General Information Request Regarding the AT&T/Plateau Wireless (ENMR) Transaction Questions for AT&T WT Docket No. 14-144 September 22, 2014 1. On page 4 of the Public Interest Statement, the Applicants contend that both AT&T and Plateau Wireless will benefit from a broader, denser, more advanced network, as well as roaming cost savings. Explain, and describe in detail, all efficiencies or savings, including roaming cost savings, of the Proposed Transaction. Provide all documents relied on in preparing the response. For each efficiency or saving identified by the Applicants: (i) provide a quantification of the efficiency or savings and an explanation of how the quantification was calculated; (ii) state the steps that the Company anticipates taking to achieve the efficiency, and the estimated time and cost required to achieve it. 2. On page 5 of the Public Interest Statement, the Applicants claim that “[t]he transaction will permit AT&T to expand its network capacity and coverage quickly in the license areas ? primarily in rural areas” and “AT&T plans to complete Plateau Wireless’s 4G HSPA+ deployment and to overlay LTE technology, both at a much faster pace than Plateau Wireless would be able to achieve.” For each Relevant Area, provide: a. A detailed discussion of the Company’s plans to provide high-quality, high-speed wireless broadband services prior to the Proposed Transaction, including a detailed description of the Company’s current and planned deployment of HSPA+ and/or LTE, which identifies the spectrum bands and the amount of spectrum currently deployed and planned for future deployment of HSPA+ and of LTE. b. A detailed explanation of why the Company needs approximately one-third or more of the suitable and available spectrum below 1 GHz for the provision of mobile wireless services. c. A detailed description of how the Company would use the spectrum that it would acquire under the Proposed Transaction to provide advanced mobile telephony/ broadband services to consumers, on a standalone basis and/or in conjunction with any other of the Company’s spectrum holdings. d. The Company’s timeline for deploying the spectrum that it would acquire in the Proposed Transaction. e. Provide all documents relied on in preparing the response to 1(a)-1(d). 3. Provide polygons in an ESRI shapefile format representing geographic coverage for AT&T, including each mobile broadband network technology (e.g., GSM, EDGE, UMTS, HSPA, HSPA+, LTE) deployed in each frequency band (e.g., Lower 700 MHz, Cellular, AWS-1, PCS). Provide all assumptions, methodology (e.g., propagation, projection, 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 polygons, and identify the propagation tool used, the propagation model used within that tool, including but not limited to, the coefficients used in the model and any additions, corrections or modifications made to the model. 2 4. In the Public Interest Statement, the Applicants emphasize the potential benefit to Plateau Wireless’s customers of access to AT&T's nationwide wireless network, as well as, but not limited to, a wider variety of rate plans, free mobile-to-mobile calling, and Wi-Fi hotspots. (Public Interest Statement 6-7.) Provide a detailed discussion of the potential benefits to customers as a result of the Proposed Transaction, including but not limited to, those identified above. 5. Explain the Proposed Transaction’s effects on any roaming agreements to which Plateau Wireless is a party, including the end date, and whether these agreements may be terminated as a result of the Proposed Transaction. Provide current copies of all such roaming agreements, and if with parties other than AT&T, explain whether AT&T will honor the terms and conditions of such agreements. 6. On page 7 of the Public Interest Statement, the Applicants contend that “[a]s part of the transition, AT&T plans to offer the majority of Plateau Wireless subscribers comparable rate plans without requiring any contract extension. AT&T will give the minority of customers for whom AT&T will be unable to offer comparable rate plans the choice between choosing non-comparable rate plans and terminating their service without early termination fees.” Describe in detail how AT&T expects to migrate Plateau Wireless customers and provide all documents discussing the migration plan, including plans for customer transition to new pricing plans and devices, and the timeline for this transition. In addition: a. Explain the likely effect of the Proposed Transaction and the Company’s migration plans on Plateau Wireless customers’ existing rates, service plans, and devices, including, but not limited to, a discussion of device replacement plans, device comparability, and whether customers will be subsidized, in full or in part, for the cost of new devices. This explanation should also include, but not be limited to, a discussion of the Company’s maintenance and transition of those Plateau Wireless customers, detailed by plan, that have lower price rate plans to the extent that the Company does not provide comparably- priced plans for comparable services. b. Explain whether AT&T will honor the terms and conditions of the Plateau Wireless customers’ existing contracts for the term of their contracts. Include in your explanation a detailed discussion of each type of postpaid and prepaid/no-contract plan (e.g., daily, monthly all-you-can-eat, and pay as you go) currently available to Plateau Wireless’s customers. c. Explain how Plateau Wireless customers will be notified of the transition and a timeline for the transition of all Plateau Wireless customers. d. Explain how many Plateau Wireless customers AT&T estimates will not have a comparable rate plan. e. Identify the number of Lifeline customers and how they will be transitioned. f. Provide all documents relied upon in preparing the responses to 6(a) – 6(e). 7. Provide the Company’s quarterly subscriber data, as specified in Attachment A. 8. Provide the Company’s quarterly porting data, as specified in Attachment B. 3 9. Attachment A – Subscribers.csv For each quarter, beginning Q3 2012 and extending through Q2 2014, for the CMAs subject to the Proposed Transaction, please provide the data requested below. Data should be reported by subscriber service designation (as indicated in Column #4 by the service variable). Please provide the file electronically in comma separated value (.csv) format. The required format for the entries in each column/field is indicated in the instructions below. Do not include text objects in numeric fields (e.g., do not include "$" in front of any dollar figures). Code any unknown values as "-99999". Column Variable Format Short Description Description 1 cma Numeric CMA Code Provide code for Cellular Market Area (CMA) of the subscribers 2 quarter 1 char. string Quarter Provide the billing quarter: 1=Q1, 2=Q2; 3=Q3; 4=Q4 3 year 4 char. string Year Provide the year in YYYY format, e.g., 2013, 2014 4 service Text Service Type Indicates whether the customer is business or residential and the service type purchased. Possible Entries: Business, Residential Prepaid, Residential Postpaid, Wholesale, Other 5 subs Numeric Subscribers The number of subscribers/lines in the CMA for the relevant service at the beginning of the quarter 6 arpu Numeric Average revenue per user Provide the average revenue per user for all subscribers for the given quarter and CMA for the relevant service 7 adds_gross Numeric Gross subscriber additions Provide the gross subscriber additions for the given month and CMA for the relevant service 8 adds_net Numeric Net subscriber additions Provide the net subscriber additions for the given quarter and CMA for the relevant service 9 ccpu Numeric Cash cost per user Provide the cash cost per user (including costs for new acquisitions) for all subscribers for the given quarter and CMA for the relevant service 10 churn Numeric Churn rate Provide the churn rate for all subscribers for the given quarter and CMA for the relevant service 4 Attachment B – Ports To and Ports From.csv For each quarter, beginning Q3 2012 and extending through Q2 2014, for the CMAs subject to the Proposed Transaction, please provide the data requested below. Please provide the file electronically in comma separated value (.csv) format. The required format for the entries in each column/field is indicated in the instructions below. Do not include text objects in numeric fields (e.g., do not include "$" in front of any dollar figures). Code any unknown values as "-99999". Column Variable Format Short Description Description 1 cma Numeric CMA Code Provide code for Cellular Market Area (CMA) of the subscribers 2 month 2 char. string Month Provide the billing quarter: 1=Q1, 2=Q2; 3=Q3; 4=Q4 3 year 4 char. string Year Provide the year in YYYY format, e.g., 2013, 2014 4 ports from Text Provider subs port from Either AT&T, or the name of the competing service provider whose subscribers port to AT&T in a particular quarter 5 ports to Text Provider subs port to Either the name of the service provider where AT&T subscribers port in a particular quarter, or AT&T 6 ports Numeric Total ports to provider The number of subscribers who port from the provider listed in Column 4 to the provider in Column 5 during the given quarter 5 Definitions 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” or “AT&T” mean AT&T, Inc., 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 “Plateau Wireless” means E.N.M.R. Telephone Cooperative (“E.N.M.R.”), Plateau Telecommunications, Inc. (“Plateau Telecommunications”), New Mexico RSA 4 East Limited Partnership, and Texas RSA 3 Limited Partnership, the 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 Plateau Wireless, collectively. 6. The term “Application” means the applications submitted by AT&T and Plateau Wireless on July 14, 2014, with the lead file number for the wireless radio services listed as 0006366669. 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. 6 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 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 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. 7 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. 23. 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 Plateau Wireless by AT&T filed on July 14, 2014, with the lead application file number for the wireless radio services listed as 0006366669. 32. The term “Public Interest Statement” refers to the document filed by the Applicants on 0006366669 entitled “Description of the Transaction and Public Interest Statement.” 8 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, including 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 9 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 June 1, 2013 through August 31, 2014. 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. Contact Commission staff to discuss an acceptable format for the submission of all documents and data. 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 submit the Company’s interrogatory responses on one disc and data responses on a separate disc). 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. Documents must be uniquely and sequentially numbered across the entire production. 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. 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 11 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). 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. 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 12 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.