market has shown that 
the Lower 700 MHz D and E blocks cannot and will not be put to full and efficient use as stand-
alone one-way 6 MHz licenses.” On page 7 of the Public Interest Statement, the Applicants state 
that “there is a risk that the unpaired Lower 700 MHz D and E blocks will remain under-utilized 
unless they can be used in conjunction with other paired spectrum to enhance broadband 
capacity.”  Provide all documents discussing how to make use of this spectrum and efforts by 
standard-setting organizations and equipment manufacturers to facilitate use, including 
documents discussing the efforts of existing licensees of the Lower 700 MHz Band, including D 
and E block licensees.
3. On page 2 of the Public Interest Statement, the Applicants state that “after an exhaustive review 
of its strategic options, Qualcomm determined that this business model was not viable and 
decided to shut down that business and sell the spectrum.”  Page 3 of the Declaration of David 
Wise states that these options “included, but were not limited to, operating the FLO TV network 
under a new wholesale service; sale to, or joint venture of the FLO TV business with, a third 
party; and/or the sale of the Qualcomm Spectrum and the discontinuance of the operation of the 
network.”  Explain these statements in detail including, for example, what prompted the 
decision, any discussion with AT&T regarding MediaFLO, and all the options for a business 
model for Qualcomm’s spectrum, including a discussion of the advantages and disadvantages of 
each option that was considered.  Provide all documents discussing these issues.
4. Page 3 of the Declaration of David Wise states that “Qualcomm solicited bids for the Qualcomm 
spectrum from various carriers.  Qualcomm also discussed a potential sale of the FLO TV 
business (including network and spectrum) with a variety of companies in the 
telecommunications and media industries.  Finally, Qualcomm discussed the sale of a majority 
equity interest in FLO TV Incorporated with certain parties.”  Explain these statements in detail 
and discuss all the options that were considered for the sale of Qualcomm’s spectrum, including 
the names of the companies that were approached and the companies that submitted bids or 
otherwise expressed interest in acquiring the Qualcomm spectrum.  Provide all documents 
discussing this issue.
5. Explain and provide all documents discussing communications between AT&T and Qualcomm 
concerning AT&T’s proposed merger with T-Mobile, including the negotiations leading to that 
proposed merger.  Explain and provide all documents discussing Qualcomm’s assessment of the 
effect of the proposed AT&T/Deutsche Telekom-T-Mobile merger on the Proposed Transaction.
6. Provide all documents, data and analysis cited in the Public Interest Statement and the 
declarations of David Wise, Kristin S. Rinne, Professor Jeffrey H. Reed and Dr. Nishith D. 
Tripathi, and all documents and data relied upon in preparing those documents, grouped by 
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declaration/Public Interest Statement as stated in Instruction number 6.  To the extent the 
information has already been provided, specify the response to which it was also submitted.
7. Provide all documents discussing any valuations of Qualcomm’s spectrum assets. Include any 
valuations of Qualcomm’s spectrum assets in the absence of the proposed AT&T/Deutsche 
Telekom-T-Mobile merger, as well as any valuations assuming that proposed merger has been 
approved.  Provide all documents discussing the cost and relative valuation of any spectrum 
license Qualcomm considered acquiring or acquired.  
8. Provide all strategic plans, policies, analyses, reports and presentations discussing the Qualcomm 
spectrum and its expected use.
9. Provide all documents discussing presentations to management committees, executive 
committees, boards of directors, investors, investor analysts, and industry analysts regarding the 
effect of the Proposed Transaction, including the effect on AT&T’s spectrum constraints and 
business plans, (a) for circumstances as set forth in the Proposed Transaction (i.e., absent any 
AT&T/Deutsche Telekom-T-Mobile merger), and (b) for circumstances that assume the 
AT&T/Deutsche Telekom-T-Mobile merger has been approved.
10. Provide all strategic plans, policies, analyses, reports and presentations discussing how to 
evaluate and monitor capacity, including the amount of spectrum, speed of connection, and 
facilities (including, cell site configuration and backhaul) that are required to meet consumer 
demand.
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Definitions
1. The term “AT&T” means AT&T Inc., its parents, predecessors, divisions, subsidiaries, affiliates, 
partnerships and joint ventures, and all directors, officers, employees, agents, and representatives 
of the foregoing. The terms "parent", “subsidiary,” “affiliate,” and “joint venture” refer to any 
person in which there is partial (10 percent or more) or total ownership or control between the 
company and any other person.
2. The term “Qualcomm” means Qualcomm Incorporated, its parents, predecessors, divisions, 
subsidiaries, affiliates, partnerships and joint ventures, and all directors, officers, employees, 
agents, and representatives of the foregoing.  The terms "parent", “subsidiary,” “affiliate,” and 
“joint venture” refer to any person in which there is partial (10 percent or more) or total 
ownership or control between the company and any other person..
3. The term “Applicants” means AT&T Inc. and Qualcomm Incorporated, collectively.
4. The term “Application” means the application, File No. 0004566825, to which Exhibit 1 –Public 
Interest Statement is attached.
5. The terms “and” and “or” have both conjunctive and disjunctive meanings.
6. 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. 
7. The term “AT&T/Deutsche-Telekom-T-Mobile merger” means the proposed acquisition of T-
Mobile USA, Inc. by AT&T filed on April 21, 2011, with lead application file number for the 
wireless radio services listed as 0004669383. 
8. The term “CDMA” means Code Division Multiple Access technology.
9. The term “CMA” means Cellular Market Area.
10. The term “discussing” when used to refer to documents means analyzing, constituting, 
summarizing, reporting on, considering, recommending, setting forth, or describing a subject.  
Documents that contain reports, studies, forecasts, analyses, plans, proposals, evaluations, 
recommendations, directives, procedures, policies, or guidelines regarding a subject should be 
treated as documents that discuss the subject.  However, documents that merely mention or refer 
to a subject without further elaboration should not be treated as documents that discuss that 
subject. 
11. 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 
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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.
12. The term "EDGE" means Enhanced Data rates for GSM Evolution technology.
13. The term “GSM” means Global System for Mobile Communications technology.
14. The term “HSPA” or “HSPA+” means High Speed Packet Access or High Speed Packet Access 
+ technology.
15. The term “identify,” when used with reference to a Person or Persons, means to state his/her full 
legal name, current or last known business address, current or last known telephone number, 
current or last known organization, and position therewith. “Identify,” when used with reference
to a document, means to state the date, author, addressee, type of document (e.g., the types of 
document, as described above), a brief description of the subject matter, its present or last known 
location, and its custodian, who must also be identified. “Identify,” when used with reference to 
an entity other than a Person, means to state its name, current or last known business address, 
and current or last known business telephone number. 
16. The term "including" shall be construed as including, but not limited to, and indicates examples 
for the Applicants to address.  The term should not be construed as to limit the response to only 
those examples listed. 
17. The term “LTE” means Long Term Evolution technology.
18. The term “mobile wireless application,” also referred to as “application software” or “app,” 
means a computer system that enables one or more function on a mobile wireless device running 
a mobile operating system (e.g., Android, iOS).
19. The term “mobile wireless data services” means any data communications service using radio 
transmission between mobile or fixed stations and a network providing communication of packet 
data information, including but not limited to, broadband data, video, remote file access, status 
reporting, facsimile, and internet/intranet access.  Mobile wireless data services include non 
interconnected Voice over IP but exclude mobile wireless voice and text services, as defined 
herein.
20. The term “mobile wireless services” includes mobile wireless voice services, mobile wireless 
text services, mobile wireless data services, and mobile wireless applications.
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21. The term “mobile wireless text services” means any communications service using radio 
transmission between mobile or fixed stations and a network providing communication of 
numeric or alphanumeric messages, such as multi media messaging, short messaging, and short 
codes.  Mobile wireless text services exclude e-mails.
22. The term “mobile wireless voice services” means interconnected voice communications services 
provided using radio transmission between mobile or fixed stations on a wireless basis to 
customers, other than fixed wireless services.  Mobile wireless voice services include 
interconnected Voice over IP.
23. The term “MSAs” means Metropolitan Statistical Areas.
24. 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. 
25. 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.
26. The term "POPs" means total aggregate population.
27. The term “Proposed Transaction” means the proposed assignment of licenses held by Qualcomm 
to AT&T filed on January 13, 2011 with file number for the wireless radio services listed as 
0004566825.
28. The term “Public Interest Statement” refers to the document filed by the Applicants on January 
13, 2011 entitled “Description of Transaction, Public Interest Showing, and Related 
Demonstrations.”
29. The term “Reed and Tripathi Declaration” refers to the Joint Declaration of Professor Jeffrey H. 
Reed and Dr. Nishith Tripathi filed as an exhibit to the Applicants’ Joint Opposition filed on 
March 21, 2011. 
30. The term "relevant product" means (and information should be provided separately for, any of 
the mobile wireless services and using any of the following formats:  GSM, EDGE, UMTS only, 
HSPA, HSPA+, and LTE):
a. feature mobile devices: wireless handset devices that are cable of supporting voice 
services as well as text services;
b. 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);
c. iPhones: smartphones designed and marketed by Apple Inc.,;
d. 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, 
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cinematic, and audio-visual media player services (including books, periodicals, 
movies, music, games);
e. iPads: tablet PCs designed by Apple Inc.,;
f. 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;
g. “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;
h. 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
i. other mobile wireless devices not listed above.  Describe the other devices included 
in this category.
31. The term “relevant service” as used herein means (and information shall be provided separately 
for, any of the services identified below and using any of the following formats:  GSM, EDGE, 
UMTS only, HSPA, HSPA+, and LTE):
a. mobile wireless voice services;
b. mobile wireless text services; 
c. mobile wireless data services; and
d. mobile wireless applications
32. The term “Rinne Declaration” refers to the Declaration of Kristin S. Rinne, Senior Vice 
President – Architecture and Planning, AT&T Services, Inc. 
33. The term “RSAs” means Rural Service Areas.
34. The term “Spectrum Assets” means the six D block and five E block licenses in the Lower 700 
MHz band subject to the instant transaction.
35. The term “T-Mobile” or "T-Mobile USA, Inc." means Deutsche Telkom AG, its domestic and 
foreign parents, predecessors, divisions, subsidiaries, affiliates, partnerships, and joint ventures, 
and all directors, officers, employees, agents, and representatives of the foregoing.  The terms 
“parents”, “subsidiary,” “affiliate,” and “joint venture” refer to any person in which there is 
partial (10 percent or more) or total ownership or control between Deutsche Telekom and any 
other person.
36. The term “UMTS” means Universal Mobile Telecommunications System technology.
37. “United States” or “U.S.” means the United States, its possessions, territories, and outlying 
areas. 
38. The term “Wise Declaration” refers to the Declaration of David Wise, Senior Vice President, 
Finance and Strategy of Qualcomm, Incorporated.
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Instructions
1. Unless otherwise specified, all Information and Document Requests cover the period from January 1, 
2009 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. 
5. Unless otherwise specified, provide data and interrogatory responses separately for prepaid, post-
paid, wholesale, and all mobile wireless services. 
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). Group submitted materials according to the request number 
to which they are responsive and then, within each of those request-number groupings, by the 
appropriate custodian.  If a document is responsive to more than one request, submit the document in 
response to the first request to which it is responsive, and, in accordance with instruction 7 below, 
indicate in the metadata accompanying the document’s electronic record all subsequent requests to 
which it also is responsive.  If any document is not dated, if known, state the date on which it was 
prepared. If any document does not identify its author(s) or recipient(s), provide, if known, the 
name(s) of the author(s) or recipient(s) as metadata in accordance with Instructions for Submission 
of Electronic Documents.    The Company must identify with reasonable specificity all documents 
provided in response to these requests. Where more than one identical copy of a requested document 
exists, the Company may submit only one representative copy, but in all cases all metadata, 
including without limitation all custodians who possessed identical documents withheld, must be 
provided in accordance with the provisions of Instructions for Submission of Electronic Documents.
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. 
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8. Any documents that are withheld in whole or in part from production based on a claim of privilege 
shall be assigned document control numbers (with unique consecutive numbers for each page of each 
document).  For any page of any Document that the Company has designated to be withheld as 
entirely privileged, the Company shall submit a substitute, placeholder page that lists only the 
Document ID of the page that was withheld in entirety as privileged and a statement indicating that 
the page has been withheld in entirety as privileged.  For any document withheld as entirely 
privilege, it is sufficient to supply one substitute, placeholder page for that document, so long as the 
range of Document IDs for the entire document is listed on the placeholder page and each Document 
ID for each page of the document is reflected in metadata.  The placeholder pages must be OCR’d as 
any other paper record, as described above.  For each document withheld as privileged, whether in 
entirety or in part, the Company shall code the substitute document submitted as specified in and 
provide as metadata the information in the attached MetaData Table of Requested Fields. 
9. For each Document identified on the Company privilege log:
A) Provide the document control number(s);
B) Identify all authors of the document;
C) Identify all addressees of the document;
D) Identify all recipients of the document or of any copies of the document,
to the extent not included among the document’s addressees;
E) Provide the date of the document;
F) Provide a description of the subject matter of the document;
G) State the nature or type of the privilege that the Company is asserting for the document (e.g., 
“attorney-client privilege”);
H) Provide the number(s) of the Request to which the document is responsive;
I) Provide the document control number(s) of any attachments to the document, regardless of 
whether any privilege is being asserted for such attachment(s); and
J) State whether the document has been produced in redacted form, and include the range of 
Document ID labels for those produced documents. 
10. The Company’s privilege log shall also conform with all of the following requirements:
A) Provide a separate legend identifying each author, addressee, and recipient identified on the 
Company’s privilege log.
B) Identify on the privilege log, and denote with an asterisk, all attorneys acting in a legal 
capacity with respect to the withheld document or communication.
C) The description of the subject matter of each document shall describe the nature of the 
document in a manner that, though not revealing information that is itself privileged, 
provides sufficiently detailed information to enable the Commission to assess the 
applicability of the privilege claimed.
D) For each document withheld under a claim that it constitutes or contains attorney work 
product, also state whether the Company asserts that the document was prepared in 
anticipation of litigation or for trial and, if so, specify the anticipated litigation or trial upon 
which the assertion is based.
E) Produce all nonprivileged portions of any responsive document (including nonprivileged or 
redactable attachments) for which a claim of privilege is asserted, except where the only 
nonprivileged information in the document has already been produced. Note where any 
redactions in the document have been made.
F) The privilege log shall be produced in both hardcopy and electronic form, the electronic 
form of which shall be both searchable and sortable.
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G) Documents sent solely between counsel, including in-house counsel acting solely in a legal 
capacity, and documents authored by the Company’s outside counsel that were not directly 
or indirectly furnished to any third party, such as internal law firm memoranda, may be 
omitted from the privilege log. However, any attachments to such documents must be 
included on the privilege log (if a privilege is applicable to such materials), unless such 
attachments are addressed and sent solely to counsel. 
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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.  
2. Each submission shall be accompanied by an index, in hard copy and electronic form, 
detailing what has been produced, by custodian and Bates number, along with information to confirm that the 
Commission has received everything that you intended to send.
3. To minimize any delay in loading your submissions, each submission shall be as large as 
practical under these specifications, while also maintaining a timely and rolling production.  However, load 
file volumes shall not contain more than 100,000 records.
4. Subsequent submissions shall not include information produced in previous submissions, 
unless specifically requested by the Commission.
5. The submission preferably shall be on a portable hard drive or DVD-ROM, depending on the 
volume, appropriately labeled with the submission(s) contained on the media. The Commission cannot 
return any submission, nor can it accept productions over the Internet.
6. A web-based, hosted production is not likely to be possible due to technical issues related to 
the Commission’s firewall.
B.  Document Types
1. Hard-copy (or paper) documents.
(a) Except as otherwise agreed, hard-copy documents shall be produced as image files 
with related searchable OCR text and bibliographic information.
(b) Some documents may more appropriately and efficiently be produced in hard-copy 
form (e.g., maps).
(c) Special care should be taken to properly unitize documents, maintain attachment 
relationships, and indicate file folder or binder labels, consistent with the Definitions and 
Instructions.
2. E-mail and Other Electronic Messages.
(a) E-mail and other electronic messages (e.g., instant messages (“IMs”)) shall be 
produced as image files with related searchable text and metadata and bibliographic information.
(b) Each IM conversation shall be produced as one document.
(c) E-mail metadata shall include the folderpath (“folder” field) information for e-mail file 
folders into which a custodian’s e-mail messages have been organized. Be sure to preserve and 
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produce this information as specified. Beware of copying e-mails into an electronic repository or 
forwarding them to a central e-mail box, as such processes may destroy this information. See also 
infra Section C(2) regarding custodian metadata.
(d) Depending on how the Company’s systems represent names in e-mail messages or 
IMs, the Commission may require a table of names or contact lists.
3. Spreadsheets shall be produced in native format (e.g., .XLS files) with the first page imaged 
and with related searchable text and metadata and bibliographic information.
4. Presentations.
(a) Presentations shall be produced as images that show the full slide images and speaker 
notes, with related searchable text and metadata and bibliographic information.
(b) Presentations shall also be produced in native format (e.g., .PPT files).
5. Word processing and other electronic documents not specifically addressed elsewhere in this 
letter shall be produced as image files with related searchable text and metadata and bibliographic 
information.
6. Databases.
(a) This letter does not address enterprise databases which may be responsive to the 
Information and Document Requests and should be the subject of a separate discussion once you 
have identified them.
(b) Smaller databases (e.g., Microsoft Access) that are responsive should be produced, but 
not as part of the load-file production. Such databases should be produced separately. 
7. Company Intranets and Social Networking Sites.
(a) If the Company’s intranet or company social networking content (e.g., Facebook, 
Twitter) contains responsive information, production of these items should be the subject of a 
separate discussion.
(b) Depending on the nature of the information, it may be appropriate to provide the 
Commission direct access to the Company’s intranet via a secure Internet connection, but significant 
technical issues are often involved.
8. Embedded files with no substantive content (e.g., corporate logos, executive
“head-shot” photographs, stationery address blocks), which would appear in the production as an otherwise 
blank and therefore unresponsive “TIFF” image, should not be produced. 
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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 you are collecting this information when collecting responsive documents. If the Company stores 
documents in a repository that does not maintain personal custodian or filepath information (e.g., that 
“journals” e-mails), it shall be required to stipulate to custodian identities for purposes of using documents.  
3. In certain circumstances, a custodian may be a shared resource (e.g., shared drive or server, 
shared filing cabinet). Materials gathered from such repositories, to which multiple people have access, shall 
be produced as separate custodians. The Company shall provide a brief description of each shared resource 
that includes a list of the employees who have access to that shared resource. The documents in shared 
resources should otherwise be produced as described in the rest of this letter. (Personal share or server drives 
are not shared resources and shall be produced as part of each human custodian’s files.)
4. Native Format Files
(a) If any native files will be produced that cannot be viewed using the standard 
configuration of Microsoft Office 2007, Adobe Acrobat Reader 9, WordPerfect X4, or Internet 
Explorer 7, you will need to notify the Commission so it can determine whether it has the 
appropriate software and licenses to view those files. If it does not, it may be necessary for the 
Company to provide that software.
(b) Any encryption or password protection shall be removed from all native format files 
produced.
5. Images and Text Files
(a) Images of the produced electronic documents shall conform with any further 
specifications provided by the Commission.
(b) Searchable OCR and extracted text from the produced electronic documents shall 
conform with any further specifications provided by the Commission.
(c) Care should be taken to ensure that the text files will properly format and wrap.
(d) If any document cannot be interpreted in image/text format (e.g., color, Microsoft 
Project), the Commission may request that it be produced natively, or the Company can contact the 
Commission to discuss producing them natively. As noted above in C(4)(a), the Company may need 
to provide the appropriate software in order for the Commission to view these documents.
6. Deduplication
(a) The Company shall deduplicate vertically within each custodian’s files.
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(b) The Commission prefers that the Company also deduplicate horizontally across all 
custodians’ files, but only if:
(i) the deduplication methodology preserves information on BCC recipients of e-
mail;
(ii) custodian information from suppressed duplicates can be preserved and 
produced as a custodian append file; and
(iii) the Company, prior to beginning its production, provides a written description 
its deduplication methodology, including how custodial and BCC information shall be 
preserved and produced, to which the Commission agrees. 
(c) The Company must produce all members of a family of documents (see C(1)) and 
cannot suppress attachments to other documents. In other words, the integrity of families of 
documents must be maintained, except as limited by any claim of privilege.
(d) The Company agrees not to raise any objections to the Commission’s use of the 
produced duplicate in relation to whether it was in the files of the custodians who had the suppressed 
duplicates in their files or were the sender or recipients of any e-mail.
7. Privilege Designations
(a) Documents redacted pursuant to any claim of privilege shall be designated “Redacted” 
in the Properties field in the metadata and bibliographic information provided. The Company shall 
provide appropriately redacted related searchable text, metadata, and bibliographic information for 
these documents.
(b) Documents withheld pursuant to any claim of privilege that are part of a document 
family shall include a designation of “Family Member of Priv Doc” in the Properties field in the 
metadata and bibliographic information provided for all the other documents in its family. A 
placeholder image with a Bates number should be provided in place of the document.
(c) Both redacted and withheld documents shall appear on the privilege log. Each 
withheld document from a family shall include the family Bates number range in its entry on the 
privilege log.
8. Bates Numbering
(a) A consistent format for Bates numbering shall be used across the entire production.
Bates 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) Bates numbers should not contain embedded spaces (“ ”), slashes (“/”), backslashes 
(“\”), or underscores (“_”). Bates numbers may contain hyphens (“-”).
(c) Native format files should be assigned a Bates number; if images have been produced 
with a native format file, the beginning Bates number of the images should be the native format file’s 
Bates number.
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9. These instructions do not address or endorse any search method the Company may use to 
identify responsive electronic documents.
10. In order to ensure the Company’s full technical and procedural compliance with these 
instructions, the Company shall make its Information Technology personnel and those of its vendors 
available to Commission staff for consultation and coordination before, during, and after its production of 
materials responsive to the requests.
D.  Sample Submission Required Prior to Full Production
In consultation with Commission staff, the Company shall submit a test submission to ensure proper 
configuration of data for uploading into the Commission’s Summation Enterprise database server before the 
Company “ramps up” production. To minimize the likelihood of encountering problems during full 
production, the sample must be representative of an actual production, including multiple types of 
documents, documents with attachments (“families”), document families from which an item has been 
removed pursuant to privilege (and replaced with a Bates-numbered, placeholder image), redacted 
documents with appropriately related searchable text, and presentation documents with speaker notes.
15
FIELD LISTING FOR SUMMATION METADATA LOAD FILE TYPE OF RECORD(S) TO WHICH EACH FIELD APPLIES
Field 
Name Field Description
Field 
Type
Hard 
Copy
E-
Mail
Spreadsheets 
and 
Presentations
Other E-Docs 
(all 
Attachments, 
Calendar 
Appts, Loose 
Files
COMPANIES Company submitting data Multi-Entry x x x x
SUBMISSION# Production volume number (e.g., ABC001) Note Text x x x x
REQUEST# Request(s) to which the document is responsive Multi-Entry x x x x
CUSTODIAN Custodian(s) / source(s) -- format: Last, First or ABC Dept Multi-Entry x x x x
BEGDOC#
Start Bates (including prefix) -- do not use 
commas, underscores, ampersands, 
slashes, spaces, characters not allowed in 
Windows file names or any character used 
as a delimiter in the load files as part of this 
number
Note Text
x x x x
ENDDOC#
End Bates (including prefix) -- do not use 
commas, underscores, ampersands, 
slashes, spaces, characters not
allowed in Windows file names, or any 
character used as a delimiter in the load file 
as part of this number
Note Text
x x x x
DOCID Must equal the value appearing in the BEGDOC# field Note Text x x x x
NUMPAGES Page count Integer x x x x
PARENTID Parent record's BEGDOC#, including prefix 
(populated ONLY in child records)
Note Text x x x x
ATTACHMENTIDS Child document list: BEGDOC# of each child 
(populated ONLY in parent records)
Multi-Entry x x x x
BATESRANGE BEGDOC# value of the parent record and 
ENDDOC# value (including prefix) of the last 
child record (for example,
ABC-001 - ABC-020); populated for all 
documents in the group - otherwise, remains 
empty
Note Text
x x x x
EPROPERTIES Indicate All That Apply :
Record Type: Loose File, E-mail, 
Attachment, Hard Copy, Calendar Appt
Privilege Notations: Redacted, Privileged, 
Family Member of Priv Doc
Multi-Entry
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 (Y/N) Note Text x x x x
FROM Author of the e-mail or loose electronic file 
(as formatted on the original)
Note Text x x x
TO Recipients of the e-mail (as formatted on the 
original)
Multi-Entry x
CC Names of the individuals who were copied 
on the e-mail (as formatted on the original)
Multi-Entry x
BCC Names of the individuals who were blind-
copied on the e-mail (as formatted on the 
original)
Multi-Entry
x
SUBJECT E-mail or calendar subject, or electronic file's 
document title
Note Text x x x
DATESENT Date the e-mail was sent - YYYYMMDD Date x
TIMESENT Time e-mail was sent -- HH:MM am/pm (e.g., 
09:32 am; Timezone indicators cannot be 
included)
Time
x
DATERECEIVED Date e-mail was received - YYYYMMDD Date x
TIMERECEIVED Time e-mail was received -- HH:MM am/pm Time x
HEADER The internet header information for e-mail 
sent through the internet;
Note Text x
INTERNETMSGID Internet message identification number Note Text x
MESSAGEID Unique system identification number for the 
e-mail message
Note Text x
DATECREATED Date electronic file was created -
YYYYMMDD
Date x x
DATESAVED Date electronic file was last modified -
YYYYMMDD
Date x x
DOCDATE Populate with: DATESAVED for electronic 
files (loose files and e-mail attachments) ; 
DATESENT for e-mails; or
DATEAPPTSTART for calendar 
appointments - YYYYMMDD
Date 
Keyed
x x x x
DATEAPPTSTART Start date of calendar appointment -
YYYYMMDD
Date x
TIMEAPPTSTART Start time of calendar appointment - HH:MM 
am/pm
Time x
16
DATEAPPTEND End date of calendar appointment -
YYYYMMDD
Date x
TIMEAPPTEND End time of calendar appointment -- HH:MM 
am/pm
Time x
FILESIZE File size (numeric value only - do not include 
unit of measure)
Integer x x x
ATTACHTITLE File name of an e-mail, e-mail attachment, or 
loose electronic document
Note Text x x x
APPLICATION Application used to create native file (e.g., 
Excel, Outlook, Word)
Note Text 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 original 
environment
Note Text x x x
DOCLINK Current file path location to the native file (on 
the delivery medium)
Note Text x
FOLDER E-mail folder path (sample: Inbox\Active); or 
Hard Copy folder/binder title/label
Note Text x x
HASHMD5 MD5 hash value (used for deduplication or 
other processing)
Note Text x x x
HASHSHA SHA1 hash value (used for deduplication or 
other processing)
Note Text x x x
SEARCHVALUES List of search terms used to identify record 
as responsive (if used)
Multi-Entry x x x x