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RECEIVED
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Suite 800
1 91 9 Pennsylvania Avenue NW
Washington, DC 20006-3401
Michael C. Sloan
202.973.4227 (Tel)
202.973.4499 (Fax)
michaelsloan@dwt.com
VIA OVERNIGHT MAIL
January 18,2018
Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472West Washington'
Boise, ID 83702 Lrz-T- t8'02*
RE: Comcast Phone of ldaho, LLC Applicationfor Registration to Provide llholesale
Loc al Te leco mmunications S e rvic es
Dear Ms. Hanian:
Included herein please find the Application of Comcast Phone of Idaho, LLC
("Comcast") for Registration to Provide Whole Telecommunications Services in the State of
Idaho. Comcast respectfully requests that the Idaho Public Utilities Commission approve
Comcast's application for registration as a provider of wholesale local telecommunications
services within the State of ldaho.
I have also enclosed an additional copy of this letter to be date stamped and returned to
me in the enclosed, self-addressed, postage-prepaid envelope.
Thank you for your prompt attention to this matter. Please do not hesitate to contact me
if you have any questions or need any further information.
Respectfully yours,
Michael C. Sloan
48 I 6-2585-3786v. I 0 I 06080-0001 79
RECEIVED
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Application for Registration of
Comcast Phone of Idaho, LLC
To Provide Facilities-Based Wholesale
Local Telecommunications Service
Throughout ldaho
Michael C. Sloan
Davis Wright Tremaine LLP
1919 Pennsylvania Ave NW Suite 800
Washington, DC 20006
P: (202) 973-4227
Email : m ichaelsloan@dwt.com
CaseNo. C Pi- r- tg -o ^
Beth O'Donnell
Comcast Phone of ldaho, LLC
Director, Regulatory Affairs
One Comcast Center, 55th Floor
1701 JFK Blvd.
Philadelphia PA 19103
P: (21s)286-s187
Email : Beth_ODonnell@Comcast.com
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APPLICATION FOR REGISTRATION TO PROVIDE WHOLESALE LOCAL
TELECOMMUNICATIONS SERVICES
Pursuant to IDAPA 3 I .01 .01 . I I 4 and the Idaho Public Utilities Commission Order No.
32277 in Case No. GNR-T-II-01, Comcast Phone of Idaho, LLC ("Comcast Phone" or
"Company") respectfully requests that the Idaho Public Utilities Commission ("Commission")
approve the Company's application for registration as a provider of wholesale local
telecommunications services within the State of Idaho.
All correspondence, notices, inquiries and other communications regarding this
Application should be addressed to the following:
In support of this Application, Comcast Phone submits the following information:
01. Name, Address and Form of Business:
(a) Comcast Phone of Idaho, LLC is a limited liability company organized in the
State of Delaware. The main address of the Company is:
One Comcast Center
Philadelphia, PA 19103
Exhibit A includes a copy of the Company's Certificate of Formation, and the
Secretary of State certificate.
4844-3799-6890v I 0 106080-0001 79
The Company's Registered Agent in Idaho is:
C T Corporation System
921 S. Orchard Street, Suite G
Boise, ID 83705
(b) Officers and Directors
Officers and Directors of Comcast Phone are provided as Exhibit B.
(c) Stockholders/Owners
Comcast Phone of ldaho, LLC is wholly 100% indirectly owned by Comcast
Corporation, Inc.
02-04. Not applicable
05. Tariff and Customer Contact
The contact for resolution of customer complaints is:
Don Laub
VP Regulatory Affairs
183 Inverness Drive West
Englewood, CO 801l2
(Tel):720-268-8022
Don_Laub@cab le. comcast.com
The contact for resolution of customer complaints with the Commission is also Don
Laub. Mr. Laub is also responsible for responding to Commission inquiries concerning
rates and price lists or tariffs.
06. Interconnection Agreements
Comcast Phone has obtained an interconnection agreement with Qwest Corp. dlbla
CenturyLink, which was filed with the Commission on August 10, 2017 and approved on
August 24,2017. See Commission Order No. 33855 (Case No. QWE-T-17-02).
2
4844-3799-6890v. I 0 I 06080-000 I 79
07. Compliance with Commission Rules
Comcast Phone has reviewed all of the Commission rules and agrees to comply with the
rules applicable to the competitive wholesale providers of local telecommunications
services.l The Company respectfully requests a waiver of rules not applicable to such
service providers.
08. Conservation of Telephone Numbers
The Applicant acknowledges that, if it obtains numbering resources in Idaho, it willbe
subject to the numbering conservation measures, including mandatory one thousand
block pooling, donation back to the pool of unused or underutilized thousand number
blocks, and submission of applicable utilization forecast reports at the one thousand block
level for each rate center within its service territory.
Wherefore, Comcast Phone of Idaho, LLC respectfully requests that the Commission
1. Approve Comcast Phone of Idaho, LLC's application for registration to provide
wholesale localtelecommunications services within the State of Idaho;and
2. Grant such other relief as it deems necessary and appropriate
Respectfully submitted,
Comcast Phone of ldaho. LLC
lsl Brian A. Rankin
Brian A. Rankin
Comcast Phone of ldaho, LLC
One Comcast Center, 55th Floor
Philadelphia, PA 19103
I The authority sought here is consistent with that granted to wholesale providers in several
recent Commission decisions. See, e.g., Application of Native Network, Inc. to Register as a
Wolesale Telecommunications Provider in ldaho, Order No. 33819, Case No NNI-T-17-01
(Idaho Public Service Commission July 25,2017); Application of Extenet Systems, Inc. to
Register as a W'holesole Telecommunications Provider in ldaho, Order No. 33572, Case No
ENS-T-16-01 (ldaho Public Service Commission August 17,2016).
4844-3799-6890v I 0 I 06080-000 I 79
J
State of ldaho
CERTTFICATE OT EXISTENCE
oF'
COMCAST PHONE OF IDAHO, LLC
File Number W-86946
I, LAWERENCE DENNEY. Secretary of State of the State of ldaho, hereby certifo that I am the custodian of the
limited liability company records of this State.
I I-'URTHER CERTIFY That the records of this office show that the above-named limited liabiliry company' was
organized under the laws of DELAWARE and frled for authorization to transact business in ldaho oa9l1612A09.
I FURTHER CERTI}'Y That the limited liability company's certificate of authority has not been canceled.
Dated: 512412016 8:06 AM
SECRETARY OF STATE
Authentic Access ldaho l)ocument ( )
Tag: b5ae5t5ft8d74087b450caead564a94120522l065374lfll5dt33a3cl8afatite056c235b2ada6b5d
Office of the Secreta ry of State
fawore PAGE 7
Tfic first Stote
r, ,JEFFREY W. BULLOCK, SSCfiSTaRY OF STATE OF TEE STATE OF
DELAWARE, DO HEREBY CERTTW TIIE ATTACITED -r.9 A TRUE N;tD CORRECT
COPY OF ItHg CERITZFICATE OT FORMATION OF "COACAST PHONE OF TDAAO,
LLC", FrtED rN TEIS OFFICE ON TfrE TANTH DAy OP SEPTEMBER, A.D-
2009t AT 7:26 o'CLOcK P-rit.
,effrey w.Bullock, Secretary of state: 7579682
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DATE:09-70-09
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090845435
Stat€ of blawaresec!€fary of Sf.abDiwision of CorprationsDeIivErEd 07:46 ilr 09/70/2009ItrLED 07:26 PM 09/70/2009*r, 090845435 - 4729222 EILE
CERTIFICATE OF TORMATION
oF
COMCAST PHOFTE OE IDAEO. LLC
This Certificate of Formation of Comcast Phonc of Idaho, LLC, datcd Scptember 10, 2009, is
being duly cxccuted and filcd by Margaret Francione, as an authorizcd pcmonr to form a limited liabilrty
company r.nrder the Dclaware Limited Liability Conryrny Act (6 Dcl. C. $ I 8-201 , et Scq).
FIRST: Thc name of the limited liability company formcd hereby is:
Comcast Phone of Idaho, LLC.
SECOND: The name and address of the registered agant for service of proccss in the Statc
of Delaware is Comcast Capital Corporation, 1201 N. Market Stree! Suite 1000, Wilmington, DE 19801,
New Castle County,
IN WITNESS WHEREOF, the rmdersigncd has orecuted this Certificatc of Formation as of the
datc first writtcn above.
Person
EXHIBIT B
Officers and Directors
All officers and directors can be reached at the Company's headquarters location: One Comcast
Center, Philadelphia, PA 19103.
Roberts, Brian L., Chairman, Chief Executive Officer, President, Comcast Corp.
Watson, David N., Chief Executive Officer & President Comcast Cable
Jenckes, Marcien, President - Advertising
Stemper, William R., President - Business Services
Kimball, Bridget D., President - CCAD, Senior Vice President - Software Development and Engineering
Baer, Joy, President - Strata Operations
Werner, Tony G., President - Technology and Product
Butz, Gregory R, President - Wireless
Cavanagh, Michael J., Chief Financial Officer and Senior Executive Vice President
Croney, Steven T., Chief Financial Officer and Executive Vice President
Schwartz, Samuel H., Chief Business Development Officer and Executive Vice President - Business
Development
Herrin, Charles D., Chief Customer Experience Officer
Hofmeyr, Jan, Chief Network Officer and Senior Vice President
Satchell, Christopher, Chief Product Officer and Executive Vice President
Davis, Noopur, Chief Product and Information Security Officer
Cohen, David L., Senior Executive Vice President, Assistant Secretary, Executive Vice President,
General Counsel
Charytan, Lynn R., Executive Vice President and General Counsel Cable
Clark, David, Executive Vice President
Clark, David, General Manager - Advanced Advertising
Kiriacoulacos, Peter (Comcast) Executive Vice President and Chief Procurement Officer
Rigdon, Gregory S., Executive Vice President - Content Acquisition
Karinshak, Thomas Allen, Executive Vice President - Customer Service
Brassel, Edwin, Executive Vice President - Enterprise Business Intelligence
Eatroff, Robert, Executive Vice President - Global Corporate Development and Strategy
Strahan, William J., Executive Vice President - Human Resources
Lang, Richard A., Executive Vice President - Sales and Marketing Operations
Strauss, Matthew E., Executive Vice President - Xfinity Services
Alcott, Scott P., Senior Vice President and Chief Information Officer
Dordelman, William E., Senior Vice President and Treasurer
Gitchell, Sarah, Senior Vice President, Deputy General Counsel and Chief Counsel - Content Acquisition
Koles, Kathryn, Senior Vice President and Deputy General Counsel
Laine, Julie, Senior Vice President and Chief Compliance Officer
Lewis, Jr., Gerard J., Senior Vice President, Chief Privacy Officer and Deputy General Counsel
Loretan, Thomas R., Senior Vice President and Executive Creative Director
Marcus, David L., Senior Vice President, Deputy General Counsel and Chief Litigation Counsel
Murdock, Daniel C., Senior Vice President, Chief Accounting Officer and Controller
Smith, Jeffrey E., Senior Vice President, Deputy General Counsel - General Operations
Soehren, Martha S., Senior Vice President and Chief Talent Development Officer
Dougherty Buchholz, Karen, Senior Vice President - Administration
Heslip, John E., Senior Vice President - Access Networks and Technical Operations
Wallach, Brian Andrew, Senior Vice President - Advanced TV Sales
Sirota, Marc S., Senior Vice President - Applied Analyics, Enterprise Business Intelligence
Arat4 Todd, Senior Vice President - Brand Marketing
Intermaggio, Peter, Senior Vice President - Brand Marketing and Communications
Hess, Mark E., Senior Vice President - Business and Industry Affairs
Gaiski, Christopher J., Senior Vice President - Business Operations, Care and CX
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