Supplement to CoxCom

SUPPLEMENT submitted by CoxCom, LLC

Supplement to Trasnfer of Control Application

2013-09-18

This document pretains to ITC-T/C-20130906-00255 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2013090600255_1013094

                                     Before the
                      FEDERAL COMMUNICATIONS COMMISSION
                               Washington, D.C. 20554

In the Matter of                                     )
                                                     )
Applications of                                      )
                                                     )
EasyTel Communications Carrier Corporation           )
                                                     )
                  Licensee                           )
                                                     )
Timothy E. Kloehr                                    )
                                                     )             WC Docket No. 13-228
                  Transferor                         )
and                                                  )      File No. ITC-T/C-INTR2013-1948
                                                     )
CoxCom, LLC                                          )
                                                     )
                  Transferee.                        )
                                                     )
Joint Application for Consent to Transfer Control    )
of International and Domestic Authority Pursuant     )
to Section 214 of the Communications Act of          )
1934, as amended                                     )



     SUPPLEMENT TO JOINT APPLICATION FOR CONSENT TO TRANSFER
  INTERNATIONAL AND DOMESTIC AUTHORITY PURSUANT TO SECTION 214
          OF THE COMMUNICATIONS ACT OF 1934, AS AMENDED

       CoxCom, LLC (“Cox”), EasyTel Communications Carrier Corporation (“EasyTel”) and

Timothy E. Kloehr (collectively, the “Applicants”), by their attorneys, hereby submit the

following supplemental information at the request of the Commission staff and in connection

with the above-referenced application (the “Joint Application”).

Information on Competitors to Cox and EasyTel

       As described in the Joint Application, EasyTel provides telecommunications and cable

television services to business customers, principally in Tulsa, Oklahoma and nearby areas.


                                                -2-


EasyTel has no residential customers. In the business services market in the Tulsa area, Cox and

EasyTel each compete with incumbent local exchange carriers (“ILECs”), such as AT&T, along

with various well-established competitive local exchange carriers (“CLECs”) and other providers

of services to business customers. The following is a partial list of competitors to Cox and

EasyTel in the business market:

AT&T

         AT&T provides telecommunications services to consumers, businesses and other

providers across the United States, including the Tulsa metropolitan market. AT&T is the largest

provider of both mobile telephone and fixed telephony services in the United States. AT&T

generates approximately $127 billion in annual revenue and has more than 1,000 employees in

Tulsa.

Verizon Business

         Verizon Business is an operating division of Verizon, Inc. Verizon Business provides

Internet protocol (“IP”), data, voice and wireless services to businesses and federal government

agencies across the United States, including the Tulsa metropolitan market. In addition, Verizon

Business offers VoIP, Internet access, security, information technology solutions and hosting,

managed networks, premises equipment, contact centers and conferencing products. Verizon

generates approximately $118 billion in annual revenue and has more than 1,000 employees in

Tulsa.

Level 3 Communications

         Level 3 Communications provides local and long distance telephone services; core

network services, including transport services, private lines, transoceanic services and dark fiber,

as well as related professional services; and colocation and data center services, such as cloud,


                                               -3-


hosting and application management solutions. Level 3 Communications provides services to

business customers of all sizes across the United States, including the Tulsa metropolitan market.

Level 3 generates approximately $6.4 billion in annual revenue and has more than 500

employees in Tulsa.

Windstream Communications

       Windstream Communications provides local and long distance telephone, Internet, data

and managed services to businesses of all sizes across the United States, including the Tulsa

metropolitan market. Windstream generates approximately $6.1 billion in annual revenue.

tw telecom

       tw telecom provides local and long distance voice services, data networking, converged,

IP-based virtual private network and Internet access services to business customers across the

United States, including the Tulsa metropolitan market. tw telecom generates approximately

$1.5 billion in annual revenue.

Cogent Communications

       Cogent Communications provides high-speed Internet access and IP-based and non-IP

communications services primarily to small and medium-sized businesses, communications

service providers and other bandwidth-intensive organizations across the United States,

including the Tulsa metropolitan market. Cogent Communications generates approximately

$333 million in annual revenue.

Birch Communications

       Birch Communications provides IP-based communications and cloud services to small-

and medium-sized businesses across the United States, including the Tulsa metropolitan market.

Birch Communications generates approximately $150 million in annual revenue.


                                                -4-


Logix Communications

        Logix Communications provides telephone and Internet and data services to small and

medium-sized businesses located in Houston, San Antonio, Austin, Dallas, Ft. Worth, Oklahoma

City and Tulsa. Logix is privately held and does not publicly disclose its financial results.

Broadvox

        Broadvox provides integrated telephone, Internet and data services to small business,

medium-sized business, enterprise and carrier customers across the United States, including the

Tulsa metropolitan market. Broadvox is privately held and does not publicly disclose its

financial results.

Bixby Telephone Company/BTC Broadband

        BTC Broadband provides local telephone and long distance telephone, Internet and data

and cable television services to residential and business customers located in Tulsa and Bixby,

Oklahoma. Bixby Telephone Company is the ILEC serving Bixby, Oklahoma and its wholly-

owned operating division BTC Broadband is a CLEC serving the Tulsa metropolitan market.

Bixby Telephone Company is privately held and does not publicly disclose its financial results.

Other Competitors

        In addition to the competitors listed above, both Cox and EasyTel compete with a number

of providers that deliver integrated telecommunications services to customers via wireless

networks or via a cloud-based “over-the-top” delivery model. The wireless providers that serve

customers in the Tulsa metropolitan market include AT&T Wireless, Verizon Wireless, US

Cellular and T-Mobile. Competitors in the cloud-based “over-the-top” category include

Bandwidth.com, Inc., RingCentral, Inc., Vonage and 8x8, Inc.


                                             -5-


      Please inform the Applicants if any questions should arise in connection with this

submission.

                                           Respectfully submitted,

                                           CoxCom, LLC


                                           By:       /s/
                                                 J.G. Harrington

                                           Dow Lohnes, PLLC
                                           1200 New Hampshire Avenue, NW
                                           Suite 800
                                           Washington, DC 20036
                                           (202) 776-2818

                                           Counsel to CoxCom, LLC

                                           Timothy E. Kloehr
                                           EasyTel Communications Carrier Corporation

                                           By:        /s/
                                                 Jean L. Kiddoo
                                                 Brett P. Ferenchak
                                                 Bingham McCutchen LLP
                                                 2020 K Street, N.W.
                                                 Washington, DC 20006
                                                 (202) 373-6000
                                                 (202) 373-6001
                                                 jean.kiddoo@bingham.com
                                                 brett.ferenchak@bingham.com

                                           Counsel to Timothy E. Kloehr and
                                           EasyTel Communications Carrier Corporation

September 18, 2013



Document Created: 2013-09-18 12:02:32
Document Modified: 2013-09-18 12:02:32

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