Joshua M. BobeckDirect Phone: 202.373.6010Direct Fax: 202.373.6014Josh.bobeck@bingham.com

March 9, 2011

VIA ELECTRONIC FILING

Marlene H . Dortch, SecretaryFederal Communications Commission445 12th Street, S.W.Washington , DC 20554

Re: Notice of Ex Parte Meeting

Qwest Communications International , Inc. and CenturyTel, Inc. d/b/aCenturyLink, Application for Transfer of Control Under Section 214 of theCommunications Act, as Amended, WC Docket No. 10-110

A National Broadband Plan for Our Future, GN Docket No. 09-51

Fixed and Mobile Services in the Mobile Satellite Service Bands at 1525-1559MHz and 1626 .5-1660 .5 MHz, 1610-1626 .5 MHz 2483 .5-2500 MHz, and 2000-2020 MHz and 2180 -2200 MHz, ET Docket No. 10-142

Boston

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Bingham McCutchenLLP

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bingham.com

Dear Ms. Dortch:

On March 8, 2011, Neil L. Brodsky, Senior Corporate Counsel, GraniteTelecommunications, LLC and the undersigned, met with Commissioner MignonClyburn and her legal advisor, Louis Peraertz. Granite updated the attendees on itsprogress in serving the national multi location business market and addressed thefollowing policy matters.

First , Granite expressed concern regarding the pending Qwest/CenturyLink transactionand the post-merger wholesale local services market in the regions that the combinedcompany will serve. Granite currently has an agreement for Qwest' s wholesale localservices and obtains such services at discounted rates. In contrast , CenturyLink has todate refused to provide similar wholesale services to Granite in the CenturyTel footprint.In its petition to deny the merger application, Granite specifically requested that theCommission require Qwest/CenturyLink , as a direct and specific condition to its pendingmerger, to offer wholesale local services not only in the Qwest region but also in thelegacy CenturyLink territories as a condition of the merger.

Second , Granite observed that Qwest continues to discriminate in the provision ofwholesale services to Granite and other similarly situated CLECs by refusing to makeavailable wholesale voice service at locations where Qwest has replaced its copper loopswith fiber fed loops. Granite reiterated its belief that the merger would only be in thepublic interest if it were conditioned on, among others , a requirement that Qwest to offer

A/74016108.2

Marlene H. Dortch, SecretaryMarch 9, 2011Page 2

its wholesale voice service at any location where a customer could purchase retail voiceservices from Qwest, regardless of the underlying technology Qwest chose to provide theloop.

Third, Granite expressed concern that as its existing agreements with the Applicantsexpire, the Applicants will raise the prices pursuant to which Granite has been purchasingservice and/or reduce retail prices below the price for their wholesale offerings. Theseconcerns are exacerbated because there is no viable wholesale commercial alternative tothe Applicants' last mile facilities and the potential for entry of another source of lastmile access is unlikely for the foreseeable future. For these reasons, the Commissionshould require, as a condition of approval of the proposed merger, that the Applicantsoffer CLECs the option of continuing current commercial agreements in effect for the fullduration of the merger conditions, and ensure that Qwest's OSS and billing systemsremain in place for the duration of any such condition.

Finally, Granite discussed its current ability to obtain DSL services for resale on acompetitive basis from a number of ILECs with the notable exception of AT&T. Whileother ILECs allow competitors to provide their customers with DSL service over thesame line they purchase for voice service, AT&T requires Granite and other requestingcarriers to purchase a separate line, thereby artificially raising Granite's costs.

Sincerely,

/s/ electronically signed

Joshua M. Bobeck

cc (by e-mail):

Commissioner Mignon ClyburnLouis Peraertz

A/74016108.2

GranitePresentation to:

Wireline Competition Bureau Carol Simpson, Alexis Johns,

Bill Dever, Jennifer Prime Federal Communications Commission

March 8, 2011

Presented by: Neil L. Brodsky

A. Granite Background

B. Web Based Middleware/National SupportI. North American Voice Management

II. Structured Cabling and Systems

III. Broadband Solutions

IV. Security and Fire Alarm Systems

C. ReferencesI. City

II. Industry

Granite Overview

Background• Granite’s 8 year history has seen explosive growth, 2010 revenues exceed

$550 million.

• Headquartered in Boston, MA with offices throughout America, our debt free and profitable company, with no outside investors, is one of the fastest growing companies in the country, and employees 900 teammates.

Recent Recognition• Ernst & Young Entrepreneur of the Year (2010)• BBJ Top 20 Charitable Contributor of the Year in Massachusetts

(2009, 2010)• Inc. 500/5000 Top 10 in Revenue/ Fastest Growing Private

Companies (2007, 2008, 2009, 2010)• BBJ Top 20 in Revenue with Private Companies in Massachusetts

(2009, 2010) • BBJ Top 20 Fastest Growing Private Companies in Massachusetts

(2006, 2007, 2008, 2009, 2010)

National and Product Support

NationalBilling: Single customized file, compatible with Oracle, JP Edwards, SAP, and countless othersSupport: Single National Account Team for entire country.Pricing: Single National Rate

ProductVoice: Local, Long distance, Analog, and Dedicated linesBroadband: DSL, Broadband, and T-1Alarm Monitoring Service: Fire and BurglarCabling Support: New Builds, Remodels, Roll Outs, and Voice Systems

Background Last 8 Years

Mill

ion

2010 Quarterly Cabling Revenue Growth

Mill

ion

*4.5 of America’s Business

lines

North American Voice Consolidation

• The nation’s largest distributor of Bell company analog services.

• North American consolidation of support and savings.

• Over 1,000,000 analog business lines under management.***Only competitor to ever have 1,000,000***

• Customers include all 10 of America’s 10 largest companies and 66 of the Fortune 100.

• Electronically bonded to 14 of the largest local carriers.

Structured Cabling and Systems

• Structured Cabling Installations: Design and installation of voice, data and video cabling for commercial and retail customers nationwide.

• Moves, adds, changes and repairs on existing cabling systems.

• Installation and maintenance of Avaya and Nortel phone systems.

• Rapid deployment of national rolls.

• Milestone - Online Project Management Tool.

• Partners - Avaya, Nortel, Samsung, Talk Switch, Leviton, Mohawk, Cisco, Shoretel, Systimax, and Novar.

Broadband Solutions

• Nationwide Broadband Service (30,000 lines installed)

• DSL, Cable, Wireless and Satellite

• One point of contact for ordering provisioning and management

• Scalable solutions

• 24/7/365 Broadband support

• Single consolidated invoice

Security & Fire Alarm Systems

• SECURITY ALARM MONITORING AND MAINTENANCE• Burglar alarm system monitoring • Back-up monitoring services utilizing cellular and long range radio service• Web access to manage and track account data

• FIRE ALARM SYSTEM MONITORING AND MAINTENANCE• Fire alarm service and monitoring• Water-flow/sprinkler monitoring • Fire extinguishers and suppression systems • Special hazard/clean agent systems

• ACCESS CONTROL SYSTEM SERVICES• Web-based, multi-site access control solutions • PC-based, small to mid-sized solutions • Biometric readers, eliminating the need for card management

• CCTV SYSTEMS• Digital video recording and storage • Remote video CCTV monitoring • Security video CCTV cameras

• Product s and Associations: Honeywell, GE, UTC Fire & Security, DSC, NFPA,ESA, and CSAA

References

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References

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References

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