1 REQUEST FOR INFORMATION FROM FRONTIER COMMUNICATIONS 1. Explain or identify and provide documents sufficient to show: a. whether and to what extent the Company’s ability to compete for Internet access service subscribers has been or would be increased by offering Internet access service using fiber to the premises (FTTP); b. the Company’s plans for capital investments that would increase the speed of the DSL-based Internet access service it offers, and the Company’s reasons to make those investments; c. the plans of the Company to replace Internet access service that it currently provides over DSL with Internet access service over FTTP and the Company’s rationales in favor of or against such replacements; d. what download and upload speeds the Company believes are required to support Internet usage for different types (e.g., standard definition, high definition, 3D, ultra HD/4K) of video consumption by the average individual and by the average household, both at present and in the future; and e. the reasons subscribers disconnect Internet access service or switch providers thereof, including but not limited to, pricing, quality of service and disputes between the Company and edge providers, CDNs or transit service providers. 2. Explain, or identify and provide documents sufficient to show, the Company’s policies or procedures with respect to decisions to establish or augment interconnection capacity with any CDNs, Internet backbone services, edge providers, Internet access service providers, and all other persons with whom the Company may engage in Internet traffic exchange. 3. Explain the Company’s use of data caps or usage allowances and describe your data cap or usage allowance plan in each of your service areas, including a description of how the company selected the service area for implementing or trialing data caps or usage allowances. In your answer, describe the factors you used to determine whether to implement data caps or usage. 4. Produce one copy of each agreement between the Company and any other persons that contain provisions relating to peering, paid peering or settlement-free interconnection. 5. Describe, and provide and identify documents sufficient to show, how the Company responds to competitors’ pricing behavior and product offerings for each relevant service. Definitions The following definitions apply only to this Request for Information. They are not intended to set or modify precedent outside the context of this document. In this Request for Information, 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): 2 1. The term “Company” means Frontier Communications Corporation and its Subsidiaries. 2. The terms “and” and “or” have both conjunctive and disjunctive meanings. 3. 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. 4. The term “Bundled Services” means, and information shall be provided separately for, (a) MVPD Service, Internet Access Service and telephone services; (b) MVPD Service and Internet Access Service; (c) MVPD Service and telephone services; and (d) Internet Access Service and telephone services; or (e) any combination thereof, each sold as a package of services for a single price. 5. The term “Cable Service” means, and information shall be provided separately for (a) MVPD Service, (b) Internet Access Service and (c) telephone services, either purchased as a standalone service or as part of a bundle. 6. The term “Capacity” means capacity for efficient provision of service, stated in the measure customarily used in the particular industry involved. When stating capacity, state each assumption used to calculate capacity, including the customary period over which capacity is measured, and the customary unit of time in which the service is provided. If you know of no customary capacity measure for a service, state the maximum amount of the service that could be provided efficiently over a one month period given existing facilities, equipment and personnel. 7. The term “Content Delivery Network” or “CDN” means a distributed system of servers that cache content closer to end users. 8. 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. 9. 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, electronic correspondence, metadata, embedded, hidden and other bibliographic or historical data describing or relating to documents created, revised, or distributed on computer systems, and all duplicates of documents (whether or not identical) in the files of or in the files maintained on behalf of all directors, officers, managers or other supervisory employees, duplicates of documents in all other files that are not identical duplicates of the originals, and duplicates of documents the originals of which are not in the possession, custody, or control of the Company. The term “documents” includes spreadsheets, as well as underlying cell formulae and other codes. 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- 3 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 instructions 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 produce one representative copy. 10. The term “Edge Provider” means entities that provide content, applications, or services over the Internet, and include but are not limited to OVDs, Voice over Internet Protocol providers, and gaming companies. 11. The term “End User” means a residential or business customer (a private or public entity or an institution) that purchases a Relevant Service. With respect to Internet Access Service, the term “End User” means a Person who originates, receives, or otherwise interacts with information, data and content on the Internet. 12. 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 Bates number, date, author, addressee, type of document (e.g., the types of documents, 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. The term “identify” when used with reference to a census block means to geocode the census block using the 2010 Census Block Identifier. 13. The term “Interconnection” means the linking together of interoperable systems, and the linkage used to join two or more communications units, such as systems, networks, links, nodes, equipment, circuits and devices. 14. The term “Interconnection Agreement” means an agreement for the purchase of Transit Service, the sale of Transit Service, Settlement-Free Peering, Paid Peering, or equivalent agreements. 15. The term “Internet Access Service” means the provision to end users of connectivity to the Internet by any means, including, for instance, hybrid-coaxial, optical fiber or coaxial cable, xDSL, satellite systems, fixed or mobile wireless services, ultra-high frequency microwave (sometimes referred to as “LMDS”), or multichannel multipoint distribution services. 16. The term “Internet Backbone Services” means services that route traffic between Internet Access Service, other Internet Backbone Services, Edge Providers, and CDNs, and, when exchanging traffic with third- party services or networks, the exchange of traffic by means of Settlement-Free Peering, Paid Peering or Transit Service. 17. The term “Internet Traffic Exchange” means interconnection between Internet Access Service, 4 Internet Backbone Services, Edge Providers, CDNs, and other Internet networks and services, where traffic is exchanged pursuant to an interconnection agreement or arrangement. 18. The term “Multichannel Video Programming Distributor” or “MVPD” means an entity, including but not limited to, a cable operator, which is engaged in the business of making available for purchase, by subscribers or customers, multiple channels of Video Programming. 19. The term “MVPD Service” means the distribution of Video Programming or Online Video Programming by an MVPD to consumers, including but not limited to, distribution as part of a programming package or tier or on an individual basis, and distribution as part of TV Everywhere or Non-Broadband Internet Access Service Data Services, regardless of whether such programming is distributed inside or outside of the MVPD’s footprint. 20. The term “Non-Broadband Internet Access Service Data Services” means services that share capacity with Internet Access Service over providers’ last-mile facilities. 21. The term “Online Video Programming” means Video Programming that is intended for distribution by means of the Internet or other IP-based transmission path. 22. The term “Online Video Distributor” or “OVD” means any entity that provides Video Programming by means of the Internet or other IP-based transmission path provided by a person other than the OVD. Unless otherwise stated, an OVD does not include an MVPD inside its MVPD footprint or an MVPD to the extent it is offering Online Video Programming as a component of an MVPD subscription to customers whose homes are inside its MVPD footprint. 23. The term “Paid Peering” is peering in which one peer pays another for the exchange of traffic. Paid peering is sometimes referred to as “Non Transit” interconnection. 24. The term “Peer” means a Person who is a party to a peering arrangement. 25. The term “Peering” means an interconnection arrangement between Persons, pursuant to which Internet traffic is exchanged between Persons and their customers, however, there is no Transit Service through networks to other Peers or Transit Service providers. 26. The term “Person” includes the Company, and means any natural person, association, partnership, corporate entity, joint stock company, trust, unincorporated association, joint venture, limited liability company or other entity, or a government or any political subdivision or agency thereof. 27. 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. 28. The term “relating to” means in the whole or in part constituting, containing, concerning, discussing, describing, analyzing, identifying, or stating. 29. The term “relevant service” as used herein means, and information shall be provided separately for, each service in the following categories: 5 a. Cable Service; b. Content Delivery Network; c. Internet Access Service, and information shall be provided separately for: i. Subscribers; and ii. Edge Providers; and d. Internet Traffic Exchange, and information shall be provided separately for interconnection between the Company and each provider of: i. Internet Backbone Services; ii. Internet Access Service; iii. Edge Providers; iv. CDNs; v. other Internet networks and services; and vi. OVDs. 30. The term “Settlement-Free Peering” means peering where there are no payments exchanged between network providers for the exchange of traffic. 31. The term “Standalone Services” means, and information shall be provided separately for: (a) MVPD Service; (b) Internet Access Service; and (c) telephone services, each sold as a separate service for a single price. 32. 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. 33. The term “Transit Service” means a service arrangement where a customer pays an Internet Backbone Services provider to send and receive traffic to and from destinations that can be either on or off the provider’s network. 34. The term “Video Programming” means programming provided by, or generally considered comparable to programming provided by, a television broadcast station or cable network, regardless of the medium or method used for distribution, and includes but is not limited to: programming prescheduled by the programming provider (also known as scheduled programming or a linear feed); programming offered to viewers on an on-demand, point-to-point basis (also known as VOD or PPV); short programming segments (also known as clips); programming that includes multiple video sources (also known as feeds, including camera angles); programming that includes video in different qualities or formats (including high- 6 definition, 3D and 4K); and films. 35. The term “Video Programming Distribution” means the provision of Video Programming to consumers. Instructions 1. Unless otherwise specified, each Request for Information that calls for documents requires the Company to submit all responsive documents that were created or received by the Company on or after July 24, 2013 through the date of this Request. Where information is required, provide it separately for each year. Where yearly data is not yet available, provide data for the calendar year to date. 2. Submit responses to Requests for Information in both paper and electronic form, unless an electronic form is specified (e.g., electronic spreadsheet). Submit responsive documents (including materials containing Highly Confidential or Confidential Information) in electronic form only, unless otherwise specified, as set forth in the Instructions for Submission of Electronic Documents. The Commission does not now require the submission of paper copies of these documents at this time, but reserves the right to require their submission at a later time. The Commission does not now require the submission of drafts and final copies of agreements between the Company and any programmer who is not an Applicant in this Matter (MB Docket No. 15-149) for the carriage or distribution of a non-Applicant programmer’s content by the Company nor any emails exchanged between the Company and a non-Applicant programmer related to negotiations over such agreements, but reserves the right to require their submission at a later time. 3. Where a narrative response is required, identify each document relied upon to support the Company’s response in the narrative response. 4. Each responsive 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. Data provided in response to this Request for Information should include a list of all parameters/assumptions on which the data are based. 6. 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. 7. For each statement submitted in response to the Request for Information, indicate, by number and subsection, the specific Request to which it is responsive. 8. For each document submitted in response to the Request for Information, identify the Person(s) from whose files the document was retrieved (i.e., the custodian). 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 9. Describe the search methodologies and the applications used to execute the search conducted in response to this Request for Information, including, if search terms were used to conduct all or any part of the search, a list of terms used. 10. Provide a glossary of industry and company terminology used in responding to the Requests, including project code words. 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. 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 imaged 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: 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 for Information 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. 14. 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 8 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. 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. 9 Instructions for Electronic Production of Documents and Electronically Stored Information Introduction This document contains the standard specifications and procedures for submitting to the Federal Communications Commission electronic versions of documents in response to an Request for Information. • In many cases, it is useful for the party producing the documents, its vendor and the FCC staff to review the technical details of the production prior to submitting the response. • Take care to ensure that all responsive data and metadata are preserved in the collection process. • Submit two copies of the response: file one copy in the docket with the Secretary’s Office and provide one copy to FCC staff or the FCC’s contractor, as directed, for loading and review. 1. Categories of Documents There are seven major categories of relevant documents: (1) email and other electronic messages (e.g., instant messaging, text messages), (2) other electronic documents, (3) hard copy documents, (4) shared resources, (5) databases, (6) audio and video data, and (7) foreign-language materials. Typically, responsive documents will come from the first four categories, although databases will be used to respond to Data Requests. The general requirements for each category of document are outlined below. The attached Metadata Table of Requested Fields provides information regarding document-specific metadata and bibliographic information (identifying information). A. Email, Attachments, and Other Electronic Messages Email and other electronic messages (e.g., instant messages (IMs), text messages) should be produced as image files with related searchable text, metadata and bibliographic information. Depending on how the Company's systems represent names in email messages, IMs or text messages, we may require a table of names or contact lists from custodians. Each IM or text conversation should be produced as one document. Email repositories, also known as email databases (e.g., Outlook .PST, Lotus .NSF), can contain a variety of items, including messages, calendars, contacts, tasks, etc. For purposes of production, responsive items should include the “Email”, "Other ESI", or "Calendar Items" metadata/database fields outlined in the Metadata Table, including but not limited to all parent items (mail, calendar, contacts, tasks, notes, etc.) and child files (attachments of files to email or other items), with the parent/child relationship preserved. Similar items found and collected outside an email repository (e.g., .MSG, .EML, .HTM, .MHT) should be produced in the same manner. Graphic objects embedded in emails such as logos, letterheads, or backgrounds should remain as part of the email and not be extracted as separate attached documents. Pay special attention to the PARENTID, ATTACHMENTIDS, and FAMILYRANGE fields, which are used to track email families. While the example below relates to email families, all attachment relationships for all responsive documents are to be produced in this format. EXAMPLE: Consider ABC-JD-00000001 a 10-page parent email, with records ABC-JD-00000011 to ABC- JD-00000015, ABC-JD-00000016 to ABC-JD-00000020, and ABC-JD-00000021 to ABC-JD- 10 00000025 as its attachments. Fields should be populated exactly as follows using the semicolon as the multi- entry delimiter for ATTACHMENTIDS: BEGDOC# ENDDOC# PARENTID ATTACHMENTIDS FAMILYRANGE ABC-JD-00000001 ABC-JD-00000010 ABC-JD-00000011; ABC-JD-00000016; ABC-JD-00000021 ABC-JD-00000001 – ABC-JD-00000025 ABC-JD-00000011 ABC-JD-00000015 ABC-JD-00000001 ABC-JD-00000001 – ABC-JD-00000025 ABC-JD-00000016 ABC-JD-00000020 ABC-JD-00000001 ABC-JD-00000001 – ABC-JD-00000025 ABC-JD-00000021 ABC-JD-00000025 ABC-JD-00000001 ABC-JD-00000001 – ABC-JD-00000025 B. Electronic Documents Electronic documents include word-processing documents, spreadsheets, presentations, and all other electronic documents not specifically discussed elsewhere. Production of these items should include image files with related searchable text, metadata, and bibliographic information. All passwords and encryption must be removed from electronic documents prior to production. Note that the following apply to both attachments of files to email or other items and loose native files: 1. Spreadsheets: Spreadsheets should be produced in native format (e.g., as .XLSX files), with searchable text for the entire document, metadata, and bibliographic information. Provide only a single image of the first page of the spreadsheet or provide a single placeholder image. The placeholder image must contain at a minimum the BEGDOC#, FILENAME, and FILEPATH. The Identification range for a spreadsheet should be a single number (e.g., ABC-JD-00000001 – ABC-JD-00000001). The linked native file name should match the BEGDOC#/DOCID with the appropriate file extension. 2. Presentations: Presentations should be produced in full slide image format along with speaker notes (which should follow the full images of the slides) with related searchable text, metadata, bibliographic information and linked native file. Presentations should also be produced in native format (e.g., as .PPT files). The linked native file name should match the BEGDOC#/DOCID with the appropriate file extension. 3. Hidden Text. All hidden text (e.g., track changes, hidden columns, hidden slides, mark-ups, notes) shall be expanded and rendered in the extracted text file. For files that cannot be expanded linked native files shall be produced with the image files. 4. Embedded Files. All embedded objects (e.g., graphical files, Word documents, Excel spreadsheets, .wav files) that are found within a file shall be produced so as to maintain the integrity of the source document as a single document. For purposes of production the embedded files shall remain 11 embedded as part of the original source document. Hyperlinked files must be produced as separate, attached documents upon request. Any objects that cannot be rendered to images and extracted text (e.g., .wav, .avi files) must be produced as separate extracted files with linked native files and placeholder images and be treated as attachments to the original file. 5. Image-Only Files. All image-only files (non-searchable .PDFs, multi-page TIFFs, Snipping Tool screenshots, etc., as well as all other images that contain text) shall be produced with associated OCR text, metadata, and bibliographic information. 6. Proprietary File Types and Non-PC or Non-Windows Based Systems. Proprietary file types, such as those generated by financial or graphic design software, should be discussed with Commission staff in advance of production to determine the optimal format of production. Also, file types from non-PC or non-Windows based systems (e.g., Apple, UNIX, LINUX systems), should be discussed with Commission staff in advance of production to determine the optimal format of production. 7. Archive File Types. Archive file types (e.g., .zip, .rar) must be uncompressed for processing. Each file contained within an archive file should be produced as a child to the parent archive file. If the archive file is itself an attachment, that parent/child relationship must also be preserved. 8. Processing Errors. The text of the placeholder image should also be contained in the searchable text of the document in the event of uncorrectable processing errors. C. Hard-Copy (or Paper) Documents Hard-copy documents are to be produced as black-and-white image files, except where noted below, with related searchable OCR text and bibliographic information. Special attention should be paid to ensure that hard-copy documents are produced as they are kept, reflecting attachment relationships between documents and information about the file folders within which each document is found. In addition, multi-page documents must be produced as single documents (i.e., properly unitized) and not as several single-page documents. Where color is required to interpret the document, such as hard copy photos, and certain charts, that image must be produced in color. These color images are to be produced as .jpg format. Hard-copy photographs should be produced as color .jpg format files, if originally in color, or black-and-white .tif files if originally in black-and-white. D. Shared Resources Shared Resources should be produced as separate custodians if responsive custodians have access to them or if they contain responsive documents. The name of the group having access would be used as the custodian name, i.e., Marketing Execs or Accounting Dept. The Company will separately provide a brief description of each shared resource that includes a list of the custodians who have access to that shared resource. E. Database Productions Production of enterprise databases are not addressed in these specifications and must be discussed with the appropriate government legal and technical staff to determine the optimal production format; these will usually fall outside the scope of an image-based production. Care must be taken to ensure that all responsive databases and their metadata are preserved. F. Audio/Video Data 12 These specifications do not address the production of audio/video data. Care must be taken to ensure that all responsive audio/video data and their metadata are preserved. These data types may be stored in audio or video recordings, voicemail text messaging, and related/similar technologies. However, such data, logs, metadata, or other files related thereto, as well as other less common but similar data types, should only be produced after consultation with and consent of Commission staff as to the format for the production of such data. G. Foreign-Language Materials Foreign language materials should be produced after consultation with Commission staff. 2. De-duplication Before doing any de-duplication, provide Commission staff with a written description of the method used to de- duplicate (including which elements are compared and what hash codes are used), and what is considered a duplicate. Then confirm that your approach is acceptable to the Commission. The Commission does not allow de-duplication of hard-copy documents, or that of "loose" electronic documents (e.g., presentation slides located on the custodian’s C: drive) against email attachment versions of those same documents. The integrity of any produced email and any related “document family” must be maintained except as limited by any claim of privilege. Email attachments may not be deduplicated against attachments in other email families. De- duplication should occur both vertically within each custodian and horizontally across custodians. Vertical de- duplication is crucial when a production includes electronic documents from back-up tapes. Horizontal de- duplication must be done in a way that preserves (and produces) information on blind copy (Bcc) recipients of emails and other custodians whose files contain the duplicates that will be eliminated from the production as well as original filepath and mailbox folder information. Custodian Append File. A Custodian Append file is to be produced when de-duplicating ACROSS custodians (i.e., horizontal de-duplication) and data is produced on a rolling basis. The file must be provided on an incremental basis starting with the second submission; as more custodians are discovered for previously produced documents, this file is updated with only the new custodian information. The Custodian Append File is a four-field delimited file consisting of the DOCIDs of the previously delivered document, the new custodian names, the Filepath(s) prepended with Custodian Name (multi-entry), and the FolderLabel(s) prepended with Custodian name (multi- entry) for the duplicates of those records that would otherwise have been produced in the subsequent (new) submissions. These specifications do not allow for near de-duplication or email threading. These forms of de- duplication must be discussed separately with Commission staff and consent obtained prior to the use of such techniques for production. 3. Document Numbering Documents must be uniquely and sequentially numbered across the entire production, with an endorsement burned into each image. Each number shall be of a consistent length, include leading zeros in the number, and unique for each produced page. Numbers should contain no more than three segments connected by a hyphen. The leading segment must be the Company identifier, a middle segment identifying the custodian, and a sequential page counter with connecting hyphens (e.g., ABCCO-CEO-00000001). The number of digits in the numeric portion of the format should not change in subsequent productions, nor should spaces, hyphens, or other separators be added or deleted. Under no circumstances should Identification numbers contain embedded spaces, slashes (/), backslashes (\), carats (^), underscores (_), ampersands (&), hash marks (#), plus signs (+), percent signs (%), dollar signs ($), exclamation marks (!), pipes (|), any character used as a delimiter in the metadata load files, or any character not allowed in Windows file-naming convention (,\ / : * ? “ < > | ~ 13 @ ^). 4. Privilege Designations Documents redacted pursuant to any claim of privilege will be designated “Redacted” in the EPROPERTIES field as described in the Metadata Table. Appropriately redacted searchable text (OCR of the redacted images is acceptable), metadata, and bibliographic information must also be provided. All documents that are part of a document family that includes a document withheld pursuant to any claim of privilege will be designated “Family Member of Privileged Doc” in the EPROPERTIES field as described in the Metadata Fields table for all other documents in its family. Placeholder images with BEGDOC#, FILENAME, FILEPATH and reason withheld (e.g., “Privileged”) should be provided in place of the document images of the privileged document. 5. Sample Before beginning production, a sample production covering files of all types, including emails with attachments, loose files including spreadsheets and presentations, redacted documents, etc., should be provided, as directed by Commission staff. The sample size should be between 500 to 1000 records to be large enough to be representative and small enough to review quickly. The Commission will take a few business days to evaluate the sample and provide feedback. If there are any problems, corrected samples will need to be resubmitted until the Commission can confirm the problems are resolved. 6. Load File Set/Volume Configuration Each production must have a unique MEDIAID name associated with it. This MEDIAID name must also appear on the physical label. The MEDIAID naming scheme should start with a 2 or 3 letter prefix identifying the Company followed by a 3-digit counter (e.g., ABC001). Each separate volume delivered on that media must also have a separate VOLUMENAME associated with it. On the root of the media, the top level folder(s) must be named for the volume(s). VOLUMENAME(s) should also be indicated on the physical label of the media. The volume naming scheme should be based on the MEDIAID name followed by a hyphen, followed by a 3-digit counter (e.g., ABC001-001). Load file volumes should be as large as practical but not contain more than 100,000 records each. The VOLUMENAME should increase sequentially across all productions on the same MEDIAID. Under the VOLUMENAME folder, the production should be organized in 4 subfolders: 1. DOCLINK (contains linked native files , may contain subfolders, with no more than 5,000 files per folder) 2. IMAGES (may contain subfolders, with no more than 5,000 image files per folder) 3. FULLTEXT (may contain subfolders, with no more than 5,000 document-level text files per folder) 4. LOADFILES (should contain the metadata, DII, OPT, LST, and custodian append files) 7. Deliverables A submission index spreadsheet must be delivered with each submission and should provide statistical information about the volume(s) and media produced. Provide this in hard copy format and electronically on the deliverable media. A sample is included in this PDF. It is expected that all productions will conform to the structure of the final, approved sample production. Any 14 changes to production procedures that alter output format will require prior submission of another sample production as outlined in section 5. Sample. The Commission accepts electronic productions loaded onto hard drives, CD-ROMs, or DVD-ROMs; however, production on hard drives minimizes costs and delay and is preferable. Where the size of the production exceeds the capacity of a single DVD-ROM, hard drives should be used as the delivery medium. For each piece of media a unique identifier (MEDIAID) must be provided and must be physically visible on the exterior of the physical item. If the media is encrypted, supply the tool for decryption on or with the same media, as well as instructions for decryption. Provide the password separately. All documents produced in electronic format shall be scanned for, and free of, viruses. The Commission will return any infected media for replacement, which may affect the timing of the Company’s compliance with this Request for Information. The Commission does not accept load file productions via email or those that are posted on download sites (e.g., FTP, secure server). The Commission recognizes that occasionally unforeseen issues will arise that require replacing documents or data from a previously delivered production with new documents or corrected data. Substantive corrections may require the reproduction of the entire production volume. The production format for all corrections must be agreed upon prior to any submission of corrections. Any productions that have been created but not delivered when the need for corrections is detected must be corrected prior to delivery. Each replacement or corrected production must be named based on the production volume that is being replaced or corrected. For example, if a corrected metadata file replaces data in the previously delivered volume ABC-001-001 then the file name ABC- 001-001-fix.txt should be used. Replacement document image file names, likewise, must be labeled with the same Identification number as the image being replaced. A separate correcting file is required for each volume to be corrected. These replacement or corrected productions must be delivered on separate media from any new productions. In the event that corrections alter the statistical information previously reported in the cover letter spreadsheet, an updated submission index spreadsheet with the corrected final statistical information must accompany each replacement or corrected submission. Provide this in hard copy format and electronically on the deliverable media. 15 METADATA TABLE OF REQUESTED FIELDS An “X” indicates that the field should be populated in the load file produced. “Other ESI” includes non-email files, such as, but not limited to MS Office files, WordPerfect files, etc. Field Name Field Description Field Type Hard- Copy Email Other ESI Calendar Items COMPANIES Company submitting data Multi-Entry X X X X MEDIAID The unique identifier on the physical piece of media (e.g., ABC001) Note Text X X X X VOLUMENAME Production volume number (e.g., ABC001-001) Note Text X X X X CUSTODIAN Custodian(s) / source(s) -- format: Last, First or ABC Dept. Be consistent across all ESI sources/productions. Multi-Entry X X X X TIMEZONE The TimeZone in which the custodian is located. Note Text X X X SPEC# Subpoena/request paragraph number to which the document is responsive Multi-Entry X X X X HASHMD5 Document MD5 hash value (used for deduplication or other processing) Note Text X X X HASHSHA Document 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 BEGDOC# Start Identification number (including prefix) -- No spaces or special characters Note Text X X X X ENDDOC# End Identification number (including prefix) -- No spaces or special characters Note Text X X X X DOCID Must equal the value appearing in the BEGDOC# field and be UNIQUE 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 FAMILYRANGE Range of the BEGDOC# value of the parent record to the ENDDOC# value (including prefix) of the last child record (for example, ABC-JD-00001201 - ABC-JD- 00001220); populated for all documents in the group. Empty if the record is NOT in family grouping Note Text X X X X EPROPERTIES Indicate all that apply : Record Type: E-Doc, E-Doc Attachment, Email, Email Attachment, Hard Copy, Calendar Appt Other Notations: Translation of [DOCID of original], Translated as [DOCID of Translation] Privilege Notations: Redacted, Privileged, Family Member of Priv Doc Multi-Entry X X X X FOLDERLABEL Email folder path (sample: Smith,James-Inbox\Active); or Hard Copy folder/binder title/label prepended with Custodian Name. Multi-Entry X X X FROM Author of the Email or Calendar item (as formatted on the original) Note Text X X TO Recipients of the Email or Calendar Item (as formatted on the original) Multi-Entry X X CC Names of the individuals who were copied on the Email or Calendar Item (as formatted on the original) Multi-Entry X X BCC Names of the individuals who were blind-copied on the Email or Calendar Item (as formatted on the original) Multi-Entry X X SUBJECT Email or calendar subject Note Text X X DATE_HC Date of hard copy documents, if coded. Format: YYYYMMDD. Date X DOCDATE This is a multipurpose date field. Populate with: DATESAVED for E-Docs; DATESENT for Emails; DATEAPPTSTART for calendar appointments; DATE_HC for hard copy documents, if available. Format: YYYYMMDD. Date X X X X DATECREATED Date electronic file was created. Format: YYYYMMDD. Date X DATESENT Date the Email or Calendar Item was sent. Format: YYYYMMDD. Date X X TIMESENT Time Email or Calendar Item was sent -- Format: HH:MM:SS (use 24 hour times, e.g., 13:32 for 1:32 pm; timezone indicators cannot be included) Time X X DATERECEIVED Date Email or Calendar Item was received. Format: YYYYMMDD. Date X X TIMERECEIVED Time Email or Calendar Item was received. Format: HH:MM:SS (use 24 hour times, e.g., 13:32 for 1:32 pm; timezone indicators cannot be included) Time X X HEADER The internet header information for Email sent through the internet; Note Text X INTERNETMSGID Globally unique identifier for a message which typically includes messageid and a domain name. Example: <0E6648D558F338179524D555@m1p.innovy.net Note Text X X MESSAGEID Unique system identification number for the e-mail message assigned by the proprietary email database/mailstore/post office file associated with centrally managed enterprise email servers. EntryID for Microsoft Outlook, the UniqueID (UNID) for Lotus Notes, or equivalent value for other proprietary mailstore formats. Note Text X X 16 INREPLYTOID Internet message ID of the Email replied to Note Text X CONVERSATIONINDEX Email Thread Identification Note Text X X IMPORTANCE Email flag indicating priority level set for message Note Text X X DELIVRECEIPT Delivery receipt request notification for Email messages Note Text X X Submission Index Spreadsheet for ABC Company Production Matter: ABC's Acquisition of XYZ Custodian Physical Media Name Volume Name Begin I.D. Number End I.D. Number Intentionally Left Blank Number of Records Number of Images Number of Native Files Number of Extracted/ OCRed Text Files Volume Size in GB Date Produced Doe, John K. ABC001 ABC001-001 ABC-JKD-00000001 ABC-JKD-00005825 258 5825 13 258 Doe, Jane B. ABC001 ABC001-001 ABC-JBD-00000001 ABC-JBD-00003711 365 3,711 52 362 TOTALS FOR THIS VOLUME 623 9,536 65 621 mm/dd/yyyy Daniels, James ABC001 ABC001-002 ABC-JAD-00000001 ABC-JAD-00005727 1,150 5,727 156 1,149 Wise, Barry ABC001 ABC001-002 ABC-BLW-00000001 ABC-BLW-00003010 600 3,010 20 598 TOTALS FOR THIS VOLUME 1,750 8,737 176 1,750 mm/dd/yyyy Brown, Charlene J. ABC002 ABC002-001 ABC-CJB-00000001 ABC-00006952 1,315 6,952 68 1,310 1.02 mm/dd/yyyy Mahan, Freda ABC002 ABC002-001 ABC-FRM-00000001 ABC-FRM-00000698 ABC-FRM-00010400 ABC-00000982 2,023 10,115 85 2,023 2.00 Mm/dd/yyyy TOTALS FOR THIS VOLUME 3,338 17,067 153 3,333 2.02 GRAND TOTALS 5,711 35,340 394 5,704 2.02 * This spreadsheet can be provided on a current production-specific or a cumulative production basis, but the totals per volume must be provided ** This spreadsheet is a sample of format and does not reflect the names/Identification numbers of the sample files provided *** Volume size is actual space used not total available space on the delivery media