Altice-Suddenlink FC

OTHER submitted by c/o Covington & Burling LLP

Letter

2016-04-26

This document pretains to ITC-T/C-20151014-00237 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2015101400237_1134766

                                                   April 26, 2016

By Electronic Filing

Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street SW
Washington, D.C. 20554

       Re:    WC Docket No. 15-135, File No. ITC-T/C-20151014-00237,
              Application of Altice N.V. and Cequel Corporation d/b/a Suddenlink
              Communications to Transfer Control of Authorizations from Suddenlink
              Communications to Altice

Dear Ms. Dortch:

               On April 20, 2016, the United States Department of Justice (“DoJ”) petitioned the
Commission to condition Altice N.V.’s (“Altice’s”) proposed acquisition of Cablevision Systems
Corporation (“Cablevision”) on the commitments and undertakings set forth in a Letter of
Agreement (“LOA”) dated April 18, 2016, and transmitted by Altice, Cablevision and Cequel
Corporation (“Cequel”) to the DoJ.1 That LOA incorporated by reference a National Security
Agreement (“NSA”), dated December 11, 2015, that was executed by and between Altice and
Cequel, on the one hand, and the DoJ, on the other hand, in connection with Altice’s acquisition
of 70 percent of the equity interest in Cequel. The Commission approved that acquisition on
December 18, 2015, subject to the terms of the NSA.2

                As signatories to the LOA, Altice and Suddenlink acknowledge that they are
bound by the commitments set forth therein. Altice and Suddenlink therefore respectfully
request that the Commission modify the sole condition set forth in the Altice/Suddenlink
Approval Order (compliance with the NSA) to include, in addition, compliance with the terms of
the LOA. Copies of both the LOA and NSA are attached hereto.

1
 See “Petition to Adopt Conditions to Authorizations and Licenses,” WC Docket No. 15-257,
File No. ITC-T/C-20151014-00237, filed April 20, 2016.
2
  See In re Application of Altice N.V. and Cequel Corporation d/b/a Suddenlink Communications
to Transfer Control of Authorizations from Suddenlink Communications to Altice, WC Docket
No. 15-135, File No. ITC-T/C-20151014-00237, Memorandum Opinion and Order, DA 15-
1451, rel. Dec. 18, 2015 (“Altice/Suddenlink Approval Order”).


Marlene H. Dortch, Secretary
April 26, 2016
Page 2


               Please direct any questions regarding this matter to the undersigned.

                                                    Respectfully submitted,

                                                    /s/

                                                    Yaron Dori
                                                    Counsel for Altice and Suddenlink

cc:    Kris Monteith, FCC
       Jody May, FCC
       Dennis Johnson, FCC
       David Krech, FCC



Document Created: 2016-04-26 13:43:11
Document Modified: 2016-04-26 13:43:11

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