200507201st Level 3 response to Qwest.pdf

Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: [phone]
joe~mcdevitt-miller .com
Attorneys for Level Communications, LLC
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ORI GINAL
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-
RESPONSES OF LEVEL 3
COMMUNICATIONS, 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 Responses 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
RESPONSES 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.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
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.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
DATA REQUEST NO.
DATA RESPONSES:
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)
(d)
(e)
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;
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
RESPONSES 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 3further 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.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
DATA REQUEST NO.
F or 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 Level 3' s Objection to Request No.
RESPONSES 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 3
Level 3 will provide a response once the Protective Agreement has been executed and Level 3
has received Qwest's signatures.
RESPONSES 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
LEVEL 3'S RESPONSE TO REQUEST QWEST 4.
Level 3 objects to this request on the grounds that it is not reasonably calculated to lead to the
discovery of admissible evidence. Subject to and without waiving its objections, Level 3
responds that it has three affiliates in Idaho: Level 3 Communications, LLC; BTE Equipment
LLC; and Level 3 Enhanced Services, LLC.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
DATA REQUEST NO.
F or 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 Level 3' 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 5.
Subject to and without waiving its objections, Level 3 responds that Level 3' s affiliates may
purchase services from Level 3. To the best of its knowledge, no network facilities are "shared"
between them as that term is normally used in the telecommunications industry.
RESPONSES 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, thenumber of minutes of use (MOUs) of each type of traffic (e., IntraLATA 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 Idaholaw. 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 6.
Subject to and without waiving its objections, Level 3 responds as follows: Qwest has (or shouldhave) this information in its possession because in the normal course Qwest' s switches do (or
should) record traffic incoming to Qwest from Level 3, and the classification of traffic into
relevant categories can be accomplished by means of comparing the originating and terminating
NPA-NXX codes on each call. If Qwest does not have accurate recordings, please so advise
Level 3 and Level 3 will provide available information subject to and without waiving its
objections and after receipt of Qwest's signed Protective Agreement
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
DATA REQUEST NO.
F or 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.
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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 7.
Subject to and without waiving its objections, Level 3 responds as follows. To the extent this
request relates to Level 3' s proposals for the parties' new interconnection agreement , please see
Level3's responses to Requests Qwest 12-16.
RESPONSES 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 8.
Subject to and without waiving its objections, Level 3 responds that with unlimited time
personnel, and money, it would be technically possible to create a separate trunking network that
meets Qwest's criteria for "Feature Group D" trunking and to migrate existing traffic flows from
existing trunk groups to this hypothetical new set of trunks. In the same sense, it would be
technically possible to construct a new 8-lane highway running directly between Level3'
headquarters in Broomfield, Colorado and Qwest's headquarters in Denver, Colorado
approximately 15-20 miles away. However, the level of actual expense and effort associated
with undertaking either of these projects so utterly dwarfs the benefits to be derived from doing
so that each may be said to be totally impracticable, if not, literally, technically impossible.
RESPONSES 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, Le., 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. 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, 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
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 9.
Subject to and without waiving its objections, Level 3 responds as follows:
Level 3 provides call flow diagrams descriptive of the information requested as
Exhibit A attached hereto.
Please see Level3's response to subpart (a) above.
Level 3 provides call flow diagrams descriptive of the information requested as
Exhibit A attached hereto.
RESPONSES 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 Level 3' s Objections to Request No.
LEVEL 3'S RESPONSE TO REQUEST QWEST 10.
Subject to and without waiving its objections, Level 3 will provide this information upon receipt
of Qwest' s signed Protective Agreement.
RESPONSES 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 11.
Subject to and without waiving its objections, Level 3 responds as follows: Please see Level 3'
responses to Requests Qwest 12-16.
RESPONSES 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 Level 3' 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 (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 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 Idaho Falls with a telephone number whose
NP AINXX relates to a wire center in Idaho Falls (i., 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 (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 transporting the call
from Level3's POI in Boise and terminating it with Qwest's customer?
(e)For 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 Level3's POI 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 NPAINXX relates to a wire center in New York City (Le., 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
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
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. As 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 12.
Qwest would receive no compensation for bringing this traffic to Level 3; indeed
payment of such compensation would violate 47 C.R. ~ 51.703(b). Qwest
would, however, receive compensation from its own end users for originating
such traffic, assuming that Qwest does not provide services to its customers for
free. The amount of such compensation will depend on the particular services
purchased by particular Qwest end users, how one allocates Qwest revenues
received under flat-rated plans to the various activities covered by such plans, etc.
Qwest would pay Level 3 $0.0007 per minute for such traffic.
As Level 3 understands this scenario, the combination of originating and
terminating NPA-NXXs would lead Qwest to view this as a toll call being
originated by one of its customers. If Qwest is the toll carrier it would charge the
customer its toll rates for the call which would compensate Qwest for the
function described in the request. If Qwest is not the toll carrier it would hand the
call off to the customer s IXC, which would pay Qwest intrastate originating
access charges.
Assuming that Qwest is the toll carrier and hands the traffic off to Level 3 at
Level 3' s Boise PO lover the parties' interconnection trunks , Qwest would pay
Level 3 $0.0007 per minute for such traffic.
As Level 3 understands this scenario, the combination of originating and
terminating NPA-NXXs would Qwest lead Qwest to view this as a toll call being
originated by one of its customers. As a general matter, as noted above, if Qwest
is the toll carrier it would charge the customer its toll rates for the call, which
would compensate Qwest for the function described in the request. If Qwest is
not the toll carrier it would hand the call off to the customer s IXC, which would
pay Qwest interstate originating access charges.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
Note, however, that it is unclear why Qwest would ever deliver such a call to
Level3's POI in Boise. For this reason, Level 3 does not believe that Qwest
would ever pay Level 3 in connection with such traffic.
As Level 3 understands this scenario, Level 3 would pay Qwest $0.0007 per
minute for the function identified. Qwest would not pay Level 3 anything for it.
As Level 3 understands this scenario, it would only arise if the originating
customer is a Level 3 VoIP customer, in which case Level 3 would pay Qwest
$0.0007 per minute for the termination function. Qwest would not pay Level 3
anything for it.
As Level 3 understands this scenario, it would only arise if the originating
customer is a Level 3 VoIP customer, in which case Level 3 would pay Qwest
$0.0007 per minute for the termination function. Qwest would not pay Level 3
anything for it.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
DATA REQUEST NO. 13:
U sing 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 13.
Please see Level3's response to Request Qwest12(a).
Please see Level3's response to Request Qwest12(b).
Please see Level3's response to Request Qwest12(c).
Please see Level3's response to Request Qwest12(d).
Please see Level3's response to Request Qwest12(e).
Please see Level3's response to Request Qwest12(t).
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
DATA REQUEST NO. 14:
U sing 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 14.
a- f: As Level 3 understands this request, the answers would not change based on the Qwestcustomer being located in Bend. However, if Qwest believes that there is something significant
about the change of hypothetical location, please provide a follow-up description of that
significance so that Level 3 can address it directly.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
DATA REQUEST NO. 15:
U sing 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 15.
Please see Level3's response to Request Qwest 14(a).
Please see Level 3' s response to Request Qwest 14(b).
Please see Level 3' s response to Request Qwest 14( c).
Please see Level 3' s response to Request Qwest 14( d).
Please see Level3's response to Request Qwest 14(e).
Please see Level3's response to Request Qwest 14(t).
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
DATA REQUEST NO. 16:
U sing 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' s 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 16.
Under Level3's proposal, billing and rating of traffic is based on NP A-NXX code and not on
any effort to identify the physical location of the end user. This is of course consistent with the
way that Qwest itself (and all ILECs of which Level 3 is aware) rates and bills traffic; indeed, as
far as Level 3 is aware, neither Qwest's switches nor any other ILEC's switches are configured
even to store, much less to make any use of, information regarding the physical location of any
end user. For these reasons the assumption that an end user is located somewhere other than the
wire center associated with his or her assigned telephone number has no impact on billing or
intercarrier compensation.
RESPONSES 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 Level3'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. As 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 17.
Seventy cents.
No.
No.
RESPONSES 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 Level3'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 Level 3'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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 18.
Assuming that "VoIP Provider POP" is the POI where Level 3 accepts traffic from Qwest, Level
3 responds as follows:
Seventy cents.
No.
No.
RESPONSES 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 Level3'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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 19.
State commissions throughout SBC, Verizon, and BellSouth territories
have approved interconnection agreements containing interconnection
provisions and definitions that are substantially the same or similar to
those proposed to Qwest by Level 3.
See Level 3's response to subpart (a) above.
RESPONSES 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 20.
In an effort to reach mutual agreement with Qwest regarding the treatment ofVoIP traffic, Level
3 has proposed language within the context of this interconnection negotiation using many terms
that Qwest proposed as Qwest rejected Level 3' s offers to use terms similar to those proposed to
SBC, Verizon, or BellSouth. Accordingly, the interconnection language presented within Level
3' s petition reflects Level 3' s attempts to accommodate Qwest' s needs, while crafting language
that complies with federal law and strikes a fair balance between the parties.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES~
DATA REQUEST NO. 21:
If Level 3' 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 21.
This request is unclear as directionality of the call flow is not indicated. Secondly, the request
appears to indicate that the definition of VoIP depends upon the existence of a broadband
connection. Level 3 agrees that as an operational matter that such a condition is generally true
however, this is not true for the purpose of applying legal tests such as those contained in the
FCC's Vonage order. Accordingly, Level 3 agrees that a "VoIP Provider" such as Level 3'
enhanced services affiliate or Qwest Communications Corp., which is Qwest's ESP affiliate
could receive VoIP traffic originating from "end user" customers via "broadband" connections
such as DSL provided by Qwest, cable modem, or a wireless link.
RESPONSES 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' 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 22.
Please see Level 3' s responses to Requests Qwest 20 and 21.
RESPONSES 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) Level3'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 the
VoIP provider must also transmit the traffic to the public switched
telephone network (PSTN) 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 23.
Level 3 responds that VoIP traffic is 2-way. A VoIP signal could originate from a VoIP
customer and terminate to the PSTN. In other words, the VoIP call would be "transmitted over a
broadband connection from the VoIP provider." Alternatively, a PSTN customer could call a
VoIP customer. That would be traffic "transmitted over a broadband connection to the VoIP
provider." Accordingly, Level 3 proposes language that permits traffic to be transmitted
transmitted over a broadband connection to or from the VoIP provider.
RESPONSES 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 $.0007 per MOU.
OBJECTION TO DATA REQUEST NO. 24:
Level 3 objects to this request on the basis that it is vague, ambiguous, overly broad, unduly
burdensome, and imprecise, and utilizes terms that are subject to multiple interpretations but are
not properly defined or explained. Level 3 further objects to this data request in so far as the
request lacks certain information required in order for Level 3 to provide an adequate response.
Level 3 further objects to this request on the grounds that it calls for a legal conclusion and is
therefore not an appropriate subject for discovery. Level 3 further objects to the request in so far
as it does not seek facts and instead requests Level 3' s opinion, and is therefore not reasonably
calculated to lead to the discovery of admissible evidence and is not relevant to the subject
matter of this action. Level 3 further objects to this request to the extent that it assumes facts and
circumstances that have never been discussed between the Parties. Subject to and without
waiving these objections, Level 3 will respond to this request.
LEVEL 3'S RESPONSE TO REQUEST QWEST 24.
Yes.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 25:
Does Level 3 agree that, for purposes of determining whether compensation at the rate of$.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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 25.
No. VoIP traffic should be subject to the $0.0007 per minute rate regardless of the factors noted
in the request. Please also see Level 3' s responses to Requests Qwest 12-16 regarding
billing/rating based on NP A - NXX as opposed to physical location.
RESPONSES 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. As 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'
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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 26.
Level 3 responds that what "should be" done cannot be determined based on the hypothetical as
stated. In general, the physical location of calling and called parties has never been a known or
useful fact in rating a call by Qwest or any other ILEC. Instead, calls have been rated based
upon the NP AINXX of the calling and called parties. To the extent that the hypothetical assumes
that the Commission would violate this traditional approach to rating calls, Level 3 would
propose that such violations "should be" as narrow as possible.
RESPONSES 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) Does Level3'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?
(b)
(c)
(d)
(e)
(t)
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? If not, why not?
Does Level 3' s proposed contract language require Qwest to transport the
call from the PO I 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 relevant to the subject matter of this action. Subject
to and without waiving these objections, Level 3 will respond to this request.
LEVEL 3'S RESPONSE TO REQUEST QWEST 27.
Level 3 responds as follows:
No. Level 3 would pay Qwest $0.0007 per MOU.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
Please see Level3's response to subpart (a) above.
Qwest would receive $0.0007 per minute for this traffic.
Please see Level 3's response to subpart (a) above.
As Level 3 understands it
, "
LIS" is simply the name that Qwest applies to
trunks that it establishes, within its own network on its side of a POI, tocarry traffic between Qwest's network and a CLEC' s network, and
further, that there is no technical or (under Level 3' s language) economic
or billing significance to that label. Given this understanding, Level 3does not know whether the trunks carrying traffic between the two
networks are called "LIS" trunks or not. The notion that different "types
of trunks are meaningfully distinguished by the "types" of traffic they
carry is a fiction that Qwest is advancing, but has no technical or
economic significance for Level 3.
Please see Level 3's response to subpart (a) above.
RESPONSES 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 28.
No.
RESPONSES 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-IP 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 29.
Yes.
RESPONSES 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) If not, does it plan to do so in the near future?
(b)
(c)
Does Level 3 provide this service to end user retail customers?
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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 30.
Level 3 responds as follows:
Yes.
Yes. Level 3 provides this service on a wholesale basis to end users who
are enhanced service providers, to large government customers, and to
large business users.
Yes.
RESPONSES 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) V oIP 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 31.
No.
RESPONSES 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 anticompetitive harm rendered by Qwest's
self-serving, archaic, and backward interpretations of federal law. Qwest has obligations understate 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.
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.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-40
LEVEL 3'S RESPONSE TO REQUEST QWEST 32.
Subject to and without waiving its objections, Level 3 responds as follows: Yes. The person
originating the analog (or time division multiplexing "TDM") call subscribes to circuit switched
telephone services such as Qwest ChoiceTM Home with Qwest ChoiceTM Unlimited Long
Distance. That person is making a circuit switched call to a VoIP customer on Level 3' s
network. Accordingly the call terminates in IP format.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-41
DATA REQUEST NO. 33:
On Exhibit A attached hereto, Level 3 states that it is "( c Jommitted to customer enablementLevel 3 will not compete against our (3) V oIP 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'
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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 33.
Please see Level3's response to Request Qwest 30.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-42
DATA REQUEST NO. 34:Does Level 3 provide "(3)Voice(ID 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' 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 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, Level3's product plans, dates of
offering service, etc. 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.
Lastly Level 3 objects to the extent that this information may by equally available to
Qwest as it is to Level 3.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-43
LEVEL 3'S RESPONSE TO REQUEST QWEST 34.
Subject to and without waiving its objections, Level 3 responds as follows:
Not applicable.
No.
Not applicable.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-44
DATA REQUEST NO. 35:
Is Level 3 providing any other VoIP services in Idaho, either in a retail or wholesale capacity?
, 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 Level 3' 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 35.
Subject to and without waiving its objections, Level 3 responds as follows: Please see Level 3' s
response to Request Qwest 9.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-45
DATA REQUEST NO. 36:
Is Level 3 a VoIP provider to end user customers in Idaho? Ifnot, does Level 3 plan to do soafter 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, undulyburdensome, 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 therequest 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 federalcourts 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 isapparently 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 faras 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 itseeks information regarding Level 3' s projections regarding future services, strategiesequipment 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 respondto this request.
LEVEL 3'S RESPONSE TO REQUEST QWEST 36.
Level 3 responds as follows: Level 3 provides wholesale VoIP service to service providers whooffer these services to end users in Idaho.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-46
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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 37.
Level 3 responds as follows: Level 3 Communications, LLC is a CLEC in Idaho and provides
telecommunications services.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-47
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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 38.
Level 3 responds as follows: Yes. This would include Qwest's affiliates such as QwestCommunications Corp. who purchase such services from Level 3.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-48
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'
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.
Additionally, Level 3'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.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-49
LEVEL 3'S RESPONSE TO REQUEST QWEST 39.
Subject to and without waiving its objections, Level 3 responds as follows: No.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 40.
State commissions throughout SBC , Verizon, and BellSouth territories
have approved interconnection agreements containing interconnection
provisions and definitions that are substantially the same or similar
those proposed to Qwest by Level 3.
Please see Level3's response to subpart (a) above.
RESPONSES 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 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 41.
Level 3 will provide this information once it receives Qwest's signed Protective Agreement.
RESPONSES 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 42.
Level 3 may be able to respond to this request if Qwest provides the following clarification:
Should Level 3 assume that (a) "the FCC's reciprocal compensation rules" refer to the rules as
contained in 47 C.R. ~ 51.701 et. seq., unchanged, (b) "the FCC's reciprocal compensation
rules" refer to those rules as necessarily modified by the D.C. Circuit's decision in WorldCom
FCC which specifically and unequivocally precluded the FCC from carving Section 251
(g)
information access" traffic out from the scope of Section 251 (b)( 5), or (c) something else?
RESPONSES 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 43.
Level 3 provides retail intrastate DID & DID/DOD (Local), Private Line (Transport), and
(3)Voice Termination (Toll) services within the State of Idaho.
RESPONSES 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 44.
Level 3 responds that the ISP mayor may not have physical facilities in the local calling area
but it is correct that ISPs, as customers of Level 3 , receive local numbers so that their customers
may access their service on a locally dialed basis where such service is terminated to Level 3
POls located within LATAs.
RESPONSES 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 NANPA.
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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 45.
Subject to and without waiving its objections, Level 3 responds as follows: Level 3 has two POls
in LATA 652.
RESPONSES 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 NPA 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:
Level 3 objects to this request on the basis that it is vague, ambiguous, overly broad, undulyburdensome, 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 3further objects to this data request to the extent that the information requested is "confidentialhighly sensitive confidential " or constitutes "trade secrets" pursuant to Idaho law. To the
extent that Qwest requests proprietary confidential business information, Level 3 will only makesuch information available once a Protective Agreement is executed in this docket. Anyproduction 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 requiredto 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 technicallyfeasible point within its network." Further, Section 51.100 of the FCC's rules require that Qwestallow 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.
RESPONSES 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 47.
Level 3 responds that it does not contend that Qwest is obligated to populate the OLI field.
RESPONSES 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 48.
Originating Line Information (OLI): Information indicating a toll class of service for the call.
ITl.667-1999) available at http://www.atis.org/tg2k/ _originating_Iine information.html.:.
RESPONSES 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 49.
Level 3 responds that Level 3 is uncertain of the origin of the term "Other Company Number
It appears from a search of the DPL in this docket that term "Other Company Number" is not in
dispute, but if it has been used somewhere and Qwest does not understand how or why, Level 3
asks that Qwest inform Level 3 as Level 3 would like to know as well. In a further effort to be
responsive Level 3 provides a standard definition for "Operating Company Number" (OCN),
which it understands would be the operative term that the Parties would use: "A code used in the
telephone industry to identify a telephone company. Company codes assigned by NECA
(National Exchange Carrier Association) may be used as OCNs. See also AOCN and NECA.
See Newton s Telecom Dictionary, 19th ed., p. 576.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--60
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:(a) intercarrier compensation of local traffic; or
(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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 50.
Level 3 responds that Level 3 does not assert that there is an industry requirement to always
provide either the "Other Company Number" or the "Operating Company Number" for the
purposes stated in the request.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-61
DATA REQUEST NO. 51:
Is Level 3' 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 51.
Subject to and without waiving its objections, Level 3 responds that Level 3' s Viper soft switch
provides SS7 connectivity to the PSTN. To the best ofLevel3's knowledge, no industry groups
are discussing the use of a Charge Number SS7 as a proxy for rating a VoIP call.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--62
DATA REQUEST NO. 52:
Is Level 3' 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'
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.
Consequently, Level3'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'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.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--63
LEVEL 3'S RESPONSE TO REQUEST QWEST 52.
Subject to and without waiving its objections, Level 3 responds as follows: Please see Level 3' s
response to Request Qwest 51.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-64
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'
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, Level3'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, 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.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--65
LEVEL 3'S RESPONSE TO REQUEST QWEST 53.
Subject to and without waiving its objections, Level 3 responds as follows: Please see Level 3' s
response to Request Qwest 51.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-66
DATA REQUEST NO. 54:
Is Level 3' 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'
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.
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.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--67
LEVEL 3'S RESPONSE TO REQUEST QWEST 54.
Subject to and without waiving its objections, Level 3 responds as follows: Please see Level 3' s
response to Request Qwest 51.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-68
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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 55.
Level 3 provides the following response: The term "Call Record Information" is a term that
Level 3 proposes to allow for the use of additional signaling parameters such as those currently
under discussion with NECA to permit the parties to flexibly develop systems for exchange of
billing information that account for the convergence of networks, applications, and the fact that
NP A-NXX codes are no longer associated with geographic locations.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES--69
DATA REQUEST NO. 56:
Exhibit B is a page from Level 3' s website related to a service entitled "(3 )Connect(ID 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)
(t)
Does Level 3 provide "(3 )Connect(ID 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 Level 3' s "(3 )Connect(ID 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 Level 3? 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(IDModem" 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.
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
(2)the specific piece or pieces of equipment that directs the call to
websites selected by the end user during the course of the call.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
(g)
(h)
Would it be fair to characterize Level 3' s "(3 )Connect~ 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
Modem" service.
Before reaching the modems and routers provided by Level 3 as part of its
(3)Connect~ 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 Level 3'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 Level 3' 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 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'
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.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
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.
RESPONSES 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) 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?
(c)
(d)
(b)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? If not, 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 " orconstitutes "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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 57.
Level 3 responds as follows:
No. Level 3's network is continuously upgradeable and the network is
constantly upgraded to provide the best services at the lowest cost using
the latest technology.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
When Level 3 provides service to ISP customers as described in this
request, Level 3 connect its equipment to the routers and modems of the
ISP according to sound engineering principles, which engineering solution
depends upon traffic volumes.
RESPONSES 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), Level
3' s proposed language for section 7.3.4.1 (Issue 4), and Level 3' s proposed language for section
1 (Issue 3C), there appears to be an inconsistency in the application of intercarrier
compensation for different types of traffic. For example, Level3's proposed 7.1 and the
definition of VNXX traffic suggest that all ISP-bound traffic and VoIP traffic will be subject to
reciprocal compensation without limitation, while section 7.3.4.1 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)
(d)
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?
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?
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
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 58.
Level 3 responds as follows:
Section 251 (b )( 5) traffic includes all reciprocal compensation traffic.
Intercarrier compensation includes compensation exchanged between the
carriers under Section 251(b)(5) of the Act or under Sections 201-204
depending upon how the parties agree to rate this traffic.
It appears from Qwest's requests that it is juxtaposing language through
the contract in order to make Level 3' s proposals appear confusing.
Section 7.3.4.1 simply addresses concepts associated with the exchange of
traffic that the FCC requires be compensated at $0.0007 per MOU in the
context of the physical interconnection of such networks.
Yes. Please see Level 3' s response to subpart ( c) above.
Please see Level 3' s response to subpart (c) above.
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
DATA REQUEST NO. 59
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 Level 3' s contention that "federal ISP-bound traffic compensation regime applies to
all ISP-bound traffic.
OBJECTION TO DATA REQUEST NO. 59:
See Level 3' s Objection to Request No.
LEVEL 3'S RESPONSE TO REQUEST QWEST 59.
Please see Level 3' s objections to Request Qwest 1 , which are incorporated herein by reference.
RESPONSES 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 Level 3' 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 60.
Please see Level 3' s objections to Request Qwest 1 , which are incorporated herein by reference.
RESPONSES 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
to make assumptions that are not contained in the request. Subject to and without waiving these
objections, Level 3 will respond to this request.
LEVEL 3'S RESPONSE TO REQUEST QWEST 61.
Level 3 responds that VoIP traffic is defined separately from ISP-bound traffic in Level 3'
proposed contract language.
RESPONSES 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.
LEVEL 3'S RESPONSE TO REQUEST QWEST 62.
Level 3 will begin remitting Idaho Universal Service Fund with the next reporting cycle. The
remittance will be based on access line counts.
RESPONSES 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.
RESPONSES 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'
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.
Level 3 objects to this request on the basis that it is vague, ambiguous, and overly broad. Level 3
further objects to this request because it is not reasonably calculated to lead to the discovery of
admissible evidence.
DATED this day of July, 2005.
Respectfully submitted
McDEVITT & MILLER LLP
D an J. Miller
McDevitt & Miller LLP
420 W. Bannock
Boise, ID 83702
Phone: [phone]Fax: [phone]
Counsel for Level 3 Communications, LLC
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
CERTIFICATE OF SERVICE
I hereby certify that on the J~ay 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]
mshobson~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
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
Fed. Express
Email
RESPONSES OF LEVEL 3 COMMUNICATIONS, LLC TO QWEST CORP'S FIRST SET OF INTERROGATORIES-
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