612 St-Jacques Street, 15
Floor, South TowerMontreal, Quebec H3C 4M8Direct line : 514 380-4792Fax: 514 380-4664Email: firstname.lastname@example.orgInternet: www.quebecor.com
12 September 2011Mr. Robert A. MorinSecretary GeneralCanadian Radio-television andTelecommunications CommissionOttawa, ON K1A 0N2
RE : Telecom Notice of Consultation CRTC 2011-77,
Review of usage-based billing for wholesale residential high-speed access services
(TNC 2011-77) – Response ofQuebecor Media Inc. (Quebecor Media), on behalf of Videotron G.P. (Videotron), toan application for costs by the Samuelson-Glushko Canadian Internet Policy andPublic Interest Clinic (CIPPIC)
Dear Mr. Morin,1. We are in receipt of the above-noted application for costs dated 01 September 2011. Weare also in receipt of a response from Bell Aliant Regional Communications, LimitedPartnership, Bell Canada and TELUS Communications Company (collectively, theCompanies) dated 12 September 2011.2. In their response to CIPPIC’s application for costs, the Companies provide evidence thatOpenMedia.ca, CIPPIC’s client for the TNC 2011-77 proceeding, conducted a publiccampaign to obtain financial support for the specific purpose of participating in the TNC2011-77 proceeding and that the funding so obtained may well have exceeded the amountof CIPPIC’s application for costs.3. In these circumstances, and consistent with the Commission’s Guidelines for theAssessment of Costs, Quebecor Media submits that, at a minimum, CIPPIC must bedirected to deduct from its application any amounts raised by OpenMedia.ca through itsTNC 2011-77 fundraising campaign. Failing this, CIPPIC’s application for costs should bedismissed in its entirety.