WT Docket Number 13-54
INFORMATION AND DISCOVERY REQUEST FOR ALLIED
1. Provide an organization chart and personnel directory in effect for the Company as a whole and for each of 
the Company’s facilities or divisions involved in any activity relating to any relevant product or any 
relevant service.
2. The Applicants state that, “[o]n its own, Allied could not build a 4G network that rivals its competitors’ in 
speed and capacity, or deliver these products and services nearly as robustly or as quickly.”  (Public
Interest Statement at i.)  Further, the Applicants state that “Allied has struggled to adjust to these changed 
conditions primarily due to its fragmented footprint and limited spectrum depth.  Unlike other regional 
carriers, Allied operates 10 noncontiguous ‘island properties.’”  (Kreisher Declaration ¶ 7.)
a. Provide all plans, analyses, and reports (including any surveys conducted by the Company or third 
party) discussing how customers view and value the Company’s voice and data network quality, 
coverage, service plans, pricing, and promotions (including local promotions).  Additionally, provide 
all plans, analyses, and reports discussing levels of, and reasons for, churn.
b. Provide all documents discussing: 
i. actual or potential competition between the Company and any competing provider’s mobile 
wireless services (either individually or in the aggregate); 
ii. actual or potential competitive responses by your Company to any other provider of mobile 
wireless services, including but not limited to, new product introductions, pricing, 
promotions retail locations, service offerings, coverage, and network or technology 
upgrades; and/or
iii. spectrum need, spectrum exhaust, or capacity constraints, including attempts by the 
Company to purchase or lease spectrum or to pursue other partnership arrangements, 
including but not limited to, joint ventures or mergers.
3. The Applicants assert that Allied has explored offering 4G service, and that the Company discovered that 
its bandwidth constraints would limit it to offering low-end 4G service.  (Kreisher Declaration ¶ 13.)  
Provide all documents discussing the Company’s plans for introducing 4G service (as well as the 
particular technologies considered), including any discussing potential limitations.
4. In 2009, Allied represented that it was “committed to investing in the Divestiture Markets to expand and 
improve the scope of services for existing and new customers.” (ATN Response at 10, December 17, 
2009, Response to Question III.8.)  
a. Provide all plans, analyses, and reports discussing Allied’s efforts to effectuate this commitment, 
including upgrade and buildout plans.
b. For each relevant market, detail whether and to what extent Allied has expanded coverage or upgraded 
any part of the network.
c. Discuss any additional services or device offerings that Allied has introduced.  At this time, what 
percent of Allied’s customers have a 3G capable device? 
5. The Applicants emphasize the scattered, rural nature of Allied's footprint, asserting that Allied faces 
significant obstacles to serving customers on a going forward basis. (E.g., Public Interest Statement at 19.)  
Explain in detail the competitive decisions (pricing, device equipment availability, service plans, 
2promotions, coverage, retail locations, etc.) made by Allied at the national, regional, state, or local level, 
including a full description of any differences in the price of the plans, add-ons, promotions, retail 
operations, coverage or devices that depend on the geographic location of the subscriber.  Provide all 
documents relied on in preparing this response.  Further, explain how these obstacles have increased, if 
they have, since Allied acquired its licenses in 2010.
6. The Applicants argue that “[b]ecause 78 percent of Allied’s subscribers reside in a county on the edge of 
Allied’s licensed area, they roam more than other carriers’ customers.”  (Public Interest Statement at 11-
12.)  “Approximately 15 percent of calls placed by Allied’s customers are made off network.” (Public 
Interest Statement at 22.)  Further, the Applicants emphasize that as mobile broadband usage increases, the 
relatively higher use of data roaming by Allied’s customers will further increase its roaming costs relative 
to other service providers.  (Public Interest Statement at 22.) 
a. Provide all documents discussing the geographic distribution of subscribers, subscriber calling and 
mobile data usage activity, and incremental roaming costs of Allied subscribers.
b. Provide for each month, expenditures on voice and data services resulting from Allied subscribers 
roaming off your Company’s network.  Additionally, provide for each month, voice and data service 
revenues generated by other providers’ subscribers who roam on your Company’s network. 
c. Provide any financial models projecting subscribers, service revenues, and roaming expenses and 
revenues.
d. Describe in detail any increase in roaming expenditures and revenues since Allied acquired its licenses 
in 2010.
e. Provide copies of all current roaming and build-out agreements and any attachments in any relevant 
area and explain the Proposed Transaction’s effects on these agreements, including whether these 
agreements may be terminated early as a result of the Proposed Transaction; and
f. Explain whether any agreements would affect the proposed network transition in any relevant area.  
7. The Applicants contend that “[customer] movement on and off Allied’s network has resulted in degraded 
customer experiences at the edges of Allied’s service areas due to dropped calls, signal loss, etc., and these 
problems have led to significant churn.”  (Public Interest Statement at 21.)  Further, the Applicants state 
that “network quality at the edge of service areas is poor due to the difficulties of inter-network handoffs, 
resulting in a degraded customer experience” and that “[c]oncentrated efforts by Allied to mitigate the 
edge experience issues have yielded minimal success.”  (Kreisher Declaration ¶ 8.) Provide all plans, 
analysis, and reports discussing network quality issues, churn resulting from degraded network quality, 
and efforts taken by Allied to mitigate these issues.
8. The Applicants state that “Allied suffers inefficiencies created due to distances between its various 
noncontiguous operating areas and their atypical borders.”  In particular, Allied claims that “switching and 
interconnection infrastructure are inefficient and have unusually high associated expenses [, . . . ,] the 
company has redundant field network and sales expenses [, . . . ,] and advertising cannot be effectively 
targeted toward potential customers.”  (Public Interest Statement at 21.)  Additionally, the Company states
that “lack of scale and presence in major markets have also prevented it from securing distribution through 
major retail chains.”  (Kreisher Declaration ¶ 10.)  Further, the Company describes the difficulties in 
obtaining consumer devices.  (Kreisher Declaration ¶ 16.)  Provide all documents relied on in preparing 
these statements, as well as all plans, analyses, and reports discussing Allied’s:
3a. expenses resulting from its geographically dispersed markets and efforts made to mitigate these 
expenses; and
b. efforts made to obtain consumer devices and retail distribution.
c. Describe whether and, if so, how these inefficiencies have increased since Allied acquired its licenses 
in 2010.
9. Provide a list, in csv format, as of the date of this Request, for each county within each state of each 
spectrum license that can be used in the provision of mobile wireless services that the Company holds, has 
a joint venture or other business arrangement with regard to, leases from another person, has another 
interest in, manages, has contracted to acquire, or is in negotiations to acquire.  For each license, identify 
the: (a) FIPS Code; (b) county; (c) state; (d) market name; (e) market number (in the case of CMA, MTA, 
or BTA); (f) spectrum type; (g) spectrum block; (h) amount of spectrum; (i) the wireless technology 
format deployed or planned (e.g., GSM, EDGE, CDMA, EV-DO, EV-DO Rev. A, UMTS, HSPA, 
HSPA+, LTE); and (j) whether the Company: (i) holds; (ii) has a joint venture or other business 
arrangement with regard to; (iii) leases to or from another person; (iv) has an interest in; (v) manages; 
(vi) has contracted to acquire; (vii) is in negotiations to acquire; or (viii) plans to sell.  
10. Provide, as of the date of this Request, maps by bands of the geographic coverage of each relevant 
wireless service provided by the Company, distinguishing by technological format (e.g., GSM, EDGE, 
CDMA, EV-DO, EV-DO Rev. A, UMTS, HSPA, HSPA+, LTE).  Provide the maps in a geo-referenced 
format, such as a shapefile (for ArcMap) or table (for Maplnfo), and provide all assumptions, methodology 
(e.g., propagation, field measurements), calculations (including link budgets), tools (e.g., predictive and 
field measurements) and data (e.g., terrain, morphology, buildings) used in the production of the maps.  
11. Provide the Company’s monthly subscriber data, as specified in Attachment A. 
12. Provide the Company’s monthly porting data, as specified in Attachment B.
4Attachment A – Subscribers.csv
5Attachment B – Ports To and Ports From.csv
6Definitions
In this Information and Document Request, the following terms shall have the following meanings (such 
meanings to be equally applicable to both the singular and plural forms of the terms defined):
1. The terms “Company”, “Allied” or “ATN” mean Allied Wireless Communications Corporation, 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 the company and any other person.
2. 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.
3. The terms “and” and “or” have both conjunctive and disjunctive meanings.
4. 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. 
5. The term “Applicants” means AT&T and Allied, collectively.
6. The term “Application” means the applications submitted by AT&T and Allied on February 5, 2013, 
with the lead file number for the wireless radio services listed as 0005632405.
7. The term “BTA” means Basic Trading Areas.
8. The term “CDMA” means Code Division Multiple Access technology. 
9. The term “CMA” means Cellular Market Area.
10. The term “competitor” includes any actual or potential competition from any partnership, corporation 
(including a business trust), joint stock company, trust, unincorporated association, joint venture, limited 
liability company, or other entity in any relevant area for any relevant product. 
11. 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.   
12. 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 
7Company.  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 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. 
13. The term “EDGE” means Enhanced Data rates for GSM Evolution technology.
14. The term “EvDO” or “EvDO Rev. A” means Evolution-Data Optimized or Evolution–Data Optimized 
Revolution A. technology.
15. The term “GSM” means Global System for Mobile Communications technology.
16. The term “HSPA” or “HSPA+” means High Speed Packet Access or High Speed Packet Access + 
technology.
17. The term “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.   
18. 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. 
19. The term “LTE” means Long Term Evolution technology.
20. 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).
21. The term “mobile wireless telephone number,” means the 10-digit telephone number assigned to an end-
user to access mobile wireless services.
22. 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.
823. The term “mobile wireless services” includes mobile wireless voice services, mobile wireless text 
services, mobile wireless data services, and mobile wireless applications.
24. 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.
25. 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.
26. The term “MTA” means Major Trading Area.
27. 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. 
28. 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.
29. The term “plans, analyses, and reports” means business plans, strategic plans, written policies, budgets, 
analyses, reports, presentations (including quantitative presentations), and similar documents, including 
all appendixes and attachments thereto, prepared for, presented to, reviewed by, discussed by, or 
considered by the Company’s board of directors or the Company’s executive management, or any 
member thereof.  The term “plans, analyses and reports” includes without limitation copies of plans, 
analyses and reports that are not identical duplicates of the originals, and copies of plans, analyses and 
reports, the originals of which are not in the possession, custody, or control of the Company, but does 
not include drafts of plans, analyses and reports, but only the final version or the latest draft if the final 
version does not exist or is not in the possession, custody, or control of the Company.  
30. The term “POPs” means total aggregate population.
31. The term “Proposed Transaction” means the proposed acquisition of Allied by AT&T filed on February 
5, 2013, with the lead application file number for the wireless radio services listed as 0005632405. 
32. The term “Public Interest Statement” refers to the document filed by the Applicants on 0005632405
entitled “Description of Transaction, Public Interest Showing, and Related Demonstrations.”
33. The term “relevant area” means, and information must be provided separately for, each Cellular Market 
Area.
34. The term “relevant product” means (and information must be provided separately for, any of the mobile 
wireless services and using any of the following formats:  GSM, EDGE, CDMA, EV-DO, EV-DO Rev. 
A, UMTS only, HSPA, HSPA+, and LTE):
1) feature mobile devices: wireless handset devices that are cable of supporting voice services as 
well as text services;
2) 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, 
9including broadband data and video applications as well as voice, photographic cinematic, and 
audio-visual media player services (including books, periodicals, movies, music, games);
3) iPhones: smartphones designed and marketed by Apple Inc.;
4) 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, cinematic, and audio-visual media player 
services (including books, periodicals, movies, music, games);
5) iPads: tablet PCs designed by Apple Inc.;
6) 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;
7) “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;
8) 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
9) other mobile wireless devices not listed above.  Describe the other devices included in this 
category.
35. The term “relevant service” means (and information must be provided separately for, any of the services 
identified below and using any of the following formats:  GSM, EDGE, CDMA, EV-DO, EV-DO Rev.
A, UMTS only, HSPA, HSPA+, and LTE):
1) mobile wireless voice services;
2) mobile wireless text services;
3) mobile wireless data services; and
4) mobile wireless applications.
36. The term “sales” means net sales in units or dollars, i.e., total sales after deducting discounts, returns, 
allowances, and excise taxes.  “Sales” includes sales of the relevant service or product whether provided 
or manufactured by the company itself or purchased from sources outside the company and resold by 
the company in the same form as purchased.
37. The term “subsidiary” as to any Person means any corporation, partnership, joint venture, limited 
liability company, or other entity of which shares of stock or other ownership interests having ordinary 
voting power to elect a majority of the board of directors or other managers of such corporation, 
partnership, joint venture, limited liability company or other entity are at the time owned, or the 
management of which is otherwise controlled, directly or indirectly, through one or more intermediaries, 
or both, by such Person. 
38. The term “UMTS” means Universal Mobile Telecommunications System technology.
39. “United States” or “U.S.” means the United States, its possessions, territories, and outlying areas. 
10
Instructions
1. Unless otherwise specified, all Information and Document Requests cover the period from April 2010
through February 5
th
, 2013.
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.  Provide final versions of each document; however, 
if a final version does not exist, provide one copy of the latest draft of the document. 
5. Those documents written in a language other than English must be translated into English; automated or 
machine translations are not permitted.  Submit the foreign language document, with the English 
translation attached thereto.  
6. Unless otherwise specified, provide data and interrogatory responses separately for prepaid, post-paid, 
wholesale, and all mobile wireless services.  The Company should provide a separate response for 
interrogatory, data, and documents (i.e., please do not submit the Company’s interrogatory and data 
responses on the same discs). 
7. Data provided in response to this Request should include a list of all parameters/assumptions on which 
the data are based.
8. Unless otherwise agreed to by the Commission, requests for the production of documents (and any 
particular type of document) require the production of all responsive documents in the possession, 
custody, or control of the Company.
9. For each document or statement submitted in response to the requests, indicate, by number and 
subsection, 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 the Instructions for 
Submission of Electronic Documents 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 
11
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.
10. If search terms were used to conduct all or any part of a search conducted in response to this 
Information Request, provide a list of search terms used, along with a glossary of industry and company 
terminology. In addition, describe the search methodologies and the applications used to execute the 
search.
11. 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. 
12. 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 privileged, 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. 
13. For each Document identified on the Company privilege log:
1) Provide the document control number(s);
2) Identify all authors of the document;
3) Identify all addressees of the document;
4) Identify all recipients of the document or of any copies of the document, to the extent not 
included among the document’s addressees;
5) Provide the date of the document;
6) Provide a description of the subject matter of the document;
7) State the nature or type of the privilege that the Company is asserting for the document (e.g., 
“attorney-client privilege”);
8) Provide the number(s) of the Request to which the document is responsive;
9) 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
10) State whether the document has been produced in redacted form, and include the range of
Document ID labels for those produced documents. 
12
14. The Company’s privilege log shall also conform with all of the following requirements:
1) Provide a separate legend identifying each author, addressee, and recipient identified on the 
Company’s privilege log.
2) 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.
3) 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.
4) 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.
5) 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.
6) The privilege log shall be produced in both hardcopy and electronic form, the electronic form of 
which shall be both searchable and sortable.
7) 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. 
13
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, including the image 
and text file specifications and the load file configuration, and for a sample load file set.
2. Each Summation submission must be on a physical media, either a portable hard drive or DVD-
ROM.    
3. Each physical media provided must have a label affixed.  The label shall state: (a) the name of 
the party submitting the data, (b) the date of the submission, (c) the volume number of production (see below), 
and (d) the range of documents contained on the media.
4. Each Summation submission must have a volume number associated with it.  On the root of the 
media, the top-level folder must be named for the volume.  This volume number should also be indicated on the 
physical label of the media.  The volume naming scheme should start with a 2 or 3 letter prefix (identifying your 
company) followed by a 3-digit counter (e.g., ABC001).  Load file volumes may not contain more than 25,000 
records each (but multiple file volumes may be included on one hard drive).
5. Under the volume folder, the production should be organized in 3 subfolders: 
a) IMAGES (may contain subfolders, with no more than 5,000 image files per folder) and 
FULLTEXT (may contain subfolders, with document-level text files).  No file may be more than 25 
megabytes.
b) DOCLINK (documents in native format, including all spreadsheets and presentations)
c) LOADFILES (the metadata, EDII, and LST information should be contained in one 
file, and the custodian append information in a separate file)
6. Each submission shall be accompanied by an spreadsheet (production index), in hard copy and 
electronic form, detailing what has been produced, by custodian and document identification number, and 
containing statistical information about each volume. 
7. If a password is used, the same password must be used for all submissions.  If encryption is 
used, only Truecrypt software may be used.
8. 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.  
9. Subsequent submissions shall not include information produced in previous submissions, unless 
specifically requested by the Commission.  However, if an error occurs in loading, the entire load must be 
resubmitted, maintaining the original volume number(s).  For example, if a hard drive contains volumes 
ABC005 – ABC 009, and there is an error with volume ABC006, ABC006 must be corrected and the entire 
submission ABC005 – ABC009 must be resubmitted on a new hard drive.
14
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 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. 
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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. 
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 
this information is collected 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.
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(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.
(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.  For example, and in particular, the 
deduplication process may not remove attachments to e-mails that are being produced because the 
attachment is produced elsewhere.  Improper dedeuplication may require the resubmission of a 
production set. 
(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 document identification number should be provided in place of the document.
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(c) Both redacted and withheld documents shall appear on the privilege log. Each withheld 
document from a family shall include the family document identification number range in its entry on 
the privilege log.
8. Document Identification Numbering
(a) A consistent format for document identification numbering shall be used across the entire 
production. Document identification 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) Document identification numbers should not contain embedded spaces (“ ”), slashes (“/”), 
backslashes (“\”), or underscores (“_”).  Document identification numbers may contain hyphens (“-”).
(c) Native format files should be assigned a document identification number; if images have 
been produced with a native format file, the beginning document identification number of the images 
should be the native format file’s document identification number.
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 document identification -numbered, placeholder image), redacted documents with 
appropriately related searchable text, and presentation documents with speaker notes.
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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
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
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
Note Text
x x x x
allowed in Windows file names, or 
any character used as a delimiter 
in the load file as part of this 
number
EPROPERTIES Indicate All That Apply : Multi-Entry
x x x x
Record Type: Loose File, E-mail, 
Attachment, Hard Copy, Calendar 
Appt
Privilege Notations: Redacted, 
Privileged, Family Member of Priv 
Doc
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
DATEAPPTSTART Start date of calendar appointment 
- YYYYMMDD
Date
x
TIMEAPPTSTART Start time of calendar appointment 
- HH:MM am/pm
Time
x
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
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
HASHMD5 MD5 hash value (used for 
deduplication or other processing)
Note Text
x x x
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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
COMPANIES Company submitting data Multi-Entry
x x x x
CUSTODIAN Custodian(s) / source(s) -- format: 
Last, First or ABC Dept
Multi-Entry
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
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
20
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 x 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
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