(1 Federal Communications Commission
Washington, D.C. 20554
December 19, 2014
Via First Class & Electronic Mail
Philip C. Maynard
Sr. VP, Chief Legal Officer & Secretary
Headquarters Limelight Networks, Inc.
222 W. Mill Ave.
Tempe AZ 85281
Re: Applications of Comcast Corporation, Time Warner Cable Inc., Charter
Communications, Inc., Time Warner Entertainment-
Advance/Newhouse Partnership, and SpinCo for Consent to Assign
Licenses or Transfer Control of Licensees, MB Docket No. 14-5 7
Dear Mr. Maynard:
On April 8, 2014 Comcast Corporation ("Comcast") and Time Warner Cable Inc.
("TWC") submitted joint applications to the Commission seeking consent to transfer control of
various Commission licenses and other authorizations pursuant to Sections 214 and 310(d) of the
Communications Act of 1934, as amended ("Act"). The proposed Comcast-TWC transfers, if
completed, would effectuate the sale of certain cable systems and assets of TWC and its affiliates
and related entities to subsidiaries or affiliates of Comcast. Additionally, in connection with the
proposed Comcast-TWC transaction, TWC and Comcast have submitted applications for the
transfer to Comcast of TWE-A/N' s interest in licenses and other authorizations held by Bright
House Networks, LLC ("Bright House"). On June 4, 2014, Comcast, Charter Communications,
Inc. ("Charter"), and SpinCo (collectively, the "Divestiture Applicants") filed transfer applications
pursuant to Sections 214 and 310(d) of the Act to effectuate a series of transactions between
Comcast and Charter (collectively, the "Divestiture Transactions"). The Divestiture Applicants
claim that the Divestiture Transactions will result in a net reduction of approximately 3.9 million
residential video customers for the combined Comcast and TWC.'
In order for the Commission to complete its review of the applications and make the
necessary public interest findings under section 310(d) of the Communications Act, we require
information and data from other commercial wireline carriers aainst which the applicants compete.
Accordingly, pursuant to sections 4(i), 4(j), and 403 of the Act, we request that Limelight
Networks, Inc. ("Limelight") provide written responses, supporting documentation, and data, as
applicable no later than Friday, January 23,2015 to the information requests set forth in the
Attachments. L i m e 1 i g h t' s response will be treated as confidential pursuant to the Protective
Public Interest Statement of Comcast Corporation and Charter Communications, Inc., Charter-to-Comcast Exchange
Transaction, MB Docket No. 14-57 (June 4, 2014) ("Charter-to-Comcast Exchange Public Interest Statement"); Public
Interest Statement of Charter Communications, Inc. and Comcast Corporation, Comcast-to-Charter Exchange and
Sale Transactions, MB Docket No. 14-57 (June 4, 2014) ("Comcast-to-Charter Sale/Exchange Public Interest
Statement"); SpinCo Public Interest Statement.
247U5C § 154(i), 154W,nd 403. See generally FCC V. Schreiber, 381 U.S. 279 (1965).
Letter to Phillip C. Maynard
Sr. VP, Chief Legal Officer
& Secretary
Limelight Networks, Inc.
December 19, 2014
Page 2.
Order issued in MB Docket No. 14-57. For documents, data and narrative responses produced in
response to this request (electronic or otherwise), each page should be marked with a corporate
identification and consecutive document control numbers as specified in the attached
instructions.
Your responses should be filed with Marlene H. Dortch, Secretary, FCC, under
reference number MB Docket No. 14-57. For any responses that contain confidential or
proprietary information, please follow the filing instructions set forth in the Joint Protective
Order. For all hand deliveries pertaining to the Joint Protective Order, please call Vanessa
L em m é (202-418-2611) to schedule receipt of hand delivery or, in her absence, Marcia
Glauberman (202-418-7046). For any responses that are submitted on paper that do not
contain confidential or proprietary information, please file in accordance with the instructions
set forth in the July 10, 2014 Public Notice. For any responses filed electronically, please
submit them according to the Instructions in the Request, and coordinate with Commission
staff, or designated information technology personnel, to ensure that any responsive electronic
records are submitted to the Commission in a technological format that is compatible with
Commission database systems and are processed and organized in a manner that is acceptable
to the Commission. For any electronic filings made using the Commission's Electronic
Comment Filing System, ("ECFS"), parties should also serve the documents via e-mail to
Vanessa Lemmé, Vanessa.Lemmefcc.gov.
If you have any questions regarding this matter, please contact Hillary Burchuk, or
William Freedman, Office of General Counsel, at (202) 418-1719 and (202) 418-1415,
respectively.
Sincerelv,QIVA4
ch
Jief, Wireline Competition Bureau
Attachments
See, Joint Protective Order, MB Docket No. 14-57, DA 14-463 (rel. April 4, 2014), as amended.