Request for Confidentiality

0002-EX-ST-2019 Text Documents

AT&T; Services, Inc.

2019-01-03ELS_221838

                                                          Michael P. Goggin                       AT&T Services, Inc.
                                                          Assistant Vice President -              1120 20th Street NW, Suite 1000
                                                          Senior Legal Counsel                    Washington, D.C. 20036
                                                                                                  Phone 202 457-2055
                                                                                                  michael.p.goggin@att.com




January 2, 2019


CONFIDENTIAL MATERIALS ATTACHED


Federal Communications Commission
Office of Engineering and Technology
Experimental Licensing Branch
Washington, DC 20554

Re:       REQUEST FOR CONFIDENTIAL TREATMENT

          Application for Experimental Special Temporary Authority by AT&T Services, Inc.
          0002-EX-ST-2019


Pursuant to Section 0.459 of the Commission’s Rules, 47 C.F.R. § 0.459, AT&T Services, Inc.
(“AT&T”), by its counsel, respectfully requests that the enclosed submission in 0002-EX-ST-
2019 be withheld from public inspection and afforded confidential treatment in accordance with
Section 4(j) of the Communications Act, 47 U.S.C. § 154(j), and Sections 0.457(c)(1) and
0.459(b) of the Commission’s Rules, 47 C.F.R. §§ 0.457(c)(1), 0.459(b). Accordingly, the
enclosed submission is labeled “Confidential – Not for Public Inspection.”

Section 4(j) of the Communications Act provides, in part, that “The Commission is authorized to
withhold publication of records or proceedings containing secret information affecting the
national defense.” 47 U.S.C. § 154(j). Section 0.457(c)(1) of the Commission’s Rules allows
persons submitting materials that they wish withheld from public inspection in accordance with
Section 154(j) to file a request for non-disclosure. 47 C.F.R. § 0.457(c)(1). The requirements
governing such requests are set forth in Section 0.459(b) of the Commission’s rules.

This Submission is being made voluntarily. If any request for inspection is received by the
Commission and/or if this request for confidentiality should be denied, AT&T requests that the
Commission provide AT&T with the opportunity to request return of these materials to AT&T
without consideration, in accordance with Section 0.459(e) of the Commission’s rules.

In accordance with Section 0.459(b) of the Commission’s Rules, this request is supported by the
following showing:

1.        Identification of the specific information for which confidential treatment is sought:

AT&T seeks to maintain confidentiality of the Narrative Attachment to application file number
0002-EX-ST-2019, including the appendix labeled APPENDIX ANTENNA SITE

\\bnasuserfile01\userdata$\profiles\ml37714\Desktop\AT&T\010319 Request for Confidentiality.doc


INFORMATION and marked “Confidential – Not for Public Inspection” (collectively “the
Confidential Submission”).

2.        Identification of the Commission proceeding in which the information was
          submitted or a description of the circumstances giving rise to the submission:

The Confidential Submission is being submitted in connection with an experimental license
application (0002-EX-ST-2019) submitted by AT&T Services, Inc.

3.        Explanation of the degree to which the information is commercial or financial, or
          contains a trade secret or is privileged:

The Confidential Submission contains information that, if disclosed, would raise significant
threats to national security.

4.        Explanation of the degree to which the information concerns a service that is subject
          to competition:

The confidential information concerns a service that is subject to competition.

5.        Explanation of how disclosure of the information could result in substantial
          competitive harm:

As noted above, the Confidential Submission contains information affecting the national defense.
Disclosure of the confidential information could result in harm to national security of the United
States.

6.        Identification of any measures taken by the submitting party to prevent
          unauthorized disclosure:

AT&T keeps this kind of sensitive national security information confidential and does not make
it publicly available.

7.        Identification of whether the information is available to the public and the extent of
          any previous disclosure of the information to third parties:

As described above, none of the information in the Confidential Submission for which AT&T
seeks confidential treatment has been provided to the public.

8.        Justification of the period during which the submitting party asserts that material
          should not be available for public disclosure:

AT&T respectfully requests that the Commission withhold the Confidential Submission from
public inspection indefinitely. AT&T would not, in the normal course of business, provide this
information to the public.




\\bnasuserfile01\userdata$\profiles\ml37714\Desktop\AT&T\010319 Request for Confidentiality.doc


If you should have any questions or need further information, please contact the undersigned
counsel for AT&T.

Respectfully submitted,

/s/ Michael P. Goggin

Michael P. Goggin
AT&T Services, Inc.



Enclosures
cc:




\\bnasuserfile01\userdata$\profiles\ml37714\Desktop\AT&T\010319 Request for Confidentiality.doc



Document Created: 2019-01-03 11:37:32
Document Modified: 2019-01-03 11:37:32

© 2025 FCC.report
This site is not affiliated with or endorsed by the FCC