200507051st Level 3 objections, requests.pdf

ORIGINAL
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: [phone]
j oe~mcdevitt -miller .com
Attorneys for Level Communications, LLC
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MA TTER OF LEVEL 3
COMMUNICATIONS, LLC'S PETITION
FOR ARBITRATION PURSUANT TO
SECTION 252(B) OF THE
COMMUNICATIONS ACT OF 1934, AS
AMENDED BY THE
TELECOMMUNICATIONS ACT OF 1996
AND THE APPLICABLE STATE LAWS FOR
RATE, TERMS, AND CONDITIONS OF
INTERCONNECTION WITH QWEST
CORPORATION
Case No. QWE-O5-
OBJECTIONS OF LEVEL 3
COMMUNI CA TI 0 NS, LLC TO
QWEST CORPORATION'S FIRST
SET OF INTERROGATORIES AND
REQUEST FOR PRODUCTION OF
DOCUMENTS
COMES NOW Level 3 Communications, LLC ("Level 3"), pursuant to IPUCRP 225-
by and through its undersigned attorneys, and hereby submits its Objections to Qwest
Corporation s ("Qwest") First Set of Interrogatories and Request for Production of Documents as
follows:
GENERAL OBJECTIONS
Level 3 objects to Qwest's instructions and to each request to the extent that such
request seeks the disclosure of information or documents containing privileged communications
attorneys' work product or trial preparation material, and/or other protected information on the
grounds that such discovery is not permissible under the applicable rules of the Idaho Public
Utilities Commission. Level 3 further objects to each request to the extent that each seeks the
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
disclosure of information or documents that are subject to any obligation of confidentiality owed
by Level 3 to any third party without an adequate protective agreement.
Level 3 objects to each and every data request to the extent that the information
requested is "confidential
" "
highly sensitive confidential " or constitutes "trade secrets
pursuant to Idaho law. To the extent that Qwest requests such proprietary, confidential or
competitively sensitive business information, Level 3 will only make such information available
once a Protective Agreement is executed in this docket.Any production by Level 3 of
confidential information or material will be governed by the Protective Agreement to be
executed in this docket.
Level 3 objects to each and every data request insofar as the data requests are
vague, ambiguous, overly broad, unduly burdensome, imprecise, or utilize terms that are subject
to multiple interpretations but are not properly defined or explained for purposes of these data
requests. Any answers provided by Level 3 in response to the data requests will be provided
subject to, and without waiver, of the foregoing objections.
Level 3 objects to each and every data request insofar as it is not reasonably
calculated to lead to the discovery of admissible evidence and is not relevant to the subject
matter of this action.
Level 3 objects to Qwest's data requests insofar as they require the production of
documents that are within the control of Qwest.
Level 3 objects to Qwest's data requests to the extent they seek to Impose
obligations on Level 3 that exceed the requirements of applicable law.
Level 3 objects to Qwest's instructions and the requests to the extent that any
instruction or request requires Level 3 to respond more fully than is required by Idaho law or the
rules of the Idaho Public Utilities Commission.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGA TORIES-
Level 3 objects to any discovery request that seeks to obtain "all
" "
each " or
every" document, item, customer, or other such piece of information to the extent that such
requests are overly broad and unduly burdensome. Any answers provided by Level 3 in response
to this discovery will be provided subject to, and without waiver of, the foregoing objection.
Level 3 objects to any discovery request that calls for a legal conclusion. Such
discovery not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action.
10.Level 3 objects to the requests to the extent such requests seek to have Level 3
conduct a special study and create documents not in existence at the time of the request.
11.Level 3 objects to the requests to the extent that the requests are not limited to any
stated time period or a stated period of time that is longer than is relevant for purposes of the
issues in this docket and are not limited by geography or jurisdiction, as such discovery is overly
broad and unduly burdensome, and is not reasonably calculated to lead to the discovery of
admissible evidence and is not relevant to the subject matter of this action..
12.Level 3 objects to each and every request that seeks information, to the extent
such is requested, regarding Level 3' s projections regarding future services, revenues, marketing,
strategies, equipment deployments, or other such future business plans as such requests are trade
secrets and, for purposes of this proceeding, would be highly speculative and irrelevant to the
issues to be decided in this docket.
13.Level 3 objects to the requests to the extent they seek information not within
Level 3' s possession, control, or custody or to the extent the requests ask that Level 3 provide
information that Level 3 does not maintain in the ordinary course of business and, therefore
requests information that cannot be provided without completing a special study or analysis.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
SPECIFIC OBJECTIONS
DATA REQUEST NO.Identify by state and case number each section 252
arbitration case or docket that Level 3 has filed against a LEC other than Qwest and each case in
which a LEC filed for arbitration against Level 3 within the past three years in which contract
language regarding any of the following issues was at issue:
(a)
(b)
(c)
single point of interconnection with a LATA;
financial responsibility for transport facilities used by ILECs to deliver
traffic to the POI of the CLEC;
commingling of switched access traffic with other types of traffic on local
interconnection service (LIS) trunks;
(d)
(e)
relative use factors with regard to ISP-bound traffic;
intercarrier compensation for ISP-bound traffic;
(t)
(g)
(h)
the definition of Voice over Internet Protocol (VoIP) service or traffic;
intercarrier compensation for VoIP traffic;
the appropriate categorization of VoIP traffic under the 1996 Act;
(i)the definition of any of the following terms:
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
Automated Message Accounting;
Switch Technology;
Basic Exchange Telecommunications Service;
Call Record;
Exchange Access;
Interconnection;
Interexchange Carrier;
IntraLA T A toll traffic;
Local Interconnection Service;
LIS Entrance Facility;
Telephone Exchange Service; or
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--4
(k)
(1)
(m)
(n)
(0)
(P)
(12)Telephone Toll Service.
deposits related to forecasts of facilities;
the use of jurisdictional allocation factors to identify compensation for
various types of traffic;
the FCC's 3:1 ratio related to ISP-bound traffic;
the proper use of signaling information;
disclaimers with regard to special construction charges;
the use of "Originating Line Indicator" as defined in Level 3 's proposed
contract language, SS7 parameter, or any other signaling parameter for the
identification of VoIP traffic; or
Call Record Information (CRI) signaling parameter.
OBJECTION TO DATA REQUEST NO.Level 3 objects to this data request insofar
as it is not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Level 3 further objects to this request in so far as it
requires Level 3 to compile a list that does not currently exist or conduct a special study, and that
the information sought is publicly available information that may as readily be compiled by
Qwest as by Level 3. Level 3 also objects to this request on the basis that it is vague, ambiguous
overly broad, unduly burdensome and imprecise, and utilizes terms that are subject to multiple
interpretations but are not properly defined or explained. Level 3 further objects to this request to
the extent it is not limited by time or geographic location.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO.For each case or docket identified in the prior request
identify the other LEC involved in the case or docket, the state commission, the docket number
of the case, its current status, whether an order has been issued (if so, when), whether the order is
on rehearing or appeal, the current status of rehearing or appeal, and, if appealed to a court, to
which court the appeal was made (including case number of the appeal).
OBJECTION TO DATA REQUEST NO.See Level3's Objection to Request No.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--6
DATA REQUEST NO.How many Points of Interconnection ("POls ) presently
exist between Qwest and Level 3 in Idaho for the exchange of traffic and what are their
locations?
OBJECTION TO DATA REQUEST NO.Level 3 objects to this data request insofar
as it seeks information already in the possession of Qwest and therefore may just as readily be
compiled by Qwest as by Level 3. Level 3 further objects to this data request to the extent that
the information requested is "confidential
" "
highly sensitive confidential " or constitutes "trade
secrets" pursuant to Idaho law. To the extent that Qwest requests proprietary confidential
business information, Level 3 will only make such information available once a Protective
Agreement is executed in this docket. Any production by Level 3 of confidential information or
material will be governed by the Protective Agreement to be executed in this docket. Subject to
and without waiving these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO.Does Level 3 have any affiliates that operate in Idaho? If so
identify each such affiliate.
OBJECTION TO DATA REQUEST NO.Level 3 objects to this request insofar as
it is not reasonably calculated to lead to the discovery of admissible evidence and is not relevant
to the subject matter of this action
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO.For each affiliate identified in the prior request, identify any
and all types of Level 3 network facilities (Le. switching, routing and transport) that are shared
with Level 3 affiliates in Idaho.
OBJECTION TO DATA REQUEST NO.See Level3's Objections to Request No.
4. In addition, Level 3 objects to this request on the basis that it is vague, ambiguous, overly
broad, unduly burdensome, and imprecise, and utilizes terms that are subject to multiple
interpretations but are not properly defined or explained.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO.Provide on a quarterly basis, beginning in January 2004
through the most recent quarter, the number of minutes of use (MOUs) of each type of traffic
(e., IntraLA T A toll traffic, InterLA T A toll traffic, ISP-bound traffic, Local/EAS traffic
Feature Group traffic, Transit Traffic, VoIP traffic) that Level 3 delivered to Qwest in Idaho.
OBJECTION TO DATA REQUEST NO.Level 3 objects to this data request to the
extent it requires Level 3 to conduct a special study. Level 3 further objects to this request
insofar as it seeks information already in the possession of Qwest and therefore may just as
readily be compiled by Qwest from its own information as by Level 3. Level 3 further objects
to this data request to the extent that the information requested is "confidential
" "
highly
sensitive confidential " or constitutes "trade secrets" pursuant to Idaho law. To the extent that
Qwest requests proprietary confidential business information, Level 3 will only make such
information available once a Protective Agreement is executed in this docket. Any production
by Level 3 of confidential information or material will be governed by the Protective Agreement
to be executed in this docket. Level 3 further objects to this request on the basis that it is vague
ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes terms that are subject
to multiple interpretations but are not properly defined or explained. Subject to and without
waiving these objections, Level 3 will respond to this request by supplying any relevant
responsive information it maintains in the ordinary course of business that is responsive to this
request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO.For each type of traffic described in the previous question
does Level 3 compensate Qwest for terminating such traffic? Describe the method of
compensation for each type of traffic
OBJECTION TO DATA REQUEST NO.See Level3's Objections to Request No.
6 Subject to and without waiving these objections, Level 3 will respond to this request by
supplying any relevant, responsive information it maintains in the ordinary course of business
that is responsive to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO.Describe all technical limitations that would prevent Level 3
from routing both its local and toll traffic to Qwest over a Feature Group D trunk group. Provide
all documents evidencing any such limitations.
OBJECTION TO DATA REQUEST NO.Level 3 objects to this request on the basis
that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes terms
that are subject to multiple interpretations but are not properly defined or explained. Level 3
objects to the data request in that it seeks to obtain "all documents" to the extent that such
request is overly broad and unduly burdensome. Level 3 further objects to this data request to
the extent that the information requested is "confidential
" "
highly sensitive confidential " or
constitutes "trade secrets" pursuant to Idaho law. To the extent that Qwest requests proprietary
confidential business information, Level 3 will only make such information available once a
Protective Agreement is executed in this docket. Any production by Level 3 of confidential
information or material will be governed by the Protective Agreement to be executed in this
docket. Level 3 further objects to this request to the extent it presumes that Qwest has any legal
right under the Act to impose legacy infrastructure requirements upon competitors. Under the
Act and FCC Rules, Qwest, not Level 3 , is required to provide interconnection at any technically
feasible point. Accordingly, pursuant to Section 251(c)(2)(B), Qwest is obligated to provide
Level 3 with interconnection "at any technically feasible point within its network." Further
Section 51.100 of the FCC's rules require that Qwest allow Level 3 to exchange all traffic over a
single point of interconnection when it has established points of interconnection for the exchange
of telephone exchange service or exchange access traffic.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO.Identify each product or service offered by Level 3 that
generates IP-enabled traffic in Idaho (e.
, "
(3) VoIP Enhanced Local Service
" "
(3)Tone
Business Service
" "
(3)VoIP Toll Free Service
" "
(3)VoIP Inbound Service
" "
(3)Voice
Termination Service
" "
(3) Connect Modem " etc.). For each product or service, provide:
(a)An explanation of how calls are or will be routed from Level 3 to Qwest
including network diagrams and call flow diagrams that illustrate the
product or service;
(b)Documents that describe and illustrate the location of other carriers (e.
CLEC, Wireless, IXC, ILEC), enhanced service providers, information
service providers, ISPs, and cable providers in the call flow, where such
entities are integral to the respective Level 3 product or service; and
(c)The location of the IP or TDM (Time Division Multiplexed/circuit-
switched format) gateways, i., the equipment that performs the protocol
converSIon.
OBJECTION TO DATA REQUEST NO.Level 3 objects to this request on the basis
that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes terms
that are subject to multiple interpretations but are not properly defined or explained. Level 3
further objects to this request on the basis that the information being sought includes extremely
confidential, and highly guarded trade secrets, and is not reasonably calculated to lead to the
discovery of admissible evidence and is not relevant to the subject matter of this action material
to the issues raised in this proceeding, The parties are not similarly situated nor are Level 3' s
relationships with "other carriers (e., CLEC, Wireless, IXC, ILEC), enhanced service
providers, information service providers, ISPs, and cable providers in the call flow, where such
entities are integral to the respective Level 3 product or service and "the location of the IP or
TDM (Time Division Multiplexed/circuit-switched format) gateways, i., the equipment that
performs the protocol conversion relevant to any issues in this arbitration.Qwest has
obligations under state and federal law for the provision of interconnection, collocation and
unbundled network elements to Level 3 that do not apply between Level 3 and other persons.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
Consequently, Level 3'policies and procedure with other persons are not relevant in
considering the reasonableness of Qwest's onerous conditions for interconnection , trunking and
rating of traffic required of Qwest by law.
Additionally, Level3's internal policies, procedures, network configurations, and
relationships with third parties are extremely valuable and highly confidential trade secrets.
Disclosure of these highly proprietary, intellectual business assets would pose significant risk of
loss to Level 3. Level 3' s policies simply can not be disclosed to Level 3 's competitors.
Disclosure of these Level 3 processes and procedures to Qwest would place Level 3 at a distinct
competitive disadvantage when competing with Qwest. It is not the role of Arbitration to expose
such trade secrets or other competitively sensitive information, including information protected
by third party agreements prohibiting such disclosure, that are neither relevant nor necessary to
Commission consideration of the issues in this matter. Accordingly, Level 3 further objects to
this data request to the extent that the information requested is "confidential
" "
highly sensitive
confidential " or constitutes "trade secrets" pursuant to Idaho law. To the extent that any of this
information is relevant to this arbitration and to the extent any of that information that Qwest
requests is proprietary confidential business information, Level 3 will only make such
information available once a Protective Agreement is executed in this docket. Any production
by Level 3 of confidential information or material will be governed by the Protective Agreement
to be executed in this docket.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 10: For each Level 3 product or service identified in the
previous request, identify the total volume of traffic (separately for each direction) exchanged
between Level 3 and Qwest in Idaho. Provide the information on a quarterly basis from January
, 2004 to the present.
OBJECTION TO DATA REQUEST NO. 10:See Level3's Objections to Request No.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 11:Does Level 3 contend that it is not required to pay recurring
or nonrecurring rates set forth in Qwest's access services catalogs on file with the IPUC when
Level 3 delivers interexchange traffic to Qwest for termination? If the answer is yes, please
describe in full the circumstances in which Level 3 contends it is not required to pay the filed
recurring or nonrecurring rates.
OBJECTION TO DATA REQUEST NO. 11:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this request to the extent it calls for a legal conclusion. Subject to and
without waiving these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 12: Assume for purposes of this request that Level 3 has a
single POI for the Boise LATA with Qwest and assume that Level3's proposed contract
language were ordered to be placed in the agreement by the IPUC. Under these assumptions
what compensation, if any, either under the interconnection agreement or Qwest tariff or catalog,
would Qwest receive for the following calls:
(a)
(b)
(c)
(d)
F or a Qwest customer located in Boise who calls a Level 3 customer with
a telephone number whose NP AINXX relates to a wire center within the
same local calling area (LCA) as the calling party (i., the numbers relate
to the same LCA and the physical locations of the customers are within
the same LCA), what compensation would Qwest receive for originating
and transporting the call to Level 3' s POI in Boise?
F or a Qwest customer located in Boise who calls a Level 3 customer
physically located in Idaho Falls with a telephone number whose
NP AINXX relates to a wire center in Idaho Falls (Le., the numbers do not
relate to the same LCA and the physical locations of the customers are not
within the same LCA), what compensation would Qwest receive for
originating and transporting the call to Level3's POI in Boise?
F or a Qwest customer located in Boise who calls a Level 3 customer
physically located in New York City with a telephone number whose
NP AINXX relates to a wire center in New York City (i., the numbers do
not relate to the same LCA and the physical locations of the customers are
not within the same LCA or LATA), what compensation would Qwest
receive for originating and transporting the call to Level3's POI in Boise?
For a Qwest customer located in Boise who receives a call from a Level 3
customer physically located in Boise with a telephone number whose
NP AINXX relates to a wire center in Boise (Le., the numbers relate to the
same LCA and the physical locations of the customers are within the same
LCA), what compensation would Qwest receive for transporting the call
from Level3's POI in Boise and terminating it with Qwest's customer?
(e)F or a Qwest customer located in Boise who receives a call from a Level 3
customer physically located in Idaho Falls with a telephone number whose
NP AINXX relates to a wire center in Idaho Falls (Le., the numbers do not
relate to the same LCA and the physical locations of the customers are not
within the same LCA), what compensation would Qwest receive for
transporting the call from Level 3' s PO I in Boise and terminating it with
Qwest's customer?
(t)For a Qwest customer located in Boise who receives a call from a Level 3
customer physically located in New York City with a telephone number
whose NP AINXX relates to a wire center in New York City (i., the
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
numbers do not relate to the same LCA and the physical locations of the
customers are not within the same LCA or LA T A), what compensation
would Qwest receive for transporting the call from Level3's POI in Boise
and terminating it with Qwest' s customer?
OBJECTION TO DATA REQUEST NO. 12:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 objects to this request to the extent that it requires Level 3 to speculate based on hypotheticals
and also requires Level 3 to make improper assumptions that are not contained in the request.
a result, the request requires Level 3 to conduct a special study. The request is also not
reasonably calculated to lead to the discovery of admissible evidence and is not relevant to the
subject matter of this action. Level 3 further objects to this request on the basis that the
hypotheticals identified in the request lack information required for Level 3 to formulate an
adequate response. Subject to and without waiving these objections, Level 3 will respond to this
request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-I 8
DATA REQUEST NO. 13: Using the same assumptions as the previous request, under
the six scenarios listed therein, what compensation would Level 3 be entitled to receive from
Qwest for transporting, terminating or originating the call? Provide a separate response for each
scenarIo.
OBJECTION TO DATA REQUEST NO. 13:See Level3's Objections to Request No.
12. Subject to and without waiving these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 14:Using the same assumptions as the previous two requests
under the six scenarios listed therein, what compensation would Qwest be entitled to receive
from Level 3 for transporting, terminating or originating the call, if instead of the Qwest
customer being located in Boise, the Qwest customer is located in Twin Falls, Idaho? Provide a
separate response for each scenario.
OBJECTION TO DATA REQUEST NO. 14: See Level3's Objections to Request No.
12. Subject to and without waiving these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 15:Using the same assumptions as the previous three requests
under the six scenarios listed therein, what compensation would Level 3 be entitled to receive
from Qwest for transporting, terminating or originating the call, if instead of the Qwest customer
being located in Boise, the Qwest customer is located in Twin Falls, Idaho? Provide a separate
response for each scenario.
OBJECTION TO DATA REQUEST NO. 15:See Level3's Objections to Request No.
12. Subject to and without waiving these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 16:Using the same assumptions as the previous four requests
under the six scenarios listed therein, what compensation would Qwest be entitled to receive
from Level 3 for transporting, terminating or originating the call, if instead of the Level 3
customer being located within the LCA associated with its assigned NP AINXX, Level 3'
customer was actually physically located in a different LCA than New York City, Boise, Idaho
Falls, or Twin Falls? Provide a separate response for each scenario.
OBJECTION TO DATA REQUEST NO. 16:See Level3's Objections to Request No.
12. Subject to and without waiving these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 17: Assume that a Qwest customer in Idaho Falls frequently
calls an ISP through a local number associated with Idaho Falls, but the ISP's modems (either
owned and operated by the ISP or provided by Level 3) and Level3's POI are both located in
Boise. Assume that the Idaho Falls customer is connected to the ISP for calls that average 1 000
minutes per month.
(a)Under Level 3' s proposed interconnection agreement language, what
amount would Qwest be required to pay Level 3 for terminating those
minutes?
(b)Assuming that Qwest's Idaho Falls customer pays for his or her local
service on a flat rated basis, would Qwest receive any additional revenues
for originating this traffic and delivering it to Level3's POI in Boise?
(c)Under Level 3' s proposed interconnection agreement language, would
Level 3 have any financial responsibility for the transporting of the call
from the end office serving Qwest's Idaho Falls customer to Level3's POI
in Boise?
OBJECTION TO DATA REQUEST NO. 17: Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 objects to this request to the extent that it requires Level 3 to speculate based on hypotheticals
and also requires Level 3 to make improper assumptions that are not contained in the request.
a result, the request requires Level 3 to conduct a special study. The request is also not
reasonably calculated to lead to the discovery of admissible evidence and is not relevant to the
subject matter of this action. Level 3 further objects to this request on the basis that the
hypotheticals identified in the request lack information required for Level 3 to formulate an
adequate response. Subject to and without waiving these objections, Level 3 will respond to this
request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 18:Assume the same scenario as the prior request, except that
instead of the calls going to an ISP in Boise, the calls are routed to a VoIP customer whose VoIP
Provider POP is located in Boise and the VoIP Provider receives service from Level 3, whose
POI is also located in Boise. Assume that the Idaho Falls customer makes 1 000 minutes of calls
directed to the VoIP customer, but that the customer accesses the VoIP provider via a local
number provided to the VoIP customer that has an NP AINXX associated with the Idaho Falls
LCA.
(a)Under Level 3' s proposed interconnection agreement language, what
amount would Qwest be required to pay Level 3 for terminating those
minutes?
(b)Assuming that Qwest's Idaho Falls customer pays for his or her local
service on a flat rated basis, would Qwest receive any additional revenues
for originating this traffic and delivering it to Level3's POI in Boise?
(c)Under Level 3' s proposed interconnection agreement language, would
Level 3 have any financial responsibility for the transporting of the call
from the end office serving Qwest's Idaho Falls customer to Level3's POI
in Boise?
OBJECTION TO DATA REQUEST NO. 18:See Level3's Objections to Request No.
17. Subject to and without waiving these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 19:With regard to the definition of "VoIP" proposed by Level
3 (Issue 16):
(a)Has any state commission adopted that definition or one that is
substantially similar to it (e., one that includes Level 3' s proposed
separate sub-definitions of "ISP-bound VNXX traffic
" "
VoIP VNXX
traffic " and "Circuit Switched VNXX traffic.)? If so, identify the state
commission, the docket number of the case, and the date of the order.
(b)Has any state commission rejected that definition or one that is
substantially similar to it (e., one that includes Level 3' s proposed
separate sub-definitions of "ISP-bound VNXX traffic
" "
VoIP VNXX
traffic " and "Circuit Switched VNXX traffic.)? If so, identify the state
commission, the docket number of the case, and the date of the order.
OBJECTION TO REQUEST NO. 19:Level 3 objects to this request on the basis that it
is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes terms that
are subject to multiple interpretations but are not properly defined or explained. Level 3 further
objects to this data request insofar as it seeks legal conclusions and not facts and is therefore not
reasonably calculated to lead to the discovery of admissible evidence and is not relevant to the
subject matter of this action. Level 3 further objects to this request insofar as it requires Level 3
to conduct a special study, and that the information sought is publicly available information that
may just as readily be compiled by Qwest as by Level 3. Level 3 also objects to this request to
the extent it seeks information that is protected by Level 3' s attorney work product privilege.
Subject to and without waiving these objections, Level 3 will respond to this request by
supplying any relevant, responsive information it maintains in the ordinary course of business
that is responsive to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 20:Does Level 3 agree that in order for a call to qualify as a
VoIP call it must be originated by the calling party in Internet Protocol (IP) using IP-Telephone
handsets, IP adapters, CPE-based IP Telephone (IPT) Management "plug and play" hardware
IPT application management and monitoring hardware or such similar equipment? If not, please
explain what portion of the foregoing Level 3 does not agree is part of an accurate definition of
VoIP or describe other requirements that should be met for a call to qualify as a VoIP call.
OBJECTION TO DATA REQUEST NO. 20:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. For
example, Qwest fails to define the terms "plug and play" and "qualify." Level 3 further objects
to the request in so far as it does not seek facts and instead requests Level 3' s legal opinion, and
is therefore not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Subject to and without waiving these objections
Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 21:IfLevel3's answer to the first sentence in the preceding
request is yes, does Level 3 agree that a VoIP call must be transmitted over a broadband
connection to the VoIP Provider? If not, please describe the types of connections that may exist
between the calling party (i., the VoIP customer) and the VoIP Provider and have the traffic
between them still considered to be VoIP traffic.
OBJECTION TO DATA REQUEST NO. 21:See Level3's Objections to Request No.
20. Subject to and without waiving these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 22:As used by Level 3 in its definition of "VoIP" in this
docket, please state Level 3' s definition of the term "broadband connection.
OBJECTION TO DATA REQUEST NO. 22:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to the request in so far as it does not seek facts and instead requests Level 3'
opinion, and is therefore not reasonably calculated to lead to the discovery of admissible
evidence and is not relevant to the subject matter of this action. Subject to and without waiving
these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 23:Qwest's proposed definition ofVoIP requires that VoIP
traffic must be "transmitted over a broadband connection to the VoIP provider." (Emphasis
added) Level 3' s definition states that VoIP traffic must be "transmitted over a broadband
connection to or from the VoIP provider." (Emphasis added).
(a)Does the addition of the phrase "or from" mean that VoIP traffic must be
transmitted to the VoIP Provider on a broadband connection and that theVoIP provider must also transmit the traffic to the public switched
telephone network (PS TN) on a broadband connection in order for the call
to qualify as VoIP?
(b)If that is not the meaning to be given to the addition of "or from" to the
definition, please explain its meaning and provide an example of traffic
from" the VoIP provider.
OBJECTION TO DATA REQUEST NO. 23:Level 3 objects to this request on the
grounds that calls for a legal conclusion and is therefore not an appropriate subject for discovery.
The request improperly assumes that Qwest is legally entitled to asymmetrical intercarrier
compensation under the FCC's Rules and the Act. Subject to and without waiving these
objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 24:Is it Level3's proposal in this docket that compensation in
the amount of $.0007 per minute of use (MOU) be paid on all VoIP traffic, regardless of where it
originates, where the VoIP Provider POP is physically located, and where the called party is
physically located? If not, please describe and distinguish the VoIP traffic that Level 3 proposes
be subject to $.0007 per MOU and the VoIP traffic that Level 3 proposes (1) should not be
subject to compensation, or (2) should be subject to compensation, but at a different rate than
0007 per MOU.
OBJECTION TO DATA REQUEST NO. 24:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to this request on the
grounds that it calls for a legal conclusion and is therefore not an appropriate subject for
discovery. Level 3 further objects to the request in so far as it does not seek facts and instead
requests Level 3' s opinion, and is therefore not reasonably calculated to lead to the discovery of
admissible evidence and is not relevant to the subject matter of this action. Level 3 further
objects to this request to the extent that it assumes facts and circumstances that have never been
discussed between the Parties. Subject to and without waiving these objections, Level 3 will
respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 25:Does Level 3 agree that, for purposes of determining
whether compensation at the rate of $.0007 per MOU applies to VoIP traffic, the physical
location of the VoIP Provider POP should be one of the two physical locations used to determine
the originating and terminating points of the specific call? If not, please explain why not.
OBJECTION TO DATA REQUEST NO. 25:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this request on the grounds that it calls for a legal conclusion and is therefore
an inappropriate subject for discovery. Level 3 further objects to this data request in so far as the
request lacks certain information required in order for Level 3 to provide an adequate response.
Level 3 further objects to the request in so far as it does not seek facts and instead requests Level
3' s opinion, and is therefore not reasonably calculated to lead to the discovery of admissible
evidence and is not relevant to the subject matter of this action. Subject to and without waiving
these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 26:Assuming hypothetically that the IPUC were to determine
that intercarrier compensation for VoIP traffic will be determined based on the physical
origination point of the call and physical termination point, should the physical location of the
person originating the call or the physical location of the VoIP Provider POP be used as the
originating point of the call? Ifneither, what physical point would Level 3 propose be used by
the IPUC?
OBJECTION TO DATA REQUEST NO. 26:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 objects to this request to the extent that it requires Level 3 to speculate based on hypotheticals
and also requires Level 3 to make improper assumptions that are not contained in the request.
a result, the request requires Level 3 to conduct a special study. The request is also not
reasonably calculated to lead to the discovery of admissible evidence and is not relevant to the
subject matter of this action. Level 3 further objects to this request on the basis that the
hypotheticals identified in the request lack information required for Level 3 to formulate an
adequate response. Level 3 further objects to the request in so far as it does not seek facts and
instead calls for a legal conclusion or Level 3' s opinion, and is therefore not reasonably
calculated to lead to the discovery of admissible evidence and is not relevant to the subject
matter of this action. Subject to and without waiving these objections, Level 3 will respond to
this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 27:If the VoIP Provider POP for a VoIP Provider served by
Level 3 and the called party (assume for purposes of this question that the called party is a Qwest
customer) on a VoIP call are not physically located within the same local calling area (as defined
by the Commission):
(a)
(b)
(c)
(d)
(e)
(t)
Does Level 3' s proposed contract language require Qwest to transport the
call from the Level3/Qwest POI to the end office serving the called party
at no cost to Level 3?
Once the call reaches the end office of the called party, does Level3'
proposed contract language require Qwest to terminate the call in the local
calling area at no cost to Level 3?
Does Level 3' s proposed contract language require Level 3 to pay Qwest
intercarrier compensation of any kind for the call? If so, describe the type
of compensation and how it would be applied.
If the answer to c. is that Level 3 would pay Qwest intercarrier
compensation, does Level 3 propose that Level 3 would pay Qwest for
transporting the call from the POI to the end office serving the called
party? Ifnot, why not?
Does Level 3' s proposed contract language require Qwest to transport the
call from the POI to the end office serving the called party over Local
Interconnection Service ("LIS") trunks? Ifnot, what type of trunks does
Level 3' s language propose be used to transport such a call?
With regard to (e), does Level 3 propose that Level 3 should bear any
financial responsibility for transporting such a VoIP call from the POI to
the end office of the called party? If so, in what manner and at what rates
should Level 3' s financial responsibility be determined?
OBJECTION TO DATA REQUEST NO. 27:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to the request in so far
as it does not seek facts and instead calls for a legal conclusion or Level 3' s opinion, and is
therefore not reasonably calculated to lead to the discovery of admissible evidence and is not
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
relevant to the subject matter of this action. Subject to and without waiving these objections
Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 28:Does Level 3 consider a call that originates in Time
Division Multiplex ("TDM"), is converted into Internet Protocol (IP), and then is terminated in
TDM (commonly referred to as a TDM-IP-TDM call) a VoIP call for purposes of the
interconnection agreement in this case?
OBJECTION TO DATA REQUEST NO. 28:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to the request in so
far as it does not seek facts and instead calls for a legal conclusion or Level 3' s opinion, and is
therefore not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Subject to and without waiving these objections
Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 29:Does Level 3 consider a call that originates in TDM and
terminates with a VoIP called party in Internet Protocol (commonly referred to as a TDM-
call) a VoIP call for purposes of the interconnection agreement in this case?
OBJECTION TO DATA REQUEST NO. 29:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to the request in so
far as it does not seek facts and instead calls for a legal conclusion or Level 3' s opinion, and is
therefore not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Subject to and without waiving these objections
Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 30:Does Level 3 provide "(3) VoIP Enhancedsm Local
Service" or a service similar to it in Idaho?
(a)
(b)
If not, does it plan to do so in the near future?
Does Level 3 provide this service to end user retail customers?
(c)Does Level 3 provide this service on a wholesale basis to VoIP or IP-
enabled service providers?
OBJECTION TO DATA REQUEST NO. 30:Level 3 objects to this request insofar as
it seeks information regarding Level 3' s projections regarding future services, strategies
equipment deployments, or other such future business plans as such requests are trade secrets
and, for purposes of this proceeding, would be highly speculative and irrelevant to the issues to
be decided in this docket. Level 3 further objects to this request on the grounds that it seeks
information that is publicly available and therefore equally accessible by Qwest. Subject to and
without waiving this objection, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 31:Does Level 3 provide any other services with similar
functionalities as "(3) VoIP Enhancedsm Local Service ? If so, identify and describe the
servIces.
OBJECTION TO DATA REQUEST NO. 31:Level 3 objects to this request insofar as
it seeks information regarding Level 3' s projections regarding future services, strategies
equipment deployments, or other such future business plans as such requests are trade secrets
and, for purposes of this proceeding, would be highly speculative and irrelevant to the issues to
be decided in this docket. Level 3 further objects to this request on the grounds that it seeks
information that is publicly available and therefore equally accessible by Qwest. Subject to and
without waiving this objection, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 32:Based on the diagram of "(3) VoIP EnhancedSM Local
Service" (attached hereto as Exhibit A), it appears that this service allows call origination from
analog phones. When a call is initiated using an analog phone per that diagram, does Level 3
consider the call to be a VoIP call?
OBJECTION TO DATA REQUEST NO. 32:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response.Level 3 further objects to the request in so
far as it does not seek facts and instead calls for a legal conclusion or Level 3' s opinion, and is
therefore not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Level 3 further objects to this request to the extent
that the information being sought includes extremely confidential, and highly guarded trade
secrets. In addition, Level 3 objects to this request on the grounds that and further that it is not
reasonably calculated to lead to the discovery of admissible evidence and is not relevant to the
subject matter of this action The parties are not similarly situated nor are Level 3' s product
offerings relevant Qwest's obligations under Section 251(c)(2) of the Act, which are entitled
Additional Obligations of Incumbent Local Exchange Carriers' except to the extent necessary to
show the anti competitive harm rendered by Qwest's self-serving, archaic, and backward
interpretations of federal law.Qwest has obligations under state and federal law for the
provision of interconnection, collocation and unbundled network elements to Level 3 that do not
apply between Level 3 and other persons. Consequently, Level 3's policies, procedures, and call
routing detail are not relevant in considering the reasonableness of Qwest's onerous conditions
for interconnection, trunking and rating of traffic required of Qwest by law.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
Additionally, Level 3'internal policies, procedures, network configurations, and
relationships with third parties are extremely valuable and highly confidential trade secrets.
Disclosure of these highly proprietary, intellectual business assets would pose significant risk of
loss to Level 3. Level 3' s policies simply can not be disclosed to Level 3 's competitors.
Disclosure of these Level 3 processes and procedures to Qwest would place Level 3 at a distinct
competitive disadvantage when competing with Qwest. It is not the role of Arbitration to expose
such trade secrets or other competitively sensitive information, including information protected
by third party agreements prohibiting such disclosure, that are neither relevant nor necessary to
Commission consideration of the issues in this matter. Accordingly, Level 3 further objects to
this data request to the extent that the information requested is "confidential
" "
highly sensitive
confidential " or constitutes "trade secrets" pursuant to Idaho law. To the extent that any of this
information is relevant to this arbitration and to the extent any of that information that Qwest
requests is proprietary confidential business information, Level 3 will only make such
information available once a Protective Agreement is executed in this docket. Any production
by Level 3 of confidential information or material will be governed by the Protective Agreement
to be executed in this docket.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--40
DATA REQUEST NO. 33:On Exhibit A attached hereto, Level 3 states that it is
(c)ommitted to customer enablement, Level 3 will not compete against our (3)VoIP Enhanced
Local customers in the retail market." Does this mean that Level 3 does not provide VoIP
services to retail end user customers? If not, please describe the VoIP services that Level 3
provides to end user retail customers.
OBJECTION TO DATA REQUEST NO. 33:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. For
example, Qwest uses the term "end user retail customer" while the FCC and numerous federal
courts have defined Level 3' s ESP customers as retail customers to which access charges do not
apply. Accordingly, Level 3 objects to Qwest's request to the extent that Qwest posits legal
argument which is apparently required in order to interpret this request as anything other than
self-contradictory and therefore not susceptible of being answered at all. Level 3 further objects
to this data request in so far as the request lacks certain information required in order for Level 3
to provide an adequate response.Level 3 further objects to the request in so far as it does not
seek facts and instead calls for a legal conclusion or Level 3' s opinion, and is therefore not
reasonably calculated to lead to the discovery of admissible evidence and is not relevant to the
subject matter of this action. Subject to and without waiving these objections, Level 3 will
respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--41
DATA REQUEST NO. 34:Does Level 3 provide "(3)VoiceCID Termination" or similar
service in Idaho?
(a)
(b)
If not, does it plan to do so in the near future?
Does Level 3 provide this service to end user retail customers?
(c)Does Level 3 provide this service on a wholesale basis to VoIP or IP-
enabled service providers?
OBJECTION TO DATA REQUEST NO. 34:Level 3 objects to this request on the
basis that it is vague and ambiguous. Level 3 further objects to this data request insofar as the
request lacks certain information required in order for Level 3 to provide an adequate response.
Level 3 further objects to the request on the grounds that it is not reasonably calculated to lead to
the discovery of admissible evidence and is not relevant to the subject matter of this action.
Level 3 also objects to this request to the extent it seeks information regarding Level 3'
projections regarding future services, strategies, equipment deployments, or other such future
business plans as such requests are trade secrets and, for purposes of this proceeding, would be
highly speculative and irrelevant to the issues to be decided in this docket. Level 3 further
objects to this request to the extent that the information being sought includes extremely guarded
trade secrets, is not material to the issues raised in this proceeding. The parties are not similarly
situated nor are Level 3' s product offerings relevant Qwest's obligations under Section 251 (b)
and/or (c) of the Act, which are entitled "Additional Obligations of Incumbent Local Exchange
Carriers' except to the extent necessary to show the anticompetitive harm rendered by Qwest's
self-serving, archaic and backward interpretations of federal law. Qwest has obligations under
state and federal law for the provision of interconnection, collocation and unbundled network
elements to Level 3 that do not apply between Level 3 and other persons. Consequently, Level
3' s product plans, dates of offering service etc. are not relevant in considering the
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--42
reasonableness of Qwest's onerous conditions for interconnection, trunking and rating of traffic
required of Qwest by law.
Additionally, Level 3'internal policies, procedures, network configurations, and
relationships with third parties are extremely valuable and highly confidential trade secrets.
Disclosure of these highly proprietary, intellectual business assets would pose significant risk of
loss to Level 3. Level 3's policies simply can not be disclosed to Level 3'S competitors.
Disclosure of these Level 3 processes and procedures to Qwest would place Level 3 at a distinct
competitive disadvantage when competing with Qwest. It is not the role of Arbitration to expose
such trade secrets or other competitively sensitive information, including information protected
by third party agreements prohibiting such disclosure, that are neither relevant nor necessary to
Commission consideration of the issues in this matter. Accordingly, Level 3 further objects to
this data request to the extent that the information requested is "confidential
" "
highly sensitive
confidential " or constitutes "trade secrets" pursuant to Idaho law. To the extent that any of this
information is relevant to this arbitration and to the extent any of that information that Qwest
requests is proprietary confidential business information, Level 3 will only make such
information available once a Protective Agreement is executed in this docket. Any production
by Level 3 of confidential information or material will be governed by the Protective Agreement
to be executed in this docket.
Lastly Level 3 objects to the extent that this information may by equally available to
Qwest as it is to Level 3.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--43
DATA REQUEST NO. 35:Is Level 3 providing any other VoIP services in Idaho
either in a retail or wholesale capacity? If so, please describe each service, and state as to each
whether it is a service to retail end user customers or to VoIP or IP-enabled service providers.
OBJECTION TO DATA REQUEST NO. 35:See Level3's Objection to Request No.
34. Level 3 further objects to this request on the grounds that it seeks information that is
publicly available and therefore equally accessible by Qwest.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--44
DATA REQUEST NO. 36:Is Level 3 a VoIP provider to end user customers in
Idaho? If not, does Level 3 plan to do so after the interconnection agreement is approved in this
docket?
OBJECTION TO DATA REQUEST NO. 36:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response. For example, Qwest uses the term "end user
customers" while the FCC and numerous federal courts have defined Level 3' s ESP customers
are treated as end user customers. Accordingly, Level 3 objects to Qwest's request to the extent
that Qwest posits legal argumentation which is apparently required in order to interpret this
request as anything other than self-contradictory and therefore not susceptible of being answered
at all. Level 3 further objects to the request in so far as it is not reasonably calculated to lead to
the discovery of admissible evidence and is not relevant to the subject matter of this action.
Level 3 also objects to this request to the extent it seeks information regarding Level 3'
projections regarding future services, strategies, equipment deployments, or other such future
business plans as such requests are trade secrets and, for purposes of this proceeding, would be
highly speculative and irrelevant to the issues to be decided in this docket. Subject to and
without waiving these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--45
DATA REQUEST NO. 37:Does Level 3 consider itself to be an enhanced service
provider (ESP) in connection with the provision of VoIP services? If so, please explain the basis
for its conclusion that it is an ESP.
OBJECTION TO DATA REQUEST NO. 37:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to the request on the
grounds that it calls for a legal conclusion, not facts and is therefore not reasonably calculated to
lead to the discovery of admissible evidence and is not relevant to the subject matter of this
action. Subject to and without waiving these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--46
DATA REQUEST NO. 38:Does Level 3 consider third party wholesale customers that
provide VoIP services that are enabled by Level 3 services such as "(3) V oIP EnhancedSM
Local Service" or similar services to be ESPs?
OBJECTION TO DATA REQUEST NO. 38:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to the request on the
grounds that it calls for a legal conclusion and therefore is not reasonably calculated to lead to
the discovery of admissible evidence and is not relevant to the subject matter of this action.
Subject to and without waiving these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--47
DATA REQUEST NO. 39:Does Level 3 require carriers or businesses purchasing its
(3) V oIP Local Inbound Service" or similar services to physically locate their equipment in the
same local calling area in which Level 3 provides telephone numbers to them for such service?
If so, provide documents relating to such requirements.
OBJECTION TO DATA REQUEST NO. 39:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response.Level 3 further objects to the request insofar
as it is not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Level 3 further objects to this request on the basis
that the information being sought includes extremely confidential, and highly guarded trade
secrets, and is not reasonably calculated to lead to the discovery of admissible evidence and is
not relevant to the subject matter of this action material to the issues raised in this proceeding,
The parties are not similarly situated nor are Level 3' s relationships with "other carriers (e.
CLEC, Wireless, IXC, ILEC), enhanced service providers, information service providers, ISPs
and cable providers in the call flow, where such entities are integral to the respective Level 3
product or service and "the location of the IP or TDM (Time Division Multiplexed/circuit-
switched format) gateways, Le., the equipment that performs the protocol conversion" relevant to
any issues in this arbitration. Qwest has obligations under state and federal law for the provision
of interconnection, collocation and unbundled network elements to Level 3 that do not apply
between Level 3 and other persons. Consequently, Level 3's policies and procedure with other
persons are not relevant in considering the reasonableness of Qwest's onerous conditions for
interconnection, trunking and rating of traffic required of Qwest by law.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--48
Additionally, Level 3'internal policies, procedures, network configurations, and
relationships with third parties are extremely valuable and highly confidential trade secrets.
Disclosure of these highly proprietary, intellectual business assets would pose significant risk of
loss to Level 3. Level 3's policies simply can not be disclosed to Level 3's competitors.
Disclosure of these Level 3 processes and procedures to Qwest would place Level 3 at a distinct
competitive disadvantage when competing with Qwest. It is not the role of Arbitration to expose
such trade secrets or other competitively sensitive information, including information protected
by third party agreements prohibiting such disclosure, that are neither relevant nor necessary to
Commission consideration of the issues in this matter. Accordingly, Level 3 further objects to
this data request to the extent that the information requested is "confidential
" "
highly sensitive
confidential " or constitutes "trade secrets" pursuant to Idaho law. To the extent that any of this
information is relevant to this arbitration and to the extent any of that information that Qwest
requests is proprietary confidential business information, Level 3 will only make such
information available once a Protective Agreement is executed in this docket. Any production
by Level 3 of confidential information or material will be governed by the Protective Agreement
to be executed in this docket.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--49
DATA REQUEST NO. 40:With regard to the definition of"VNXX traffic" proposed
by Level 3 (Issue 3B):
(a)Has any state commission adopted that definition or one that is
substantially similar to it (e., one that includes Level 3' s proposed
separate sub-definitions of "ISP-bound VNXX traffic
" "
VoIP VNXX
traffic " and "Circuit Switched VNXX traffic.)? If so, identify the state
commission, the docket number of the case, and the date of the order.
(b)Has any state commission rejected that definition or one that is
substantially similar to it (e., one that includes Level 3' s proposed
separate sub-definitions of "ISP-bound VNXX traffic
" "
VoIP VNXX
traffic " and "Circuit Switched VNXX traffic.)? If so, identify the state
commission, the docket number of the case, and the date of the order.
OBJECTION TO DATA REQUEST NO. 40:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request insofar as it seeks legal conclusions and not facts and is
therefore not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Level 3 further objects to this request insofar as it
requires Level 3 to conduct a special study, and that the information sought is publicly available
information that may as readily be compiled by Qwest as by Level 3. Level 3 also objects to this
request to the extent it seeks information that is protected by Level 3' s attorney work product
privilege. Subject to and without waiving these objections, Level 3 will respond to this request
by supplying any relevant, responsive information it maintains in the ordinary course of business
that is responsive to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 41:On a monthly basis for all types of traffic for the past two
years, what percent of traffic from Qwest customers in Idaho that is delivered to Level 3 has
been ISP-bound traffic?
OBJECTION TO DATA REQUEST NO. 41:Level 3 objects to this request to the
extent it requires Level 3 to conduct a special study. Level 3 further objects to this request on the
basis that it is vague and ambiguous. Level 3 further objects to this data request in so far as the
request lacks certain information required in order for Level 3 to provide an adequate response.
Level 3 further objects to the request insofar as it is not reasonably calculated to lead to the
discovery of admissible evidence and is not relevant to the subject matter of this action. Level 3
also objects to this request to the extent it seeks information regarding Level3's projections
regarding future services, strategies, equipment deployments, or other such future business plans
as such requests are trade secrets and, for purposes of this proceeding, would be highly
speculative and irrelevant to the issues to be decided in this docket. Subject to and without
waiving these objections, Level 3 will respond to this request by supplying any relevant
responsive information it maintains in the ordinary course of business that is responsive to this
request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 42:Taking all telecommunications traffic (as defined in the
FCC's reciprocal compensation rules) exchanged between Qwest and Level 3 in Idaho for the
past two years:
(a)What percentage of that telecommunications traffic has been delivered by
Qwest to Level 3?
(b)What percentage of that telecommunications traffic has been delivered by
Level 3 to Qwest?
OBJECTION TO DATA REQUEST NO. 42:Level 3 objects to this request to the
extent it requires Level 3 to conduct a special study. Level 3 further objects to this request on the
basis that it is vague and ambiguous. Level 3 further objects to this data request insofar as the
request lacks certain information required in order for Level 3 to provide an adequate response.
Level 3 further objects to the request insofar as it is not reasonably calculated to lead to the
discovery of admissible evidence and is not relevant to the subject matter of this action. Level 3
also objects to this request to the extent it seeks information regarding Level 3' s projections
regarding future services, strategies, equipment deployments, or other such future business plans
as such requests are trade secrets and, for purposes of this proceeding, would be highly
speculative and irrelevant to the issues to be decided in this docket. Subject to and without
waiving these objections, Level 3 will respond to this request by supplying any relevant
responsive information it maintains in the ordinary course of business that is responsive to this
request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 43:As a CLEC in Idaho, does Level 3 provide local exchange
service to end user retail customers? If so, what percent of total minutes exchanged by Qwest
and Level 3 in Idaho in the past two years is represented by minutes originating from retail end
user customers served by Level 3?
OBJECTION TO DATA REQUEST NO. 43:Level 3 objects to this request to the
extent it requires Level 3 to conduct a special study. Level 3 further objects to this request on the
basis that it is vague and ambiguous. Level 3 further objects to this data request insofar as the
request lacks certain information required in order for Level 3 to provide an adequate response.
Level 3 further objects to the request insofar as it is not reasonably calculated to lead to the
discovery of admissible evidence and is not relevant to the subject matter of this action. Level 3
also objects to this request to the extent it seeks information regarding Level 3' s projections
regarding future services, strategies, equipment deployments, or other such future business plans
as such requests are trade secrets and, for purposes of this proceeding, would be highly
speculative and irrelevant to the issues to be decided in this docket. Subject to and without
waiving these objections, Level 3 will respond to this request by supplying any relevant
responsive information it maintains in the ordinary course of business that is responsive to this
request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 44:In Idaho, does Level 3 obtain local telephone numbers from
NANPA (North American Numbering Plan Administrator) for the use by Level3's ISP
customers so that customers of that ISP may call a local number in order to obtain access to the
ISP, even though that ISP has no physical facilities located in the local calling area (as defined
by the Commission) associated with such telephone numbers?
OBJECTION TO DATA REQUEST NO. 44:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request insofar as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to the request insofar
as it is not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Subject to and without waiving these objections
Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 45:In Idaho identify each LATA and local calling areas for
which Level 3 has obtained telephone numbers from NANP
OBJECTION TO DATA REQUEST NO. 45:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request insofar as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to the request insofar
as it is not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Level 3 further objects to this data request to the
extent that the information requested is "confidential
" "
highly sensitive confidential " or
constitutes "trade secrets" pursuant to Idaho law. To the extent that Qwest requests proprietary
confidential business information, Level 3 will only make such information available once a
Protective Agreement is executed in this docket. Any production by Level 3 of confidential
information or material will be governed by the Protective Agreement to be executed in this
docket.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 46 For each of the local calling areas identified in the response
to the prior question provide:
(a)the NP A NXXs that Level 3 has obtained (including pooled or ported
numbers);
(b)
(c)
the number of Level 3 subscribers that Level 3 provides with local service;
the number of Level 3 subscribers that are ISPs;
(d)
(e)
the number of Level 3 subscribers that are not ISPs; and
the description of any Level 3 subscribers that are not included in sub-
questions c and d.
OBJECTION TO DATA REQUEST NO. 46:See Level3's Objection to Request No.
45.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 47:Provide the industry standard or any other documentation
reference that Level 3 relies upon for the proposition that Qwest has an obligation to always
populate the Originating Line Information parameter.
OBJECTION TO DATA REQUEST NO. 47:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to this request insofar
as it requests information that is not in the possession, custody, or control of Level 3. Level 3
further objects to this request to the extent the request seeks information in the public domain
that is just as easily available to Qwest as it is to Level 3. Subject to and without waiving these
objections, Level 3 will respond to this request by supplying any relevant, responsive
information it maintains in the ordinary course of business that is responsive to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 48:Provide the industry known definition for "Originating Line
Indicator" and provide a description of the difference between "Originating Line Indicator " and
the "Originating Line Information" (as defined in the SS7 Protocol).
OBJECTION TO DATA REQUEST NO. 48:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to this request insofar
as it requests information that is not in the possession, custody, or control of Level 3. Level 3
further objects to this request to the extent the request seeks information in the public domain
that is just as easily available to Qwest as it is to Level 3. Subject to and without waiving these
objections, Level 3 will respond to this request by supplying any relevant, responsive
information it maintains in the ordinary course of business that is responsive to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 49:Provide the industry known definition for "Other Company
Number" and provide a description of the difference between "Other Company Number" and the
Operating Company Number" (as defined in the LERG).
OBJECTION TO DATA REQUEST NO. 49:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to this request insofar
as it requests information that is not in the possession, custody, or control of Level 3. Level 3
further objects to this request to the extent the request seeks information in the public domain
that is just as easily available to Qwest as it is to Level 3. Subject to and without waiving these
objections, Level 3 will respond to this request by supplying . any relevant, responsive
information it maintains in the ordinary course of business that is responsive to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 50:Provide the industry standard, or any other documentation
reference that Level 3 relies upon, that requires Qwest or any other company to always provide
either the "Other Company Number" or the "Operating Company Number" for purposes of:
intercarrier compensation of local traffic; or(a)
(b)intercarrier compensation of non-local traffic.
OBJECTION TO DATA REQUEST NO. 50:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to this request insofar
as it requests information that is not in the possession, custody, or control of Level 3. Level 3
further objects to this request to the extent the request seeks information in the public domain
that is just as easily available to Qwest as it is to Level 3. Subject to and without waiving these
objections, Level 3 will respond to this request by supplying any relevant, responsive
information it maintains in the ordinary course of business that is responsive to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--60
DATA REQUEST NO. 51:Is Level3's network switching/routing infrastructure
capable of accurately and reliably populating the Charge Number SS7 parameter for local traffic
routing to Qwest?
OBJECTION TO DATA REQUEST 51:Level 3 objects to this request on the basis
that it is vague, ambiguous, overly broad, unduly burdensome and imprecise, and utilizes terms
that are subject to multiple interpretations but are not properly defined or explained. Level 3
further objects to this data request insofar as the request lacks certain information required in
order for Level 3 to provide an adequate response.Level 3 further objects to the request insofar
as it is not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Level 3 further objects to this data request to the
extent that the information requested is "confidential
" "
highly sensitive confidential " or
constitutes "trade secrets" pursuant to Idaho law. To the extent that Qwest requests proprietary
confidential business information, Level 3 will only make such information available once a
Protective Agreement is executed in this docket. Any production by Level 3 of confidential
information or material will be governed by the Protective Agreement to be executed in this
docket.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--61
DATA REQUEST NO. 52:Is Level3's network switching/routing infrastructure
capable of accurately and reliably populating the Charge Number SS7 parameter for non-local
traffic routing to Qwest?
OBJECTION TO DATA REQUEST NO. 52:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request insofar as the request lacks certain information required in
order for Level 3 to provide an adequate response.Level 3 further objects to the request insofar
as it is not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Level 3 further objects to this request on the basis
that the information being sought includes extremely confidential, and highly guarded trade
secrets, and is not reasonably calculated to lead to the discovery of admissible evidence and is
not relevant to the subject matter of this action material to the issues raised in this proceeding,
The parties are not similarly situated nor are Level 3' s relationships with "other carriers (e.
CLEC, Wireless, IXC, ILEC), enhanced service providers, information service providers, ISPs
and cable providers in the call flow, where such entities are integral to the respective Level 3
product or service and "the location of the IP or TDM (Time Division Multiplexedlcircuit-
switched format) gateways, i., the equipment that performs the protocol conversion" relevant to
any issues in this arbitration. Qwest has obligations under state and federal law for the provision
of interconnection, collocation and unbundled network elements to Level 3 that do not apply
between Level 3 and other persons. Consequently, Level 3's policies and procedure with other
persons are not relevant in considering the reasonableness of Qwest's onerous conditions for
interconnection, trunking and rating of traffic required of Qwest by law.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--62
Additionally, Level 3'internal policies, procedures, network configurations, and
relationships with third parties are extremely valuable and highly confidential trade secrets.
Disclosure of these highly proprietary, intellectual business assets would pose significant risk of
loss to Level 3. Level 3' s policies simply can not be disclosed to Level 3 's competitors.
Disclosure of these Level 3 processes and procedures to Qwest would place Level 3 at a distinct
competitive disadvantage when competing with Qwest. It is not the role of Arbitration to expose
such trade secrets or other competitively sensitive information, including information protected
by third party agreements prohibiting such disclosure, that are neither relevant nor necessary to
Commission consideration of the issues in this matter. Accordingly, Level 3 further objects to
this data request to the extent that the information requested is "confidential
" "
highly sensitive
confidential " or constitutes "trade secrets" pursuant to Idaho law. To the extent that any of this
information is relevant to this arbitration and to the extent any of that information that Qwest
requests is proprietary confidential business information, Level 3 will only make such
information available once a Protective Agreement is executed in this docket. Any production
by Level 3 of confidential information or material will be governed by the Protective Agreement
to be executed in this docket.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--63
DATA REQUEST NO. 53:Is Level 3' s network switching/routing infrastructure
capable of accurately and reliably populating the Calling Party Number SS7 parameter for local
traffic routing to Qwest?
OBJECTION TO DATA REQUEST NO. 53:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request insofar as the request lacks certain information required in
order for Level 3 to provide an adequate response.Level 3 further objects to the request insofar
as it is not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Level 3 further objects to this request on the basis
that the information being sought includes extremely confidential, and highly guarded trade
secrets, and is not reasonably calculated to lead to the discovery of admissible evidence and is
not relevant to the subject matter of this action material to the issues raised in this proceeding,
The parties are not similarly situated nor are Level 3' s relationships with "other carriers (e.
CLEC, Wireless, IXC, ILEC), enhanced service providers, information service providers, ISPs
and cable providers in the call flow, where such entities are integral to the respective Level 3
product or service and "the location of the IP or TDM (Time Division Multiplexedlcircuit-
switched format) gateways, i., the equipment that performs the protocol conversion" relevant to
any issues in this arbitration. Qwest has obligations under state and federal law for the provision
of interconnection, collocation and unbundled network elements to Level 3 that do not apply
between Level 3 and other persons. Consequently, Level 3' s policies and procedure with other
persons are not relevant in considering the reasonableness of Qwest's onerous conditions for
interconnection, trunking and rating of traffic required of Qwest by law.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--64
Additionally, Level 3'internal policies, procedures, network configurations, and
relationships with third parties are extremely valuable and highly confidential trade secrets.
Disclosure of these highly proprietary, intellectual business assets would pose significant risk of
loss to Level 3. Level 3's policies simply can not be disclosed to Level 3's competitors.
Disclosure of these Level 3 processes and procedures to Qwest would place Level 3 at a distinct
competitive disadvantage when competing with Qwest. It is not the role of Arbitration to expose
such trade secrets or other competitively sensitive information, including information protected
by third party agreements prohibiting such disclosure, that are neither relevant nor necessary to
Commission consideration of the issues in this matter. Accordingly, Level 3 further objects to
this data request to the extent that the information requested is "confidential
" "
highly sensitive
confidential " or constitutes "trade secrets" pursuant to Idaho law. To the extent that any of this
information is relevant to this arbitration and to the extent any of that information that Qwest
requests is proprietary confidential business information, Level 3 will only make such
information available once a Protective Agreement is executed in this docket. Any production
by Level 3 of confidential information or material will be governed by the Protective Agreement
to be executed in this docket.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--65
DATA REQUEST NO. 54:Is Level3's network switching/routing infrastructure
capable of accurately and reliably populating the Calling Party Number SS7 parameter for non-
local traffic routing to Qwest?
OBJECTION TO REQUEST NO. 54:Level 3 objects to this request on the basis that it
is vague, ambiguous, overly broad, and imprecise, and utilizes terms that are subject to multiple
interpretations but are not properly defined or explained. Level 3 further objects to this data
request insofar as the request lacks certain information required in order for Level 3 to provide
an adequate response.Level 3 further objects to the request insofar as it is not reasonably
calculated to lead to the discovery of admissible evidence and is not relevant to the subject
matter of this action. Level 3 further objects to this request on the basis that the information
being sought includes extremely confidential, and highly guarded trade secrets, and is not
reasonably calculated to lead to the discovery of admissible evidence and is not relevant to the
subject matter of this action material to the issues raised in this proceeding, The parties are not
similarly situated nor are Level 3' s relationships with "other carriers (e., CLEC, Wireless, IXC
ILEC), enhanced service providers, information service providers, ISPs, and cable providers in
the call flow, where such entities are integral to the respective Level 3 product or service and
the location of the IP or TDM (Time Division Multiplexed/circuit-switched format) gateways
Le., the equipment that performs the protocol conversion" relevant to any issues in this
arbitration.Qwest has obligations under state and federal law for the provision of
interconnection, collocation and unbundled network elements to Level 3 that do not apply
between Level 3 and other persons. Consequently, Level 3's policies and procedure with other
persons are not relevant in considering the reasonableness of Qwest's onerous conditions for
interconnection, trunking and rating of traffic required of Qwest by law.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--66
Additionally, Level 3'internal policies, procedures, network configurations, and
relationships with third parties are extremely valuable and highly confidential trade secrets.
Disclosure of these highly proprietary, intellectual business assets would pose significant risk of
loss to Level 3. Level 3's policies simply can not be disclosed to Level 3's competitors.
Disclosure of these Level 3 processes and procedures to Qwest would place Level 3 at a distinct
competitive disadvantage when competing with Qwest. It is not the role of Arbitration to expose
such trade secrets or other competitively sensitive information, including information protected
by third party agreements prohibiting such disclosure, that are neither relevant nor necessary to
Commission consideration of the issues in this matter. Accordingly, Level 3 further objects to
this data request to the extent that the information requested is "confidential
" "
highly sensitive
confidential " or constitutes "trade secrets" pursuant to Idaho law. To the extent that any of this
information is relevant to this arbitration and to the extent any of that information that Qwest
requests is proprietary confidential business information, Level 3 will only make such
information available once a Protective Agreement is executed in this docket. Any production
by Level 3 of confidential information or material will be governed by the Protective Agreement
to be executed in this docket.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--67
DATA REQUEST NO. 55:Produce all industry standards and vendor documentation
that defines the "Call Record Information" signaling parameter.
OBJECTION TO DATA REQUEST NO. 55:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, and imprecise, and utilizes terms that are subject
to multiple interpretations but are not properly defined or explained. Level 3 objects to the data
request in that it seeks to obtain "all industry standards and vendor documentation" to the extent
that such request is overly broad and unduly burdensome. Level 3 also objects to this request
insofar as it requires Level 3 to compile a list and/or undertake a special study to acquire such
information. Level 3 further objects to this request insofar as it requests information that is not
in the possession, custody, or control of Level 3. Level 3 further objects to this request to the
extent the request seeks information in the public domain that is just as easily available to Qwest
as it is to Level 3. Subject to and without waiving these objections, Level 3 will respond to this
request by supplying any relevant, responsive information it maintains in the ordinary course of
business that is responsive to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--68
DATA REQUEST NO. 55:Exhibit B is a page from Level3's web site related to a
service entitled "(3 )Connect(8) Modem" service. It states that "Level 3 takes care of setting up a
local Internet dial-up network, securing local numbers, deploying modems, and staffing a round-
the-clock operations center to manage the network and hardware so you can do what you do best
- service your end user customers." Please respond to the following questions with regard to
that service (or with regard to other services of Level 3 whereby Level 3 obtains local numbers
for ISPs and provides the functionalities of modems and routers for the ISP):
(a)
(b)
(c)
(d)
(e)
Does Level 3 provide "(3 )Connect(8) Modem" service to ISP customers that
provide dial-up service in Idaho?
Does Level 3 maintain "modems to collect traffic" or "managed routers
that are physically located in any local calling areas in Idaho? If so, please
identify the local calling areas in Idaho in which Level 3 maintains such
modems to collect traffic" or "managed routers.
When Level 3 serves an ISP through Level3's "(3)Connect(8) Modem
service or similar service, what equipment is the ISP required to maintain
to communicate with Level 3?
Describe how the customer validation process is conducted to determine if
the calling party is a valid customer of the ISP served by Level3? What
specific equipment must the ISP have in order to conduct the validation
process?
Assume hypothetically that a Qwest customer is also a dial-up customer of
an ISP served by Level 3 through Level3's "(3)Connect(8) Modem" service
or similar service.
(1)When that customer dials the local number provided by Level 3 to
access the ISP, where is the call answered? (For example, is it
answered by the modems provided by Level 3 for the ISP or by
some other piece of equipment provided by Level 3?)
(2)Are there any circumstances in which the call is answered by the
ISP's equipment? If so, describe the circumstances under which
the ISP answers the call and the type of equipment used to do so.
(t)Whether the equipment is provided by Level 3 for its ISP customers or by
the ISP on its own behalf for a dial-up Internet session, please describe:
(1)the specific piece or pieces of equipment that retains the ongoing
connection to the end user during the course of the call; and
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--69
(g)
(h)
the specific piece or pieces of equipment that directs the call to
websites selected by the end user during the course of the call.
Would it be fair to characterize Level 3' s "(3 )Connect(8) Modem" service
as a service by which Level 3 provides ISPs with basic functionalities
related to access to the Internet (e., modems and routers) on a wholesale
basis so that the ISP need not perform those functions on its own behalf?
If not, please accurately describe Level 3' s characterization of its
relationship with its ISP customers to whom it provides "(3 )Connect(8)
Modem" service.
(2)
Before reaching the modems and routers provided by Level 3 as part of its
(3)Connect(8) Modem" service or similar service, does the traffic go
through a switch owned or operated by Level 3? If so, provide the
addresses of any such switches in Idaho.
(i)Does Level 3 require an ISP purchasing Level3's "(3) Connect Modem
service or any other similar dial-up ISP product to physically locate its
equipment in the same local calling area in which Level 3 assigns dial-up
telephone numbers for the ISP's customers to call? If so, provide
documents relating to such requirements.
Does Level 3 require an ISP purchasing Level3's "(3) Connect Modem
service or any other similar dial-up ISP product to physically locate its
equipment in the same state in which Level 3 assigns dial-up telephone
numbers for the ISP's customers to call? If so, provide documents relating
to such requirements.
OBJECTION TO DATA REQUEST NO. 56:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this request insofar as the request lacks certain information required in order
for Level 3 to provide an adequate response.Level 3 further objects to the request insofar as it
is not reasonably calculated to lead to the discovery of admissible evidence and is not relevant to
the subject matter of this action. Level 3 objects to this request to the extent that it requires
Level 3 to speculate based on hypotheticals and also requires Level 3 to make improper
assumptions that are not contained in the request. Level 3 further objects to this request on the
basis that the information being sought includes extremely confidential, and highly guarded trade
secrets, and is not reasonably calculated to lead to the discovery of admissible evidence and is
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
not relevant to the subject matter of this action material to the issues raised in this proceeding,
The parties are not similarly situated nor are Level 3' s relationships with "other carriers (e.
CLEC, Wireless, IXC, ILEC), enhanced service providers, information service providers, ISPs
and cable providers in the call flow, where such entities are integral to the respective Level 3
product or service and "the location of the IP or TDM (Time Division Multiplexedlcircuit-
switched format) gateways, i., the equipment that performs the protocol conversion" relevant to
any issues in this arbitration. Qwest has obligations under state and federal law for the provision
of interconnection, collocation and unbundled network elements to Level 3 that do not apply
between Level 3 and other persons. Consequently, Level 3's policies and procedure with other
persons are not relevant in considering the reasonableness of Qwest's onerous conditions for
interconnection, trunking and rating of traffic required of Qwest by law.
Additionally, Level 3'internal policies, procedures, network configurations, and
relationships with third parties are extremely valuable and highly confidential trade secrets.
Disclosure of these highly proprietary, intellectual business assets would pose significant risk of
loss to Level 3. Level 3's policies simply can not be disclosed to Level 3's competitors.
Disclosure of these Level 3 processes and procedures to Qwest would place Level 3 at a distinct
competitive disadvantage when competing with Qwest. It is not the role of Arbitration to expose
such trade secrets or other competitively sensitive information, including information protected
by third party agreements prohibiting such disclosure, that are neither relevant nor necessary to
Commission consideration of the issues in this matter. Accordingly, Level 3 further objects to
this data request to the extent that the information requested is "confidential
" "
highly sensitive
confidential " or constitutes "trade secrets" pursuant to Idaho law. To the extent that any of this
information is relevant to this arbitration and to the extent any of that information that Qwest
requests is proprietary confidential business information, Level 3 will only make such
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
information available once a Protective Agreement is executed in this docket. Any production
by Level 3 of confidential information or material will be governed by the Protective Agreement
to be executed in this docket.
Subject to and without waiving these objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 57:The following set of questions relate to situations where
instead of Level 3 providing modems and routers for its ISP customers, the ISPs obtain local
telephone numbers through Level 3 and traffic is gathered from Qwest by Level 3 on behalf of
such ISPs, but the ISPs provide their own modems and routers for themselves.
(a)
(b)
(c)
(d)
Does Level 3 provide service as described above to any ISP that provides
service to customers in Idaho? If so, how many ISPs that provide service
to customers on that basis provide service to customers in Idaho?
How many ISP customers identified in the previous subpart, physically
locate their modems and routers in Idaho and how many physically locate
their modems and routers in other states?
When Level 3 provides service to ISP customers as described in this
question, does the traffic go through a Level 3 switch before being
delivered to the ISP's modems and routers? Ifnot, does the traffic go
through any Level 3 equipment between its POI and the modems and
routers of the ISP? If so, describe all such equipment.
When Level 3 provides service to ISP customers as described in this
question, how does Level 3 connect its equipment to the routers and
modems of the ISP (e., high-capacity circuit, over the Internet)?
OBJECTION TO DATA REQUEST NO. 57:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 objects to this request to the extent that it requires Level 3 to speculate based on hypotheticals
and also requires Level 3 to make improper assumptions and which lack information required for
Level 3 to formulate an adequate response. Such hypotheticals are not reasonably calculated to
lead to the discovery of admissible evidence and is not relevant to the subject matter of this
action. Level 3 further objects to this data request to the extent that the information requested is
confidential
" "
highly sensitive confidential " or constitutes "trade secrets" pursuant to Idaho
law. To the extent that Qwest requests proprietary confidential business information, Level 3
will only make such information available once a Protective Agreement is executed in this
docket. Any production by Level 3 of confidential information or material will be governed by
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
the Protective Agreement to be executed in this docket. Subject to and without waiving these
objections, Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 58:Based on Qwest's reading ofLevel3's proposed definition
ofVNXX Traffic (Issue 3B), Level3's proposed language for section 7.3.4.1 (Issue 4), and
Level3's proposed language for section 7.6.1 (Issue 3C), there appears to be an inconsistency
in the application of intercarrier compensation for different types of traffic. For example, Level
s proposed 7.3.1 and the definition ofVNXX traffic suggest that all ISP-bound traffic and
VoIP traffic will be subject to reciprocal compensation without limitation, while section 7.3.4.
states that "intercarrier compensation" for all "section 251 (b )( 5) traffic" will be based on
whether the "originating and terminating NP A-NXX codes correspond to rate centers located
within defined local calling areas (including ISP-bound and VoIP Traffic)." In light of the
foregoing, please respond to the following:
(a)
(b)
(c)
Describe all specific types of traffic Level 3 includes in its definition of
section 251 (b)( 5) traffic.
What is Level 3' s definition of the term "intercarrier compensation" as
used in its proposed language for section 7.3.4.1? Is that the same
definition used whenever that term is used in other places in Level 3'
proposed language? If not, identify the sections in which the term has a
different meaning and state the definition as used in those sections.
Is it Level3's position that compensation at $.0007 per minute for all
traffic destined for the Internet should be required in the interconnection
agreement? If so, what is the purpose for the language of section 7.3.4.
that suggests that compensation will paid only when the NP AlNXXs of
the called and calling parties correspond to rate centers located within
defined Qwest local calling areas?
(d)Is it Level3's position that compensation at $.0007 per minute for all
VoIP traffic should be required in the interconnection agreement? If so
what is the purpose for the language of section 7.3 .4.1 that suggests that
compensation will paid only when the NP AlNXXs of the called and
calling parties correspond to rate centers located within defined Qwest
local calling areas?
(e)Level 3' s language for section 7.3.4.1 omits any mention of "EAS/Local"
traffic. How does Level 3 propose to treat that category of traffic for
intercarrier compensation purposes?
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
OBJECTION TO DATA REQUEST NO. 58:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request insofar as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to this request to the
extent it calls for a legal conclusion. Level 3 further objects to the request insofar as it is not
reasonably calculated to lead to the discovery of admissible evidence and is not relevant to the
subject matter of this action. Level 3 objects to this discovery request to the extent that it
requires Level 3 to speculate and also requires Level 3 to make assumptions that are not
contained in the request. Subject to and without waiving these objections, Level 3 will respond
to this request by supplying any relevant, responsive information it maintains in the ordinary
course of business that is responsive to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. : With regard to section 252 arbitration proceedings in which
Level 3 has been a party, identify each state commission (by case name, docket number, and date
of order) that has adopted or agreed with Level3's contention that "federal ISP-bound traffic
compensation regime applies to all ISP-bound traffic.
OBJECTION TO DATA REQUEST NO. 59:See Level3's Objection to Request No.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 60:With regard to section 252 arbitration proceedings in which
Level 3 has been a party, identify each state commission (by case name, docket number, and date
of order) that has rejected or disagreed with Level3's contention that "federal ISP-bound traffic
compensation regime applies to all ISP-bound traffic.
OBJECTION TO DATA REQUEST NO. 60:See Level3's Objection to Request No.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 61:Does Level 3 consider VoIP traffic to be "ISP-bound
traffic
OBJECTION TO DATA REQUEST NO. 61:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request in so far as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to this request to the
extent it calls for a legal conclusion. Level 3 further objects to the request in so far as it is not
reasonably calculated to lead to the discovery of admissible evidence and is not relevant to the
subject matter of this action. Level 3 objects to this discovery request to the extent that it
requires Level 3 to speculate and also requires Level 3 to make assumptions that are not
contained in the request. Subject to and without waiving these objections, Level 3 will respond
to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 62:Does Level 3 collect and remit state universal fund
surcharges to the Idaho Universal Service Fund (USF) for any services that Level 3 provides to
its customers in Idaho? If so, for what services?
OBJECTION TO DATA REQUEST NO. 62:Level 3 objects to this request on the
grounds it is not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Subject to and without waiving these objections
Level 3 will respond to this request.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. : that Level 3 provides to its customers? To the extent VoIP
services are provided by third party provider customers of Level 3, state whether Level 3 is
aware whether those third party providers collect and remit universal fund surcharges to the
Idaho USF.
OBJECTION TO DATA REQUEST NO. 63:Level 3 objects to this request because it
contains an incomplete sentence making it impossible for Level 3 to understand what is
requested. The request is also not reasonably calculated to lead to the discovery of admissible
evidence and is not relevant to the subject matter of this action.
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 64:Under Level3's proposal, how would a terminating carrier
other than Qwest be provided with call records or otherwise compensated for traffic that Level 3
routes through a portion of Qwest's network for termination with that terminating carrier?
OBJECTION TO DATA REQUEST NO. 64:Level 3 objects to this request on the
basis that it is vague, ambiguous, overly broad, unduly burdensome, and imprecise, and utilizes
terms that are subject to multiple interpretations but are not properly defined or explained. Level
3 further objects to this data request insofar as the request lacks certain information required in
order for Level 3 to provide an adequate response. Level 3 further objects to the request insofar
as it is not reasonably calculated to lead to the discovery of admissible evidence and is not
relevant to the subject matter of this action. Subject to and without waiving these objections
Level 3 will respond to this request.
DATED this day of July, 2005.
Respectfully submitted
McDEVITT & MILLER LLP
Dea ~. Miller
McDevitt & Miller LLP
420 W. Bannock
Boise, ID 83702
Phone: [phone]Fax: [phone]
Counsel for Level 3 Communications, LLC
OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
CERTIFICATE OF SERVICE
I hereby certify that on the day of July, 2005 , I caused to be served, via the methodes)
indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
i iewell~puc.state.id. us
Mary S. Hobson
STOEL RIVES LLP
101 S Capitol Boulevard - Suite 1900
Boise, ID 83702-5958
Telephone: [phone]
Facsimile: [phone]
msho bson~stoel.com
Thomas M. Dethlefs
Senior Attorney
Qwest Services Corporation
1801 California Street - 10th Floor
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Thomas. Dethlefs~q west. com
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S. Mail
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Hand Delivered
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OBJECTIONS OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGA TORIES-