20131029QLW to Staff 1-13.pdf

Lance J.M. Steinhart, P.C.
Attorneys At Law
I 725 Windward Concourse
Suite 150
Alpharetta, Georgia 30005
Also Admitted in New York
Email: [e-mail]
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Telephone: [phone]
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October 28,2013
VIA OVERNIGHT DELTVERY
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise,Idaho 83702
Re: Q LINK WIRELESS LLC (Case No. QLW-T-13-01)
Responses to First Production Request of the Commission Staff to Q LINK
WIRELESS LLC
Dear Ms. Jewell:
Enclosed please find for filing three (3) copies of Q LINK WIRELESS LLC's ("Q LINK" or
the "Company'') Responses to the First Production Request of the Commission Staffto Q LINK.
Q LINK has also enclosed one (1) copy on YELLOW PAPER of Production Request
Exhibit I (Q LINK's 2012 Financial Information) and one (l) copy on YELLOW PAPER of
Production Request Exhibit 2 (QUADRANT HOLDINGS GROUP LLC's 2012 Financial
Information) in separate sealed envelopes marked "CONFIDENTIAL." This Financial
Infonnation is protected by law from public inspection, examination or copying. Q LINK
respectfully requests the appropriate confidential treatment of the enclosed Financial
Information in accordance with Rule 67 of the Commission's Rules of Procedure. Both Q
LINK and its parent holding company QUADRANT HOLDINGS GROUP LLC are privately-
held limited liabitity companies that restrict review of any financial information. Disclosure of
the enclosed Financial Information would ham Q LINK and put the Company at a
competitive disadvantage. Q LINK expects that the Financial Information will be restricted to
counsel, agents, and employees who are specifically assigned to this Case No. QLW-T-13-01 by
the Commission.
Idaho Public Utilities Commission
October 28,2013
Page 2
I have also enclosed an extra copy of this letter to be date stamped and retumed to me in the
enclosed, self-addressed, postage prepaid envelope. If you have any questions or if I may provide you
with additional ffirmation, please do not hesitate to contact me. Thank you.
Kasey C. Chow, Esq.
Associate at Lance J.M. Steinhart, P.C.
Attorneys for Q LINK WIRELESS LLC
Enclosurescc: Issa Asad
Neil Price, Attorney for Commission Staff
Grace Seamarq Technical Staff
Respectfully submitted,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF Q LINK WIRELESS LLC FOR )
LIMITED DESIGNATION AS AN )
ELIGIBLE TELECOMMUNICATIONS )CARRIER )
)
)
)
cAsE NO. QLW-T-13-01
RESPONSES TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO Q LINK
WIRELESS LLC
Q LINK WIRELESS LLC ("Q LINK" or the "Company"), by and through its counsel,
Lance J.M. Steinhart, P.C., provides the following in response to the Staffof the Idaho Public
Utilities Commission's (o'Staff') First Production Request to Q LINK:
REQUEST NO. 1: Based on the Secretary of State documents, Q LINK's Certificate of
Authority to conduct business in ldaho was approved on December 28, 2011. Please indicate if
the Company has current customers in Idaho.
RESPONSE: The Company does not have current customers in ldaho.
REQUEST NO. 2: All wireless carriers, including mobile network virtual operators
(MNVO) are required to remit fees associated with the Idaho Telephone Assistance Program
(ITSAP) and E9l ll9ll. Please confirm that Q LINK understands and will comply with the
remittance of ITSAP, E-911 and other applicable fees.
RESPONSE: Q LINK understands and will comply with the remittance of all fees
to the extent such fees are applicable to the Company as a wireless Eligible
Telecommunications Carrier ("ETC'), including, but not limited to ITSAP and E-911 fees.
REQUEST NO.3: On page 5 of the Application, Q LINK states that "customers can
purchase additional bundles of minute in denominations as low as $10, $20, $35, $50, and $60."
Please explain the minutes of talk time or text messages associated with each denomination.
How do these denominations correlate with the Q LINK cards described in Exhibit F Terms and
Conditions?
RESPONSES TO FIRST PRODUCTION
REQUEST TO Q LINK WIRELESS October 28,2013
RESPONSE: Up-to-date information on Q LINK's additional minutes can be found
on the Company's website here -
httns://www.qlinkwireless.com/members/cart/quickpurchase.aspx. The $10 denomination
is 50 minutes for 30 service days; the $20 denomination is 100 minutes for 30 service days;
the $30 denomination is 150 minutes for 30 service days; the $35 denomination is 200
minutes for 60 service days; the $50 denomination is 500 minutes for 60 seroice days; and
the $60 denomination is unlimited minutes for 30 service days. Texting is at a rate of one
minute, i.e., one incoming or outgoing text is equal to one minute of voice.
Exhibit F Terms and Conditions is an exhibit of the Company's Application Exhibit
4 Q LINK's FCC Compliance Plan as filed with the FCC on July 30,2012 (and approved
by the FCC August 8,2012). Up-to-date Tenns and Conditions can be found on the
Company' s website here - h ttn s : //www. q lin kwi reless. com/term s.asrrx.
REQUEST NO. 4: On page 5 of the Application, Q LINK indicates that it blocks
roaming; please verify that 9l I calls will be allowed while roaming.
RESPONSE: 911 calls are always allowed, regardless of distance, service activation,
or availability of minutes.
REQUEST NO. 5: On page 17 of the Application, Q LINK states that it "intends to
launch its retail and Lifeline wireless service simultaneously." Does Q LINK provide retail
services not tied to Lifeline? [f yes, please explain.
RESPONSE: Q LINK's prepaid minute cards are available to both retail wireless
and Lifeline wireless customers alike.
REQUEST NO. 6: Exhibit C Confidential Financial information is redacted. Please
provide a copy of the financial information without the redaction. If you wish to keep this
information from public review, please follow Rule 67 of the Commission's Rules of Procedure.
See IDAPA 31.01.01 Rule 67.
RESPONSE: Exhibit C Financial Infomation is an exhibit of the Company's
Application Exhibit 4 Q LINK's FCC Compliance Plan as filed with the FCC on Juty 30,
2012 (and approved by the FCC August 8,2012). That exhibit is no longer the most
RESPONSES TO FIRST PRODUCTION
REQUEST TO Q LINK WIRELESS 2 October 28,2013
current financial information for Q LINK. A copy of the Company's2012 Balance Sheet
and Profit & Loss Statement as well as a copy of the Company's parent holding company
QUADRANT HOLDINGS GROUP LLC's 20l2Balance Sheet and Profit & Loss
Statement are being filed herewith as Production Request Exhibit 1 and Production
Request Exhibit 2, respectively, in accordance with Rule 67 of the Commission's Rules of
Procedure to evidence the Company's financial capability.
REQUEST NO. 7: On page 21 of the Third Amended Compliance Plan, dated July 20,
2012 (Exhibit 4), the Company states that it does not currently provide service in any state.
Please submit a current list of states where Q LINK is providing Lifeline service.
RESPONSE: The Company's Application Exhibit 4 is Q LINK's FCC Compliance
Plan as liled with the FCC on July 30,2012 (and approved by the FCC August 8,2012).
On page 3 of the Company's Application, Q LINK stated that as of the date of filing (May
3,2013), it has been designated as an ETC in Arizona, Colorado, Kansas, Kentucky, Maine,
Maryland, Michigan, Minnesota, Missouri, Nevada, Ohio, Oklahoma, Pennsylvania, Texas,
Utah, West Virginia, and Wisconsin. Q LINK is currently providing Lifeline seryice in all
of these states, as well as the following newly-approved jurisdictions: Iowa, South Carolina,
and Vermont.
REQUEST NO. 8: On the Q LINK website,
https://qlinkwireless.com/register/default.aspx, the Company displays a matrix with the
headings: Free Plan Feature, Q Link Wireless, and Others. This matrix states that Q LINK offers
all the features listed such as National Long Distance, Free Minutes Every Month, Local Calls,
etc. It appears that the "Others" heading does not offer any of the features on the matrix. Please
explain.
RESPONSE: This matrix was an outdated comparison between a paid plan and a
free plan; this has since been updated on Q LINK's website.
REQUEST NO. 9: On the Q LINK website, and under How Q Link's Lifeline Program
Works, one of the bullet items states "250 FREE Minutes Every Month." The ETC Application
lists four Lifeline plans and only one of the plans includes 250 minutes. The ETC Application
RESPONSES TO FIRST PRODUCTION
REQUEST TO Q LINK WIRELESS October 28,2013
Exhibit B (Q LINK WIRELESSTM Lifeline Terms and Conditions of Service) lists three plans
and only one includes 250 minutes. Please explain the inconsistencies and veriff which
information source is correct for Idaho.
RESPONSE: Exhibit 2 Proposed Lifeline Offering of the Company's Application is
correct for ldaho. This Exhibit 2 Proposed Lifeline Offering lists four plans; the first three
plans are the Company's standard 68 minutes, 125 minutes, and 250 minutes Lifeline plans
available to Non-Tribal Lifeline customers. The fourth plan is only available to Tribal
Lifeline customers. These four plans are also outlined on pages 4-5 of the Company's
Application.
REQUEST NO. 10: On the Q LINK website under the About Us link, the Company
claims it is known for "superior customer support." On the Dania, Florida BBB Business
Review website: http://www.bbb.org/south-east-florida/business-reviews/telephone-equipment-
and-systems-repair-service/q-link-wireless-in-dania-fl-90052553 the Company received a failing
grade due to the number of complaints received (70), the number of failures to respond to
complaints (18) and the number of unresolved complaints (6). Please explain.
RESPONSE: The complaints are unrelated to customer support. The majority of
the consumer complaints are from consumers who have been denied Lifeline senice by Q
LINK because they did not meet Lifeline eligibility requirements or because the consumers
are attempting to apply in a jurisdiction where Q LINK does not yet have ETC
designation. The number of complaints is less than 0.01o/o of the total number of
subscribers Q LINK has, which is an exceptionally low percentage. All Q LINK customers
receive quality customer care support. Atl consumer complaints are responded to and Q
LINK always attempts to seek satisfactory resolutions whenever possible.
RBQUEST NO. 11: On June 25,2013,the FCC released Enforcement Advisory DA
13-1435 and DA 13-1441. Please acknowledge that the Company has reviewed these Orders and
will comply.
RESPONSE: Q LINK has reviewed and will comply with FCC Enforcement
Advisory DA 13-1435 and DAl3-1441. As always, Q LINK has and will continue to
comply with all FCC rules and regulations.
RESPONSES TO FIRST PRODUCTION
REQUEST TO Q LINK WIRELESS October 28,2013
REQUEST NO. 12: The Idaho PUC understands that Puerto Rico initially denied Q
LINK's ETC Application due to negative working capital. Q LINK filed a Motion for
Reconsideration. Please provide a status on that case.
RESPONSE: The Puerto Rico Telecommunications Regulatory Board has granted
Q LINK a hearing; the hearing is set for November 26,2013.
REQUEST NO. 13: Effective September 30,2013, all wireless carriers are required to
send an automatic "bounce-back" message to any consumer who tries to send a text message to a
911 center where this service is not yet available. Please verify that Q LINK and its underlying
carrier will continue complying with this requirement.
RESPONSE: Q LINK will continue complying with this requirement.
The name, job title, location, and telephone number of the preparer and record holder for
all of the foregoing responses is as follows:
Issa Asad
CEO of Q LINK WIRELESS LLC
499 East Sheridan Street
Suite 300
Dania, FL 33004
(954) 482-42ss
Respectfully submitted,
Lance J.M. Steinhart, P.C.
Attorneys at Law
I 725 Windward Concourse
Suite 150
Alpharetta, GA 30005
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Q LINK MRELESS LLC
Dated: October 28,2013
RESPONSES TO FIRST PRODUCTION
REQUEST TO Q LINK WIRELESS October 28,2013
PRODUCTION REOUEST EXHIBIT 1
Copy of Q LINK WIRELESS LLC's 20l2Balance Sheet and20l2 Profit & Loss Statement
CONFIDENTIAL
CONFIDENTIAL
This page allegedly contains trade secrets or confidential material and is separately filed.
PRODUCTION REOUEST EXHIBIT 2
Copy of QUADRANT HOLDINGS GROUP LLC's 20l2Balance Sheet
and2012 Profit & Loss Statement
CONFIDENTIAL
CONX'IDENTIAL
This page allegedly contains trade secrets or conlidential material and is separately filed.