Case 1:17-cv-02028 Document 1 Filed 10/02/17 Page 1 of 16
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA,
United States Department of Justice
Antitrust Division
450 Fifth Street, N.W., Suite 7000
Washington, DC 20530
Plaintiff,
v.
CENTURYLINK, INC.
100 CenturyLink Drive
Monroe, Louisiana 71203
and
LEVEL 3 COMMUNICATIONS, INC.,
1025 Eldorado Boulevard
Broomfield, Colorado 80021
Defendants.
Civil Action No. _______________
COMPLAINT
The United States of America brings this civil action to enjoin the acquisition of Level 3
Communications, Inc. by CenturyLink, Inc. and to obtain other equitable relief.
I. NATURE OF THE ACTION
1. On October 31, 2016, CenturyLink, Inc. (“CenturyLink”) and Level 3
Communications, Inc. (“Level 3”) entered into an Agreement and Plan of Merger whereby
CenturyLink would acquire Level 3. CenturyLink’s proposed acquisition of Level 3 would
consolidate two of the largest wireline telecommunications services providers in the United
States.
Case 1:17-cv-02028 Document 1 Filed 10/02/17 Page 2 of 16
2. CenturyLink and Level 3 compete to provide fiber-optic-based connectivity and
telecommunications services to enterprise and wholesale customers. Enterprise customers
(including all sizes of bu sinesses and institutions, such as community colleges, hospitals, and
government agencies) purchase high quality fiber-optic-based connectivity and
telecommunications services from CenturyLink and Level 3 for their own telecommunications
services needs. Wholesale customers (i.e., tel ecommunications carriers seeking to provide
telecommunications services to customer locations in areas where they do not have their own
wireline infrastructure) purchase lo cal network and building-level fiber connectivity from
CenturyLink and Level 3 in order to provide telecommunications services to their end-user
customers.
3. In three Metropolitan Statistical Areas (“MSAs”)
1
–
Albuquerque, New Mexico;
Boise, Idaho;
2
and Tucson, Arizona
–
CenturyLink and Level 3 have two of the three most
extensive fiber-based metropolitan area networks.
Without
significant competitors to rival
their
networks’ scale in each of these three MSAs, CenturyLink and Level 3
represent each other’s
closest competitor for many
enterprise and wholesale customers
in these MSAs, including, for
example,
enterprise customers with locations spread throughout an MSA. In man
y buildings
within each of these three MSAs, CenturyLink and Level 3 are
the only two providers, or
two of
only three providers, that own a direct fiber connection
to the building.
In
a substantial
proportion of buildings in these MSAs, though CenturyLink and Level 3 may not be connected
1
An MSA is a geographical region defined by the Office of Management and Budget for use by
federal statistical agencies, such as the Census Bureau. It is based on the concept of a core area
with a large concentrated population, plus adjacent communities having close economic and
social ties to the core. For the purposes of this Complaint, it includes the dense central business
districts in Albuquerque, Tucson, and Boise as well as the adjacent, connected communities.
2
The full name of this MSA as defined by the Office of Management and Budget is Boise City-
Nampa, Idaho.
2
Case 1:17-cv-02028 Document 1 Filed 10/02/17 Page 3 of 16
to these buildings, they are the only two providers with metropolitan area network fiber located
close enough to connect economically, making CenturyLink and Level 3 the best options for
customers in those buildings. The consolidation of these two competitors thus would likely
substantially lessen competition for the provision of fiber-optic-based connectivity and
telecommunications services in these three MSAs in violation of Section 7 of the Clayton Act, 15
U.S.C. § 18.
4. CenturyLink and Level 3 also own substantial amounts of dark fiber connecting
pairs of cities (“Intercity Dark Fiber”). Dark fiber is fiber-optic cable that has been installed,
typically in conduit in the ground, but has not been “lit” by attaching optical electronic
equipment at each end. Fiber that has had such equipment attached is called “lit” fiber because
the equipment sends data through the fiber in the form of light waves. Such lit fiber can rapidly
transmit thousands of terabits of data. Owners of Intercity Dark Fiber may “light” the fiber
themselves and then use the lit fiber to sell telecommunications services, including data
transport, to customers. But only a small handful of Intercity Dark Fiber owners, including
CenturyLink and Level 3, also sell the fiber “dark” and permit customers to add their own
electronic equipment and control their own data transport. Between some city pairs,
CenturyLink and Level 3 are the only two Intercity Dark Fiber providers. Between some other
city pairs, CenturyLink and Level 3 are two of only three Intercity Dark Fiber providers.
5. Dark fiber is a crucial input for large, sophisticated customers that need to move
substantial amounts of data between specific cities. These customers have specialized data
transport needs, including capacity, scalability, flexibility, and security, that can be fulfilled only
by Intercity Dark Fiber. CenturyLink and Level 3 compete to sell Intercity Dark Fiber to these
customers, and this competition has led to lower prices for and increased availability of Intercity
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Case 1:17-cv-02028 Document 1 Filed 10/02/17 Page 4 of 16
Dark Fiber. The consolidation of these two competitors would likely substantially lessen
competition for the sale of Intercity Dark Fiber for thirty city pairs in the United States in
violation of Section 7 of the Clayton Act, 15 U.S.C. § 18.
II. DEFENDANTS AND THE TRANSACTION
6. CenturyLink is a Louisiana corporation headquartered in Monroe, Louisiana. It is
the third largest wireline telecommunications provider in the United States and is the Incumbent
Local Exchange Carrier (“ILEC”)
3
in portions of 37 states. CenturyLink owns one of the most
extensive physical fiber networks in the United States, including metropolitan area network
components and direct fiber connections to numerous commercial buildings throughout the
United States, particularly where it serves as the ILEC, as well as considerable intercity fiber
infrastructure. Over the past ten years, CenturyLink has grown by acquiring a number of other
large telecommunications providers, including Embarq Corporation in 2009 and Qwest
Communications, Inc. in 2011. As of December 31, 2016, CenturyLink owned and operated a
360,000 route-mile global network, including a 265,000 route-mile U.S. fiber network, and
generated 2016 operating revenues of $17.47 billion.
7. Level 3 is a Delaware corporation headquartered in Broomfield, Colorado. It is
one of the largest wireline tele communications companies in the United States a nd operates as
one of the largest Competitive Local Exchange Carriers (“CLEC”), owning significant local
network assets comprised of metropolitan area network components and direct fiber connections
to numerous commercial buildings throughout the United States, including within portions of
CenturyLink’s ILEC territory. Level 3 operates one of the most extensive physical fiber
3
An incumbent local exchange carrier (ILEC) is the telephone company that was the sole
provider of local exchange service (local phone service) in a given local area prior to passage of
the 1996 Telecommunications Act, which allowed for competitive local exchange carriers
(CLECs) to compete for this local service.
4
Case 1:17-cv-02028 Document 1 Filed 10/02/17 Page 5 of 16
networks in the United States, including sizeable intercity
fiber infrastructure.
Level 3 has made
a number of significant
acquisitions in the past ten years, including Global Crossing L
imited in
2011 and tw telecom inc.
in 2014.
Level 3 owns and operates a 200,000 ro
ute-mile global
fiber
network a
nd generated
$8.172 billion of operating revenues in 2016.
8.
On October
31, 2016, CenturyLink and Level 3
entered into an Agreement and
Plan of Merger whereby
CenturyLink will
acquire
Level 3
for
approximately
$34 billion.
III. JURISDICTION AND VENUE
9.
The United States brings this action
under the direction of the Attorney General
and pursuant to
Section 15 of the Clayton Act, as amended, 15
U.S.C. §
25, to prevent and
restrain CenturyLink and
Level 3
from violating Section
7 of the Clayton Act, 15
U.S.C. §
18.
10.
CenturyLink and Level 3
are engaged in, and their activities substantially affect,
interstate commerce.
CenturyLink and Level 3 sell wireline telecommunications goods and
services throughout the
United States. The Court has subject-matter jurisdiction over this action
and these defendants pursuant to Section
15 of the Clayton Act, as amended, 15
U.S.C. §
25, and
28 U.S.C
. §§
1331, 1337(a), and 1345.
11.
Defendants CenturyLink and Level 3
transact business in the District of Columbia
and have
consented to venue and personal jurisdiction in this District.
Venue
is
proper in this
District under Section
12 of the Clayton Act, 15
U.S.C. §
22, and 28 U.S.C
. §
1391(b)(1) and (c).
IV. BACKGROUND
12.
Wireline telecommunications
infrastructure
is critical in transporting
the data that
individuals, businesses, and other entities
transmit.
Among the key components of this
infrastructure
are:
the fiber strands connecting an individual building to a metropolitan area
5
Case 1:17-cv-02028 Document 1 Filed 10/02/17 Page 6 of 16
network; the fiber strands and related equipment comprising a metropolitan area network that
serve an entire city or MSA; and the intercity fiber strands connecting cities to one another.
13. Fiber strands connecting an individual building to the metropolitan area network
serving an entire MSA are often referred to as “last-mile” connections. Without a last-mile fiber
connection to the building, customers cannot send data to or receive data from any point outside
of the building. And without the metropolitan area network to which those last-mile building
fibers connect, customers cannot communicate with other buildings in the same MSA or reach
any points beyond.
14. These fiber building connections and fiber-based metropolitan area networks
carry critical telecommunications services for enterprise customers. They also provide a link
over which wholesale providers – who sell services to end users in buildings to which the
wholesale provider does not own direct fiber connections – can serve their own customers.
15. Each ILEC has its own territory, which can include entire MSAs and/or portions
of MSAs. The ILEC typically has the largest number of fiber building connections in its
territory. As such, CenturyLink typically has the largest number of fiber connections to the
buildings where it is the ILEC, serving the majority of buildings that require high-bandwidth,
high-reliability telecommunications services. CLECs like Level 3 have built fiber connections to
buildings in CenturyLink’s and other ILEC’s territories, giving some buildings additional fiber
connections. More recently, other entities like cable companies have begun investing in fiber
connections to buildings in certain MSAs, though, like the CLECs, they typically have nowhere
near the scale of the ILEC.
16. In the MSAs of Albuquerque, New Mexico; Boise, Idaho; and Tucson, Arizona,
CenturyLink is the ILEC and owns the largest and most extensive fiber-based metropolitan area
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network, and Level 3 owns one of the top three largest fiber-based networks in all three MSAs.
In each of these MSAs, CenturyLink owns fiber connections to more than a thousand buildings,
while Level 3 owns connections to hundreds of buildings. In many of these buildings,
CenturyLink and Level 3 also control the only last-mile fiber connections. Moreover, they are
two of only three significant providers with metropolitan area network fiber nearby.
17. Intercity fiber connects a city’s metropolitan area network to other cities’
metropolitan area networks. Without fiber connecting cities’ metropolitan area networks, each
city would be an island, with no way for data sent by or destined for customers in one city to
reach to or from any other city. This intercity fiber linking city pairs is distinct from
metropolitan area network fiber that links locations within a city but does not connect outside –
the only connection between a metropolitan area network and any point beyond is intercity fiber.
CenturyLink and Level 3 are two of only a handful of companies with robust nationwide
intercity fiber networks.
18. Companies can light intercity fiber to send data across long distances between
cities. Intercity Dark Fiber providers can light the fiber themselves, supplying and controlling
the optical electronic equipment, and then sell lit services to customers. Intercity Dark Fiber
providers can also sell the fiber dark to large, sophisticated customers, in which case the
customer purchases the right to control the underlying fiber and then arranges for placement of
optical electronic equipment to light the fiber and manages its own traffic on the fiber.
19. Intercity Dark Fiber can provide customers additional data capacity, faster speeds,
and more robust security and control over their data networks. Intercity Dark Fiber sales are
typically structured as something similar to a long-term lease, known in the industry as an
7
Case 1:17-cv-02028 Document 1 Filed 10/02/17 Page 8 of 16
Indefeasible Right of Use (“IRU”),
4
with an up-front payment and some recurring fees for
maintenance of the fiber. Only a few companies in the United States sell Intercity Dark Fiber.
Most Intercity Dark Fiber providers also sell lit services, sometimes to the same customer.
V. RELEVANT MARKETS
A. Fiber-Based Enterprise and Wholesale Telecommunications Services Providing
Local Connectivity to Customer Premises
20. Fiber-based enterprise and wholesale telecommunications services providing local
connectivity to customer premises constitutes a relevant market and line of commerce under
Section 7 of the Clayton Act, 15 U.S.C. § 18.
21. Customers require this product to deliver high-bandwidth, high-reliability
telecommunications services. Customers who purchase fiber-based telecommunications services
providing connectivity to their premises will not turn to other connectivity technologies (such as
hybrid fiber-coax, copper, or fixed or mobile wireless) in sufficient numbers to make a small but
significant increase in price of fiber-based telecommunications services unprofitable for a
provider of these fiber-based telecommunications services.
22. In some instances, the relevant telecommunications services to individual
buildings are priced and sold separately. In other instances, including where MSA-wide price
lists are used and where customers have multiple locations throughout an MSA, sales and pricing
may be determined at the level of the MSA. Customers with multiple building locations spread
throughout an MSA may demand integrated telecommunications services to all locations.
Providers with a broad fiber presence in an MSA may be best suited to supply such customers.
4
The FCC defines an IRU, in part, as an indefeasible long-term leasehold interest for a minimum
total duration of ten years that gives the grantee the right to access and exclusively use specified
strands of fiber or allocated bandwidth to provide a service as determined by the grantee. An
IRU confers on the grantee substantially all of the risks and rewards of ownership.
8
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For such situations, the nature of competition may be best assessed at the MSA level. The
geographic markets relevant to these services are no narrower than each individual building and
no broader than each MSA.
23. The relevant geographic markets and sections of the country under Section 7 of
the Clayton Act, 15 U.S.C. § 18, withi n which to assess the competitive impact of a combination
of CenturyLink and Level 3 are the MSAs of Albuquerque, New Mexico; Boise, Idaho; and
Tucson, Arizona (collectively, the “Three MSAs”).
B. Intercity Dark Fiber
24. Intercity Dark Fiber constitutes a relevant product market and line of commerce
under Section 7 of the Clayton Act, 15 U.S.C. § 18.
25. Level 3 and CenturyLink utilize their intercity fiber to sell both lit services and
Intercity Dark Fiber. Lit services generally are sold for a certain capacity and paid for on a
monthly basis. The provider serves the customer using the provider’s optical electronic
equipment, and the provider manages the traffic on the fiber. In contrast, dark fiber is generally
sold through IRUs so that the customer can arrange for its own equipment to be placed and
manage its own traffic on the fiber. Customers who buy Intercity Dark Fiber, including
webscale companies
5
and financial institutions, require the properties of dark fiber for scalability,
capacity, flexibility, and security. Lit services sold by telecommunications providers cannot
match these qualities provided by Intercity Dark Fiber and are generally much more costly than
Intercity Dark Fiber for these customers’ purposes. Customers who purchase Intercity Dark
5
Webscale companies are those primarily engaged in the business of providing large amounts of
data to end users through web-based services; they require facilities and infrastructure to create,
store, and then transport that data across long distances.
9
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Fiber will not turn to an a
lternate service like lit services in the event of a small but significant
increase in the price of Intercity Dark Fiber.
26. The geographic markets relevant to this product are specific city pairs in the
United States. Intercity Dark Fiber customers generally need to transport data between specific
sources and destinations (for example, data centers and headquarters), and accordingly require a
fiber connection between cities close to those locations. Customers who face a small but
significant increase in price for Intercity Dark Fiber between a specific city pair typically will not
substitute different city pairs in response.
27. Further, the directness of the route between cities is critical for purposes of
reducing latency and expense. Therefore, Intercity Dark Fiber customers generally will consider
only certain routes between a city pair to fulfill their needs. The more circuitous a route, the
longer data needs to travel, and the more latency is introduced into the transmission. Longer
routes are also more costly to operate as more amplifier and regeneration equipment must be
added to the fiber to ensure proper transmission of the signal. Accordingly, only certain routes
between a city pair are viable substitutes for Intercity Dark Fiber customers.
28. The relevant geographic markets and sections of the country under Section 7 of
the Clayton Act, 15 U.S.C. § 18, within which to assess the competitive impact of a combination
of CenturyLink and Level 3 (collectively, the “Thirty City Pairs”) are:
1. Atlanta-Nashville
2. Birmingham-Billingsley
3. Charlotte-Atlanta
4. Cleveland-Buffalo
5. Dallas-Memphis
6. Denver-Dallas
7. Denver-Kansas City
8. El Paso-San Antonio
9. Houston-New Orleans
10. Indianapolis-Cincinnati
16.
Orlando-Daytona Beach
17. Phoenix-El Paso
18. Portland-Salt Lake City
19. Raleigh-Charlotte
20. Richmond-Raleigh
21. Sacramento-Salt Lake City
22. Sacramento-San Francisco
23. Salt Lake City-Denver
24. San Diego-Phoenix
25. San Francisco-Los Angeles
10
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11. Kansas City-St. Louis
12. Los Angeles-Las Vegas
13. Memphis-Nashville
14. Miami-Jacksonville
15. Nashville-Indianapolis
26. Tallahassee-Jacksonville
27. Tallahassee-Tampa
28. Tampa-Miami
29. Tampa-Orlando
30. Washington, DC-Richmond
VI. ANTICOMPETITIVE EFFECTS
29. The transaction likely would substantially lessen competition in the markets of
enterprise and wholesale fiber-based local connectivity telecommunications services in the Three
MSAs.
30. Enterprise and wholesale customers in the Three MSAs who depend on fiber-
based local connectivity telecommunications services provided by the defendants would be
harmed as a result of CenturyLink’s acquisition of Level 3. In particular, in addition to
wholesale customers, in each of the Three MSAs there are a substantial number of enterprise
customers with significant high-bandwidth, high-reliability telecommunications services needs.
While some of these customers have a single location, many others have multiple locations
throughout the metropolitan area and require telecommunications providers who can offer fiber-
based connections to all of their locations. CenturyLink and Level 3 use their metropolitan area
networks to compete for customers at locations in the Three MSAs where the two companies
already have connected fiber, and to compete for opportunities at new locations throughout the
MSAs where CenturyLink and Level 3 could economically add lines to connect to new locations.
31. In each of the Three MSAs, CenturyLink is the largest provider of fiber
connectivity and has fiber connections to over a thousand buildings. Level 3 has fiber
connections to several hundred buildings in each of the Three MSAs, making it the second
largest provider of fiber connectivity to buildings in Albuquerque and Tucson, and one of the top
three largest in Boise. In many buildings in the Three MSAs, CenturyLink and Level 3 control
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the only last-mile fiber connections. Moreover, they are two of only three significant providers
with fiber connections to, or metropolitan area network fiber nearby, buildings in the Three
MSAs, representing a customer’s best choices for this product in many instances in the Three
MSAs. Competitor metropolitan area networks in these Three MSAs that have smaller, less
robust networks are not close substitutes for CenturyLink’s and Level 3’s networks.
32. CenturyLink and Level 3 compete directly against one another to provide fiber-
based enterprise and wholesale local connectivity telecommunications services to a wide variety
of customers in the Three MSAs, including, but not limited to, small- to medium-sized enterprise
customers with one or multiple locations, large multi-regional enterprise customers with branch
locations in the Three MSAs, and wholesale customers who resell to all types of end users.
Customers have benefitted from this competition, including by receiving lower prices and higher
quality services. The acquisition of Level 3 by CenturyLink would represent a loss of this
competition.
33. This loss of competition likely will result in increased prices for enterprise and
wholesale customers purchasing fiber-based local connectivity telecommunications services in
the Three MSAs. In each of the Three MSAs, CenturyLink and Level 3 operate in a highly
concentrated market, representing for hundreds of buildings two of only three, and in some cases
the only two, providers with fiber connectivity to or near customer premises. While currently
these customers can turn to Level 3 if CenturyLink raises prices, the loss of Level 3 as a
competitor would leave some customers with only one alternative and many others with no
competitive choice at all. Post-merger, these highly concentrated markets will become
significantly more concentrated, with the parties’ combined share of all last-mile fiber building
connections at approximately 90% in Albuquerque, New Mexico; 80% in Tucson, Arizona; and
12
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70% in Boise, Idaho. Without Level 3 as a competitive constraint in these highly concentrated
markets, the merged firm will have the incentive and ability to increase prices above competitive
levels and reduce quality of service.
34. The transaction likely would also substantially lessen competition for Intercity
Dark Fiber for the Thirty City Pairs. Webscale and financial customers who currently rely on
Level 3 and CenturyLink to compete for Intercity Dark Fiber sales would be harmed by this
transaction. Not all telecommunications providers sell Intercity Dark Fiber. The ability to sell
Intercity Dark Fiber requires that a provider control enough fiber for its own operations and have
enough remaining to sell the amount requested by the customer, on the route specified by the
customer, and for the length of time required by the customer. CenturyLink and Level 3 are two
of only a few providers, and in most cases the only two providers, who have this ability and offer
to sell Intercity Dark Fiber between each of the Thirty City Pairs. Webscale company customers
typically require dark fiber across multiple intercity routes, and they prefer dark fiber providers
who can provide them with contiguous routes, including those spanning from coast to coast.
CenturyLink and Level 3 are two of only three Intercity Dark Fiber providers with at least one
contiguous route from the west coast to the east coast.
35. For the Thirty City Pairs, where competition is so highly concentrated, the
acquisition of Level 3 by CenturyLink would represent a loss of crucial competition for
customers who require Intercity Dark Fiber. The competition between CenturyLink and Level 3
for Intercity Dark Fiber between these city pairs has led to decreased prices and increased
availability, with each defendant being more willing to lower price and offer more Intercity Dark
Fiber, or offer Intercity Dark Fiber at all, in response to competitive pressure from the other.
Currently, customers can turn to CenturyLink for Intercity Dark Fiber for any of the Thirty City
13
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Pairs
if Level 3 raises price or is unwilling to sell
Intercity
Dark Fiber, but
the loss of
CenturyLink as a competitor would leave
customers with no such option, providing the merged
firm the incentive and ability to raise prices
above competitive levels.
VII. ABSENCE OF COUNTERVAILING
FACTORS
36.
Entry of new competitors
in the relevant markets is unlikely to prevent or remedy
the proposed merger’s anticompetitive effects.
37.
The proposed merger would be unlikely to generate verifiable, merger-specific
efficiencies sufficient to reverse or outweigh the anticompetitive effects that are likely to occur.
VIII. VIOLATIONS ALLEGED
38.
The acquisition of
Level 3 by CenturyLink likely
would substantially lessen
competition in each of the relevant markets in violation of
Section 7 of
the Clayton Act,
15 U.S.C
. §
18.
39.
Unless enjoined, the acquisition
will
likely
have the following a
nticompetitive
effects, among others:
a.
competition in the market for fiber-based enterprise and wholesale
telecommunications services providing local connectivity to customer premises
in
the Three MSAs –
Albuquerque, New Mexico;
Boise, Idaho; and Tucson, Arizona
–
would be substantially
lessened;
b.
prices for
fiber-based enterprise and wholesale telecommunications services
providing local connectivity to customer premises
in
the Three MSAs would
increase
and
quality of service would decline;
c.
competition in the markets
for
Intercity
Dark Fiber between each of
the Thirty
City Pairs
would be substantially lessened;
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d. prices for Intercity Dark Fiber between each of the Thirty City Pairs would
increase; and
e. availability of Intercity Dark Fiber between each of the Thirty City Pairs w ould
decrease.
IX. REQUESTED RELIEF
40. The United States requests that thi s Court:
a. adjudge and decree CenturyLink’s acquisition of Level 3 to violate Section 7 of
the Clayton Act, 15 U.S.C. § 18;
b. permanently enjoin and restrain CenturyLink and Level 3 from carrying out the
Agreement and Plan of Merger dated October 31, 2016, or f rom entering into or
carrying out any contract, agreement, plan, or understanding, by which
CenturyLink would combine with or acquire Level 3, its capital stock, or any of
its assets;
c. award the United States its costs for this action; and
d. award the United States such other and further relief as the Court deems just and
proper.
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Dated:
October 2,
2017
Respectfully submitted,
FOR PLAINTIFF
UNITED
STAT
ES:
MAKAN DELRAHIM
Assistant Attorney General
Antitrust Division
ANDREW C. FINCH
Principal Deputy Assistant Attorney General
Antitrust Division
DONALD G. KEMPF, JR.
Deputy Assistant Attorney General
Antitrust Division
PA
TRICIA A. BRINK
Director
of
Civil Enforcement
Antitrust Division
SCOTT A. SCHEELE (D.C. Bar#429061)
Chief
Telecommunications & Media Enforcement Section
LAWRENCE M.
FRANKEL (DC.Bar
#441532)
Assistant Chief
Telecommunications
& Media Enforcement Section
SCOTT REITE
R*
ALEXIS K BROWN-REILLY (D.C.
Bar
#1000424)
ROBERT DRABA (D.C. Bar #496815)
MAUREEN CASEY (D.C. Bar #415893)
CORY BRADER LEUCHTEN
KELLY SCHOOLMEESTER (D.C. Bar #1008354)
MATTHEW SIEGEL
CARL WILLNER (D.C. Bar #412841)
CATHARINE WRIGHT (D.C. Bar #1019454)
United States Department
of
Justice
Antitrust Division
Telecommunications & Media Enforcement Section
450 Fifth Street, N.W., Suite 7000
Washington, DC 20530
Telephone: (202) 598-8796
Facsimile: (202) 514-63
81
Erp.ail
: scott.reiter@usdoj .gov
*LEAD ATTORNEY TO BE NOTICED
