TRADE SECRET DATA REDACTED

 

Appendix

 

1.               Qwest described the extent of its UNE-P services in Minnesota as follows:

As of November 30, 2001, Qwest provides 80,847 UNE-P combinations to 11 CLECs in Minnesota. This includes 32,392 UNE-P-POTS combinations; 47,318 UNE-P-Centrex combinations; 1,135 UNE-P DSS combinations; and 2 UNE-P ISDN combination services.[1]

2.               Qwest did not indicate that it was including its UNE-Star product in the totals of UNE-P afforded to CLECS.  When the numbers of lines are broken out by category, the totals are:

*** BEGIN TRADE SECRET

 

 

 

 

 

 

[2]

END TRADE SECRET ***

3.               As the line counts show, fully *** BEGIN TRADE SECRET                                  END TRADE SECRET ***     of  Qwest’s claimed competition through UNE-P is actually provided though UNE-Star (which is essentially a resale product).  Of even greater concern, *** BEGIN TRADE SECRET                   END TRADE SECRET ***     of  the competition in UNE-P Centrex is actually accomplished through UNE-Star.  These numbers demonstrate that, as of November 30, 2001, the level of competition using UNE-P is far below the levels that Qwest is claiming. 



[1] Ex. 127 (Simpson Direct re: Item 2), p. 6.

[2] Trade Secret Ex. 32 (Lundquist), at 27.