Federal Communications Commission
Washington, D.C. 20554
May 1,2012
Via US. Mail and Electronic Mail
Michael Samsock
Celico Partnership dba Verizon Wireless
1300 I Street, NW
Suite 400
Washington, DC 20005
Steven Teplitz
Senior Vice President, Government Affairs
Time Warner Cable Inc.
901 F Street, N.W. Suite 800
Washington, DC 20004
David Don
SpectrumCo, LLC
300 New Jersey Avenue, N.W., Suite 700
Washington, DC 20001-2030
Lynn Charytan
Vice President, Legal Regulatory Affairs
and Senior Deputy General Counsel
Comcast Corporation
300 New Jersey Avenue, N.W., Suite 700
Washington, DC 20001-2030
Bright House Networks, LLC
Attn: Cody Harrison
Sabin, Bermant & Gould LLP
Four Times Square
New York, NY 10036
Jennifer Hightower
Cox TMI Wireless, LLC
1400 Lake Heam Drive
Atlanta, GA 30319
Re: Applications of Celico Partnership d/bla/ Verizon Wireless, SpectrumCo,
LLC, and Cox TMI Wireless, LLC for Consent to Assign Wireless Licenses,
WT Docket No. 12-4
Dear Ms. Charytan, Mr. Don, Mr. Harrison, Ms. Hightower, Mr. Samsock, and Mr. Teplitz:
On March 8, 2012, we issued Requests for Information to Ceilco Partnership d/b/aJ
Verizon Wireless, the constituent entities of SpectrumCo, LLC, and Cox TMI Wireless, LLC
(all, collectively, the "Applicants").' We asked the Applicants to provide documents and other
information responsive to the Requests no later than March 22, 2012.
1 Letter from Rick Kaplan, Chief, Wireless Telecommunications Bureau, FCC, to Michael Samsock, Ceilco
Partnership, dlb/a Verizon Wireless, WT Docket No, 12-4 (Mar. 8, 2012); Letter from Rick Kaplan, Chief, Wireless
Telecommunications Bureau, FCC, to David Don, SpectrumCo, LLC, WT Docket No. 12-4 (Mar. 8, 2012); Letter
from Rick Kaplan, Chief, Wireless Telecommunications Bureau, FCC, to Jeimifer Hightower, Cox TMI Wireless,
LLC, WT Docket No. 12-4 (Mar. 8, 2012); Letter from Rick Kaplan, Chief, Wireless Telecommunications Bureau,
FCC, to Lynn Charytan, Vice President, Legal Regulatory Affairs and Senior Deputy General Counsel, Comcast
Corporation, WT Docket No. 12-4 (Mar. 8, 2012); Letter from Rick Kaplan, Chief, Wireless Telecommunications
Bureau, FCC, to Bright House Networks, LLC, Attn: Cody Harrison, Sabin, Bermant & Gould LLP, WT Docket
No. 12-4 (Mar. 8, 2012); Letter from Rick Kaplan, Chief, Wireless Telecommunications Bureau, FCC, to Steven
Teplitz, Senior Vice President, Government Affairs, Time Warner Cable Inc., WT Docket No. 12-4 (Mar. 8, 2012).
May 1,2012
Page 2
None of the Applicants completed a responsive production by March 22. Indeed, nearly
two-thirds of the responsive documents the Applicants have submitted to date were submitted
after April 6, and more than half of the Applicants' total production was submitted after April 19.
Verizon Wireless, for example, responded to the Requests with a production of approximately
4,000 documents as of April 5. But in light of deficiencies Commission staff identified in that
initial production, the company's response grew to more than 50,000 documents as of April 27.
Cox and Bright House Networks did not submit the great majority of responsive documents in
proper form until April 24.
In addition, other parties to the proceeding have complained of various problems they
have encountered when attempting to gain access to the Applicants' documents.2 The Applicants
have responded that these allegations lack merit or are "unspecified."3 Nevertheless, on April
30, 2012, the Applicants filed an exparte letter in which they committed to go beyond the
requirements of the Commission's orders in this matter by taking additional steps to facilitate
third-party review of the record materials.4 We anticipate that these steps will assist access to the
productions.
The Applicants' untimely productions have delayed staff's review of the proposed
transactions by at least three weeks. Other parties' document reviews have been affected as well.
To account for this delay, we are extending the Commission's informal 180-day transaction
review period by 21 days. Assuming the adequacy of the current productions in response to the
Requests, we do not anticipate further extension of the 180-day period on account of the matters
discussed above.
2 Letter from Monica Desai, Patton Boggs LLP to Marlene H. Dortch, Secretary, FCC, WI Docket 12-4 (April 20,
2012); Letter from William Wiltshire, Wiltshire Grannis LLP, Patrick Morse, Fairpoint Communications, Derek
lurner, Free Press, Andrew Schwartzman, Media Access Project, Michael Calabrese, Open lechnology Initiative,
Harold Feld, Public Knowledge, Michael Lazarus, lelecommunications Law Professionals PLLC, Caressa Bennet,
Rural lelecommunications Group, Inc., Antoinette Cook Bush, Skadden, Arps, Slate, Meagher & Flom LLP to
Marlene H. Dortch, Secretary, FCC, WI Docket 12-4 (April 24,2012).
Letter from John Scott, III, Verizon, Daniel Brenner, Hogan Lovells US LLP, Matthew Brill, Latham & Watkins
LLP, Michael Hammer, Wilikie Fan & Gallagher LLP, J. G. Harrington, Dow Lohnes PLLC to Marlene Dortch,
Secretary, FCC, WI Docket 12-4 (April 25, 2012).
Letter from Nancy J. Victory, Wiley Rein LLP, Michael H. Hammer, Willkie Fan & Gallagher LLP, Robert G.
Kidwell, Mintz Levin, J. G. Harrington, Dow Lolmes PLLC, and Matthew Brill, Latham & Watkins LLP to Marlene
H. Dortch, Secretary, FCC, WI Docket No. 12-4 (April 30, 2012) (describing steps including making documents
available for review in searchable format using database review software in Washington, D.C. offices, providing
PDF versions of the production, and providing an index in searchable and sortable electronic form).
May 1,2012
Page 3
Please do not hesitate to contact me should you have any questions concerning the
foregoing.
Sincerely,
Rick Kaplan
Chief, Wireless Telecommunications Bureau
cc: Joim T. Scott, III, Verizon Wireless
Michael G. Jones, Wilikie Fan & Gallagher LLP
Michael H. Hammer, Willkie Fan & Gallagher LLP
Matthew Brill, Latham & Watkins LLP
Daniel Brenner, Hogan Lovells US LLP
Christina H. Burrow, Dow Lobnes PLLC