Federal Communications Commission Enforcement Bureau Market Disputes Resolution Division 45 L Street, NE Washington, DC 20554 June 15, 2026 NOTICE OF FORMAL COMPLAINT By E-Mail LIFE TIME, INC., ) Proceeding No. 26-95 ) Bureau ID Number EB-26-MD-003 Complainant, ) ) v. ) ) VERIZON BUSINESS NETWORK ) SERVICES LLC, ) ) Defendant. ) Erik A. Lindseth Curtis L. Groves Life Time, Inc. Beatriz L. Albornoz General Counsel Verizon 2902 Corporate Place 1300 I Street, NW Chanhassen, MN 55317 Suite 500E elindseth@lt.life Washington, DC 20005 curtis.groves@verizon.com Charles W. Steese beatriz.albornoz@verizon.com Papetti Samuels Weiss McKirgan 16430 N. Scottsdale Road Scott H. Angstreich Suite 290 Abigail E. DeHart Scottsdale, AZ 82254 Brenna L. Darling csteese@pswmlaw.com Kellogg, Hansen, Todd, Figel & Frederick, P.L.L.C. Counsel for Complainant 1615 M Street NW Suite 400 Washington, DC 20036 sangstreich@kellogghansen.com adehart@kellogghansen.com bdarling@kellogghansen.com Counsel for Defendant Dear Counsel: On June 11, 2026, Life Time, Inc. (Life Time) filed with this Commission a complaint against Verizon Business Network Services LLC (Verizon) under section 208 of the Communications Act of 1934, as amended (the Act), 47 U.S.C. § 208.1 Verizon should have a copy of the Complaint as served by email by Life Time on June 11, 2026. If that is not the case, Verizon immediately should contact Commission counsel. Ryan McDonald, Michael Hunseder, and I are Commission counsel for this proceeding. My phone number is (202) 418-0198, and my email address is anthony.delaurentis@fcc.gov. Ryan McDonald’s phone number is (202) 418-0156, and his e-mail address is ryan.mcdonald@fcc.gov. Michael Hunseder’s phone number is (202) 418-7391, and his e-mail address is michael.hunseder@fcc.gov. This letter outlines the procedural rules relevant to this case and establishes a schedule for the proceeding. Although the Commission’s rules governing section 208 complaints (which are found at 47 CFR §§ 1.720-1.740)2 will generally apply to this proceeding, at the request of the parties,3 we herein modify the filing deadlines and discovery, and waive certain filing requirements in accordance with the authority delegated by sections 0.111, 0.311, 1.3, and 1.721(n) of the rules. 47 CFR §§ 0.111, 0.311, 1.3, 1.721(n).4 Schedule for this Proceeding The modified schedule for this proceeding is set forth below. All filings must comply with the Commission’s rules and with this Notice.5 1) By JULY 13, 2026, Verizon must answer the interrogatories that Life Time served with its Complaint in accordance with section 1.730(c) of the Commission’s rules. 47 CFR §1.730(a), (c). 1 Life Time, Inc. v. Verizon Business Network Services, LLC, Unjust and Unreasonable Rate Complaint – Federal Universal Service Charges (filed June 11, 2026) (Complaint). 2 See also Amendment of Procedural Rules Governing Formal Complaint Proceedings Delegated to the Enforcement Bureau, Report and Order, 33 FCC Rcd 7178 (2018) (Rule Consolidation Order); Implementation of the Telecommunications Act of 1996, Amendment of Rules Governing Procedures to Be Followed when Formal Complaints Are Filed Against Common Carriers, Report and Order, 12 FCC Rcd 22497 (1997) (Formal Complaints Order), Order on Reconsideration, 16 FCC Rcd 5681 (2001) (Formal Complaints Recon Order); Amendment of Certain of the Commission’s Part 1 Rules of Practice and Procedure Relating to the Filing of Formal Complaints Under Section 208 of the Communications Act and Pole Attachment Complaints Under Section 224 of the Communications Act, Order, 29 FCC Rcd 14078 (2014) (Formal Complaints Amendment Order). The rules governing this proceeding differ significantly from the Federal Rules of Civil Procedure. For example, the Commission requires parties to file fact-based pleadings. See Formal Complaints Order, 12 FCC Rcd at 54, para. 120, 47 CFR §§ 1.721(b)-(d), (r), 1.726(b). Further, Commission formal complaint proceedings “are generally resolved on a written record consisting of a complaint, answer, reply, and joint statement of stipulated facts, disputed facts and key legal issues, along with all associated evidence in the record.” 47 CFR § 1.721. 3 Letter from Charles W. Steese, Counsel for Life Time to Rosemary McEnery, Chief, Market Disputes Resolution Division, FCC Enforcement Bureau, Proceeding No. 26-95, Bureau ID No. EB-26-MD-003 (dated June 1, 2026) (Joint Letter). 4 Staff has authority under sections 0.111, 0.311 and 1.3 of the Commission’s rules, 47 CFR §§ 0.111, 0.311, 1.3, to modify the filing deadlines and other requirements contained in the formal complaint rules as the circumstances of individual cases warrant and to the extent consistent with section 1.740 of the rules, 47 CFR § 1.740. 5 In addition, if a filing contains a citation to material that appears on the Internet, the filing must attach a hard copy of that material. See 47 CFR §1.721(g), (k). 2 2) By JULY 28, 2026, Verizon must file and serve an answer to the Complaint that complies with 47 CFR § 1.726. Any interrogatories posed by Verizon must be filed and served concurrently with the answer. 47 CFR §1.730(a). 3) By AUGUST 27, 2026, Life Time must file and serve a reply to the answer that complies with 47 CFR § 1.728. Any additional interrogatories posed by Life Time must be filed and served concurrently with its reply. 47 CFR § 1.730(a). Life Time must also answer the interrogatories that Verizon served with its answer in accordance with section 1.730(c) of the Commission’s rules. 47 CFR §1.730(a), (c). 4) By SEPTEMBER 29, 2026, Verizon must answer the interrogatories that Life Time served with its reply in accordance with section 1.730(c) of the Commission’s rules. 47 CFR §1.730(a), (c). 5) At the request of the parties. we waive sections 1.722(i)(2), 1.726(f)(2), and 1.728(d)(2) of the rules for the complaint, answer, and reply.6 See 47 CFR §§ 1.722(i)(2), 1.726(f)(2), 1.728(d)(2). We note, however, that each party must still comply with section 1.721(d) and provide copies of the affidavits, documents, data compilations, and tangible things in its possession, custody, or control upon which that party relies or intends to rely to support the facts alleged and legal arguments made in its pleading. See 47 CFR § 1.721(d). 6) A party must file and serve any opposition and objections to the opposing party’s interrogatories within seven calendar days of service of the interrogatories. Any interrogatories to which no opposition or objection is raised must be answered in accordance with the schedule above. The parties engaged in pre-complaint discovery and have agreed that discovery in this proceeding shall be in accordance with the agreement in their Joint Letter.7 7) The parties must meet to discuss the resolution or narrowing of as many issues as possible. Such discussions should include the following matters: settlement prospects, discovery, factual and legal issues in dispute, the case schedule, and the preparation of a joint statement.8 See 47 CFR § 1.733(b). Based on these discussions, the parties should prepare a joint statement of (a) stipulated facts, (b) disputed facts, (c) key legal issues, (d) all proposals agreed to, and (e) any disputes remaining regarding the matters listed in 47 CFR § 1.733(b)(1). The parties’ joint statement must be filed by OCTOBER 15, 2026. We strongly encourage the parties to devote substantial effort to developing a comprehensive and detailed joint statement. See Formal Complaints Recon Order, 16 FCC Rcd at 5696-97, para. 35. After reviewing the joint statement, staff will contact the parties to discuss future steps in the proceeding. 8) The above schedule anticipates final action on the Complaint within 270 days of its filing. See 47 CFR § 1.740. The Enforcement Bureau has discretion to pause the 270-day review period where actions outside the Commission’s control (such as settlement discussions or mediation) delay Commission review of the complaint or where the Bureau determines that the issues and record are particularly complex, necessitating additional time for discovery, briefing or the submission of information requested by the Bureau. Id. The Enforcement Bureau intends to meet the 270-day deadline for final action and will be disinclined to grant requests for deadline extensions, absent a showing of good 6 See Joint Letter at 3. 7 See id. at 2. 8 Parties should attempt to resolve any discovery disputes prior to the submission of the joint statement. Staff will address any unresolved discovery disputes. Staff generally will consider motions to compel discovery filed pursuant to sections 1.729(b) and 1.730(h), 47 CFR §§ 1.729(b), 1.730(h), only after a party fails to comply with discovery ordered by Commission staff. 3 cause. Further, tight deadlines will apply to any discovery and briefing that may be permitted in this matter, and the parties and their counsel should plan their schedules accordingly. Any request for extension of the scheduled filing dates must be for good cause shown, and the parties should understand that the grant of such request will result in an adjustment to the deadline for final action based generally on the length of the extension. The parties must file a public version of all written submissions in this proceeding using the Commission’s Electronic Comment Filing System (ECFS). All written submissions should (a) prominently contain the Proceeding Number and Bureau ID Number referenced above, and (b) be addressed to the Commission Secretary. A party that seeks to file both a public version and a confidential version of a submission must do so in compliance with section 1.731 of the Commission’s rules, and must file the public (redacted) version on ECFS and file the confidential (unredacted) version in hard copy form with the Office of the Commission Secretary.9 See 47 CFR § 1.731. See 47 CFR § 1.731(a)(3). A party asserting confidentiality for any information or materials should restrict its designations to encompass only the specific information that it asserts is confidential, and the request for confidential treatment of any information shall contain a statement of the reasons for withholding each such confidential designation. 47 CFR § 0.459(b). Confidential designations in pleadings must be clearly identified and marked accordingly, e.g., [Begin Confidential]/[End Confidential]. Confidential filings also must clearly identify and mark each page, or portion thereof, which includes confidential designations. See 47 CFR § 1.731(a)(1). However, any “casual requests” that “simply [stamp] pages ‘confidential’” are insufficient and “will not be considered.” 47 CFR § 0.459(c). In addition to filing the original, unredacted version with the Office of the Secretary, please provide the Secretary’s Office with four (4) additional unredacted hard copies marked as “Courtesy Staff Copies. EB-MDRD, 202-418- 7330.” See 47 U.S.C. § 154(i); 47 CFR § 1.734(e). The parties must serve all filings via e-mail, hand- delivery, or overnight delivery, together with proof of service. See 47 CFR § 1.734(f). No hand or courier service deliveries are accepted at the FCC Headquarters. All hand and courier deliveries should be directed to Marlene H. Dortch, Secretary, Federal Communications Commission, Office of the Secretary, 9050 Junction Drive, Annapolis Junction, MD 20701. Also, please email courtesy copies of all filings (both public versions and confidential versions) in a format that permits full text searching, if possible, to Commission counsel for this proceeding and to Sandra Gray-Fields (sandra.gray- fields@fcc.gov). See 47 U.S.C. § 154(i); 47 CFR § 1.734(e).10 This proceeding is restricted for ex parte purposes. See 47 CFR Part 1, Subpart H. Further, the parties are required to retain all records that may be relevant to the complaint, including electronic records, until the Commission’s decision in this proceeding is final and no longer subject to judicial review. 9 We waive section 1.731(a)(3), 47 CFR § 1.731(a)(3), to the extent that it requires a hard copy of any confidential filing be delivered to the Secretary on the day of filing. A confidential filing in this proceeding will be considered timely filed provided that it is sent to the Secretary via overnight courier the first business day after any applicable service deadline. See Joint Letter at 3. 10 See Amendment of Certain of the Commission’s Part 1 Rules of Practice and Procedure Relating to the Filing of Formal Complaints Under Section 208 of the Communications Act and Pole Attachment Complaints Under Section 224 of the Communications Act, Order, 29 FCC Rcd 14078, 14081, para. 11 (2014) (requiring parties to provide hard copies of submissions to Commission staff upon request). 4 We issue this letter ruling under sections 4(i), 4(j), and 208 of the Act, 47 U.S.C. §§ 154(i), 154(j),208, , sections 1.3, 1.720-1.740, and 1.1401-1.1416 of the Commission’s rules, 47 CFR §§ 1.3, 1.720-1.740, 1.1401-1.1416, and the authority delegated in sections 0.111 and 0.311 of the Commission’s rules, 47 CFR §§ 0.111, 0.311. FEDERAL COMMUNICATIONS COMMISSION Anthony J. DeLaurentis Special Counsel Market Disputes Resolution Division Enforcement Bureau 5