AT&T-MediaOne Document and Information Requests December 22, 1999 1. Reference Question 7 of the November 3, 1999 Request: "Please provide all internal and external research in AT&T's and MediaOne's possession concerning customer preferences for bundled services, including the Yankee Group survey and MediaOne's own research cited on page 4 of the McGee affidavit to the Joint Reply filed on September 17, 1999." The November 22, 1999 response to Question 7 states that the Yankee Group survey and the MediaOne research cited in the McGee affidavit would be provided under separate cover. Please provide all other documents that are responsive to Question 7 or confirm that no such documents exist. 2. Reference Question 11 of the November 3, 1999 Request: "Please submit all documents discussing the advantages and disadvantages of a merger between AT&T and MediaOne, or comparisons of such a merger with other strategies for AT&T's offering of high-speed Internet or local telephony services to residential customers." The November 24, 1999 response to Question 11 states that "AT&T will provide . . . documents that show the advantages of the merger with MediaOne." Please provide the other requested documents or confirm that no such documents exist. 3. Reference Question 14 of the November 3, 1999 Request: "Please provide a description of, and all documents related to, AT&T's post-merger strategy to provide local telephony and Internet services in MediaOne's markets, including the anticipated steps, investments, revenue increases, and timetables for the rollout of each service. Identify the extent to which the introduction of each service is dependent on and specific to the merger, and provide all documents that are relied on to support your response." The November 24, 1999 response to Question 14 states that "[b]ecause the merger has not been consummated, AT&T and MediaOne have not completed any formal planning regarding post-merger activity in MediaOne's service areas." No documents were provided in response to this request. Question 14 was not limited to AT&T's and MediaOne's formal planning. Accordingly, please provide all information and documents that are responsive to Question 14 or confirm that no such documents exist. 4. Reference Question 16 of the November 3, 1999 Request: "Please identify any and all interests held by MediaOne (including TWE, TWE Advance/Newhouse, and TWI Cable) in: a. MDS licensees serving, in whole or in part, any portion of a cable franchise area in which AT&T or the above named cable operators are authorized to provide service. b. Television broadcast stations whose predicted grade B contours overlap with any portion of the cable franchise area in which AT&T or the above named cable operators are authorized to provide service. c. SMATV operators serving any portion of a cable franchise area in which AT&T or the above named cable operators are authorized to provide service." The November 22, 1999 response to Question 16 states that "[d]ue to its position as a passive investor in Time Warner Entertainment Company, L.P., MediaOne does not have access to information that would be necessary to respond to this question regarding the holdings of TWE, TWE Advance/Newhouse or TWI Cable." Please provide the requested information as it pertains to TWE, TWE Advance/Newhouse, and TWI Cable. MediaOne's status as an investor in TWE, whether active or passive, does not affect MediaOne's obligation to provide information necessary for Commission staff to process its application. The requested information is necessary to enable staff to determine whether the proposed license transfers would violate the Commission's cross-ownership rules. 5. Reference Question 19 of the November 3, 1999 Request: "Does MediaOne (including TWE, TWE Advance/Newhouse, and TWI Cable) have any interests in a competitive or incumbent local exchange carrier? If so, please identify the following: a. The name of the carrier and level of ownership interest. b. Whether AT&T's acquisition of such interest would violate the prohibition on buy-outs as stated in 47 U.S.C.  572." The November 24, 1999 response to Question 19 indicates that MediaOne owns interests in competitive local exchange carriers that provide service in AT&T cable franchise areas. The response includes a chart showing areas of overlap between MediaOne cable franchise areas and areas where AT&T is or will be providing local telephone service using its own switching facilities. Using a similar chart and/or other descriptive means, please: (a) identify AT&T cable franchise areas in which MediaOne owns an interest in any local exchange carrier; (b) identify the local exchange carrier and the level of MediaOne's ownership interest; (c) describe the nature of the service being provided by the local exchange carrier; (d) state when the local exchange carrier first provided service in each area, how many customers are now served, and how many customers could be served using existing facilities (assuming the addition of drop lines or other facilities that normally would be installed upon initial customer hook-up); (e) state the market share held by MediaOne or its affiliates in each overlap area; and (f) identify all other entities that provide residential local exchange service in each area. 6. In the Transfer of Control Applications Public Interest Statement dated July 7, 1999 ("Public Interest Statement"), at 41 n.93, AT&T and MediaOne state, "MediaOne has entered into definitive agreements for transfers to Time Warner that will eliminate [franchise] overlaps with AT&T in Riverside-San Bernardino, with the exception of franchise territories in which there is no overbuilding." After the Time Warner-MediaOne transfer agreements are consummated, will AT&T and MediaOne hold cable franchises with overlapping territories in Riverside-San Bernardino? If so, identify any such overlapping territories. 7. Identify all AT&T and MediaOne cable franchises that have overlapping service areas, including franchises that were transferred after July 7, 1999, or for which transfer of ownership agreements are now pending. For each cable franchise identified, state: (a) the service area (including city and county) of the franchise; (b) the franchise's community unit identification number(s) ("CUID"); (c) the acquiring party; (d) the date the transfer agreement was entered into; and (e) if applicable, the date on which the agreement was consummated. 8. At the November 17, 1999 meeting between MediaOne and Commission staff, staff requested and MediaOne agreed to provide maps and charts showing the projected timeline for systems upgrades and provision of new broadband and telephony services in MediaOne's franchise areas, and the average income levels and racial and ethnic composition of households in the covered areas. Please provide the requested maps and charts. 2 3