null  null
Christopher Heimann
General Attorney
AT&T Services, Inc.
1120 20th Street NW, Suite 1000
Washington, D.C. 20005
Phone 202 457-3058
Fax 202 457-3074
REDACTED — FOR PUBLIC INSPECTION
February 27, 2014
Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street S.W.
Washington, D.C. 20554
Re:
Technology Transitions, GN Docket No. 13-5; AT&T Petition to Launch a
Proceeding Concerning the TDM-to-IP Transition, GN Docket No. 12-353
Dear Ms. Dortch:
AT&T respectfully submits the attached Proposal for Wire Center Trials in the abovereferenced dockets. Pursuant to the terms of the Protective Order and Second Protective Order in
these dockets, AT&T has redacted from this version all confidential and highly confidential
information for public inspection. Technology Transitions, AT&T Petition to Launch a
Proceeding Concerning the TDM-to-IP Transition, GN Docket Nos. 13-5, 12-353, Protective
Order, DA 14-272 (rel. Feb. 27, 2014); Technology Transitions, AT&T Petition to Launch a
Proceeding Concerning the TDM-to-IP Transition, GN Docket Nos. 13-5, 12-353, Second
Protective Order, DA 14-273 (rel. Feb. 27, 2014). Tomorrow, February 28, AT&T will file a
paper copy of the highly confidential version, which will include the confidential and highly
confidential information. If you have any questions, please contact me.
Respectfully submitted by,
/s/ Christopher M. Heimann
Enclosures
REDACTED -- FOR PUBLIC INSPECTION
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
In the Matter of
Technology Transitions
AT&T Petition to Launch a Proceeding
Concerning the TDM-to-IP Transition
)
)
)
)
)
GN Docket No. 13-5
GN Docket No. 12-353
AT&T PROPOSAL FOR WIRE CENTER TRIALS
CHRISTOPHER M HEIMANN
GARY L PHILLIPS
LORI A FINK
Attorneys For:
AT&T Services INC.
1120 20th Street, NW
Suite 1000
Washington, D.C. 20036
(202) 457-3058 – phone
February 27, 2014
REDACTED -- FOR PUBLIC INSPECTION
TABLE OF CONTENTS
Introduction and Overview …………………….………………………………………………....1
Trial Objectives ..………………………………………………………………………………..12
Trial Locations and Scope ………………………………………………………………………13
Services Included in the Trials ………………………………………………………………….17
Protecting Enduring Values ……………………………………………………………………..22
Wholesale Services ………………………………….…………………………………………..27
Conclusion ………………………………………………………………………………………30
i
REDACTED -- FOR PUBLIC INSPECTION
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
In the Matter of
Technology Transitions
AT&T Petition to Launch a Proceeding
Concerning the TDM-to-IP Transition
)
)
)
)
)
GN Docket No. 13-5
GN Docket No. 12-353
AT&T1 PROPOSAL FOR WIRE CENTER TRIALS
Introduction and Overview
Fifteen months ago, recognizing the seismic forces that were reshaping the
communications industry and the economy at large as IP platforms displaced legacy TDM
networks and services, AT&T filed a petition asking the Commission to authorize trials to
provide a forum for identifying and resolving the many operational, technical and social issues
raised by those changes. Under the leadership of Chairman Wheeler, the Commission granted
AT&T’s petition and provided a blueprint for those seeking approval to conduct such trials.
AT&T is pleased to submit this proposal for two trials involving the transition of two wire
centers — one rural and one suburban — to all IP services. AT&T’s hope and expectation is that
1
AT&T Services, Inc. files this proposal on behalf of itself and its operating company affiliates
(collectively “AT&T,” except where otherwise expressly noted). AT&T provides TDM and IP-based
services in the wire centers in which AT&T proposes to conduct the TDM-to-IP transition trials proposed
herein through multiple affiliates, including AT&T Communications of the Southern States, LLC, AT&T
Corp., AT&T Long Distance, AT&T Mobility LLC, BellSouth Long Distance, Inc., BellSouth
Telecommunications, LLC, and SBC of Florida. Throughout this operating plan, the term “AT&T”
generically refers to all such entities.
REDACTED -- FOR PUBLIC INSPECTION
the trials will provide the Commission, AT&T and other stakeholders valuable information to
ensure that the historic transition from 20th Century TDM technology to next-generation IP
networks and services proceeds as smoothly as possible, and in a way that is faithful to the
enduring social values — ensuring universal connectivity, consumer protection, public safety,
reliability and competition — that must continue to provide the foundation for communications
policies in the 21st Century.
The significance of this transition from a circuit-switched network to an all-IP world
cannot be overstated, nor can its potential to improve American lives and benefit consumers.
Indeed, Chairman Wheeler has described the IP transition as “the fourth network revolution,”
likening it to Gutenberg’s invention of the printing press, the birth of the railroad, and the advent
of instantaneous communications via telegraph and telephone. Each of those revolutions
collapsed time and distance as impediments to communication and human interaction. Each
resulted in exponential improvements in innovation, creativity, efficiency and human
communication.
The IP transition is well underway, even though its potential has barely been tapped.
Already it has transformed the way we communicate, educate our children, deliver healthcare,
consume energy, obtain news and other information, engage in commerce, and interact with
government. These changes, though, are just the tip of the iceberg: we have not yet even begun
to imagine, let alone experience, the promise of this Fourth Network Revolution.
Importantly, IP networks are also transforming the structure of the communications
industry. In the mid-1990s, during the last significant rewrite of the Communications Act, it was
assumed that a communications provider needed to own, or at the very least lease, transmission
facilities to the home in order to deliver communications services to customers and countless
2
REDACTED -- FOR PUBLIC INSPECTION
pages of new laws and regulations were written to promote investment in or sharing of those
facilities. Today, that vision is all but obsolete. To be sure, facilities-based providers of rival
broadband platforms engage in intense competition, as was envisioned by the 1996 Act. But this
competition is supplemented by intense competition from “over the top” providers of
applications and services, which compete head to head with facilities-based providers. Vonage
and Skype, for example, compete aggressively with telephone companies, cable multiple system
operators (MSOs) and others in the provision of voice telephone services, while Apple, Roku,
Google and others deliver video content directly to consumers through small pieces of hardware
that connect wirelessly to the consumer’s underlying broadband service. And just last week,
Facebook paid $19 billion for a provider of text messaging services that has more than 400
million users worldwide, despite the fact that it does not provide the underlying connectivity to
any of them. Incredibly enough, just a decade ago Facebook itself was an incipient social
networking service for Harvard University students; today it is a worldwide platform with 1.25
billion users.
These transformative changes are taking place at an extraordinary pace. Indeed, a
significant majority of Americans already have transitioned away from circuit-switched
telephony, even if many are not aware they have done so. More than 70 percent of residential
consumers in the 22 states where AT&T is the legacy “phone company” have abandoned legacy
phone service. They rely instead on wireless, VoIP, and/or other services offered by cable
companies and others. Indeed, in some states, the number of housing units purchasing legacy
circuit-switched services from an ILEC has fallen below 20 percent.
The reason so many consumers have made this transition so quickly is simple: IP-based
services offer greater functionality than circuit-switched telephony ever could offer, and the
3
REDACTED -- FOR PUBLIC INSPECTION
“value gap” will only widen with the continuing integration of IP networks with cloud
computing and the Internet of things. In other words, it is inevitable that over time circuitswitched telephony will become irretrievably obsolete. And that day is fast approaching. Not
only are customers abandoning circuit-switched networks and services in droves, making it
increasingly uneconomic to maintain those legacy networks, but manufacturers of the equipment
needed to maintain and operate those networks are likewise moving on. Those manufacturers
want to focus their businesses on the networks of the future, not technology that is being
displaced, and so they are discontinuing production of TDM equipment. As a result, it is
becoming increasingly difficult to obtain needed spare parts to keep legacy TDM networks
going. Indeed, as strange as it may seem, AT&T has had to turn to Ebay to locate spare parts for
its TDM network. At the same time, much of the workforce with the expertise to support TDM
networks and services has retired or is nearing retirement, and those who are replacing them have
no interest in becoming experts in yesterday’s technology. To the contrary, the best and the
brightest minds emerging from our nation’s leading engineering universities are focused on IP
technologies, the technologies of the future. In short, the IP-transition is well past the tipping
point, and at some point in the not-too-distant future it will no longer be possible to maintain
traditional TDM-based telephone networks and services. The demand won’t be there, the
economics won’t support it, and the parts and labor to keep these networks going will not be
available.
This is not news to the Commission. The Commission recognized in its historic National
Broadband Plan that IP networks and services are displacing TDM networks and services and
that maintaining both platforms in parallel is not a viable long term option. Doing so both
“reduces the incentive for incumbents to deploy” next generation facilities and “siphons
4
REDACTED -- FOR PUBLIC INSPECTION
investments away from new networks and services.”2 As Chairman Wheeler recently observed,
“[d]ue in part to outdated rules, the majority of the capital investments made by U.S. telephone
companies from 2006 to 2011 went toward maintaining the declining telephone network, despite
the fact that only one-third of U.S. households use it at all.”3 “The challenge for the country,” as
the Commission put it, “is to ensure that as IP-based services replace circuit-switched services,
there is a smooth transition for Americans who use traditional phone service and for the
businesses that provide it.”4 The trials that are now being initiated should provide valuable
information that can ensure we meet that challenge. And these trials come not a moment too
soon because they can be conducted while the existing circuit-switched infrastructure remains
operational.
To be sure, the transition to IP services will continue at rapid pace organically. Certainly
that is AT&T’s expectation, and AT&T is putting its money where its mouth is. Through our
Project Velocity IP (VIP), AT&T is investing billions of dollars in wireless and wireline
broadband networks to support future IP data growth and new services. We are planning to
expand our award winning U-verse broadband and video footprint to an additional 8.5 million
customer locations in our 22 state wireline footprint (resulting in a total of almost 33 million
customer locations — representing approximately 43 percent of our customer footprint — having
the capability of receiving a video, voice and broadband bundle). In total, we plan to expand our
wireline IP-broadband service to approximately 57 million customer locations, including U-verse
2
FCC, Connecting America: The National Broadband Plan, at 49, 59 (2010) (“National Broadband
Plan”).
3
Prepared Remarks of FCC Chairman Tom Wheeler, Silicon Flatirons, University of Colorado Law
School, Boulder, CO (Feb. 10, 2014), available at: http://www.fcc.gov/document/fcc-chairman-tomwheeler-remarks-silicon-flatirons (last checked Feb. 25, 2014) (adding that we must “act to ensure that
more investment flows to the fiber-optic networks of tomorrow. . . .”).
4
The National Broadband Plan at 59.
5
REDACTED -- FOR PUBLIC INSPECTION
services to a total of 33 million customer locations. We expect to be substantially complete in the
2015 and 2016 timeframe. At the same time, we are significantly increasing the broadband
speeds available to U-verse customers as part of this plan. More than half of AT&T’s U-verse
broadband base has downstream speeds of 12MB or higher and we can deliver speeds of up to
45MB to approximately two-thirds of our U-verse video customers.
Our investments are not limited to residential customers. We also are expanding our
fiber deployment, building fiber facilities to a planned 1,000,000 additional business locations
within our 22 state wireline footprint. That investment will also serve as the platform for
additional Distributed Antennae Systems, Cloud capabilities and enhanced Network-based
security capabilities.
On the wireless side, we are expanding our 4G LTE network to cover approximately 300
million people across the nation and expect to essentially complete this expansion by the summer
of 2014. To enhance that additional coverage, we announced plans to build 10,000 new macro
cell sites, utilize over 40,000 small cells and construct over 1000 Distributed Antennae systems.
In total, we expect Project VIP to provide high-speed connectivity to approximately 99
percent of customer locations in AT&T’s 22-state wireline service area, producing significantly
greater broadband speeds and capabilities for AT&T’s customers across the board. Our wireline
IP network will reach approximately 75 percent of the customer locations in our 22-state wireline
footprint, with many experiencing significantly faster speeds. Those customers will also have
access to 4G LTE services, as will almost all the customers who will not be reached by U-verse
or U-verse IPDSL. Our 4G LTE network will provide broadband at speeds up to 12 Mbps –
significantly more robust than any of our legacy wireline DSL products. In addition to
upgrading the reach of our 4G LTE networks, AT&T plans to introduce a Wireless Home Phone
6
REDACTED -- FOR PUBLIC INSPECTION
service with LTE capabilities provided by AT&T Mobility, which will enable customers to use
their existing home telephone to connect to our wireless broadband service with the features
customers expect from a home telephone service, with the additional option of purchasing
wireless broadband Internet access service. The only difference is that customers will be
connected to our network wirelessly rather than through a legacy twisted-pair, copper loop. As a
result of these investments, we will be able to ensure that there are robust options for customers
throughout our serving area in an all-IP world. The underlying technology will change and
customers will enjoy an expanded palate of enhanced features, functions, and capabilities. But
while it is understandable that some consumers fear change, consumers are not going to lose
phone service as a result of these trials, nor will AT&T abandon its commitment to the core
principles that have guided communications policies over the past century.
To the contrary, in developing its plans for the trials (and the IP transition more
generally), AT&T was guided by the same principles and values that the Commission articulated
in its order authorizing these trials. These principles are:
x
Universal Connectivity – All Americans, regardless of who they are or where
they live, should have access to next generation broadband networks and
services. The trials should shed light on how best to achieve that core goal.
x
Consumer Protection – Consumers are entitled to certain basic protections,
including a right to privacy, number portability, and safeguards against
fraudulent, deceptive and unfair business practices.
x
Public Safety – The transition to next generation wireless and IP-based services
should not disrupt public safety, national security or emergency preparedness and
response.
x
Reliability – Next generation wireless and IP-based networks and services should
be dependable and reliable. As we transition to services that rely increasingly on
commercial power for customer premises equipment, service providers,
manufacturers, consumers, and policymakers need to work together to ensure that
such equipment has adequate battery back-up and consumers understand the
steps they need to take to avoid losing connectivity during a power outage.
7
REDACTED -- FOR PUBLIC INSPECTION
x
Competition – Competition produces better outcomes for consumers than
regulated or uncompetitive markets. Competition encourages innovation and
investment, ensures that consumers have access to the services (including
features, functions, and capabilities) they want at prices that are reasonable.
These principles (and the policies and rules enshrining them) have made America’s
existing communications network the envy of the world, and should continue to apply across all
platforms and providers as we complete the historic transition to all-IP networks and services.
But the way in which these principles are implemented must evolve to reflect marketplace and
technological developments. While all of them are likely to undergo significant adaptation as we
complete the IP transition, perhaps none will be as challenging as ensuring that next-generation
services extend to all Americans, in particular to Americans who live in rural areas.
In the attached document, AT&T has laid out a detailed plan for how we propose to
conduct TDM to all-IP trials in two wire centers. The plan identifies the geographic areas in
which AT&T will conduct the trials, the specific TDM-based services that ultimately will be
discontinued, the wireless and wireline IP-based alternatives that AT&T will offer, and other
competitive alternatives available to customers in the test-bed wire centers. It also details
AT&T’s plans for notifying customers about the transition and migrating them to alternatives,
and identifies special considerations, such as how AT&T proposes to address public safety,
access by persons with disabilities, access by seniors and others with unique needs, and other
important issues. AT&T is eager to receive input on its proposed trial plan from the Commission
and other interested parties. We look forward to working with all stakeholders to resolve any
issues that may arise.
For the most part, current federal and state rules will not stand in the way of these trials.
We can introduce new IP-based services at any time and indeed already have introduced many
8
REDACTED -- FOR PUBLIC INSPECTION
such services. However, we understand the need to work cooperatively with federal and state
policymakers to retire the circuit-switched and TDM services that have served this country for so
many years. By working together, policy-makers, consumers, service providers and other
industry stakeholders will be able to develop plans to manage the IP transition in an efficient and
pro-consumer manner, while the TDM network remains in place. This proceeding provides a
forum to help ease this transition and address any unresolved or unknown issue that could
impede our progress. But make no mistake, whether a customer subscribes to a wireless or a
wireline broadband product, the capabilities of both of those services far exceed what is available
in the circuit-switched POTs environment.
The Commission successfully has overseen similar technology transitions before. Twice
in the past decade, the country has gone through similar transitions in communications
technology and services – in the transition from analog to digital cellular service, and from
analog to digital TV. In both cases, the Commission planned ahead and adopted policies to
“ensure that legacy regulations and services did not become a drag on the transition to a more
modern and efficient use of resources, that consumers did not lose services they needed and that
business could plan and adjust to the new standards.”5 These prior transitions establish the
critical importance of identifying and cooperatively planning for all of the challenges that may
arise as the country completes the TDM-to-IP technology transition, which is likely to have more
far-reaching consequences and be more important to the economic growth and well-being of the
nation than any that came before. Like the DTV trial in Wilmington, North Carolina,
geographically limited IP trials, like those proposed herein, will provide the Commission,
industry, and customers invaluable real-world experience regarding the issues that may arise as
5
National Broadband Plan at 59.
9
REDACTED -- FOR PUBLIC INSPECTION
we discontinue the TDM facilities and services on which many Americans still rely even as
many others already have made the switch to next-generation wireless and wireline IP-based
services.
Under the order the Commission adopted to oversee these trials, wholesale customer
participation will be voluntary during the initial stage of the trials. Retirement of wholesale
services does remain a critical issue in the conversion to an all-IP world. At the same time we
recognize that wholesale access, and other issues, are likely to be contentious, and will spark
much debate over the next few years. Consequently, we have included in this plan a description
with details of how we intend to proceed with respect to wholesale issues. We will either
address those issues by proposing additions to the trials themselves or through existing processes
under the Communications Act and the Commission’s rules. It is important to be transparent
about how these issues fit into the overall IP transition. It is our goal to pursue consensus and
certainty regarding these issues, as well as to ensure that all providers have sufficient notice to
prepare for the transition and the day when TDM wholesale services no longer will be available.
The IP transition, and the wire center trials detailed herein, will not happen overnight.
AT&T expects that the trials and transition will take several years. Many of the products and
services AT&T intends to offer in place of traditional, wireline TDM telephone services are
already available in the marketplace, and millions of customers already have transitioned to
them. But AT&T is still working on developing and enhancing other services that will become
available as the trials proceed. Thus, the transition of customers to IP will vary depending on the
services at issue, and the trial and this detailed plan likely will change and evolve as we proceed.
In all cases, AT&T will seek to encourage to the greatest extent possible a voluntary migration
through customer outreach and education. During the first phase of the trial, and after the
10
REDACTED -- FOR PUBLIC INSPECTION
Commission’s approval, AT&T plans to grandfather existing customers, and offer only next
generation wireless and wireline IP-based services for new orders. Ultimately, existing
customers will also have to upgrade to such alternatives, but as the FCC has constructed the
trials, that second phase will not begin until after the Commission has evaluated results of Phase
1 and authorized us once again to move forward to the full IP transition. In each case though,
AT&T will afford customers ample notice regarding the transition so that they can plan
accordingly. And consistent with the Technology Transitions Trial Order, AT&T will seek
Commission approval at each stage in the process to ensure the Commission is satisfied that
customers will be protected.
We note that AT&T’s proposed wire center trials contemplate network and service
changes beyond those addressed in the Technology Transitions Trial Order. Thus, we recognize
that, at this time, the Commission may not approve all aspects of the trial proposed herein. But,
all of the network and service changes identified in the attached plan will be essential to
complete the IP transition. And, insofar as the purpose of the trials is to enable all interested
parties to identify and resolve the many issues that will arise as the nation migrates to all-IP
services, we have sought to identify all of the network, service and other changes that will be
necessary to complete the transition (or at least all of the changes we have identified to date) to
open a dialogue regarding all of the implications and questions that must be addressed as the
transition proceeds. We emphasize that, at all phases of the trial and transition, AT&T will
proceed in an open and transparent manner, and that the Commission will remain in control of
the trials to ensure that the transition proceeds in a manner consistent with the public interest.
11
REDACTED -- FOR PUBLIC INSPECTION
Trial Objectives
The trials AT&T is proposing have several important objectives. First, the trials are
designed to provide a process and forum for identifying and resolving the operational, technical,
logistic, and other issues (both known and unforeseen) that could arise when existing TDMbased networks and services are discontinued and the customers remaining on those networks
have to transition to next-generation wireless and wireline IP-based alternatives. We need to
understand how this major technology change will impact consumers to ensure that IP transition
proceeds as smoothly as possible, and in a way that is faithful to the enduring social values that
have been at the root of communications policies over the past century. The trials provide a
forum to work with and hear from customers and policymakers to make sure that we are timely
addressing any issues or concerns that could impede an orderly transition. Second, the trials are
intended to help AT&T (working with policymakers, customers and other stakeholders) further
develop and implement processes for migrating customers (including residential, small and large
business, wholesale, and governmental customers) off of traditional TDM networks and services
and onto all IP platforms. We need to understand how to actually operationalize this effort
efficiently, so that we have as little customer disruption as possible. Third, the trials seek to
ensure that customers, manufacturers, policymakers, and other stakeholders have sufficient
education and notice regarding the impending transition so that they also have the opportunity to
prepare for the time when TDM networks and services no longer are available. And fourth, we
hope to come out of the trials with an actionable plan that we can utilize to continue this
transition in our approximately 4,700 wire centers and across the country in order to meet our
stated goal of completing the IP Transition by the end of 2020.
12
REDACTED -- FOR PUBLIC INSPECTION
Consistent with these objectives, the trials seek to replicate on a small scale the broader
TDM sunset and migration to all-IP networks and services. Although many of the issues posed
by the transition are common to all customers, each customer segment (residential, small and
large business, government, wholesale) has its own, unique needs and challenges. Consequently,
what works well for one segment may not be the best for another. The trials AT&T is proposing
thus seek a complete migration of all customers (or as many as possible) to IP-based services in
two wire centers. Excluding particular customer segments and/or services (such as dedicated or
wholesale services) from the trial will deprive the Commission, consumers, industry and others
of important real-world experience needed to prepare for the IP transition.
Trial Locations and Scope
AT&T is proposing to conduct the trials in a rural wire center in Carbon Hill, AL, and in
Kings Point, a suburban wire center in Palm Beach County, FL.6 AT&T chose these wire
centers with an eye towards gaining insights into some of the more difficult issues that likely will
be presented by the TDM sunset. For example, Carbon Hill is a sparsely populated wire center
located in rural Alabama with particularly challenging economic and geographic characteristics.
There are approximately 4,388 living units in the Carbon Hill wire center. Living units include
both business and residential locations (even if not currently occupied), as well as business or
residential locations currently under construction.7 Of the 4,388 living units in Carbon Hill to
which AT&T offers wireline services, roughly [CONFIDENTIAL – NOT FOR PUBLIC
DISCLOSURE] percent subscribe to AT&T’s retail wireline services (TDM and IP). This fact
6
The Kings Point serving wire center is located in an unincorporated part of Palm Beach County, west of
the City of Delray Beach, FL. For purposes of this filing and the attached detailed plan, we will refer to
that serving wire center as the “Kings Point” wire center.
7
Living Units are the units AT&T’s network engineers use when designing and building communications
networks because each living unit is a separate location that AT&T historically has been required to serve
upon request.
13
REDACTED -- FOR PUBLIC INSPECTION
underscores the point that many customers already have made the choice, even in rural areas, to
transition away from the traditional TDM telephone network and services; it also vividly
illustrates the increasingly difficult economics of the traditional wireline business and the
regulatory framework associated with it. It is also worth noting that while the Carbon Hill wire
center may qualify for funding under the Commission’s revised universal service rules, the
amount of that funding has yet to be determined — we thus welcome the CAF Phase II trial
proposed by the Commission to try to begin finding answers to some of these questions.
Under AT&T’s proposed plan, we would provide wireline and/or wireless broadband
services to approximately 96 percent of the Carbon Hill living units – [CONFIDENTIAL –
NOT FOR PUBLIC DISCLOSURE] percent of those living units will have a wireline
broadband alternative and [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE] percent
will have only a wireless 4G LTE solution available. Providing broadband services to the final 4
percent of the living units will be more difficult given the economics of deploying broadband
services to those areas. AT&T recognizes that it is responsible for ensuring that these customers
will have an alternative available to them prior to discontinuing TDM services and is, in all
events, committed to working with the Commission, policymakers and other stakeholders to
ensure that this happens. It is, however, critically important that we engage in a dialogue that
addresses the geographic, demographic, and economic challenges of deploying and offering
broadband in sparsely populated areas, like Carbon Hill. This is precisely why AT&T selected
Carbon Hill as one of the trial wire centers, so that we and other stakeholders can begin that
dialog on how best to resolve this issue while the TDM network remains in place.
Kings Point likewise raises important issues. Kings Point is a suburban wire center
located in the West Palm Beach metropolitan area with a large population of older Americans
14
REDACTED -- FOR PUBLIC INSPECTION
(according to US Census data, more than 70 percent of its population is over 50 years of age).
Although many older Americans already have made the transition from traditional wireline
telephone services to wireless and wireline IP-based services (often without even knowing they
have done so), as a group they have been slower to migrate to these newer technologies. Kings
Point thus will provide AT&T, the Commission and other stakeholders with critical insights into
any unique challenges the IP transition may pose for seniors, and how best to address them.
There are 49,712 living units in Kings Point to which AT&T offers wireline services, of which
only [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE] percent currently subscribe to
an AT&T wireline retail service. That means that, like Carbon Hill, a large percentage of
customers have already migrated to wireless, IP-based or other services. Under AT&T’s current
plans, we will offer wireless broadband services to 100 percent of the living units in Kings Point,
and wireline broadband services to [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE]
percent of the living units.
The wire centers AT&T chose for these trials will raise some of the most challenging
geographic and economic issues that we will face with respect to the IP transition. While we
recognize that other locations will raise issues that may be different in either degree or kind, we
believe that these two wire centers will provide many valuable insights into most of the
challenges that must be overcome to make the transition as smooth as possible.
Among the most important of these issues is how to achieve universal access to
broadband and other communications services in competitive markets. Over the last century,
policy-makers and local telephone companies relied on a complex web of implicit subsidies
(shifting costs from local to long distance, rural to urban, and residential to business) to fund
universal wireline service in rural and other high cost areas. That system made sense at a time
15
REDACTED -- FOR PUBLIC INSPECTION
when local telephone companies were granted monopoly franchises in return for their universal
service commitment. But the 1996 Act made that regulatory compact obsolete by opening all
telecommunications markets to competition and requiring that the web of implicit subsidies,
which Congress recognized would no longer be sustainable with competition, be replaced with
adequate explicit subsidies targeted to rural and other high cost areas. In the ensuing two
decades, robust competition both in urban areas and for the lowest cost, most profitable
customers, combined with intercarrier compensation reform, have eliminated the implicit
subsidies on which local telephone companies relied to make universal, low-cost wireline service
feasible. The introduction of broadband services and the arrival of even more competition from
“over-the-top” service providers gave consumers even more choices, but also put the subsidy
system in free fall. Existing federal and state universal service support mechanisms (at least for
price cap carriers like AT&T) were not designed to make up the shortfall, and the Commission’s
new mechanisms to support broadband deployment in high cost areas remain works in progress.
As a consequence, the system pursuant to which one provider (the ILEC) could shoulder
the entire burden of achieving universal connectivity in high cost areas is long gone. The good
news is that by opening up our markets to competition, we have seen investments by telephone
companies that have enabled them to compete in the video market; investments by cable
companies that enabled them to compete in the voice market; and investment by cable,
telephone, wireless companies and others, resulting in a robustly competitive broadband market
that has brought more service choices to consumers. According to a White House report on
Broadband Growth released in June 2013, “two of the largest telecommunications companies
account[ed] for greater combined stateside investment than the top five oil/gas companies, and
16
REDACTED -- FOR PUBLIC INSPECTION
nearly four times more than the big three auto companies combined.”8 Indeed, between 2009
and 2012, nearly $250 billion in private capital was invested in U.S. wired and wireless
broadband networks, annual investment in U.S. wireless networks grew more than 40 percent,
from $21 billion to $30 billion, and more high-speed fiber cables were laid in the United States
than in any similar period since 2000.9 But, given the high cost, and limited returns, of
deploying broadband in remote areas with sparse populations, some locations lack a positive
business case for private sector investment. In these areas, additional universal service support
may be necessary to solve the broadband equation for everyone. Thus, while universal
connectivity is a bedrock principle that should continue in an all-IP ecosystem, how we as a
nation achieve that goal will have to change.
The foregoing universal service, intercarrier compensation, and Lifeline issues have been
raised in a myriad of different proceedings currently pending before the Commission. We hope
and expect that the trials commenced in this proceeding will provide the context and information
the Commission needs to complete its reform of universal service in a way that will enable the
United States to achieve its goal of ensuring that all Americans have access to affordable
broadband services. And, as we indicate above, AT&T is committed to working with policymakers, customers, industry, and others to find the right solutions.
Services Included in the Trials
AT&T proposes to include in the trials all of its consumer TDM-based voice and internet
access transport services, and to offer AT&T’s U-verse Voice service, AT&T’s U-verse High
8
Office of Science and Technology Policy & The National Economic Council, Four Years of Broadband
Growth, at 5 (June 2013) (citations omitted), available at
http://www.whitehouse.gov/sites/default/files/broadband_report_final.pdf (last checked Feb. 23, 2014).
9
Id. (citations omitted).
17
REDACTED -- FOR PUBLIC INSPECTION
Speed Internet services, and AT&T Mobility’s Wireless Home Phone and Wireless Home Phone
and Internet with 4G LTE Broadband services in place of those TDM services. Customers
within AT&T’s wireline IP network footprint have access to AT&T’s U-verse® Voice and High
Speed Internet services, which provide next-generation voice calling features and high-speed
broadband Internet access.10 Customers in AT&T’s wireless footprint also will be able to
purchase one of AT&T’s commercial mobile radio services (CMRS) (including AT&T
Mobility’s Wireless Home Phone and Wireless Home Phone and Internet with 4G LTE
Broadband service) in place of traditional, TDM-based voice telephone services. For those
customers located outside AT&T’s wireline IP footprint, AT&T will offer only its Wireless
Home Phone and Wireless Home Phone and Internet with 4G LTE Broadband service (or other
wireless services) in place of TDM services.11 AT&T’s Wireless Home Phone and Wireless
Home Phone and Internet with 4G LTE Broadband services include nationwide calling with
enhanced calling features. The wireless Internet component of Wireless Home Phone and
Internet provides broadband Internet speeds generally capable of downstream speeds between 512 Mbps. AT&T’s LTE network is consistently recognized as the fastest, most reliable LTE
network in the nation.
AT&T also proposes to transition its current retail business customers in the trial wire
centers from TDM-based voice and data services to wireless and wireline IP-based services over
the next three years. AT&T will offer business customers within its wireline IP network
10
Approximately [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE] percent of the living units in the
King’s Point Wire Center will have access to AT&T’s U-verse video service as well as broadband and
voice.
11
Fewer than one percent of AT&T existing consumer customers with TDM-based services are located in
areas outside of AT&T’s IP network footprint and are ineligible for the Wireless Home Phone products
because of the wireless network coverage issues.
18
REDACTED -- FOR PUBLIC INSPECTION
footprint a variety of IP-based business-class voice services that include next generation calling
features,12 such as U-verse® Business Voice, AT&T Voice DNA® and IP Flexible Reach, in
place of legacy TDM services, such as BellSouth Centrex and Business Access line services.
AT&T also offers IP-based Internet access and data services in the Trial Wire Centers, including
U-verse® High Speed Internet-Business Edition, and a variety of business-class Ethernet
services that deliver extremely reliable service at ultra-fast speeds. AT&T is in the process of
developing a wireless business phone product, which (like Wireless Home Phone) will enable
business customers in AT&T’s wireless footprint to use their existing CPE to communicate over
AT&T’s wireless network. AT&T’s Wireless Business Phone service will include nationwide
calling with enhanced calling features designed for business and wireless Internet access using
AT&T’s 4G LTE network.
The wireless and wireline IP-based services that AT&T will offer in place of traditional
TDM-based services will support the vast majority of the devices and applications enumerated in
Appendix B of the Transitions Trial Order. However, AT&T does not currently plan to support
certain limited applications with rapidly declining market demand or applications that are based
on outdated technology. In the Device and Application Compatibility Chart included in the
attached Wire Center Trial Operating Plan, AT&T has identified whether particular applications
or devices currently supported over TDM also are (or will be) supported over AT&T’s wireless
and wireline IP-based replacement services (we also identify the date by which AT&T expects to
support applications and devices still under development). We do so in order to ensure that all
12
AT&T’s wireline IP network in the Carbon Hill and Kings Point wire centers currently covers
[CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE] percent of the service locations of AT&T’s
current business customers in Kings Point, percent in Carbon Hill. AT&T recognizes that it is and
[CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE] responsible for ensuring that these customers
will have an alternative available to them prior to discontinuing TDM services and is, in all events,
committed to working with the Commission, policymakers and other stakeholders to ensure that this
happens.
19
REDACTED -- FOR PUBLIC INSPECTION
interested parties have an opportunity to engage in a dialog regarding the features and functions
consumers and businesses that should continue in an all-IP ecosystem even if the particular
application by which that functionality is provided today is retired.
In addition, AT&T Mobility’s Wireless Home Phone and Wireless Home Phone and
Internet services currently are not compatible with analog data devices and services (e.g., home
security systems, fax machines, and dial-up Internet service). AT&T understands the importance
of some of these capabilities and is therefore developing enhancements to Wireless Home Phone
with LTE that will allow this wireless service to work with analog data devices, such as alarm
monitoring, medical alert and credit card applications. We currently plan to introduce all of the
foregoing enhancements [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE]. AT&T
will not seek to grandfather its TDM-based voice services until these enhancements are
available.
Like AT&T Mobility’s other mobile wireless (“CMRS”) service offerings, Wireless
Home Phone presently complies with the Commission’s existing CMRS 911 service regulations
(47 C.F.R. Part 20). This means that, depending on the subscriber’s location, Wireless Home
Phone will provide access to Basic 911 Service (Basic), Phase I Enhanced 911 Service (Phase I),
or Phase II Enhanced 911 Service (Phase II). As the Commission knows, Phase II service
includes providing the PSAP both the telephone number of the originator of the 911 call and the
caller’s longitude and latitude in conformance with the Commission’s Phase II accuracy
requirements.13 All of the PSAPs serving the Carbon Hill and Kings Point wire centers are
Phase II compliant.
13
47 C.F.R. § 20.18(h).
20
REDACTED -- FOR PUBLIC INSPECTION
AT&T recognizes that regulators and the public safety community have raised concerns
regarding situations in which consumers are required to accept a different standard of 911
access, and thus is working on a solution to address these concerns. Specifically, AT&T is
developing upgrades to the 911 capability of Wireless Home Phone by adding an ALI function to
emulate the customer’s experience with wireline TDM service.14 To emulate the wireline 911
experience in a mobile offering, we are developing enhancements that will allow AT&T to send
MSAG information to the appropriate PSAP while the device is at a registered service address.
Under any such solution, the service would have to allow subscribers to update their MSAG
address easily and accurately when the base station device has been moved to a new location.15
To the extent a customer uses the device while in motion (such as in a mobile home or other
vehicle), the device would provide the same 911 functionality as any other CMRS device. We
currently plan to introduce this enhancement [CONFIDENTIAL – NOT FOR PUBLIC
DISCLOSURE]. AT&T will not seek to grandfather its TDM-based voice services until this
enhancement is available.
AT&T has included in Exhibit E Product Data sheets for each TDM-based service that
AT&T proposes to grandfather, and ultimately sunset, in the trial wire centers. The Product Data
sheets provide the following information concerning each service: current customer counts for
the service, proposed grandfather and sunset dates, proposed customer notification dates,
AT&T’s replacement products, and the presence of competitive alternatives in the trial wire
centers.
14
Today, with wireline telephony, calls to 9-1-1 provide both the call back telephone number (ANI) and
the Master Street Address Guide (MSAG) location—i.e., the dialing party’s actual street address.
15
If the wireless device were not at the registered MSAG location, then the service could still provide the
calling party’s ANI and ALI, i.e., the latitude and longitude of the caller’s location, as appropriate for any
other wireless device operating on AT&T’s licensed spectrum.
21
REDACTED -- FOR PUBLIC INSPECTION
Protecting Enduring Values
Protecting Consumers
AT&T will continue to meet its historic commitment to meeting the needs of persons
with disabilities and populations with unique needs (including seniors, persons with limited
English proficiency, low-income populations, and residents of Tribal lands).16 That commitment
will not change during the trials proposed herein (or, indeed, during the broader IP transition).
That commitment is unparalleled in the communications industry and is a model for service
providers in other industries.
From its founding, AT&T has recognized the vital role that technology can play in
enhancing the lives of all persons, especially those with disabilities, and how products designed
to enable disability access can benefit all customers.17 Thus it has integrated accessibility into all
aspects of the product and service life-cycle from basic research and product development to
marketing and customer service in order to create cutting-edge products and services to meet the
communications needs of persons with disabilities, seniors and other underrepresented
populations with unique needs, and ensure that they can benefit from advances in
communications technologies. Among other things, AT&T has developed a corporate
16
As discussed in section 6.2.2. of the Trial Operating Plan, one of the IP-based replacement services
AT&T will offer in the trial wire centers is its Wireless Home Phone service. The price of Wireless
Home Phone is lower than a typical customer pays today for traditional telephone service, providing low
income consumers (including seniors on a fixed income) a low-cost option that meets their budgetary
needs.
17
Indeed, Alexander Graham Bell, the founder of AT&T, was a teacher of deaf people, and his invention
of the telephone in 1876 was an outgrowth of his efforts to develop the first hearing aid. Global Initiative
for Inclusive Information and Communication Technologies (G3ict), White Paper, Accessibility,
Innovation, and Sustainability at AT&T: How a culture of inclusion and the adoption of Universal
Design at AT&T drive business processes to serve persons with disabilities, at 13 (2013) (listing early
accessibility milestones at AT&T) (available at:
http://www.att.com/Common/merger/files/pdf/G3ict_White_Paper.pdf), attached hereto as Exhibit G.
G3ict is an Advocacy Initiative of the United Nations Global Alliance for ICT and Development, which
seeks to facilitate and support implementation of the Convention on the Rights of Persons with
Disabilities.
22
REDACTED -- FOR PUBLIC INSPECTION
accessibility policy, which provides that AT&T will perform accessibility evaluations as early as
feasible in the design of new and redesigned products and services, networks, and applications,
and implement accessibility features where achievable. It has a Corporate Accessibility
Technology Office to undertake those evaluations and to engage the disability community about
how to improve the accessibility of products and services to persons with disabilities. AT&T
also has a Human Factors Group to test company designs to evaluate the accessibility and
usability of products and services, and invites aging adults and persons with disabilities to take
part in these studies as appropriate.
Although AT&T itself does not develop or manufacture customer equipment, it works
with manufacturers and third-party accessibility, aging, technology and disability organizations
to encourage and specify the development of products that meet the needs of persons with
disabilities, seniors, and others with unique needs. It also has an Advisory Panel on Access and
Aging, which meets regularly with national leaders in assistive technology, aging and disabilities
to discuss issues impacting customers, emerging accessible and usable technologies, current
products and services, and customer service for persons with disabilities and seniors; a
Citizenship & Sustainability Expert Team on Access and Aging to champion accessibility across
AT&T; a National Center for Customers with Disabilities, which handles inquiries and requests
relating to AT&T Mobility’s products and services; and a Disability and Aging Center, which
operates call centers dedicated to serving the elderly and persons with disabilities, in English and
in Spanish, across AT&T’s entire wireline footprint. In addition, AT&T has customer service
representatives available to respond to inquiries from persons with limited English proficiency in
Cantonese, Mandarin, Korean, Tagalog, Japanese, Russian, and Polish, in addition to Spanish.
In short, ensuring that persons with disabilities, seniors and other populations with unique needs
23
REDACTED -- FOR PUBLIC INSPECTION
have access to communications products and services that meet their needs is our commitment
and integral to everything we do.
AT&T has a proven track record of delivering innovative solutions to ensure that persons
with disabilities and others with unique needs have access to cutting edge communications
technologies and services. The following list highlights just a few of these solutions:
FACETIME OVER CELLULAR
In October 2012, AT&T rolled out several new billing plans making FaceTime over
Cellular available to deaf and hard of hearing customers who qualify for special text and
data-only packages.
TEXT ACCESSIBILITY PLAN (TAP)
AT&T offers the Text Accessibility Plans (TAP), which was designed with input from
the deaf community and provides lower-cost data and text plans for the deaf and hard of
hearing.
FREE 411 (MOBILITY DIRECTORY ASSISTANCE)
Recognizing that directory assistance services can facilitate dialing by customers with
significant visual, cognitive, and physical disabilities, AT&T provides 24/7 access to live
operators to enable customers to obtain local and national telephone numbers and
addresses ( which can be delivered via a text message), and connections to those numbers
at no additional fee to qualified customers. Customers also can use 4-1-1 Info to obtain
information regarding nearby businesses, movie showtimes, turn-by-turn driving
directions, reverse lookup, and business category search information.
U-VERSE® EASY REMOTE
24
REDACTED -- FOR PUBLIC INSPECTION
AT&T developed Easy Remote to make it easier for persons with disabilities and older
customers to access and use AT&T’s award-winning U-verse television service through
voice commands, and even customer gestures. U-verse Easy Remote provides access to
more than 50 powerful and user-friendly features, like customizable screen displays and
gesture commands, to help users quickly navigate to their favorite channels. Powered by
AT&T WatsonSM speech recognition technology through the AT&T Speech API, the app
not only recognizes voice input, but also will learn and adapt to individual speech
patterns. The U-verse Easy Remote app is currently available for download free of
charge in the iTunes store.
AT&T SPEECH MASHUP
AT&T’s cloud-based Speech Mashup enables anyone to easily create innovative and
accessible services for a wide variety of internet connected devices including smart
phones, tablets, computers and television control boxes. In 2011, AT&T received the
FCC Chairman’s “Lifted By The Cloud Award” and the FCC Chairman’s Award for
Advancement in Accessibility for Speech Mashup.
ACCESSIBLE DVR PROGRAMMING FOR U-VERSE TV
AT&T U-verse customers can program their DVR from their PC, allowing visually
impaired subscribers to easily schedule recordings.
HEARING AID COMPATIBLE MOBILE PHONES
To ensure that deaf and hard of hearing individuals have access to digital wireless devices
that meet their needs, AT&T offers dozens of hearing aid compatible mobile phones with
different features and at different prince points. Nearly all of these devices carry a
25
REDACTED -- FOR PUBLIC INSPECTION
compatibility rating of M3 or M4, which are less likely to generate interference to
hearing devices.
AT&T also has been recognized frequently as a leading provider of accessibility and
equal opportunity by disability organizations, including:
x
American Foundation for the Blind Access Award, 2013, which honors
individuals, corporations and organizations that eliminate or substantially reduce
inequities faced by people with vision loss. AT&T won the award for its UVerse Easy Remote App;
x
DiversityInc Top 10 Companies for People with Disabilities, 2013, which ranked
AT&T at number 6 (AT&T also ranked in the top 10 in 2012);
x
DiversityInc Top Company for Supplier Diversity, 2013;
x
Careers and the Disabled Magazine Top 50 Employers List, 2012 (AT&T ranked
as Number 1 employer for professionals with disabilities);
x
USBLN Market Share Corporation of the Year, 2011 (presented to the employer
that has demonstrated exceptional products and/or services to benefit the
disability community);
x
Equal Opportunity Employer Magazine, 2011, Top 50 Employer;
x
2013 Company of the Year from the Texas Department of Assistive and
Rehabilitative Services (DARS) for a “culture that gives all employees the
opportunity to excel both personally and professionally.”
AT&T has included in its detailed plan for conducting TDM to all-IP trials an outreach
plan for persons with disabilities and other populations with unique needs as an integral
component of the trials to ensure that they will continue to have access to the communications
services they need. That plan has five elements: identifying customers with disabilities in the
trial wire centers; customer outreach and education; customer care and support; identifying
accessible technology solutions; and transitioning persons with disabilities from one service to
another. Taken together, these elements will ensure that AT&T can and will meet the needs of
disabled persons and other populations with unique needs.
26
REDACTED -- FOR PUBLIC INSPECTION
Protecting Customer Privacy.
AT&T will conduct all aspects of the trial consistent with the AT&T Privacy Policy,
which applies to our legacy TDM services, as well as IP-based services. In addition, AT&T will
continue to comply with applicable privacy laws and regulations, including those concerning
customer proprietary network information (CPNI). AT&T has established comprehensive
processes and procedures designed to ensure compliance with the Commission’s CPNI
regulations.18 Accordingly, pursuant to the Commission’s 2007 order extending the CPNI
regulations to interconnected VoIP providers, the AT&T business units that provide
interconnected VoIP services – AT&T Business, AT&T Home Solutions and AT&T Mobility –
apply these processes and procedures today to safeguard the CPNI of AT&T’s interconnected
VoIP customers.19 AT&T’s CPNI processes and procedures are described in AT&T’s annual
CPNI compliance certifications filed with the Commission pursuant to 47 C.F.R. § 64.2009, and
will apply to all CPNI generated in connection with the interconnected VoIP services used in the
trial.20
Wholesale Services
Any robust and meaningful examination of the processes necessary to effect an orderly
transition from legacy TDM-based services to an all-IP ecosystem necessarily must include an
assessment of the impact of that transition on wholesale customers. To that end, AT&T has
endeavored to identify the extent to which wholesale customers are active in the two trial wire
18
47 C.F.R. § 64.2001 et seq.
19
See Implementation of the Telecommunications Act of 1996: Telecommunications Carriers’ Use of
Customer Proprietary Network Information, 22 FCC Rcd. 6927, ¶¶ 54-59 (2007).
20
See, e.g., AT&T Annual CPNI Compliance Certifications Calendar Year 2012, EB Docket No. 06-36,
filed Mar. 1, 2013; AT&T Annual CPNI Compliance Certifications Calendar Year 2011, EB Docket No.
06-36, filed Mar. 1, 2012; AT&T Annual CPNI Compliance Certifications Calendar Year 2010, EB
Docket No. 06-36, filed Mar. 1, 2011.
27
REDACTED -- FOR PUBLIC INSPECTION
centers, as well as the legacy TDM products and services they are obtaining and their IP-based
replacements, and to develop plans for engaging those customers in the trials and encouraging
them to purchase the replacement products and services. As is the case with AT&T’s retail
customers, a complete test of the transition will entail the required participation of all actors in
the test wire centers, including wholesale customers. AT&T nevertheless is prepared to move
forward with trials in the test wire centers subject to the condition established in the Transition
Trials Order limiting the involvement of wholesale customers in the initial phase of the trials to
those that participate voluntarily.21 But, as the Order contemplates,22 AT&T intends to pursue
additional phases of these trials that would include, with the Commission’s authorization through
the Section 214 process, the complete withdrawal of TDM-based wholesale services. To that
end, AT&T has identified in the detailed plan the interstate TDM wholesale services for which
214 applications will be filed, and anticipates submitting an application to grandfather those
services in the trial wire centers.
AT&T values its relations with its wholesale customers, and intends to work aggressively
to retain their business as the entire industry undergoes the transition to an all-IP ecosystem.
AT&T is interested in receiving feedback from its wholesale customers on how the transition can
work best for their needs as well as the needs of their customers. Accordingly, AT&T has
identified the replacement products that already are available as alternatives to current legacy
TDM services – such as the AT&T Switched Ethernet (ASE) service that is available to replace
DSn-level special access services and high capacity loop and transport UNEs – and will provide
customers who choose to do so the opportunity to transition to those alternatives in this initial
21
Transition Trials Order, ¶ 59 and n.91.
22
Id., n.91.
28
REDACTED -- FOR PUBLIC INSPECTION
phase of the trial. Similarly, while AT&T will continue to meet its wholesale obligations under
Section 251(c) of the Act (including by making UNEs available through the current stage of the
trial), AT&T intends eventually not only to withdraw its legacy TDM services but also to retire
the TDM electronics and other facilities used to provide those TDM services (and UNEs). At the
same time, wholesale customers will have the opportunity to obtain bare copper loops and utilize
their own electronics to provide high capacity services to their end user customers — TDM or IP
or any other technology the wholesale customer desires to provision.23 AT&T also is working
diligently to develop IP replacement services that it will make available for [CONFIDENTIAL
– NOT FOR PUBLIC DISCLOSURE]. AT&T’s objective is to complete those development
efforts, as well as those aimed at developing an IP-based alternative to the Local Wholesale
Complete product, as soon as possible, although it is likely the final commercial products will
not be available until the trials already are underway.
23
The Transition Trials Order stated that the Commission did not intend to resolve legal and policy
questions resulting from the transition in the context of any trials. Technology Transitions, et al., GN
Docket No. 13-5, et al., Order, Report and Order and Further Notice of Proposed Rulemaking, FCC 14-5
at ¶ 8 (rel. Jan. 31, 2014) (Transition Trials Order). Consistent with the Commission’s intent, AT&T is
not seeking to resolve any issues through this application, nor in this phase of the proposed trial, on such
issues, including those concerning the extent to which wholesale obligations associated with an ILEC’s
provision of TDM-based services, such as the required unbundling of high capacity loops or the resale of
telecommunications services, apply to IP-based services.
29
REDACTED -- FOR PUBLIC INSPECTION
Conclusion
For the foregoing reasons, the Commission should approve the trials proposed herein.
/s/ Christopher M Heimann
CHRISTOPHER M HEIMANN
GARY L PHILLIPS
LORI A FINK
Attorneys For:
AT&T Services INC.
1120 20th Street, NW
Suite 1000
Washington, D.C. 20036
(202) 457-3058 – phone
February 27, 2014
30
REDACTED -- FOR PUBLIC INSPECTION
Wire Center Trial
Operating Plan
February 27, 2014
REDACTED -- FOR PUBLIC INSPECTION
Section 1:
Introduction and Overview
In this document, AT&T has laid out a detailed plan for conducting TDM to all-IP trials
in two wire centers. The plan identifies the geographic areas in which AT&T will conduct the
trials, the specific TDM-based services that ultimately will be discontinued, the alternative
wireless and wireline IP-based alternatives that AT&T will offer, the dates by which AT&T
intends to seek Commission approval to grandfather and later sunset such services, and other
competitive alternatives available to customers in the test-bed wire centers. It also details
AT&T’s plans for notifying customers about the transition and informing them of the available
service alternatives, and identifies special considerations, such as how AT&T proposes to
address public safety, access by persons with disabilities, and other important issues.
As set forth herein, AT&T initially will seek to encourage to the greatest extent possible a
voluntary migration of its existing customers for wireline TDM services through customer
outreach and education. Subsequently, AT&T plans to seek Commission approval to grandfather
existing customers and offer only next generation wireless and wireline IP-based services for
new orders. Ultimately, AT&T will seek approval to upgrade existing customers to such
alternatives after the Commission has evaluated the results of the first phase of the trials. The
dates on which AT&T plans to seek approval to grandfather existing customers, and later to
sunset existing wireline TDM-based services, will vary depending on the services at issue and
the availability of IP-based alternatives.
In addition to providing detailed information regarding AT&T’s plan for conducting the
proposed trials, this document explains how AT&T will preserve and protect the enduring
principles and values articulated by the Commission in its order authorizing the trials.1 Those
values should continue to apply across all platforms and providers as we complete the transition
to all-IP networks and services.
AT&T is eager to receive input on its proposed trial plan from the Commission and other
interested parties. We look forward to working with all stakeholders to resolve any issues that
may arise.
Section 2:
Statement of Purpose & Scope
The trials proposed herein have several important objectives. First, the trials are designed
to provide a process and forum for identifying and resolving the operational, technical, logistic,
and other issues (both known and unforeseen) that could arise when existing TDM-based
networks and services are discontinued and the customers remaining on those networks have to
transition to next-generation wireless and wireline IP-based alternatives. Identifying and
resolving these issues in the context of a limited trial while the TDM network still is in place is
1
Technology Transitions, et al., GN Docket No. 13-5, et al., Order, Report and Order and Further Notice of
Proposed Rulemaking, FCC 14-5 at ¶ 23 (rel. Jan. 31, 2014) (Technology Transition Trials Order).
REDACTED -- FOR PUBLIC INSPECTION
critical to ensure that the transition is orderly. Second, the trials are intended to help AT&T
(working with policymakers, consumers and other stakeholders) further develop and implement
processes for migrating customers (including residential, small and large business, wholesale,
and governmental customers) off of traditional TDM services and onto all IP platforms in an
efficient manner, with as little disruption as possible. And third, the trials seek to ensure that
customers, manufacturers, policymakers, and other stakeholders have sufficient notice regarding
any issues raised by the impending transition so that they also have the opportunity to prepare for
the time when TDM networks and services no longer are available.
Consistent with these objectives, the trials seek to replicate on a small scale the broader
TDM sunset and migration to all-IP networks and services. Although many of the issues posed
by the transition are common to all customers, each customer segment (residential, small and
large business, government, wholesale) has its own, unique needs and challenges. Consequently,
what works well for one segment may not be the best for another. The trials proposed herein
thus seek a complete migration of all customers (or as many as possible) to IP-based services in
two wire centers. Excluding particular customer segments and/or services (such as dedicated or
wholesale services) from the trial will deprive the Commission, consumers, industry and others
of important real-world experience needed to prepare for the IP transition.
This application proposes to conduct the trials in a rural wire center in Carbon Hill, AL,
and in Kings Point, a suburban wire center in Palm Beach County, FL.2 AT&T chose these wire
centers with an eye towards gaining insights into some of the more difficult issues that likely will
be presented by the TDM sunset. For example, Carbon Hill is a sparsely populated wire center
located in rural Alabama with particularly challenging economic and geographic characteristics.
There are approximately 4,388 living units in the Carbon Hill wire center. Living units include
both business and residential locations (even if not currently occupied), as well as business or
residential locations currently under construction, and are the units AT&T’s network engineers
use when designing and building communications networks because each living unit is a separate
location that AT&T historically has been required to serve upon request. Of those 4,388 living
units to which AT&T currently offers wireline service in Carbon Hill, roughly
[CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE] percent actually subscribe to
AT&T’s retail wireline services (TDM and IP). This fact underscores that numerous customers
already have made the choice to abandon traditional TDM telephone services, and the difficult
economics of the existing wireline regulatory regime. Adding to the uncertainty is the fact that,
while the Carbon Hill wire center may qualify for funding under the Commission’s revised
universal service rules, the amount of that funding has yet to be determined — we thus welcome
the CAF Phase II trial proposed by the Commission to answer some of these questions.
2
The Kings Point serving wire center is located in an unincorporated part of Palm Beach County, west of the City of
Delray Beach, FL. For purposes of this plan, we will refer to that serving wire center as the “Kings Point” wire
center.
2
REDACTED -- FOR PUBLIC INSPECTION
Under AT&T’s current plans, we will offer wireline and/or wireless broadband services
to [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE] percent of the living units in
Carbon Hill. Providing broadband services to the [CONFIDENTIAL – NOT FOR PUBLIC
DISCLOSURE] percent is going to be more difficult given the economics of deploying
broadband services to those areas. AT&T recognizes that it is responsible for ensuring that these
customers will have an alternative available to them prior to discontinuing TDM services, and is,
in all events, committed to working with the Commission, policymakers, and other stakeholders
to ensure that this happens. But, it is critically important that we, as a nation, engage in a dialog
that addresses the geographic and economic challenges of deploying and offering broadband in
sparsely populated areas like Carbon Hill. That is precisely why AT&T selected Carbon Hill as
one of the trial wire centers so that we and other stakeholders can begin that dialog on how best
to resolve this issue while the TDM network remains in place.
Kings Point likewise raises important issues. Although many seniors already have made
the transition from traditional wireline telephone services to wireless and wireline IP-based
services (often without even knowing they have done so), as a group they have been slower to
migrate to these newer technologies. Kings Point has a sizable population of seniors, and thus
will provide AT&T, the Commission and other stakeholders insights into any unique challenges
the IP transition may pose for seniors, and how best to address them.
To evaluate whether AT&T’s plan for transitioning customers (residential, business,
wholesale, and government) from TDM to all-IP networks and services will preserve core
network values, AT&T proposes to collect and report data about the progress of the trial, IP call
quality and network performance, and customer satisfaction with the migration process and the
new wireless/IP products.
Section 3:
3.1
Description of Trial Serving Wire Centers
OVERVIEW
AT&T has selected two diverse serving wire centers for the trials: Carbon Hill, Alabama
and Kings Point, Florida.3 The Carbon Hill wire center has a generally rural customer base with
a population of 6,594 and 4,388 living units.4 Of the 4,388 living units to which AT&T offers
wireline services in Carbon Hill, [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE]
currently subscribe to AT&T’s retail wireline services (TDM and IP).
3
Kings Point, Florida is also sometimes referred to as Delray Beach, Florida.
4
See U.S. Census Bureau, The 2006-2010 ACS 5-Year Summary File Technical Documentation, available at
https://assets.nhgis.org/original-data/acs/2010ACS_5.pdf (2006-2010 ACS Data). Census blocks have been
mapped to the wire center boundaries to obtain relevant data for the wire centers. Living units include business,
residential, vacant and under-construction locations. Living units are the units network engineers use when
designing and building communications networks because each living unit is a separate location that AT&T
historically has been required to serve upon request.
3
REDACTED -- FOR PUBLIC INSPECTION
The Kings Point wire center serves parts of Palm Beach County west of Delray Beach
with a population of 64,218 across 49,712 living units,5 of which [CONFIDENTIAL – NOT
FOR PUBLIC DISCLOSURE] percent currently subscribe to an AT&T retail wireline service.
These two wire centers afford ample opportunity to address industry-wide challenges using a
customer-focused approach. See Exhibit A for maps of the wire centers.
3.2
WIRE CENTER SUMMARY
Serving Wire
Center
Address
CLLI
Switch Type
Overview of Area
(based on public
information)
Carbon Hill, AL
th
Kings Point, FL
308 NW 4 Street,
Carbon Hill, Alabama 35549
6037 W Atlantic Ave,
Delray Beach, Florida 33445
CRHLALNM
DLBHFLKP
DMS-100 Remote
5ESS
Primarily comprised of
Western Walker County but
includes SE corner of
Marion and NE corner of
Fayette Counties
Palm Beach County
City total area is 5.6 sq.
miles
City total area is 15.9 sq.
miles
Rural, former mining town
Coastal city, part of West Palm
Beach metropolitan area
6,594 people in the wire center 64,218 people in the wire center
Living Units
(includes business,
residential, vacant
lots, and locations
under construction)
5
4,388 Living Units
See 2006-2010 ACS Data.
4
49,712 Living Units
REDACTED -- FOR PUBLIC INSPECTION
3.3
GEOGRAPHY
Walker County, Alabama, where most of the Carbon Hill wire center serving area is
located, has an area of approximately 790 square miles in the Northwestern part of the state.6
The average annual rainfall in the city of Carbon Hill is 59.67 inches of rain.7 Palm Beach
County, Florida, where Kings Point is located, has an area of 1,977 square miles on the
Southeastern Coast of Florida, in the West Palm Beach metropolitan area.8 The average annual
rainfall is 62.33 inches in the city of Delray Beach.9 Both areas can experience severe weather
including hurricanes or tornados. See Exhibit B for topographical maps.
3.4
DEMOGRAPHICS
The population density in the Carbon Hill wire center is 38 per square mile. The
population density in the Kings Point wire center is 1,961 per square mile.10
Carbon Hill, AL
Kings Point, FL
Population Density
Population
Area
Sq Miles
6,594
172
Population
per Sq Mile
38
64,218
32.75
1,961
Alabama
4,779,736
52,420
91
Florida
18,801,310
65,758
286
United States
308,745,538 3,796,742
81
Source: U.S. Census Bureau, United States Census 2010, available at
http://www.census.gov/2010census
In the Carbon Hill wire center, 95 percent of the 6,594 residents are white, and four
percent African-American. In the Kings Point wire center, 84 percent of the 64,218 residents are
white, seven percent are African-American, and seven percent Hispanic.11
6
United States Census Bureau, State and County Quick Facts (Walker County, Alabama),
http://quickfacts.census.gov/qfd/states/01/01127.html (visited Feb. 11, 2014).
7
See Weatherdb.com, available at http://average-rainfall.weatherdb.com/d/d/Alabama (visited Feb. 9, 2014).
8
See Palm Beach County Interesting Facts and Figures, available at
http://www.pbcgov.com/publicaffairs/facts.htm#Geography (visited Feb. 9, 2014).
9
See Weatherdb.com, available at http://forecast.weatherdb.com/l/33445/Delray-Beach-FL (visited Feb. 9, 2014).
10
See 2006-2010 ACS Data. To obtain wire center data, AT&T mapped census blocks to wire center boundaries.
11
See 2006-2010 ACS Data.
5
REDACTED -- FOR PUBLIC INSPECTION
White
alone
Total
American
Black or
Indian and
African
Alaska
American
Native
alone
alone
Asian
alone
6,594
6,250
95%
275
4%
2
0%
6
0%
Kings Point, FL 64,218
53,715
84%
4,330
7%
59
0%
1,089
2%
Carbon Hill, AL
Native
Hawaiian
Some
and Other
other race
Pacific
alone
Islander
alone
0
0
0%
0%
0
0%
259
0%
Two or
more
races
Hispanic
or Latino
55
1%
6
0%
455
1%
4,311
7%
Source: U.S. Census Bureau, The 2006-2010 ACS 5-Year Summary File Technical
Documentation, available at https://assets.nhgis.org/original-data/acs/2010ACS_5.pdf.
In the Carbon Hill wire center, approximately 99 percent of the population speaks
English only. In the Kings Point wire center, approximately 81 percent speaks English only and
six percent speak Spanish.12
SpanishͲNo SpanishͲAt
one14and leastone
overspeaks person14and
Englishonly overspeaks Other
orspeaks Englishonlyor IndoͲ
Englishvery speaksEnglish European
English
verywell languages
well
Total only Spanish
CarbonHill,AL 6,594 6,556 27 Ͳ
99.42% 0.41%
KingsPt,FL
OtherIndoͲ
EuropeanͲNo
one14and
overspeaks
Englishonlyor
speaksEnglish
verywell
27 9 Ͳ
0.14%
OtherIndoͲ
EuropeanͲAt
leastoneperson
14andover
speaksEnglish Asianand
onlyorspeaks PacificIsland
Englishverywell languages
Asianand
Asianand
PacificͲNoone PacificͲAtleast
14andover oneperson14
speaksEnglish andoverspeaks
onlyorspeaks Englishonlyor
Englishvery speaksEnglish Other
well
verywell languages
9 2 Ͳ
0.04%
OtherͲNo
one14and
overspeaks
Englishonly
orspeaks
Englishvery
well
2 Ͳ Ͳ
0.00%
OtherͲAt
leastone
person14and
overspeaks
Englishonlyor
speaksEnglish
verywell
Ͳ
64,218 52,186 4,044 1,149 2,895 6,698 2,055 4,643 603 157 445 686 260 426
81.26% 6.30%
10.43%
0.94%
1.07%
Source: U.S. Census Bureau, The 2006-2010 ACS 5-Year Summary File Technical Documentation,
available at https://assets.nhgis.org/original-data/acs/2010ACS_5.pdf.
In the Carbon Hill wire center, the single largest age group is 22 to 49 year olds, with 38
percent of the population 50 years old or older. In the Kings Point wire center, 70 percent of the
population are 50 years of age or older, although the single largest age group (19%) is 22 to 49
year olds.13
12
See 2006-2010 ACS Data. To obtain wire center data, AT&T mapped census blocks to wire center boundaries.
13
See 2006-2010 ACS Data. To obtain wire center data, AT&T mapped census blocks to wire center boundaries.
6
REDACTED -- FOR PUBLIC INSPECTION
AgeNumberofPeople
(MenandWomen)
CarbonHill,AL
Unde r 18
18 to 2 1
2 2 to 4 9
5 0 to 5 4
5 5 to 5 9
6 0 a nd 6 1
6 2 to 6 4
6 5 to 6 9
7 0 to 7 4
7 5 to 7 9
8 0 to 8 4
8 5 a nd ove r
5 0 a nd ove r
1,524
291
2,296
542
293
206
311
301
324
242
23%
4%
35%
8%
4%
3%
5%
5%
5%
4%
167
97
2,483
3%
1%
38%
6,594
KingsPoint,FL
6,277
964
12,066
3,024
4,130
1,776
3,265
5,164
6,297
7,886
7,398
5,970
44,911
10%
2%
19%
5%
6%
3%
5%
8%
10%
12%
12%
9%
70%
64,218
Alabama
1,132,303
284,216
1,766,242
337,627
301,166
113,367
142,513
197,198
156,036
120,449
87,698
73,836
1,529,890
24%
6%
37%
7%
6%
2%
3%
4%
3%
3%
2%
2%
32%
4,712,651
Florida
4,013,090
1,017,224
6,837,598
1,283,619
1,162,393
447,540
616,051
897,204
735,810
615,886
472,654
412,551
6,643,708
22%
5%
37%
7%
6%
2%
3%
5%
4%
3%
3%
2%
36%
18,511,620
UnitedStates
74,033,117 17,940,909 117,432,247 21,532,191 18,817,728 6,776,873 8,682,794 11,518,053 8,975,414 7,358,170 5,721,633
24%
6%
39%
7%
6%
2%
3%
4%
3%
2%
2%
5,176,143
94,558,999
2%
31%
303,965,272
Source: U.S. Census Bureau, The 2006-2010 ACS 5-Year Summary File Technical Documentation,
available at https://assets.nhgis.org/original-data/acs/2010ACS_5.pdf
In the Carbon Hill wire center, 21 percent of households have income below the poverty
line, compared to 9 percent in the Kings Point wire center.14
Percent of HHs with Income
Below Poverty Level
HHs (%)
HHs
Carbon Hill, AL
21%
579
Kings Point, FL
9%
2,955
Alabama
17%
308,181
Florida
13%
923,394
United States
13%
14,865,322
Source: U.S. Census Bureau, The 2006-2010
ACS 5-Year Summary File Technical
Documentation, available at
https://assets.nhgis.org/originaldata/acs/2010ACS_5.pdf.
14
See 2006-2010 ACS Data. Through the American Community Survey, the US Census Bureau estimates the
number of households in poverty by Census Block Group (CBG). The standard for poverty varies as a function of
household size. To obtain wire center data, AT&T mapped the Census Blocks to the wire center boundaries, based
on the assumption that the Census Blocks that make up the wire center have the same poverty characteristics as the
Census Block Group.
7
REDACTED -- FOR PUBLIC INSPECTION
3.5
WIRE CENTER PROFILES
During the course of the trials, AT&T plans to use a combination of IP-based wireline
and wireless service solutions as replacements for legacy TDM-based services in the Carbon Hill
and Kings Point wire centers.15 The wireline service solutions will be provided by AT&T
Southeast and the wireless service solutions will be provided by AT&T Mobility. As part of
planning for the trials, AT&T has performed a careful analysis of the availability of wireline and
wireless IP-based alternatives to living units in these wire centers. The results of that analysis
are set forth in the table below.16
3.5.1. Carbon Hill. As of December 2013, AT&T provides wireline retail
services to [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE]17 in the Carbon Hill
wire center out of a total of 4,388 living units in the wire center to which it offers wireline
services. [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE] percent of the Carbon
Hill living units will have a wireline IP-based alternative to TDM-based services available from
AT&T by the end of 2015. [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE]
percent will have at least one IP-based alternative available—wireline, wireless or both. AT&T
has not yet found a viable replacement service for the [CONFIDENTIAL – NOT FOR
PUBLIC DISCLOSURE] percent of living units, and still is considering its options for those
living units. AT&T recognizes that it is responsible for ensuring that these customers will have
an alternative available to them prior to discontinuing TDM services, and is, in all events,
committed to working with the Commission, policymakers, and other stakeholders to ensure that
this happens.
15
See Section 4.
16
In the table, living units are listed as “green” for a particular service if that service will be available to those
locations from AT&T by the end of 2015 and as “red” if the service will be unavailable. Living units included in the
“IP Wireline Green” category will have available a wireline IP alternative to TDM-based services. Approximately
[CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE] percent of the Carbon Hill living units and all of the
Kings Point living units in the Wireline IP Green category will also have a wireless IP broadband service alternative.
Living units in the “Wireline IP Red/Wireless IP Green” will have a wireless IP broadband alternative, but not a
wireline IP broadband alternative. The living units in the “IP Wireline Red and IP Wireless Red” category will not
have an IP-based alternative available from AT&T. AT&T continues to consider options for these living units.
17
Business customers include small business, enterprise, affiliates and unidentified business customers. This
analysis does not include wholesale customers. See Section 6.3.
8
REDACTED -- FOR PUBLIC INSPECTION
3.5.2. Kings Point. As of December 2013, AT&T provides wireline retail
services to [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE] in the Kings Point wire
center out of a total of 49,712 living units in the wire center. [CONFIDENTIAL – NOT FOR
PUBLIC DISCLOSURE] percent of these living units will have a wireline IP-based alternative
to TDM-based services available from AT&T by the end of 2015. [CONFIDENTIAL – NOT
FOR PUBLIC DISCLOSURE] percent will have at least one IP-based alternative available—
wireline, wireless or both.
3.6.
SCHOOLS AND LIBRARIES.18
Among AT&T’s customers is the Walker County, Alabama School System, which has
one public school location in the Carbon Hill wire center. [CONFIDENTIAL – NOT FOR
PUBLIC DISCLOSURE]. In the Kings Point wire center, there is one public school and one
private school. [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE].
In addition, AT&T has identified one library in Carbon Hill—the Carbon Hill City
Library—and two libraries in Kings Point—the Hagen Ranch Road Branch of the Palm Beach
County Library System and the Donald B. Gordon Memorial Library of the Morikami Museum
and Japanese Gardens. All three libraries are [CONFIDENTIAL – NOT FOR PUBLIC
DISCLOSURE].
3.7.
COMPETITORS.
Among others, AT&T has identified cable, wireless and satellite providers that compete
aggressively and head-to-head with AT&T for both business and residential, voice and
broadband customers in the Carbon Hill and Kings Point wire centers. In Carbon Hill, Charter
Communications, Verizon LTE, Sprint 3G, T-Mobile 3G, HughesNet, Dish Network, and
DirecTV provide alternatives to consumers and businesses for voice and broadband services.
Among others, in Kings Point, Comcast Communications, Verizon LTE, Sprint 3G, T-Mobile
3G, HughesNet, Dish Network, and DirecTV provide alternatives to consumers and businesses
for voice and broadband services. The maps in Exhibit C show the coverage of these
competitors in each wire center.
3.8.
STATE, TRIBAL, AND OTHER GOVERNMENT ENTITIES.
AT&T does not expect to need any authorization from other federal, State, Tribal or other
governmental entities to conduct the trials in Kings Point, Florida or Carbon Hill, Alabama.19
There are no Tribal governments in the trial areas. Although no authorizations will be required,
18
Any transition of schools and libraries to IP-based services will be done a manner fully compliant with the E-Rate
program and obligations.
19
To the extent that AT&T seeks to withdraw intrastate switched and/or special access services in Carbon Hill, it
will have to obtain approval from the Alabama PSC. AT&T will comply with all requirements to do so. To the
extent necessary AT&T will request ETC relief in both wire centers. See section 6.2.2.
9
REDACTED -- FOR PUBLIC INSPECTION
AT&T has a comprehensive plan to inform, educate and coordinate with government entities in
the trial areas.20 AT&T requests no preemption by the FCC of any state or local law to conduct
the trials at this time. In the course of the trials, AT&T will comply with all applicable State
laws and regulations.21
20
See section 5.
21
AT&T’s VoIP and wireless services meet or exceed all current federal, state, and local requirements for 911
emergency services. See also section 6.1.
10
REDACTED -- FOR PUBLIC INSPECTION
State & Local Government Contacts
Carbon Hill Wire Center
Dr. Robert Bentley
Ki ngs Poi nt Wire Center
Office of Governor Rick Scott
Governor – State of Alabama
State of Florida
600 Dexter Avenue
The Capitol
N-104
400 S. Monroe St.
Montgomery, Alabama 36130
Tallahassee, FL 32399-0001
State
Department of Agriculture and
Consumer Affairs
Adam Putnam, Commissioner
The Capitol
400 S. Monroe St.
Tallahassee, FL 32399-0800
Alabama Public Service
Commission
Public Utility
Commission
Florida Public Service
Commission
Hon. Walter Thomas, Secretary Office of Commission Clerk
Carlotta S. Stauffer, Commission
Suite 850
Clerk
100 North Union Street
2540 Shumard Oak Blvd.
Montgomery, AL 36104
Tallahassee, FL 32399-0850
Fayette County Commission
Palm Beach County
103 1st Avenue NW, Suite 2
301 N. Olive Avenue
Fayette, AL 35555
West Palm Beach, FL 33401
Marion County Commission
County
P. O. Box 460
Hamilton, AL 35570
Walker County Commission
P. O. Box 1447
Jasper, AL 35502-1447
Town of Carbon Hill
City of Delray Beach
P. O. Box 519
City Hall
Carbon Hill, AL 35549
100 NW 1st Avenue
Delray Beach, Florida 33444
Town of Eldridge
City
P. O. Box 99
Eldridge, AL 35554
Town of Kansas
P. O. Box 186
Kansas, AL 35573
Fayette County E-911
Palm Beach County, FL
Attn: Treasa Blake, Director
Mr. Charles Spalding
118 1st Ave NE
[email protected]
Fayette, AL 35555
Department of Public Safety
Phone: 205 932-1911
20 S Military Trail
West Palm Beach, FL 33415
Phone: 561 712-6339
Marion County E 911
911 Authorities
PO Box 1744 Linda Winters,
Director
Hamilton, AL 35570
Phone: 205.921-0911
Walker County E9-1-1 District
302 15th St NE Attn: Roger D.
Wilson, Director
Jasper, AL 35504
Phone: 205-221-7911
11
REDACTED -- FOR PUBLIC INSPECTION
Section 4:
Technical Parameters and Timeline
AT&T’s proposed trials contemplate replacing the vast majority of the TDM-based
services in the trial wire centers over the next three years. AT&T identifies below each TDMbased service it currently offers in the trial wire centers and the wireless and wireline IP-based
alternatives that AT&T will offer in the trial wire centers, along with a timeline setting forth the
dates on which AT&T proposes to implement each stage of the trials to the extent it receives the
necessary approvals to do so.22 Many of the TDM-based services listed herein are intrastate
services. Nonetheless, AT&T has included all of the TDM services that AT&T proposes to
include in the trials regardless of their regulatory jurisdiction to ensure the Commission and other
interested parties have a comprehensive view of the implications of the IP transition.23
4.1.
CONSUMER SERVICES
AT&T proposes to include in the trial all of its consumer TDM-based voice and internet
access transport services, and to offer the following services in place of those TDM services:
AT&T’s U-verse Voice service, AT&T’s U-verse High Speed Internet services, and AT&T’s
Wireless Home Phone service and Wireless Home Phone and Internet service.
Customers within AT&T’s wireline IP network footprint have access to AT&T’s Uverse® Voice and High Speed Internet services, which provide next-generation voice calling
features and high-speed broadband Internet access. More than half of AT&T’s U-verse
broadband base has downstream speeds of 12MB or higher and we can deliver speeds of up to
45MB to approximately two-thirds of our U-verse video customers. Consumers in AT&T’s
wireless footprint also will be able to purchase one of AT&T’s CMRS services (including
AT&T’s Wireless Home Phone and Wireless Home Phone and Internet services) in place of
traditional, TDM-based voice telephone services. AT&T’s Wireless Home Phone and Wireless
Home Phone and Internet services include nationwide calling with enhanced calling features.
The wireless Internet component of Wireless Home Phone and Internet provides broadband
Internet speeds capable of downstream speeds between 5-12 Mbps. AT&T’s LTE network is
consistently recognized as the fastest, most reliable LTE network in the nation.
AT&T has included in Exhibit E, Product Data sheets for each consumer service that
AT&T proposes to grandfather, and ultimately sunset, in the trial wire centers. The Product Data
22
Exhibit D.
23
When AT&T is ready to grandfather its TDM-based services, AT&T will file Section 214 Discontinuance
Applications for the TDM-based services that it provides subject to the FCC’s interstate jurisdiction. AT&T will
follow applicable intrastate regulatory requirements to grandfather and/or discontinue the intrastate TDM-based
services identified in this plan.
12
REDACTED -- FOR PUBLIC INSPECTION
sheets provide the following information concerning each service: current customer counts for
the service, proposed grandfather and sunset dates, proposed customer notification dates,
AT&T’s replacement products, and the competitive presence in the trial wire centers.
4.2.
BUSINESS SERVICES
AT&T also proposes to transition its current retail business customers in the trial wire
centers from TDM-based voice and data services to wireless and wireline IP-based services over
the next three years. AT&T will offer business customers within its wireline IP network
footprint a variety of IP-based business-class voice services that include next generation calling
features, such as U-verse® Business Voice, AT&T Voice DNA® and IP Flexible Reach, in place
of legacy TDM services, such as BellSouth Centrex and Business Access line services. AT&T
also offers IP-based Internet access and data services in the Trial Wire Centers, including Uverse® High Speed Internet-Business Edition, and a variety of business-class Ethernet services
that deliver extremely reliable service at ultra-fast speeds. In addition, AT&T is in the process
of developing a wireless business phone product, which (like Wireless Home Phone) will enable
business customers to use their existing CPE to communicate over AT&T’s wireless network.
AT&T’s Wireless Business Phone service include nationwide calling with enhanced calling
features designed for business and wireless Internet access using AT&T’s 4G network.
AT&T has included in Exhibit E, Product Data sheets for each business service that
AT&T proposes to grandfather, and ultimately sunset, in the trial wire centers. The Product Data
sheets provide the following information concerning each service: current customer counts for
the service, proposed grandfather and sunset dates, proposed customer notification dates,
AT&T’s replacement products, and the competitive presence in the trial wire centers.
4.3.
DEVICE AND SERVICE APPLICATION COMPATIBILITY
As illustrated in the chart below, the wireless and wireline IP-based services that AT&T
will offer in place of traditional TDM-based services will support the vast majority of the devices
and applications enumerated in Appendix B of the Transitions Trial Order. However, AT&T
does not currently plan to support certain applications with rapidly declining market demand or
applications that are based on outdated technology such as DVR services, elevator phones, third
party pay per call, dial around calls, and operator services functions (live operators and collect
calling). The chart identifies whether particular applications or devices currently supported over
TDM also are (or will be) supported over AT&T’s wireless and wireline IP-based replacement
services (we also identify the date by which AT&T expects to support applications and devices
still under development).
13
REDACTED -- FOR PUBLIC INSPECTION
Application/Devices
Wireless Home/Business
Phone
TDM
Voice
U-verse
Voice
E-911 with Address
Y
Y
Ya
Yb
Alarm Monitoring
Y
Y
Yc
Yd
Medical Alert
Y
Y
Ye
Yf
411
Y
Y
Y
Y
DVR Services24
Y
Y
N
N
Credit Card/Merchant Services
Y
Y
Yg
Yh
800 # Service
Y
N
Yi
Yj
3rd Party Pay per Call (500, 976,
etc.)
Y
N
N
N
Calling Card calls using IVR (8xx
platforms)
Y
Y
Y
Y
Dial-around calls
Y
N
N
N
Abbreviated Dialing Codes (N11)26
Y
Y
Y
Y
Live Operator via “0”
Y
N
N
N
Collect Calls
Y
Nk
Nl
Nm
Correctional Facility
Ankle Bracelets
TTY-Assistive Technology
Y
Y
N
N
Y
Y
Yn
Yo
Elevator Phone Service27
Y
N
N
N
25
Wireless Home/Business
Phone with Internet
24
DVR compatibility should be a relatively minor concern as the DVRs provided by video content providers no
longer require the use of TDM-voice service or a separate internet connection to operate. DVRs that are purchased
without a video service may be unable to utilize the full functionality of the DVR without a TDM-voice connection;
however, AT&T believes this to be a very small and rapidly declining user group.
25
800 number service permits 800 calls that originate from diverse geographic locations within the U.S. to terminate
onto the subscribing customer's local exchange service lines.
26
AT&T’s services support the abbreviated dialing codes that are have been activated in the specific geographic
area. For example, in Carbon Hill, the 311 and 511 codes are not active or operational on AT&T’s services.
27
Based on AT&T’s initial research, there are no elevator phones in the trial wire centers.
14
REDACTED -- FOR PUBLIC INSPECTION
Notes a-h:
Currently, Wireless Home Phone and Wireless Home Phone and Internet, which
are CMRS, comply with the Commission’s existing 911 requirements for CMRS, and do not
provide E-911 with street address. Nor does Wireless Home Phone and Wireless Home Phone
and Internet currently support alarm monitoring, medical alert and credit card validation
applications. However, AT&T currently is developing enhancements that will provide all of
these applications (i.e., E-911 with street address, as well as alarm monitoring, medical alert and
credit card applications), which we plan to introduce in the [CONFIDENTIAL – NOT FOR
PUBLIC DISCLOSURE]. AT&T knows that these applications are vitally important to its
customers and is committed to supporting these applications before AT&T takes any action to
grandfather or discontinue its TDM-based voice services. The E-911 enhancement for Wireless
Home Phone and Wireless Home Phone and Internet will deliver an address when the device is
stationary. When the device is in motion, it will deliver a location generated by GPS like any
other CMRS device and service.
Notes i-j:
800 number service is not supported by Wireless Home Phone/Wireless Home
Phone and Internet for consumer customers but will be included in AT&T’s wireless business
voice services.
Notes k-m: U-verse Voice, Wireless Home Phone and Wireless Home Phone and Internet do
not support collect calling, but some 3rd party systems have applications that facilitate collect
calls from correctional institutions. These 3rd party applications will function with AT&T’s
services.
Notes n-o: TTY compatibility and accessibility for Wireless Home Phone and Wireless Home
Phone and Internet services is being carefully assessed. AT&T is committed to supporting this
functionality and will not take any action to grandfather or discontinue service to a customer
with assistive technology that is known to be incompatible with AT&T’s replacement services.
4.4.
SWITCHED ACCESS SERVICES
AT&T plans to discontinue its ILEC-provided TDM-based interstate and intrastate
switched access services in the trial wire centers as well. These services are used to originate
and terminate interexchange calls. As discussed above, AT&T intends to offer wireless and
wireline IP-based services in place of traditional TDM voice services in the trial wire centers.
Both are all-distance services with unlimited domestic local and long distance calling. As a
consequence, customers that transition to those services will have no need to purchase a standalone interexchange service that would require originating access, and thus neither offers equal
access functionalities. Currently, AT&T’s affiliate, AT&T Corp., provides TDM
interconnection for the exchange of traffic to or from AT&T’s VoIP customers primarily through
indirect interconnection arrangements. For customers that transition to AT&T VoIP services,
AT&T will exchange traffic to or from end users on another provider’s network through that
provider’s existing interconnection arrangement with AT&T’s access tandem, which then routes
15
REDACTED -- FOR PUBLIC INSPECTION
traffic to and from AT&T Corp. — just as AT&T does today for its existing VoIP customers.
Likewise, for customers that transition to an AT&T wireless service, AT&T will exchange traffic
to or from end users on another provider’s network through that provider’s existing
interconnection arrangement with AT&T’s access tandem, which then routes traffic to and from
AT&T Mobility. To the extent a provider has direct interconnection arrangements with AT&T
Corp. or AT&T Mobility, the traffic will be exchanged with AT&T over the existing
interconnection arrangements designated for each type of traffic. The dates on which AT&T will
grandfather and sunset its ILEC-provided interstate and intrastate switched access services
depend on when AT&T grandfathers and sunsets the underlying consumer and business voice
services. Accordingly, AT&T will not take any steps to grandfather or sunset switched access
services until the replacement voice services are available as discussed above.
AT&T has included in Exhibit E, Product Data sheets for each interstate and intrastate
switched access service that AT&T proposes to grandfather, and ultimately sunset, in the trial
wire centers. The Product Data sheets provide the following information concerning each
service: current customer counts for the service, proposed grandfather and sunset dates, and
proposed customer notification dates.
4.5.
PRIVATE LINE AND SPECIAL ACCESS SERVICES
AT&T also intends to grandfather, and ultimately withdraw, intrastate private line and
interstate and intrastate TDM-based special access services in the trial wire centers. AT&T
currently provides the following categories of TDM-based special access and private line
services in the trial wire centers: DS-0, DS-1, DS-3 and OC-N speeds, shared SONET service
and Dedicated Ring service. AT&T Switched Ethernet (ASE) service and several new services
that are in development, will replace those TDM-based private line and special access services in
the trial wire centers.
AT&T has included in Exhibit E, Product Data sheets for each special access service that
AT&T proposes to grandfather, and ultimately sunset, in the trial wire centers.28
Section 5:
Customer Notice and Outreach
AT&T shares the Commission’s view that “we can only achieve our goal of advancing
technology transitions if customers are fully educated and informed.”29 Thus, customer outreach
and education are critical elements of our plan for the trials, and will be essential to their success.
Consequently, we have developed detailed and extensive plans both to notify specific customers
28
AT&T understands that special access services may have an end-point that is located outside of the trial wire
center. AT&T will manage the transition of these services on a case by case basis with the applicable customers in
the trial wire centers.
29
Technology Transition Trials Orders at ¶ 69.
16
REDACTED -- FOR PUBLIC INSPECTION
about the transition and its impact on them, and to educate the customers, community leaders and
other stakeholders about the transition and trial in the trial wire centers and more broadly. In the
latter effort, we will tailor our outreach efforts to ensure that certain populations with unique
needs (including seniors and persons with disabilities) have the information they need regarding
the trials and transition, and what they mean for those particular groups.
5.1.
CUSTOMER OUTREACH.
AT&T has developed detailed customer outreach campaigns in Carbon Hill and Kings
Point, which will include, inter alia, briefing state and local leaders, briefing the press, posts to
Twitter, direct mailings to customers, community meetings, and launching microsites on the web
where customers can obtain information about the trials. Our specific plans for each wire center
are set forth below. In addition to the plans outlined here, AT&T has developed targeted
outreach efforts to inform disabled persons, seniors, and others with unique needs regarding the
trials, which are described in section 6.2.1. below.
5.1.1. Carbon Hill.
AT&T will take the following steps to inform customers, community leaders and others
in Carbon Hill of the trial:
•
AT&T will send direct mail to all consumer and small business customers in the
Carbon Hill wire center that currently purchase wireline TDM-based services notifying
them that: (1) AT&T has selected their community as the location for a trial; (2) the trial
will be overseen by the FCC; (3) AT&T will host meetings and town halls to provide
more information about the trial, and (4) providing a 1-800 telephone number and
website where they can obtain more information. These letters will be mailed so that
they arrive on or shortly after February 27.30
•
AT&T will post a blog, post a Twitter communication, issue a press release, and
host a press conference for national media on the day after AT&T files this plan with the
Commission.
•
AT&T’s state external affairs team will begin briefing state and local leaders
during the week we file the plan.
•
AT&T will distribute internal and external e-newsletters to its employees and
customers in Carbon Hill.
•
30
AT&T will activate a microsite to provide information regarding the trial.
See Exhibit F.
17
REDACTED -- FOR PUBLIC INSPECTION
In the weeks following the filing of this detailed plan, AT&T will engage in the following
additional outreach measures:
•
AT&T will hold community events at different locations around Carbon Hill to
provide customers information about the trial and transition. AT&T will send direct mail
to its customers and run informational advertisements in local media to notify interested
parties of these meetings. The following are the initial dates and locations of such events:
•
Thursday, March 6 – Carbon Hill Community Center
•
Saturday, March 8 – American Legion, Post 101
•
Tuesday, March 11 – Carbon Hill Community Center
•
Thursday, March 13 – Carbon Hill Community Center
•
AT&T tentatively plans to hold the following additional meetings to inform
interested parties of the trial and its implications:
•
April: Meeting with first responders (fire, police, EMS)
•
May: Open meeting for customers with questions or concerns.
•
June: Meeting with local religious leaders. Possible additional meetings in
each of their churches.
•
July: Meeting with focus on seniors and senior tech training.
•
August: Meeting with local educators (teachers, principals, librarians)
•
September: Meeting with economic developers (local business
owners/managers)
•
October: Meeting focused on introducing new technologies
•
November: Open meeting for customers with questions or concerns.
•
December: Meeting with health care providers
5.1.2. Kings Point.
AT&T will take the following steps to inform customers, community leaders and others
in Kings Point of the trial:
•
AT&T will send direct mail to all consumer and small business customers in the
Kings Point wire center that currently purchase wireline TDM-based services notifying
18
REDACTED -- FOR PUBLIC INSPECTION
them that: (1) AT&T has selected their community as the location for a trial; (2) the trial
will be overseen by the FCC; (3) AT&T will host meetings and town halls to provide
more information about the trial, and (4) providing a telephone number and website
where they can obtain more information. These letters will be mailed so that they arrive
on or shortly after February 27.31
•
AT&T will post a blog, issue a press release to the South Florida Business Journal
and the AT&T State President for Florida will provide an interview to the Fort
Lauderdale Sun Sentinel on the day after AT&T files this plan with the Commission.
•
During the week of the filing, AT&T will hold press briefings with local media,
including the daily for the West Delray Beach area and the Ft. Lauderdale Sun Sentinel.
We also will provide press releases to the South Florida Business Journal and the Palm
Beach Post. AT&T also will post a communication on Twitter, and post a blog regarding
the trial.
•
AT&T’s state external affairs team will begin briefing state and local leaders
immediately after the filing.
•
AT&T will distribute internal and external e-newsletters to its employees and
customers in Kings Point.
•
AT&T will activate a microsite to provide information regarding the trial.
In the weeks following the filing of this detailed plan, AT&T will engage in the following
additional outreach measures:
•
AT&T will hold community events at different locations around Kings Point to
provide customers information about the trial and transition. AT&T will send direct mail
to its customers and run informational advertisements in local media to notify interested
parties of these meetings. These events will include meetings with local senior groups,
local churches and synagogues, the local chamber of commerce and economic
development agencies, first responders, educators and healthcare providers. These
include:
•
Two to four Listening Tour Meetings with Key Stakeholders and AT&T’s
state president for Florida within the first 30 days after filing this plan.
•
Two to four Town Hall events within the first 45 days, depending on
community participation and interest.
31
See Exhibit F.
19
REDACTED -- FOR PUBLIC INSPECTION
•
AT&T will hold several technology training events within the first 90 days to
demonstrate how to use the IP-based replacement products AT&T will offer in Kings
Point.
5.2.
CUSTOMER NOTICE.
In addition to the customer outreach and education efforts described above, AT&T will
send its residential customers multiple notices regarding AT&T’s plans to grandfather and
ultimately sunset existing TDM-based services. These notices will identify the specific TDMbased services that AT&T plans to grandfather (and later sunset), the date on which AT&T
proposes to grandfather or sunset such services, the IP-based alternative service(s) available from
AT&T, a description of any difference in features or functions between such TDM-based
services and their IP-based replacements, information regarding the pricing of the IP-based
alternative services, information about how to contact AT&T for more information or to provide
AT&T feedback, a statement that the trials are being conducted under Commission oversight,
and information about how to contact the Commission with any concerns. AT&T will provide
these notices through direct mail, email, door hangers, and bill messages throughout the trial. In
addition, when AT&T seeks approval to grandfather interstate TDM-based services, its customer
notices for these services will include the information required by section 63.71 of the
Commission’s rules.
AT&T will notify business customers (both wholesale and retail) regarding the trials
through its business customer account teams and sales agents, using the customers’ preferred
method of contact, which might include email, telephone calls, personal visits, or some
combination thereof. AT&T will inform such customers regarding its plans to grandfather
and/or sunset existing TDM-based services and the IP-based wireline and wireless alternatives
(including those alternatives’ features, capabilities and options) available to them, and assist
them in developing a migration plan. AT&T will mail such customers section 214 customer
notification letters before it proposes to grandfather any business services, and before it proposes
to sunset any such services. In addition, AT&T customer account and sales teams will contact
each business customer semiannually to provide them information regarding the trials and to
consult with them regarding their migration plans.
Section 6: Protecting Enduring Values
6.1.
PUBLIC SAFETY & NATIONAL SECURITY
AT&T shares the Commission’s commitment to protecting public safety and national
security. AT&T is dedicated to making sure that, during the trials proposed herein, as well as
during the ultimate transition from TDM-based networks to all-IP networks and services, the
existing level of public safety and national security services is maintained.
20
REDACTED -- FOR PUBLIC INSPECTION
6.1.1. Preserving 911/E911 and Next Generation 911 Capabilities
As a condition to approving any Trial Proposal, the Commission has made it clear that
services provided by trial participants must “in no way diminish consumer access to 911/E911
emergency services” and that Public Safety Answering Points (PSAPs) must “continue to receive
all consumer, phone identifying, and automatically-provided street address location information
associated with a 911/E911 call, consistent with existing Commission rules and regulation.”32
Moreover, the Commission has informed potential participants that PSAPs must be “provided
with at least the same level of network access, resiliency, redundancy, and security that they
enjoy under agreements and tariffs currently framing the legacy emergency network.”33 As
explained below, AT&T’s Trial Proposal will meet these conditions.
Today, AT&T uses its IP network to offer interconnected Voice over IP services (AT&T
VoIP services) in its ILEC regions.34 AT&T also already is providing CMRS service (including
its Wireless Home Phone service) in its service territory and across the country. During the trial,
AT&T intends to offer its existing VoIP and CMRS services as replacements for TDM-based
voice services in the trial wire centers (in some areas, AT&T will offer only a wireless
replacement service).35 Hence, AT&T is not proposing to offer experimental services as legacy
replacements, rather AT&T is proposing to expand the reach of its existing IP services, which
include the ability to provide appropriate E911 access, and an appropriate wireless service,
where available.
a.
VoIP Services
AT&T’s U-verse Voice residential services currently are geographically fixed to the
consumer’s service address. Likewise, business customers can buy fixed VoIP services, but
customers may augment these services to include a nomadic feature.36 This fixed aspect allows
AT&T VoIP service to emulate the E911 experience enjoyed by users of traditional telephone
service.37 When an AT&T VoIP customer dials 9-1-1, his or her call is routed to the service’s
network gateway where the call is converted from IP to TDM and delivered to the legacy
telephone network. Once on the Public Switched Telephone Network (PSTN), the 9-1-1 call hits
32
Technology Transition Trials Order, ¶ 39.
33
Id., ¶ 39.
34
Some of these VoIP services are sold as a bundled offering of U-verse High-Speed Internet access (HSIA), Uverse TV (IPTV), and U-verse Voice (VoIP) or, alternatively, just HSIA and VoIP. AT&T relies on different
network architectures, such as its VDSL and its IP-DSLAM architectures, to provide these services. Residential or
consumer service is referred to as “CVoIP,” while the business service is referred to as “BVoIP.”
35
See discussion below on AT&T’s wireless service.
36
AT&T offers non-fixed or nomadic VoIP applications that expand the reach of some business VoIP services. For
those services, AT&T adheres to the Commission’s 911/E911 regulations and directives. By way of example, for
nomadic interconnected VoIP services, the PSAP is provided with the caller’s Registered Location, which is initially
obtained by the service provider and later, if the subscriber changes his or her physical location, must be updated by
the subscriber. See 47 C.F.R. § 9.3.
37
AT&T VoIP is presently only offered in or provisioned in areas in which the PSAP is Phase I or Phase II capable.
21
REDACTED -- FOR PUBLIC INSPECTION
the selective router switch, which queries the Selective Router Database (SRDB) and the Master
Street Address Guide (MSAG) using the caller’s originating telephone number to match the call
to the appropriate PSAP’s Emergency Service Number (ESN). The 9-1-1 call is then routed to
the PSAP using the ESN. As is the case with traditional TDM-based calls, AT&T VoIP services
provide the PSAP with both the user’s call-back number (automatic number identification or
ANI) and the automatic location information (ALI) consistent with existing Commission rules
and regulation. For AT&T VoIP services, ALI information also is verified with the MSAG
database. Consequently, AT&T VoIP services already provide a reliable and accurate E911
service on par with TDM-based 9-1-1 calls.38
Some PSAPs are starting the transition to Next Generation 911 service (NG911), which
will provide PSAPs with enhanced features, like use of real time text, still images, and video.
Due to state and municipal government budget constraints and other issues, the rollout of NG911
will take time, however. We anticipate that, before the sunset of the PSTN, it will be common
for 911 Service Providers39 to support both traditional E911 and NG911 services. For the Trial
Wire Centers, however, no PSAPs have migrated off the legacy system and onto a NG911
system, and AT&T’s Trial Proposal does not include any plans to migrate those PSAPs off of the
legacy system as part of the trial. Consequently, for the foreseeable future, AT&T VoIP
services will continue to provide routing for 9-1-1 calls to these legacy PSAPs in the manner
described above and consistent with existing Commission rules.
For the Trial Wire Centers, AT&T acts as the 911 Service Provider for the area PSAPs.
Because these PSAPs have not yet transitioned to NG911, AT&T does not foresee any reason
that it would not be able to meet its obligations as a “Covered 911 Service Provider” under the
Commission’s recently released 911 Network Reliability R&O.40 Nonetheless, were these
PSAPs to green light a plan to migrate to NG911 after the Commission approves AT&T’s Trial
Proposal, AT&T would be willing to provide the Commission with supplemental information
that would reassure the Commission of AT&T’s intention to abide by the requirements of the
911 Network Reliability R&O, including bringing the Commission up to date on any “alternative
measures” such a change might require.41
38
See e.g., IP-Enabled Services; E911 Requirements for IP-Enabled Service Providers, First Report and Order and
Notice of Proposed Rulemaking, WC Docket Nos. 04-36 and 05-196, 20 FCC Rcd 10245, n.80 (20005) (VoIP 911
Order) (“In general, providers of solely ‘fixed’ VoIP services (i.e., those that are not portable) face fewer technical
obstacles to providing their customers with E911 service. [References omitted.] It appears that most fixed VoIP
service providers already have deployed, or are in the process of deploying, E911 services very much like those
provided to wireline telephone customers.”).
39
Also known as System Service Providers.
40
See Improving 911 Reliability; Reliability and Continuity of Communications Networks, Including Broadband
Technologies, PS Docket Nos. 13-75, 11-60, Report and Order, FCC 13-158 (rel. Dec. 12, 2013) (911 Network
Reliability R&O)
41
See Technology Transitions Trial Order, ¶ 14.
22
REDACTED -- FOR PUBLIC INSPECTION
b.
Wireless Service
AT&T Mobility’s Wireless Home Phone service is a Commercial Mobile Radio Service
(CMRS). Wireless Home Phone uses a mobile base station device to facilitate the use of
AT&T’s CMRS voice service in the home by allowing a subscriber to connect traditional
customer premises equipment (i.e., touch-tone, corded or cordless home telephones) to the
Wireless Home Phone base station and thereby allow connectivity to AT&T’s licensed
spectrum—just like any of AT&T’s other CMRS voice network-compatible devices.42
Because it is a CMRS service, Wireless Home Phone is mobile and can be used at
different locations and, like AT&T’s other CMRS service offerings, presently complies with the
Commission’s existing CMRS 911 service regulations (47 C.F.R. Part 20). This means that,
depending on the subscriber’s location, Wireless Home Phone will provide access to Basic 911
Service (Basic), Phase I Enhanced 911 Service (Phase I), or Phase II Enhanced 911 Service
(Phase II). As the Commission knows, Phase II service includes providing the PSAP both the
telephone number of the originator of the 911 call and the caller’s longitude and latitude in
conformance with the Commission’s Phase II accuracy requirements.43
Wireless Home Phone is a reliable CMRS product. It provides at least the same level of
service and access to 911 as other CMRS services. Across the country, consumers have opted to
replace wireline POTS service with interconnected VoIP (e.g., AT&T’s U-verse fixed voice
offering or Vonage’s nomadic VoIP service) or with wireless service (e.g., by using a traditional
handset or smartphone or by using a base-station device, like AT&T’s Wireless Home Phone)
regardless of the differences between the 911 access provided by POTS and these alternative
services. For consumers opting to choose wireless service as an alternative to wireline POTS,
Wireless Home Phone provides a convenient, economical, reliable, and practical choice. AT&T
recognizes, however, that regulators and the public safety community have raised concerns
regarding situations in which consumers are required to accept a different standard of 911
access. AT&T seeks to address these concerns ahead of proposing a wireless service as a
substitute for wireline POTS.
AT&T is already working on upgrading the 911 capability of its Wireless Home Phone
offering to address the concerns expressed by the public safety community, such as adding an
ALI function to emulate the customer’s experience with wireline TDM service.44 Naturally, this
effort to enhance the Wireless Home Phone offering is complicated by the mobile aspect of the
service. To emulate the wireline 911 experience in a mobile offering, we are developing
42
The Wireless Home Phone base station doesn’t have a key pad and relies on the corded or cordless home
telephone to dial telephone numbers. Wireless Home Phone includes caller-ID, call forwarding, and voicemail
features.
43
47 C.F.R. § 20.18(h).
44
Today, with wireline telephony, calls to 9-1-1 provide both the call back telephone number (ANI) and the Master
Street Address Guide (MSAG) location—i.e., the dialing party’s actual street address.
23
REDACTED -- FOR PUBLIC INSPECTION
enhancements that will allow AT&T to send MSAG information to the appropriate PSAP while
the device is at a registered service address. Under any such solution, the service would have to
allow subscribers to update their MSAG address easily and accurately when the base station
device has been moved to a new location.45 To the extent a customer uses the device while in
motion (such as in a mobile home or other vehicle), the device would provide the same 911
functionality as any other CMRS device. AT&T will not seek to grandfather its TDM-based
voice services until these enhancements are available.
6.1.2. Safeguards to Ensure Public Safety Functionality in Adverse Conditions
In any trial of IP-based services, the Commission wants providers to demonstrate that
they “will be able to immediately restore [their] legacy service, fix [their] IP-based service, or
provide a comparable service.”46 This condition has already been addressed for AT&T’s
proposed trial because (1) AT&T is planning on replacing legacy services with tested AT&T
VoIP services, which are highly reliable; and (2) AT&T has long-standing and well-tested
maintenance and repair operations and procedures to address the occasional service disruption.
Likewise, AT&T has the personnel, equipment, experience, and training to address service
disruptions caused by natural or manmade disasters (e.g., hurricanes, tornados, or derechos).
The AT&T VoIP services that AT&T plans to use during the Wire Center Trial are
already in place in those wire centers, as well as in hundreds of other wire centers across
AT&T’s in-region footprint. They have been tested over time and under various conditions.
AT&T intends to offer these services in place of legacy services—first on a voluntary basis and
ultimately as a replacement for discontinued services. These services are generally available in
the marketplace, and have been for years—they are not in any way new or experimental.
Consequently we already have practices and procedures in place to maintain and test facilities
and to address service disruptions. During the Wire Center Trials, AT&T will exercise the same
standard of maintenance, repair, and replacement for its IP-based services that it applies when
maintaining, repairing, and replacing legacy services.
In addition to everyday efforts to maintain and repair AT&T VoIP services, AT&T stands
ready, today, to respond to man-made and natural disasters that are capable of inflicting
significant damage to communities at large, resulting in commercial power outages and
destruction of facilities. As explained in prior filings with the Commission, AT&T has the
personnel, equipment, and know-how to respond to such events.47
45
If the wireless device were not at the registered MSAG location, then the service could still provide the calling
party’s ANI and ALI, i.e., the latitude and longitude of the caller’s location, as appropriate for any other wireless
device operating on AT&T’s licensed spectrum.
46
Technology Transition Trials Order, Appendix B, ¶ 17.
47
See, e.g., Comments of AT&T, PS Dockets Nos. 11-60, 10-92, 06-119, pp. 3-12 (filed July 7, 2011) (AT&T July
2011 Comments).
24
REDACTED -- FOR PUBLIC INSPECTION
The first line of defense is a hardened network. AT&T protects its facilities from
physical damage by designing them to meet or exceed industry standards for continued
operations during a wide range of natural and man-made disasters. This design focus includes
reference to specific conditions inherent to the local environment (e.g., frequency of earthquake
activity, susceptibility to hurricanes, likelihood of wild fires, etc.). At a minimum, AT&T
requires that critical equipment comply with Network Equipment-Building System (NEBS)
guidelines developed originally by Bell Labs and then later maintained by Telcordia
Technologies, Inc., now Ericsson. Moreover, AT&T is a leader in the measurement of network
reliability by adapting the manufacturing model of defects per million (DPM) to the
measurement of reliability in its own networks. Through the DPM measurement, AT&T is able
to rapidly and accurately determine the root cause of a network outage and to hold the
responsible party (e.g., vendor, supplier, process, or business unit) to account with the aim of
avoiding similar events in the future.
In addition to hardening the network, AT&T has invested in a Network Disaster
Recovery (NDR) program whereby AT&T “strives to deliver the highest levels of service,
quality, and reliability under all circumstances.”48 Under the NDR program, AT&T stands ready
to mobilize personnel and equipment by pre-staging and distributing mobile disaster response
technologies across the country. For example, AT&T has specially-designed tractor-trailers,
which act as virtual network offices and mobile command centers, called Emergency
Communications Vehicles (ECVs), and self-contained mobile cell sites (e.g., cells on wheels,
COWs, and cells on light trucks, COLTs) and satellite COLTs, which employ a satellite link to
provide voice and data service within 30 minutes of arriving on site.49
Additionally, AT&T maintains other emergency equipment and logistical support ready
for quick deployment, such as portable generators, industrial chillers, dewatering pumps, diesel,
gasoline, compressed natural gas fuel tanker capability, and mobile local fuel storage cells.
AT&T maintains a robust, best-in-class disaster recovery program, prepared to set up a
“M.A.S.H.”-style tent city, with thousands of military-grade Meals Ready to Eat (MRE) and
complete life, health, and safety support for AT&T’s army of restoration personnel. When a
telecommunications disaster strikes, it does not necessarily leave any supporting infrastructure,
so AT&T is prepared to operate a self-sufficient restoration camp, whenever necessary.50
AT&T applies the same staff, equipment, and know-how to AT&T VoIP services.
Therefore, the switch from reliance on TDM-based services to VoIP services will not diminish
48
See id., pp. 10-12. See also: http://www.corp.att.com/ndr/.
49
An example of this can be seen in AT&T’s response to the EF-5 tornado that struck Moore, OK, on May 21,
2013. http://www.corp.att.com/ndr/deployment_2013_moore_tornado.html.
50
AT&T was the first company in the country certified by Department of Homeland Security under the PS-Prep™
standards. See: https://www.dhs.gov/news/2012/03/14/dhs-announces-att-ps-prep-certification (“The Department
of Homeland Security (DHS) announced today that AT&T Inc. has become the first private sector company to be
certified to DHS-selected standards under the Voluntary Private Sector Preparedness Program. PS-Prep™”).
25
REDACTED -- FOR PUBLIC INSPECTION
AT&T’s investment in disaster recovery preparedness, lessen AT&T’s commitment to respond
quickly to disaster events, or otherwise undermine AT&T’s abilities to address the unique
challenges presented by such events. So, whether through everyday maintenance and repair
operations or through disaster recovery plans, AT&T has contingencies in place to address the
Commission’s concerns about confronting events that might compromise public safety.
6.1.3. Protect Essential Communications Services for Safety of Life and National
Security.
In the Technology Trial Order, the Commission emphasized that the proposed trials
would not “be permitted to threaten our country’s essential national security and public safety
communications systems.”51 As noted, certain departments and agencies of the United States
Government “maintain communications systems that today rely heavily on legacy TDM-based
networks and services.”52 In the Order, the Commission mentioned two by name—i.e.,
Department of Defense (DOD) and the Federal Aviation Administration (FAA)—but other
executive branch agencies may be in the same situation. Therefore, the Commission directed
applicants that any proposed trials “must . . . allow for the continuation of TDM-based networks
and services for critical Federal systems until it is proven that IP-based solutions can meet
system requirements for the performance of safety of life and national security missions.”53
Our study indicates that there are no DOD facilities or facilities of any other Federal
executive branch agency, including the FAA, served by any legacy TDM-based network
facilities or services originating from the Trial Wire Centers. Nevertheless, to the extent such
facilities exist, AT&T is committed to maintaining them until it is proven that AT&T IP-based
solutions can meet system requirements for the performance of safety of life and national
security missions.
6.1.4. Ensure Network Security
The Commission has requested detailed descriptions, including supporting data,
regarding the security practices that applicants have undertaken to secure IP-based infrastructure
and descriptions of the Supply Chain Risk Management (SCRM) practices applicants will follow
in the course of conducting their experiments. Network and information security are a
cornerstone of AT&T’s operations worldwide. AT&T has in place today a comprehensive risk
management program to ensure the security and integrity of its network and services, including
our IP-based infrastructure. In this section, AT&T provides an overview of that program, which
will apply to the wireless and wireline IP-based services AT&T will offer in place of TDM both
during and after the trials proposed here. Given the sensitivity of providing more detailed
51
Technology Transition Trials Order, ¶ 42.
52
Id.
53
Id., Appendix B, ¶ 18.
26
REDACTED -- FOR PUBLIC INSPECTION
information on AT&T’s security practices, additional information may be provided upon request
in direct consultation with the Commission.
AT&T has a long history of collaborating with the Commission on emerging issues and
security standards development through the Communications Security Reliability and
Interoperability Council (CSRIC). We also participate in the communications sector
coordination process for critical infrastructure, which is led by the Department of Homeland
Security (DHS). AT&T also notes that on February 12, 2014, the National Institute of Standards
and Technology (NIST) published its initial baseline Cybersecurity Framework to fulfill
President Obama’s Executive Order on cybersecurity, which proposes a set of baseline
requirements for critical infrastructure.54 NIST designed that framework based on industry
standards and best practices, with input from the communications sector and other stakeholders.
The implementation and continued evolution of the NIST framework should be a cooperative
effort that includes industry and government agencies. In addition, any standards that the
Commission develops in this area should broadly apply to all IP service providers, including
providers of VoIP services.
a.
AT&T’s Security Practices
AT&T’s corporate policy and practice is to protect its information resources from
unauthorized or improper use, theft, accidental or unauthorized modification, disclosure, transfer,
or destruction, and to implement protective measures commensurate with their sensitivity, value,
and criticality. AT&T’s information resources include any owned or managed systems,
applications, and network elements, and the information stored, transmitted, or processed with
these resources. AT&T develops and issues specific internal standards and other reference
materials in support of this policy, collectively referred to as the “AT&T Security Policy and
Requirements” (ASPR). ASPR includes policies addressing AT&T's workforce; its technology,
vendor, contractor, and supplier contracts; and overall compliance, as well as related riskassessment practices. Given the dynamic environment that AT&T supports, ASPR is continually
re-evaluated and modified as industry standards evolve and as circumstances require.
AT&T’s program is built upon industry standards such as ISO/IEC 27001:2005. AT&T
has undertaken an audit of its enterprise security policies, program and practices, resulting in
formal certification to the ISO27001:2005 Information Security Management Standard,
including the latest certification, which covers hosting and cloud services. Consistent with such
certification, AT&T: (1) systematically examines the organization's information security risks,
taking account of the threats, vulnerabilities, and impacts; (2) designs and implements a coherent
and comprehensive suite of information security controls and/or other forms of risk treatment
(such as risk avoidance or risk transfer) to address those risks that are deemed unacceptable; and
54
Framework for Improving Critical Infrastructure Cybersecurity, Version 1.0, National Institute of Standards and
Technology, Feb. 12, 2014. Available at http://www.nist.gov/cyberframework/.
27
REDACTED -- FOR PUBLIC INSPECTION
(3) has adopted an overarching management process to maintain information security controls
that continue to meet the organization's information security needs on an ongoing basis. AT&T
follows standards and certifications required for specific lines of business, including SSAE
16/ISAE 3402/SOC1 (formerly SAS 70), SOC 3 (formerly SysTrust), Payment Card Industry
(PCI) Data Security Standard (DSS), HITRUST, or similar certifications or audits.
Further, AT&T actively participates in a wide range of standards bodies that include
initiatives related to information security including the Internet Engineering Task Force (IETF),
Alliance for Telecommunications Industry Solutions (ATIS), 3rd Generation Partnership Project
(3GPP), GSMA, and the National Institute of Standards and Technology (NIST).
AT&T regularly conducts internal reviews of operations and applications functions to
ensure adherence to established security procedures. AT&T reports the results of these reviews
to its regional security managers and executive management. AT&T’s internal review of
business unit and operational compliance with security requirements consists of a comprehensive
review of an organization’s adherence to regulatory guidelines and internal policies, controls,
and procedures, as applicable. AT&T security auditors and assessors evaluate the strength and
thoroughness of compliance. Assessors review security policies, user access controls, and risk
management procedures over the course of a compliance engagement and report the findings to
all key stakeholders.
More specific to cybersecurity, AT&T maintains an extensive security program for the
detection and mitigation of cyber threats. There are multiple components to the program
including physical and logical access controls; network perimeter protection; intrusion detection;
workstation security management; security status checking and vulnerability testing; risk
management; security advisory program; security incident reporting; management and response;
security compliance reviews; internal and external reviews and audits; real time traffic
monitoring; change management; business continuity and disaster recovery; AT&T corporate
management engagement; strategy for continuous improvement; personnel security; security
awareness and education; and security training and certifications.
AT&T also has in place control frameworks that span various network assets including
applications, databases, servers, end-user devices (e.g., personal computers), modems, routers
and switches, and firewalls. These control areas can include, but are not limited to, as
appropriate, authentication, authorization, user and session management, data protection, data
validation, error and exception handling, auditing and login, configuration management, account
control, identification, system protection and integrity, patch management, anti-virus, disk
encryption, host intrusion, and a variety of other security controls. With respect to company
security practices that may be broadly applicable across sectors and throughout industry, AT&T
employs processes and procedures in each of the following functional categories: separation of
business from operational systems; separation of duties for administrators and users; use of
encryption and key management; identification and authorization of users accessing systems;
28
REDACTED -- FOR PUBLIC INSPECTION
asset identification and management; monitoring and incident detection tools and capabilities;
incident handling policies and procedures; mission/system resiliency practices; and security
engineering practices.
AT&T also maintains the security of its mobile network. AT&T’s Radio Access
Network (RAN) complies with 3GPP airlink security standards, as well as AT&T Security
policies, which are in turn certified to the ISO/IEC 27001:2005 Information Security
Management Standard. The RAN uses secure protocols in order to maintain and manage
communication with the mobile station, as well as specific procedures that include power control
and handover management. An important security mechanism that protects the radio link against
eavesdropping is encryption, which protects both user data and network control information.
AT&T and its employees also interact with and participate in several U.S. and
international security organizations, including, but not limited to the following:
•
Communications Sector Coordinating Council (CSCC);
•
National Security Telecommunications Advisory Council (NSTAC);
•
Computer Emergency Response Team/Coordination Center (CERT/CC);
•
Forum of International Response and Security Teams (FIRST) Team;
•
U.S. Department of Homeland Security’s National Security Telecommunications
Advisory Committee (NSTAC) and its National Coordinating Center (NCC) for
Telecommunication;
•
U.K. Centre for the Protection of National Infrastructure (CPNI);
•
National Security Information Exchange (NSIE);
•
Various Information Sharing and Analysis Centers (ISACs), including
Information Technology-ISAC and communications-ISAC;
•
US InfraGard;
•
Security activities within the Internet Engineering Task Force (IETF).
AT&T also participates in the following government cybersecurity initiatives:
•
National Infrastructure Protection Center (NIPC);
•
National Telecommunications and Information Administration (NTIA);
•
Network Reliability Steering Committee (NRSC).
29
REDACTED -- FOR PUBLIC INSPECTION
b.
Supply Chain Security Requirements
AT&T deals with a carefully selected and limited number of well-established core
network router and switch vendors, and has trusted relationships with these manufacturers and
vendors that have developed over time. When conducting due diligence in the selection of
network equipment, AT&T may, among other things, evaluate hardware and software to ensure
it meets AT&T’s security standards; test equipment to ensure data transfers cannot be intercepted
or redirected; test software to ensure data transmission security; examine manufacturer’s
provenance and business history; and consult with the NIST or the Department of Commerce.
AT&T generally requires its vendors to comply with the specifications applicable to the
network equipment, software, and devices that it procures. Compliance with these specifications
is an important factor in the vendor selection process. In addition, vendors generally are required
to comply with AT&T’s Supplier Information Security Requirements (SISR), a detailed set of
information and data security requirements incorporated into contracts. SISR, among other
things, requires a vendor to document its security controls and procedures and requires that they
be made available to AT&T for audit. These SISR requirements are an integral part of ASPR.
All suppliers and contractors and agents of the AT&T companies are responsible for protecting
AT&T information resources to preserve the confidentiality, integrity, and availability of
computing, networking, and information assets. Suppliers and contactors are trained before
being admitted into an AT&T workspace.
c.
IP Telephony
The security challenges associated with IP services include the risk of toll fraud, concerns
over data transmission and eavesdropping, voice phishing, denial of service attacks and spam.55
Most, if not all, of these threats are not new; they existed on traditional TDM networks too.
With proper precautions in place, security threats can be managed and minimized. Recently, a
range of standards and best practices to address these concerns have emerged.
AT&T follows standard security practices for IP-based services as part of its security risk
management program. During the trial, and throughout the transition, AT&T will continue its
review of emerging cybersecurity threats and security standards to determine which are
appropriate to protect its IP-based infrastructure. In 2010, the Commission, through CSRIC
(working group #2A, which was co-chaired by AT&T), refreshed its cybersecurity best practices
from its predecessor the Network Reliability and Interoperability Council (NRIC) and added
several practices related to VoIP. These include the suggestions that: service providers and
network operators should use dedicated VoIP servers; service providers and network operators
should block protocols meant for internal VoIP call control use at the VoIP perimeter; service
55
http://eandt.theiet.org/magazine/2011/07/voicing-security-concerns.cfm.
30
REDACTED -- FOR PUBLIC INSPECTION
providers should proxy remote HTTP access to VoIP perimeter firewalls; network operators
should ensure that network services are hardened and have authentication, integrity and
authorization controls in place to avoid inappropriate use of services; and equipment suppliers
should harden their equipment.
These recommended practices are based upon standards developed by the Defense
Information Systems Agency (DISA), the National Security Agency's (NSA) Security Guidance
for Deploying IP Telephony Systems and the PacketCable Security Specifications. In addition,
the industry has developed a range of common practices for the protection of IP-based telephony
services, including NIST 800-58 Security Considerations for Voice Over IP Systems. Most of
these documents apply existing cybersecurity practices—such as hardening, encryption, access
controls etc.—in a VoIP configuration.
6.1.5. Ensure Adequate Backup Power
In its Technology Trials Order, the Commission asks applicants to supply sufficient
information to help the Commission “evaluate the measures that will be taken to maintain
communications services in the event of a power outage.”56 In particular, the Commission is
focused on compliance with the Commission’s rules recently adopted in the 911 Network
Reliability R&O.
As to the 911 Network Reliability R&O, the Commission has directed Covered 911
Service Providers to submit an annual reliability certification, which includes certifications with
respect to backup power.57 The rule adopted in 2013, and which is still subject to Office of
Management and Budget approval under the Paperwork Reduction Act, requires certification
with respect to the manner of backup power (fixed or portable generators, batteries, fuel cells, or
combination), the duration of backup power (24 hours for Central Offices that directly serve a
PSAP; 72 hours for such Central Offices if they also host a selective router), testing and
maintenance of backup power equipment, and design of backup power equipment (e.g., fully
automatic operation, stand-alone functioning).58 If the Covered 911 Service Provider cannot
certify to all these elements, the rule also allows it to certify to alternative measures employed
by the provider to mitigate loss of service.
56
Technology Transition Trials Order, ¶ 44.
57
A “Covered 911 Service Provider” is defined as: “Any entity that: (A) Provides 911, E911, or NG911 capabilities
such as call routing, automatic location information (ALI), automatic number identification (ANI), or the functional
equivalent of those capabilities, directly to a public safety answering point (PSAP), statewide default answering
point, or appropriate local emergency authority as defined in sections 64.3000(b) and 20.3; and/or (B) Operates one
or more central offices that directly serve a PSAP. For purposes of this section, a central office directly serves a
PSAP if it hosts a selective router or ALI/ANI database, provides equivalent NG911 capabilities, or is the last
service-provider facility through which a 911 trunk or administrative line passes before connecting to a PSAP.” 911
Network Reliability R&O, Appendix B, Rule 12.4(a)(4).
58
911 Network Reliability R&O, Appendix B, Rule 12.4(c)(2).
31
REDACTED -- FOR PUBLIC INSPECTION
With respect to the Trial Wire Centers, AT&T is a Covered 911 Service Provider and, as
such, it fully intends to comply with all applicable Commission rules regarding 911 network
reliability and backup power. Today, on the network side, AT&T’s IP networks rely on
commercial power with a combination of fixed and portable generators and batteries to supply
backup power in case of loss of commercial power.
The Test Wire Centers have fixed diesel-fueled, backup engines. As a general practice,
AT&T strives to maintain a minimum of 72 hours’ worth of fuel in the engine tanks at all times.
For its disaster recovery efforts, AT&T has an emergency fueling plan, which is managed by its
Emergency Response Center and Fleet. And AT&T has a strategic partnership with a national
fueling vendor that is capable of drawing upon resources from around the country in support of
emergency refueling efforts.
In addition to the backup engines, each Test Wire Center has backup battery arrays. The
Carbon Hill Wire Center has a 7.7 Battery Hour Reserve (BHR) and Kings Point has a 3.6 BHR.
The BHR is the estimated battery life in terms of hours. Besides these backup power battery
arrays, AT&T has portable generators available to support the fixed engines in the event of a
failure for any reason. Portable generators are not typically staged at the wire center, but they
are close enough for AT&T to deploy them before exhaustion of the battery reserve life of the
direct-current plant (i.e., backup battery array) for each office. With the portable generators, run
times vary by the size of tank and the engine and current office load.
A significant difference between the network architecture of the TDM network and the IP
network is that the IP network is more distributed, meaning that not all of the critical network
elements are found within the confines of a wire center. These distributed elements are also
powered by commercial power with battery backup power. Typically, depending on the facility
in question, the backup power for distributed network elements runs from approximately four to
eight hours. Power to these distributed facilities, like a DLC remote terminal, is also backed up
by portable generators that are designed to be easily and quickly deployed and operationalized.
The only distributed network facility that relies solely on batteries for backup power is the fiberto-the-premises optical network terminal (ONT), which normally operates on commercial power
drawn from the subscriber’s home or place of business. Depending on circumstances, the ONT
backup power lasts approximately eight hours.
AT&T provides customers information regarding the battery backup for the terminal
equipment used with AT&T’s VoIP services online at its U-verse Voice Support web page.59
There, and in other customer-facing documents, AT&T alerts subscribers to the differences
between traditional telephone service and AT&T VoIP service, the different devices used to
provide the service (e.g., residential gateway and ONT), how such equipment is powered, their
respective backup power options, and instructions on what to do in preparation for and during
59
See: http://www.att.com/esupport/article.jsp?sid=KB409162#fbid=Yn0OinKDlSU.
32
REDACTED -- FOR PUBLIC INSPECTION
commercial power outages with the aim of improving the subscriber’s backup power battery life.
During the trial, the same information will be readily available to customers of the Trial Wire
Centers.
On the customer side of the demarcation point, AT&T U-verse VoIP, HSIA and IPTV
service rely on a residential gateway (RG) for customer access. Customers simply plug in
traditional corded or cordless home telephones to access the VoIP service.60 The RG runs on
commercial power but has a self-contained, rechargeable backup battery device that attaches to
the power wall socket on one side and the RG on the other.61 Should a subscriber lose
commercial power, the battery device automatically provides backup power for approximately
four hours.
Likewise, for Wireless Home Phone, the base-station device has a manufacturer-provided
rechargeable battery pack that has an approximate 36 stand-by hours and three and a half (3.5)
talk-time hours.62
6.1.6. Report Network Outages
In the Technology Trial Order, the Commission stated that, during any “experiments,”
the trial applicants should “commit[] to filing outage reports and PSAP notifications consistent
with the Part 4 rules.”63 The VoIP services that AT&T will use in the Trial Wire Centers to
replace existing TDM-based services are not experiments but rather tested services (see
discussion above). As such, with respect to these services today, AT&T is presently reporting
outages as set forth in the Part 4 rules and is committed to continue doing so during the Trial and
going forward.64
Similarly, Wireless Home Phone is a tested CMRS product and CMRS outages affecting
Wireless Home Phone customers are presently reported in conformance with 47 C.F.R. § 4.9(e).
AT&T fully expects any enhanced, successor product to be handled in a similar fashion.
6.1.7. Continued Compliance with CALEA
The Commission seeks acknowledgement from applicants that services used by
customers during any approved trial “will satisfy the Communications Assistance for Law
Enforcement Act (CALEA), their obligations under Titles 18 and 50, and similar State
60
While traditional corded phones do not reply on commercial power, cordless phones do. The backup power
options for a subscriber’s cordless phone would depend entirely on the make and model.
61
With future models of the RG, the backup power will be contained within the RG unit itself.
62
The rechargeable battery can be recharged by commercial power and by tapping into a motor vehicle electrical
system using an inverter or the vehicle’s power port or cigarette lighter.
63
Technology Transition Trials Order, ¶ 45.
64
47 C.F.R.§§ 4.1 et seq.
33
REDACTED -- FOR PUBLIC INSPECTION
requirements.”65 With respect to AT&T VoIP services, AT&T presently complies with its
CALEA and other law enforcement obligations. With respect to CALEA in particular, AT&T
VoIP services are compliant with the ATIS-1000678.v2.2006 (also known as T1.678) standard.
Likewise, AT&T’s wireless services are CALEA compliant. Our Wireless Home Phone
product today complies with the J-STD-025 for TDM-based wireless service. Moreover, with
the rollout of AT&T’s Voice over LTE (VoLTE) service, Wireless Home Phone will comply
with the appropriate IP-based standard (ATIS 0700005). Again, AT&T fully expects any
enhanced, successor product to be handled in a similar fashion.
6.1.8. Maintain Network Reliability
As previously noted, the Commission is expecting trial applicants to show that they will
maintain the “current levels of reliability, including the ability to function during commercial
power failures and security from external attack, should be maintained in an experiment.”66 To
this end, the Commission is interested in considering “the extent to which applicants will follow
the CSRIC best practices in the course of conducting their experiments,” both with regard to
their new networks and their transitioned networks.67
In its efforts to build and maintain a reliable and resilient network, AT&T strives to apply
best practices wherever and whenever such practices are appropriate to the situation at hand.
AT&T is an active participant in CSRIC, and has willingly adopted CSRIC best practices as
appropriate to the field conditions and the nature of the service offering. During the trial, AT&T
will continue to follow the CSRIC best practices, as applicable, with respect to its legacy
network and in the provision of VoIP and Wireless Home Phone services.
Both AT&T VoIP services and AT&T’s wireless services are highly reliable. With
respect to AT&T VoIP services, these services are at least as reliable as competitive fixed VoIP
services offered in AT&T’s in-region territories.68 Apart from the inherent reliability of the
AT&T VoIP services, AT&T has committed to a program to address the occasional, temporary
loss of commercial power (see discussion above on Backup Power), as well as the more serious
challenges posed during and after man-made and nature disasters (see Safeguards to Ensure
Public Safety above).
6.1.9. Provision of Public Alerts
The Commission correctly presumes that “applicants who support provision of Wireless
Emergency Alerts (WEA) over some or all of their service areas’ legacy infrastructure will
65
Technology Transition Trials Order, ¶ 46.
66
Id., Appendix B, ¶ 24.
67
Id.
68
Both Comcast in Kings Point and Charter Communications, Inc., in Carbon Hill offer competing VoIP services.
34
REDACTED -- FOR PUBLIC INSPECTION
continue to provide WEA or provide equivalent alerting capability in such areas.”69 With regard
to AT&T, that presumption is correct. This trial will in no way alter or diminish AT&T’s
provision of WEA.
Emergency Alert Systems (EAS) will not be affected by AT&T’s Transition Trial
because EAS are not dependent on legacy TDM facilities. As for AT&Ts U-verse television
service, in particular, we monitor, receive, and retransmit emergency alerts independently of
TDM services.
Accordingly, during AT&T’s Transition Trial, there should be no issue with sustaining
and providing current levels of public alerts.
6.1.10. Public Safety Priority Services
The Commission also presumes that during any trial, applicants “will accommodate
priority access, routing, provisioning, and restoration for essential national security and
emergency preparedness communications.”70 In particular, the Commission highlighted the
importance of Wireless Priority Service (WPS), Government Emergency Telecommunications
Service (GETS), and Telecommunications Service Priority (TSP) as being “at the core of
community planning” and “vital for tactical, emergency response.”71 None of these services will
be adversely affected by the proposed trial.
GETS traffic prioritization has been engineered into AT&T's business VoIP offering
allowing call prioritization across the IP and TDM networks. GETS prioritization has not yet
been engineered into the AT&T’s consumer VoIP offering (e.g., U-verse). GETS calls will still
complete across the CVoIP platform, but call prioritization would only occur on a portion of the
call that was engineered for NS/EP priority, (e.g., a TDM or BVoIP portion). WPS will not be
adversely impacted by the Wire Center Trial. WPS access is currently available through
AT&T’s Wireless Home Phone service.72
During the Trial, AT&T will support and comply with all TSP rules and policies for
applicable services—i.e., those services that have a Layer 1 component to the
circuit. Specifically, in the Trial Wire Centers, AT&T will be able to tag AT&T VoIP service
circuits to provide priority service for our TSP subscribers.73 As for any future enhanced version
69
Technology Transition Trials Order, Appendix B, ¶ 25.
70
Id., Appendix B, ¶ 27.
71
Id.
72
AT&T Mobility subscribers seeking to use the Wireless Home Phone service for WPS access will need a SIM
card provisioned for such access and will need to pay a subscription for the service. Access to GETS does not
require a paid subscription, but subscribers are charged when GETS is accessed.
73
While not anticipating any issues, AT&T is willing to take any unforeseen matters to the Commission’s TSP
Oversight Committee.
35
REDACTED -- FOR PUBLIC INSPECTION
of Wireless Home Phone, there would be no individualized Layer 1 element to prioritize.74
Restoration of wireless network service is appropriately prioritized to address the needs of
Wireless Home Phone subscribers.
6.2.
UNIVERSAL ACCESS
6.2.1. Access for Persons with Disabilities and Populations with Unique Needs.
During the trial (and, indeed, the broader IP transition), AT&T will continue to meet its
historic commitment to satisfying the communications needs of persons with disabilities and
populations with unique needs (including seniors, persons with limited English proficiency, lowincome populations, and residents of Tribal lands).75 That commitment dates to AT&T’s
founding, and is unparalleled in the communications industry and a model for service providers
in other industries.76 That will not change during the trials. To meet that commitment, AT&T
has developed an outreach plan for persons with disabilities and other populations with unique
needs as an integral component of the trials. That plan has five elements: identifying customers
with disabilities in the trial wire centers; customer outreach and education; customer care and
support; identifying accessible technology solutions; and transitioning persons with disabilities
from one service to another.
a.
Customer Identification
An essential component of AT&T’s outreach plan for persons with disabilities and other
populations with unique needs is to identify these customers so that we can provide notice of the
trials, accommodate their needs, and provide them a means to communicate with AT&T with
any concerns or issues they may have. However, AT&T does not generally request customers to
self-identify any disability or keep any records identifying customers with disabilities or who use
assistive technology. As a consequence, AT&T is seeking the cooperation and assistance of
national, state and local disability organizations with expertise regarding a range of disabilities to
help AT&T identify customers with disabilities while simultaneously maintaining those
customers’ reasonable expectations of privacy. Already, AT&T has met with disability
advocates and experts representing a dozen national organizations to share its plans for the trial
74
The Wireless Home Phone base station device is like any hand-held wireless device; that is, it is owned by the
subscriber. AT&T does not dispatch repair services for CPE.
75
As discussed in section 6.2.2., one of the IP-based replacement services AT&T will offer in the trial wire centers
is its Wireless Home Phone service. The price of Wireless Home Phone is lower than a typical customer pays today
for traditional POTS service, providing low income consumers (including elderly customers on a fixed income) a
low-cost option that meets their budgetary needs.
76
Indeed, Alexander Graham Bell, the founder of AT&T, was a teacher of deaf people, and his invention of the
telephone in 1876 was an outgrowth of his efforts to develop the first hearing aid. Global Initiative for Inclusive
Information and Communication Technologies (G3ict), White Paper, Accessibility, Innovation, and Sustainability at
AT&T: How a culture of inclusion and the adoption of Universal Design at AT&T drive business processes to serve
persons with disabilities, at 13 (2013) (listing early accessibility milestones at AT&T) (available at:
http://www.att.com/Common/merger/files/pdf/G3ict_White_Paper.pdf), attached hereto as Exhibit G. G3ict is an
Advocacy Initiative of the United Nations Global Alliance for ICT and Development, which seeks to facilitate and
support implementation of the Convention on the Rights of Persons with Disabilities.
36
REDACTED -- FOR PUBLIC INSPECTION
and to discuss the limitations we face in identifying customers with disabilities. AT&T will
work with these organizations to develop a plan for providing persons with disabilities detailed
information regarding the trials, and the steps AT&T will make to ensure they continue to have
access to accessible communications technologies and services. That plan will rely on those
organizations to contact their constituents directly to provide them such information using
communications media appropriate for individuals with different disabilities. AT&T is soliciting
proposals from these disability groups regarding how they will identify and communicate with
their constituents.
b.
Outreach/Communications
As discussed in Section 5, AT&T has developed a detailed and extensive customer
outreach and communications plan to ensure that all of our customers receive appropriate notice
and information about the trials, and their potential impact on customers. AT&T will include in
this initiative messages and communications media specifically tailored to meet the needs of
persons with various disabilities, and populations with unique needs. In particular, AT&T will:
•
Work with national disability organizations to identify and begin outreach to local
disability organizations in the trial areas and brief those local organizations on the IP
trials;
•
Include in customer notices regarding the trial a telephone number that customers
can call to speak with representatives at AT&T’s Disability and Aging Center, who are
specially trained to assist seniors and customers with disabilities and will be able to
communicate using TTY;
•
Launch an accessible website with information about the IP transition for
customers with and without disabilities;
•
Ensure that information it posts to the web about the trials will be accessible to
customers who are blind, with low vision, or other disabilities;
•
Provide customer service agents and retail employees with training materials
about the impact of the IP Transition on customers with disabilities;
•
Hold training sessions for local disability organizations, and for seniors;
•
Provide informational materials to local disability organizations and seniors
groups, and support their efforts to educate their constituents about the trials, how AT&T
plans to address the needs of persons with disabilities and seniors, and how to provide
feedback about their experiences to AT&T;
•
Collaborate with other organizations in the development of outreach material; and
•
Engage with local disability organizations and groups for seniors upon request ,
and participate with them in trial-related events.
37
REDACTED -- FOR PUBLIC INSPECTION
c.
Customer Care Process
AT&T’s customer care and support plans also have been designed to accommodate
persons with disabilities and populations with unique needs. Among other things, AT&T has
designed its customer care webpages and online tools to be accessible by persons with
disabilities and populations with unique needs (for example, the customer care webpages are
available in English and Spanish). We also have provided customer care agents at AT&T’s
Disability and Aging Center training and other materials regarding the trials, and how the
transition could impact assistive technology to ensure they provide appropriate care and support
to persons with disabilities and seniors.
d.
Technology
In section 4 and the detailed product sheets attached as Exhibit E, we have provided
detailed information regarding the transition, including information about the TDM-based
products and services offered in the trial wire centers, their IP-based wireline and wireless
replacements, and any differences in features, functions and capabilities between them. As
discussed above, AT&T still is developing some of these replacement services, and is in the
process of upgrading others to meet its customers’ needs and the fundamental network values
discussed above. For example, AT&T is upgrading its Wireless Home Phone service to provide
enhanced location accuracy, and to ensure that health monitoring and other devices will function
properly.
In developing and upgrading its IP-based wireline and wireless services, AT&T has
sought to ensure that they will meet the needs of persons with disabilities, seniors and other
populations with unique needs. We recognize the concerns such persons may have regarding the
impact of the TDM to IP transition, and plan to address accessibility issues head-on during the
trial so that we can work cooperatively with disability organizations, seniors and others to
develop appropriate technical solutions, consistent with our product/service design and
development process outlined above.
e.
Specific Customer Transitions
In the foregoing subsections, we have described AT&T’s general plans for addressing the
unique needs of persons with disabilities, seniors and other populations so they have access to
IP-based communications products and services that meet their needs, and are providing them
information needed to make the transition from TDM to IP during the trial. But we recognize
that each of our customers is a unique individual, and may have needs or concerns that we may
not have anticipated. As a consequence, we have implemented two precautions to ensure that all
of our customers with disabilities continue to have access to accessible communications services.
First, if a customer with a disability relies on assistive technology that does not function
effectively over AT&T’s IP-based alternative service and an IP-compatible device with
comparable functionality is not available, AT&T will not seek to transition that customer to an IP
alternative. Second, if customers with disabilities transition from TDM to IP and later find their
assistive technology does not work, AT&T promptly will switch them back to their prior TDM
service while we identify an appropriate solution.
38
REDACTED -- FOR PUBLIC INSPECTION
6.2.2. Maintaining Universal Service Status Quo.
Consistent with the Commission’s presumption in the Technology Transitions Order,
AT&T will maintain its existing eligible telecommunications carrier (ETC) status and comply
with all obligations arising from that status, at the outset of the trials — that is, during the period
AT&T offers IP-based services only on a voluntary basis in the wire centers.77 But, at an
appropriate time before AT&T seeks to grandfather existing customers of TDM-based services,
AT&T plans to file a request for relief from the ETC obligations in the trial wire centers
effective on the first day of Stage 1 of the trials.78 In that request, AT&T will demonstrate how it
will satisfy the universal access statutory objective in other ways, and elaborate on why such
relief is appropriate. In this section, we provide a brief overview of the issue to preview why it
will be unnecessary to require AT&T and AT&T to maintain their ETC status in the two trial
wire centers, and how doing so would hinder these experiments.
Congress created the ETC designation in the Telecommunications Act of 1996 (1996
Act) and determined that only ETCs shall be eligible to receive specific universal service
support,79 except for Lifeline support, which Congress exempted from that requirement.80
Notwithstanding this congressional exemption, the Commission has linked participation in its
Lifeline program to the ETC designation through its rules so that, currently, every ETC must
participate in the Commission’s Lifeline program.81 Additionally, the Commission has permitted
providers to participate only in the Commission’s Lifeline program but it has required those
providers to become Lifeline-only “ETCs,” which, is unnecessary pursuant to section 254(j) of
the statute.
By statute, ETCs are common carriers that must “offer the services that are supported by
Federal universal service support mechanisms” throughout their designated ETC service areas.82
Currently, “voice telephony service” is the sole supported service.83 As a condition of receiving
high-cost support in a state, the Commission requires an ETC to offer voice telephony service on
a standalone basis throughout its designated service area in that state.84 AT&T does not offer its
77
Technology Transition Trials Order, App. B at ¶ 32.
78
Of course, if the Commission modifies its ETC requirements before the first day of Stage 1 of the trials, which it
should, there may be no need for AT&T to request such relief.
79
See 47 U.S.C. §§ 214(e), 254(e).
80
47 U.S.C. § 254(j) (“Nothing in this section shall affect the collection, distribution, or administration of the
Lifeline Assistance Program . . . .”).
81
See 47 C.F.R. § 54.405(a).
82
See 47 U.S.C. § 214(e)(1).
83
47 C.F.R. § 54.101(a).
84
See Connect America Fund, et al., WC Docket No. 10-90 et al., 26 FCC Rcd 17663, ¶ 80 (2011) (USF/ICC
Transformation Order).
39
REDACTED -- FOR PUBLIC INSPECTION
VoIP services on a common carrier basis, nor does it offer its VoIP services on a standalone
basis. Additionally, as noted above, ETCs must offer Lifeline-discounted service to eligible lowincome customers and comply with the Commission’s Lifeline program obligations.
ETCs also must comply with various reporting requirements and, potentially, stateimposed ETC obligations. State commissions are required to permit an ETC to relinquish its
designation in any area served by another ETC.85 But, there is no clear path for ETCs to
relinquish their designations in those geographic areas where there is no other ETC even if there
are numerous other providers offering voice telephony service in such areas.
Despite the Commission’s directive in 1997 that states should not designate large carriers
as ETCs throughout their entire study areas,86 all of the state commissions where AT&T provides
service as an incumbent local exchange carrier (ILEC) did just that. The ETC service areas of
AT&T’s ILECs mirror these carriers’ study areas. Consequently, in those states where AT&T’s
ILECs receive some amount of high-cost support, however small or targeted to discrete
geographic areas, these carriers are required to offer voice telephony service on a standalone
basis throughout their vast study areas. AT&T receives so-called frozen high-cost support in
Alabama and Florida. Although it is not required to spend any of that high-cost support in the
trial wire centers under the Commission’s current requirements, AT&T must offer a standalone
voice service in these wire centers.
Later this year, the Commission will offer price cap carriers, such as AT&T, Connect
America Fund (CAF) Phase II support.87 This support will be targeted to Commission-identified
high-cost areas. All other areas within a price cap carrier’s study area will be ineligible for CAF
Phase II support. If a price cap carrier declines the Commission’s offer of model-calculated
support (referred to as the state-level commitment), the Commission will commence a
competitive process to award support to providers that will deploy broadband in these
Commission-identified areas.88 Unless the Commission modifies the ETC requirements
applicable to price cap carriers, which it should, any AT&T ILEC that remains a legacy ETC will
be saddled with service obligations (to provide Lifeline, to the extent it continues to receive
frozen high cost support and stand-alone voice throughout its entire study area) that would not
apply to their competitors receiving the same support. Those competitors likely will seek and
obtain ETC designations covering only those areas where they actually receive CAF Phase II
support. Even if AT&T’s ILECs do not accept any CAF Phase II support, they will be subject to
service obligations (to offer voice telephony service and Lifeline supported services throughout
the area for which they have been designated as an ETC) that will not apply to such competitors.
85
47 U.S.C. § 214(e)(4).
86
First Universal Service Order at ¶¶ 184, 185.
87
Technology Transitions Trial Order at ¶ 98 (“We expect to implement the offer of model-based support to price
cap carriers before the end of 2014.”).
88
See, id. at ¶ 100.
40
REDACTED -- FOR PUBLIC INSPECTION
Moreover, insofar as large swaths of AT&T ILECs’ service territories will be ineligible for CAF
Phase II support, their obligation to provide voice and Lifeline service in much, if not most, of
their territories will be unfunded.
Under the latest version of the Commission’s Connect America Model (CAM), almost all
of the Kings Point wire center is ineligible for CAF Phase II support, and many areas within the
Carbon Hill wire center are similarly ineligible.89 Unless the Wireline Competition Bureau
drastically changes the CAM before the date it is scheduled to offer price cap carriers Phase II
support later this year, the Commission soon will conclude (based on its own measure — the
CAM) that the trial wire centers require little or no universal service support to preserve and
advance universal access,90 and neither AT&T nor any other provider will be eligible to receive
support there. If the Commission determines that support is unnecessary to maintain universal
access in these areas, it also should find that requiring a carrier to maintain its ETC status is
unnecessary to protect the public interest. For those pockets of the two trial wire centers that are
CAF Phase II eligible, if the Commission offers a sufficient amount of support, some provider –
which may be AT&T or some unaffiliated provider – may accept the service obligations in
exchange for the funding. And, that provider will be an ETC, in accordance with the
Commission’s requirements.
Requiring AT&T to provide voice on a standalone basis in areas where it does not
receive – and, under CAF Phase II, where it cannot receive – high-cost support, would distort the
market. In particular, such a requirement would preclude AT&T, but not its competitors, from
offering voice only as part of a bundle with broadband Internet access and/or video services, or
as an application provided over a broadband Internet access service.91 Particularly given the
robust competition AT&T faces from wireless, cable MSOs and other wireline providers of
broadband, there is no basis for limiting the way in which AT&T and other ETCs may structure
their services if those limits do not apply to competitors as well — particularly in areas where the
Commission has concluded that funding is unnecessary to support universal service. Any such
requirement is wholly unnecessary because customers in the trial wire centers have a multitude
89
See Wireline Competition Bureau Releases Maps of Illustrative Results for Connect America Cost Model Version
4.0, WC Docket No. 10-90, Public Notice, DA 14-153 (rel. Feb. 6, 2014). According to CAM v4.0, the amount of
CAF Phase II support that would be available to serve the eligible areas in the Kings Point wire center is less than
$8,900/year and $160,000/year in the Carbon Hill wire center.
90
See 47 U.S.C. § 254(b)(5) (The Commission should establish “specific, predictable, and sufficient . . .
mechanisms to preserve and advance universal service.”).
91
Given the very high capital costs necessary to expand broadband deployment, service providers must be able to
recover their costs from subscribers. Often the most cost-effective way to do so is by offering bundled packages of
services. The alternative is to significantly increase the cost of stand-alone voice services to levels that may be
unacceptable to consumers.
41
REDACTED -- FOR PUBLIC INSPECTION
of voice offerings available,92 including AT&T Mobility’s Wireless Home Phone service, which
provides unlimited local and long distance calling within the United States for $19.99/month
Nor is there any reason to require AT&T to remain an ETC in the trial wire centers solely
to provide Lifeline. Other than AT&T, there currently are 19 providers offering Lifeline in the
Carbon Hill wire center and 7 providers offering Lifeline in the Kings Point wire center.
Moreover, as discussed above, AT&T will offer in the trial wire centers unlimited local and
domestic long-distance calling over its Wireless Home Phone service at rates that are typically
less expensive than the amount AT&T’s Lifeline customers currently pay for traditional voice
telephone services.93 Consequently, irrespective of whether AT&T provides Lifeline service,
low income customers (and, indeed, other persons with unique needs, such as seniors on fixed
incomes) will continue to have access to low cost voice telephone services in the trial wire
centers.
In any event, one of the objectives of these trials is to evaluate the effect the IP transition
will have on customers. As broadband is ubiquitously deployed and adoption rates increase,
voice is apt to become just another application that will be offered to customers. Quite simply,
as the IP transition progresses, there likely will be no business case for a wireline provider to
offer voice on a standalone basis. Post-transition, to the extent that companies offer “standalone”
voice, they are likely to do so only at prices that are approximately the same as the price for
standalone broadband service, and there is no policy reason why the Commission should compel
AT&T to do otherwise during the experiment. For the reasons mentioned above, which will be
described in further detail in a subsequent pleading, AT&T will request relief from their ETC
obligations in the two trial wire centers.
6.2.3. Preserving and Enhancing Broadband Access.
AT&T has long been committed to deploying next generation broadband facilities and
services to as much of its service territory and customers as possible. Where it is economic to do
so, AT&T is expanding its U-verse footprint and replacing its traditional DSL broadband
technology (which is approaching the end of its life cycle) in order to provide higher-speed, IPbased wireline broadband to 57 million customer locations. In particular, AT&T is expanding Uverse—AT&T’s integrated voice, data, and IPTV platform—by 8.5 million additional customer
locations, for a total potential U-verse market of nearly 33 million customer locations. AT&T
also plans to offer IPDSL-based service (U-verse High-Speed Internet) to nearly 24 million
customer locations in its wireline service area. At the same time, AT&T is expanding its LTE
deployment to reach 300 million people. As part of that initiative, AT&T will offer wireless
92
See supra section 3.7.
93
Using billing data for a one month period, the average monthly bill for traditional voice telephone services
(including local telephone service with features and long distance services) for Lifeline customers in Carbon Hill
was [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE]and for Lifeline customers in Kings Point it was
[CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE]. These amounts include the Lifeline discount.
42
REDACTED -- FOR PUBLIC INSPECTION
communications alternatives (including its Wireless Home Phone, Wireless Home Phone and
Internet and Wireless Business Phone services) to customers living in particularly high-cost
areas. Taken together, these deployments are projected to extend high-quality IP-based
broadband services (wireline, wireless or both) to 99 percent of all customer locations within
AT&T’s 22-state wireline service area. Those broadband services are significantly better than
AT&T’s legacy ATM-based DSL services, enabling customers to access the Internet faster and
with better quality service than ever before.
However, AT&T cannot economically extend its next generation wireline and wireless
broadband footprint to reach every corner and customer across its 22-state wireline service area,
which is the case in the trial wire centers as well. As discussed above, AT&T designed these
trials to ensure that they will provide an opportunity to flesh out the most challenging issues
raised by the IP transition. The Carbon Hill wire center, in particular, presents geographic,
economic and technical challenges. It is a sparsely populated area located in rural Alabama.
These factors make it uneconomic for AT&T to extend its next generation wireline broadband
network and services to all existing customer locations in Carbon Hill. Consequently, AT&T
currently plans to offer such wireline IP services to approximately [CONFIDENTIAL – NOT
FOR PUBLIC DISCLOSURE] percent of living units in Carbon Hill. It will offer its wireless
broadband voice and data services only to an additional [CONFIDENTIAL – NOT FOR
PUBLIC DISCLOSURE] percent of living units. AT&T has not yet found a viable
replacement service for the remaining four percent of locations, and still is considering its
options for those living units. AT&T recognizes that it is responsible for ensuring that these
customers will have an alternative available to them prior to discontinuing TDM services, and is,
in all events, committed to working with the Commission, policymakers, and other stakeholders
to ensure that this happens.
Some of AT&T’s existing wireline broadband customers (those purchasing traditional
DSL services) reside at locations that cannot be reached by AT&T’s U-verse or IP DSLAM
network and services given the distance limitations of those technologies. At the same time,
AT&T economically cannot maintain its legacy network (including the facilities used to provide
traditional DSL services) to continue serving the relatively small number of such locations that
could be reached by legacy DSL but not AT&T’s U-verse VDSL or IPDSL services. In all
cases, AT&T will be able to offer those customers wireline or wireless broadband services. In
Carbon Hill, [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE] percent of existing
consumer DSL customers will have only a wireless broadband service available from AT&T.
The remaining [CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE] percent will have a
wireline broadband replacement available from AT&T, and most of these also will have access
to a wireless broadband service. In Kings Point, [CONFIDENTIAL – NOT FOR PUBLIC
DISCLOSURE] percent of existing consumer DSL customers will have only a wireless
broadband service available from AT&T. The remaining approximately [CONFIDENTIAL –
43
REDACTED -- FOR PUBLIC INSPECTION
NOT FOR PUBLIC DISCLOSURE] percent will have wireline broadband replacement
available from AT&T, and most of these also will have access to a wireless broadband service.
6.2.4. Maintaining Quality of Service.
As the Commission itself recognizes, converged IP networks are far more dynamic,
versatile, resilient, and efficient than the single-purpose TDM networks they are replacing. IP
networks (both wireline and wireless) thus enable a variety of new services, features and
functions that will benefit customers and provide a platform for growth and innovation. It is
important not to lose sight of this enormous potential amidst fears that not everything will be
exactly the same or that certain functionalities will be lost as the transition proceeds. If
customers experience significant net benefits from the transition — which they will — then the
transition is in the public interest. But, if service providers end up designing their IP networks
and services simply to replicate the features, functions and capabilities of legacy TDM networks
and services, the IP Transition will be a failure insofar as customers will not realize the full
benefits offered by the transition. As AT&T previously has explained,94 the transition to all-IP
services will entail trade-offs, and not every feature and function offered over TDM will be
available or will work in the same manner during and after the transition.
In designing the wireline and wireless IP-based services that it will offer in place of
legacy TDM services, AT&T has sought to carry over those features and functions that
customers demand, and that are necessary to meet the foregoing fundamental principles and
values. In some cases, the features and functions of those replacement services differ from those
of existing services. For example, voice quality on CMRS networks and services currently
differs from that of traditional, TDM voice services (which were designed solely to transmit
voice communications). Nonetheless, over 40 percent of American households have cut the cord
entirely and rely solely on CMRS service for their voice communications needs. And millions of
these rely on CMRS to connect traditional telephone handsets to the PSTN (e.g., through
AT&T’s Wireless Home Phone and other comparable services). The question then is whether
the differences in features and functions between legacy TDM services and their wireless and
wireline IP replacements are nonetheless acceptable, and thus whether those replacements are
reasonable and adequate alternative to TDM,95 which are some of the questions these trials are
intended to address.
Of course, IP services are continuing to evolve, and they undoubtedly will provide even
greater levels of functionality and higher quality to users than they do now. Today, wireline
VoIP services offer sound quality as good as or better than the sound quality customers have
come to expect from TDM voice services. That was not always the case. And even if some
94
See Reply Comments of AT&T Services, Inc., GN Docket No. 13-5, at 9-12 (filed Aug. 7, 2013).
95
As the tens of millions of customers that have cut the cord and rely solely on wireless for voice communications
both in and outside their homes demonstrate, that would appear to be the case with wireless voice quality.
44
REDACTED -- FOR PUBLIC INSPECTION
customers do not deem the sound quality of CMRS to be as good as traditional POTS, that
quality will only get better as wireless providers expand their deployment of LTE, which will
enable high-definition (“HD”) voice, which, in turn, is expected to provide audio quality superior
to traditional POTS services. But these innovations will never get off the ground if the transition
is bogged down by misguided calls to replicate every facet of the TDM network.
In this plan, AT&T has identified the features and functions of its wireless and wireline
IP replacement products (including those already available and those that will be implemented in
the course of the trial along with a timeline showing when they will be available). It also has
identified whether and how they differ from TDM to ensure all interested parties understand the
impact of, and can appropriately prepare for, the IP transition. AT&T believes its IP replacement
services (most of which already are available in the market today) provide appropriate and, in
many cases, superior substitutes for the legacy TDM services it will discontinue as the IP
transition proceeds. We welcome a dialogue with consumers, policymakers and others regarding
any potential gap in technology or services they may identify, and whether and by whom such
gap should be filled.
6.3
COMPETITION
6.3.1. Maintaining Wholesale Access.
As is the case with AT&T’s end user retail customers, a complete test of the transition
would entail the required participation of all actors in the test wire centers, including wholesale
customers. AT&T nevertheless is prepared to move forward with trials in the test wire centers
subject to the condition established in the Transition Trials Order limiting the involvement of
wholesale customers at the initiation of the trial to those that participate voluntarily.96 In this
section, AT&T describes its plans for addressing the other conditions and presumptions
established in the Order and its Appendix B that are pertinent to our wholesale customers.97
Non-affiliated carriers currently are purchasing wholesale services in both proposed test
wire centers.98 As might be expected for a wire center of its size and rural location, the Carbon
Hill wire center has less wholesale activity than Kings Point. The most recent data available
shows that the bulk of the wholesale services that non-affiliated carriers purchase in Carbon Hill
involves CLECs purchasing either AT&T’s Local Wholesale Complete™ (LWC) commercial
product or retail services for resale, although other carriers also are purchasing DS1 special
access circuits for what appears to be wireless backhaul.
96
Technology Transition Trials Order, ¶ 59 and n.91. As the Order contemplates (id., n.91), AT&T expects to
pursue additional phases of these trials that would include, with the Commission’s authorization through the Section
214 process, the complete withdrawal of TDM-based wholesale services. To that end, AT&T has identified in the
product data sheets in Exhibit E the interstate TDM wholesale services for which 214 applications will be filed, and
anticipates submitting an application to grandfather those services in the trial wire centers on July 1, 2015, with the
goal of sunsetting TDM wholesale services there by March 31, 2017.
97
See id., ¶¶ 59-64 and App. B, ¶¶ 35-39.
98
AT&T is continuing to research the specific extent of wholesale activity in each wire center, and will supplement
this filing at an appropriate time to incorporate information regarding such activity.
45
REDACTED -- FOR PUBLIC INSPECTION
In contrast, far more wholesale customers are active in the Kings Point wire center, and
they purchase wholesale services in greater volumes than in Carbon Hill, which is not surprising,
given the relatively larger and denser population and suburban location of that wire center.
Those customers are a diverse group, including large national wireless carriers, some of the
nation’s largest CLECs, and smaller, regional carriers. The TDM-based products and services
they purchase are just as diverse, and encompass not only the commercial LWC product, but also
switched Ethernet services, legacy DSn-level special access services, unbundled network
elements (including 2-wire voice grade loops, unbundled DSL capable loops, 2- and 4-wire
digital loops, and DS-1 enhanced extended loops), and resold consumer and business retail
services.
As we stated at the outset of this submission, AT&T values its relations with its
wholesale customers, and intends to work aggressively to retain their business as the entire
industry undergoes the transition to an all-IP ecosystem. Accordingly, AT&T has identified the
replacement products that already are available as alternatives to current legacy TDM services –
such as the AT&T Switched Ethernet (ASE) service that is available to replace DSn-level special
access services and high capacity loop and transport UNEs – and will provide customers who
choose to do so the opportunity to transition to those alternatives in this initial phase of the trial.
AT&T also will continue to meet its wholesale obligations under Section 251(c) of the Act,
including by making UNEs available through the current stage of the trial. At the same time,
wholesale customers will have the opportunity to obtain bare copper loops and utilize their own
electronics to provide high capacity services to their end user customers.99 AT&T also is
working diligently to develop IP replacement services, which it intends to make available for
resale to wholesale customers on commercial terms. AT&T’s objective is to complete those
development efforts, as well as those aimed at developing an IP-based alternative to the LWC
product, as soon as possible, although it is likely the final commercial products will not be
available until the trials already are underway.
AT&T’s wholesale marketing plan for the initial stage of the proposed trials is
straightforward: we will proactively engage our wholesale customers in these wire centers to
offer them the opportunity voluntarily to migrate from their existing TDM-based services and
products to the available replacement products. This process will include normal methods for
contacting wholesale customers on an industry-wide basis (such as through accessible letters),100
and direct outreach by sales teams to the customers identified as active in these wire centers.
99
The Technology Transition Trials Order stated that the Commission did not intend to resolve legal and policy
questions resulting from the transition in the context of any trials. Id., ¶ 8. Consistent with the Commission’s intent,
AT&T is not seeking to resolve any issues through this application, nor in this phase of the proposed trial, on such
issues, including those concerning the extent to which wholesale obligations associated with an ILEC’s provision of
TDM-based services, such as the required unbundling of high capacity loops or the resale of telecommunications
services, apply to IP-based services.
100
These larger industry outreach efforts are important because the universe of potential customers in these wire
centers is not limited to those that already are active there. For example, any CLEC authorized to provide service in
the states of Alabama or Florida could elect to participate in the trial.
46
REDACTED -- FOR PUBLIC INSPECTION
Finally, and as noted previously, the Commission established specific conditions and
presumptions that are intended to ensure that parties seeking to engage in transitions-related
trials secure and support the core value of Competition in the course of any proposed trials.
AT&T embraces that core value, and shares the Commission’s goal of preserving it in the
proposed wire center trials. Accordingly, AT&T addresses each of those conditions and
presumptions below:
a.
Wholesale Access
As noted above, and as required in the Order,101 any participation by wholesale
customers in this first phase of the proposed wire center trials will be entirely voluntary. No
customer will be forced to migrate to alternative services or products, or to alter its current
wholesale arrangements with AT&T during the initial phase of the trials. In particular, the same
wholesale customers that currently use AT&T’s network in these wire centers will continue to be
able to do so during this phase of the proposed trials.102 There are no plans to change the types
of wholesale access that customers who do not participate in the initial phase of the trial
currently receive, or to alter the price or cost of that access.103 As for those customers that do
voluntarily elect to participate, that decision undoubtedly will be driven by their determination
that the alternative service is at least functionally equivalent to the original – and more likely
better -- and provides greater value for that level of functionality. For example, the ASE service
provides significantly higher, and scalable, bandwidth than the legacy TDM DSn service it
replaces. Again, participation at the initiation of the proposed trials is entirely voluntary on the
part of our wholesale customers, and we fully anticipate that any customer considering doing so
– especially these sophisticated wholesale customers – will drive a hard bargain in that process –
and that the end results of those negotiations would likely encompass terms such as those
identified by the Commission in Appendix B.104
b.
Interconnection
AT&T’s proposed test satisfies the condition established in the Order “to maintain the
status quo in providing interconnection arrangements to both existing and new customers.”105 In
particular, the proposed trial will not result “in the cessation or impairment of service” for either
other providers or end user customers.106 Obviously, the interconnection arrangements necessary
to carry traffic to and from the embedded base of TDM customers in these wire centers will be
unaffected during the first phase of the trials for one very obvious reason – those customers are
not required to participate in the trial. But the same holds true for traffic destined to new retail
101
Id., ¶ 59.
102
See id., App. B, ¶ 35 (applicant must “ensure that the same types of wholesale customers can continue to use its
network. . . .”).
103
See id.
104
See id. (describing terms that would apply purchases of alternative services to discounts for purchases “outside of
the experiment areas” and waiver of early termination fees “if early termination is caused by the experiment.”).
105
Id., ¶ 61.
106
See id., ¶ 62.
47
REDACTED -- FOR PUBLIC INSPECTION
customers, who may be required in the trial to utilize either U-verse Voice or Wireless Home
Phone as alternatives to legacy TDM wireline retail services, and those existing customers who
voluntarily elect to make the transition in the trial. This again is true for one very simple reason - the interconnection arrangements necessary to terminate traffic to AT&T’s VoIP voice
customers or to its Wireless Home Phone customers, as opposed to TDM customers, already are
present in the market and are being used to successfully carry that traffic.
To be clear, the exchange of traffic for customers subscribing to those IP replacement
services will entail differences in call routing from that for customers subscribing to AT&T’s
legacy wireline TDM services. For example, a call from a CLEC end user customer to an AT&T
consumer VoIP customer would be routed through AT&T’s access tandem for delivery to
AT&T’s affiliate serving the customer. This might mean a change in routing for a provider that
had established direct end office trunking at the AT&T ILEC central office in order to terminate
calls to AT&T’s legacy TDM customers. Similarly, a call from an IXC customer to an AT&T
customer subscribing to the Wireless Home Phone product would also utilize trunking to the
AT&T access tandem or a competitive transit provider.107 But this is nothing new because
customers already are utilizing these existing trunking arrangements outside of the trials, and
thus these types of changes in trunking and routing arrangements exist in the marketplace today
without raising any issues. And AT&T’s proposed trials will not negatively affect that status
quo.
By the same token, any changes in costs associated with changes in these routing
protocols already are being captured in the market. And given the small size of the Carbon Hill
wire center, and the overall limitations imposed in the Order on the customers in either wire
center who can be required to subscribe to the IP-based services (that is, only new retail
customers), there should be no material cost impact on interconnecting carriers attributable to
this phase of the trials, since the arrangements carriers already have implemented to carry traffic
to and from VoIP and Wireless Home Phone customers are plainly sufficient to meet existing
demand. Moreover, as the transition proceeds, carriers also will likely experience cost savings as
they eliminate existing direct end office trunking arrangements that no longer would be
necessary to reach TDM customers.
Finally, the Order notes that the Commission wants to “be able to evaluate whether
customers in experiment arenas will be able to select their own interexchange carrier (IXC) and
how IXCs will terminate interstate interexchange or international calls to customers participating
in the experiment.108 Taking these issues in reverse order, AT&T’s proposed wire center trials
will have no effect on how IXCs terminate interstate interexchange or international calls to
customers participating in the experiment. Any such calls will continue to be routed to U-verse
Voice and Wireless Home Phone customers as they are today. As for the first issue, retail
customers who voluntarily choose to participate in the trials – and thus to subscribe to either Uverse Voice or Wireless Home Phone -- will not select a separate IXC to carry long distance
107
To the extent a provider has direct interconnection arrangements with AT&T Corp. or AT&T Mobility, the traffic
will be exchanged with AT&T over those existing interconnection arrangements.
108
Id. Contrary to the suggestion in the Technology Transition Trials Order, no additional guidance on these issues
is provided in Appendix B.
48
REDACTED -- FOR PUBLIC INSPECTION
calls. Indeed, assuming it is even technically feasible, imposing such a requirement on these IPbased services would be prohibitively expensive and fundamentally at odds with the “any
distance” nature of IP services themselves.109 As the Order’s portrayal of the history of
transformative technology transitions suggests, these trials are about testing effects of deploying
network infrastructure “that can conquer space and time. . . .”110 Constraining those tests with
anachronistic concepts rooted in discrete markets for local, intraLATA, interLATA and interstate
traffic that no longer reflect customer preferences and marketplace conditions would be
counterproductive.111
6.3.2. Intercarrier Compensation.
During the trials, AT&T will maintain the intercarrier compensation status quo ante in
accordance with the Commission’s USF/ICC Transformation Order,112 including the transition
to bill-and-keep in these wire centers. AT&T’s VoIP and Wireless Home Phone services are and
will remain subject to the existing intercarrier compensation regimes for VoIP-PSTN or CMRS
traffic, as appropriate.
Intercarrier compensation revenues and obligations would change only due to customers’
shifts between services subject to different intercarrier compensation regimes rather than any
impact from the trial itself. For example, if an end user chooses Wireless Home Phone instead of
POTS, compensation for terminating calls to that customer would be the compensation regime
applicable to CMRS, rather than the wireline compensation regime. That is a function of the
intercarrier compensation regime itself and is the case anytime a customer switches, even outside
a trial. AT&T does not and will not as part of the trial charge subscriber line charges (“SLCs”)
or access recovery charges (“ARCs”) on VoIP or Wireless Home Phone services. Accordingly,
AT&T seeks no new authorization to tariff or otherwise charge SLCs or ARCs for the customers
109
Cf. Vonage Holdings Corporation Petition for Declaratory Ruling Concerning an Order of the Minnesota Public
Utilities Commission, Memorandum Opinion and Order, WC Docket No. 03-211 (Nov. 12, 2004), at ¶ 14 (finding
that the characteristics of Vonage’s VoIP service “preclude any practical identification of, and separation into,
interstate and intrastate communications for purposes of effectuating a dual federal/state regulatory scheme. . . .”).
110
Id., ¶ 11.
111
It is clear that any equal access obligations that are now captured in the provisions of the 1996 Act will no longer
apply in an all-IP environment. For example, the dialing parity requirement established in 47 U.S.C. §251(b)(3) is
imposed on Local exchange carriers.” Thus, insofar as AT&T, as a VoIP provider, is not providing that service as a
common carrier and no longer will provide telephone exchange service or exchange access, it no longer would be
subject to that obligation. The provision also would be inapplicable to VoIP service, which is by its nature distance
agnostic, because it is not properly classified as “telephone exchange service” or “telephone toll service.” See 47
U.S.C. §153(54), (55) (defining “telephone exchange service” and “telephone toll service”).
112
See generally Connect America Fund, et al., WC Docket No. 10-90, et al., Report and Order and Further Notice
of Proposed Rulemaking, 26 FCC Rcd 17663 (2011) (USF/ICC Transformation Order), pets. for review pending
sub nom. In re: FCC 11-161, No. 11-9900 (10th Cir. filed Dec. 8, 2011) (subsequent history omitted).
49
REDACTED -- FOR PUBLIC INSPECTION
in the trial. In addition, the trials as proposed should not have material impact on AT&T’s
Eligible Recovery.113
Finally, AT&T agrees that policy issues, including those related to compensation
between providers in an all-IP environment, are appropriately addressed outside of the trials,114
and as the Commission notes, it “need not address these issues before proceeding with the
experiments.”115 As noted above, these trials will not affect wholesale access or interconnection,
and therefore, resolving policy and legal issues related to compensation for IP interconnection is
not within the scope of this trial. In any event, AT&T does not intend to test IP-to-IP
interconnection in the context of these wire center trials; indeed, as AT&T noted in prior
comments on this issue, because interconnection arrangements in an all-IP world will not be
based around LATA (or even state) boundaries, much less even more limited wire center
boundaries, and also will not respect artificial distinctions between “local” and “long-distance”
services, and are highly unlikely to be limited to “voice,” running geographically limited trials of
IP-based interconnection makes little sense.116
6.4
CONSUMER PROTECTION
6.4.1. Customer Privacy.
AT&T will conduct all aspects of the trial consistent with the AT&T Privacy Policy,
which applies to our legacy TDM services, as well as IP-based services. In addition, AT&T will
continue to comply with applicable privacy laws and regulations, including those concerning
customer proprietary network information (CPNI). AT&T has established comprehensive
processes and procedures designed to ensure compliance with the Commission’s CPNI
regulations.117 Accordingly, pursuant to the Commission’s 2007 order extending the CPNI
regulations to interconnected VoIP providers, the AT&T business units that provide
interconnected VoIP services – AT&T Business, AT&T Home Solutions and AT&T Mobility –
apply these processes and procedures today to safeguard the CPNI of AT&T’s interconnected
VoIP customers.118 AT&T’s CPNI processes and procedures are described in AT&T’s annual
CPNI compliance certifications filed with the Commission pursuant to 47 C.F.R. § 64.2009, and
113
47 C.F.R. § 51.915(d).
114
See USF/ICC Transformation Order at paras. 1335-98 (seeking comment on IP-to-IP interconnection issues).
115
Technology Transition Trials Order at ¶ 64; see also id. at ¶ 8.
116
Technology Transitions Policy Task Force Seeks Comment on Potential Trials, GN Docket 13-5, Comments of
AT&T (July 8, 2013), at 20-27.
117
47 C.F.R. § 64.2001 et seq.
118
See Implementation of the Telecommunications Act of 1996: Telecommunications Carriers’ Use of Customer
Proprietary Network Information, 22 FCC Rcd. 6927, ¶¶ 54-59 (2007).
50
REDACTED -- FOR PUBLIC INSPECTION
will apply to all CPNI generated in connection with the interconnected VoIP services used in the
trial.119
6.4.2. Truth-in-Billing.
During the trial, AT&T will comply fully with the Commission’s truth-in-billing,
slamming and cramming requirements in its provision of next-generation wireless and IP-based
services regardless of the regulatory classification of those services. As discussed above, AT&T
will offer consumers its Wireless Home Phone service, VoIP, or both, in place of TDM-based
voice services during the trial. AT&T’s Wireless Home Phone service is a commercial mobile
radio service that is subject to (and complies with) the truth-in-billing rules, and that will not
change during and after the trials.120
Although AT&T’s VoIP services are properly classified as information services, and thus
not subject to the Commission’s truth-in-billing (or cramming) rules, AT&T’s bills for those
services would comply with the truth-in-billing requirements if they did apply. As the attached
samples of the bills AT&T renders for VoIP services demonstrate,121 those bills are clearly
organized, include a brief description of the services provided and the charges therefor, as well
as contact information about how to make inquiries about or contest the charges on the bill. In
addition, AT&T does not bill for other providers’ services or products on its bills for VoIP
service. Moreover, insofar as AT&T’s VoIP services are all-distance voice services that allow
unlimited domestic voice calls, AT&T’s bills have no need to, and do not distinguish, between
deniable and non-deniable charges. As a consequence, customers purchasing AT&T’s VoIP
services will continue to receive the protections of the truth-in-billing (and concomitantly the
Commission’s slamming and cramming) requirements throughout the trial.
AT&T also will comply fully with the Commission’s prohibition against unauthorized
service changes in its slamming rules in its provision of Wireless Home Phone or VoIP services.
In order to utilize either service, customers will require additional CPE to which they can attach
their existing telephone set. Specifically, Wireless Home Phone customers will need a Wireless
Home Phone device, which provides the transmitter/receiver necessary to connect to AT&T’s
radio access network (RAN). Likewise, VoIP customers will need a residential gateway, which
both receives and transmits voice packets in IP, and converts them to and from analog for
transmission to and from a customer’s voice handset. As a consequence, both services will
require customer cooperation and approval to switch from TDM to next generation voice
services, and thus unauthorized service changes simply are not possible.
119
See, e.g., AT&T Annual CPNI Compliance Certifications Calendar Year 2012, EB Docket No. 06-36, filed Mar.
1, 2013; AT&T Annual CPNI Compliance Certifications Calendar Year 2011, EB Docket No. 06-36, filed Mar. 1,
2012; AT&T Annual CPNI Compliance Certifications Calendar Year 2010, EB Docket No. 06-36, filed Mar. 1,
2011.
120
Attached hereto is a sample bill for AT&T’s Wireless Home Phone service. See Exhibit H.
121
See Exhibit H.
51
REDACTED -- FOR PUBLIC INSPECTION
6.4.3. Number Portability.
The Commission has directed that, for any experiments, its “number portability rules and
policies will continue to apply,”122 and asks whether “other providers’ customers could
potentially be affected by a proposed experiment” and whether “the ability of other providers’
customers to keep and port their numbers will not be jeopardized.”123 In the Trial Wire Centers,
AT&T will replace legacy TDM services with interconnected VoIP and CMRS services that
already are in the market. These services are subject to and fully comply with the Commission’s
number portability rules and policies. As a consequence, both AT&T’s customers and the
customers of competing providers will be able to port their numbers during the trial to the same
extent that they are able to port their numbers today.
6.4.4. Routing.
AT&T strongly supports the Commission’s efforts to ensure the reliable and efficient
operation of the nation’s telephone network and that will be no different under the trials.124
AT&T’s VoIP and Wireless Home Phone services are already operational and available in the
market. All call completion, routing and signaling will be handled under the trial as it is today
for these services. AT&T holds itself and its vendors to high standards for handling all traffic.
Our customers expect as much from AT&T. AT&T ensures proper, high-quality routing and
signaling through internal procedures, including rigorous oversight of vendors,125 and
compliance with industry best practices.126 Moreover, AT&T’s VoIP and Wireless Home Phone
services are subject to the Rural Call Completion Order127 and the signaling rules under the
USF/ICC Transformation Order.128 AT&T will continue to operate these services in the trial
consistent with the terms of these orders and rules.129 Together, the Commission’s rules,
122
Technology Transition Trials Order, ¶ 68.
123
Id., Appendix B, ¶ 42.
124
See Rural Call Completion, WC Docket 13-39, Comments of AT&T (May 13, 2013) (AT&T RCC Comments);
Rural Call Completion, WC Docket 13-39, Reply Comments of AT&T (June 11, 2013) (AT&T RCC Reply).
125
See AT&T RCC Comments at 3 (citing Presentation of Penn Pfautz, AT&T, FCC Rural Call Completion
Workshop (Oct. 18, 2011), available at http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-310507A1.pdf;
Statements of Kim Meola, AT&T & Penn Pfautz, AT&T, Rural Call Completion Workshop video, available at
http://www.fcc.gov/events/rural-callcompletion-workshop (describing AT&T’s practice of limiting by contract the
services provided by call termination suppliers to one additional intermediate provider)); AT&T RCC Reply at 2.
126
AT&T complies with and has been actively involved in development of best practices through ATIS. See
“Alliance for Telecommunications Industry Solutions, ATIS Standard on Intercarrier Call Completion/Call
Termination Handbook,” ATIS-0300106, available at <http://www.atis.org/docstore/product.aspx?id=26780> (rel.
Mar. 2013).
127
See generally Rural Call Completion, WC Docket No 13-39, Report and Order and Further Notice of Proposed
Rulemaking, 28 FCC Rcd 16154 (2013) (RCC Order).
128
See USF/ICC Transformation Order at paras. 702-35.
129
Both the RCC Order and the signaling portion of the USF/ICC Transformation Order provide for waivers of the
rules under certain circumstances. See RCC Order at paras. 95-97; USF/ICC Transformation Order at 723. AT&T
52
REDACTED -- FOR PUBLIC INSPECTION
AT&T’s company procedures, and industry best practices ensure that no systemic routing
problem exists, and when an isolated problem is identified, AT&T can quickly and effectively
resolve the issue. AT&T expects the trial to raise no key technical issues that would affect
routing or signaling but to the extent a routing or signaling concern surfaces, even if unrelated to
the trial, AT&T will work promptly and cooperatively toward a resolution.
6.5
DATA COLLECTION AND REPORTING
As part of the trials, AT&T will collect and report to the Commission a variety of data,
including data regarding the progress of the trial, customer complaints, network performance,
call quality, and issues relating to access by persons with disabilities. This section describes
these data below.
6.5.1. Quarterly Transition Progress Report
AT&T will track and report the number of customer migrations from TDM products to IP
products by wire center. The report will classify migrations by the replacement product category
(i.e., wireline or wireless) and market segment (i.e., consumer, business and wholesale).
6.5.2. Quarterly §214 Customer Notification Report
The Customer Notification Report provides a summary of Section 214 grandfather and
sunset customer notifications by AT&T to TDM trial customers. The report will summarize by
product the date of notification and the number of customers notified.
6.5.3. Quarterly Customer Issues Report
AT&T will provide a summary of trial-specific customer issues. Data will be collected
from: direct customer input to trial-specific web sites, calls to AT&T customer care centers and
issues identified by AT&T field representatives having customer contact. AT&T will classify
issues in a way that is reflective of the type of issues customers are describing, such as:
accessibility, product availability or product performance.
6.5.4. Quarterly Defects Per Million (DPM) Report
AT&T will track and report quarterly data concerning the performance of the wireline IPbased voice services, and the TDM voice services they replace. For each trial wire center,
AT&T will select a nearby wire center to serve as a “control group” to ensure that both the trial
and control wire centers are subject to similar weather conditions, traffic congestion, and other
has petitioned for a limited waiver of the signaling rules adopted in the USF/ICC Transformation Order. See
Connect America Fund, et al., WC Docket No. 10-90, et al., Petition for Limited Waiver of AT&T (Dec. 29, 2011).
In addition, AT&T expects to request a waiver of certain reporting requirements pursuant to the terms of the RCC
Order. See Letter to Marlene H. Dortch, Secretary, FCC from Brian Benison, Director, Federal Regulatory, WC
Docket No. 13-39 (filed Jan. 17, 2014) (providing notice of meeting with FCC staff to discuss a possible waiver
proposal).
53
REDACTED -- FOR PUBLIC INSPECTION
network-effecting events. AT&T will provide performance data for the two trial wire centers,
and the same data for the two control wire centers. In each case, AT&T will provide a metric
based on the number of blocked or dropped calls. A defect generally equates to a blocked or
dropped call. 130 By treating each blocked and/or dropped call as a “defect,” this report will
enable AT&T to provide a legitimate comparison of the performance of AT&T’s legacy TDM
voice services and its wireless and wireline IP-based replacement services. Although the report
format is still under development, the specific metrics AT&T plans to report are:
TDM DPM (Total blocked calls/total attempts) x 1M
•
Description: For TDM, the DPM metric includes defects attributable to regional and
long distance network events like equipment, engineering, transport, process or software.
A defect is defined as a blocked call.
VOIP DPM (Total blocked/dropped calls/total attempts) x 1M
•
Description: For VoIP (Both CVOIP and BVOIP), the DPM metric includes defects
attributable to AT&Ts VoIP elements, along with those resulting from transport, process
or software related defects within the AT&T network. A defect is defined as a blocked or
dropped call.
Wireless Network Performance
•
Description: Measurement of Accessibility and Retainability, which defines the
customer’s ability to make and retain a call on the wireless network. Accessibility =
percent of attempted calls that are successfully established and allow voice
communication to begin while retainability = percent of voice calls that are successfully
carried for the duration of the conversation.
6.5.5. Access by Persons with Disabilities
Due to the wide range of potential accessibility needs that AT&T may encounter in the
trial wire centers, we believe that qualitative data concerning issues or problems involving
persons with disabilities will be more instructive than quantitative data. Accordingly, AT&T
will: (1) separately track and report on a quarterly basis complaints to AT&T’s Office of the
President from the trial wire centers where a customer self-identifies him- or herself as having a
disability, or the customer’s issue relates to assistive technology; and (2) ask disability
organizations that are assisting AT&T with the trial to record and report to AT&T any feedback
that they receive in connection with their outreach to persons with disabilities.
130
Wireless performance measures utilizes a slightly different variation based on percent of attempted calls that are
successfully established and allow voice communication to begin and percent of voice calls that are successfully
carried for the duration of the conversation.
54
REDACTED -- FOR PUBLIC INSPECTION
6.5.6. Quarterly IP Network Outage Report
AT&T also will submit in the record of this proceeding a quarterly report summarizing
network outages that affected voice services in a trial wire center area that were reported to the
FCC via NORS, pursuant 47CFR Part 4.
6.5.7.
Voice Quality Metric
AT&T has compared the voice quality of its legacy TDM voice services with the quality
of its VoIP and Wireless Home Phone services by conducting a Mean Opinion Score (MOS) test
for each service. MOS provides a numerical measure of the quality of human speech at the
destination end of a circuit. MOS has been used for decades in telephone networks to provide
the human user's view of the quality of the service. MOS tests for voice are specified by ITU-T
recommendation P.800. The U-verse Voice and Wireless Home Phone sections of the report
represent the experimental result and the PSTN section of the report represents the control
result.
Section 7:
Exhibits
55
Exhibit A
Exhibit A
Wire Center Maps
Carbon Hill, AL SWC Area Coverage Map
Kings Point, FL SWC Area Coverage Map
Exhibit B
Exhibit B
Topographical Maps
Walker County, location of the Carbon Hill Wire Center1
WalkerCounty
CarbonHill
WireCenter
WalkerCounty
CarbonHill
WireCenter
1
See Geology.com, Alabama Map Collection, available at http://geology.com/state-map/alabama.shtml (visited Feb.
24, 2014).
Palm Beach County, location of the Kings Point Wire Center2
PalmBeachCounty
KingsPoint
WireCenter
PalmBeachCounty
KingsPoint
WireCenter
2
See Geology.com, Florida Map Collection, available at http://geology.com/state-map/florida.shtml (visited Feb. 24,
2014).
Exhibit C
Exhibit C
Competitive Maps
Exhibit C
Competitive Maps
Exhibit C
Competitive Maps
Exhibit C
Competitive Maps
Exhibit C
Competitive Maps
Exhibit C
Competitive Maps
Exhibit D
REDACTED
FOR PUBLIC
INSPECTION
EXHIBIT D -- PUBLIC VERSION -- PROPOSED TRANSISTION TIMELINE
AT&T’sProposedServiceTransitionTimeline
ConsumerTimeline
SunsetCustomer
GrandfatherCustomer
Proposed
Notice&PhaseII214
Notice&PhaseI214
Sunset
FilingforInterstate
ProposedEffective FilingforInterstate EffectiveDateto Complete
BellSouthConsumerTDMͲ
(0customers)
Sunset
Services
Services
DatetoGrandfather
basedServices
TDMͲVoiceSvcs:
FlatLineSvc
MeasuredRate
VoicePackages
LocalIntralatatoll
EUCL
LongDistancePlans:
DomesticUnlimitedPlan
DomesticBlockoftime
Int'lPerMinute
Int'lVoicePlans
ConsumerInternetAccess:
DSLDirect
DSLLineshare
SeetheProductDatasheetsforthedetailsassociatedwitheachproductcategory
BusinessTimeline
BellSouthBusinessTDMͲ
basedServices
SunsetCustomer
GrandfatherCustomer
Proposed
Notice&PhaseII214
Notice&PhaseI214
Sunset
FilingforInterstate
ProposedEffective FilingforInterstate EffectiveDateto Complete
(0customers)
Sunset
Services
Services
DatetoGrandfather
FlatLine;MeasuredLine
FlatTrunks;PBXTrunks
ISDNBRI/PRI
Centrex
BusinessDSL
AnalogPLͲVoiceGrade
Services(DS0)
DSͲ1Services
DSͲ3Services
SwitchedAccess:FGͲA,FGͲ
B,FGͲD
fg
SMARTRing
GrandfatheringBeyond2016
SeetheProductDataSheetsforthedetailsassociatedwitheachproductcategory
Exhibit E
REDACTED
FOR PUBLIC
INSPECTION
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill, Consumer Market Product
Data Sheets
PUBLIC VERSION
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: Flat Rate Main Station Line Service, Individual Line, Residence (Active)
Wire Center
CRHLALNM
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Alabama (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Regulatory Jurisdiction
Intrastate
Dominant
Product Data Sheet #
CH1
Guidebook Reference
AL Gen Exchange GB: A3.2.1
USOC 1FR, 1FRCL
Product Retirement
Service to be Discontinued
Flat Rate Main Station Line Service, individual line, Residence
Service Description
A classification of exchange access line service for which a stipulated charge is made, regardless of the amount of
use.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/al/g003.pdf
Next Generation Product Offer
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice 200 BOT with Internet
Speed Range: 3MB- 100MB Rack Rate
Price Range: $41.00 to $111.00
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20 advanced voice
features. $.05 per minute after 200 minutes includes Canada. 200 minutes include unlimited
local calling and 200 long distance minutes. Requires the purchase of IP Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice Unlimited with Internet
Speed Range: 3MB to 100MB Rack Rate
Price Range: $51.00 to $121.00
CATCH PRODUCT
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over 20
advanced voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and low rates
to International countries with over 20 advanced voice features. Requires the purchase of IP
Broadband.
AT&T U-verse International with Internet
Speed Range: 3MB to 100MB Rack Rate
Price Range: $56.00 to $126.00
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID, Three Way
Calling, Call Forwarding and Voicemail.
Demand Count
Number of Customers
Number of customers Without
An AT&T Catch Product
Number of Customer Locations
Number of Customers with a
Competitive Catch Product in
their Service Area
Number of Services
Number of Customers Without
AT&T or Competitive Catch
Product
Number of Customers with an
AT&T Catch Product Available
in their Service Area
Under Assessment, may have
AT&T or Competitive Catch
Product
Competitive Presence
COMPETITOR
CHARTER COMMUNICATIONS
WEST ALABAMA TV CABLE
HUGHESNET
DISH NETWORK
DIRECTV
Sprint
Verizon Wireless
T-Mobile USA
TECHNOLOGY
Cable C DOWN : 100 Mbps - C UP : 4 Mbps
Cable C DOWN : UNKNOWN - C UP : UNKNOWN
SATELLITE
SATELLITE
SATELLITE
WIRELESS 3G
WIRELESS LTE
WIRELESS 3G
Percent Covered
88.00 %
2.23 %
90.23 %
90.23 %
90.23 %
54.23 %
46.23 %
82.67 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: Area Plus Service, Individual line service, Residence (Active)
Wire Center
Legal Name of Service
Provider
d/b/a Name of Service
Provider
Product Data Sheet #
CRHLALNM
BellSouth Telecommunications,
LLC
AT&T Alabama (BellSouth
Telecommunications, LLC)
CH2
Regulatory Jurisdiction
Type of Regulation
FRN
Guidebook Reference
Intrastate
Dominant
1857952
ALGenExchgGBA3.2.11USOC AC1,
AC1CL,VR5,VR5CL,VRS,VR6CL,
ACML2,ACML3
Product Retirement
Service to be Discontinued
Area Plus Service, Individual line service, Residence
Service Description
Area Plus service provides residence subscribers a flat rate access line with unlimited calling to all access lines within the serving exchange,
the additional exchanges in the associated Extended Area Service (EAS) and Extended Calling.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
06/01/2016
http://cpr.web.att.com/pdf/al/g003.pdf
Next Generation Product Offer
CATCH PRODUCT
AT&T U-Verse Voice 200 BOT with
Internet Speed Range: 3MB- 100MB;
Rack Rate Price Range: $41.00 to
$111.00
CATCH PRODUCT
AT&T U-Verse Voice Unlimited with
Internet Speed Range: 3MB to 100MB;
Rack Rate Price Range: $51.00 to
$121.00
CATCH PRODUCT
AT&T U-verse International with
Internet Speed Range: 3MB to 100MB;
Rack Rate Price Range: $56.00 to
$126.00
CATCH PRODUCT
AT&T Wireless Home Phone/
$19.99 per month/$9.99 when
added with Family Talk
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20 advanced voice
features. $.05 per minute after 200 minutes includes Canada. 200 minutes include unlimited
local calling and 200 long distance minutes. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over 20
advanced voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and low rates to
International countries with over 20 advanced voice features. Requires the purchase of IP
Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller
ID, Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T
Catch Product
Number of Customer Locations
Number of Customers with a Competitive
Catch Product in their Service Area
Number of Services
Number of Customers Without AT&T or
Competitive Catch Product
Number of Customers with an AT&T
Catch Product Available in their
Service Area
Under Assessment, may have AT&T or
Competitive Catch Product
Competitive Presence
COMPETITOR
CHARTER COMMUNICATIONS
HUGHESNET
DISH NETWORK
DIRECTV
Sprint
Verizon Wireless
T-Mobile USA
TECHNOLOGY
Cable C DOWN : 100 Mbps - C UP : 4 Mbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS 3G
WIRELESS LTE
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
62.50 %
87.50 %
100.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: Area Calling Service, Access Line, Residence (Grandfathered)
Wire Center
CRHLALNM
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Alabama (BellSouth
Telecommunications, LLC)
Type of Regulation
Dominant
FRN
1857952
Regulatory Jurisdiction
Intrastate
Product Data Sheet #
CH3
Guidebook Reference
AL Gen Exch. GB A103.2.9
USOC: ACP, ACPCL, ASR,
ASRCL
Product Retirement
Service to be Discontinued
Area Calling Service, Access Line, Residence
Service Description
A classification of exchange service which includes an individual line and a usage package. In addition, usage charges apply for
outward completed local calling and are based on number of calls, duration, time of day/day.
Customer Notice: Product
Grandfather
GRANDFATHER
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Disallow Adds, Moves, Changes
Guidebook Link
http://cpr.web.att.com/pdf/al/g103.pdf
CATCH PRODUCT
AT&T U-Verse Voice 200 BOT with
Internet Speed Range: 3MB- 100MB;
Rack Rate Price Range: $41.00 to
$111.00
CATCH PRODUCT
AT&T U-Verse Voice Unlimited with
Internet Speed Range: 3MB to 100MB;
Rack Rate Price Range: $51.00 to
$121.00
CATCH PRODUCT
AT&T U-verse International with Internet
Speed Range: 3MB to 100MB; Rack
Rate Price Range: $56.00 to $126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family
Talk
Next Generation Product Offer
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20 advanced voice
features. $.05 per minute after 200 minutes includes Canada. 200 minutes include unlimited
local calling and 200 long distance minutes. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over 20
advanced voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and low rates to
International countries with over 20 advanced voice features. Requires the purchase of IP
Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID, Three Way
Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T
Catch Product
Number of Customer Locations
Number of Customers with a
Competitive Catch Product in their
Service Area
Number of Services
Number of Customers Without AT&T
or Competitive Catch Product
Number of Customers with an AT&T
Catch Product Available in their Service
Area
Under Assessment, may have AT&T or
Competitive Catch Product
Competitive Presence
COMPETITOR
CHARTER COMMUNICATIONS
WEST ALABAMA TV CABLE
HUGHESNET
DISH NETWORK
DIRECTV
Sprint
Verizon Wireless
T-Mobile USA
TECHNOLOGY
Cable C DOWN : 100 Mbps - C UP : 4 Mbps
Cable C DOWN : UNKNOWN - C UP : UNKNOWN
SATELLITE
SATELLITE
SATELLITE
WIRELESS 3G
WIRELESS LTE
WIRELESS 3G
Percent Covered
95.00 %
5.00 %
100.00 %
100.00 %
100.00 %
65.00 %
45.00 %
90.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: Complete Choice Basic Service (Active)
Wire Center
Legal Name of Service
Provider
d/b/a Name of Service
Provider
Product Data Sheet #
CRHLALNM
BellSouth Telecommunications,
LLC
AT&T Alabama (BellSouth
Telecommunications, LLC)
CH5
Regulatory Jurisdiction
Type of Regulation
Intrastate
Dominant
FRN
Guidebook Reference
1857952
AL Gen Exchg A3.2.15 USOC:
PAMA7
Product Retirement
Service to be Discontinued
Complete Choice Basic Service
Service Description
Complete Choice Basic service provides a flat rate access line and unlimited calling to all exchange access lines within the
subscriber’s local calling area. Subscribers have unlimited use of 2 calling features: Call Waiting ID and Caller ID.
Customer Notice: Product
Grandfather
GRANDFATHER
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Disallow Adds, Moves, Changes
Guidebook Link
http://cpr.web.att.com/pdf/al/g003.pdf
Next Generation Product Offer
CATCH PRODUCT
AT&T U-Verse Voice 200 BOT with
Internet Speed Range: 3MB- 100MB
Rack Rate Price Range: $41.00 to
$111.00
CATCH PRODUCT
AT&T U-Verse Voice Unlimited with
Internet Speed Range: 3MB to
100MB; Rack Rate Price Range:
$51.00 to $121.00
CATCH PRODUCT
AT&T U-verse International with
Internet Speed Range: 3MB to
100MB; Rack Rate Price Range:
$56.00 to $126.00
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20
advanced voice features. $.05 per minute after 200 minutes includes Canada.
200 minutes include unlimited local calling and 200 long distance
minutes. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with
over 20 advanced voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada
and low rates to International countries with over 20 advanced voice features.
Requires the purchase of IP Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T Wireless Home Phone/ $19.99
per month/$9.99 when added with
Family Talk
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID,
Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An
AT&T Catch Product
Number of Customer Locations
Number of Customers with a
Competitive Catch Product in their
Service Area
Number of Services
Number of Customers Without AT&T
or Competitive Catch Product
Number of Customers with an AT&T
Catch Product Available in their Service
Area
Under Assessment, may have AT&T
or Competitive Catch Product
Competitive Presence
COMPETITIOR
CHARTER COMMUNICATIONS
WEST ALABAMA TV CABLE
HUGHESNET
DISH NETWORK
DIRECTV
Sprint
Verizon Wireless
TECHNOLOGY
Cable C DOWN : 100 Mbps - C UP : 4 Mbps
Cable C DOWN : UNKNOWN - C UP : UNKNOWN
SATELLITE
SATELLITE
SATELLITE
WIRELESS 3G
WIRELESS LTE
Percent Covered
98.21 %
0.89 %
99.10 %
99.10 %
99.10 %
54.46 %
69.64 %
T-Mobile USA
WIRELESS 3G
95.54 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: 2 Pack Plan (Grandfathered)
Wire Center
CRHLALNM
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Alabama (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Regulatory Jurisdiction
Intrastate
Dominant
Product Data Sheet #
CH6
Guidebook Reference
AL Gen Exchng GB: A103.2.13
USOC PAMA6
Product Retirement
Service to be Discontinued
2 Pack Plan
Service Description
The 2 Pack Plan provides a flat rate access line with Touch-Tone capability and unlimited calling to all exchange
access lines within the subscriber’s local calling area. The plan also entitles a residence subscriber to unlimited use
of 5 features and services Subscribers have unlimited use of 6 the features/services.
Customer Notice: Product
Grandfather
GRANDFATHER
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Disallow Adds, Moves, Changes
Guidebook Link
http://cpr.web.att.com/pdf/al/g103.pdf
Next Generation Product Offer
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20 advanced
AT&T U-Verse Voice 200 BOT with Internet
voice features. $.05 per minute after 200 minutes includes Canada. 200 minutes include
Speed Range: 3MB- 100MB Rack Rate Price
unlimited local calling and 200 long distance minutes. Requires the purchase of IP
Range: $41.00 to $111.00
Broadband.
CATCH PRODUCT
AT&T U-Verse Voice Unlimited with Internet
Speed Range: 3MB to 100MB; Rack Rate
Price Range: $51.00 to $121.00
CATCH PRODUCT
AT&T U-verse International with Internet
Speed Range: 3MB to 100MB; Rack Rate
Price Range: $56.00 to $126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over 20
advanced voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and low rates
to International countries with over 20 advanced voice features. Requires the purchase of
IP Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID, Three
Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T
Catch Product
Number of Customer Locations
Number of Customers with a Competitive
Catch Product in their Service Area
Number of Services
Number of Customers Without AT&T or
Competitive Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or
Competitive Catch Product
Competitive Presence
COMPETITIOR
CHARTER COMMUNICATIONS
HUGHESNET
DISH NETWORK
DIRECTV
Sprint
Verizon Wireless
T-Mobile USA
TECHNOLOGY
Cable C DOWN : 100 Mbps - C UP : 4 Mbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS 3G
WIRELESS LTE
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
60.00 %
40.00 %
80.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: Long Distance Message Telecommunications Service (Active)
Wire Center
CRHLALNM
Regulatory Jurisdiction
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Alabama (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
Intrastate
Dominant
Product Data Sheet #
CH7
Guidebook Reference
AL Gen Exchg GB:A18.3.1
USOC: PAMA1, PAMA2
1857952
Product Retirement
Service to be Discontinued
Long Distance Message Telecommunications Service
Service Description
(IntraLATA Local Toll) Long Distance Message Telecommunications Service provides facilities for communications
between stations in different rate centers for either two-point or conference service. Rates for service between
points are based on airline mileage between rate centers. In general, each point is designated as a rate center
except that certain small towns or communities are assigned adjacent rate centers with which they are closely
associated for communication purposes or by community of interest.
Customer Notice: Product
Grandfather
GRANDFATHER
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Disallow Adds, Moves, Changes
Guidebook Link
http://cpr.web.att.com/pdf/al/g018.pdf
Next Generation Product Offer
CATCH PRODUCT
AT&T U-Verse Voice 200 BOT with
Internet Speed Range: 3MB- 100MB
Rack Rate Price Range: $41.00 to
$111.00
CATCH PRODUCT
AT&T U-Verse Voice Unlimited with
Internet Speed Range: 3MB to
100MB; Rack Rate Price Range:
$51.00 to $121.00
CATCH PRODUCT
AT&T U-verse International with
Internet Speed Range: 3MB to
100MB; Rack Rate Price Range:
$56.00 to $126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99
per month/$9.99 when added with
Family Talk
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20
advanced voice features. $.05 per minute after 200 minutes includes
Canada. 200 minutes include unlimited local calling and 200 long distance
minutes. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada
with over 20 advanced voice features. Requires the purchase of IP
Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and
Canada and low rates to International countries with over 20 advanced voice
features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with
Caller ID, Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T
Catch Product
Number of Customer Locations
Number of Customers with a Competitive
Catch Product in their Service Area
Number of Services
Number of Customers Without AT&T or
Competitive Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or
Competitive Catch Product
Competitive Presence
COMPETITOR
No Records Found.
TECHNOLOGY
Percent Covered
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: PreferredPack Plan (Grandfathered)
Wire Center
CRHLALNM
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Alabama (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Regulatory Jurisdiction
Intrastate
Dominant
Product Data Sheet #
CH8
Guidebook Reference
AL Gen Exchg GB: A103.2.12
USOC: PAMA5
Product Retirement
Service to be Discontinued
PreferredPack Plan
Service Description
The Preferred Pack plan provides a flat rate access line with Touch-Tone capability and entitles a residence
subscriber to unlimited calling to all exchange access lines within the subscriber’s local calling area 3. The plan
also entitles a residence subscriber to unlimited use of 9 features/services.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Moves, Add, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/al/g103.pdf
Next Generation Product Offer
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20 advanced
AT&T U-Verse Voice 200 BOT with Internet
voice features. $.05 per minute after 200 minutes includes Canada. 200 minutes include
Speed Range: 3MB- 100MB Rack Rate Price
unlimited local calling and 200 long distance minutes. Requires the purchase of IP
Range: $41.00 to $111.00
Broadband.
CATCH PRODUCT
AT&T U-Verse Voice Unlimited with Internet
Speed Range: 3MB to 100MB; Rack Rate
Price Range: $51.00 to $121.00
CATCH PRODUCT
AT&T U-verse International with Internet
Speed Range: 3MB to 100MB; Rack Rate
Price Range: $56.00 to $126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over 20
advanced voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and low rates
to International countries with over 20 advanced voice features. Requires the purchase of
IP Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID, Three
Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T
Catch Product
Number of Customer Locations
Number of Customers with a
Competitive Catch Product in their
Service Area
Number of Services
Number of Customers Without AT&T or
Competitive Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or
Competitive Catch Product
Competitive Presence
COMPETITIOR
CHARTER COMMUNICATIONS
HUGHESNET
DISH NETWORK
DIRECTV
Sprint
Verizon Wireless
T-Mobile USA
TECHNOLOGY
Cable C DOWN : 100 Mbps - C UP : 4 Mbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS 3G
WIRELESS LTE
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
33.33 %
33.33 %
100.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: Custom Rate Plan (Active)
Wire Center
CRHLALNM
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Alabama (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Regulatory Jurisdiction
Intrastate
Dominant
Product Data Sheet #
CH9
Guidebook Reference
AL Gen Exchg GB: A20.3.9
USOC OSR2O
Product Retirement
Service to be Discontinued
Custom Rate Plan
Service Description
Custom Rate Plan is an Optional Calling Plan offered to residential customers and is applicable to intrastate
intraLATA long distance calls originated and terminated in the customer's home state. Eligible calls include those
dialed on a Station-to-Station basis (as either Dial, Dial Calling Card, or Operator) or on a Person-to-Person basis.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Moves, Add, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/al/g020.pdf
Next Generation Product Offer
CATCH PRODUCT
AT&T U-Verse Voice 200 BOT with Internet
Speed Range: 3MB- 100MB Rack Rate Price
Range: $41.00 to $111.00
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over
20 advanced voice features. $.05 per minute after 200 minutes includes
Canada. 200 minutes include unlimited local calling and 200 long distance
minutes. Requires the purchase of IP Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice Unlimited with Internet
Speed Range: 3MB to 100MB Rack Rate Price
Range: $51.00 to $121.00
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over 20
advanced voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and low
AT&T U-verse International with Internet Speed rates to International countries with over 20 advanced voice features. Requires the
Range: 3MB to 100MB Rack Rate Price Range: purchase of IP Broadband.
$56.00 to $126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID, Three
Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T
Catch Product
Number of Customer Locations
Number of Customers with a Competitive
Catch Product in their Service Area
Number of Services
Number of Customers Without AT&T or
Competitive Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or
Competitive Catch Product
Competitive Presence
COMPETITIOR
CHARTER COMMUNICATIONS
HUGHESNET
DISH NETWORK
DIRECTV
Verizon Wireless
T-Mobile USA
TECHNOLOGY
Cable C DOWN : 100 Mbps - C UP : 4 Mbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: Easy Calling Plans, Plan No.1 (Active)
Wire Center
CRHLALNM
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Alabama (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Regulatory Jurisdiction
Intrastate
Dominant
Product Data Sheet #
CH10
Guidebook Reference
AL Gen Exchg. GB: A20.4, USOC
OC91O
Product Retirement
Service to be Discontinued
Easy Calling Plans, Plan No.1
Service Description
An optional intrastate intraLATA toll calling plan that allows all direct dialed sent paid (non-operator assisted)
intrastate calls that originate and terminate in the customer's home Calling Zone/LATA to be rated at $.10 per
minute.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Moves, Add, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/al/g020.pdf
Next Generation Product Offer
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice 200 BOT with Internet
Speed Range: 3MB- 100MB Rack Rate Price
Range: $41.00 to $111.00
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20 advanced
voice features. $.05 per minute after 200 minutes includes Canada. 200 minutes include
unlimited local calling and 200 long distance minutes. Requires the purchase of IP
Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice Unlimited with Internet
Speed Range: 3MB to 100MB Rack Rate Price
Range: $51.00 to $121.00
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over 20
advanced voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and low
AT&T U-verse International with Internet Speed rates to International countries with over 20 advanced voice features. Requires the
Range: 3MB to 100MB Rack Rate Price Range: purchase of IP Broadband.
$56.00 to $126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID, Three
Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch
Product
Number of Customer Locations
Number of Customers with a Competitive
Catch Product in their Service Area
Number of Services
Number of Customers Without AT&T or
Competitive Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or
Competitive Catch Product
Competitive Presence
COMPETITOR
CHARTER COMMUNICATIONS
HUGHESNET
DISH NETWORK
DIRECTV
Sprint
Verizon Wireless
T-Mobile USA
TECHNOLOGY
Cable C DOWN : 100 Mbps - C UP : 4 Mbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS 3G
WIRELESS LTE
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
33.34 %
83.34 %
83.34 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: Integrated Services Digital Network (ISDN),Residence Srvc (IRS) (Active)
Wire Center
CRHLALNM
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Florida (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
Guidebook Reference
1857952
AL Gen Exchng GB A42.2
USOC: LQAFX,LQGFX
Regulatory Jurisdiction
Intrastate
Dominant
Product Data Sheet #
CH11
Product Retirement
Service to be Discontinued
Integrated Services Digital Network (ISDN), Residence Service (IRS)
Service Description
Residence Service (IRS) supports simultaneous transmission of voice, data, and packet services on the same
exchange access line. Calling/Called Number Delivery, Calling Name Delivery, and Call Hold are included with this
service. IRS provides a method of access to the telephone network called Basic Rate Access. Basic Rate Access
consists of the ability to access up to two 64 Kbps (B) channels and one 16 Kbps (D) channel at the service
delivery point. IRS is provided through Basic Rate Access. Features are available to increase the capability of the
Bearer Alternative Service and may be subscribed to on an as-needed basis. B channel circuit switched services
offer up to 64 Kbps intra-office transmission of voice or data. This option permits the customer to utilize either
circuit voice or data transmission paths on a per call selection basis. Transmission on the B channel will be circuit
switched at 64 Kbps within the switch and/or equipped facilities between ISDN compatible central offices.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Moves, Add, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/fl/g042.p
df
Next Generation Product Offer
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice 200 BOT with Internet
Speed Range: 3MB- 100MB Rack Rate Price
Range: $41.00 to $111.00
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20 advanced
voice features. $.05 per minute after 200 minutes includes Canada. 200 minutes include
unlimited local calling and 200 long distance minutes. Requires the purchase of IP
Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice Unlimited with Internet
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over 20
Speed Range: 3MB to 100MB Rack Rate Price
advanced voice features. Requires the purchase of IP Broadband.
Range: $51.00 to $121.00
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and low
AT&T U-verse International with Internet
rates to International countries with over 20 advanced voice features. Requires the
Speed Range: 3MB to 100MB Rack Rate Price purchase of IP Broadband.
Range: $56.00 to $126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID, Three
Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch Product
Number of Customer Locations
Number of Customers with a Competitive Catch
Product in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or Competitive
Catch Product
Competitive Presence
COMPETITOR
No Records Found.
TECHNOLOGY
Percent Covered
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: Complete Choice Service (Grandfathered)
Wire Center
Legal Name of Service
Provider
CRHLALNM
BellSouth Telecommunications, LLC
Regulatory Jurisdiction
Type of Regulation
Intrastate
d/b/a Name of Service
Provider
Product Data Sheet #
AT&T Alabama (BellSouth
CH12
Telecommunications, LLC)
Dominant
FRN
Guidebook Reference
1857952
AL Gen Exchange GB A103.2.10 USOC Vr3, VSB,
CCML2, CCML3
Product Retirement
Service to be Discontinued
Complete Choice Service
Service Description
Complete Choice service provides a flat rate access line with Touch-Tone capability and unlimited calling to all exchange access lines in
the subscriber's local calling area. It also entitles a residence subscriber to unlimited use of 32 services/features. Residence customers
may subscribe to the Two-Line Plan or the Three-Line Plan for Complete Choice service. All lines in each multi-line package must be
billed to the same account and located at the same premises.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Moves, Add, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/al/g103.pdf
Next Generation Product Offer
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20 advanced
AT&T U-Verse Voice 200 BOT with Internet
voice features. $.05 per minute after 200 minutes includes Canada. 200 minutes include
Speed Range: 3MB- 100MB Rack Rate Price
unlimited local calling and 200 long distance minutes. Requires the purchase of IP
Range: $41.00 to $111.00
Broadband.
CATCH PRODUCT
AT&T U-Verse Voice Unlimited with Internet
Speed Range: 3MB to 100MB; Rack Rate
Price Range: $51.00 to $121.00
CATCH PRODUCT
AT&T U-verse International with Internet
Speed Range: 3MB to 100MB; Rack Rate
Price Range: $56.00 to $126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over 20
advanced voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and low rates
to International countries with over 20 advanced voice features. Requires the purchase of
IP Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID, Three
Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch Product
Number of Customer Locations
Number of Customers with a Competitive Catch
Product in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T
Catch Product Available in their Service
Area
Under Assessment, may have AT&T or Competitive
Catch Product
Competitive Presence
COMPETITOR
CHARTER COMMUNICATIONS
HUGHESNET
DISH NETWORK
DIRECTV
Sprint
Verizon Wireless
T-Mobile USA
TECHNOLOGY
Cable C DOWN : 100 Mbps - C UP : 4 Mbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS 3G
WIRELESS LTE
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
66.67 %
69.05 %
97.62 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: Foreign Exchange Service (Active)
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Alabama (BellSouth
Telecommunications, LLC)
Regulatory Jurisdiction
Type of Regulation
Intrastate
Dominant
FRN
1857952
Wire Center
CRHLALNM
Product Data Sheet #
CH13
Guidebook Reference
AL Gen Exchg GB A9.1.3
USOC 1LH++,FRT++
Product Retirement
Service to be Discontinued
Foreign Exchange Service
Service Description
A classification of exchange service furnished to a subscriber from an exchange other than the one from which
they would normally be served
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Moves, Add, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/al/g
009.pdf
Next Generation Product Offer
CATCH PRODUCT
n/a
CATCH PRODUCT DESCRIPTION
n/a
Demand Count
Number of Customers
Number of customers Without An AT&T Catch Product
Number of Customer Locations
Number of Customers with a Competitive Catch Product
in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or Competitive
Catch Product
Competitive Presence
COMPETITOR
No Records Found.
TECHNOLOGY
Percent Covered
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: Foreign Central Office Service (Active)
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Alabama (BellSouth
Telecommunications, LLC)
Regulatory Jurisdiction
Type of Regulation
Intrastate
Dominant
FRN
1857952
Wire Center
CRHLALNM
Product Data Sheet #
CH 14
Guidebook Reference
AL Gen Exchg GB: A9.2.2
USOC 1LX++
Product Retirement
Service to be Discontinued
Foreign Central Office Service
Service Description
Foreign Central Office Service is exchange service furnished to a subscriber in a multi-office exchange from a
central office
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Moves, Add, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/al/g009.pdf
Next Generation Product Offer
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
Demand Count
Number of Customers
Number of customers Without An AT&T Catch Product
Number of Customer Locations
Number of Customers with a Competitive Catch Product in
their Service Area
Number of Services
Number of Customers Without AT&T or Competitive Catch
Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or Competitive Catch
Product
Competitive Presence
COMPETITOR
No Records Found.
TECHNOLOGY
Percent Covered
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
CarbonHillConsumer:DSLDirect
Wire Center
Legal Name of Service
Provider
d/b/a Name of Service
Provider
Product Data Sheet #
CRHLALNM
BellSouth Telecommunications,
LLC
AT&T Florida (BellSouth
Telecommunications, LLC)
CH15
Type of Regulation
n/a
FRN
n/a
Regulatory Jurisdiction
n/a
Tariff Reference (Tariff
N/A
Product Retirement
DSL Direct (Elite, Pro, Express and Basic)
Service Description
DSL WITHOUT home phone service: DSL Direct Elite up to 6.0 Mbps downstream and up to 768 Kbps Upstream;
DSL Direct Pro up to 3.0 Mbps Downstream and up to 512 Kbps Upstream;DSL Direct Basic up to 768 Kpbs
Downstream and up to 384 Kpbs Upstream.
Customer Notice: Product
Grandfather
GRANDFATHER
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Disallow Adds, Moves, Changes
CATCH PRODUCT NAME
AT&T U-Verse HSIA.
Speed Range: 3MB to
100MB Rack Rate Price
Range: $41.00 to
$110.00
Next Generation Product Offer
CATCH PRODUCT DESCRIPTION
High Speed Internet providing streaming video, large downloads, gaming with
speeds available up to 24Mbps and access to national AT&T Wi-Fi Hot Spot network
included. Requires the purchase of IP Broadband
Demand Count
Number of Customers
Number of Services Without An AT&T Catch Product
Number of Customer Locations
Number of Services with a Competitive Catch Produc
in their Service Area
Number of Services
Number of Services Without AT&T or Competitive
Catch Product
Number of Services with an AT&T Catch
Product Available in their Service Area
Competitive Presence
COMPETITOR
CHARTER COMMUNICATIONS
HUGHESNET
DISH NETWORK
DIRECTV
SPRINT
VERIZON WIRELESS
T-Mobile USA
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
Cable C DOWN : UNKNOWN - C UP : UNKNOWN
SATELLITE
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
Percent Covered
100%
90.00 %
75.00 %
100%
100%
100%
100%
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
CarbonHillConsumer:DSLLineShare
Wire Center
Legal Name of Service
Provider
d/b/a Name of Service
Provider
Product Data Sheet #
CRHLALNM
BellSouth Telecommunications,
LLC
AT&T Florida (BellSouth
Telecommunications, LLC)
CH16
Regulatory Jurisdiction
n/a
Type of Regulation
n/a
FRN
Tariff Reference (Tariff
N/A
n/a
Product Retirement
DSL Line Share
Service Description
DSL WITH home phone service: DSL Direct Elite up to 6.0 Mbps downstream and up to 768 Kbps Upstream; DSL
Direct Pro up to 3.0 Mbps Downstream and up to 512 Kbps Upstream; DSL Direct Basic up to 768 Kpbs Downstream
and up to 384 Kpbs Upstream.
Customer Notice: Product
Grandfather
GRANDFATHER
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Disallow Adds, Moves, Changes
CATCH PRODUCT NAME
AT&TU-Verse HSIA.
Speed Range: 3MB to
100MB Rack Rate Price
Range: $41.00 to
$110.00
Next Generation Product Offer
CATCH PRODUCT DESCRIPTION
High Speed Internet providing streaming video, large downloads, gaming with
speeds available up to 24Mbps and access to national AT&T Wi-Fi Hot Spot network
included. Requires the purchase of IP Broadband.
Demand Count
Number of Customers
Number of Services Without An AT&T Catch Product
Number of Customer Locations
Number of Services with a Competitive Catch Produc
in their Service Area
Number of Services
Number of Services Without AT&T or Competitive
Catch Product
Number of Services with an AT&T Catch
Product Available in their Service Area
Competitive Presence
COMPETITOR
CHARTER COMMUNICATIONS
HUGHESNET
DISH NETWORK
DIRECTV
SPRINT
VERIZON WIRELESS
T-Mobile USA
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
Cable C DOWN : UNKNOWN - C UP : UNKNOWN
SATELLITE
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
Percent Covered
100%
90.00 %
75.00 %
100%
100%
100%
100%
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: EndUserAccessService(Active)
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
Wire Center
CRHLALNM
Regulatory
Jurisdiction
Type of Regulation
Interstate
Dominant
d/b/a Name of Service
Provider
AT&T Alabama (BellSouth
Telecommunications, LLC)
FRN
Product Data Sheet #
CH17
Tariff Reference
1857952
FCC Tariff #1 Access Services. USOC(s): 9LM 9ZR,
Product Retirement
End User Access Service
Service Description
End User Access service provides for the use of an End User Common Line by an end user. AT&T provides End
User Access service to end users who obtain local exchange service from its general interstate or local exchange
tariffs.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Tariff Link
http://cpr.att.com/pdf/fcc/1004.pdf
CATCH PRODUCT
N/A
Number of Customers
Next Generation Product Offer
CATCH PRODUCT DESCRIPTION
Demand Count
Number of Services Without
An AT&T Catch Product
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill Consumer: Complete Choice Enhanced (Active)
Wire Center
Legal Name of Service
Provider
d/b/a Name of Service
Provider
Product Data Sheet #
CRHLALNM
BellSouth Telecommunications,
LLC
AT&T Alabama (BellSouth
Telecommunications, LLC)
CH18
Regulatory Jurisdiction
Type of Regulation
Intrastate
Dominant
FRN
Guidebook Reference
1857952
AL Gen Exchg A3.2.1 USOC:
PAMA8
Product Retirement
Service to be Discontinued
Complete Choice Basic Service
Service Description
Complete Choice Enhanced service provides a flat rate access line and unlimited calling to all exchange access lines
within the subscriber’s local calling area. Subscribers may select an unlimited number of the following compatible services
or features: Custom Calling, TouchStar, RingMaster, Message Waiting Indicator. *some exclusions may apply.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/al/g003.pdf
Next Generation Product Offer
CATCH PRODUCT
AT&T U-Verse Voice 200 BOT with
Internet Speed Range: 3MB- 100MB
Rack Rate Price Range: $41.00 to
$111.00
CATCH PRODUCT
AT&T U-Verse Voice Unlimited with
Internet Speed Range: 3MB to 100MB
Rack Rate Price Range: $51.00 to
$121.00
CATCH PRODUCT
AT&T U-verse International with
Internet Speed Range: 3MB to 100MB
Rack Rate Price Range: $56.00 to
$126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99
per month/$9.99 when added with
Family Talk
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20 advanced
voice features. $.05 per minute after 200 minutes includes Canada. 200 minutes
include unlimited local calling and 200 long distance minutes. Requires the purchase
of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over
20 advanced voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and low
rates to International countries with over 20 advanced voice features. Requires the
purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID,
Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An
AT&T Catch Product
Number of Customer Locations
Number of Customers with a
Competitive Catch Product in their
Service Area
Number of Services
Number of Customers Without AT&T
or Competitive Catch Product
Number of Customers with an AT&T
Catch Product Available in their Service
Area
Under Assessment, may have AT&T
or Competitive Catch Product
COMPETITIOR
No Records Found.
Competitive Presence
TECHNOLOGY
Percent Covered
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King’s Point, Consumer Market Product
Data Sheets
PUBLIC VERSION
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King's Point Consumer: Flat Rate Service, Residence Service, Individual Service (Active)
Wire Center
DLBHFLKP
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
Regulatory Jurisdiction
Type of Regulation
Intrastate
Dominant
d/b/a Name of Service
Provider
AT&T Florida (BellSouth
Telecommunications, LLC)
Product Data Sheet #
KP1
Guidebook Reference
FL Gen Exchg GB: A3.4.2 USOC:
1FR, 1FRCL
1857952
Product Retirement
Service to be Discontinued
Flat Rate Service, Residence Service, Individual Service
Service Description
A classification of exchange access line service for which a stipulated charge is made, regardless of the amount of
use.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/fl/g003.pdf
Next Generation Product Offer
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20
AT&T U-Verse Voice 200 BOT with Internet
advanced voice features. $.05 per minute after 200 minutes includes Canada. 200
Speed Range: 3MB- 100MB Rack Rate
minutes include unlimited local calling and 200 long distance minutes. Requires the
Price Range: $41.00 to $111.00
purchase of IP Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice Unlimited with Internet
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over
Speed Range: 3MB to 100MB Rack Rate
20 advanced voice features. Requires the purchase of IP Broadband.
Price Range: $51.00 to $121.00
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse International with Internet
Speed Range: 3MB to 100MB Rack Rate
Price Range: $56.00 to $126.00
CATCH PRODUCT
AT&T U-verse Voice International includes Unlimited calls to US and Canada and
low rates to International countries with over 20 advanced voice features. Requires
the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID,
Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch Product
Number of Customer Locations
Number of Customers with a Competitive Catch
Product in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or Competitive
Catch Product
Competitive Presence
COMPETITOR
COMCAST CORPORATION
HOTWIRE COMMUNICATIONS
HUGHESNET
DIRECTV
DISH NETWORK
Verizon Wireless
SPRINT
T-MOBILE
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
Cable C DOWN : UNKNOWN - C UP : UNKNOWN
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
WIRELESS 3G
WIRELESS 3G
Percent Covered
98.63 %
0.02 %
98.64 %
98.64 %
98.64 %
98.64 %
98.64 %
98.64 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King's Point Consumer: Flat Rate Service, Area Plus Service (Active)
Wire Center
DLBHFLKP
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
Regulatory Jurisdiction
Intrastate
Type of Regulation
Dominant
d/b/a Name of Service
Provider
AT&T Florida (BellSouth
Telecommunications, LLC)
FRN
1857952
Product Data Sheet #
KP2
Guidebook Reference
FL Gen Exchg GB: A3.4.4, A103.4.3 USOC:
VR5, VR5CL, VR6, VR6CL, ACML2, ACML3
Product Retirement
Service to be Discontinued
Flat Rate Service, Area Plus Service
Service Description
Area Plus service provides residence subscribers a flat rate access line with unlimited calling to all access lines
within the serving exchange, the additional exchanges in the associated Extended Area Service(EAS)and
Extended Calling.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/fl/g003.pdf
Next Generation Product Offer
CATCH PRODUCT
AT&T U-Verse Voice 200 BOT with
Internet Speed Range: 3MB- 100MB
Rack Rate Price Range: $41.00 to
$111.00
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over
20 advanced voice features. $.05 per minute after 200 minutes includes
Canada. 200 minutes include unlimited local calling and 200 long distance
minutes. Requires the purchase of IP Broadband.
CATCH PRODUCT
AT&T U-Verse Voice Unlimited with
Internet Speed Range: 3MB to 100MB
Rack Rate Price Range: $51.00 to
$121.00
CATCH PRODUCT DESCRIPTION
CATCH PRODUCT
AT&T U-verse International with
Internet Speed Range: 3MB to 100MB
Rack Rate Price Range: $56.00 to
$126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99
per month/$9.99 when added with
Family Talk
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada
with over 20 advanced voice features. Requires the purchase of IP
Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and
Canada and low rates to International countries with over 20 advanced
voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with
Caller ID, Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch Product
Number of Customer Locations
Number of Customers with a Competitive Catch
Product in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or Competitive
Catch Product
Competitive Presence
COMPETITOR
COMCAST CORPORATION
HUGHESNET
DIRECTV
DISH NETWORK
Verizon Wireless
SPRINT
T-MOBILE
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
WIRELESS 3G
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King's Point Consumer: Complete Choice Basic Service (Active)
Wire Center
DLBHFLKP
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Florida (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Regulatory Jurisdiction
Intrastate
Dominant
Product Data Sheet #
KP3
Guidebook Referrence
FL Gen Exchg GB: A3.49 USOC
PAMA7
Product Retirement
Complete Choice Basic Service
Service to be Discontinued
Service Description
Complete Choice Basic service provides a flat rate access line and unlimited calling to all exchange access lines
within the subscribers local calling area. Subscribers have unlimited use of 2 calling features: Call Waiting ID and
Caller ID.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/fl/g003.pdf
Next Generation Product Offer
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20
AT&T U-Verse Voice 200 BOT with Internet
advanced voice features. $.05 per minute after 200 minutes includes Canada. 200
Speed Range: 3MB- 100MB Rack Rate
minutes include unlimited local calling and 200 long distance minutes. Requires the
Price Range: $41.00 to $111.00
purchase of IP Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice Unlimited with Internet
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over
Speed Range: 3MB to 100MB Rack Rate
20 advanced voice features. Requires the purchase of IP Broadband.
Price Range: $51.00 to $121.00
CATCH PRODUCT
AT&T U-verse International with Internet
Speed Range: 3MB to 100MB; Rack Rate
Price Range: $56.00 to $126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and
low rates to International countries with over 20 advanced voice features. Requires
the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID,
Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch Product
Number of Customer Locations
Number of Customers with a Competitive Catch Product in
their Service Area
Number of Services
Number of Customers Without AT&T or Competitive Catch
Product
Number of Customers with an AT&T
Catch Product Available in their Service
Area
Under Assessment, may have AT&T or Competitive Catch
Product
Competitive Presence
COMPETITOR
TECHNOLOGY
Percent Covered
COMCAST CORPORATION
HOTWIRE COMMUNICATIONS
HUGHESNET
DIRECTV
DISH NETWORK
Verizon Wireless
SPRINT
T-MOBILE
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
Cable C DOWN : UNKNOWN - C UP : UNKNOWN
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
WIRELESS 3G
WIRELESS 3G
96.67 %
0.10 %
96.77 %
96.77 %
96.77 %
96.77 %
96.77 %
96.77 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King's Point Consumer: Easy Calling Plans, Plan No.1 (Active)
Wire Center
DLBHFLKP
Regulatory Jurisdiction
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Florida (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Intrastate
Dominant
Product Data Sheet #
KP4
Guidebook Reference
FL Gen Exchg GB: A18.18 USOC:
OC910
Product Retirement
Service to be Discontinued
Easy Calling Plans, Plan No.1
Service Description
An optional intrastate intraLATA toll calling plan that allows all direct dialed sent paid (non-operator assisted)
intrastate calls that originate and terminate in the customer's home Calling Zone/LATA to be rated at $.10 per
minute.
Customer Notice: Product Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/fl/g018.pdf
Next Generation Product Offer
CATCH PRODUCT
AT&T U-Verse Voice 200 BOT with
Internet Speed Range: 3MB- 100MB
Rack Rate Price Range: $41.00 to
$111.00
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over
20 advanced voice features. $.05 per minute after 200 minutes includes
Canada. 200 minutes include unlimited local calling and 200 long distance
minutes. Requires the purchase of IP Broadband.
CATCH PRODUCT
AT&T U-Verse Voice Unlimited with
Internet Speed Range: 3MB to 100MB
Rack Rate Price Range: $51.00 to
$121.00
CATCH PRODUCT DESCRIPTION
CATCH PRODUCT
AT&T U-verse International with
Internet Speed Range: 3MB to 100MB
Rack Rate Price Range: $56.00 to
$126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99
per month/$9.99 when added with
Family Talk
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and
Canada with over 20 advanced voice features. Requires the purchase of
IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and
Canada and low rates to International countries with over 20 advanced
voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with
Caller ID, Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch Product
Number of Customer Locations
Number of Customers with a Competitive Catch Product
in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or Competitive
Catch Product
Competitive Presence
COMPETITOR
COMCAST CORPORATION
HUGHESNET
DIRECTV
DISH NETWORK
Verizon Wireless
SPRINT
T-MOBILE
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
WIRELESS 3G
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King's Point Consumer: Long Distance Message Telecommunications Service (Active)
Wire Center
Legal Name of Service Provider d/b/a Name of Service Provider
DLBHFLKP
BellSouth
Telecommunications, LLC
AT&T Florida (BellSouth
Telecommunications, LLC)
Regulatory Jurisdiction
Type of Regulation
FRN
1857952
Intrastate
Dominant
Product Data Sheet #
KP5
Guidebook Reference
FL Gen. Excg GB: A18.3 USOC:
PAMA1, PAMA2
Product Retirement
Long Distance Message Telecommunications Service
Service to be Discontinued
Service Description
Long Distance Message Telecommunications Service is that of furnishing facilities for communications between
stations in different rate centers for either two-point or conference service. Rates for service between points are
based on airline mileage between rate centers. In general, each point is designated as a rate center except that
certain small towns or communities are assigned adjacent rate centers with which they are closely associated for
communication purposes or by community of interest.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/fl/g018.pdf
Next Generation Product Offer
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice 200 BOT with
Internet Speed Range: 3MB- 100MB
Rack Rate Price Range: $41.00 to
$111.00
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over
20 advanced voice features. $.05 per minute after 200 minutes includes
Canada. 200 minutes include unlimited local calling and 200 long distance
minutes. Requires the purchase of IP Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice Unlimited with
Internet Speed Range: 3MB to 100MB
Rack Rate Price Range: $51.00 to
$121.00
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada
with over 20 advanced voice features. Requires the purchase of IP
Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse International with
Internet Speed Range: 3MB to 100MB
Rack Rate Price Range: $56.00 to
$126.00
CATCH PRODUCT
AT&T U-verse Voice International includes Unlimited calls to US and
Canada and low rates to International countries with over 20 advanced
voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T Wireless Home Phone/ $19.99
per month/$9.99 when added with
Family Talk
Unlimited Nationwide Calling- Home Phone with Wireless Network with
Caller ID, Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch Product
Number of Customer Locations
Number of Customers with a Competitive Catch Product
in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or Competitive
Catch Product
Competitive Presence
COMPETITOR
COMCAST CORPORATION
HUGHESNET
DIRECTV
DISH NETWORK
Verizon Wireless
SPRINT
T-MOBILE
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
WIRELESS 3G
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King's Point Consumer: 2 Pack Plan (Grandfathered)
Wire Center
DLBHFLKP
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Florida (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Regulatory Jurisdiction
Intrastate
Dominant
Product Data Sheet #
KP6
Guidebook Reference #
FL Gen Exchg GB: A103.4.7 USOC:
PAMA6
Product Retirement
Service to be Discontinued
2 Pack Plan
Service Description
The 2 Pack Plan provides a flat rate access line with Touch-Tone capability and unlimited calling to all exchange
access lines within the subscribers local calling area. The plan also entitles a residence subscriber to unlimited use
of 5 features and services Subscribers have unlimited use of 6 the features/services.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/fl/g103.pdf
Next Generation Product Offer
CATCH PRODUCT
AT&T U-Verse Voice 200 BOT with
Internet Speed Range: 3MB- 100MB
Rack Rate Price Range: $41.00 to
$111.00
CATCH PRODUCT
AT&T U-Verse Voice Unlimited with
Internet Speed Range: 3MB to
100MB; Rack Rate Price Range:
$51.00 to $121.00
CATCH PRODUCT
AT&T U-verse International with
Internet Speed Range: 3MB to
100MB; Rack Rate Price Range:
$56.00 to $126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99
per month/$9.99 when added with
Family Talk
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20
advanced voice features. $.05 per minute after 200 minutes includes
Canada. 200 minutes include unlimited local calling and 200 long distance
minutes. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada
with over 20 advanced voice features. Requires the purchase of IP
Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and
Canada and low rates to International countries with over 20 advanced voice
features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with
Caller ID, Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch Product
Number of Customer Locations
Number of Customers with a Competitive Catch Product
in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or Competitive
Catch Product
Competitive Presence
COMPETITOR
COMCAST CORPORATION
HUGHESNET
DIRECTV
DISH NETWORK
Verizon Wireless
SPRINT
T-MOBILE
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
WIRELESS 3G
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King's Point Consumer: PreferredPack Plan (Grandfathered)
Wire Center
DLBHFLKP
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Florida (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Regulatory Jurisdiction
Intrastate
Dominant
Project Data Sheet #
KP7
Guidebook Ref
FL Gen Exchg GB: A103.4.6 USOC:
PAMA5
Product Retirement
PreferredPack Plan
Service to be Discontinued
Service Description
The Preferred Pack plan provides a flat rate access line with Touch-Tone capability and entitles a residence
subscriber to unlimited calling to all exchange access lines within the subscriber’s local calling area 3. The plan
also entitles a residence subscriber to unlimited use of 9 features/services.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/fl/g103.pdf
Next Generation Product Offer
CATCH PRODUCT DESCRIPTION
CATCH PRODUCT
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20
AT&T U-Verse Voice 200 BOT with Internet
advanced voice features. $.05 per minute after 200 minutes includes Canada. 200
Speed Range: 3MB- 100MB Rack Rate
minutes include unlimited local calling and 200 long distance minutes. Requires the
Price Range: $41.00 to $111.00
purchase of IP Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice Unlimited with Internet
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over
Speed Range: 3MB to 100MB Rack Rate
20 advanced voice features. Requires the purchase of IP Broadband.
Price Range: $51.00 to $121.00
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and
low rates to International countries with over 20 advanced voice features. Requires
the purchase of IP Broadband.
AT&T U-verse International with Internet
Speed Range: 3MB to 100MB Rack Rate
Price Range: $56.00 to $126.00
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID,
Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch
Product
Number of Customer Locations
Number of Customers with a Competitive Catch
Product in their Service Area
Number of Services
Number of Customers Without AT&T or
Competitive Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or Competitive
Catch Product
Competitive Presence
COMPETITOR
COMCAST CORPORATION
HUGHESNET
DIRECTV
DISH NETWORK
Verizon Wireless
SPRINT
T-MOBILE
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
WIRELESS 3G
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King's Point Consumer: Custom Rate Plan (Active)
Wire Center
DLBHFLKP
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Florida (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Regulatory Jurisdiction
Intrastate
Dominant
Product Data Sheet #
KP8
Guidebook Reference
FL Gen Excg GB: A18.21 USOC
OSR20
Product Retirement
Service to be Discontinued
Custom Rate Plan
Service Description
Custom Rate Plan is an Optional Calling Plan offered to residential customers and is applicable to intrastate
intraLATA long distance calls originated and terminated in the customer's home state. Eligible calls include those
dialed on a Station-to-Station basis (as either Dial, Dial Calling Card, or Operator) or on a Person-to-Person basis.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/fl/g018.pdf
Next Generation Product Offer
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20
AT&T U-Verse Voice 200 BOT with Internet
advanced voice features. $.05 per minute after 200 minutes includes Canada. 200
Speed Range: 3MB- 100MB Rack Rate
minutes include unlimited local calling and 200 long distance minutes. Requires the
Price Range: $41.00 to $111.00
purchase of IP Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice Unlimited with Internet
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over
Speed Range: 3MB to 100MB Rack Rate
20 advanced voice features. Requires the purchase of IP Broadband.
Price Range: $51.00 to $121.00
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and
low rates to International countries with over 20 advanced voice features. Requires
the purchase of IP Broadband.
AT&T U-verse International with Internet
Speed Range: 3MB to 100MB Rack Rate
Price Range: $56.00 to $126.00
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID,
Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch
Product
Number of Customer Locations
Number of Customers with a Competitive Catch
Product in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or Competitive
Catch Product
Competitive Presence
COMPETITOR
COMCAST CORPORATION
HUGHESNET
DIRECTV
DISH NETWORK
Verizon Wireless
SPRINT
T-MOBILE
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
WIRELESS 3G
WIRELESS 3G
Percent Covered
97.62 %
97.62 %
97.62 %
97.62 %
97.62 %
97.62 %
97.62 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King's Point Consumer: Integrated Services Digital Network(ISDN),ResidenceService(IRS)
(Active)
Wire Center
DLBHFLKP
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Alabama (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Regulatory Jurisdiction
Intrastate
Dominant
Product Data Sheet #
KP9
Guidebook Reference
FL Gen Exchg GB: A42.2 USOC:
LQAFX, LQGFX
Product Retirement
Service to be Discontinued
Integrated Services Digital Network (ISDN), Residence Service (IRS)
Service Description
Residence Service (IRS) supports simultaneous transmission of voice, data, and packet services on the same exchange access
line. Calling/Called Number Delivery, Calling Name Delivery, and Call Hold are included with this service. IRS provides a method
of access to the telephone network called Basic Rate Access. Basic Rate Access consists of the ability to access up to two 64
Kbps (B) channels and one 16 Kbps (D) channel at the service delivery point. IRS is provided through Basic Rate Access. B
channel circuit switched services offer up to 64 Kbps intra-office transmission of voice or data. This option permits the customer to
utilize either circuit voice or data transmission paths on a per call selection basis. Transmission on the B channel will be circuit
switched at 64 Kbps within the switch and/or equipped facilities between ISDN compatible central offices.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/fl/g042.pdf
Next Generation Product Offer
CATCH PRODUCT
AT&T U-Verse Voice 200 BOT with
Internet Speed Range: 3MB- 100MB Rack
Rate Price Range: $41.00 to $111.00
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20
advanced voice features. $.05 per minute after 200 minutes includes Canada. 200
minutes include unlimited local calling and 200 long distance minutes. Requires the
purchase of IP Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice Unlimited with Internet
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over
Speed Range: 3MB to 100MB Rack Rate
20 advanced voice features. Requires the purchase of IP Broadband.
Price Range: $51.00 to $121.00
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and
low rates to International countries with over 20 advanced voice features. Requires
the purchase of IP Broadband.
AT&T U-verse International with Internet
Speed Range: 3MB to 100MB Rack Rate
Price Range: $56.00 to $126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID,
Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch Product
Number of Customer Locations
Number of Customers with a Competitive Catch Product
in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or Competitive
Catch Product
Competitive Presence
COMPETITOR
COMCAST CORPORATION
HUGHESNET
DIRECTV
DISH NETWORK
Verizon Wireless
SPRINT
T-MOBILE
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
WIRELESS 3G
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King's Point Consumer: Complete Choice Service (Grandfathered)
Wire Center
Legal Name of Service Provider d/b/a Name of Service Provider
DLBHFLKP
BellSouth
Telecommunications, LLC
AT&T Florida (BellSouth
Telecommunications, LLC)
Regulatory Jurisdiction
Type of Regulation
FRN
1857952
Intrastate
Service to be Discontinued
Dominant
Product Data Sheet #
KP10
Guidebook Reference
FL Gen. Exng GB: A103.4.3 USOC
VR3, VSB, CCML2, CCML3
Product Retirement
Complete Choice Service
Service Description
Complete Choice service provides a flat rate access line with Touch-Tone capability and unlimited calling to all
exchange access lines in the subscriber's local calling area. It also entitles a residence subscriber to unlimited use
of 32 services/features. Residence customers may subscribe to the Two-Line Plan or the Three-Line Plan for
Complete Choice service. All lines in each multi-line package must be billed to the same account and located at the
same premises. Complete Choice is also available with Area Plus Service.
Customer Notice: Product
Grandfather
Customer Notice: Service
Discontinuance (Sunset)
GRANDFATHER
Disallow Adds, Moves, Changes
Guidebook Link
SERVICE DISCONTINUANCE
http://cpr.web.att.com/pdf/fl/g103.pdf
Next Generation Product Offer
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20
AT&T U-Verse Voice 200 BOT with Internet
advanced voice features. $.05 per minute after 200 minutes includes Canada. 200
Speed Range: 3MB- 100MB Rack Rate
minutes include unlimited local calling and 200 long distance minutes. Requires the
Price Range: $41.00 to $111.00
purchase of IP Broadband.
CATCH PRODUCT
CATCH PRODUCT DESCRIPTION
AT&T U-Verse Voice Unlimited with Internet
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over
Speed Range: 3MB to 100MB Rack Rate
20 advanced voice features. Requires the purchase of IP Broadband.
Price Range: $51.00 to $121.00
CATCH PRODUCT
AT&T U-verse International with Internet
Speed Range: 3MB to 100MB Rack Rate
Price Range: $56.00 to $126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99 per
month/$9.99 when added with Family Talk
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and
low rates to International countries with over 20 advanced voice features. Requires
the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID,
Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An AT&T Catch
Product
Number of Customer Locations
Number of Customers with a Competitive Catch
Product in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or Competitive
Catch Product
Competitive Presence
COMPETITOR
COMCAST CORPORATION
HUGHESNET
DIRECTV
DISH NETWORK
Verizon Wireless
SPRINT
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
SATELLITE
SATELLITE
SATELLITE
WIRELESS LTE
WIRELESS 3G
Percent Covered
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
100.00 %
T-MOBILE
WIRELESS 3G
100.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King's Point Consumer: Foreign Exchange Service (Active)
Wire Center
DLBHFLKP
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Florida (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Regulatory Jurisdiction
Intrastate
Product Data Sheet #
KP11
Guidebook Reference
FL Gen Exchg GB: A9.1.6
USOC: 1D9++, 1L9++, BME,
FX5++
Dominant
Product Retirement
Service to be Discontinued
Foreign Exchange Service
Service Description
A classification of exchange service furnished to a subscriber from an exchange other than the one from which
they would normally be served
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/fl/g009.pdf
Next Generation Product Offer
CATCH PRODUCT
n/a
CATCH PRODUCT DESCRIPTION
n/a
Demand Count
Number of Customers
Number of customers Without An AT&T Catch
Product
Number of Customer Locations
Number of Customers with a Competitive Catch
Product in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or
Competitive Catch Product
COMPETITOR
No records found.
Competitive Presence
TECHNOLOGY
Percent Covered
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King's Point Consumer: Foreign Central Office Service (Active)
Wire Center
DLBHFLKP
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
d/b/a Name of Service
Provider
AT&T Florida (BellSouth
Telecommunications, LLC)
Type of Regulation
FRN
1857952
Regulatory Jurisdiction
Intrastate
Dominant
Product Data Sheet #
KP11
Guidebook Reference
FL Gen Exchg GB: A9.2
USOC: 1LHGV
Product Retirement
Service to be Discontinued
Foreign Exchange Service
Service Description
Foreign Central Office Service is exchange service furnished to a subscriber in a multi-office exchange from a
central office
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Guidebook Link
http://cpr.web.att.com/pdf/fl/g009.pdf
Next Generation Product Offer
CATCH PRODUCT
n/a
CATCH PRODUCT DESCRIPTION
n/a
Demand Count
Number of Customers
Number of customers Without An AT&T Catch
Product
Number of Customer Locations
Number of Customers with a Competitive Catch
Product in their Service Area
Number of Services
Number of Customers Without AT&T or Competitive
Catch Product
Number of Customers with an AT&T Catch
Product Available in their Service Area
Under Assessment, may have AT&T or
Competitive Catch Product
Competitive Presence
TECHNOLOGY
COMPETITOR
No records found.
Percent Covered
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King’sPointConsumer:DSLDirect
Wire Center
Legal Name of Service
Provider
d/b/a Name of Service
Provider
Product Data Sheet #
DLBHFLKP
BellSouth Telecommunications,
LLC
AT&T Florida (BellSouth
Telecommunications, LLC)
KP13
Regulatory Jurisdiction
n/a
Type of Regulation
n/a
FRN
Tariff Reference (Tariff
N/A
n/a
Product Retirement
DSL Direct (Elite, Pro, Express and Basic)
Service Description
DSL WITHOUT home phone service: DSL Direct Elite up to 6.0 Mbps downstream and up to 768 Kbps Upstream;
DSL Direct Pro up to 3.0 Mbps Downstream and up to 512 Kbps Upstream; DSL Direct Basic up to 768 Kpbs
Downstream and up to 384 Kpbs Upstream.
Customer Notice: Product
Grandfather
GRANDFATHER
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Disallow Adds, Moves, Changes
CATCH PRODUCT NAME
AT&T U-Verse HSIA.
Speed Range: 3MB to
100MB; Rack Rate Price
Range: $41.00 to
$111.00
Next Generation Product Offer
CATCH PRODUCT DESCRIPTION
High Speed Internet providing streaming video, large downloads, gaming with
speeds available up to 24Mbps and access to national AT&T Wi-Fi Hot Spot network
included. Requires the purchase of IP Broadband
Demand Count
Number of Customers
Number of Services Without An AT&T Catch Product
Number of Customer Locations
Number of Services with a Competitive Catch Product
in their Service Area
Number of Services
Number of Services Without AT&T or Competitive
Catch Product
Number of Services with an AT&T Catch
Product Available in their Service Area
Competitive Presence
COMPETITOR
COMCAST
HUGHESNET
DISH NETWORK
DIRECTV
SPRINT
VERIZON WIRELESS
T-MOBILE USA
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
Cable C DOWN : UNKNOWN - C UP : UNKNOWN
SATELLITE
SATELLITE
3G
LTE
3G
Percent Covered
99%
96.00 %
96.00 %
96.00 %
96.00 %
96.00 %
96.00 %
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King’sPointConsumer:DSLLineShare
Wire Center
Legal Name of Service
Provider
d/b/a Name of Service
Provider
Product Data Sheet #
DLBHFLKP
BellSouth Telecommunications,
LLC
AT&T Florida (BellSouth
Telecommunications, LLC)
KP14
Regulatory Jurisdiction
n/a
Type of Regulation
n/a
FRN
Tariff Reference (Tariff
N/A
n/a
Product Retirement
DSL Line Share
Service Description
DSL WITH home phone service: DSL Direct Elite up to 6.0 Mbps downstream and up to 768 Kbps Upstream; DSL
Direct Pro up to 3.0 Mbps Downstream and up to 512 Kbps Upstream; DSL Direct Basic up to 768 Kpbs Downstream
and up to 384 Kpbs Upstream.
Customer Notice: Product
Grandfather
GRANDFATHER
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Disallow Adds, Moves, Changes
CATCH PRODUCT NAME
AT&T U-Verse HSIA.
Speed Range: 3MB to
100MB; Rack Rate Price
Range: $41.00 to
$111.00
Next Generation Product Offer
CATCH PRODUCT DESCRIPTION
High Speed Internet providing streaming video, large downloads, gaming with
speeds available up to 24Mbps and access to national AT&T Wi-Fi Hot Spot network
included. Requires the purchase of IP Broadband
Demand Count
Number of Customers
Number of Services Without An AT&T Catch Product
Number of Customer Locations
Number of Services with a Competitive Catch Product in
their Service Area
Number of Services
Number of Services Without AT&T or Competitive Catch
Product
Number of Services with an AT&T Catch
Product Available in their Service Area
COMPETITOR
COMCAST
HUGHESNET
DISH NETWORK
DIRECTV
SPRINT
VERIZON WIRELESS
T-MOBILE USA
Competitive Presence
TECHNOLOGY
Cable C DOWN : 105 Mbps - C UP : 768 Kbps
Cable C DOWN : UNKNOWN - C UP : UNKNOWN
SATELLITE
SATELLITE
3G
LTE
3G
Percent Covered
99.00%
99.00%
99.00%
99.00%
99.00%
99.00%
99.00%
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King’s Point Consumer: EndUserAccessService(Active)
Legal Name of Service
Provider
BellSouth
Telecommunications, LLC
Wire Center
DLBHFLKP
Regulatory
Jurisdiction
Type of Regulation
Interstate
Dominant
d/b/a Name of Service
Provider
AT&T Florida (BellSouth
Telecommunications, LLC)
FRN
Product Data Sheet #
KP15
Tariff Reference
1857952
FCC Tariff #1 Access Services. USOC(s): 9LM 9ZR,
Product Retirement
End User Access Service
Service Description
End User Access service provides for the use of an End User Common Line by an end user. AT&T provides End
User Access service to end users who obtain local exchange service from its general interstate or local exchange
tariffs.
Customer Notice: Product
Grandfather
GRANDFATHER
Disallow Adds, Moves, Changes
Customer Notice: Service
Discontinuance (Sunset)
SERVICE DISCONTINUANCE
Tariff Link
http://cpr.att.com/pdf/fcc/1004.pdf
CATCH PRODUCT
N/A
Number of Customers
Next Generation Product Offer
CATCH PRODUCT DESCRIPTION
Demand Count
Number of Services Without
An AT&T Catch Product
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King’s Point Consumer: Complete Choice Enhanced (Active)
Wire Center
Legal Name of Service
Provider
d/b/a Name of Service
Provider
Product Data Sheet #
CRHLALNM
BellSouth Telecommunications,
LLC
AT&T Alabama (BellSouth
Telecommunications, LLC)
KP16
Regulatory Jurisdiction
Type of Regulation
Intrastate
Dominant
FRN
Guidebook Reference
1857952
FL Gen Exchg A3.4.8 USOC:
PAMA8
Product Retirement
Service to be Discontinued
Complete Choice Basic Service
Service Description
Complete Choice Enhanced service provides a flat rate access line and unlimited calling to all exchange access lines
within the subscriber’s local calling area. Subscribers may select an unlimited number of the following compatible services
or features: Custom Calling, TouchStar, RingMaster, Message Waiting Indicator. *some exclusions may apply.
Customer Notice: Product
Grandfather
Customer Notice: Service
Discontinuance (Sunset)
GRANDFATHER
Disallow Adds, Moves, Changes
Guidebook Link
SERVICE DISCONTINUANCE
http://cpr.web.att.com/pdf/fl/g003.pdf
Next Generation Product Offer
CATCH PRODUCT
AT&T U-Verse Voice 200 BOT with
Internet Speed Range: 3MB- 100MB
Rack Rate Price Range: $41.00 to
$111.00
CATCH PRODUCT
AT&T U-Verse Voice Unlimited with
Internet Speed Range: 3MB to 100MB
Rack Rate Price Range: $51.00 to
$121.00
CATCH PRODUCT
AT&T U-verse International with
Internet Speed Range: 3MB to 100MB
Rack Rate Price Range: $56.00 to
$126.00
CATCH PRODUCT
AT&T Wireless Home Phone/ $19.99
per month/$9.99 when added with
Family Talk
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice 200 BOT includes 200 minutes per month with over 20 advanced
voice features. $.05 per minute after 200 minutes includes Canada. 200 minutes
include unlimited local calling and 200 long distance minutes. Requires the purchase
of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice Unlimited includes Unlimited Calls to US and Canada with over
20 advanced voice features. Requires the purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
AT&T U-verse Voice International includes Unlimited calls to US and Canada and low
rates to International countries with over 20 advanced voice features. Requires the
purchase of IP Broadband.
CATCH PRODUCT DESCRIPTION
Unlimited Nationwide Calling- Home Phone with Wireless Network with Caller ID,
Three Way Calling, Call Forwarding and Voicemail
Demand Count
Number of Customers
Number of customers Without An
AT&T Catch Product
Number of Customer Locations
Number of Customers with a
Competitive Catch Product in their
Service Area
Number of Services
Number of Customers Without AT&T
or Competitive Catch Product
Number of Customers with an AT&T
Catch Product Available in their Service
Area
Under Assessment, may have AT&T
or Competitive Catch Product
COMPETITIOR
No Records Found
Competitive Presence
TECHNOLOGY
Percent Covered
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Carbon Hill, Business Market Product
Data Sheets
PUBLIC VERSION
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
CarbonHillBusiness:,QGLYLGXDOOLQH0HDVXUHG5DWH6HUYLFH%XVLQHVV$UHD&DOOLQJ6HUYLFH
$FFHVV/LQH%XVLQHVV&ODVVURRP&RPPXQLFDWLRQ6HUYLFH(Active)
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
&5+/$/10
5HJXODWRU\-XULVGLFWLRQ
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
)51
3URGXFW'DWD6KHHW
&+%
*XLGHERRN5HIHUHQFH
$/*HQ([FKJ$$
$862&%08336((&$
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
$/RQO\,QGLYLGXDOOLQH0HDVXUHG5DWH6HUYLFH%XVLQHVV$UHD&DOOLQJ6HUYLFH
$FFHVV/LQH%XVLQHVV&ODVVURRP&RPPXQLFDWLRQ6HUYLFH
6HUYLFH'HVFULSWLRQ
$FODVVLILFDWLRQRIH[FKDQJHVHUYLFHZKLFKLVFKDUJHGRQWKHEDVLVRIORFDOXVDJHDVGHWHUPLQHGE\WKHQXPEHURI
FDOOVWKHGXUDWLRQRIWKHFDOOVWKHGLVWDQFHRIWKHFDOOVDQGWKHWLPHRIGD\WKHFDOOVDUHSODFHG
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*XLGHERRN/LQN
6(59,&(',6&217,18$1&(
http://cpr.web.att.com/pdf/fl/g003.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
1HZ3URGXFW$
&$7&+352'8&7
1HZ3URGXFW±%
&$7&+352'8&7
,3)OH[5HDFK
&$7&+352'8&7'(6&5,37,21
$OO'LVWDQFH86'RPHVWLF9R,3RIIHULQWHJUDWHGZLWKLQWKH,3%URDGEDQG
,QFOXGHVRYHUYRLFHIHDWXUHVSOXVFRQYHQLHQWZHEEDVHGFDOO
PDQDJHPHQW2IIHUVLQWHJUDWHGEXVLQHVVSKRQHDQGZLUHOHVVYRLFHPDLO
IURPDVLQJOHPDLOER[
&$7&+352'8&7'(6&5,37,21
+RVWHG,3SURGXFWWKDWFRPELQHVORFDOYRLFHGRPHVWLF/'DQG
EURDGEDQGZLWKWKHDELOLW\WREULQJ\RXURZQEURDGEDQGIURP$77RUD
FRPSHWLWRU
&$7&+352'8&7'(6&5,37,21
$QLQWHJUDWHGDFFHVVFRQYHUJHGVROXWLRQGHVLJQHGWRGHOLYHURXWERXQG
LQERXQGORFDODQGORQJGLVWDQFHFDOOLQJRYHU$77
V,QWHUQHW3URWRFRO,3
DQG9LUWXDO3ULYDWH1HWZRUN931VHUYLFHV$OVRUHIHUUHGWRDVD6HVVLRQ
,QLWLDWLRQ3URWRFRO6,37UXQNLQJVROXWLRQ'HSOR\HGLQVLWXDWLRQVZKHUH
FXVWRPHUVRZQWKHLURZQSUHPLVHVWHOHSKRQ\DQDORJSKRQHVNH\
V\VWHP7'03%;RU,33%;HTXLSPHQW
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH&DWFK
3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
&+$57(5&20081,&$7,216
+8*+(61(76$7(//,7(
',6+1(7:25.
',5(&796$7(//,7(
9HUL]RQ:LUHOHVV
6SULQW
70RELOH86$
7(&+12/2*<
&DEOH&'2:10ESV&830ESV
6$7(//,7(
:,5(/(66/7(
:,5(/(66*
:,5(/(66*
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
CarbonHillBusiness:7UXQN/LQH0HDVXUHG5DWH6HUYLFH%XVLQHVV$UHD&DOOLQJ6HUYLFH7UXQN
/LQH%XVLQHVV$FWLYH
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
&5+/$/10
5HJXODWRU\-XULVGLFWLRQ
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
)51
3URGXFW'DWD6KHHW
&+%
*XLGHERRN5HIHUHQFH
$/*HQ([FKJ*%$862&%08
7.*8336
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
$/RQO\7UXQN/LQH0HDVXUHG5DWH6HUYLFH%XVLQHVV$UHD&DOOLQJ6HUYLFH7UXQN
/LQH%XVLQHVV
6HUYLFH'HVFULSWLRQ
$FODVVLILFDWLRQRIH[FKDQJHVHUYLFHZKLFKLVFKDUJHGRQWKHEDVLVRIORFDOXVDJHDVGHWHUPLQHGE\WKHQXPEHURI
FDOOVWKHGXUDWLRQRIWKHFDOOVWKHGLVWDQFHRIWKHFDOOVDQGWKHWLPHRIGD\WKHFDOOVDUHSODFHG
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
6(59,&(',6&217,18$1&(
*XLGHERRN/LQN
http://cpr.web.att.com/pdf/fl/g003.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
1HZ3URGXFW$
&$7&+352'8&7
1HZ3URGXFW%
&$7&+352'8&7
,3)OH[5HDFK
&$7&+352'8&7'(6&5,37,21
$OO'LVWDQFH86'RPHVWLF9R,3RIIHULQWHJUDWHGZLWKLQWKH,3%URDGEDQG,QFOXGHVRYHU
YRLFHIHDWXUHVSOXVFRQYHQLHQWZHEEDVHGFDOOPDQDJHPHQW2IIHUVLQWHJUDWHG
EXVLQHVVSKRQHDQGZLUHOHVVYRLFHPDLOIURPDVLQJOHPDLOER[
&$7&+352'8&7'(6&5,37,21
+RVWHG,3SURGXFWWKDWFRPELQHVORFDOYRLFHGRPHVWLF/'DQGEURDGEDQGZLWKWKHDELOLW\
WREULQJ\RXURZQEURDGEDQGIURP$77RUDFRPSHWLWRU
&$7&+352'8&7'(6&5,37,21
$QLQWHJUDWHGDFFHVVFRQYHUJHGVROXWLRQGHVLJQHGWRGHOLYHURXWERXQGLQERXQGORFDO
DQGORQJGLVWDQFHFDOOLQJRYHU$77
V,QWHUQHW3URWRFRO,3DQG9LUWXDO3ULYDWH1HWZRUN
931VHUYLFHV$OVRUHIHUUHGWRDVD6HVVLRQ,QLWLDWLRQ3URWRFRO6,37UXQNLQJVROXWLRQ
'HSOR\HGLQVLWXDWLRQVZKHUHFXVWRPHUVRZQWKHLURZQSUHPLVHVWHOHSKRQ\DQDORJ
SKRQHVNH\V\VWHP7'03%;RU,33%;HTXLSPHQW
&$7&+352'8&7
1XPEHURI&XVWRPHUV
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH&DWFK3URGXFW
LQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU&RPSHWLWLYH&DWFK
3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77
&DWFK3URGXFW$YDLODEOHLQWKHLU
6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
&+$57(5&20081,&$7,216
+8*+(61(76$7(//,7(
',6+1(7:25.
',5(&796$7(//,7(
9HUL]RQ:LUHOHVV
6SULQW
70RELOH86$
7(&+12/2*<
&DEOH&'2:10ESV&830ESV
6$7(//,7(
:,5(/(66/7(
:,5(/(66*
:,5(/(66*
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
&DUERQ+LOO%XVLQHVV0HVVDJH5DWH6HUYLFH%XVLQHVV7UXQNV$FWLYH
:LUH&HQWHU
&5+/$/10
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
5HJXODWRU\-XULVGLFWLRQ
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
)51
3URGXFW7UDFNLQJ
&+%
*XLGHERRN5HIHUHQFH
$/*HQ([J*%$$
862&70&7070870
3URGXFW5HWLUHPHQW
0HVVDJH5DWH6HUYLFH%XVLQHVV7UXQNV
6HUYLFHWREH'LVFRQWLQXHG
6HUYLFH'HVFULSWLRQ
$FODVVLILFDWLRQRIH[FKDQJHVHUYLFHZKLFKLVFKDUJHGRQWKHEDVLVRIORFDOXVDJHDVGHWHUPLQHGE\WKHQXPEHURI
FDOOVSODFHG
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
&$7&+352'8&7
1HZ3URGXFW$
&$7&+352'8&7
1HZ3URGXFW%
&$7&+352'8&7
,3)OH[5HDFK
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
6(59,&(',6&217,18$1&(
*XLGHERRN/LQN
KWWSFSUZHEDWWFRPSGIIOJSGI
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
$OO'LVWDQFH86'RPHVWLF9R,3RIIHULQWHJUDWHGZLWKLQWKH,3%URDGEDQG,QFOXGHV
RYHUYRLFHIHDWXUHVSOXVFRQYHQLHQWZHEEDVHGFDOOPDQDJHPHQW2IIHUV
LQWHJUDWHGEXVLQHVVSKRQHDQGZLUHOHVVYRLFHPDLOIURPDVLQJOHPDLOER[
&$7&+352'8&7'(6&5,37,21
+RVWHG,3SURGXFWWKDWFRPELQHVORFDOYRLFHGRPHVWLF/'DQGEURDGEDQGZLWKWKH
DELOLW\WREULQJ\RXURZQEURDGEDQGIURP$77RUDFRPSHWLWRU
&$7&+352'8&7'(6&5,37,21
$QLQWHJUDWHGDFFHVVFRQYHUJHGVROXWLRQGHVLJQHGWRGHOLYHURXWERXQGLQERXQG
ORFDODQGORQJGLVWDQFHFDOOLQJRYHU$77
V,QWHUQHW3URWRFRO,3DQG9LUWXDO3ULYDWH
1HWZRUN931VHUYLFHV$OVRUHIHUUHGWRDVD6HVVLRQ,QLWLDWLRQ3URWRFRO6,3
7UXQNLQJVROXWLRQ'HSOR\HGLQVLWXDWLRQVZKHUHFXVWRPHUVRZQWKHLURZQSUHPLVHV
WHOHSKRQ\DQDORJSKRQHVNH\V\VWHP7'03%;RU,33%;HTXLSPHQW
&$7&+352'8&7
1XPEHURI&XVWRPHUV
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH&DWFK
3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&203(7,725
1RUHFRUGVIRXQG
&RPSHWLWLYH$QDO\VLV
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
&DUERQ+LOO%XVLQHVV%HOO6RXWK3ULPDU\5DWH,6'1$FWLYH
:LUH&HQWHU
&5+/$/10
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
5HJXODWRU\-XULVGLFWLRQ
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
)51
3URGXFW'DWD6KHHW
&+%
*XLGHERRN5HIHUHQFH
$/*HQ([FKJ*%$862&
/'/'35
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
%HOO6RXWK3ULPDU\UDWH,6'1
6HUYLFH'HVFULSWLRQ
,QWHJUDWHG6HUYLFHV'LJLWDO1HWZRUN3ULPDU\5DWH,QWHUIDFH,6'135,LVDYRLFHDQGGDWDVHUYLFHWKDWSURYLGHV
KLJKYROXPHDFFHVVWRWKHSXEOLFVZLWFKHGWHOHSKRQHQHWZRUN36717KLVVHUYLFHOHWV\RXWUDQVPLWGDWDDWKLJK
VSHHGVWRDFFRPPRGDWHYRLFHGDWDLPDJHDQGYLGHRRYHUWKHVDPHGLJLWDOIDFLOLWLHV,6'135,SURYLGHVGLJLWDO
FKDQQHOVRYHURQHWUDQVSRUWOLQHDWKFKDQQHOFDUULHVVLJQDOLQJLQIRUPDWLRQ7KLVVHUYLFHRIIHUV\RXRQH7FLUFXLW
ZLWKVHSDUDWHYRLFHOLQHVRUDFRPELQDWLRQRIVHUYLFHV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
6(59,&(',6&217,18$1&(
*XLGHERRN/LQN
KWWSFSUZHEDWWFRPSGIIOJSGI
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
,3)OH[5HDFK
&$7&+352'8&7'(6&5,37,21
$QLQWHJUDWHGDFFHVVFRQYHUJHGVROXWLRQGHVLJQHGWRGHOLYHURXWERXQGLQERXQGORFDO
DQGORQJGLVWDQFHFDOOLQJRYHU$77
V,QWHUQHW3URWRFRO,3DQG9LUWXDO3ULYDWH
1HWZRUN931VHUYLFHV$OVRUHIHUUHGWRDVD6HVVLRQ,QLWLDWLRQ3URWRFRO6,3
7UXQNLQJVROXWLRQ'HSOR\HGLQVLWXDWLRQVZKHUHFXVWRPHUVRZQWKHLURZQSUHPLVHV
WHOHSKRQ\DQDORJSKRQHVNH\V\VWHP7'03%;RU,33%;HTXLSPHQW
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&203(7,725
1RUHFRUGVIRXQG
&RPSHWLWLYH$QDO\VLV
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
CarbonHillBusiness:6HOI+HDOLQJ0XOWL1RGDO$OWHUQDWH5RXWH7RSRORJ\5LQJ6PDUW5LQJ
6HUYLFH$FWLYH
:LUH&HQWHU
&5+/$/10
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
7\SHRI5HJXODWLRQ
)51
5HJXODWRU\-XULVGLFWLRQ
,QWUDVWDWH'RPLQDQW
3URGXFW'DWD6KHHW
&+%
*XLGHERRN5HIHUHQFH
$/39/*%%
862&+96+15&&1
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
6HOI+HDOLQJ0XOWL1RGDO$OWHUQDWH5RXWH7RSRORJ\5LQJ6PDUW5LQJ6HUYLFH
6HUYLFH'HVFULSWLRQ
60$575LQJ621(7DUFKLWHFWXUHXVHVDGXDOILEHUVHOIKHDOLQJULQJZLWKDSULPDU\SDWKDQGDSURWHFWHGSDWK
+(/3,1*72SUHYHQWDQ\VLQJOHSRLQWRIIDLOXUH6HUYLFHDXWRPDWLFDOO\VZLWFKHVWRWKHSURWHFWHGSDWKLIWKHSULPDU\
SDWKIDLOV$OO5LQJVDUHDYDLODEOHLQWKHVWDQGDUGVSHHGV%DQGZLGWK6SHHGV2&2&2&2&
&XVWRPHU1RWLFH3URGXFW*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
6(59,&(',6&217,18$1&(
*XLGHERRN/LQN
7%'
http://cpr.web.att.com/pdf/al/h007.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
1HZ3URGXFW(
&$7&+352'8&7
891
&$7&+352'8&7
$776ZLWFKHG(WKHUQHW
$6(
&$7&+352'8&7'(6&5,37,21
8OWUDYDLODEOH([SUHVVLVD':'0VHUYLFHWKDWZLOOUHSODFHWKHYDULRXV,/(&DQG7&RUS621(7
5LQJSURGXFWV891([SUHVVSURYLGHVWKHUHOLDEOHDQGVFDODEOH5LQJVROXWLRQWKDWFXVWRPHUV
KDYHFRPHWRH[SHFWIURP$77ZKLOHSURYLGLQJDGGHGYDOXHDQGIXQFWLRQDOLW\WKURXJK
HQKDQFHPHQWVVXFKDVH6DOHVDQG6HUYLFLQJWKURXJK%XVLQHVV'LUHFW
&$7&+352'8&7'(6&5,37,21
77V8OWUDYDLODEOHŠ1HWZRUN6HUYLFH891LVDIXOO\PDQDJHGKLJKVSHHGRSWLFDOWUDQVSRUW
VHUYLFHWKDWLQWHJUDWHV(WKHUQHW'HQVH:DYHOHQJWK'LYLVLRQ0XOWLSOH[LQJ':'0DQG1DWLYH
:DYHOHQJWKWHFKQRORJLHVLQWRDVLQJOHHQGWRHQGQHWZRUNVROXWLRQ
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWURDUHDZLWKD
YDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WRJURZDQGDGDSWDVWKH
QHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV*ESV*ESV&RPPLWWHG
,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV0ESVWR*ESV6L[FODVVHVRIVHUYLFH
RIIHULQJWKHULJKWSHUIRUPDQFH6/$IRU\RXUDSSOLFDWLRQV(WKHUQHW3ULYDWH/LQH(3/(93/LV
RIIHUHGIRUFRQQHFWLRQVEHWZHHQWZRORFDWLRQVZKLOH
&$7&+352'8&7
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHUV
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHVZLWKDQ$77
&DWFK3URGXFW$YDLODEOHLQWKHLU6HUYLFH
$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
1RUHFRUGVIRXQG
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
&DUERQ+LOO%XVLQHVV6XE9RLFHJUDGH6HUYLFHV6HULHV&KDQQHOV
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
&5+/$/10
5HJXODWRU\-XULVGLFWLRQ
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
)51
7ULDO7UDFNLQJ1XPEHU
&+%
*XLGHERRN5HIHUHQFH
$/39/*%%$/*HQ([FK*%$
$862&
+%:%+(/212
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
6XE9RLFHJUDGH6HUYLFHV6HULHV&KDQQHOV
6HUYLFH'HVFULSWLRQ
$QDQDORJFKDQQHOIRUWKHWUDQVPLVVLRQRIDV\QFKURQRXVRUV\QFKURQRXVVHULDOGDWDDWUDWHVRIXSWRRU
.ESV2SWLRQDODUUDQJHPHQWVDUHDYDLODEOHIRUWUDQVPLVVLRQRIV\QFKURQRXVVHULDOGDWDUDWHVDWRU
.ESV%HOO6RXWKŠ&KDQQHOL]HG7UXQNVSURYLGHVXSWRWZHQW\IRXU'LUHFW,QZDUG'LDO','
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
6(59,&(',6&217,18$1&(
*XLGHERRN/LQN
KWWSFSUZHEDWWFRPSGIDOKSGI
KWWSFSUZHEDWWFRPSGIDOJSGI
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
$776ZLWFKHG(WKHUQHW
$6(
&$7&+352'8&7
$1,5$2YHU%URDGEDQG
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWUR
DUHDZLWKDYDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WR
JURZDQGDGDSWDVWKHQHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV
*ESV*ESV&RPPLWWHG,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV
0ESVWR*ESV6L[FODVVHVRIVHUYLFHRIIHULQJWKHULJKWSHUIRUPDQFH6/$IRU
DSSOLFDWLRQV(WKHUQHW3ULYDWH/LQH(3/(93/LVRIIHUHGIRUFRQQHFWLRQVEHWZHHQ
WZRORFDWLRQVZKLOH9LUWXDO3ULYDWH/$16HUYLFH93/6LVIRUFRQQHFWLRQVEHWZHHQ
RUPRUHORFDWLRQV
&$7&+352'8&7'(6&5,37,21
$771HWZRUN%DVHG,39315HPRWH$FFHVV$1,5$SURYLGHVVHFXUHDFFHVV
DFURVVWKH,QWHUQHWIRU6LQJOH8VHUVGLDOEURDGEDQGFHOOXODU*:,),:LUHG
(WKHUQHWXVLQJWKH$77*OREDO1HWZRUN&OLHQW$*1&DQGVPDOOPXOWLXVHUVLWHV
6R+R6PDOO2IILFH+RPH2IILFH$1,5$LVD1HWZRUN%DVHG5HPRWH$FFHVV,3
931VHUYLFH$1,5$FRQQHFWVWRDQH[LVWLQJ$77/D\HU9311HWZRUNV(931
$931,3H)5RU317YLDD3ULYDWH1HWZRUN&RQQHFWLRQ31&
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
7(&+12/2*<
1RUHFRUGVIRXQG
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
&DUERQ+LOO%XVLQHVV9RLFH*UDGH6HUYLFH6HULHV$FWLYH
:LUH&HQWHU
&5+/$/10
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
5HJXODWRU\-XULVGLFWLRQ
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
)51
3URMHFW'DWD6KHHW
&+%
*XLGHERRN5HIHUHQFH
$/39/*%%%862&
3-+;3-:;3-8;3-4;
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
9RLFH*UDGH6HUYLFH6HULHV
6HUYLFH'HVFULSWLRQ
$QDQDORJFKDQQHOIRUWKHWUDQVPLVVLRQRIDV\QFKURQRXVRUV\QFKURQRXVVHULDOGDWDDWUDWHVRIXSWRRU
.ESV2SWLRQDODUUDQJHPHQWVDUHDYDLODEOHIRUWUDQVPLVVLRQRIV\QFKURQRXVVHULDOGDWDUDWHVDWRU
.ESV$FFX3XOVHVHUYLFHLVDGLJLWDOVZLWFKHGVHUYLFHWKDWSURYLGHVIXOOGXSOH[NLORELWVSHUVHFRQG
LQIRUPDWLRQWUDQVSRUWYLDDVSHFLDOO\HTXLSSHGWZRZLUH$FFX3XOVH$FFHVV/LQH'DWD7UDQVSRUW$FFHVV&KDQQHO
6HUYLFHSURYLGHVWKHGDWDFKDQQHOIDFLOLWLHVEHWZHHQDFXVWRPHU
VSUHPLVHVDQGDFHQWUDORIILFH
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
6(59,&(',6&217,18$1&(
*XLGHERRN/LQN
KWWSFSUZHEDWWFRPSGIDOKSGI KWWSFSUZHEDWWFRPSGIDOKSGI
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
$776ZLWFKHG(WKHUQHW
$6(
&$7&+352'8&7
$1,5$2YHU%URDGEDQG
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWUR
DUHDZLWKDYDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WR
JURZDQGDGDSWDVWKHQHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV
*ESV*ESV&RPPLWWHG,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV
0ESVWR*ESV 6L[FODVVHVRIVHUYLFHRIIHULQJWKHULJKWSHUIRUPDQFH6/$IRU
\RXUDSSOLFDWLRQV(WKHUQHW3ULYDWH/LQH(3/(93/LVRIIHUHGIRUFRQQHFWLRQV
EHWZHHQWZRORFDWLRQVZKLOH 9LUWXDO3ULYDWH/$16HUYLFH93/6LVIRUFRQQHFWLRQV
EHWZHHQRUPRUHORFDWLRQV
&$7&+352'8&7'(6&5,37,21
$771HWZRUN%DVHG,39315HPRWH$FFHVV$1,5$SURYLGHVVHFXUHDFFHVV
DFURVVWKH,QWHUQHWIRU6LQJOH8VHUVGLDOEURDGEDQGFHOOXODU*:,),:LUHG
(WKHUQHWXVLQJWKH$77*OREDO1HWZRUN&OLHQW$*1&DQGVPDOOPXOWLXVHUVLWHV
6R+R6PDOO2IILFH+RPH2IILFH$1,5$LVD1HWZRUN%DVHG5HPRWH$FFHVV,3
931VHUYLFH$1,5$FRQQHFWVWRDQH[LVWLQJ$77/D\HU9311HWZRUNV(931
$931,3H)5RU317YLDD3ULYDWH1HWZRUN&RQQHFWLRQ31&
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHVZLWKDQ$77
&DWFK3URGXFW$YDLODEOHLQWKHLU6HUYLFH
$UHD
&203(7,725
1RUHFRUGVIRXQG
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
&RPSHWLWLYH$QDO\VLV
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
&DUERQ+LOO%XVLQHVV%HOO6RXWK&HQWUH[6HUYLFH0XOWL6HUY0XOWL6HUY3OXV0XOWL6HUY
0XOWL$FFRXQW$FWLYH
:LUH&HQWHU
&5+/$/10
5HJXODWRU\
-XULVGLFWLRQ
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
)51
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
&+%
*XLGHERRN5HIHUHQFH
3URGXFW'DWD6KHHW
$/*HQ([FKJ*%$862&
0$&&0$&60/)$0/)+0/6$0/)$00$
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
%HOO6RXWK&HQWUH[6HUYLFH0XOWL6HUY0XOWL6HUY3OXV0XOWL6HUY0XOWL$FFRXQW
6HUYLFH'HVFULSWLRQ
$KRVWHGSKRQHVHUYLFHZLWKDXVHUIULHQGO\LQWHUIDFHEXLOWLQUHGXQGDQF\DQGKRXUPRQLWRULQJDQG
PDLQWHQDQFH
&XVWRPHU1RWLFH3URGXFW*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
6(59,&(',6&217,18$1&(
*XLGHERRN/LQN
http://cpr.web.att.com/pdf/al/g012.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
1HZ3URGXFW%
&$7&+352'8&7
9'1$(
&$7&+352'8&7
2IILFH#+DQG
&$7&+352'8&7'(6&5,37,21
+RVWHG,3SURGXFWWKDWFRPELQHVORFDOYRLFHGRPHVWLF/'DQGEURDGEDQGZLWKWKHDELOLW\WR
EULQJ\RXURZQEURDGEDQGIURP$77RUDFRPSHWLWRU
&$7&+352'8&7'(6&5,37,21
$779RLFH'1$SURYLGHVDQHWZRUNKRVWHG6HVVLRQ,QLWLDWLRQ3URWRFRO6,3EDVHG
FRPPXQLFDWLRQVVROXWLRQ9RLFH'1$OHYHUDJHV$77SURYLGHGDFFHVVFRQYHUJLQJYRLFHDQG
GDWDDSSOLFDWLRQVRYHURQHFRQQHFWLRQSURYLGLQJRXUFXVWRPHUVZLWKFDUULHUFODVVIHDWXUHV
(OLPLQDWHVWKHQHHGIRUD3%;RU,33%;RQWKHFXVWRPHU¶VSUHPLVHV'HOLYHUVFRQVLVWHQW
IHDWXUHIXQFWLRQDOLW\DFURVVPXOWLORFDWLRQV1HWZRUNEDVHGDFFHVVIRUUHPRWHRIILFHVLVHDVLO\
DFKLHYHGZLWKDYDULHW\RIDFFHVVW\SHVVXSSRUWHG9LUWXDOO\DQ\ORFDWLRQFDQEHFRQQHFWHG
/HDGRIIHULQWKH&HQWUH[&XVWRPHUVSDFH
&$7&+352'8&7'(6&5,37,21
$FRPSOHWHFORXGEDVHGSKRQHV\VWHPIXOO\LQWHJUDWHG9R,3ZLWK%ULQJ<RXU2ZQ%URDGEDQG
%<2%+RVWHG3%;LQFOXGLQJORFDOYRLFH86DQG&DQDGD/')D[606DQGWROOIUHH
'HOLYHUHGZLWKDPRELOHILUVWFXVWRPHUH[SHULHQFHHQGWRHQG,QWHJUDWHG3OXJ5LQJ5HDG\,3
3KRQHVDQG6RIWSKRQHFOLHQWVDYDLODEOH%DFNGRZQRIIHUWR,3%DVHG2IIHUVLQ,3*UHHQ3276
DQG&HQWUH[FXVWRPHUV%DFNGRZQRIIHULQ,3UHGZLWKXVHUVQRUHTXLUHPHQWIRU$77
PDQDJHG,3VHUYLFHV
&$7&+352'8&7
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
1RUHFRUGVIRXQG
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
CarbonHillBusiness.ESV6HUYLFH'6.ESV6HUYLFH'6.ESV6HUYLFH'6
.ESV6HUYLFH'6.ESV6HUYLFH'6.ESV6HUYLFH$FWLYH
:LUH&HQWHU
&5+/$/10
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
5HJXODWRU\-XULVGLFWLRQ
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
)51
3URGXFW'DWD6KHHW
&+%
*XLGHERRN5HIHUHQFH
$/*HQ([J*%%862&,56
81/%%16)6
3URGXFW5HWLUHPHQW
6\QFKUR1HW6HUYLFH '6.ESV6HUYLFH'6.ESV6HUYLFH'6.ESV
6HUYLFHWREH'LVFRQWLQXHG
6HUYLFH'6.ESV6HUYLFH'6.ESV6HUYLFH'6.ESV6HUYLFH
6HUYLFH'HVFULSWLRQ
$FKDQQHOIRUWKHGLJLWDOWUDQVPLVVLRQRIV\QFKURQRXVVHULDOGDWDDWGLVFUHWHSRLQWWRSRLQWELWUDWHVRI.ESV
.ESV.ESV.ESV.ESVDQG.ESVVHUYLFH
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
&$7&+352'8&7
$776ZLWFKHG(WKHUQHW
$6(
&$7&+352'8&7
$1,5$2YHU%URDGEDQG
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
6(59,&(',6&217,18$1&(
*XLGHERRN/LQN
http://cpr.web.att.com/pdf/al/h007.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWUR
DUHDZLWKDYDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WR
JURZDQGDGDSWDVWKHQHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV
*ESV*ESV&RPPLWWHG,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV
0ESVWR*ESV6L[FODVVHVRIVHUYLFHRIIHULQJWKHULJKWSHUIRUPDQFH6/$IRU\RXU
DSSOLFDWLRQV(WKHUQHW3ULYDWH/LQH(3/(93/LVRIIHUHGIRUFRQQHFWLRQVEHWZHHQ
WZRORFDWLRQVZKLOH9LUWXDO3ULYDWH/$16HUYLFH93/6LVIRUFRQQHFWLRQVEHWZHHQ
RUPRUHORFDWLRQV
&$7&+352'8&7'(6&5,37,21
$771HWZRUN%DVHG,39315HPRWH$FFHVV$1,5$SURYLGHVVHFXUHDFFHVV
DFURVVWKH,QWHUQHWIRU6LQJOH8VHUVGLDOEURDGEDQGFHOOXODU*:,),:LUHG
(WKHUQHWXVLQJWKH$77*OREDO1HWZRUN&OLHQW$*1&DQGVPDOOPXOWLXVHUVLWHV
6R+R6PDOO2IILFH+RPH2IILFH$1,5$LVD1HWZRUN%DVHG5HPRWH$FFHVV,3
931VHUYLFH$1,5$FRQQHFWVWRDQH[LVWLQJ$77/D\HU9311HWZRUNV(931
$931,3H)5RU317YLDD3ULYDWH1HWZRUN&RQQHFWLRQ31&
1XPEHURI&XVWRPHUV
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH&DWFK
3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&203(7,725
1RUHFRUGVIRXQG
&RPSHWLWLYH$QDO\VLV
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
CarbonHillBusiness:0HJD/LQN,QWHJUDWLRQ3OXV0DQDJHPHQW6HUYLFHV,306$FWLYH
:LUH&HQWHU
&5+/$/10
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
5HJXODWRU\
7\SHRI
-XULVGLFWLRQ
5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
)51
3URGXFW'DWD6KHHW
&+%
*XLGHERRN5HIHUHQFH
$/39/**%$/*HQ([FJ*%$862&
/'3/1&&20*/98034:/'0//3-3
$3)$3)$$3)$$3)$$3)$$3)'$3)'$3)'
'6/:(
6HUYLFHWREH'LVFRQWLQXHG
3URGXFW5HWLUHPHQW
0HJD/LQN6HUYLFHLQFOXGHV0HJD/LQN&KDQQHO6HUYLFH0HJD/LQN3OXV6HUYLFH
0HJD/LQN/LJKW6HUYLFH,QWHJUDWLRQ3OXV0DQDJHPHQW6HUYLFHV,306
6HUYLFH'HVFULSWLRQ
$77/RFDO3ULYDWH/LQH6HUYLFHLVDGHGLFDWHGSULYDWHDQGVHFXUHSRLQWWRSRLQWFRQQHFWLYLW\EHWZHHQEXVLQHVV
ORFDWLRQVKRVWLQJFHQWHUVGDWDFHQWHUVDQGRWKHUVHUYLFHSURYLGHUVZLWKVDIHHIILFLHQWDQGUHOLDEOHFRPPXQLFDWLRQV
DW'6VSHHGVXVLQJ$77VQHWZRUN7KH,QWHJUDWLRQ3OXV0DQDJHPHQW6HUYLFHV7HUPLQDO,QWHUIDFHFKRVHQLV
XWLOL]HGZLWKHLWKHUDVZLWFKHGVHUYLFHSULYDWHOLQHVHUYLFHRUZHEDFFHVVVHUYLFHDVDPHDQVRIDFFHVVLQJ)OH[6HUY
VHUYLFH
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
&$7&+352'8&7
$776ZLWFKHG(WKHUQHW
$6(
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
6(59,&(',6&217,18$1&(
*XLGHERRN/LQN
KWWSFSUZHEDWWFRPSGIDOKSGI
KWWSFSUZHEDWWFRPSGIDOJSGI
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWURDUHD
ZLWKDYDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WRJURZDQG
DGDSWDVWKHQHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV*ESV
*ESV&RPPLWWHG,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV0ESVWR
*ESV6L[FODVVHVRIVHUYLFHRIIHULQJWKHULJKWSHUIRUPDQFH6/$IRU\RXUDSSOLFDWLRQV
(WKHUQHW3ULYDWH/LQH(3/(93/LVRIIHUHGIRUFRQQHFWLRQVEHWZHHQWZRORFDWLRQV
ZKLOH9LUWXDO3ULYDWH/$16HUYLFH93/6LVIRUFRQQHFWLRQVEHWZHHQRUPRUH
ORFDWLRQV
1XPEHURI&XVWRPHUV
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&203(7,725
1RUHFRUGVIRXQG
&RPSHWLWLYH$QDO\VLV
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
&DUERQ+LOO%XVLQHVV/LJKWJDWH6HUYLFH%HOO6RXWK:DYHOHQJWK6HUYLFH$FWLYH
:LUH&HQWHU
&5+/$/10
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
5HJXODWRU\-XULVGLFWLRQ
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
)51
3URGXFW'DWD6KHHW
&+%
*XLGHERRN5HIHUHQFH
$/39/*%%862&/'3/1
&&20*/98034:/'
0//3-3$3)$3)$$3)$
$3)$$3)$$3)'$3)'$3)'
'6/:
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
/LJKWJDWH6HUYLFH%HOO6RXWK:DYHOHQJWK6HUYLFH%DVLF$UUDQJHPHQW
6HUYLFH'HVFULSWLRQ
$77/RFDO3ULYDWH/LQH6HUYLFHLVDGHGLFDWHGSULYDWHDQGVHFXUHSRLQWWRSRLQWFRQQHFWLYLW\EHWZHHQEXVLQHVV
ORFDWLRQVKRVWLQJFHQWHUVGDWDFHQWHUVDQGRWKHUVHUYLFHSURYLGHUVZLWKVDIHHIILFLHQWDQGUHOLDEOHFRPPXQLFDWLRQV
DW'6VSHHGVXVLQJ$77¶VQHWZRUN%HOO6RXWK:DYHOHQJWKVHUYLFH%DVLF$UUDQJHPHQWSURYLGHVGHGLFDWHG
EDQGZLGWKRYHUVKDUHGIDFLOLWLHVLQSRLQWWRSRLQWVHUYLFHFRQILJXUDWLRQV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
&$7&+352'8&7
$776ZLWFKHG(WKHUQHW
$6(
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
6(59,&(',6&217,18$1&(
*XLGHERRN/LQN
http://cpr.web.att.com/pdf/al/h007.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWUR
DUHDZLWKDYDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WR
JURZDQGDGDSWDVWKHQHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV*ESV
*ESV&RPPLWWHG,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV0ESVWR
*ESV6L[FODVVHVRIVHUYLFHRIIHULQJWKHULJKWSHUIRUPDQFH6/$IRU\RXU
DSSOLFDWLRQV(WKHUQHW3ULYDWH/LQH(3/(93/LVRIIHUHGIRUFRQQHFWLRQVEHWZHHQ
WZRORFDWLRQVZKLOH9LUWXDO3ULYDWH/$16HUYLFH93/6LVIRUFRQQHFWLRQVEHWZHHQ
RUPRUHORFDWLRQV
1XPEHURI&XVWRPHUV
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH&DWFK
3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&203(7,725
1RUHFRUGVIRXQG
&RPSHWLWLYH$QDO\VLV
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
CarbonHillBusiness:)ODW5DWH0DLQ6WDWLRQ/LQH6HUYLFHLQGLYLGXDOOLQH%XVLQHVV)ODW5DWH$X[LOLDU\/LQH
6HUYLFH,QZDUG6HUYLFH%HOO6RXWK%XVLQHVV3OXV6HUYLFH&RPSOHWH&KRLFH)RU%XVLQHVV3DFNDJH$77
%XVLQHVV/RFDO&DOOLQJ$VVXUDQFH$77%XVLQHVV/RFDO&DOOLQJ%/&%HOO6RXWK%XVLQHVV&KRLFH3DFNDJH
/HJDO1DPHRI6HUYLFH
GED1DPHRI6HUYLFH
:LUH&HQWHU
3URGXFW'DWD6KHHW
3URYLGHU
3URYLGHU
%HOO6RXWK
$77$ODEDPD%HOO6RXWK
&5+/$/10
&+%
7HOHFRPPXQLFDWLRQV//& 7HOHFRPPXQLFDWLRQV//&
5HJXODWRU\-XULVGLFWLRQ
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
)51
*XLGHERRN5HIHUHQFH
$/*HQ([FKJ$$862&)%)%&/
0)%0)%&/)%)%&/0%2)%<0%
20%%)%)&/%)%)&/&20
3*293
3URGXFW5HWLUHPHQW
)ODW5DWH0DLQ6WDWLRQ/LQH6HUYLFHLQGLYLGXDOOLQH%XVLQHVV)ODW5DWH$X[LOLDU\/LQH
6HUYLFH,QZDUG6HUYLFH$/)/3DFNDJHV%HOO6RXWK%XVLQHVV3OXV6HUYLFH
6HUYLFHWREH'LVFRQWLQXHG
&RPSOHWH&KRLFH)RU%XVLQHVV3DFNDJH$77%XVLQHVV/RFDO&DOOLQJ$VVXUDQFH
$77%XVLQHVV/RFDO&DOOLQJ%/&%HOO6RXWK%XVLQHVV&KRLFH3DFNDJH
6HUYLFH'HVFULSWLRQ
$FODVVLILFDWLRQRIH[FKDQJHDFFHVVOLQHVHUYLFHIRUZKLFKDVWLSXODWHGFKDUJHLVPDGHUHJDUGOHVVRIWKHDPRXQWRI
XVH
&XVWRPHU1RWLFH3URGXFW*UDQGIDWKHU
*5$1')$7+(5
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
'LVDOORZ$GGV0RYHV&KDQJHV
*XLGHERRN/LQN
6(59,&(',6&217,18$1&(
http://cpr.web.att.com/pdf/fl/g003.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
&$7&+352'8&7
1HZ3URGXFW$
$OO'LVWDQFH86'RPHVWLF9R,3RIIHULQWHJUDWHGZLWKLQWKH,3%URDGEDQG,QFOXGHV
RYHUYRLFHIHDWXUHVSOXVFRQYHQLHQWZHEEDVHGFDOOPDQDJHPHQW2IIHUV
LQWHJUDWHGEXVLQHVVSKRQHDQGZLUHOHVVYRLFHPDLOIURPDVLQJOHPDLOER[
&$7&+352'8&7
1HZ3URGXFW%
&$7&+352'8&7'(6&5,37,21
+RVWHG,3SURGXFWWKDWFRPELQHVORFDOYRLFHGRPHVWLF/'DQGEURDGEDQGZLWKWKH
DELOLW\WREULQJ\RXURZQEURDGEDQGIURP$77RUDFRPSHWLWRU
&$7&+352'8&7
,3)OH[5HDFK
&$7&+352'8&7'(6&5,37,21
$QLQWHJUDWHGDFFHVVFRQYHUJHGVROXWLRQGHVLJQHGWRGHOLYHURXWERXQGLQERXQG
ORFDODQGORQJGLVWDQFHFDOOLQJRYHU$77
V,QWHUQHW3URWRFRO,3DQG9LUWXDO3ULYDWH
1HWZRUN931VHUYLFHV$OVRUHIHUUHGWRDVD6HVVLRQ,QLWLDWLRQ3URWRFRO6,3
7UXQNLQJVROXWLRQ'HSOR\HGLQVLWXDWLRQVZKHUHFXVWRPHUVRZQWKHLURZQSUHPLVHV
WHOHSKRQ\DQDORJSKRQHVNH\V\VWHP7'03%;RU,33%;HTXLSPHQW
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHUV
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH&DWFK
3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK3URGXFW
$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
&+$57(5&20081,&$7,216
+8*+(61(76$7(//,7(
',6+1(7:25.
',5(&796$7(//,7(
9HUL]RQ:LUHOHVV
6SULQW
70RELOH86$
7(&+12/2*<
&DEOH&'2:10ESV&830ESV
6$7(//,7(
:,5(/(66/7(
:,5(/(66*
:,5(/(66*
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
CarbonHillBusiness:)ODW5DWH6HUYLFH3%;7UXQNV%XVLQHVV&RPELQDWLRQ2XWGLDO,QZDUGRQO\','
'LUHFW,Q'LDO','&RPELQDWLRQ$FWLYH
/HJDO1DPHRI6HUYLFH
GED1DPHRI6HUYLFH
:LUH&HQWHU
3URGXFW'DWD6KHHW
3URYLGHU
3URYLGHU
%HOO6RXWK
$77$ODEDPD%HOO6RXWK
&5+/$/10
&+%
7HOHFRPPXQLFDWLRQV//& 7HOHFRPPXQLFDWLRQV//&
5HJXODWRU\-XULVGLFWLRQ
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
6HUYLFHWREH'LVFRQWLQXHG
)51
*XLGHERRN5HIHUHQFH
$/*HQ([FK*%$$$862&
7)&7)87)17'';7''&;7)%&;
3URGXFW5HWLUHPHQW
)ODW5DWH6HUYLFH3%;7UXQNV%XVLQHVV&RPELQDWLRQ2XWGLDO,QZDUGRQO\
',''LUHFW,Q'LDO','&RPELQDWLRQ
6HUYLFH'HVFULSWLRQ
$FODVVLILFDWLRQRIH[FKDQJHDFFHVVOLQHVHUYLFHIRUZKLFKDVWLSXODWHGFKDUJHLVPDGHUHJDUGOHVVRIWKHDPRXQW
RIXVH
&XVWRPHU1RWLFH3URGXFW*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*XLGHERRN/LQN
6(59,&(',6&217,18$1&(
KWWSFSUZHEDWWFRPSGIIOJSGI KWWSFSUZHEDWWFRPSGIDOJSGI
&$7&+352'8&7
1HZ3URGXFW$
&$7&+352'8&7
1HZ3URGXFW%
&$7&+352'8&7
,3)OH[5HDFK
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
$OO'LVWDQFH86'RPHVWLF9R,3RIIHULQWHJUDWHGZLWKLQWKH,3%URDGEDQG,QFOXGHVRYHU
YRLFHIHDWXUHVSOXVFRQYHQLHQWZHEEDVHGFDOOPDQDJHPHQW2IIHUVLQWHJUDWHG
EXVLQHVVSKRQHDQGZLUHOHVVYRLFHPDLOIURPDVLQJOHPDLOER[
&$7&+352'8&7'(6&5,37,21
+RVWHG,3SURGXFWWKDWFRPELQHVORFDOYRLFHGRPHVWLF/'DQGEURDGEDQGZLWKWKHDELOLW\
WREULQJ\RXURZQEURDGEDQGIURP$77RUDFRPSHWLWRU
&$7&+352'8&7'(6&5,37,21
$QLQWHJUDWHGDFFHVVFRQYHUJHGVROXWLRQGHVLJQHGWRGHOLYHURXWERXQGLQERXQGORFDO
DQGORQJGLVWDQFHFDOOLQJRYHU$77
V,QWHUQHW3URWRFRO,3DQG9LUWXDO3ULYDWH1HWZRUN
931VHUYLFHV$OVRUHIHUUHGWRDVD6HVVLRQ,QLWLDWLRQ3URWRFRO6,37UXQNLQJVROXWLRQ
'HSOR\HGLQVLWXDWLRQVZKHUHFXVWRPHUVRZQWKHLURZQSUHPLVHVWHOHSKRQ\DQDORJ
SKRQHVNH\V\VWHP7'03%;RU,33%;HTXLSPHQW
&$7&+352'8&7
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH&DWFK
3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77
&DWFK3URGXFW$YDLODEOHLQWKHLU
6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
7(&+12/2*<
&+$57(5&20081,&$7,216 &DEOH&'2:10ESV&830ESV
+8*+(61(76$7
(//,7(
',6+1(7:25.
6$7(//,7(
',5(&796$7
(//,7(
6SULQW
:,5(/(66*
70RELOH86$
:,5(/(66*
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
&DUERQ+LOO%XVLQHVV,QWHJUDWHG6HUYLFH'LJLWDO1HWZRUN,6'1,6'1%XVLQHVV,%6$FWLYH
:LUH&HQWHU
&5+/$/10
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
5HJXODWRU\-XULVGLFWLRQ
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
6HUYLFHWREH'LVFRQWLQXHG
)51
3URGXFW'DWD6KHHW
&+%
*XLGHERRN5HIHUHQFH
*HQ([FKJ*%$862& 0,
/4(:4$3(35/3
/7
3URGXFW5HWLUHPHQW
,QWHJUDWHG6HUYLFH'LJLWDO1HWZRUN,6'1,6'1%XVLQHVV,%6
6HUYLFH'HVFULSWLRQ
,6'1%XVLQHVV6HUYLFH,%6VXSSRUWVVLPXOWDQHRXVWUDQVPLVVLRQRIYRLFHGDWDDQGSDFNHWVHUYLFHVRQWKH
VDPHH[FKDQJHDFFHVVOLQH&DOOLQJ&DOOHG1XPEHU'HOLYHU\&DOOLQJ1DPH'HOLYHU\DQG&DOO+ROGDUHLQFOXGHG
ZLWKWKLVVHUYLFH,%6SURYLGHVDPHWKRGRIDFFHVVWRWKHWHOHSKRQHQHWZRUNFDOOHG%DVLF5DWH$FFHVV%DVLF5DWH
$FFHVVFRQVLVWVRIWKHDELOLW\WRDFFHVVXSWRWZR.ESV%FKDQQHOVDQGRQH.ESV'FKDQQHODWWKHVHUYLFH
GHOLYHU\SRLQW,%6LVSURYLGHGWKURXJK%DVLF5DWH$FFHVV)HDWXUHVDUHDYDLODEOHWRLQFUHDVHWKHFDSDELOLW\RIWKH
%HDUHU$OWHUQDWLYH6HUYLFHDQGPD\EHVXEVFULEHGWRRQDQDVQHHGHGEDVLV%FKDQQHOFLUFXLWVZLWFKHGVHUYLFHV
RIIHUXSWR.ESVLQWUDRIILFHWUDQVPLVVLRQRIYRLFHRUGDWD7KLVRSWLRQSHUPLWVWKHFXVWRPHUWRXWLOL]HHLWKHU
FLUFXLWYRLFHRUGDWDWUDQVPLVVLRQSDWKVRQDSHUFDOOVHOHFWLRQEDVLV7UDQVPLVVLRQRQWKH%FKDQQHOZLOOEHFLUFXLW
VZLWFKHGDW.ESVZLWKLQWKHVZLWFKDQGRUHTXLSSHGIDFLOLWLHVEHWZHHQ,6'1FRPSDWLEOHFHQWUDORIILFHV
&XVWRPHU1RWLFH3URGXFW*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*5$1')$7+(5
6(59,&(',6&217,18$1&(
'LVDOORZ$GGV0RYHV&KDQJHV
*XLGHERRN/LQN
http://cpr.web.att.com/pdf/fl/g042.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
$778YHUVHŠ+LJK6SHHG,QWHUQHW%XVLQHVV(GLWLRQSURYLGHVFXVWRPHUVZLWK
,QWHUQHWDFFHVV)HDWXUHVLQFOXGH6SHHGVXSWR0ESVGRZQVWUHDPDQGXSWR
8YHUVH+LJK6SHHG,QWHUQHW 0ESVXSVWUHDPDWDIUDFWLRQRIWKHFRVWRI3ULYDWH/LQHRU(WKHUQHW,QWHUQHWDFFHVV
%XVLQHVV(GLWLRQ
UHOLDELOLW\RSWLPDOSHUIRUPDQFHVFDODELOLW\DQGJUHDWVHFXULW\IHDWXUHVKLJKFDSDFLW\WR
VXSSRUWPXOWLSOHHPSOR\HHVWKDWQHHGVLPXOWDQHRXV,QWHUQHWDFFHVVWKHDELOLW\WR
VXSSRUWD:L)LQHWZRUNIRUHPSOR\HHVRUFXVWRPHUV
&$7&+352'8&7
1XPEHURI&XVWRPHUV
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&203(7,725
1RUHFRUGVIRXQG
&RPSHWLWLYH$QDO\VLV
7(&+12/2*<
3HUFHQW&RYHUHG
&DUERQ+LOO%XVLQHVV$77)DVW$FFHVV%XVLQHVV'6/LQFOXGHV'LUHFW'U\/RRSRSWLRQ
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
:LUH&HQWHU
&5+/$/10
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
5HJXODWRU\-XULVGLFWLRQ
7\SHRI5HJXODWLRQ
%RWK1RQ'RPLQDQW
6HUYLFHWREH'LVFRQWLQXHG
3URMHFW'DWD6KHHW
&%
)51
862&1RJXLGHERRNUHI
$'/
3URGXFW5HWLUHPHQW
$77)DVW$FFHVV%XVLQHVV'6/LQFOXGHV'LUHFW'U\/RRSRSWLRQ
6HUYLFH'HVFULSWLRQ
)DVW$FFHVVŠ%XVLQHVV'6/LVDGLJLWDOGDWDVHUYLFHWKDWOHWVWKHFXVWRPHUVHQGDQGUHFHLYHGDWDRYHUH[LVWLQJ
WHOHSKRQHOLQHV)DVW$FFHVVŠ%XVLQHVV'6/HQDEOHVWKHFXVWRPHUWRFRQQHFWWRWKH,QWHUQHWDWVSHHGVPXFKIDVWHU
WKDQDVWDQGDUGGLDOXSFRQQHFWLRQ:LWKGRZQVWUHDPVSHHGVRIXSWR0ESV)DVW$FFHVV%XVLQHVV'6/²WKH
IDVWHVWRSWLRQ²OHWVWKHFXVWRPHUTXLFNO\GRZQORDGILOHVYLHZJUDSKLFLQWHQVLYHZHEVLWHVDQGHYHQKDQGOHH
FRPPHUFHWUDQVDFWLRQV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
&$7&+352'8&7
8YHUVH+LJK6SHHG
,QWHUQHW%XVLQHVV(GLWLRQ
1XPEHURI&XVWRPHUV
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
6(59,&(
',6&217,18$1&(
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
$778YHUVHŠ+LJK6SHHG,QWHUQHW%XVLQHVV(GLWLRQSURYLGHVFXVWRPHUVZLWK
,QWHUQHWDFFHVV)HDWXUHVLQFOXGH6SHHGVXSWR0ESVGRZQVWUHDPDQGXSWR0ESV
XSVWUHDPDWDIUDFWLRQRIWKHFRVWRI3ULYDWH/LQHRU(WKHUQHW,QWHUQHWDFFHVVUHOLDELOLW\
RSWLPDOSHUIRUPDQFHVFDODELOLW\DQGJUHDWVHFXULW\IHDWXUHVKLJKFDSDFLW\WRVXSSRUW
PXOWLSOHHPSOR\HHVWKDWQHHGVLPXOWDQHRXV,QWHUQHWDFFHVVWKHDELOLW\WRVXSSRUWD:L
)LQHWZRUNIRUHPSOR\HHVRUFXVWRPHUV
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW
$Q$77&DWFK3URGXFW
1XPEHURI&XVWRPHU
/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD
&RPSHWLWLYH&DWFK3URGXFW
LQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW
$77RU&RPSHWLWLYH&DWFK
3URGXFW
1XPEHURI6HUYLFHVZLWKDQ
$77&DWFK3URGXFW
$YDLODEOHLQWKHLU6HUYLFH
$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
7(&+12/2*<
&+$57(5&20081,&$7,216 &DEOH&'2:10ESV&830ESV
+8*+(61(76$7
(//,7(
',6+1(7:25.
6$7(//,7(
',5(&796$7
(//,7(
9HUL]RQ:LUHOHVV
:,5(/(66/7(
6SULQW
:,5(/(66*
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King’s Point, Business Market Product
Data Sheets
PUBLIC VERSION
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW%XVLQHVV,QWHJUDWHG6HUYLFH'LJLWDO1HWZRUN,6'1,6'1%XVLQHVV,%6$FWLYH
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
'/%+)/.3
5HJXODWRU\
-XULVGLFWLRQ
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
)51
.3%
*XLGHERRN5HIHUHQFH
3URGXFW'DWD6KHHW
)/*HQ([FKJ*%$862&
0,/4(:4$3(35/3/7
3URGXFW5HWLUHPHQW
,QWHJUDWHG6HUYLFH'LJLWDO1HWZRUN,6'1,6'1%XVLQHVV,%6
6HUYLFHWREH'LVFRQWLQXHG
6HUYLFH'HVFULSWLRQ
,6'1%XVLQHVV6HUYLFH,%6VXSSRUWVVLPXOWDQHRXVWUDQVPLVVLRQRIYRLFHGDWDDQGSDFNHWVHUYLFHVRQWKHVDPHH[FKDQJH
DFFHVVOLQH&DOOLQJ&DOOHG1XPEHU'HOLYHU\&DOOLQJ1DPH'HOLYHU\DQG&DOO+ROGDUHLQFOXGHGZLWKWKLVVHUYLFH,%6SURYLGHVD
PHWKRGRIDFFHVVWRWKHWHOHSKRQHQHWZRUNFDOOHG%DVLF5DWH$FFHVV%DVLF5DWH$FFHVVFRQVLVWVRIWKHDELOLW\WRDFFHVVXSWRWZR
.ESV%FKDQQHOVDQGRQH.ESV'FKDQQHODWWKHVHUYLFHGHOLYHU\SRLQW,%6LVSURYLGHGWKURXJK%DVLF5DWH$FFHVV
)HDWXUHVDUHDYDLODEOHWRLQFUHDVHWKHFDSDELOLW\RIWKH%HDUHU$OWHUQDWLYH6HUYLFHDQGPD\EHVXEVFULEHGWRRQDQDVQHHGHGEDVLV
%FKDQQHOFLUFXLWVZLWFKHGVHUYLFHVRIIHUXSWR.ESVLQWUDRIILFHWUDQVPLVVLRQRIYRLFHRUGDWD7KLVRSWLRQSHUPLWVWKHFXVWRPHU
WRXWLOL]HHLWKHUFLUFXLWYRLFHRUGDWDWUDQVPLVVLRQSDWKVRQDSHUFDOOVHOHFWLRQEDVLV7UDQVPLVVLRQRQWKH%FKDQQHOZLOOEHFLUFXLW
VZLWFKHGDW.ESVZLWKLQWKHVZLWFKDQGRUHTXLSSHGIDFLOLWLHVEHWZHHQ,6'1FRPSDWLEOHFHQWUDORIILFHV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
6(59,&(',6&217,18$1&(
*XLGHERRN/LQN
http://cpr.web.att.com/pdf/fl/g042.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
&$7&+352'8&7'(6&5,37,21
$778YHUVHŠ+LJK6SHHG,QWHUQHW%XVLQHVV(GLWLRQSURYLGHVFXVWRPHUVZLWK
8YHUVH+LJK6SHHG,QWHUQHW
,QWHUQHWDFFHVV)HDWXUHVLQFOXGH6SHHGVXSWR0ESVGRZQVWUHDPDQGXSWR0ESV
%XVLQHVV(GLWLRQ
XSVWUHDPDWDIUDFWLRQRIWKHFRVWRI3ULYDWH/LQHRU(WKHUQHW,QWHUQHWDFFHVV
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH&DWFK
3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH3UHVHQFH
&203(7,725
&20&$67&25325$7,21
+8*+(61(76$7(//,7(
',5(&796$7(//,7(
',6+1(7:25.
9HUL]RQ:LUHOHVV
6SULQW
70RELOH86$
7(&+12/2*<
&DEOH&'2:10ESV&83.ESV
6$7(//,7(
:,5(/(66/7(
:,5(/(66*
:,5(/(66*
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW%XVLQHVV0HVVDJH5DWH6HUYLFH%XVLQHVV,QGLYLGXDO/LQH$FWLYH
:LUH&HQWHU
'/%+)/.3
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
7\SHRI5HJXODWLRQ
)51
5HJXODWRU\-XULVGLFWLRQ
,QWUDVWDWH'RPLQDQW
3URGXFW'DWD6KHHW
.3%
*XLGHERRN5HIHUHQFH
862&0%1RWLQ
*XLGHERRN
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
0HVVDJH5DWH6HUYLFH%XVLQHVV,QGLYLGXDO/LQH
6HUYLFH'HVFULSWLRQ
$FODVVLILFDWLRQRIH[FKDQJHVHUYLFHZKLFKLVFKDUJHGRQWKHEDVLVRIORFDOXVDJHDVGHWHUPLQHGE\WKHQXPEHURI
FDOOVSODFHG
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
6(59,&(',6&217,18$1&(
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
1HZ3URGXFW$
&$7&+352'8&7
1HZ3URGXFW%
&$7&+352'8&7
,3)OH[5HDFK
&$7&+352'8&7'(6&5,37,21
$OO'LVWDQFH86'RPHVWLF9R,3RIIHULQWHJUDWHGZLWKLQWKH,3%URDGEDQG,QFOXGHV
RYHUYRLFHIHDWXUHVSOXVFRQYHQLHQWZHEEDVHGFDOOPDQDJHPHQW2IIHUVLQWHJUDWHG
EXVLQHVVSKRQHDQGZLUHOHVVYRLFHPDLOIURPDVLQJOHPDLOER[
&$7&+352'8&7'(6&5,37,21
+RVWHG,3SURGXFWWKDWFRPELQHVORFDOYRLFHGRPHVWLF/'DQGEURDGEDQGZLWKWKH
DELOLW\WREULQJ\RXURZQEURDGEDQGIURP$77RUDFRPSHWLWRU
&$7&+352'8&7'(6&5,37,21
$QLQWHJUDWHGDFFHVVFRQYHUJHGVROXWLRQGHVLJQHGWRGHOLYHURXWERXQGLQERXQGORFDO
DQGORQJGLVWDQFHFDOOLQJRYHU$77
V,QWHUQHW3URWRFRO,3DQG9LUWXDO3ULYDWH
1HWZRUN931VHUYLFHV$OVRUHIHUUHGWRDVD6HVVLRQ,QLWLDWLRQ3URWRFRO6,3
7UXQNLQJVROXWLRQ'HSOR\HGLQVLWXDWLRQVZKHUHFXVWRPHUVRZQWKHLURZQSUHPLVHV
WHOHSKRQ\DQDORJSKRQHVNH\V\VWHP7'03%;RU,33%;HTXLSPHQW
&$7&+352'8&7
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
&20&$67&25325$7,21
+8*+(61(76$7
',5(&796$7
',6+1(7:25.
9HUL]RQ:LUHOHVV
6SULQW
70RELOH86$
7(&+12/2*<
&DEOH&'2:10ESV&83.ESV
(//,7(
(//,7(
6$7(//,7(
:,5(/(66/7(
:,5(/(66*
:,5(/(66*
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW%XVLQHVV0HVVDJH5DWH6HUYLFH%XVLQHVV7UXQNV$FWLYH
/HJDO1DPHRI6HUYLFH
3URYLGHU
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
%HOO6RXWK
7HOHFRPPXQLFDWLRQV
7HOHFRPPXQLFDWLRQV//&
//&
:LUH&HQWHU
'/%+)/.3
5HJXODWRU\-XULVGLFWLRQ
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
)51
3URGXFW'DWD6KHHW
.3%
*XLGHERRN5HIHUHQFH
)/*HQ([FKJ*%$
862&70&70708
70
3URGXFW5HWLUHPHQW
6HUYLFHWREH
'LVFRQWLQXHG
0HVVDJH5DWH6HUYLFH%XVLQHVV7UXQNV
6HUYLFH'HVFULSWLRQ
$FODVVLILFDWLRQRIH[FKDQJHVHUYLFHZKLFKLVFKDUJHGRQWKHEDVLVRIORFDOXVDJHDVGHWHUPLQHGE\WKHQXPEHURI
FDOOVSODFHG
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*XLGHERRN
6(59,&(',6&217,18$1&(
http://cpr.web.att.com/pdf/fl/g003.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
1HZ3URGXFW$
&$7&+352'8&7
1HZ3URGXFW%
&$7&+352'8&7
,3)OH[5HDFK
&$7&+352'8&7'(6&5,37,21
$OO'LVWDQFH86'RPHVWLF9R,3RIIHULQWHJUDWHGZLWKLQWKH,3%URDGEDQG,QFOXGHV
RYHUYRLFHIHDWXUHVSOXVFRQYHQLHQWZHEEDVHGFDOOPDQDJHPHQW2IIHUV
LQWHJUDWHGEXVLQHVVSKRQHDQGZLUHOHVVYRLFHPDLOIURPDVLQJOHPDLOER[
&$7&+352'8&7'(6&5,37,21
+RVWHG,3SURGXFWWKDWFRPELQHVORFDOYRLFHGRPHVWLF/'DQGEURDGEDQGZLWKWKH
DELOLW\WREULQJ\RXURZQEURDGEDQGIURP$77RUDFRPSHWLWRU
&$7&+352'8&7'(6&5,37,21
$QLQWHJUDWHGDFFHVVFRQYHUJHGVROXWLRQGHVLJQHGWRGHOLYHURXWERXQGLQERXQG
ORFDODQGORQJGLVWDQFHFDOOLQJRYHU$77
V,QWHUQHW3URWRFRO,3DQG9LUWXDO3ULYDWH
1HWZRUN931VHUYLFHV$OVRUHIHUUHGWRDVD6HVVLRQ,QLWLDWLRQ3URWRFRO6,3
7UXQNLQJVROXWLRQ'HSOR\HGLQVLWXDWLRQVZKHUHFXVWRPHUVRZQWKHLURZQSUHPLVHV
WHOHSKRQ\DQDORJSKRQHVNH\V\VWHP7'03%;RU,33%;HTXLSPHQW
&$7&+352'8&7
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
1RUHFRUGVIRXQG
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW%XVLQHVV6HOI+HDOLQJ0XOWL1RGDO$OWHUQDWH5RXWH7RSRORJ\5LQJ6PDUW5LQJ
6HUYLFH$FWLYH
:LUH&HQWHU
'/%+)/.3
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
7\SHRI5HJXODWLRQ
)51
5HJXODWRU\-XULVGLFWLRQ
,QWUDVWDWH'RPLQDQW
3URGXFW'DWD6KHHW
.3%
*XLGHERRNUHIHUHQFH
)/*HQ([FK*%%
862&
+96+15&&1
3URGXFW5HWLUHPHQW
6HOI+HDOLQJ0XOWL1RGDO$OWHUQDWH5RXWH7RSRORJ\5LQJ6PDUW5LQJ6HUYLFH
6HUYLFHWREH'LVFRQWLQXHG
6HUYLFH'HVFULSWLRQ
60$575LQJ621(7DUFKLWHFWXUHXVHVDGXDOILEHUVHOIKHDOLQJULQJZLWKDSULPDU\SDWKDQGDSURWHFWHGSDWK
+(/3,1*72SUHYHQWDQ\VLQJOHSRLQWRIIDLOXUH6HUYLFHDXWRPDWLFDOO\VZLWFKHVWRWKHSURWHFWHGSDWKLIWKHSULPDU\
SDWKIDLOV$OO5LQJVDUHDYDLODEOHLQWKHVWDQGDUGVSHHGV%DQGZLGWK6SHHGV2&2&2&2&
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV
&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*XLGHERRN
6(59,&(',6&217,18$1&(
http://cpr.web.att.com/pdf/fl/h007.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
1HZ3URGXFW(
&$7&+352'8&7
891
&$7&+352'8&7
$776ZLWFKHG(WKHUQHW
$6(
&$7&+352'8&7'(6&5,37,21
8OWUDYDLODEOH([SUHVVLVD':'0VHUYLFHWKDWZLOOUHSODFHWKHYDULRXV,/(&DQG7
&RUS621(75LQJSURGXFWV891([SUHVVSURYLGHVWKHUHOLDEOHDQGVFDODEOH5LQJ
VROXWLRQ
&$7&+352'8&7'(6&5,37,21
8OWUDYDLODEOHŠ1HWZRUN6HUYLFH891LVDIXOO\PDQDJHGKLJKVSHHGRSWLFDO
WUDQVSRUWVHUYLFHWKDWLQWHJUDWHV(WKHUQHW'HQVH:DYHOHQJWK'LYLVLRQ0XOWLSOH[LQJ
':'0DQG1DWLYH:DYHOHQJWKWHFKQRORJLHVLQWRDVLQJOHHQGWRHQGQHWZRUN
VROXWLRQ
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWUR
DUHDZLWKDYDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WR
JURZDQGDGDSWDVWKHQHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV
*ESV*ESV&RPPLWWHG,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV
0ESVWR*ESV
&$7&+352'8&7
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
&RPSHWLWLYH$QDO\VLV
&203(7,725
1RUHFRUGVIRXQG
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW%XVLQHVV6HULHV&KDQQHOV'DWD7UDQVSRUW$FFHVV&KDQQHO6HUYLFH$FWLYH
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
'/%+)/.3
5HJXODWRU\-XULVGLFWLRQ
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
)51
3URGXFW'DWD6KHHW
.3%
*XLGHERRN5HIHUHQFH
)/*HQ([FKJ*%%862&
+%:%+(/212
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
6HULHV&KDQQHOV'DWD7UDQVSRUW$FFHVV&KDQQHO6HUYLFH
6HUYLFH'HVFULSWLRQ
$QDQDORJFKDQQHOIRUWKHWUDQVPLVVLRQRIDV\QFKURQRXVRUV\QFKURQRXVVHULDOGDWDDWUDWHVRIXSWRRU
.ESV2SWLRQDODUUDQJHPHQWVDUHDYDLODEOHIRUWUDQVPLVVLRQRIV\QFKURQRXVVHULDOGDWDUDWHVDWRU
.ESV'DWD7UDQVSRUW$FFHVV&KDQQHO6HUYLFHSURYLGHVWKHGDWDFKDQQHOIDFLOLWLHVEHWZHHQDFXVWRPHU
V
SUHPLVHVDQGDFHQWUDORIILFHRUEHWZHHQWZRFHQWUDORIILFHV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV
&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
6(59,&(',6&217,18$1&(
*XLGHERRN
http://cpr.web.att.com/pdf/fl/h003.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
$776ZLWFKHG(WKHUQHW
$6(
&$7&+352'8&7
$1,5$2YHU%URDGEDQG
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWURDUHD
ZLWKDYDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WRJURZDQG
DGDSWDVWKHQHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV*ESV
*ESV&RPPLWWHG,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV0ESVWR*ESV
&$7&+352'8&7'(6&5,37,21
$771HWZRUN%DVHG,39315HPRWH$FFHVV$1,5$SURYLGHVVHFXUHDFFHVVDFURVV
WKH,QWHUQHWIRU6LQJOH8VHUVGLDOEURDGEDQGFHOOXODU*:,),:LUHG(WKHUQHWXVLQJ
WKH$77*OREDO1HWZRUN&OLHQW$*1&DQGVPDOOPXOWLXVHUVLWHV6R+R6PDOO2IILFH
+RPH2IILFH$1,5$LVD1HWZRUN%DVHG5HPRWH$FFHVV,3931VHUYLFH$1,5$
FRQQHFWVWRDQH[LVWLQJ$77/D\HU9311HWZRUNV(931$931,3H)5RU317YLD
D3ULYDWH1HWZRUN&RQQHFWLRQ31&
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
1RUHFRUGVIRXQG
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW%XVLQHVV9RLFH*UDGH6HUYLFH6HULHV$FWLYH
:LUH&HQWHU
'/%+)/.3
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
7\SHRI5HJXODWLRQ
DQW
)51
5HJXODWRU\-XULVGLFWLRQ
,QWUDVWDWH'RPLQ
3URGXFW'DWD6KHHW
.3%
*XLGHERRN5HIHUHQFH
)/*HQ([FKJ*%%
862&3-+;3-:;3-8;
3-4;70(&6
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
9RLFH*UDGH6HUYLFH6HULHV
6HUYLFH'HVFULSWLRQ
$QDQDORJFKDQQHOIRUWKHWUDQVPLVVLRQRIDV\QFKURQRXVRUV\QFKURQRXVVHULDOGDWDDWUDWHVRIXSWRRU
.ESV2SWLRQDODUUDQJHPHQWVDUHDYDLODEOHIRUWUDQVPLVVLRQRIV\QFKURQRXVVHULDOGDWDUDWHVDWRU
.ESV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
6(59,&(',6&217,18$1&(
*XLGHERRN/LQN
http://cpr.web.att.com/pdf/fl/h003.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
$776ZLWFKHG(WKHUQHW
$6(
&$7&+352'8&7
$1,5$2YHU%URDGEDQG
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWURDUHD
ZLWKDYDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WRJURZDQG
DGDSWDVWKHQHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV*ESV
*ESV&RPPLWWHG,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV0ESVWR
*ESV
&$7&+352'8&7'(6&5,37,21
$771HWZRUN%DVHG,39315HPRWH$FFHVV$1,5$SURYLGHVVHFXUHDFFHVVDFURVV
WKH,QWHUQHWIRU6LQJOH8VHUVGLDOEURDGEDQGFHOOXODU*:,),:LUHG(WKHUQHWXVLQJ
WKH$77*OREDO1HWZRUN&OLHQW$*1&DQGVPDOOPXOWLXVHUVLWHV6R+R6PDOO
2IILFH+RPH2IILFH$1,5$LVD1HWZRUN%DVHG5HPRWH$FFHVV,3931VHUYLFH
$1,5$FRQQHFWVWRDQH[LVWLQJ$77/D\HU9311HWZRUNV(931$931,3H)5RU
317YLDD3ULYDWH1HWZRUN&RQQHFWLRQ31&
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
1R5HFRUGVIRXQG
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King'sPointBusiness:BellSouthCentrexService(Active)
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
'/%+)/.3
5HJXODWRU\-XULVGLFWLRQ
,QWUDVWDWH'RPLQ
7\SHRI5HJXODWLRQ
DQW
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
)51
3URGXFW'DWD6KHHW
.3%
*XLGHERRN5HIHUHQFH
)/*HQ([FKJ*%$862&0$&&0$&6
0/)$0/)+0/6$0/)$00$
3URGXFW5HWLUHPHQW
%HOO6RXWK&HQWUH[6HUYLFH0XOWL6HUY0XOWL6HUY3OXV0XOWL6HUY0XOWL$FFRXQW
&HQWUH[&26HUYLFH(66;Š6HUYLFH9LQWDJH,,
6HUYLFHWREH'LVFRQWLQXHG
6HUYLFH'HVFULSWLRQ
$KRVWHGSKRQHVHUYLFHZLWKDXVHUIULHQGO\LQWHUIDFHEXLOWLQUHGXQGDQF\DQGKRXUPRQLWRULQJDQGPDLQWHQDQFH
*URXS$DQG%&HQWUH[&26HUYLFHV(66;ŠVHUYLFH([FKDQJH$FFHVV&KDUJH1HWZRUN$FFHVV/LPLWHU)ODW
5DWH0HVVDJH5DWHRU0HDVXUHG5DWH$1'(66;Š6HUYLFH96DQG67KH(66;ŠVHUYLFH96DQG6PDLQVWDWLRQ
OLQHUDWHZLOOEHFRPSRVHGRIWKHLQWHUFRPFKDUJHDQGWKHDSSURSULDWHZLUHFHQWHUOLQHFKDUJHRUHTXLYDOHQW
&XVWRPHU1RWLFH3URGXFW*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV
&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*XLGHERRNOLQN
6(59,&(',6&217,18$1&(
http://cpr.web.att.com/pdf/al/g112.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
1HZ3URGXFW%
&$7&+352'8&7'(6&5,37,21
+RVWHG,3SURGXFWWKDWFRPELQHVORFDOYRLFHGRPHVWLF/'DQGEURDGEDQGZLWKWKH
DELOLW\WREULQJ\RXURZQEURDGEDQGIURP$77RUDFRPSHWLWRU
&$7&+352'8&7
9'1$(
&$7&+352'8&7'(6&5,37,21
$779RLFH'1$SURYLGHVDQHWZRUNKRVWHG6HVVLRQ,QLWLDWLRQ3URWRFRO6,3EDVHG
FRPPXQLFDWLRQVVROXWLRQ9RLFH'1$OHYHUDJHV$77SURYLGHGDFFHVVFRQYHUJLQJ
YRLFHDQGGDWDDSSOLFDWLRQVRYHURQHFRQQHFWLRQSURYLGLQJRXUFXVWRPHUVZLWKFDUULHU
FODVVIHDWXUHV(OLPLQDWHVWKHQHHGIRUD3%;RU,33%;RQWKHFXVWRPHU¶VSUHPLVHV
'HOLYHUVFRQVLVWHQWIHDWXUHIXQFWLRQDOLW\DFURVVPXOWLORFDWLRQV1HWZRUNEDVHGDFFHVV
IRUUHPRWHRIILFHVLVHDVLO\DFKLHYHGZLWKDYDULHW\RIDFFHVVW\SHVVXSSRUWHG9LUWXDOO\
DQ\ORFDWLRQFDQEHFRQQHFWHG/HDGRIIHULQWKH&HQWUH[&XVWRPHUVSDFH
&$7&+352'8&7
&$7&+352'8&7'(6&5,37,21
9'1$(
$FRPSOHWHFORXGEDVHGSKRQHV\VWHPIXOO\LQWHJUDWHG9R,3ZLWK%ULQJ<RXU2ZQ
%URDGEDQG%<2%+RVWHG3%;LQFOXGLQJORFDOYRLFH86DQG&DQDGD/')D[606
DQGWROOIUHH'HOLYHUHGZLWKDPRELOHILUVWFXVWRPHUH[SHULHQFHHQGWRHQG,QWHJUDWHG
3OXJ5LQJ5HDG\,33KRQHVDQG6RIWSKRQHFOLHQWVDYDLODEOH%DFNGRZQRIIHUWR,3
%DVHG2IIHUVLQ,3*UHHQ3276DQG&HQWUH[FXVWRPHUV%DFNGRZQRIIHULQ,3UHG
ZLWKXVHUVQRUHTXLUHPHQWIRU$77PDQDJHG,3VHUYLFHV
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHUV
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
&20&$67&25325$7,21
+8*+(61(76$7(//,7(
',5(&796$7(//,7(
',6+1(7:25.
9HUL]RQ:LUHOHVV
6SULQW
70RELOH86$
7(&+12/2*<
&DEOH&'2:10ESV&83.ESV
6$7(//,7(
:,5(/(66/7(
:,5(/(66*
:,5(/(66*
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King'sPointBusiness:SynchroNetServiceͲDS0Ͳ19.2KbpsService;DS0Ͳ2.4KbpsService;DS0Ͳ4.8
KbpsService;DS0Ͳ19.2KbpsService;DS0Ͳ2.4KbpsService;DS0Ͳ4.8KbpsService;DS0Ͳ56Kbps
Service;DS0Ͳ64KbpsService;DS0Ͳ9.6KbpsService(Active)
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
'/%+)/.3
5HJXODWRU\-XULVGLFWLRQ
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
6HUYLFHWREH'LVFRQWLQXHG
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
)51
3URGXFW'DWD6KHHW
.3%
*XLGHERRN5HIHUHQFH
)/*HQ([FKJ*%%862&
,5681/%%16)6
3URGXFW5HWLUHPHQW
6\QFKUR1HW6HUYLFH'6.ESV6HUYLFH'6.ESV6HUYLFH'6
.ESV6HUYLFH'6.ESV6HUYLFH'6.ESV6HUYLFH'6.ESV
6HUYLFH'6.ESV6HUYLFH'6.ESV6HUYLFH'6.ESV6HUYLFH
6HUYLFH'HVFULSWLRQ
$FKDQQHOIRUWKHGLJLWDOWUDQVPLVVLRQRIV\QFKURQRXVVHULDOGDWDDWGLVFUHWHSRLQWWRSRLQWELWUDWHVRI.ESV
.ESV.ESV.ESV.ESVDQG.ESVVHUYLFH
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
$776ZLWFKHG(WKHUQHW
$6(
&$7&+352'8&7
$1,5$2YHU%URDGEDQG
*XLGHERRN/LQN
http://cpr.web.att.com/pdf/fl/h007.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWURDUHD
ZLWKDYDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WRJURZDQG
DGDSWDVWKHQHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV*ESV
*ESV&RPPLWWHG,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV0ESVWR
*ESV
&$7&+352'8&7'(6&5,37,21
$771HWZRUN%DVHG,39315HPRWH$FFHVV$1,5$SURYLGHVVHFXUHDFFHVVDFURVV
WKH,QWHUQHWIRU6LQJOH8VHUVGLDOEURDGEDQGFHOOXODU*:,),:LUHG(WKHUQHWXVLQJ
WKH$77*OREDO1HWZRUN&OLHQW$*1&DQGVPDOOPXOWLXVHUVLWHV6R+R6PDOO
2IILFH+RPH2IILFH$1,5$LVD1HWZRUN%DVHG5HPRWH$FFHVV,3931VHUYLFH
$1,5$FRQQHFWVWRDQH[LVWLQJ$77/D\HU9311HWZRUNV(931$931,3H)5RU
317YLDD3ULYDWH1HWZRUN&RQQHFWLRQ31&
1XPEHURI&XVWRPHUV
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&203(7,725
1RUHFRUGVIRXQG
6(59,&(',6&217,18$1&(
&$7&+352'8&7
'LVDOORZ$GGV0RYHV&KDQJHV
&RPSHWLWLYH$QDO\VLV
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King'sPointBusiness:MegaLinkService(includesMegaLinkChannelService,MegaLinkPlusService,
MegaLinkLightService),IntegrationPlusManagementServices(IPMS),SMARTPathService(Active)
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
'/%+)/.3
5HJXODWRU\
-XULVGLFWLRQ
)51
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
.3%
*XLGHERRN5HIHUHQFH
3URGXFW'DWD6KHHW
)/39/*%%862&
/'3/1&&20*/98034:/'0//3-3
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
0HJD/LQN6HUYLFHLQFOXGHV0HJD/LQN&KDQQHO6HUYLFH0HJD/LQN3OXV6HUYLFH
0HJD/LQN/LJKW6HUYLFH,QWHJUDWLRQ3OXV0DQDJHPHQW6HUYLFHV,30660$573DWK
6HUYLFH
6HUYLFH'HVFULSWLRQ
$77/RFDO3ULYDWH/LQH6HUYLFHLVDGHGLFDWHGSULYDWHDQGVHFXUHSRLQWWRSRLQWFRQQHFWLYLW\EHWZHHQEXVLQHVV
ORFDWLRQVKRVWLQJFHQWHUVGDWDFHQWHUVDQGRWKHUVHUYLFHSURYLGHUVZLWKVDIHHIILFLHQWDQGUHOLDEOHFRPPXQLFDWLRQV
DW'6VSHHGVXVLQJ$77
VQHWZRUN7KH,QWHJUDWLRQ3OXV0DQDJHPHQW6HUYLFHV7HUPLQDO,QWHUIDFHFKRVHQLV
XWLOL]HGZLWKHLWKHUDVZLWFKHGVHUYLFHSULYDWHOLQHVHUYLFHRUZHEDFFHVVVHUYLFHDVDPHDQVRIDFFHVVLQJ)OH[6HUY
VHUYLFH,3067,60$573DWKVHUYLFHLVDVHUYLFHIRUWUDQVPLVVLRQRIGLJLWDOVLJQDOVRQO\DQGXVHVRQO\GLJLWDO
WUDQVPLVVLRQIDFLOLWLHV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*XLGHERRN/LQN
6(59,&(',6&217,18$1&(
http://cpr.web.att.com/pdf/fl/h007.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
$776ZLWFKHG(WKHUQHW
$6(
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWUR
DUHDZLWKDYDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WR
JURZDQGDGDSWDVWKHQHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV*ESV
*ESV&RPPLWWHG,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV0ESVWR
*ESV6L[FODVVHVRIVHUYLFHRIIHULQJWKHULJKWSHUIRUPDQFH6/$IRU\RXU
DSSOLFDWLRQV(WKHUQHW3ULYDWH/LQH(3/(93/LVRIIHUHGIRUFRQQHFWLRQVEHWZHHQ
WZRORFDWLRQVZKLOH9LUWXDO3ULYDWH/$16HUYLFH93/6LVIRUFRQQHFWLRQVEHWZHHQ
RUPRUHORFDWLRQV
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
&20&$67&25325$7,21
+8*+(61(76$7
',5(&796$7
',6+1(7:25.
9HUL]RQ:LUHOHVV
6SULQW
70RELOH86$
7(&+12/2*<
&DEOH&'2:10ESV&83.ESV
(//,7(
(//,7(
6$7(//,7(
:,5(/(66/7(
:,5(/(66*
:,5(/(66*
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW%XVLQHVV/LJKWJDWH6HUYLFH$FWLYH
:LUH&HQWHU
'/%+)/.3
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
7\SHRI5HJXODWLRQ
)51
5HJXODWRU\-XULVGLFWLRQ
,QWUDVWDWH'RPLQDQW
3URGXFW'DWD6KHHW
.3%
*XLGHERRN5HIHUHQFH
)/39/*%%
862&+)634
/3/
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
/LJKWJDWH6HUYLFH
6HUYLFH'HVFULSWLRQ
$77/RFDO3ULYDWH/LQH6HUYLFHLVDGHGLFDWHGSULYDWHDQGVHFXUHSRLQWWRSRLQWFRQQHFWLYLW\EHWZHHQEXVLQHVV
ORFDWLRQVKRVWLQJFHQWHUVGDWDFHQWHUVDQGRWKHUVHUYLFHSURYLGHUVZLWKVDIHHIILFLHQWDQGUHOLDEOHFRPPXQLFDWLRQV
DW'6VSHHGVXVLQJ$77¶VQHWZRUN
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*XLGHERRN/LQN
6(59,&(',6&217,18$1&(
http://cpr.web.att.com/pdf/fl/h007.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
$776ZLWFKHG(WKHUQHW
$6(
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWUR
DUHDZLWKDYDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WR
JURZDQGDGDSWDVWKHQHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV
*ESV*ESV&RPPLWWHG,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV
0ESVWR*ESV6L[FODVVHVRIVHUYLFHRIIHULQJWKHULJKWSHUIRUPDQFH6/$IRU
\RXUDSSOLFDWLRQV(WKHUQHW3ULYDWH/LQH(3/(93/LVRIIHUHGIRUFRQQHFWLRQV
EHWZHHQWZRORFDWLRQVZKLOH9LUWXDO3ULYDWH/$16HUYLFH93/6LVIRUFRQQHFWLRQV
EHWZHHQRUPRUHORFDWLRQV
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
&20&$67&25325$7,21
+8*+(61(76$7
',5(&796$7
',6+1(7:25.
9HUL]RQ:LUHOHVV
6SULQW
70RELOH86$
7(&+12/2*<
&DEOH&'2:10ESV&83.ESV
(//,7(
(//,7(
6$7(//,7(
:,5(/(66/7(
:,5(/(66*
:,5(/(66*
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW%XVLQHVV)ODW5DWH6HUYLFH%XVLQHVV6HUYLFH$FWLYH
:LUH&HQWHU
/HJDO1DPHRI6HUYLFH3URYLGHU GED1DPHRI6HUYLFH3URYLGHU
%HOO6RXWK7HOHFRPPXQLFDWLRQV
$77)ORULGD%HOO6RXWK
//&
7HOHFRPPXQLFDWLRQV//&
'/%+)/.3
5HJXODWRU\
7\SHRI
-XULVGLFWLRQ
5HJXODWLRQ
,QWUDVWDWH'RPLQ
DQW
6HUYLFHWREH'LVFRQWLQXHG
)51
3URGXFW'DWD6KHHW
.3%
*XLGHERRN5HIHUHQFH
)/*HQ([FK*%$862&
)%)%&/0)%0)%&/)%)%&/0%2)%<0%20%%)%)&/
%)%)&/&203*293
3URGXFW5HWLUHPHQW
)/)ODW5DWH6HUYLFH%XVLQHVV6HUYLFH,QGLYLGXDO/LQH0XOWLOLQH([FKDQJH
$FFHVV/LQH$/)/)ODW5DWH$X[LOLDU\/LQH6HUYLFH,QZDUG6HUYLFH)/
2XWJRLQJ2QO\6HUYLFH$/)/3DFNDJHV%HOO6RXWK%XVLQHVV3OXV6HUYLFH
&RPSOHWH&KRLFH)RU%XVLQHVV3DFNDJH$77%XVLQHVV/RFDO&DOOLQJ$VVXUDQFH
$77%XVLQHVV/RFDO&DOOLQJ%/&%HOO6RXWK%XVLQHVV&KRLFH3DFNDJH
6HUYLFH'HVFULSWLRQ
$FODVVLILFDWLRQRIH[FKDQJHDFFHVVOLQHVHUYLFHIRUZKLFKDVWLSXODWHGFKDUJHLVPDGHUHJDUGOHVVRIWKHDPRXQWRI
XVH
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
&$7&+352'8&7
1HZ3URGXFW$
&$7&+352'8&7
1HZ3URGXFW%
&$7&+352'8&7
,3)OH[5HDFK
'LVDOORZ$GGV0RYHV&KDQJHV
*XLGHERRN/LQN
6(59,&(',6&217,18$1&(
http://cpr.web.att.com/pdf/fl/g003.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
$OO'LVWDQFH86'RPHVWLF9R,3RIIHULQWHJUDWHGZLWKLQWKH,3%URDGEDQG,QFOXGHV
RYHUYRLFHIHDWXUHVSOXVFRQYHQLHQWZHEEDVHGFDOOPDQDJHPHQW2IIHUV
LQWHJUDWHGEXVLQHVVSKRQHDQGZLUHOHVVYRLFHPDLOIURPDVLQJOHPDLOER[
&$7&+352'8&7'(6&5,37,21
+RVWHG,3SURGXFWWKDWFRPELQHVORFDOYRLFHGRPHVWLF/'DQGEURDGEDQGZLWKWKH
DELOLW\WREULQJ\RXURZQEURDGEDQGIURP$77RUDFRPSHWLWRU
&$7&+352'8&7'(6&5,37,21
$QLQWHJUDWHGDFFHVVFRQYHUJHGVROXWLRQGHVLJQHGWRGHOLYHURXWERXQGLQERXQG
ORFDODQGORQJGLVWDQFHFDOOLQJRYHU$77
V,QWHUQHW3URWRFRO,3DQG9LUWXDO3ULYDWH
1HWZRUN931VHUYLFHV$OVRUHIHUUHGWRDVD6HVVLRQ,QLWLDWLRQ3URWRFRO6,3
7UXQNLQJVROXWLRQ'HSOR\HGLQVLWXDWLRQVZKHUHFXVWRPHUVRZQWKHLURZQSUHPLVHV
WHOHSKRQ\DQDORJSKRQHVNH\V\VWHP7'03%;RU,33%;HTXLSPHQW
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
7(&+12/2*<
&20&$67&25325$7,21
&DEOH&'2:10ESV&83.ESV
+27:,5(&20081,&$7,216
&DEOH&'2:181.12:1&8381.12:1
+8*+(61(76$7(//,7(
',5(&796$7(//,7(
',6+1(7:25.
6$7(//,7(
9HUL]RQ:LUHOHVV
:,5(/(66/7(
6SULQW
:,5(/(66*
70RELOH86$
:,5(/(66*
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW%XVLQHVV)ODW5DWH6HUYLFH3%;7UXQNV%XVLQHVV$FWLYH
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
'/%+)/.3
5HJXODWRU\-XULVGLFWLRQ
3URGXFW'DWD6KHHW
3URGXFW'DWD6KHHW
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
.3%
7\SHRI5HJXODWLRQ
,QWUDVWDWH'RPLQDQW
)51
*XLGHERRN5HIHUHQFH
)/*HQ([FK*%$862&
7)&7)87)17'';7''&;7)%&;
3URGXFW5HWLUHPHQW
6HUYLFHWREH
'LVFRQWLQXHG
)ODW5DWH6HUYLFH3%;7UXQNV%XVLQHVV&RPELQDWLRQ2XWGLDO,QZDUGRQO\','
'LUHFW,Q'LDO','&RPELQDWLRQ
6HUYLFH'HVFULSWLRQ
$FODVVLILFDWLRQRIH[FKDQJHDFFHVVOLQHVHUYLFHIRUZKLFKDVWLSXODWHGFKDUJHLVPDGHUHJDUGOHVVRIWKHDPRXQWRI
XVH
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*XLGHERRNOLQN
6(59,&(',6&217,18$1&(
http://cpr.web.att.com/pdf/fl/g003.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7
1HZ3URGXFW$
&$7&+352'8&7'(6&5,37,21
$OO'LVWDQFH86'RPHVWLF9R,3RIIHULQWHJUDWHGZLWKLQWKH,3%URDGEDQG,QFOXGHV
RYHUYRLFHIHDWXUHVSOXVFRQYHQLHQWZHEEDVHGFDOOPDQDJHPHQW2IIHUV
LQWHJUDWHGEXVLQHVVSKRQHDQGZLUHOHVVYRLFHPDLOIURPDVLQJOHPDLOER[
&$7&+352'8&7
1HZ3URGXFW%
&$7&+352'8&7'(6&5,37,21
+RVWHG,3SURGXFWWKDWFRPELQHVORFDOYRLFHGRPHVWLF/'DQGEURDGEDQGZLWKWKH
DELOLW\WREULQJ\RXURZQEURDGEDQGIURP$77RUDFRPSHWLWRU
&$7&+352'8&7
,3)OH[5HDFK
&$7&+352'8&7'(6&5,37,21
$QLQWHJUDWHGDFFHVVFRQYHUJHGVROXWLRQGHVLJQHGWRGHOLYHURXWERXQGLQERXQG
ORFDODQGORQJGLVWDQFHFDOOLQJRYHU$77
V,QWHUQHW3URWRFRO,3DQG9LUWXDO3ULYDWH
1HWZRUN931VHUYLFHV$OVRUHIHUUHGWRDVD6HVVLRQ,QLWLDWLRQ3URWRFRO6,3
7UXQNLQJVROXWLRQ'HSOR\HGLQVLWXDWLRQVZKHUHFXVWRPHUVRZQWKHLURZQSUHPLVHV
WHOHSKRQ\DQDORJSKRQHVNH\V\VWHP7'03%;RU,33%;HTXLSPHQW
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
&20&$67&25325$7,21
+8*+(61(76$7
',5(&796$7
',6+1(7:25.
9HUL]RQ:LUHOHVV
6SULQW
70RELOH86$
7(&+12/2*<
&DEOH&'2:10ESV&83.ESV
(//,7(
(//,7(
6$7(//,7(
:,5(/(66/7(
:,5(/(66*
:,5(/(66*
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW%XVLQHVV$77)DVW$FFHVV%XVLQHVV'6/LQFOXGHV'LUHFW'U\/RRSRSWLRQ
:LUH&HQWHU
'/%+)/.3
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
7\SHRI5HJXODWLRQ
RPLQDQW
)51
5HJXODWRU\-XULVGLFWLRQ
%RWK1RQ'
6HUYLFHWREH'LVFRQWLQXHG
3URMHFW'DWD6KHHW
.3%
*XLGHERRN5HIHUHQFH
$'/
3URGXFW5HWLUHPHQW
$77)DVW$FFHVV%XVLQHVV'6/LQFOXGHV'LUHFW'U\/RRSRSWLRQ
6HUYLFH'HVFULSWLRQ
)DVW$FFHVVŠ%XVLQHVV'6/LVDGLJLWDOGDWDVHUYLFHWKDWOHWVWKHFXVWRPHUVHQGDQGUHFHLYHGDWDRYHUH[LVWLQJ
WHOHSKRQHOLQHV)DVW$FFHVVŠ%XVLQHVV'6/HQDEOHVWKHFXVWRPHUWRFRQQHFWWRWKH,QWHUQHWDWVSHHGVPXFKIDVWHU
WKDQDVWDQGDUGGLDOXSFRQQHFWLRQ:LWKGRZQVWUHDPVSHHGVRIXSWR0ESV)DVW$FFHVV%XVLQHVV'6/²WKH
IDVWHVWRSWLRQ²OHWVWKHFXVWRPHUTXLFNO\GRZQORDGILOHVYLHZJUDSKLFLQWHQVLYHZHEVLWHVDQGHYHQKDQGOHH
FRPPHUFHWUDQVDFWLRQV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
6(59,&(
',6&217,18$1&(
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
$778YHUVHŠ+LJK6SHHG,QWHUQHW%XVLQHVV(GLWLRQSURYLGHVFXVWRPHUVZLWK,QWHUQHW
DFFHVV)HDWXUHVLQFOXGH6SHHGVXSWR0ESVGRZQVWUHDPDQGXSWR0ESVXSVWUHDP
8YHUVH+LJK6SHHG,QWHUQHWDWDIUDFWLRQRIWKHFRVWRI3ULYDWH/LQHRU(WKHUQHW,QWHUQHWDFFHVVUHOLDELOLW\RSWLPDO
%XVLQHVV(GLWLRQ
SHUIRUPDQFHVFDODELOLW\DQGJUHDWVHFXULW\IHDWXUHVKLJKFDSDFLW\WRVXSSRUWPXOWLSOH
HPSOR\HHVWKDWQHHGVLPXOWDQHRXV,QWHUQHWDFFHVVWKHDELOLW\WRVXSSRUWD:L)L
QHWZRUNIRUHPSOR\HHVRUFXVWRPHUV
&$7&+352'8&7
1XPEHURI&XVWRPHUV
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW
$Q$77&DWFK3URGXFW
1XPEHURI&XVWRPHU
/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD
&RPSHWLWLYH&DWFK3URGXFW
LQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW
$77RU&RPSHWLWLYH&DWFK
3URGXFW
1XPEHURI6HUYLFHVZLWKDQ
$77&DWFK3URGXFW
$YDLODEOHLQWKHLU6HUYLFH
$UHD
&RPSHWLWLYH$QDO\VLV
7(&+12/2*<
&DEOH&'2:10ESV&83.ESV
&DEOH&'2:181.12:1&83
+27:,5(&20081,&$7,216
81.12:1
+8*+(61(76$7
(//,7(
',5(&796$7
(//,7(
',6+1(7:25.
6$7(//,7(
9HUL]RQ:LUHOHVV
:,5(/(66/7(
6SULQW
:,5(/(66*
70RELOH86$
:,5(/(66*
&203(7,25
&20&$67&25325$7,21
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW%XVLQHVV%DFN8S/LQHSHU/LQH%XVLQHVV3OXV6HUYLFH2SWLRQ%XVLQHVV
3OXV2SWLRQ(Grandfathered)
:LUH&HQWHU
'/%+)/.3
5HJXODWRU\-XULVGLFWLRQ
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
7\SHRI5HJXODWLRQ
)51
,QWUDVWDWH'RPLQDQW
6HUYLFHWREH'LVFRQWLQXHG
7ULDO7UDFNLQJ1XPEHU
.3%
*XLGHERRN5HIHUHQFH
)O*HQ([FKJ$862&
6%/);6%/26%/2
3URGXFW5HWLUHPHQW
%DFN8S/LQHSHU/LQH%XVLQHVV3OXV6HUYLFH2SWLRQ%XVLQHVV3OXV2SWLRQ
6HUYLFH'HVFULSWLRQ
%DFN8S/LQHLVDQRSWLRQDOVHUYLFHZKLFKSURYLGHVLQGLYLGXDOOLQHVXEVFULEHUVZLWKDQDGGLWLRQDOOLQHZKLFKLV
DYDLODEOHIRULQZDUGDQGDQGRXWZDUGFDOOLQJ8VDJHFKDUJHVDSSO\IRUDOOLQZDUGDQGRXWZDUGFDOOV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
&$7&+352'8&7
8YHUVH%XVLQHVV9RLFH
&$7&+352'8&7
1HZ3URGXFW%
&$7&+352'8&7
,3)OH[5HDFK
*5$1')$7+(5
6(59,&(
',6&217,18$1&(
'LVDOORZ$GGV0RYHV&KDQJHV
*XLGHERRN/LQN
http://cpr.web.att.com/pdf/fl/g103.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
$OO'LVWDQFH86'RPHVWLF9R,3RIIHULQWHJUDWHGZLWKLQWKH,3%URDGEDQG,QFOXGHV
RYHUYRLFHIHDWXUHVSOXVFRQYHQLHQWZHEEDVHGFDOOPDQDJHPHQW2IIHUV
LQWHJUDWHGEXVLQHVVSKRQHDQGZLUHOHVVYRLFHPDLOIURPDVLQJOHPDLOER[
&$7&+352'8&7'(6&5,37,21
+RVWHG,3SURGXFWWKDWFRPELQHVORFDOYRLFHGRPHVWLF/'DQGEURDGEDQGZLWKWKH
DELOLW\WREULQJ%URDGEDQGIURPXVRUDFRPSHWLWRU
&$7&+352'8&7'(6&5,37,21
$QLQWHJUDWHGDFFHVVFRQYHUJHGVROXWLRQGHVLJQHGWRGHOLYHURXWERXQGLQERXQG
ORFDODQGORQJGLVWDQFHFDOOLQJRYHU$77¢V,QWHUQHW3URWRFRO,3DQG9LUWXDO3ULYDWH
1HWZRUN931VHUYLFHV$OVRUHIHUUHGWRDVD6HVVLRQ,QLWLDWLRQ3URWRFRO6,3
7UXQNLQJVROXWLRQ'HSOR\HGLQVLWXDWLRQVZKHUHFXVWRPHUVRZQWKHLURZQSUHPLVHV
WHOHSKRQ\DQDORJSKRQHVNH\V\VWHP7'03%;RU,33%;HTXLSPHQW/HDGRIIHU
LQWKHOLQH3276&XVWRPHUVSDFH
&$7&+352'8&7
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q
$77&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD
&RPSHWLWLYH&DWFK3URGXFWLQ
WKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW
$77RU&RPSHWLWLYH&DWFK
3URGXFW
1XPEHURI6HUYLFHVZLWKDQ
$77&DWFK3URGXFW$YDLODEOH
LQWKHLU6HUYLFH$UHD
&203(7,7,9(&$7&+352'8&7
&20&$67&25325$7,21
+8*+(61(76$7(//,7(
',5(&796$7(//,7(
',6+1(7:25.
9HUL]RQ:LUHOHVV
6SULQW
70RELOH86$
&RPSHWLWLYH$QDO\VLV
&203(7,7,9(352'8&7'(6&5,37,21
3HUFHQW&RYHUHG
&DEOH&'2:10ESV&83.ESV
6$7(//,7(
:,5(/(66/7(
:,5(/(66*
:,5(/(66*
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King’s Point, Special Access
Product Data Sheets
PUBLIC VERSION
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJV3RLQW6SHFLDO$FFHVV'66HUYLFHV
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
'/%+)/.3
5HJXODWRU\
7\SHRI5HJXODWLRQ
-XULVGLFWLRQ
,QWHUVWDWH'RPLQ
DQW
6HUYLFHWREH'LVFRQWLQXHG±
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
)51
3URGXFW'DWD6KHHW
:6$
7DULII5HIHUHQFH7DULII1DPH6HFWLRQDQG
862&V
AT&TSoutheastFCCTariff1Section7
USOC:T6ECS
3URGXFW5HWLUHPHQW
9RLFH*UDGH'66HUYLFHVDQG.ESV/RFDO
&KDQQHOFRXQWV'6,2)0LOHDJHDQG0XOWLSOH[LQJLVDOVRWREHUHWLUHG
6HUYLFH'HVFULSWLRQ
'66HUYLFH$FKDQQHOIRUWKHWUDQVPLVVLRQRIORZVSHHGGDWDVLJQDOVDWVL[VHOHFWHGVSHHGV.ESV
.ESV.ESV.ESV.ESVDQG.ESV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*XLGHERRN/LQN
6(59,&(',6&217,18$1&(
http://cpr.att.com/pdf/fcc/1007b.pdf
&$7&+352'8&7
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWURDUHDZLWKD
YDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WRJURZDQGDGDSWDVWKH
$776ZLWFKHG(WKHUQHW$6(
QHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV*ESV*ESV&RPPLWWHG
,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV0ESVWR*ESV
&$7&+352'8&7
$1,5$2YHU%URDGEDQG
&$7&+352'8&71$0(
:LUHOHVV'DWD
&$7&+352'8&7'(6&5,37,21
$771HWZRUN%DVHG,39315HPRWH$FFHVV$1,5$SURYLGHVVHFXUHDFFHVVDFURVVWKH
,QWHUQHWIRU6LQJOH8VHUVGLDOEURDGEDQGFHOOXODU*:,),:LUHG(WKHUQHWXVLQJWKH$77
*OREDO1HWZRUN&OLHQW$*1&DQGVPDOOPXOWLXVHUVLWHV6R+R6PDOO2IILFH+RPH2IILFH
$1,5$LVD1HWZRUN%DVHG5HPRWH$FFHVV,3931VHUYLFH$1,5$FRQQHFWVWRDQH[LVWLQJ$77
/D\HU9311HWZRUNV(931$931,3H)5RU317YLDD3ULYDWH1HWZRUN&RQQHFWLRQ31&
&$7&+352'8&7'(6&5,37,21
3URGXFWLQGHYHORSPHQW
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI&XVWRPHU/RFDWLRQV:LWKRXW$Q
$77&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI&KDQQHO7HUPLQDWLRQV
1XPEHURI&XVWRPHU/RFDWLRQVZLWKDQ
$77&DWFK3URGXFW$YDLODEOHLQWKHLU
6HUYLFH$UHD
1XPEHURI&XVWRPHU/RFDWLRQVZLWKD
&RPSHWLWLYH&DWFK3URGXFWLQWKHLU6HUYLFH
$UHD
1XPEHURI&XVWRPHU/RFDWLRQV:LWKRXW
$77RU&RPSHWLWLYH&DWFK3URGXFW
&RPSHWLWLYH$QDO\VLV
&203(7,725
&20&$67&25325$7,21
+8*+(61(76$7
',5(&796$7
9HUL]RQ:LUHOHVV
7(&+12/2*<
&DEOH&'2:10ESV&83.ESV
(//,7(
(//,7(
/7(
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
KingsPointSpecialAccess:('63/6HUYLFHV
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
'/%+)/.3
5HJXODWRU\
7\SHRI
-XULVGLFWLRQ
5HJXODWLRQ
,QWHUVWDWH'RPLQ
DQW
)51
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
3URGXFW'DWD6KHHW
:6$
7DULII5HIHUHQFH7DULII1DPH6HFWLRQDQG862&V
AT&TSoutheastFCCTariff1Section7USOC:TMECS,
FloridaPVLGuidebookB7.3
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG±
'6/RFDO&KDQQHOV0LOHDJHDQG0XOWLSOH[LQJ
6HUYLFH'HVFULSWLRQ
'66HUYLFH$FKDQQHOIRUWKHWUDQVPLVVLRQRIGDWDVLJQDOVDW0ESVWKHVHUYLFHVFDQEHFKDQQHOL]HGLQWR
ORZHU'6VHUYLFHVRUPXOWLSOH[HGXSWRULGHDKLJKHUVSHHGVHUYLFH'6RU2&Q
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*XLGHERRN/LQN
6(59,&(',6&217,18$1&(
http://cpr.att.com/pdf/fcc/1007b.pdf
&$7&+352'8&7
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWURDUHDZLWKD
YDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WRJURZDQGDGDSWDVWKH
$776ZLWFKHG(WKHUQHW$6(
QHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV*ESV*ESV&RPPLWWHG
,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV0ESVWR*ESV
&$7&+352'8&7
$1,5$2YHU%URDGEDQG
&$7&+352'8&7'(6&5,37,21
$771HWZRUN%DVHG,39315HPRWH$FFHVV$1,5$SURYLGHVVHFXUHDFFHVVDFURVVWKH
,QWHUQHWIRU6LQJOH8VHUVGLDOEURDGEDQGFHOOXODU*:,),:LUHG(WKHUQHWXVLQJWKH$77
*OREDO1HWZRUN&OLHQW$*1&DQGVPDOOPXOWLXVHUVLWHV6R+R6PDOO2IILFH+RPH2IILFH
$1,5$LVD1HWZRUN%DVHG5HPRWH$FFHVV,3931VHUYLFH$1,5$FRQQHFWVWRDQH[LVWLQJ$77
/D\HU9311HWZRUNV(931$931,3H)5RU317YLDD3ULYDWH1HWZRUN&RQQHFWLRQ31&
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI&XVWRPHU/RFDWLRQV:LWKRXW
$Q$77&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI&XVWRPHU/RFDWLRQVZLWKD
&RPSHWLWLYH&DWFK3URGXFWLQWKHLU6HUYLFH
$UHD
1XPEHURI&XVWRPHU/RFDWLRQV:LWKRXW
$77RU&RPSHWLWLYH&DWFK3URGXFW
1XPEHURIFKDQQHO7HUPLQDWLRQV
1XPEHURI&XVWRPHU/RFDWLRQVZLWK
DQ$77&DWFK3URGXFW$YDLODEOHLQ
WKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
&20&$67&25325$7,21
+8*+(61(76$7
',6+1HWZRUN
',5(&796$7
9HUL]RQ:LUHOHVV
6SULQW*
7(&+12/2*<
&DEOH&'2:10ESV&83.ESV
(//,7(
6$7(//,7(
(//,7(
/7(
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJV3RLQW6SHFLDO$FFHVV'6/LJKWJDWH3/6HUYLFHV
:LUH&HQWHU
/HJDO1DPHRI6HUYLFH3URYLGHU GED1DPHRI6HUYLFH3URYLGHU
%HOO6RXWK7HOHFRPPXQLFDWLRQV
$77)ORULGD%HOO6RXWK
//&
7HOHFRPPXQLFDWLRQV//&
'/%+)/.3
5HJXODWRU\
7\SHRI5HJXODWLRQ
-XULVGLFWLRQ
,QWUDVWDWH'RPLQ
DQW
)51
3URGXFW'DWD6KHHW
:6$
7DULII5HIHUHQFH7DULII1DPH6HFWLRQDQG862&V
AT&TSoutheastFCCTariff1Section7.2.9,AT&T
GuidebookPart11Section7.2.9USOC:HTN,
1D3CA
3URGXFW5HWLUHPHQW
'62&2&2&DQG2&±/RFDO&KDQQHOV0LOHDJHDQG0XOWLSOH[LQJ
6HUYLFHWREH'LVFRQWLQXHG±
6HUYLFH'HVFULSWLRQ
/LJKW*DWH6HUYLFHLVDEDVLFILEHURSWLFEDVHGGLJLWDOVHUYLFH/LJKW*DWHVDUHVL]HGIURPD'6OHYHOWRDQ2&
OHYHODQGFDQSURYLGHFKDQQHOL]DWLRQFDSDELOLW\IRUWKHFXVWRPHULQSDFNDJHVEDVHGRQV\VWHPVFRQVLVWLQJRI'6
'66762&2&2&DQG2&FKDQQHOV/LJKW*DWHFDQDJJUHJDWHWUDIILFEHWZHHQDFXVWRPHU
SUHPLVHVDQGD&HQWUDO2IILFH
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
&$7&+352'8&7
$776ZLWFKHG(WKHUQHW$6(
'LVDOORZ$GGV0RYHV&KDQJHV
*XLGHERRN/LQN
6(59,&(',6&217,18$1&(
http://cpr.att.com/pdf/fcc/1007b.pdf
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
$6(RIIHUV(WKHUQHWFRQQHFWLYLW\IRUFXVWRPHUVZLWKPXOWLSOHORFDWLRQVLQDPHWURDUHDZLWKD
YDULHW\RIFRQILJXUDWLRQVWRPHHWWKHFXVWRPHU
VQHHGVZLWKIOH[LELOLW\WRJURZDQGDGDSWDVWKH
QHHGVFKDQJH3RUWVDUHRIIHUHGLQVL]HV0ESV*ESV*ESV&RPPLWWHG
,QIRUPDWLRQ5DWHEDQGZLGWKRIIHUHGLQVL]HV0ESVWR*ESV
&$7&+352'8&7
&$7&+352'8&7'(6&5,37,21
:DYH/HQJWK&KDQQHO6HUYLFH :&6DQG$'(ZLOOEHFDSDEOHRISURYLGHG'HGLFDWHGSRLQWWRSRLQW(WKHUQHWWUDQVPLVVLRQDW
:&6±)XWXUH$77'HGLFDWHG VSHHGVRI*ESV)XWXUHDQG*ESVRYHUDILEHURSWLFIDFLOLWLHV
(WKHUQHW$'(
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI&KDQQHO7HUPLQDWLRQV
1XPEHURI&XVWRPHU/RFDWLRQV
:LWKRXW$Q$77&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQVZLWKD
&RPSHWLWLYH&DWFK3URGXFWLQWKHLU
6HUYLFH$UHD
1XPEHURI&XVWRPHU/RFDWLRQV
:LWKRXW$77RU&RPSHWLWLYH&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQVZLWKDQ
$77&DWFK3URGXFW$YDLODEOHLQWKHLU
6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
&20&$67&25325$7,21
+8*+(61(76$7
',6+1HWZRUN
',5(&796$7
9HUL]RQ:LUHOHVV
6SULQW*
&20&$67&25325$7,21
7(&+12/2*<
&DEOH&'2:10ESV&83.ESV
(//,7(
6$7(//,7(
(//,7(
/7(
&DEOH&'2:10ESV&83.ESV
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
King’s Point, Wholesale: DSL
Transmission Service Product Data
Sheets
PUBLIC VERSION
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ¶V3RLQW:KROHVDOH'6/7UDQVPLVVLRQ6HUYLFH
:LUH&HQWHU
/HJDO1DPHRI6HUYLFH
3URYLGHU
GED1DPHRI6HUYLFH
3URYLGHU
3URGXFW'DWD6KHHW
'/%+)/.3
%HOO6RXWK7HOHFRPPXQLFDWLRQV
//&
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
'6/7UDQV
5HJXODWRU\-XULVGLFWLRQ
QDQD
7\SHRI5HJXODWLRQ
)51
QD
7DULII5HIHUHQFH
1$
3URGXFW5HWLUHPHQW
'6/7UDQVPLVVLRQ6HUYLFH
6HUYLFH'HVFULSWLRQ
7KH6HUYLFHLVSURYLGH GEHWZHHQWKH&X VWRPHU¶VGHVLJQDWHG(QG8VHUSUHPL VHVDQGWKH &XVWRPHU¶V
(QG8VHU$JJUHJDWLRQQHW ZRUN FRQQHFWLRQ,WXWLOL]HVDV\PP HWULFDO'6/WHFKQRORJ\RYHU WKHKLJK
IUHTXHQF\SRUWLRQRID'6/OLQH$'6/OLQHLVW KHSK\VLFDOIDFLOLW\EHWZHHQ$776RXWKHDVW¶V'6/$0
RUUHPRWHW HUPLQDOZKHUH D UHPRWHWH UPLQDOKD V EHHQL QVWDOOHGE\$776 RXWKHDVWDQ GWKH 1, '
ORFDWHGDWWKH(QG8VH USUHPLVHV³'6//LQH´ 7KH6HUYLFH UHTXLUHVDQLQ VHUYLFH$776RXWKHDVW
SURYLGHGUHWDLO(QG 8VHUSUHPLVHVH[FKDQJHOLQHIDFLOLW\³,Q6H UYLFH([FKDQ JH/LQH )DFLOLW\´$Q,Q
6HUYLFH([FKDQJH/LQH)DFLOLW\VKDOOP HDQWKH VHUYLQJ &HQWUDO2IILFHOLQHHTXLSPHQWDQG DOOWKHSODQW
IDFLOLWLHVXSWRDQGLQFOXGLQJWKH$77 6RXWKHDVWSURYLGHG1,'$776RXWKHDVWUHWDLQVRZQHUVKLSRI
WKH'6//LQH7KH6HUYLFHLVQRWDYDLODEOHRYHUXQEXQGOHGQHWZRUNHOHPHQWV³81(V´
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
6(59,&(',6&217,18$1&(
&$7&+352'8&71$0(
1$
'LVDOORZ$GGV0RYHV&KDQJHV
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK3URGXF
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH&DWFK
3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU&RPSHWLWLYH
&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH3UHVHQFH
&203(7,725
1R5HFRUGV)RXQG
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Local Wholesale Complete
Product Data Sheets
PUBLIC VERSION
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW:KROHVDOH/RFDO:KROHVDOH&RPSOHWH³/:&´
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
'/%+)/.3
5HJXODWRU\ 7\SHRI
)51
-XULVGLFWLRQ5HJXODWLRQ
,QWUDVWDWH 'RPLQDQW 6HUYLFHWREH'LVFRQWLQXHG±
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
3URGXFW'DWD6KHHW
:/:&
7DULII5HIHUHQFH7DULII1DPH6HFWLRQDQG862&V
/:&LVQRWRIIHUHGWKURXJKWDULIIEXWE\FRPPHUFLDOFRQWUDFW
&ODVVRIVHUYLFH862&VZLWKLQVHUYLFHXQLWV8(3%;8(35;8(39%
3URGXFW5HWLUHPHQW
/RFDO:KROHVDOH&RPSOHWH³/:&´7KH/:&VHUYLFHVWKDWH[LVWDQGVKDOOEH
UHWLUHGZLWKLQWKLVZLUHFHQWHUDUH/:&%XVLQHVV/:&5HVLGHQWLDODQG/:&
5HPRWH&DOO)RUZDUGLQJIRU%XVLQHVV
6HUYLFH'HVFULSWLRQ
/RFDO:KROHVDOH&RPSOHWH³/:&´LVDQHQGWRHQGZKROHVDOHDFFHVVOLQHWKDWDOORZVD&RPSHWLWLYH/RFDO
([FKDQJH&DUULHU³&/(&´WROHDVHIDFLOLWLHVRQDOLQHE\OLQHYDULDEOHEDVLVWRVHUYHHQGXVHUV,WSURYLGHVWKH
DELOLW\WRPDNHDQGUHFHLYHORFDOFDOOFDOOVDQGDFFHVVWRVZLWFKEDVHGYHUWLFDOIHDWXUHV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
1XPEHURI&XVWRPHUV
*XLGHERRN/LQN
KWWSVFOHFDWWFRPFOHFVKHOOFIP"V
HFWLRQ 1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
7%'
'HPDQG&RXQW
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH&DWFK
3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHV
6(59,&(',6&217,18$1&(
&$7&+352'8&71$0(
7%'
'LVDOORZ$GGV0RYHV&KDQJHV
1XPEHURI6HUYLFHV:LWKRXW$77RU&RPSHWLWLYH
&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&203(7,7,9(&$7&+352'8&7
&RPSHWLWLYH$QDO\VLV
&203(7,7,9(352'8&7'(6&5,37,21
3HUFHQW&RYHUHG
1R5HFRUGV)RXQG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
&DUERQ+LOO:KROHVDOH/RFDO:KROHVDOH&RPSOHWH³/:&´
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
&5+/$/10
5HJXODWRU\ 7\SHRI
)51
-XULVGLFWLRQ5HJXODWLRQ
,QWUDVWDWH 'RPLQDQW 6HUYLFHWREH'LVFRQWLQXHG±
VHUYLFHVWKDWIDOOXQGHUWKH
3URGXFWW\SHDUHOLVWHGKHUH
GED1DPHRI6HUYLFH
3URYLGHU
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
3URGXFW'DWD6KHHW
:/:&
7DULII5HIHUHQFH7DULII1DPH6HFWLRQDQG862&V
/:&LVQRWRIIHUHGWKURXJKWDULIIEXWE\FRPPHUFLDOFRQWUDFW
&ODVVRIVHUYLFH862&VZLWKLQVHUYLFHXQLWV8(3%;DQG8(35;
3URGXFW5HWLUHPHQW
/RFDO:KROHVDOH&RPSOHWH³/:&´7KH/:&VHUYLFHVWKDWH[LVWDQGVKDOOEHUHWLUHG
ZLWKLQWKLVZLUHFHQWHUDUH/:&%XVLQHVVDQG/:&5HVLGHQWLDO
6HUYLFH'HVFULSWLRQ
/RFDO:KROHVDOH&RPSOHWH³/:&´LVDQHQGWRHQGZKROHVDOHDFFHVVOLQHWKDWDOORZVD&RPSHWLWLYH/RFDO
([FKDQJH&DUULHU³&/(&´WROHDVHIDFLOLWLHVRQDOLQHE\OLQHYDULDEOHEDVLVWRVHUYHHQGXVHUV,WSURYLGHVWKH
DELOLW\WRPDNHDQGUHFHLYHORFDOFDOOFDOOVDQGDFFHVVWRVZLWFKEDVHGYHUWLFDOIHDWXUHV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
6(59,&(',6&217,18$1&(
&$7&+352'8&71$0(
7%'
'LVDOORZ$GGV0RYHV&KDQJHV
3ODQQHG'DWHRI)LQDO&XVWRPHU1RWLFH
RI6HUYLFH'LVFRQWLQXDQFH
*XLGHERRN/LQN
KWWSVFOHFDWWFRPFOHFVKHOOFIP"V
HFWLRQ 1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
7%'
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHVZLWKDQ$77
&DWFK3URGXFW$YDLODEOHLQWKHLU
6HUYLFH$UHD
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
&RPSHWLWLYH$QDO\VLV
&203(7,7,9(&$7&+352'8&7
1R5HFRUGV)RXQG
&203(7,7,9(352'8&7'(6&5,37,21
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
Wholesale Switched Access
Product Data Sheets
PUBLIC VERSION
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQWWholesale:SwitchedAccessFeatureGroupD
:LUH&HQWHU
'/%+)/.3
5HJXODWRU\
-XULVGLFWLRQ
%RWK
/HJDO1DPHRI6HUYLFH
3URYLGHU
GED1DPHRI6HUYLFH
3URYLGHU
Bellsouth
$77)ORULGD%HOO6RXWK
Telecommunications,LLC 7HOHFRPPXQLFDWLRQV//&
7\SHRI
5HJXODWLRQ
'RPLQDQW
)51
3URGXFW'DWD6KHHW
:6:,
7DULII5HIHUHQFH7DULII1DPH6HFWLRQDQG862&V
%(//6287+7(/(&20081,&$7,2167$5,)))&&12
6HFWLRQ'
%(//6287+7(/(&20081,&$7,216)/25,'$$&&(66
6(59,&(67$5,))6HFWLRQ'
3URGXFW5HWLUHPHQW
SwitchedAccess)HDWXUH*URXS'
6HUYLFHWREH'LVFRQWLQXHG
6HUYLFH'HVFULSWLRQ
%HOO6RXWK6:$)*'ZKLFKLVDYDLODEOHWRDOOFXVWRPHUVSURYLGHVWUXQNVLGHDFFHVVWR7HOHSKRQH&RPSDQ\HQG
RIILFHVZLWFKHVZLWKDQDVVRFLDWHGXQLIRUP;;;;DFFHVVFRGHIRUWKHFXVWRPHU
VXVHLQRULJLQDWLQJDQG
WHUPLQDWLQJFRPPXQLFDWLRQV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
6(59,&(',6&217,18$1&(
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&71$0(
&$7&+352'8&7'(6&5,37,21
,3,QWHUFRQQHFWLRQIRUH[FKDQJHRIWUDIILF3URYLGHVD,3LQWHUFRQQHFWLRQWRWKHFXVWRPHUIRUWKHH[FKDQJHRIWUDIILF
ZLWKDOO$779R,3HQG8VHUV
ZLWKDOO$779R,3HQGXVHUV
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77
&DWFK3URGXFW$YDLODEOHLQWKHLU
6HUYLFH$UHD
&203(7,725
1$
&RPSHWLWLYH$QDO\VLV
7(&+12/2*<
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQWWholesale:SwitchedAccessFeatureGroupB
:LUH&HQWHU
/HJDO1DPHRI6HUYLFH3URYLGHU GED1DPHRI6HUYLFH3URYLGHU
%HOO6RXWK7HOHFRPPXQLFDWLRQV
$77)ORULGD%HOO6RXWK
//&
7HOHFRPPXQLFDWLRQV//&
'/%+)/.3
5HJXODWRU\
-XULVGLFWLRQ
%RWK'RPLQ
7\SHRI
5HJXODWLRQ
DQW
)51
3URGXFW'DWD6KHHW
:6:,
7DULII5HIHUHQFH7DULII1DPH6HFWLRQDQG862&V
%(//6287+7(/(&20081,&$7,2167$5,)))&&12
6HFWLRQ%
%(//6287+7(/(&20081,&$7,216)/25,'$$&&(66
6(59,&(67$5,))6HFWLRQ%
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG
6ZLWFKHG$FFHVV)HDWXUH*URXS%
6HUYLFH'HVFULSWLRQ
%HOO6RXWK6:$)*%ZKLFKLVDYDLODEOHWRDOOFXVWRPHUVSURYLGHVWUXQNVLGHDFFHVVWR7HOHSKRQH&RPSDQ\HQG
RIILFHVZLWFKHVZLWKDQDVVRFLDWHGXQLIRUP;;;;DFFHVVFRGHIRUWKHFXVWRPHU
VXVHLQRULJLQDWLQJDQG
WHUPLQDWLQJFRPPXQLFDWLRQVWRDQ,QWHUH[FKDQJH&DUULHU
VLQWHUVWDWHVHUYLFHRUDFXVWRPHUSURYLGHGLQWHUVWDWH
FRPPXQLFDWLRQVFDSDELOLW\
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
&$7&+352'8&71$0(
QRQH
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
6(59,&(',6&217,18$1&(
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
1$
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$Q
$77&DWFK3URGXFW
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ
$77&DWFK3URGXFW$YDLODEOHLQ
WKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
7(&+12/2*<
3HUFHQW&RYHUHG
1$
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
.LQJ
V3RLQW:KROHVDOH6ZLWFKHG$FFHVV)HDWXUH*URXS$
:LUH&HQWHU
/HJDO1DPHRI6HUYLFH
3URYLGHU
GED1DPHRI6HUYLFH
3URYLGHU
3URGXFW'DWD6KHHW
'/%+)/.3
%HOO6RXWK7HOHFRPPXQLFDWLRQV
//&
$77)ORULGD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
:6:,
5HJXODWRU\
-XULVGLFWLRQ
%RWK
7\SHRI
5HJXODWLRQ
'RPLQDQW
)51
7DULII5HIHUHQFH7DULII1DPH6HFWLRQDQG862&V
%(//6287+7(/(&20081,&$7,2167$5,)))&&12
6HFWLRQ$
%(//6287+7(/(&20081,&$7,216)/25,'$$&&(66
6(59,&(67$5,))6HFWLRQ$
3URGXFW5HWLUHPHQW
6HUYLFHWREH'LVFRQWLQXHG±
VHUYLFHVWKDWIDOOXQGHUWKH
3URGXFWW\SHDUHOLVWHGKHUH
6ZLWFKHG$FFHVV)HDWXUH*URXS$
6HUYLFH'HVFULSWLRQ
%HOO6RXWK6:$)*$ZKLFKLVDYDLODEOHWRDOOFXVWRPHUVSURYLGHVOLQHVLGHDFFHVVWR7HOHSKRQH&RPSDQ\HQGRIILFHVZLWFKHVZLWK
DQDVVRFLDWHGVHYHQGLJLWORFDOWHOHSKRQHQXPEHUIRUWKHFXVWRPHU
VXVHLQRULJLQDWLQJDQGRUWHUPLQDWLQJFRPPXQLFDWLRQVWR
DQRWKHUFXVWRPHU
VLQWHUVWDWHVHUYLFHRUDFXVWRPHUSURYLGHGLQWHUVWDWHFRPPXQLFDWLRQVFDSDELOLW\
&XVWRPHU1RWLFH3URGXFW*UDQGIDWKHU
*5$1')$7+(5
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
&$7&+352'8&71$0(
1RQH
'LVDOORZ$GGV0RYHV&KDQJHV
6(59,&(',6&217,18$1&(
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH&DWFK
3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77
&DWFK3URGXFW$YDLODEOHLQWKHLU
6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,7257(&+12/2*<
1$
3HUFHQW&RYHUHG
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
&DUERQ+LOO:KROHVDOH6ZLWFKHG$FFHVV)HDWXUH*URXSD
:LUH&HQWHU
&5+/$/10
/HJDO1DPHRI6HUYLFH
3URYLGHU
%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
5HJXODWRU\ 7\SHRI
)51
-XULVGLFWLRQ5HJXODWLRQ
%RWK'RPLQ
DQW GED1DPHRI6HUYLFH
3URYLGHU
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//&
3URGXFW'DWD6KHHW
:6:,
7DULII5HIHUHQFH7DULII1DPH6HFWLRQDQG862&V
%(//6287+7(/(&20081,&$7,2167$5,)))&&126HFWLRQ'
%(//6287+7(/(&20081,&$7,216$/$%$0$$&&(666(59,&(67$5,))6HFWLRQ'
3URGXFW5HWLUHPHQW
6ZLWFKHG$FFHVV)HDWXUH*URXS'
6HUYLFHWREH'LVFRQWLQXHG±
VHUYLFHVWKDWIDOOXQGHUWKH
3URGXFWW\SHDUHOLVWHGKHUH
6HUYLFH'HVFULSWLRQ
%HOO6RXWK6:$)*'ZKLFKLVDYDLODEOHWRDOOFXVWRPHUVSURYLGHVWUXQNVLGHDFFHVVWR7HOHSKRQH&RPSDQ\HQGRIILFHVZLWFKHV
ZLWKDQDVVRFLDWHGXQLIRUP;;;;DFFHVVFRGHIRUWKHFXVWRPHU
VXVHLQRULJLQDWLQJDQGWHUPLQDWLQJFRPPXQLFDWLRQV
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
6(59,&(',6&217,18$1&(
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&71$0(
&$7&+352'8&7'(6&5,37,21
3URYLGHVD,3LQWHUFRQQHFWLRQWRWKHFXVWRPHUIRUWKHH[FKDQJHRIWUDIILFZLWKDOO$77
,3,QWHUFRQQHFWLRQIRU
H[FKDQJHRIWUDIILFZLWKDOO 9R,3HQGXVHUV
$779R,3HQG8VHUV
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77
&DWFK3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77&DWFK
3URGXFW$YDLODEOHLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
7(&+12/2*<
3HUFHQW&RYHUHG
1$
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
&DUERQ+LOO:KROHVDOH6ZLWFKHG$FFHVV)HDWXUH*URXS%
/HJDO1DPHRI6HUYLFH
GED1DPHRI6HUYLFH
3URYLGHU
3URYLGHU
%HOO6RXWK
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//& 7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
&5+/$/1056
5HJXODWRU\ 7\SHRI
)51
-XULVGLFWLRQ5HJXODWLRQ
%RWK'RPLQ
DQW 3URGXFW'DWD6KHHW
:6:,
7DULII5HIHUHQFH7DULII1DPH6HFWLRQDQG862&V
%(//6287+7(/(&20081,&$7,2167$5,)))&&126HFWLRQ%
%(//6287+7(/(&20081,&$7,216$/$%$0$$&&(666(59,&(67$5,))6HFWLRQ%
3URGXFW5HWLUHPHQW
6ZLWFKHG$FFHVV)HDWXUH*URXS%
6HUYLFHWREH'LVFRQWLQXHG±
6HUYLFH'HVFULSWLRQ
%HOO6RXWK6:$)*%ZKLFKLVDYDLODEOHWRDOOFXVWRPHUVSURYLGHVWUXQNVLGHDFFHVVWR7HOHSKRQH&RPSDQ\HQG
RIILFHVZLWFKHVZLWKDQDVVRFLDWHGXQLIRUP;;;;DFFHVVFRGHIRUWKHFXVWRPHU
VXVHLQRULJLQDWLQJDQG
WHUPLQDWLQJFRPPXQLFDWLRQVWRDQ,QWHUH[FKDQJH&DUULHU
VLQWHUVWDWHVHUYLFHRUDFXVWRPHUSURYLGHGLQWHUVWDWH
FRPPXQLFDWLRQVFDSDELOLW\
&XVWRPHU1RWLFH3URGXFW*UDQGIDWKHU
'LVDOORZ$GGV0RYHV
&KDQJHV
*5$1')$7+(5
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
6(59,&(',6&217,18$1&(
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&71$0(
QRQH
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH&DWFK
3URGXFWLQWKHLU6HUYLFH$UHD
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHVZLWKDQ$77
&DWFK3URGXFW$YDLODEOHLQWKHLU
6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
&203(7,725
7(&+12/2*<
3HUFHQW&RYHUHG
1$
EXHIBIT E -- PUBLIC VERSION -- PRODUCT DATA SHEETS
&DUERQ+LOO:KROHVDOH6ZLWFKHG$FFHVV)HDWXUH*URXS$
/HJDO1DPHRI6HUYLFH
GED1DPHRI6HUYLFH
3URYLGHU
3URYLGHU
%HOO6RXWK
$77$ODEDPD%HOO6RXWK
7HOHFRPPXQLFDWLRQV//& 7HOHFRPPXQLFDWLRQV//&
:LUH&HQWHU
&5+/$/1056
5HJXODWRU\ 7\SHRI
-XULVGLFWLRQ 5HJXODWLRQ
%RWK
'RPLQDQW
)51
3URGXFW'DWD6KHHW
:6:,
7DULII5HIHUHQFH7DULII1DPH6HFWLRQDQG862&V
%(//6287 +7(/(&20081,&$7,2167$5,)))&&126HFWLRQ
$
%(//6287+7(/(&20081,&$7,216$/$%$0$$&&(666(59,&(6
7$5,))6HFWLRQ$
3URGXFW5HWLUHPHQW
6ZLWFKHG$FFHVV)HDWXUH*URXS$
6HUYLFHWREH'LVFRQWLQXHG±
6HUYLFH'HVFULSWLRQ
%HOO6RXWK6:$)*$ZKLFKLVDYDLODEOHWRDOOFXVWRPHUVSURYLGHVOLQHVLGHDFFHVVWR7HOHSKRQH&RPSDQ\HQG
RIILFHVZLWFKHVZLWKDQDVVRFLDWHGVHYHQGLJLWORFDOWHOHSKRQHQXPEHUIRUWKHFXVWRPHU
VXVHLQRULJLQDWLQJDQGRU
WHUPLQDWLQJFRPPXQLFDWLRQVWRDQRWKHUFXVWRPHU
VLQWHUVWDWHVHUYLFHRUDFXVWRPHUSURYLGHGLQWHUVWDWH
FRPPXQLFDWLRQVFDSDELOLW\
&XVWRPHU1RWLFH3URGXFW
*UDQGIDWKHU
&XVWRPHU1RWLFH6HUYLFH
'LVFRQWLQXDQFH6XQVHW
&$7&+352'8&71$0(
1RQH
*5$1')$7+(5
'LVDOORZ$GGV0RYHV&KDQJHV
6(59,&(',6&217,18$1&(
1H[W*HQHUDWLRQ3URGXFW2IIHU
&$7&+352'8&7'(6&5,37,21
'HPDQG&RXQW
1XPEHURI&XVWRPHUV
1XPEHURI6HUYLFHV:LWKRXW$Q$77&DWFK
3URGXFW
1XPEHURI&XVWRPHU/RFDWLRQV
1XPEHURI6HUYLFHV:LWKRXW$77RU
&RPSHWLWLYH&DWFK3URGXFW
1XPEHURI6HUYLFHV
1XPEHURI6HUYLFHVZLWKDQ$77
&DWFK3URGXFW$YDLODEOHLQWKHLU
6HUYLFH$UHD
&203(7,725
1$
1XPEHURI6HUYLFHVZLWKD&RPSHWLWLYH
&DWFK3URGXFWLQWKHLU6HUYLFH$UHD
&RPSHWLWLYH$QDO\VLV
7(&+12/2*<
3HUFHQW&RYHUHG
Exhibit F
DearValuedCustomer,
AtAT&T,ourmostimportantjobismakingsurethattheconnectionsweofferourcustomersand
businessesaresafe,strongandreliable.AsanAT&TbusinesscustomerinCarbonHill,Alabama,your
experiencewithAT&Twillbemyhighestpriorityandamongthemostimportantprioritiesforour
company.
Moreofourbusinesscustomersareconnectingusingnewtechnologies–likewirelessandInternetͲbased
phones(thatis,phonesthatuseVoiceͲoverͲInternetͲProtocol—or“VoIP”—technology).Wewantto
makesurethatyouhaveaccesstothecommunicationstoolsyourbusinessneedstoseamlesslyconnect
withyourcustomersandtothenetworkofthefuture.
TheFederalCommunicationsCommission(FCC),thefederalagencythatregulatestelecommunications
services,hascalledoncompanieslikeAT&Ttosubmitproposalsforconductingtrialswherethese
connectionsandserviceswillberolledoutinacommunityandofferedtoconsumersandbusinesses,while
ensuringthevaluesofuniversalservice,competition,publicsafety,reliabilityandconsumerprotection
continuetobemet.
AT&ThasproposedtoincludeCarbonHill,AlabamaasoneoftwolocationsnationwideforamultiͲyeartrial
tobeoverseenbytheFCC.
AT&Twillworkresponsibly,openlyandtransparentlywithlocalandstategovernment,theFCC,andmost
importantly,withyouthroughoutthisprocess.Andallofthiswillbehappeningwhilethetraditional
telephonenetworkisstillinplace.Wearecommittedtomeetingandexceedingyourexpectations,while
alsogivingyouaccesstothebenefitsthatamodernnetworkprovidesyourbusinesswith.
Wewanttomakesurethatyouareinformedandcanbeinvolvedintheprocess.Wewillbeholding
meetingsandeventsthroughoutthecommunity.Formoreinformationonthose,oranythingelserelated
tothetrial,pleasevisitourwebsiteat:http://ip4carbonhill.att.com.Oryoucancallusat866Ͳ992Ͳ9357.
AsalifelongAlabaman,IampleasedthatCarbonHillwasselectedasoneofthetriallocationstohelp
ensurethatbusinessesacrossAmerica–includingthoseinsmalltownsandruralareas–haveaccesstothe
servicesmodernnetworkscandeliver.AT&TanditsAlabamaemployeesconsiderthemselvesapartofthe
fabricofthecommunitieswhereweliveandwork.Wearen’tjustprovidingaservicetoourcustomersand
businesses;weareconnectingourneighborsandcommunities.
Thankyouforyourbusiness.Welookforwardtoworkingwithyouonthisexcitingopportunityforour
customersandforourcompany.
Sincerely,
FredMcCallum,PresidentAT&TAlabama
Dear(INSERTCUSTOMERNAMEHERE),
AtAT&T,ourmostimportantjobismakingsurethattheconnectionsweofferourcustomersaresafe,
strongandreliable.Iamwritingtodaybecause,asanAT&TcustomerinCarbonHill,Alabama,your
experiencewithAT&Tisamongthemostimportantprioritiesforourcompany.
Moreofourcustomersarechoosingtoconnectusingnewertechnologies–likewirelessandInternetͲbased
phones(thatis,phonesthatuseVoiceͲoverͲInternetͲProtocol—or“VoIP”—technology)–thatdeliver
voice,Internetandvideoathomeandaway.
TheFederalCommunicationsCommission(FCC),thefederalagencythatregulatestelecommunications
service,hascalledoncompanieslikeAT&Ttosubmitproposalsforconductingtrialswherethese
connectionsandserviceswillberolledoutinacommunityandofferedtoconsumers,allwhileensuringthe
valuesofuniversalservice,competition,publicsafety,reliabilityandconsumerprotectioncontinuetobe
met.
IamwritingtosharethenewsthatAT&ThasproposedtoincludeCarbonHill,Alabamaasoneoftwo
locationsnationwideforamultiͲyeartrialthatwillbeoverseenbytheFCC.
AT&Twillworkresponsibly,openlyandtransparentlywithlocalandstategovernment,theFCC,and,most
importantly,withyouthroughoutthisprocess.Andallofthiswillbehappeningwhilethetraditional
telephonenetworkisstillinplace.Wearecommittedtomeetingandexceedingyourexpectations
regardingthebenefitsthatamodernnetworkprovides.Wewanttomakesureyouarekeptinformedand
canbeinvolved.Yourvoiceandexperiencewillhelpinformfutureeffortstorolloutthesetechnologiesto
cities,smalltownsandruralcommunitiesacrossAmerica.
MyteamandIwillbeheretoanswerquestions,andkeepyouposted.Wewillbeholdingmeetingsand
eventsthroughoutthecommunity.Formoreinformationonthose,oranythingelserelatedtothetrial,
pleasevisitourwebsiteat:http://ip4carbonhill.att.com.Oryoucancallusat:855Ͳ920Ͳ0066(inEnglish)
or855Ͳ920Ͳ0072(inSpanish).
AsalifelongAlabaman,IampleasedthatCarbonHillwasselectedasoneofthetriallocationstohelp
ensurethatcommunitiesacrossAmerica–includingsmalltownsandruralareas–haveaccesstothe
servicesmodernnetworkscandeliver.AT&TanditsAlabamaemployeesconsiderthemselvesapartofthe
fabricofthesecommunities.Weliveandworkhere,sendourchildrenandgrandchildrentolocalschools,
cheeronthelocalsportsteamsandshopatthelocalstores.Wearen’tjustprovidingaserviceto
customers;weareconnectingourneighborsandcommunities.
Thankyouforyourbusiness.Welookforwardtoworkingwithyouonthisexcitingopportunityforour
customersandforourcompany.
Sincerely,
FredMcCallum,PresidentAT&TAlabama
DearValuedCustomer,
Lastyear,IwashonoredtobenamedthePresidentofAT&TFlorida.AsanAT&TbusinesscustomerintheWest
DelrayBeachareaofFlorida,yourexperiencewiththecompanyismytoppriority.Wearecommittedto
providingsafe,strongandreliableconnectionsforourcustomersandbusinesses.Andyoursatisfactionisamong
themostimportantprioritiesforAT&T.
OurbusinessandresidentialcustomersareincreasinglyusingnewertechnologieslikewirelessandInternetͲ
basedserviceratherthantraditionalservices.
Weareinvestingandbuildingoutnewandenhancedconnectionsforourbusinesscustomerssothatyoucan
communicateusingnextͲgenerationproductsandapplications.Wearecommittedtoensuringthese
connectionsaresafe,strongandreliable.
TheFederalCommunicationsCommission(FCC),thefederalagencythatregulatestelecommunicationsservice,
hascalledoncompanieslikeAT&Ttosubmitproposalsforconductingtrialswherethesenewconnectionsand
serviceswillberolledoutinacommunityandofferedtoconsumersandbusinesses,allwhileensuringthe
valuesofuniversalservice,competition,publicsafety,reliabilityandconsumerprotectioncontinuetobemet.
AT&ThasproposedtoincludetheWestDelrayBeachareaofFloridaasoneoftwoU.S.locationsforamultiͲyear
trialtobeoverseenbytheFCC.Throughoutthetrialprocess,AT&Tiscommittedtoworkingopenlyand
transparentlywithourbusinesscustomers,localandstategovernment,andtheFCC.Thisprocesswilloccur
whilethetraditionaltelephonenetworkisstillinplace.
Wearecommittedtomeetingandexceedingyourexpectationsregardingthebenefitsthatamodernnetwork
provides.Wewanttomakesureyouarekeptinformedandcanbeinvolvedintheprocess.Yourvoiceand
experiencewillhelpshapefutureeffortstorolloutthesetechnologiestobusinessesacrossAmerica.
Wewillbeholdingmeetingsandtownhallsthroughoutthecommunity,watchforlocations,datesandtimes.
Formoreinformationontheseeventsandanythingelserelatedtothetrial,pleasevisit
http://ip4westdelraybeach.att.com.Oryoucanreachusat866Ͳ992Ͳ9357.
Wewanttomakesurethatourbusinesscustomers,nomattertheirsize,canbepartofthisprocess.
AT&TiscommittedtobringingFloridianstheconnectionsandtechnologytheywantandneed.Youaren’tjust
ourcustomers,youareourfriendsandneighbors,andourcommitmentreflectsthis.
ThankyouforbeinganAT&Tcustomer.Welookforwardtoworkingwithyouduringthisexcitingopportunity.
Sincerely,
JoeYork,PresidentAT&TFlorida
[Date]
Dear [Customer Name],
Last year, I was honored to be named the President of AT&T Florida. As an AT&T customer in the West Delray Beach area of Florida,
your experience with the company is my top priority. We are committed to providing safe, strong and reliable connections for our
customers. And your satisfaction is among the most important priorities for AT&T.
Our customers are increasingly using newer technologies – like wireless and Internet-based services that can deliver voice, Internet
and video at home and away. We are investing and building out new and enhanced connections for our customers so you can
communicate using next-generation products and applications. We are committed to ensuring that these connections are safe,
strong and reliable.
The Federal Communications Commission (FCC) the federal agency that regulates telecommunications service, has called on
companies like AT&T to submit proposals for conducting trials where these new connections and services will be rolled out in a
community and offered to consumers, all while ensuring the values of universal service, competition, public safety, reliability and
consumer protection continue to be met.
AT&T has proposed to include the West Delray Beach area of Florida as one of two locations for a multi-year trial to be overseen by
the FCC. This process will occur while the traditional telephone network is still in place. Throughout the trial process, AT&T is
committed to working openly and transparently with our customers, local and state government, and with the FCC.
We are committed to meeting and exceeding your expectations regarding the benefits that a modern network provides. We want to
make sure you are kept informed and can be involved. Your voice and experience will help shape future efforts to roll out these
technologies nationwide.
We want customers of all ages to take part in this process. Last year, we partnered with national and local organizations to host
events across the state where consumers had an opportunity to learn about new products and services. We will be holding events
like these in the West Delray Beach area as part of the trial.
We will be holding meetings and town halls throughout the community, watch for locations, dates and times. For more information
on these events and anything else related to the trial, please visit http://ip4westdelraybeach.att.com. Or you can reach us at 855920-0066 (in English) and 855-920-0072 (in Spanish).
AT&T is committed to bringing Floridians the connections and technology they want and need. You aren’t just our customers, you
are our friends and neighbors, and our commitment reflects this.
Thank you for being an AT&T customer. We look forward to working with you during this exciting opportunity for our customers and
for our company.
Signed,
Joe York, President AT&T Florida
Exhibit G
www.g3ict.org
G3ict Publications & Reports
EXHIBIT G
G3ict WHITE PAPER
Case Study White Paper Series
How a culture of inclusion and the adoption of
Universal Design at AT&T drive business processes to
serve persons with disabilities
Accessibility, Innovation
and Sustainability at AT&T
Global Initiative for Inclusive Information
and Communication Technologies
A Flagship Advocacy Initiative
of the United Nations Global Alliance
for ICT and Development
EXHIBIT G
G3ict WHITE PAPER
About G3ict
Acknowledgments
G3ict is an Advocacy Initiative of the United Nations Global Alliance
for ICT and Development, launched in December 2006 in cooperation
with the Secretariat for the Convention on the Rights of Persons with
Disabilities at UN DESA. Its mission is to facilitate and support the
implementation of the dispositions of the Convention on the Rights
of Persons with Disabilities promoting e-accessibility and assistive
technologies. G3ict participants include industry, the public sector,
academia and organizations representing persons with disabilities.
G3ict relies on an international network of ICT accessibility experts to
develop practical tools, evaluation methods and benchmarks for States
Parties and Disabled Persons Organizations to implement policies in
support of assistive technologies and e-accessibility. Since inception,
G3ict has organized or contributed to 79 awareness raising and capacity
building programs for policy makers in cooperation with international
organizations such as the ITU, UNESCO, UNITAR and the World
Bank. G3ict co-produces with ITU the “e-Accessibility Policy Toolkit for
Persons with Disabilities” (www.e-accessibilitytolkit.org) which is widely
used around the world by policy makers involved in the implementation
of the Convention on the Rights of Persons with Disabilities. For
additional information on G3ict, visit www.g3ict.org
G3ict wishes to express its sincere appreciation to AT&T for opening its door
to document this case study and to the many individuals and organizations
who participated in the data collection and multiple interviews conducted
during this inquiry. Our special appreciation goes to:
Susan Mazrui - Director - Global Public Policy
Tari Hartman Squire - Strategic Marketing Communications
Consultant - Disability Issues
Avalyn Jackson - Associate Director - Product Marketing
Aaron Bangor - Principal Member of Technical Staff - AT&T Labs
Jody Garcia - VP Consumer Sales & Service
Roman Smith - Director - Public Affairs
Elizabeth P Dixon - Lead HR Specialist
Diane Rodriguez - Area Manager - Regulatory Relations
Cecilia Martaus - General Attorney
Mark Witcher - General Attorney & Associate General Counsel
Rob Earnhardt - Mgr - Sales Execution
Bob Gorman - Director - Business Development
Brooks Newton - Technical Architect
Jason Whorton - Lead Technical Architect
Sam Fabens - VOX Global
Channing Barringer - VOX Global
Jay Wilpon - Executive Director - Tech Research
Amanda Stent - AT&T Research - Principal Member
of Technical Staff
AT&T’s Advisory Panel on Access & Aging (AAPAA)
AT&T Labs
Citizenship and Sustainability
Consumer Sales and Service
EcoSystem and Innovation
Global Public Policy
HR Diversity
G3ict editorial team: Francesca Cesa Bianchi, Nilofar Ansher, David Ross.
Design by Manuel Ortiz - www.modesignstudio.com
Special Mentions
This publication is intended for educational and informational purposes.
Reference to specific companies has been included solely to advance
these purposes and do not constitute and endorsement, sponsorship or
recommendation by G3ict. Trademarks or registered marks mentioned
in this White Paper include: AT&T™, Pantech BreEZe™, Android™,
Voluntary Product Accessibility Template® or VPAT®, Microsoft
Windows®, DiversityInc Top 50 Companies for Diversity®, Natural
Voices®, iPhone®, Bluetooth®, StarLines®, Blackberry®, Apple®,
iPad®, TuneWiki®.
© 2011 G3ict: Global Initiative for Inclusive Information and Communication
Technologies. All Rights Reserved.
1110 W. Peachtree Street, NW Atlanta, GA 30309-3609 – U.S.A.
EXHIBIT G
G3ict WHITE PAPER
Case Study: Accessibility, Innovation and Sustainability at AT&T
ix
Foreword
For aging adults and persons living with disabilities, as for everyone, communications are essential to increased productivity,
independent living, a sense of well-being and safety. Communications technology enables individuals with disabilities (and those
without) to participate in social, educational and economic activities; retrieve information; receive warnings from government
authorities in emergencies; and conduct a number of essential tasks that require access to phone or web services. Accessibility
of communications is vital for an ever larger population of customers. In the United States, 54 million persons are identified
by the U.S. Census Bureau as living with disabilities. Of those ages 65 and older, 52 percent live with a disability.
While accessibility is required by law, it is also an important element of a company’s citizenship and sustainability strategy,
as well as a market and employment opportunity. Many companies, however, have yet to fully integrate accessibility across
companywide business divisions and into their product development and services design. Accessibility is a complex, multifaceted discipline, one that can only be successfully implemented with the full participation and engagement of a number of
business functions in large organizations and buy-in from senior leadership.
This case study describes how AT&T has integrated accessibility into its activities, from product development, human resources
and talent retention to recruitment, marketing and customer service. As is often the case, AT&T’s achievements result from
a combination of factors: a rich history of developing products for persons with disabilities that dates back to the company’s
founder, a clearly defined set of citizenship and sustainability objectives, a commitment to Universal Design and, perhaps
most importantly, a desire to involve persons with disabilities in these internal processes.
Our sincere appreciation goes to AT&T for opening its doors to G3ict and for sharing its experience with other corporations,
disability and aging organizations, and the many stakeholders involved in promoting the accessibility of information and
communication technologies.
Axel Leblois
Executive Director, G3ict
EXHIBIT G
G3ict WHITE PAPER
EXHIBIT G
G3ict WHITE PAPER
CONTENTS
02 Why Accessibility Matters
02
Key Facts
02
How is Disability Measured?
03
Question: What is Disability?
03
Universal Design
04 The Inner Workings of Accessible Product Design at AT&T
04
Managing Accessibility along the Product Development Cycle
05
How the Human Factors Group Works at AT&T
06
Addressing Customers’ Diverse Abilities
06
Enhancing Web Site Accessibility
06
Universal Design at AT&T
09 How a Culture of Inclusion and Sustainability Supports Accessibility
10
AT&T’s Advisory Panel on Access and Aging (AAPAA)
10
Citizenship & Sustainability Expert Team – Access and Aging
11
Recruiting and Career Advancements for Persons with Disabilities
13
Early Accessibility Milestones
13
Accessibility Innovation: A Continuous Process
16 A New Frontier for Accessible and Assistive Mobile Phones
16
From Blueprint to Market: Accessibility in a Product Life Cycle
17
AT&T’s Mobile Accessibility and Assistive Technologies at a Glance
18 Making Customer Service Work for Persons with Disabilities and Aging Adults
18
Communications and Points of Sale
19
Customized Services for Persons with Disabilities
20
The AT&T National Center for Customers with Disabilities
21
Serving Persons with Disabilities: Involving All Employees
22 Using Innovation for Accessibility: iPhone and Smart Phone Features for Persons with Disabilities
24 Conclusion
EXHIBIT G
G3ict WHITE PAPER
02
Case Study: Accessibility, Innovation and Sustainability at AT&T
Why Accessibility Matters
Key Facts
At AT&T, knowledge of demographic realities is a key component
of promoting Universal Design and assistive functionalities for
products and services, and an integral part of the company’s
sustainability strategy:
Among ages 65 and older
Persons with disabilities in the United States
Among ages 80 and older
° 54.4 million, or 17 percent of the population, on the rise
from previous U.S. Census (2002)
° 35 million (12 percent) with a severe disability
° 69 percent of those ages 21 – 64 with a severe disability
are unemployed
° 30 percent of households have a family member with
disabilities
° 71 percent had a disability, including 56 percent who have
a severe disability.
Among persons 15 and older
How is Disability Measured?
° 7.8 million (3 percent) had difficulty hearing a regular
conversation, with 1 million unable to hear at all. 4.3 million
persons reported using a hearing aid.
° 3.3 million persons (1 percent) ages 15 and older used a
wheelchair or similar device, with 10.2 million (4 percent)
using a cane, crutches or walker.
° 7.8 million had difficulty seeing words or letters in ordinary
newspaper print, including 1.8 million who were completely
unable to see.
° More than 16 million had difficulty with cognitive, mental or
emotional functioning.
The U.S. Census Bureau was among the first government
agencies in the world to shift the measurement of disability
away from the outdated medical model and to adopt functional
measurements of disability, which provide far more accurate
disability demographics. Questions are asked about an
individual’s ability to perform certain tasks, rather than
asking to disclose medical conditions. For example, aging
adults with macular degeneration who lose central vision
may not be able to read a mobile phone screen. However,
because their peripheral vision remains, they would not
self-report as “blind” in the context of a traditional survey or
questionnaire. The new methodology identifies such disabilities
with questions about one’s ability to read a newspaper.
° 52 percent had a disability and 37 percent have a severe
disability.
Source: Matthew W. Brault, Americans with Disabilities: 2005, Current
Population Reports, P70-117, U.S. Census Bureau, Washington, DC. 2008.
See www.census.gov/prod/2008pubs/p70-117.pdf
EXHIBIT G
G3ict WHITE PAPER
03
Case Study: Accessibility, Innovation and Sustainability at AT&T
AT&T Executive, Susan Mazrui (Global Public Policy), presenting at the
NDI REI Tour National Press Club Kick Off event, October 2010.
Left to right: Gregg Vanderheiden (University of Wisconsin-Madison), Susan
Mazrui (Global Public Policy), Tari Hartman Squire (AT&T Consultant) and Larry
Goldberg (AAPAA member, WGBH National Center for Accessible Media) at
the White House for the ADA 20th anniversary celebration event, July 2010.
Question: What is Disability?
Universal Design
According to the Preamble of the United Nations Convention on
the Rights of Persons with Disabilities, signed as of December
2010 by 144 countries including the United States, “Disability
is an evolving concept. It results from the interaction between
persons with impairments and attitudinal and environmental
barriers that hinders their full and effective participation in society
on an equal basis with others.” Over the past two decades,
this social definition of disability has been universally endorsed
around the world, while the medical definition, which focuses
solely on a person’s impairment, has been abandoned. It implies
that society at large is responsible for eliminating barriers to
access and ensuring full participation of persons living with
disabilities. Disability is viewed as the intersection of the person
and the built, electronic, or attitudinal environment.
The Convention on the Rights of Persons with Disabilities states:
“Universal Design” means the design of products, environments,
programmes and services to be usable by all people, to the greatest
extent possible, without the need for adaptation or specialized design.
“Universal Design” shall not exclude assistive devices for particular
groups of persons with disabilities where this is needed. (Article 2)
States Parties undertake or promote research and development
of universally designed goods, services, equipment and facilities,
as defined in Article 2 of the present Convention, which should
require the minimum possible adaptation and the least cost to
meet the specific needs of a person with disabilities, to promote
their availability and use, and to promote Universal Design in
the development of standards and guidelines. (Article 4.1.f)
“Universal Design” means the design of products, environments, programmes and
services to be usable by all people, to the greatest extent possible, without the
need for adaptation or specialized design.”
EXHIBIT G
G3ict WHITE PAPER
04
Case Study: Accessibility, Innovation and Sustainability at AT&T
The Inner Workings of Accessible
Product Design at AT&T
Managing Accessibility along the Product Development Cycle
Making technology work for all requires a disciplined approach
to product design. Evaluating a product’s accessibility at an
early stage of its development significantly reduces the cost
of providing accessible features. Retrofitting a non-accessible
product can be very expensive, when it is even possible. This
is why, from the conception of a product or service, AT&T
applies user-centered design. User-centered design calls for
a deep knowledge and understanding of human factors, or
how individuals with different mixes of abilities, needs and
limitations interact with their environment.
° Who users are
° What users want
° What users know
° How users work
° User capabilities
° User limitations
User Centric Design and Development: Start with the user;
Design and Development; End with the user.
This approach includes tools that help product development
teams evaluate the accessibility and usability of products. For
example, one of the components in AT&T’s standard project
process is to identify Universal Design requirements using
accessibility checklists, which prompt the product development
teams to think about how a person with a disability might
use their product. Their evaluation is then entered into the
checklists and becomes part of the official documentation of
each project.
°
°
°
°
Objective user testing
Subjective user evaluation
Post-deployment analysis
Iteration of design
EXHIBIT G
G3ict WHITE PAPER
05
Case Study: Accessibility, Innovation and Sustainability at AT&T
AT&T does not develop or manufacture customer equipment
such as handsets, although it does resell products from thirdparty vendors. Nevertheless, the company is committed to
offering a range of equipment operating on its network that
is accessible and usable to customers both with and without
disabilities. Besides applying accessibility rules embedded in
its own product development processes, AT&T collaborates
with handset manufacturers and third-party accessibility, aging,
technology and disability organizations to collect input on
optimum accessibility specifications. AT&T also works with
nongovernmental organizations (NGOs) for recommendations
and assessments of product accessibility and usability.
Human Factors Lab: A control room where experimenters observe
customers interacting with AT&T products and services.
How the Human Factors Group Works at AT&T
AT&T has established a “Human Factors Group” to test many
of the company’s designs in order to evaluate the accessibility
and usability of products and services. When appropriate, the
team invites aging adults and persons with disabilities to take
part in these studies. AT&T professionals have experience
with accessibility issues and frequently participate in local
accessible technology groups. They also support their peers
throughout the company in matters of accessibility of products
or services.
For example, the Human Factors Group helped develop the ANSI/
HFES 200 standard (Human Factors Engineering of Software).
The objective of this standard is to provide design requirements
and recommendations that make software more accessible
and easier to learn and use. The ultimate beneficiaries are
the end users of software, whose needs motivated the design
recommendations in HFES 200. The application of this standard
is intended to provide user interfaces that are more usable,
accessible and consistent and that enable greater productivity
and satisfaction. Its main components cover accessibility,
interaction techniques, interactive voice response (IVR) and
visual presentation and use of color.
The Human Factors Group at AT&T conducts customer
research, analysis, design and usability testing to help develop
products and services that are accessible, useful and usable
for customers with and without disabilities. The fundamental
goal of the Human Factors Lab is to learn and adjust product
design in the lab from inception, rather than after a product or
service is deployed to tens of millions of customers.
The Human Factors Group supports product development
project teams within relevant divisions of the company and
champions the needs of customers. Members bring their
technical background in the human factors profession, drawing
on knowledge from both industrial engineering and psychology.
The group uses scientific data collection techniques to find out
how customers want to use services and how they think they
should work. Most of that research is conducted in the Human
Factors Labs, located in Austin, Texas, and Atlanta, Georgia.
The labs are capable of testing any service AT&T provides,
from traditional phone services, automated voice response
systems, and web sites, to cutting-edge mobile devices and
television services. The Human Factors Group has conducted
studies with thousands of customers to find out how they
interact with new products or services.
A key benefit of having actual customers test services in the
Human Factors Lab is that it enables engineers to get the
customer’s perspective firsthand, a perspective that may differ
from an engineer’s.
EXHIBIT G
G3ict WHITE PAPER
06
Case Study: Accessibility, Innovation and Sustainability at AT&T
Addressing Customers’ Diverse Abilities
There is no such thing as a “typical” customer. What customers
need and how they use products and services varies. For
example, customers who are blind surf the web, too, but instead
of seeing web pages, they listen as the text on the screen is
read aloud by software called a “screen reader.” Listening to
a web page, however, is not quite the same as seeing it. For
example, a picture of a button for “Log in” cannot be read by
the screen reader, so a text tag that says “Log in” is associated
with the picture.
Taking the lessons learned from individual projects in different
lines of business and applying them to similar services is
another way the Human Factors Group develops solutions for
customers. For example, building on a thorough understanding
of perceived picture quality for television, the Human Factors
Group applies that same research to watching video on cell
phones. Ultimately, the goal is to adapt technology to people,
rather than force people to adapt to the technology.
Enhancing Web Site Accessibility
The Web Accessibility Program conducts testing and reviews,
retrofitting, accessibility training, and is also building relationships
inside and outside AT&T. The Web Accessibility Team works
closely with Creative Experience Team personnel, including
Design Standards, Customer Insight & Usability Engineering,
Design, Content, Rich Media, Interaction Architecture, and
Motion, as well as other internal and external media and
accessibility consulting organizations.
The Web Accessibility Team utilizes a two-part testing process
of scanning for machine-detectable accessibility errors on the
page, and human review. Using specialized software, the team
filters through thousands of web pages each week, looking
for accessibility issues. In addition, the program conducts
time-intensive manual reviews of web page content, searching
for hidden barriers to access for site visitors browsing with
a disability. The team uses the results of automated testing
to focus a human reviewer’s intervention. The program’s site
retrofitting efforts have led to significant decreases in machinedetectable errors. To prevent accessibility errors from making it onto
the web in the first place, the team provides accessibility training to
the various disciplines involved in the web production process.
The WGBH National Center for Accessible Media in Boston
and AT&T have worked together to develop a program that
enables AT&T to provide captioning for online video produced
and hosted through att.com. The captioning program is an
example of how a corporate production process can adapt
principles of accessible design to reach a wider audience, as
well as give existing customers an enhanced user experience.
Providing captioning enables rich media access for audiences
who are deaf or have a hearing loss. It also adds utility for
our mainstream users in noisy environments, for those whose
primary language is not English, or for those who simply enjoy
reading along with the audio turned off.
Universal Design at AT&T
“Universal Design” is at the center of AT&T’s strategy to ensure
that new communications products and services are accessible to
and usable by customers with disabilities. Universal Design is the
practice of designing products, services and applications that are
usable by the broadest possible range of consumers in the widest
possible array of circumstances, including when physical, cognitive
or sensory access to the handset or device is limited. Whether the
limitation is short-term or long-term or related to vision, hearing,
speech, cognition or dexterity, mobile products and applications
need to be designed to enhance accessibility and usability.
Experiencing Accessibility
Try sending a text message from a dark room,
listening to a voice mail message during a loud concert,
or answering the phone with a grocery bag in each
hand. These are some of the situations providing some
experience, however temporary, of what it is like to be
in a situation of sensorial or physical limitation.
EXHIBIT G
G3ict WHITE PAPER
07
Case Study: Accessibility, Innovation and Sustainability at AT&T
”Integration of Universal Design into business practice is fundamental to our mission
of equitable access to wireless technologies for persons of all ages and abilities.”
Jim Mueller, Project Director, User-Centered Research, Rehabilitation Engineering Research Center
for Wireless Technologies, Georgia Institute of Technology
Because of its commitment to Universal Design and its collaborations
with handset and software vendors to develop new products and
services www.att.com/gen/general?pid=10471, AT&T has urged its suppliers
to consider applying a Universal Design methodology as they
develop wireless products and applications, as well as to take into
consideration the needs of aging adults and customers living with
disabilities. In March 2008, the company made its Universal Design
methodology available to suppliers and third-party developers in
order to further facilitate collaborations and joint developments
of innovative solutions for improved accessibility on a variety of
platforms. The original document describing AT&T’s Universal
Design methodology explained the benefits of Universal Design. It
also provided several scenarios to further illustrate the relevance
of this approach in the context of mobile handset and software
design. For example, to meet the needs of someone who may have
difficulty hearing, the document advised manufacturers to consider
text and picture messaging, vibration and light-emitting diodes
displays in their design to alert the user to a call. In the case of
someone who may have limited dexterity, the document suggested
such features as speech recognition and voice commands.
Apps4Access ADA 20th anniversary celebration event: Sam Fabens, VOX Global.
As part of this collaborative process, AT&T also encourages its
suppliers to submit a Voluntary Product Accessibility Template
(VPAT), a checklist designed to gauge how easy it will be for aging
adults and those with disabilities to use the product. For example,
it would indicate that icons include additional descriptions so that
screen readers can “read” these descriptions aloud. It also guides
suppliers not to rely too heavily on visual representations for the
main functionalities of a device. It also recommends specific icons
that are non-textual so that users unable to read can understand
them, and reminds suppliers to consider the needs of customers
who are color-blind.
EXHIBIT G
G3ict WHITE PAPER
08
Case Study: Accessibility, Innovation and Sustainability at AT&T
“It is our goal that the concept of ‘design for all’ is not viewed as a constraint but as a
catalyst for innovation across the industry. We believe that, by making our methodology
on Universal Design available for all to see, we can show the importance and value of
creating wireless products and services that are usable and beneficial to as many
persons as possible. The end result will be more choices for more consumers.”
Carlton Hill, Vice President of Marketing, AT&T
“TDI commends AT&T for the announcement on its Universal Design principles. AT&T fully
understands the benefits and impact it brings to the needs of persons with disabilities and
their contacts upon its addressing and conforming to these principles. AT&T understands
that in order to make its products and services accessible and usable to both persons
with disabilities and those without disabilities, it is promoting a climate of full inclusion
and integration for all Americans in the community, as well as in the business market. TDI
salutes AT&T for taking this special initiative, and calls on other companies and businesses
to emulate this noble approach to ensuring one’s first-class pursuits of life, security and
happiness in the community.”
Claude Stout, Executive Director, Telecommunications for the Deaf and
Individuals Living with a Hearing Loss, Inc.
EXHIBIT G
G3ict WHITE PAPER
09
Case Study: Accessibility, Innovation and Sustainability at AT&T
How a Culture of Inclusion and
Sustainability Supports Accessibility
While Universal Design methodologies provide a solid foundation
for the company’s product and services accessibility efforts, its
culture of inclusion and management processes involving persons
with disabilities deserves much credit for its accomplishments.
Three processes help the company stay focused on accessibility
and aware of accessibility challenges and opportunities:
° The AT&T Advisory Panel on Access & Aging (AAPAA)
° The Citizenship & Sustainability Expert Team – Access and Aging
° Developing an employee base that includes persons with
disabilities
Each is a unique source of continuous innovations and refinements
to serve customers and employees with disabilities.
AT&T Advisory Panel on Access & Aging (AAPAA)
The process of seeking input from representatives of the disability
and aging adults communities is not new at AT&T; it engaged
with both communities beginning in the 1980s. Input has taken
several forms, including the former Wireless Access Task Force
(WATF), mystery shopping with the assistance of communitybased organizations, focus groups on a variety of topics and
inviting constituency expertise. Today, AT&T’s Advisory Panel
on Access & Aging (AAPAA) meets three times a year with key
decision makers from the company’s major business divisions
and provides recommendations on issues impacting customers
and employees: emerging accessible and usable technologies,
current products and services, customer service, strategic
marketing and employment issues.
More than a decade ago, what is now AT&T Mobility created
WATF, which was in charge of assessing the needs of customers
with disabilities. The WATF panel, composed of representatives
from consumer groups and advocates for aging adults and
persons with disabilities, met twice per year with company
officials to articulate their opinions, provide feedback and to
learn about the wireless business. Members also had the
opportunity to meet with handset manufacturers. WATF helped
the company develop a range of accessible and usable products
and services, including TTY and hearing-aid compatible handsets,
network-based voice dialing, and a range of devices that can
be used by persons with little or no vision. While the Wireless
Access Task Force held its last meeting in September 2007,
the knowledge and expertise developed in the past decade
continue through its members who serve on the AAPAA.
AAPAA meeting, February 2010.
EXHIBIT G
G3ict WHITE PAPER
10
Case Study: Accessibility, Innovation and Sustainability at AT&T
“Our progress in these areas is made possible by the tireless efforts and passion of
our employees and by the support and guidance of our external stakeholders like the
members of the AAPAA. We will continue to listen and cultivate those collaborations, as
they challenge us to improve the way we run our business.”
Charlene Lake, Sr. Vice President, Public Affairs,
and Chief Sustainability Officer, AT&T
Citizenship & Sustainability Expert Team Access and Aging
A more recent example of this collaboration resulted in the
development of a stylus to be utilized by customers for capacitive
touch-screen devices in 2010. AAPAA members provided
feedback on the rise of the smart phone market with touchscreen devices and how these products impact customers
with disabilities. Within a few months, the company was able
to source a stylus to be utilized on all capacitive touch-screen
devices and have it on the market at a competitive price. In
fact, AT&T introduced the stylus at the next AAPAA meeting
in the summer of 2010.
While the AAPAA is charged with seeking input from the disability
and aging adult communities and related market segments, the
Citizenship & Sustainability Expert Team on Access and Aging
is composed of employees and other representatives whose role is
to champion the cause of accessibility across all business divisions
of the organization. This is particularly important to ensuring that
accessibility is taken into account in all aspects of new product and
service deployments, customer management, and internal employment
policies and recruitment practices.
As Roman Smith, AT&T‘s Director of Public Affairs for Corporate
Citizenship & Sustainability, explains: “AT&T strives to keep all members
of the communities that it services connected with their world, including
those who have communications difficulties and disabilities. Through
its Citizenship & Sustainability Expert Team on Access and Aging, the
company brings together constituents who drive the most important
accessibility initiatives. Corporate sustainability is woven into the fabric
of the way the company does business. Our view of sustainability is
broad. It includes environmental stewardship, as well as encompasses
a wide variety of issues the company believes are integral to be a
good corporate citizen — fostering an inclusive workplace and offering
customers with disabilities products and services that support them
to live more sustainable and independent lives.”
The stylus suggested by the AAPAA.
The Expert Team on Access and Aging has been particularly effective
in supporting awareness and competency training programs on
disability and accessibility issues for hundreds of thousands of
employees in all divisions of the company, providing inter-divisional
briefings on innovative products and services and helping define
and coordinate process adjustments for customers.
EXHIBIT G
G3ict WHITE PAPER
11
Case Study: Accessibility, Innovation and Sustainability at AT&T
Recruiting and Career Advancements for
Persons with Disabilities
Employees with disabilities help a company make the best informed
decisions on accessibility and customer service for persons with
disabilities. How better to reflect potential customers than through
the societal realities of a diverse workforce that includes persons
with multiple mixes of abilities? With these principles in mind,
AT&T has implemented several programs over the years to
promote the recruitment of persons with disabilities and workplace
accommodations, including alliances with Career Opportunities
for Students with Disabilities (COSD); The Washington Center, an
initiative with historically black colleges and universities supporting
work with students with disabilities; and a new customer care program
staffed entirely by U.S. military veterans with disabilities. This latest pilot
was launched in Atlanta in November 2010 with a goal of employing
approximately 60 veterans with disabilities by March 2011. The veterans
serve as front line customer service representatives, as well as in
supervisory, operational and support functions.
AT&T has also invested in career development for managers
with disabilities as a co-founder of the UCLA Anderson School of
Management’s Leadership Institute for Managers with Disabilities.
So far, five AT&T directors and managers have completed the
course. For its disability-inclusive diversity leadership in the
workforce, AT&T was recognized by the U.S. Department of
Labor’s Office of Disability Employment Policy (ODEP).
To improve the working environment for its new recruits and
employees with disabilities, the company’s Integrated Disability
Service Center helps them maintain regular work commitments when
they are faced with situations that may affect their ability to perform
essential job functions. A well-established job accommodation
process allows employees to request temporary or permanent
work restrictions, obtain appropriate accommodations to assist
them in performing their job responsibilities, or be considered
for temporary work assignments as needed. Since 1993, the
“Individuals with Disabilities Enabling Advocacy Link” (IDEAL), one
of 10 company-recognized Employee Resource Groups, has also
served as a resource for employees with disabilities. Members
of IDEAL deliver presentations on disability etiquette and other
aspects of the employment experience as part of National Disability
Employment Awareness month each October. IDEAL also provides
employees with disabilities the opportunity for mentoring, networking
and leadership development which directly supports the company’s
overall diversity and inclusion objectives. In 2010, AT&T ranked
#3 in DiversityInc’s Top 50 Companies for Diversity.
Career Opportunities for Students with Disabilities (COSD) Executive
Director, Alan Muir, and Jim Skurka (AT&T Business Solutions).
Jim Skurka (AT&T Business Solutions) presenting at a COSD Student Summit.
Workplace Accessibility
As Dr. Aaron Bangor explained to diversitycareers.
com, when he was five years old, he experienced
juvenile rheumatoid arthritis that caused cataracts,
leaving him legally blind. To assist in his work as part
of the Human Factors Group at AT&T, Dr. Bangor
uses Microsoft Windows to enlarge text and display
it as white on a black background so he can read it
more easily. He also uses a closed-circuit TV and
camera that can send images to a screen, images he
can then enlarge. Dr. Bangor ardently believes that
technology should be designed around the needs of
the user, regardless of their abilities.
EXHIBIT G
G3ict WHITE PAPER
12
Case Study: Accessibility, Innovation and Sustainability at AT&T
Data Point: Consumer Attitudes Toward Companies that Hire Persons with Disabilities
A National Survey conducted in 2005 on sample of 806 consumers by Gary N. Sipersteina, Neil Romanob, Amanda
Mohlera and Robin Parkera, University of Massachusetts, Boston, MA, USA and the America’s Strength Foundation,
Ellicott City, MD, USA.
Most of the participants (75 percent) had direct experience with persons with disabilities in a work environment.
Moreover, these experiences were positive. All participants responded positively towards companies that are socially
responsible, including 92 percent of consumers who felt more favorable toward those that hire individuals with
disabilities. The participants also had strong positive beliefs about the value and benefits of hiring people with
disabilities, with 87 percent specifically agreeing that they would prefer to give their business to companies that hire
individuals with disabilities. www.worksupport.com/resources/viewContent.cfm/637
Accessibility and Sustainability: Q & A with Roman Smith, Director –
Public Affairs, Corporate Citizenship & Sustainability, AT&T
For Roman Smith, Director – Public Affairs, Corporate Citizenship & Sustainability, sustainability
is more than just an environmental principle. It is at the core of a company’s corporate citizenship,
particularly its commitment to the disability and aging adults communities.
How does AT&T define sustainability?
Sustainability is a way of doing business that recognizes our company’s impact on society, as well as the impact that
social issues have on our business. Our citizenship and sustainability efforts target areas where the needs of our
company intersect with the needs of our communities. There are certainly many needs of society; however, at AT&T,
we focus on the issues that are important to our business and communities and that provide us with an opportunity
to make the most meaningful impact on areas such as accessibility, education and diversity.
How do you approach sustainability?
I approach sustainability as an “operating principle” of how we run our business. Sustainability is not a token program
or marketing effort at AT&T, but a commitment to operate better, smarter, and in a way that makes sense for both
our company and our world.
Is sustainability just about the environment?
No. While sustainability at AT&T does include environmental stewardship, it also encompasses a wide variety of issues
that we believe are central to our responsibilities as a corporate citizen. Examples include making our communities
stronger through volunteer opportunities such as job shadowing, fostering an inclusive workplace, supporting the
National Disability Institute’s Real Economic Impact Tour to help low-income persons with disabilities and their
families gain financial literacy skills, protecting the environment by consuming less energy, and offering products
and services to help our customers live more independent and sustainable lives.
What does sustainability mean personally?
At a personal level, sustainability is about choosing actions that create a positive and a sustainable future for myself,
my community and my company.
EXHIBIT G
G3ict WHITE PAPER
13
Case Study: Accessibility, Innovation and Sustainability at AT&T
Alexander Graham Bell – An Accessibility Pioneer
Alexander Graham Bell, the inventor of the telephone
and the founder of the company that would become
AT&T, was a teacher of deaf people. His father,
grandfather and brother all studied elocution and
speech, and both his mother and his wife were deaf.
All of this exerted a profound influence on Bell. In fact,
Bell’s invention of the telephone in 1876 grew out of
his efforts to develop the first hearing aid.
Accessibility Innovation: A Continuous Process
Today, AT&T Labs continue working on innovation, developing
core technologies for advanced solutions to meet the needs of
persons with disabilities and those without disabilities. For example
WATSON, AT&T’s speech and language engine, integrates a
variety of speech technologies, including network-based, speakerindependent automatic speech recognition (ASR), Natural Voices
text-to-speech conversion, natural language understanding (which
includes machine learning), and dialog management.
WATSON has been used within AT&T for interactive voice response
(IVR) customers for over 20 years during which time its algorithms
and tools have been refined to improve accuracy, convenience and
integration. WATSON has also been used for speech analytics,
mobile voice search of multimedia data, video search, voice remote,
voice mail to text, web search and SMS, with multiple web-based
applications under development.
Early Accessibility Milestones
1922
Dr. Harvey Fletcher and R. E. Wegel of the Bell System, in
cooperation with Dr. E. P. Fowler, a New York City ear and throat
specialist, announce their experiments in the measurement of
hearing. From their work, Bell Laboratories eventually developed the
1A and 2A audiometers for physicians to use in aiding deaf patients.
AT&T’s Chris Boyer (Public Policy) presenting at Lights! Camera! Access! ADA
event with the U.S. Department of Labor and Academy of Television
Arts & Sciences. Photo: Christopher Voelker.
1924
Western Electric develops the artificial larynx for those who have lost
their voices through surgical removal or paralysis of the vocal cords.
1925
AT&T produces its first telephone amplifier, the model 23A.
AT&T’s Aaron Bangor (AT&T Labs) and Doug Burasco (Relay), attending UCLA
Leadership Institute for Managers with Disabilities. Photo: UCLA Anderson
School of Management.
1931
AT&T introduces the Telex switched typewriter service.
1947
Bell Labs invents the transistor, which allows significant reduction
in the size and weight of hearing aids. Bell Labs subsequently
provides hearing-aid manufacturers with royalty-free licenses.
AT&T’s Susan Mazrui (Global Public Policy), first from left, attending UCLA
Anderson Leadership Institute for Managers with Disabilities, along with other
corporate executives. Photo: UCLA Anderson School of Management.
EXHIBIT G
G3ict WHITE PAPER
14
Case Study: Accessibility, Innovation and Sustainability at AT&T
Pioneering Speech Synthesis - An Interview with Jay Wilpon and Amanda Stent, AT&T Labs - Research
Research on speech synthesis started in the 1930s and an early demonstration of a voice synthesizer was made
at the 1939 World’s Fair in New York City. Speech recognition research started in the 1950s in the early electronics
research group at Bell Labs. However, it was not before the early 1970s that computers became advanced enough to
develop speech recognition for commercial applications. The main purpose at that time was to automate services so
that customers could access a variety of information and services without always having to go through an operator.
This, in turn, allowed companies such as AT&T to scale up services.
It all started with “yes/no” choices, one word at a time. Recognizing natural conversation has always been the
ultimate goal and, as higher performance computers became available, research began a push in this direction. In
the early days, disability and accessibility were not really the purpose. For example, in 1979, the company started
a research program to voice-activate call dial functions. At the time this was a real stretch for speech recognition
technologies, and yet it was successful and patented by AT&T. This was 25 years before voice dialing became a
mainstream application in telephony, especially on mobile phones.
Recognizing everyone’s speech no matter what they said, however, remained the key objective R&D teams were
pursuing. In the 1970s the issue was that if a model had to be built for each person, hundreds of millions of models
would be needed. Obviously, this was impractical for broad use in the marketplace. Speech recognition, to be viable,
has to be speaker-independent. AT&T’s team invented algorithms to make speech recognition speaker independent.
The company filed over 500 patents and thousands of papers. The team, led by Jim Flanagan and Larry Rabiner,
fathers of many signal processing inventions at AT&T, contributed seminal concepts to this new scientific discipline.
Over the years, many members of the team have been honored with fellowships in the IEEE, the National Academy
of Sciences and the National Academy of Engineering. The team has laid out all the fundamental solutions to
produce and recognize speech. The artificial larynx for persons with voice impairments was developed from the
same fundamental technology out of the same group.
The notion that those technologies could benefit persons with disabilities gained momentum in the 1980s. The first
application was a text-to-speech component for a dual-party relay solution using Telecommunications Devices for
the Deaf (TDD). In TDD, a sentence is typed in by the caller at one end and sent to the operator who reads it back
to the caller at the other end. With a speech synthesizer in the middle of the transaction, after the caller typed in the
sentence, the speech synthesizer would read the text instead of the operator. This allowed increasing the speed
and efficiency of relay services. It was first deployed in Washington State in 1984.
Using those leading technologies to address the needs of persons with disabilities gained further momentum as
awareness and interest for assistive technologies grew in the general public. As a result, the AT&T Speech Research
Group became more involved with numerous initiatives to develop solutions for persons with disabilities, from
telecommunications to computer human interfaces. Some of its technologies were used by third parties developing
new solutions, for example evaluating the emotional stability of autistic children. Over the past ten years a multimedia
research group at AT&T has also applied speech recognition and language processing to the problem of automatic
captioning and segmentation of multimedia videos.
EXHIBIT G
G3ict WHITE PAPER
Case Study: Accessibility, Innovation and Sustainability at AT&T
cont.
While text-to-speech and speech recognition can help build very valuable applications for persons with disabilities,
the assistive technologies market may be perceived as too small to justify investments in applications based on
those technologies. AT&T Labs made a bold move in 2007 by evaluating offering its technology as a web-service
with the ability for application developers to “mash it up” with other applications such as e-book readers and voiceenabled directions. When voice recognition was made available as a service ‘in the cloud’, the number of applications
using it grew very rapidly. The company uses a business model that is free to use up to a limit and then costs users
pennies after 1,000 or so licenses. Today, hundreds of organizations use AT&T speech technologies through its
speech mashup prototype. Its customer base grew via word of mouth and includes a large variety of organizations
from little Mom & Pop shops to universities to major enterprises across the world. Currently, AT&T is in the process
of productizing “speech as a service” for broad market use and expects a robust offer by mid-2011.
Looking at recent trends, some of the promising areas for voice technologies include closed captioning of multimedia,
accessible navigation services, assisted virtual remote console using mobile devices, searching the web, searching
and browsing through music or video libraries or TV, e-readers available on the web as an application with an option
to search, change speed, etc. All the while, scientists at AT&T Labs continue to push the scientific frontiers of speech
research to better improve the recognition, synthesis and understanding of the spoken and written word.
One trend is certain: Mainstream assistive products and services will be more and more cloud-based rather than
device-based. Cloud-based applications are easier to maintain and upgrade. As cloud-based applications multiply,
the ability to build at greater scale will contribute to lower costs, to the benefit of both application developers and
persons with disabilities.
AT&T WATSON Speech Technologies.
15
EXHIBIT G
G3ict WHITE PAPER
16
Case Study: Accessibility, Innovation and Sustainability at AT&T
A New Frontier for Accessible
and Assistive Mobile Phones
From Blueprint to Market: Accessibility in a Product Life Cycle
The product development cycle of a new handset follows a well-defined
methodology incorporating accessible and assistive features at an
early stage of design while allowing developers to check their usability
as the product takes shape and is finally marketed. The launch of
the Pantech BreEZe, one of AT&T’s most popular handsets among
persons with disabilities and aging adults, is a good example.
In 2007, AAPAA provided feedback indicating the need for a handset
that would be easy to use for aging adults and persons of all ages.
AAPAA recommended that such a handset should incorporate assistive
features for persons with low vision, dexterity limitations or hearing
loss and those needing simplified commands for frequent tasks.
However, the Panel also suggested that such a product should look
similar to mainstream handsets and be as stylish as any regular
model. With this input, the User Experience Design Team developed
a list of specifications and searched for a handset vendor capable of
meeting those specifications. It selected Pantech, a South Korean
company, with whom it developed a collaborative work process in
order to design the new handset with the desired features.
During the first phase, the AT&T team briefed the Pantech team about
accessibility guidelines, market segments, form factors, ergonomic
features, display menus, text menus, text-to-speech software and voice
output. The Pantech development team worked for approximately
one year on developing the first prototypes. During this development
stage, the AT&T team provided feedback to the Pantech team by
testing the first sketches of menu flows and screen shots with thirdparty research services and user experience groups. This iterative
process allowed Pantech to adjust both software and hardware design
while developing the first prototypes.
Once available, the prototypes went through the standard rigorous
lab quality control process that precedes any new product launch,
typically 12 weeks (not including user testing). Once approved, market
launch occurred four weeks later. Meanwhile, specific attention
was given to make the supporting documentation for the phone
accessible using large fonts, and going through the regular process
of developing support tools for the customer service representatives
handling calls from aging adults and persons with disabilities.
When the Pantech BreEZe was launched, its unique features
marked a step forward in intuitive mobile phone design. Besides
its sleek and simple appearance, it offered an extra-large color
display, a simple user interface to access its various features,
lighted EZ One-Touch Quick Call keys, Bluetooth, magnifier,
hearing aid compatibility and voice dialing. Product testing
showed that most of the desired outcomes were being met.
As with any product, however, the company carefully collected
user feedback and tracked issues. It does so through customer
service and twice a year via a systematic review by its lab of
all its phones, using several hundred data points including an
entire section of questions on accessibility. The initial Pantech
BreEZe review led to a first iteration of suggested improvements:
its documentation accessibility, for example, was further improved
as well as its form factor for messaging. Also, keys were renamed
(the “send” key was relabeled “call”). Future reviews will likely lead
to incorporation of additional features as needed.
EXHIBIT G
G3ict WHITE PAPER
Case Study: Accessibility, Innovation and Sustainability at AT&T
The success the Pantech BreEZe has enjoyed since its launch is no
secret at AT&T. It gained quick market acceptance and recognition
such as its inclusion in the list of Oprah Winfrey’s holiday gifts for under
$100. In May 2010 the successor to the Pantech BreEZe, the aptly named
Pantech BreEZe, 2 included many of the improvements identified in the
product and customer reviews. Some of those improvements included
improving the UI menus and font sizes for better readability, added voice
command feature for improved accessibility to basic phone functions,
added a large visual indicator for call, message and batter life status and
upgraded the technology to 3G HSDPA over 2G EDGE.
AT&T’s Mobile Accessibility and Assistive Technologies at a Glance
As mobile devices and services expanded,AT&T systematically developed
and introduced accessibility and assistive features in cooperation with a
variety of third parties. Key features which significantly enhanced the usability
of mobile phones by persons with disabilities and aging adults include:
° Audible prompts to assist persons with low vision. AT&T was
the first major wireless carrier to offer screen-reading software,
which makes handsets accessible to persons who are blind via
voice output. This software reads basic handset functions aloud,
such as battery life and network strength, as well as Caller ID,
the calendar, text messages and e-mail.
The Pantech BreEZe II
17
° Voice input and voice output for many of the handset functions
such as key echo or dialing from a contact list, or for handsets
that speak aloud each dialed number.
° Mobile Speak by Code Factory: Mobile Speak allows a user
to have access to all elements of a mobile phone screen and
functions and can enable customers with qualifying disabilities
to read books in a specialized format (such as DAISY) designed
for persons who are blind or have reading impairments.
° Mobile Magnifier by Code Factory enlarges the font size on
the screen of the phone.
° Voice command software that allows customers to use verbal
commands to dial a number or retrieve information such as
the date and time.
° TTY-Compatible Phones: AT&T supports phones that are
teletypewriter (TTY) compatible. The TTY device enables visual
communication via a one-line or two-line electronic display
between two users both equipped with TTY devices. When
used in combination with a TTY-compatible wireless phone,
customers with speech or hearing disabilities can stay in touch
while on the go. TTY-compatible wireless phones have a 2.5mm
port that accommodates the 2.5mm audio jack connector on
the TTY device.
° Hearing Aid Compatibility: AT&T works closely with handset
vendors to improve the user experience of customers who
have hearing aids. Pursuant to FCC guidelines, handsets are
tested and rated for Hearing Aid Compatibility (HAC). These
HAC ratings, or “M-Ratings” and “T-Ratings,” help hearing aid
users find the best phone for them.
Persons with disabilities are often early adopters of accessible
technologies that migrate into crossover mainstream audiences.
Those features and services that are developed to support
customers with disabilities end up being useful to all customers.
A vibrating phone helps persons with a hearing loss, but it also
allows a user who can hear to avoid embarrassing interruptions
during a business meeting. The talking Caller ID device is
essential for users with vision loss, but it also comes in handy
for a sighted person who doesn’t want to leave the dinner
table to check who is calling. User-selected ringtones are fun
but can also be set to indicate specific callers and can help a
person who does not want to take every call or wants to set
a ringtone that is easier to hear because hearing loss may be
more significant in certain frequencies.
EXHIBIT G
G3ict WHITE PAPER
18
Case Study: Accessibility, Innovation and Sustainability at AT&T
Making Customer Service Work for Persons
with Disabilities and Aging Adults
Similar to product design, customer service for persons with
disabilities and aging adults is organized along the principle of
Universal Design, so that it may be available to the broadest
possible range of consumers in the widest possible array of
circumstances, including those when physical or sensory access
is limited. Differences among customers, however, are not
just due to disability or functional limitation; they may simply
be a preference for how a customer wants to do business.
If they have a question about their service, they can call for
assistance. However, many customers would rather use a web
site, conduct a chat session with a representative, or even visit
one of AT&T’s retail stores to have their question answered. This
variety meets the preferences of a larger number of customers,
but it also gives flexibility to a customer with a disability for
how they choose to interact with the company.
The company developed a dedicated web site to help wireless
www.wireless.att.com/disabilityresources customers with disabilities
identify products and services that may better address
accessibility needs. It includes comprehensive disability
resources and information on products such as Mobile Speak &
Mobile Magnifier, HAC devices, AT&T 411 Info, 711 TRS Access,
Video Relay, TTY compatible telephones and TTY compatible
devices, and Text Accessibility Plan (TAP). Customers have
the option to call a voice or TTY number displayed on each
web page to ask for more information.
Communications and Points of Sale
Communications with aging adults and persons living with
disabilities include web sites, company-owned points of sale,
and targeted advertising campaigns that explain the benefits
of accessibility and assistive features for different types of
customer situations.
The AT&T accessibility web page.
EXHIBIT G
G3ict WHITE PAPER
19
Case Study: Accessibility, Innovation and Sustainability at AT&T
The company also uses targeted advertising campaigns
emphasizing how accessibility features of its phones may
benefit persons with disabilities or aging adults. In doing so, it
uses efforts to enhance the usability of advertising messages for
persons with disabilities. Since June 2007, for example, nearly
all of its television commercials have been close captioned.
The company runs ads in appropriate publications tailored to
persons with disabilities such as “Diversity Careers in Engineering
and Information Technology” or regional editions of the AARP
magazine. It also uses StarLines, a state-specific insert which
is sent with telephone bills to 11.4 million residential customers
in nine southeastern states (including a Spanish version in
Florida), dedicated to customers with disabilities and their
families. The insert includes information on AT&T’s products
and services for customers with disabilities. Other customers
are reached via direct mail campaigns, requesting that they
contact company representatives at the National Center for
Customers with Disabilities (NCCD), a toll-free number if they,
or someone they know, has a disability.
For its points of sale, the company has deployed Section 255
of the Telecommunications Act and Hearing Aid Compatibility
(HAC) training for all its U.S. stores in order to ensure that sales
personnel are well-versed in HAC programs and protocols as
well as provided with basic information about the Americans
with Disabilities Act (ADA). Every other month, the company
conducts audits of all its retail stores to ensure that it meets
the legislation’s requirements to serve aging adult customers
and those with disabilities.
Customized Services for Persons with Disabilities
Beyond accessible and assistive solutions offered on handsets,
customized services were created and marketed to customers
with disabilities that meet their specific requirements:
° Video Relay Services (VRS) connect individuals with an interpreter
who translates between American Sign Language (ASL) and
spoken English. Users can download a free VRS videophone
software, Video Link. Video Link is only available for persons who
are deaf or living with a hearing loss www.att.com/vrs. An iPhone
VRS application is also available in the iPhone App Store.
Video Relay Services (VRS) for deaf viewers on YouTube.
° Instant Message (IM) Relay www.att.com/relay is a text-based
solution for individuals who are deaf or have a speech or
hearing loss and that has been ported on many mobile devices.
Customers can also use an Internet connection and an AOL
Instant Messenger (AIM) account. To relay with one-step
dialing, users send the phone number they are calling via
instant message to a screen name “ATTRelay.” An AT&T
Relay operator calls the phone number and translates the
text to voice to the other party. There is no charge to use
this service, but users must register. Aside from using IM
relay on personal computers, IM relay is accessible on the
many mobile platforms on which AOL is available such as
iPhone, Android, iPad, Blackberry, and Windows Mobile.
Customers can also get their own personal 10-digit phone
number and people can call them via the IM Relay.
° AT&T 411 Info lets users dial 4-1-1 from their wireless phone
for live directory information, send a text message with the
listing and connect at no additional fee. AT&T 411 Info can
also find a business near the user’s location. It also offers
movie showtimes, turn-by-turn driving directions, reverse
lookup and business category search, all with access to
live operators 24/7.
° Text Accessibility Plans (TAPs) were developed for persons
who are deaf or have a speech disability and/or hearing
loss and who use almost exclusively text messages rather
than voice calls. Those data plans were designed with input
from users via focus groups. Rates are more favorable than
those of voice plans with similar text usage, and voice calls
are charged by the unit if needed.
EXHIBIT G
G3ict WHITE PAPER
20
Case Study: Accessibility, Innovation and Sustainability at AT&T
The AT&T National Center for Customers with Disabilities
The National Center for Customers with Disabilities (NCCD)
handles inquiries and requests relating to AT&T Mobility’s
products and services.
Based in Baton Rouge, LA, it includes customer care personnel
who have received training on disability-related wireless products
and services. In addition to training required for all customer
service representatives and customer facing personnel, the
NCCD staff members are trained to address the specific wireless
product and service needs of aging adult customers and those
with disabilities. The Center uses specialized channels (including
TTY and e-mail) to help customers with disabilities who have
accessibility and usability questions.
Customer service representatives are given specialized training
on hearing aids, screen reader software, voice dialing, and
TTY compatibility. They provide referrals for phone peripherals
meeting customer needs. In addition, a list of customers using
specialized programs such as Voice Dial, TAP Rate Plans
and buyers of Mobile Speak & Mobile Magnifier software that
have applied for a rebate is maintained, and representatives
can arrange for alternate formats such as Braille or large print
billing, as well as materials in alternate format when requested
by the customer. Finally, for each product launch, a specific
customer support knowledge base is made available to customer
service representatives, product briefings are conducted, and
sample phones are distributed.
Operator serving a customer via TTY.
One of the most impressive features of the NCCD is its ability to
interface with the communication medium of choice of customers
with disabilities. It may be a live text exchange, a mini-video
relay call or a TTY call. All customer service representatives
have been trained to handle any and all of those customer
communication preferences. For Tier Two support requiring
specific technical knowledge beyond the knowledge base used
by AT&T’s own customer service representatives, third parties
are chosen who have both the required technical knowledge
and the ability to interact with customers with disabilities in
a similar fashion.
“AT&T has a long legacy of providing products and services designed to meet and exceed
our customers’ expectations and supporting the disability community. The goal of AT&T’s
care centers is to understand our customers’ needs and preferences and help identify
the best options available -- whether they have a disability or not.”
Jody Garcia, Vice President, Consumer Sales and Service, AT&T
EXHIBIT G
G3ict WHITE PAPER
21
Case Study: Accessibility, Innovation and Sustainability at AT&T
A Brief History
It was 1978 when AT&T opened its first call center
dedicated to serving the disability and aging adult
markets. The center served wireline customers in
California through voice and TTY access.
Today, centers located in Oakland, CA, Lees Summit,
MO, and Albany, GA, are dedicated to serving the
disability and aging markets, in English and Spanish,
across AT&T’s entire wireline footprint.
Point of Sale Accessibility.
Employees are trained to assist and advise customers
with hearing, vision, mobility and/or speech disabilities
about equipment, accessories, features and calling
plans, as well as choices for TV and wireless products
and services. They can also arrange for an alternate
billing format, such as Braille or large print.
Serving Persons with Disabilities: Involving All Employees
Serving persons with disabilities and aging adults, however,
cannot be accomplished successfully in isolation. In 2009, the
company embarked on an ambitious program to train employees
on disability awareness. With input from AAPAA members,
it designed a training module delivered as an instructor-led
course or self-paced e-learning program lasting approximately
45 minutes. The training module covers definitions of disabilities
and demographics, Section 255 of the Telecommunications Act,
how to interact and communicate with persons with disabilities
(including practical etiquette guidelines and communications
techniques) and understand the requirements that they may
have in relation to mobile phones and wireless services. More
than 160,000 AT&T employees have completed the training
program. When asked if all those efforts, in addition to meeting
the company’s sustainability objectives did translate in some
form of competitive edge, the answer among AT&T executives
has been “absolutely.”
Point of Sale Accessibility.
EXHIBIT G
G3ict WHITE PAPER
22
Case Study: Accessibility, Innovation and Sustainability at AT&T
Using Innovation for Accessibility:
iPhone and Smart Phone Features
for Persons with Disabilities
As technology evolves and third parties develop new hardware
and software solutions, wireless service providers need to constantly
assess how these may present challenges or opportunities for
aging adults and customers with disabilities. AT&T does this through
systematic advance briefings and exchanges with third parties
providing handsets, middleware or applications, and by leveraging
its own research and market surveys.
For example, the launch of smart phones has opened an
entirely new chapter in the development of assistive solutions
for persons with disabilities. Today, iPhone customers living with
disabilities enjoy a vast array of breakthroughs in accessibility
and usability www.apple.com/accessibility/iphone/vision.html. Some of
the key features are standard on the iPhone, but many other are
third-party applications that have proliferated since its launch.
AT&T Video Link app for iPhone 4 can be used to place video relay calls.
EXHIBIT G
G3ict WHITE PAPER
Case Study: Accessibility, Innovation and Sustainability at AT&T
23
“When AT&T and Apple brought closed captioning to the iPhone, Universal Design met
cutting-edge technology. Deaf and hard-of-hearing persons celebrated, and everyone
who appreciates captioning benefited from this remarkable achievement.”
Larry Goldberg, Director, Carl and Ruth Shapiro Family National Center
for Accessible Media at WGBH (NCAM)
AT&T Video Link user interface.
VoiceOver, which was originally a screen reader for the Mac, has
been adapted by Apple for iPhone 3GS and comes standard on
the iPhone 4. It allows users to operate the phone even if they
cannot see the screen. VoiceOver reads aloud a description of
each item touched by the finger of the user. It also reads aloud all
critical indicators on the phone such as connectivity choices, battery
level, signal level, screen orientation and whether the screen is
locked or unlocked. As is the case for the Mac version, VoiceOver
lets the user choose the speaking rate. It offers an innovative
capability, the “Rotor.” Turning the rotor — by rotating two fingers
on the screen as if you were turning an actual dial — changes the
way VoiceOver moves through a document based on a setting
you choose.VoiceOver also offers a Bluetooth-enabled Braille
interface, which can be used both for output and input devices.
Voice recognition can be activated by pressing and holding the
home button to choose and play music or make a phone call.
Perhaps most intriguing and promising is the array of new
applications that have been launched for persons with disabilities
by third-party developers. For users with a hearing loss for
example, TuneWiki enables the iPhone to display closed and
open captioning similar to a TV set, a real breakthrough in
accessibility for mobile platforms. Other programs offer additional
resources, such as the iSign application to assist in learning
American Sign Language or “A Special Phone,” an application
allowing dialing a number by simply shaking the phone. For
children with autism or developmental delays, several innovative
applications have emerged demonstrating that the iPhone
intuitive graphical user interface and ability to let the user
manipulate pictures can boost non-verbal communications to
a much higher level than traditional paper based methods.
The future looks bright for new types of communications for
deaf and non-verbal users who converse in sign language.
EXHIBIT G
G3ict WHITE PAPER
24
Case Study: Accessibility, Innovation and Sustainability at AT&T
Conclusion
This review of AT&T’s internal processes to address the market
of persons with disabilities and aging adults provided G3ict
with important insights on four key success factors that may
be replicated in a number of industries or services:
° First, AT&T leadership sees the benefits of the link between
innovation and opportunity as it applies to the communication
needs of people with disabilities and aging adults.
° Second, it was clear during our data collection and interviews
that the culture of inclusiveness and commitment to sustainability
were the foundation of its achievements; it permeates all areas
of the company, allows accessibility advocates to have their
voice heard in product development, marketing and services
and facilitates the involvement of persons with disabilities
at all levels of the decision making process. AT&T’s training
investment on disability awareness is considerable, enhancing
its entire workforce effectiveness in interacting with customers
and colleagues with disabilities and aging adults.
° Third, the incorporation of accessibility criteria at an early
stage of development of all products and services has become
an integral part of the company’s way of doing things. It is
not a process forced on the product development teams
but a philosophy that permeates their product development
methodology and that of their suppliers. In that regard, the
company’s Universal Design public guidelines for suppliers
constitute an innovative step rarely seen in any industry.
° Fourth, the systematic research conducted on human factors
and on the needs of persons with disabilities and aging adults
with a good understanding of market demographics via customer
research or direct input from various advisory councils enables
the company to develop integrated, sustainable and consistent
strategies. Those include all stages of a product life cycle from
product design to marketing, communications, points of sale
and customer services. Such an integrated strategy is essential
to reach out to new customers, managing sales and offering
dedicated customer services trained to handle the specific needs
of persons with disabilities and aging adults.
As for the future of accessible and assistive mobile products
and services, this review of AT&T’s accessibility strategies
points to a sea change in how new technology and solutions
will evolve. Most remarkable, in our opinion, is the fact that
the best solutions are increasingly the result of cooperation
involving multiple players: hardware manufacturers, operating
system vendors, application developers, service providers,
experts with disabilities. The emergence of smart phones with
unifying trends such as the use of HTML 5 among developers
opens an unprecedented opportunity for the creation of specific
applications addressing the many specialized needs and
preferences of persons with disabilities and aging adults.
EXHIBIT G
G3ict WHITE PAPER
Case Study: Accessibility, Innovation and Sustainability at AT&T
AT&T’s Elizabeth Dixon (Human Resources) sharing her experience
in promoting inclusion among the AT&T work force at the U.S.
Department of Labor/ODEP Listening Tour in Boston, March 2010.
Ultimately, however, technology solutions for persons with
disabilities and aging adults will always require dedicated and
appropriate customer support and services. With hundreds of
new applications appearing on platforms such as the iPhone,
Android and other major operating systems, the next challenge
will be for service providers to develop new processes and
business models that are sustainable and work for customers
in this complex environment. Companies such as AT&T, which
have adopted Universal Design principles, rely on the ongoing
input of persons with disabilities and aging adults, and invest
heavily in nurturing a culture of inclusion among their workforce,
will be well-positioned to successfully tackle these challenges
for generations to come.
25
EXHIBIT G
G3ict WHITE PAPER
Global Initiative for Inclusive Information
and Communication Technologies
www.g3ict.org
1110 W. Peachtree Street, NW
Atlanta, GA 30309-3609 – U.S.A.
Exhibit H
BVoIP Bill
Exhibit H
BVoiP Bill
Exhibit H
BVoiP Bill
IPFlex Bill
Exhibit H
IPFlex Bill
丠丠丠丠丠✐丠✐✐✐✐✐✐✐丠丠𕾐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐丠丠田丠✐丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠丠丠丠丠丠丠丠丠丠✐丠丠✐𘚠𑅰𕾐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐
丠✐✐✐✐✐✐✐丠✐✐✐✐✐
丠✐✐✐✐✐✐✐丠✐✐✐
丠✐✐✐✐✐✐✐✐𤧰
丠✐✐✐丠✐✐✐
丠✐✐✐✐✐✐
✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐
𓢀田✐𘚠𘚠𘚠𘚠𘚠丠✐썐썐✐𓢀田丠
丠✐✐✐✐✐𓢀✐丠𘚠✐✐
✐✐𓢀𘚠𘚠✐丠田썐𘚠𑅰썐丠鱀
att.com
鱀𕾐鱀✐썐丠✐𘚠𕾐
丠✐✐✐✐✐✐𘚠𘚠𘚠𘚠𘚠✐✐𘚠✐丠✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐丠✐✐✐
✐✐✐✐✐田田𓢀田田𓢀𚶰✐丠
丠✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐𚶰𘚠𘚠
丠✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐𚶰𘚠𘚠
丠✐✐✐✐丠✐✐✐𘚠✐丠✐✐✐✐✐✐丠✐✐✐丠✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐田田𓢀田田𓢀𚶰✐丠
丠✐✐✐✐✐✐✐丠✐✐✐✐✐✐
✐✐✐✐✐✐鱀𓢀✐𘚠𚶰𘚠
丠✐✐✐✐✐丠✐✐✐✐✐✐丠✐✐
✐✐✐✐✐田田𑅰𓢀鱀𕾐𓢀𚶰✐𓢀
丠✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐丠✐✐✐✐✐✐丠✐✐✐✐✐✐
丠✐✐✐𑅰𓢀✐丠𘚠✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐𚶰✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐✐𚶰✐✐✐
丠✐✐✐✐✐✐✐✐𤧰✐丠✐✐✐🯐 ✐✐𓢀𘚠𘚠✐丠田썐𘚠𑅰썐丠鱀
丠丠田丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐
丠✐✐✐✐✐✐𘚠𘚠𘚠𘚠𘚠✐
丠✐✐𘚠丠✐✐✐✐✐✐✐✐𓢀田✐𘚠𘚠𘚠𘚠𘚠丠田𕾐丠✐鱀썐𘚠
✐✐✐✐✐✐✐✐田✐𕾐𚶰썐丠
丠✐✐𘚠丠✐✐✐✐✐✐✐✐𓢀田✐𘚠𘚠𘚠𘚠𘚠丠田𕾐✐丠썐𓢀
✐✐✐✐✐✐田𓢀𓢀鱀𘚠𚶰썐鱀
丠✐✐✐✐✐丠✐✐✐✐✐✐𘚠𘚠𘚠𘚠𘚠✐
✐✐✐✐✐✐鱀𓢀✐𘚠𚶰𘚠
丠✐✐✐✐✐丠✐✐✐✐✐✐✐丠✐✐✐✐✐✐
✐✐✐✐✐✐鱀𓢀✐𘚠𚶰𘚠
丠✐✐✐✐✐✐𘚠𘚠𘚠𘚠𘚠✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐𘚠丠✐✐✐✐✐✐✐✐𓢀田✐𘚠𘚠𘚠𘚠𘚠丠田𕾐丠✐鱀썐𘚠
丠✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐𝓀丠✐✐✐✐✐✐丠丠✐𘚠𘚠𘚠𘚠鱀𓢀𕾐𕾐썐✐✐✐✐✐✐✐✐✐✐✐✐
丠丠썐✐丠✐丠丠丠丠丠丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠丠丠丠𓢀✐丠丠✐𘚠𘚠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐丠✐✐✐✐丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐🯐
丠✐✐✐✐✐𓢀✐丠𘚠✐✐✐✐✐✐✐✐丠✐✐✐✐𘚠𓢀✐丠𘚠✐✐
✐✐✐𚶰 丠✐✐✐✐✐✐丠✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐丠𚶰 丠丠田丠✐丠丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐田𚶰 丠✐丠丠✐丠✐✐✐✐✐✐✐丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐鱀𚶰 丠丠田丠✐丠丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰
✐✐✐✐✐✐✐✐✐썐썐𚶰𓢀𘚠
✐✐✐✐✐✐✐✐✐丠𕾐𚶰𑅰𘚠
✐✐✐✐✐✐✐✐✐鱀𓢀𚶰썐𘚠
✐✐✐✐✐✐✐✐✐✐✐𚶰𓢀𕾐
丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐🯐
丠✐✐✐✐✐𓢀✐丠𘚠✐✐✐✐✐✐✐✐丠✐✐✐✐𘚠𓢀✐丠𘚠✐✐
✐✐썐𚶰 丠✐丠丠✐丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐𘚠✐丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐✐丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐
✐✐𚶰 丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐𘚠✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐𑅰𚶰 丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐丠✐✐✐𘚠✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐𓢀𚶰 丠✐✐✐✐✐✐✐✐丠✐✐✐丠✐✐✐✐✐✐✐✐✐𘚠✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐𕾐𚶰 丠✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐丠✐✐✐𘚠✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐
丠✐✐✐✐
丠✐✐✐✐🯐
✐✐𘚠𚶰 ✐丠丠𝓀丠丠丠丠丠丠丠丠✐丠丠丠丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐𚶰 ✐丠丠𝓀丠丠丠丠丠丠丠丠丠丠丠丠丠丠✐丠丠丠丠✐丠丠丠✐✐✐✐✐✐✐
✐✐丠𚶰 ✐丠丠𝓀丠丠丠丠丠丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐🯐
✐✐田𚶰 ✐丠丠丠丠丠丠✐丠丠丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐🯐
✐✐鱀𚶰 ✐丠丠𝓀丠丠丠丠丠丠丠✐丠丠丠丠丠丠丠✐丠丠丠丠丠丠✐✐✐✐✐✐✐✐
✐✐썐𚶰 ✐丠丠丠丠丠✐丠丠丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐丠✐✐✐✐
丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐𝓀丠✐✐✐✐✐✐丠丠✐𘚠𘚠𘚠𘚠鱀𓢀𕾐𕾐썐✐✐✐✐✐✐
丠✐✐✐✐✐丠✐✐𘚠丠✐✐✐✐✐✐✐✐𓢀田✐𘚠𘚠𘚠𘚠𘚠丠田𕾐丠✐鱀썐𘚠
丠✐✐𘚠丠✐✐✐✐✐✐✐✐𓢀田✐𘚠𘚠𘚠𘚠𘚠丠田𕾐✐丠썐𓢀
丠✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐𝓀丠✐✐✐✐✐✐丠丠✐𘚠𘚠𘚠𘚠丠鱀𓢀𑅰썐丠✐✐✐✐✐✐✐✐✐✐✐✐
丠𘚠𘚠✐丠丠丠丠丠丠✐丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠丠丠丠丠丠✐丠丠丠𓢀✐丠丠✐𘚠𑅰𑅰鱀𓢀✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐丠✐✐✐✐丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐🯐
丠✐✐✐✐✐𓢀✐丠𘚠✐✐✐✐✐✐✐✐丠✐✐✐✐𘚠𓢀✐丠𘚠✐✐
✐✐𚶰 丠✐✐✐✐✐✐丠✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐𑅰𚶰 丠丠田丠✐丠丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐𓢀𚶰 丠✐丠丠✐丠✐✐✐✐✐✐✐丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐𕾐𚶰 丠丠田丠✐丠丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐
丠✐✐✐丠✐✐✐✐丠✐✐✐✐✐✐🯐
✐丠𘚠𚶰 丠✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐丠✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐
✐丠✐𚶰 丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐𘚠✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐丠丠𚶰 丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐丠✐✐✐𘚠✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐丠田𚶰 丠✐✐✐✐✐✐✐✐丠✐✐✐丠✐✐✐✐✐✐✐✐✐𘚠✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐丠鱀𚶰 丠✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐丠✐✐✐𘚠✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐
丠✐✐✐✐
丠✐✐✐✐🯐
✐丠썐𚶰 ✐丠丠𝓀丠丠丠✐丠丠丠丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐丠𚶰 ✐丠丠𝓀𕾐✐✐✐丠丠丠丠丠丠𝓀丠丠丠丠丠𚶰✐丠丠丠丠𚶰✐丠丠丠✐✐✐
丠✐✐✐✐✐丠✐✐✐✐
丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐𝓀丠✐✐✐✐✐✐丠丠✐𘚠𘚠𘚠𘚠丠鱀𓢀𑅰썐丠✐✐✐✐✐✐
丠✐✐✐✐✐丠✐✐𘚠丠✐✐✐✐✐✐✐✐𓢀田✐𘚠𘚠𘚠𘚠𘚠丠田𕾐✐丠썐𓢀
丠✐✐✐✐✐丠✐✐✐✐✐✐𘚠𘚠𘚠𘚠𘚠✐
丠✐✐✐✐✐丠✐✐✐✐✐✐✐丠✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐丠𘚠𚶰𑅰𓢀
✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐
✐✐✐✐✐✐✐✐✐✐鱀𚶰썐𘚠
✐✐✐✐✐✐✐✐✐✐丠𚶰𑅰丠
✐✐✐✐✐✐✐✐✐丠𕾐𚶰✐✐
✐✐✐✐✐✐✐✐✐✐썐𚶰𑅰𑅰
✐✐✐✐✐✐✐✐✐✐✐𚶰✐田
✐✐✐✐✐✐✐✐✐✐田𚶰鱀𕾐
✐✐✐✐✐✐✐✐✐✐✐𚶰丠
✐✐✐✐✐✐✐✐✐✐썐𚶰𑅰𑅰
✐✐✐✐✐✐✐✐✐✐✐𚶰𑅰𘚠
✐✐✐✐✐✐✐✐✐田𓢀𚶰✐丠
✐✐✐✐✐✐✐✐田✐𕾐𚶰썐丠
✐✐✐✐✐✐✐✐田✐𕾐𚶰썐丠
✐✐✐✐✐✐✐✐✐썐썐𚶰𓢀𘚠
✐✐✐✐✐✐✐✐✐丠𕾐𚶰𑅰𘚠
✐✐✐✐✐✐丠𓢀𕾐𑅰𘚠𚶰𘚠𘚠
✐✐✐✐✐✐✐✐✐✐鱀𚶰✐
✐✐✐✐✐✐✐✐✐✐✐𚶰𘚠田
✐✐✐✐✐✐✐✐田✐𑅰𚶰𓢀✐
✐✐✐✐✐✐✐✐✐✐𑅰𚶰✐
✐✐✐✐✐✐✐✐✐𓢀𚶰𓢀✐
✐✐✐✐✐✐✐✐✐鱀✐𚶰𑅰丠
✐✐✐✐✐✐✐✐鱀鱀썐𚶰썐𘚠
✐✐✐✐✐✐✐✐丠鱀썐𚶰田썐
✐✐✐✐✐✐✐✐✐𕾐𘚠𚶰𘚠𘚠
✐✐✐✐✐✐✐✐田田썐𚶰田썐
✐✐✐✐✐✐田𓢀𓢀鱀𘚠𚶰썐鱀
✐✐✐✐✐✐田𓢀𓢀鱀𘚠𚶰썐鱀
✐✐✐✐✐✐鱀𓢀✐𘚠𚶰𘚠
✐✐✐✐✐✐鱀𓢀✐𘚠𚶰𘚠
丠𚶰丠𚶰✐丠✐✐𚶰✐丠鱀✐𘚠𓢀𕾐썐𘚠✐✐✐✐✐丠鱀✐鱀𓢀썐✐𘚠
丠丠丠✐丠丠🯐✐丠✐✐✐𑅰𓢀✐丠𘚠✐✐✐
丠✐✐✐✐✐✐✐丠✐✐✐✐丠✐✐✐✐✐𓢀✐丠𘚠✐✐
✐✐✐✐✐✐✐✐✐✐𑅰𚶰鱀𘚠
✐✐✐✐✐✐✐✐丠썐丠𚶰丠𕾐
丠✐✐✐✐✐✐✐丠✐✐✐✐✐
𓢀田✐𘚠𘚠𘚠𘚠𘚠丠✐썐썐✐𓢀田丠
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
田田𑅰𓢀鱀𕾐𓢀𚶰✐𓢀✐✐
丠丠丠丠丠✐丠✐✐✐✐✐✐✐丠丠𕾐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐丠丠田丠✐丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠丠丠丠丠丠丠丠丠丠✐丠丠✐𘚠𑅰𕾐丠✐
Make checks payable to:
丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠𚶰丠𚶰✐丠✐✐✐썐𘚠✐𕾐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐丠✐✐✐✐✐𓢀✐丠丠✐𘚠✐𕾐𑅰𘚠썐𘚠✐𕾐
!601975019002!
83100021558324941526109008200000374981800004160064
Exhibit H
IPFlex Bill
丠丠丠丠丠✐丠✐✐✐✐✐✐✐丠丠𕾐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐丠丠田丠✐丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠丠丠丠丠丠丠丠丠丠✐丠丠✐𘚠𑅰𕾐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐
丠✐✐✐✐✐✐✐丠✐✐✐✐✐
丠✐✐✐✐✐✐✐丠✐✐✐
丠✐✐✐✐✐✐✐✐𤧰
丠✐✐✐丠✐✐✐
✐
丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐
𓢀田✐𘚠𘚠𘚠𘚠𘚠丠✐썐썐✐𓢀田丠
丠✐✐✐✐✐𓢀✐丠𘚠✐✐
✐✐𓢀𘚠𘚠✐丠田썐𘚠𑅰썐丠鱀
att.com
丠✐✐✐✐丠✐✐✐丠✐✐✐丠✐✐
丠✐✐✐✐丠✐✐✐丠✐✐✐丠✐✐
丠丠丠丠丠丠丠✐丠丠丠丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𓢀✐丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐𓢀丠✐✐✐✐✐✐✐✐✐𚶰✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐丠✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠丠田丠𚶰✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠丠✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠丠丠𚶰✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𓢀✐丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐田丠썐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐🯐✐丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐田丠썐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𓢀✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐✐✐✐✐✐✐✐✐✐✐
✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𓢀✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐丠✐✐✐✐✐✐𓢀
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𓢀✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𘚠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐𚶰✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐
丠丠丠丠丠丠丠丠丠丠✐丠丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𑅰𓢀✐丠𘚠✐✐✐丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𕾐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐丠丠田丠✐丠丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐𓢀✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐丠丠田丠✐丠✐✐✐✐丠丠丠✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𕾐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠丠田丠✐✐✐✐
丠✐✐✐✐✐✐✐✐丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𘚠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠丠田丠✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠丠丠丠丠丠丠丠丠丠✐丠丠丠丠✐𘚠✐丠✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𑅰𓢀✐丠𘚠✐✐✐丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𕾐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐丠✐✐✐✐丠丠丠𑅰✐✐✐✐✐丠丠田丠✐丠丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐𓢀✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐丠丠田丠✐丠✐✐✐✐丠丠丠
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𕾐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐丠✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠丠田丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐𘚠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐丠丠田丠✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐
丠✐✐✐✐✐丠✐✐✐丠✐✐✐丠✐✐✐✐✐✐✐✐丠丠田丠✐丠✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𑅰𓢀✐丠𘚠✐✐✐丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𕾐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐丠丠田丠✐丠丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐𓢀✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐𚶰✐丠丠田丠✐丠✐✐✐✐丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𕾐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐𓢀✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𑅰𓢀✐丠𘚠✐✐𓢀✐丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐丠丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐丠丠丠丠✐✐✐✐✐✐✐✐✐𚶰✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠丠田丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𘚠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠丠田丠✐丠✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𑅰𓢀✐丠𘚠✐✐✐丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𕾐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐丠丠田丠✐丠丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐𓢀✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐𚶰✐丠丠田丠✐丠✐✐✐✐丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𕾐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐丠✐✐✐𓢀✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𑅰𓢀✐丠𘚠✐✐𓢀✐丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐丠✐✐✐✐丠丠丠𑅰✐✐✐✐✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐丠丠✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐丠丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐
✐✐✐✐丠丠丠丠✐✐✐✐✐✐✐✐✐𚶰✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠丠田丠✐丠✐✐✐✐✐✐✐✐✐
丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𘚠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠丠田丠✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𑅰𓢀✐丠𘚠✐✐✐丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𕾐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐丠丠田丠✐丠丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐𓢀✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐丠丠田丠✐丠✐✐✐✐丠丠丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𕾐✐✐
丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐丠✐✐✐𓢀✐✐✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐𑅰𓢀✐丠𘚠✐✐𓢀✐丠丠田丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐丠丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐丠丠丠丠✐✐✐✐✐✐✐✐✐𚶰✐丠✐✐✐
✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐丠丠田丠✐丠✐✐✐✐✐✐✐✐丠✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐𘚠✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
✐✐✐✐✐丠丠田丠✐丠✐✐✐✐✐丠✐✐✐✐✐✐✐✐✐✐✐✐✐𚶰✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐✐
丠✐✐✐✐✐✐✐✐✐丠𘚠𘚠✐丠丠田丠✐丠✐✐✐✐✐✐✐✐✐丠✐✐✐✐✐✐✐𚶰✐丠✐✐✐丠✐✐✐✐✐✐丠✐✐✐✐✐✐✐𚶰
U-verse Bill
att.com
Exhibit H
U-verse Bill
AT&T CUSTOMER
1234 TELEPHONE LN
ANY CITY ST 99999 - 1234
Page:
Bill Cycle Date:
Account:
1 of 3
11/07/13 - 12/06/13
123456789
Sample Bill
Visit us online at: www.att.com
U-verse Statement
Bill-At-A-Glance
Previous Balance
$121.39
Payment - 11/28 - Thank You!
$121.39CR
Adjustments
$0.00
Balance
$0.00
New Charges
$111.05
Total Amount Due
$111.05
Amount Due in Full by
Dec 30, 2013
Account Charges
Monthly Charges - Dec 7 thru Jan 6
Service Summary
Service
1. High Speed Internet Equipment Fee
Page
Account Charges
1
$6.14
U-verse TV
1
$41.20
U-verse Internet
2
$30.00
U-verse Voice
2
$33.71
Total New Charges
6.00
Total
Other Charges and Credits
Government Fees and Taxes
2. County District Sales Tax
3. Local Video Facilities Fee
Total Government Fees and Taxes
0.06
0.08
0.14
Total Other Charges & Credits
0.14
Total Account Charges
6.14
$111.05
U-verse TV
Monthly Charges - Dec 7 thru Jan 6
1. AT&T U-verse TV U200
2. AT&T U-verse TV U200 (Bundle Discount)
(Expires 08/16/2014)
How to Contact Us:
For Ordering, Billing or Support: Call 800-288-2020
For TTY: Call 800-855-2880 and type “U-verse”
For Online Billing and Account Support:
Visit att.com/bill
Total Monthly Charges
74.00
40.00CR
34.00
For Important Information about your bill, please
see the News You Can Use section (Page 2).
AT&T U-verse(SM) Services provided by AT&T <Your State>.
Return bottom portion with your check in the enclosed envelope.
Payments may take 7 days to post.
DUE BY: Dec 30, 2013
Printed on Recyclable Paper
$111.05
Account Number
123456789-4
Please include account number on your check.
AT&T CUSTOMER
1234 TELEPHONE LN
ANY CITY ST 99999 - 1234
Make checks payable to:
CHECK FOR AUTO PAY
(SEE REVERSE)
AT&T
PO BOX 5014
CAROL STREAM, IL 60197-5014
41004033000123456789400000001213900000001110500005
Exhibit H
U-verse Bill
AT&T CUSTOMER
1234 TELEPHONE LN
ANY CITY ST 99999 - 1234
Page
Bill Cycle Date:
Account:
Sample Bill
U-verse TV -
Visit us online at: www.att.com
Monthly Charges - Continued
Continued
2. AT&T U-verse Voice 123 555-1111
(Promotional Offer)
Other Charges and Credits
Total Monthly Charges
Surcharges and Other Fees
3. Broadcast TV Surcharge
4. Local Video Service Franchise Fee
Total Surcharges and Other Fees
1.99
2.01
4.00
Government Fees and Taxes
5. County Sales Tax
6. State Sales Tax
Total Government Fees and Taxes
0.96
2.24
3.20
Total Other Charges & Credits
7.20
Total U-verse TV
2 of 3
11/07/13 - 12/06/13
123456789
41.20
U-verse Internet
AT&T High Speed Internet Elite - provides the speed and
security you need, including built-in wireless home
networking capability, access to AT&T’s entire National
Wi-Fi network, 11 email accounts, photo storage, AT&T
Security Suite powered by McAfee, pop-up blocker, and
parental controls.
5.00CR
30.00
Other Charges and Credits
Call Detail Charges
123 555-1111
Domestic Off-net Charges
Minutes Used
Number of Calls
2,548
211
Surcharges and Other Fees
3. Federal Universal Service Fund
4. State Universal Service Fund
5. State Universal Service Fund
Total Surcharges and Other Fees
3.04
0.41
0.01
3.46
Government Fees and Taxes
6. County 911 Service Fee
0.25
Total Other Charges & Credits
3.71
Total U-verse Voice
33.71
News You Can Use
Monthly Charges - Dec 7 thru Jan 6
1. AT&T U-verse Internet Elite
2. AT&T U-verse Internet Elite (Bundle
Discount) (Expires 08/16/2014)
Total Monthly Charges
Total U-verse Internet
46.00
16.00CR
30.00
NO TEXT IS WORTH THE RISK
Take the pledge at www.itcanwait.com, and make a commitment
to end texting while driving. No text is worth the risk.
It Can Wait.
30.00
Important Information
U-verse Voice
U-verse Voice - Includes over 20 features, including advanced
features that integrate with U-verse TV, Internet, and
Wireless from AT&T.
Monthly Charges - Dec 7 thru Jan 6
1. AT&T U-verse Voice Unlimited 123 555-1111
35.00
LATE PAYMENT FEE
A Late Payment Charge of $8.00 will be assessed if payment is
not received on or before the due date.
ELECTRONIC CHECK CONVERSION
Paying by check authorizes AT&T to use the information from
your check to make a one-time electronic fund transfer from
your account. Funds may be withdrawn from your account as
soon as the same day your payment is received. If we cannot
© 2012 AT&T Intellectual Property. All rights reserved.
ta020714
AT&T CUSTOMER
1234 TELEPHONE LN
ANY CITY ST 99999 - 1234
9565.8.231.51977 1 AV 0.340
AutoPay Enrollment
If I enroll in AutoPay, I authorize AT&T to pay my bill
monthly by electronically deducting money from my bank
account. I can cancel authorization by notifying AT&T at
www.att.com or by calling the customer care number
listed on my bill.
Bank Account Holder Signature: ________________________
Date: ________________________
Exhibit H
U-verse Bill
AT&T CUSTOMER
1234 TELEPHONE LN
ANY CITY ST 99999 - 1234
Sample Bill
Important Information - Continued
process the transaction electronically, you authorize AT&T to
present an image copy of your check for payment. Your
original check will be destroyed once processed. If your check
is returned unpaid you agree to pay such fees as identified
in the terms and conditions of your AT&T Service Agreement.
Returned checks may be presented electronically. If you want
to save time and stamps, sign up for auto payment at
www.att.com/stoppaper using your checking account. It’s
easy, secure, and convenient!
SUPPORT WHEN YOU NEED IT
Need help resolving a problem or want to learn more about the
latest AT&T products? Find answers to commonly asked questions,
get troubleshooting tips and so much more at
att.com/UverseSupport.
ACCOUNT MANAGEMENT MADE EASY
View and pay your bill, track On Demand purchases, change your
plan and features and find support for your U-verse services all in
one place. Visit att.com/myuverse or go to Channel 9910 today!
LEGAL NOTIFICATION
For information on upcoming U-verse TV programming changes
please consult the Legal Notices published in USA Today on the
first and third Tuesday of each month or our website
att.com/U-verseprogrammingchanges.
U-VERSE CLOSED CAPTIONING TECHNICAL SUPPORT:
Telephone: 866-912-8216
Fax: 866-750-6606
E-mail: [email protected]
CLOSED CAPTIONING ISSUES:
Mailing Address: AT&T Closed Captioning, ATTN: Ms. Strohl,
1010 Pine St., 6-E-22, St. Louis, MO 63101
Telephone: 314-235-3333
Fax: 314-335-5735
E-mail: [email protected]
Page
Bill Cycle Date:
Account:
3 of 3
11/07/13 - 12/06/13
123456789
Visit us online at: www.att.com
Wireless
Home Phone
Bill
att.com
Exhibit H
Wireless Home Phone Bill
Page:
Bill Cycle Date:
Account:
Foundation Account:
AT&T CUSTOMER
1234 TELEPHONE LN
ANY CITY ST 99999 - 1234
1 of 4
04/03/13 - 05/02/13
123456789124
FAN 12345678
Sample Bill
Visit us online at: www.att.com
Wireless Statement
Bill-At-A-Glance
Previous Balance
$187.59
Payment - 04/22 - Thank You!
$187.59CR
Adjustments
$0.00
Balance
$0.00
$161.79
New Charges
Total Amount Due
$161.79
Amount Due in Full by
May 22, 2013
Get yours now:
1-866-444-1212, att.com or visit
your local AT&T store.
Wireless
Service Summary
Group 1 - Data Summary
Service
Page
Wireless
Total
$161.79
123 444-2323
$124.57
1
123 444-3434
$37.22
3
Total New Charges
$161.79
Mobile Share 1GB with Unlimited Talk & Text - Includes 1
1 gigabyte of domestic data, $15 per each additional 1 gigabyte
of data. Additional monthly charge applies for each device on
the plan. Unlimited talk & text on phones. Mobile Hotspot,
tethering, video calling, and Visual Voicemail available with
compatible devices. Unlimited domestic data usage on the
AT&T Wi-Fi Basic network.
Mobile Share
Data Used (MB)
123 444-2323
818
205
123 444-3434
Total
1,023
123 444-2323
AT&T CUSTOMER NAME
How to Contact Us:
Mobile Share for Smartphone 4G LTE - Includes unlimited
Anytime Minutes, Nationwide Long Distance & Roaming,
Unlimited domestic text, picture, video and instant messages
and unlimited calling to/from any other domestic mobile phone,
Call Forward feature, Caller ID, Call Wait, Conference Call feature.
Mobile Share voice and data plan required.
For questions about your account: 1 800 331-0500
or 611 from your cell phone
For Deaf/Hard of hearing TTY: 1 866 241-6567
Visit us online at www.att.com
For Important Information about your bill, please
see the News You Can Use section (Page 3).
Return bottom portion with your check in the enclosed envelope.
Payments may take 7 days to post.
DUE BY: May 22, 2013
Wireless Services provided by AT&T Mobility, LLC.
Printed on Recyclable Paper
$161.79
Account Number
123456789124
Please include account number on your check.
Make checks payable to:
CHECK FOR AUTO PAY
(SEE REVERSE)
AT&T MOBILITY
PO BOX 537104
ATLANTA GA 30353-7104
9470012345678912400000000161790000000000016179004
AT&T CUSTOMER
1234 TELEPHONE LN
ANY CITY ST 99999 - 1234
Exhibit H
Wireless Home Phone Bill
Page
Bill Cycle Date:
Account:
Foundation Account:
AT&T CUSTOMER
1234 TELEPHONE LN
ANY CITY ST 99999 - 1234
2 of 4
04/03/13 - 05/02/13
123456789124
FAN 12345678
Visit us online at: www.att.com
123 444-2323
Other Charges and Credits - Continued
AT&T CUSTOMER NAME
Data Usage Summary
Mobile Share with Unlimited Talk & Text Unlimited
Used
255 1
Monthly Charges - May 3 thru Jun 2
1. Mobile Share 1GB with Unlimited Talk & Text
2. Mobile Share for iPhone on 4G LTE
40.00
45.00
Get help and manage your purchases several ways:
- Go to att.com/MobilePurchases
- To speak with a service representative, dial 611 from your
mobile phone, or 1 800-331-0500 from any phone.
1 Gigabyte (GB) = 1024 MB, 1 Megabyte (MB) = 1024 KB
Get help and manage your purchases several ways:
- Go to att.com/MobilePurchases
- To speak with a service representative, dial 611 from your
mobile phone, or 1 800-331-0500 from any phone.
To stop a subscription, text STOP to the Short Code using the
mobile phone associated with those
e charges.. If a Short Code is
not listed go to att.com/directbill.
AT&T Monthly Subscriptions
Date
Cost
AT&T Purchases and Downloads
Tax
3. 04/14 ApplicationsSub: ATT
9.99
0.00
Navigator with promo
Provider: Telenav Inc
Contact: www.att.com/mobilepurchases
Renew Date: 05/13/2013
9.99
0.00
4. 04/16 Multiple Types:
Casualite Alerts
Short Code: 84425 ID: 12143
Provider: Itelia
Contact: 1-800-331-0500
Renew Date: 05/15/2013
Total AT&T Monthly Subscriptions
9.99
9.99
19.98
3rd Party Monthly Subscriptions
Date
Cost
Tax
5. 04/11 Access: 30 Day
5.95
0.00
Subscription
Short Code: 3000 ID: 19449
Merchant: Animal Jam
Contact: BilltoMobile: 888-654-6494
Renew Date: 05/10/2013
Total 3rd Party Monthly Subscriptions
Total Monthly Charges
Mobile Share 1GB with Unlimted Talk & Text
Included in Plan MB
1,024
Individual MB Used
818
Others in Group MB Used
205
Date
Cost
Tax
6. 04/19 Multiple Types:
3.99
0.47
4.36
Ringtones Universe
Provider: AT&T AppCenter - FunMobility Inc.
Contact: att.com/mobilepurchases
7. 04/22 Charitable: mGiveFndn 10.00
0.00
10.00
Short Code: 80108 ID: 19934
Provider: mGive
Contact: att.com/mobilepurchases
8. 04/24 Text Services: CBS Big
1.00
0.06
1.06
Brother ITV Vote
Short Code: 81818 ID: 19634
Provider: mGive
Contact: www.att.com/mobilepurchases
Total AT&T Purchases and Downloads
4.36
5.95
3rd Party Purchases and Downloads
Date
5.95
110.93
Other Charges and Credits
Voice Usage Summary
Mobile Share with Unlimited Talk & Text Unlimited
999,999.99CR
Daytime Minutes
Minutes Used
297
Night & Weekend Minutes
415
Minutes Used
Cost
Tax
9. 04/22 Product 1380 RIOT
10.00
0.00
POINT
Short Code: 26588 ID: 36471
Merchant: Riot Games
Contact: BOKU Inc.: 800-495-1823
Total 3rd Party Purchases and Downloads
Surcharges and Other Fees
10. Administrative Fee
11. Federal Universal Service Charge
12. Regulatory Cost Recovery Charge
Total Surcharges and Other Fees
10.00
10.00
0.61
3.21
0.45
4.27
© 2012 AT&T Intellectual Property. All rights reserved.
051513ct
AT&T CUSTOMER
1234 TELEPHONE LN
ANY CITY ST 99999 - 1234
9565.8.231.51977 1 AV 0.340
AutoPay Enrollment
If I enroll in AutoPay, I authorize AT&T to pay my bill
monthly by electronically deducting money from my bank
account. I can cancel authorization by notifying AT&T at
www.att.com or by calling the customer care number
listed on my bill.
Bank Account Holder Signature: ________________________
Date: ________________________
Exhibit H
Wireless Home Phone Bill
AT&T CUSTOMER
1234 TELEPHONE LN
ANY CITY ST 99999 - 1234
Page
Bill Cycle Date:
Account:
Foundation Account:
3 of 4
04/03/13 - 05/02/13
123456789124
FAN 12345678
Visit us online at: www.att.com
123 444-2323
Other Charges and Credits
AT&T CUSTOMER NAME
Other Charges and Credits
- Continued
Government Fees and Taxes
13. 9-1-1 Service Fee
14. County Sales Tax - Telecom
15. NY State Sales Tax - Telecom
Total Government Fees and Taxes
Total Other Charges & Credits
Total for 123 444-2323
- Continued
4. Regulatory Cost Recovery Charge
5. State Telecommunications Excise
Surcharge
Total Surcharges and Other Fees
1.20
1.84
1.96
5.00
23.63
6. 9-1-1 Service Fee
7. County Sales Tax - Telecom
8. NY State Sales Tax - Telecom
Total Government Fees and Taxes
1.20
1.23
1.31
3.74
124.57
Total Other Charges & Credits
7.22
123 444-3434
Total for Wireless accounts
AT&T CUSTOMER NAME
Mobile Share for Basic Phone - Includes unlimited Anytime
Minutes, Nationwide Long Distance & Roaming, Unlimited
domestic text, picture, video and instant messages and unlimited
calling to/from any other domestic mobile phone, Call Forward
feature, Caller ID, Call Wait, Conference Call feature. Mobile
Share voice and data plan required.
Monthly Charges - May 3 thru Jun 2
37.22
161.79
News You Can Use
ADD A TABLET FROM AT&T
Enjoy gaming, surfing and streaming on more than just Wi-Fi add a tablet from AT&T today. Call 1-800-449-1672 or visit
att.com/addaline to get started.
30.00
Important Information
Other Charges and Credits
Voice Usage Summary
Mobile Share with Unlimited Talk & Text Unlimited
Daytime Minutes
999,999.99CR
Minutes Used
937
Night & Weekend Minutes
715
Minutes Used
Data Usage Summary
Mobile Share with Unlimited Talk & Text Unlimited
Used
259 1
Mobile Share 1GB with Unlimted Talk & Text
Individual MB Used
205
1 Gigabyte (GB) = 1024 MB, 1 Megabyte (MB) = 1024 KB
Surcharges and Other Fees
2. Administrative Fee
3. Federal Universal Service Charge
3.48
Government Fees and Taxes
Total for 123 444-3434
1. Mobile Share for Basic Phone
0.45
0.94
0.61
1.48
LATE PAYMENT FEE
Accounts with former AT&T Wireless plans are charged 1.5%
or less of the balance unpaid as of the next bill period.
Accounts with Cingular/new AT&T plans are charged $5 in CT,
DC,DE,IL,KS,MA,MD,ME,MI,MO,NH,NJ,NY,PA,OK,OH,RI,VA,
VT,WI,WV, or 1.5% of the balance unpaid as of the next bill
period in all other states. Accounts with former AT&T Wireless
and Cingular/new AT&T plans incur the lesser of these charges.
ELECTRONIC CHECK CONVERSION
Paying by check authorizes AT&T to use the information from
your check to make a one-time electronic fund transfer from
your account. Funds may be withdrawn from your account as
soon as the same day your payment is received. If we cannot
process the transaction electronically, you authorize AT&T
to present an image copy of your check for payment. Your
original check will be destroyed once processed. If your check
Exhibit H
Wireless Home Phone Bill
AT&T CUSTOMER
1234 TELEPHONE LN
ANY CITY ST 99999 - 1234
Sample Bill
Important Information - Continued
is returned unpaid you agree to pay such fees as identified
in the terms and conditions of your AT&T Service Agreement.
Returned checks may be presented electronically. If you want
to save time and stamps, sign up for auto payment at
www.att.com/stoppaper using your checking account. It’s
easy, secure, and convenient!
TAX ID
AT&T Mobility Tax ID # 84-1659970.
SURCHARGES AND OTHER FEES
In addition to the monthly cost of the rate plan and any selected
features, AT&T imposes the following other charges, on a per
line basis: (1) federal and state universal service charges, (2) a
Regulatory Cost Recovery Charge of up to $1.25 to help defray its
cost incurred in complying with obligations and charges imposed
by state and federal telecom regulations, (3) an Administrative Fee
on consumer and Individual Responsibility User (IRU) lines to help
defray certain expenses AT&T incurs, such as interconnection
and cell site rents and maintenance, and (4) other government
assessments, including without limitation a gross receipts
surcharge and a Property Tax Allotment surcharge of $0.20 $0.45 applied per Corporate Responsibility User’s assigned
number. These fees are not taxes or government-required charges.
See att.com/additionalcharges.
SINGLE PAYMENT AGREEMENT (FOR KIOSK PAYMENT)
For Kiosk Payment: I authorize AT&T to pay my bill by debiting my
bank account. If my bank rejects a payment, I may be charged a
return fee up to $30.
AT&T NATL CENTER FOR CUSTOMERS WITH DISABILITIES
Questions on accessibility by persons with disabilities:
1 866 241-6568.
WRITTEN CORRESPONDENCE
Do not send notes/letters with payment. We cannot guarantee
receipt. Send notes/letters to AT&T Mobility Customer Care, PO
Box 755, Atwater, CA 95301
Page
Bill Cycle Date:
Account:
Foundation Account:
4 of 4
04/03/13 - 05/02/13
123456789124
FAN 12345678
Visit us online at: www.att.com
Was this manual useful for you? yes no
Thank you for your participation!

* Your assessment is very important for improving the work of artificial intelligence, which forms the content of this project

Download PDF

advertisement