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( \ ) Federal Communications CommissionWashington, D.C. 20554
August 26, 2011
Via First Class Mail and Electronic Mail
Richard L. Rosen, Esquire
Arnold & Porter, LLP
12th Street, NW
Washington, DC 20004
Re: Applications of AT&T Inc. and Deutsche Telekom AG for Consent to Assign or
Transfer Control of License and Authorizations, WTB Docket No. 11-65
Dear Mr. Rosen:
By letter dated July 20, 2011, the Wireless Telecommunications Bureau ("Bureau") advised you
that it was stopping the Commission's informal 180-day clock in view of AT&T's announcement that it
had developed and would be submitting new models to bolster its arguments concerning the size of the
efficiencies made possible by the merger as weighed against the potential anti-competitive effects. We
iiidicated that we would restart the informal clock when AT&T submitted the new evidence in a format
and with sufficient explanation and back-up information to enable us, and third parties entitled to have
access to the information, to evaluate it.
Since our original correspondence, AT&T has submitted the models and subsequently updated
one of them. We have had several meetings with AT&T regarding the models and have posed a number
of detailed questions concerning their construction and the assumptions they contain. In particular, on
August II, 2011, we sent AT&T a list of questions seeking further clarification. We also discussed with
AT&T that the Bureau would restart the informal clock once AT&T submitted responses to our questions
and AT&T was comfortable that the Commission's record contained AT&T's full explanation of the
models.
We have now received AT&T's answers to our specific questions as well as AT&T's
confirmation that it believes our record is complete with respect to the models. Our understanding is that,
unless specifically prompted by a request from the Commission or the Department of Justice, AT&T will
not be submitting any further revisions to the models. Based on this understanding, we are restarting the
informal clock effective today. As such, today, August 26, 2011, is Day 83 under the time clock.
Sincerely,
Rtck Kaplan
Chief, Wireless Telecommunications Bureau