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TNC 2011-77 - Response to Application for Costs - Quebecor

TNC 2011-77 - Response to Application for Costs - Quebecor

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Published by: Mark Goldberg on Sep 12, 2011
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09/12/2011

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612 St-Jacques Street, 15 Floor, South Tower Montreal, Quebec H3C 4M8

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Direct line : 514 380-4792 Fax: 514 380-4664 Email: dennis.beland@quebecor.com Internet: www.quebecor.com

12 September 2011

Mr. Robert A. Morin Secretary General Canadian Radio-television and Telecommunications Commission Ottawa, 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 of Quebecor Media Inc. (Quebecor Media), on behalf of Videotron G.P. (Videotron), to an application for costs by the Samuelson-Glushko Canadian Internet Policy and Public Interest Clinic (CIPPIC)

Dear Mr. Morin, 1. We are in receipt of the above-noted application for costs dated 01 September 2011. We are also in receipt of a response from Bell Aliant Regional Communications, Limited Partnership, Bell Canada and TELUS Communications Company (collectively, the Companies) dated 12 September 2011. In their response to CIPPIC’s application for costs, the Companies provide evidence that OpenMedia.ca, CIPPIC’s client for the TNC 2011-77 proceeding, conducted a public campaign to obtain financial support for the specific purpose of participating in the TNC 2011-77 proceeding and that the funding so obtained may well have exceeded the amount of CIPPIC’s application for costs. In these circumstances, and consistent with the Commission’s Guidelines for the Assessment of Costs, Quebecor Media submits that, at a minimum, CIPPIC must be directed to deduct from its application any amounts raised by OpenMedia.ca through its TNC 2011-77 fundraising campaign. Failing this, CIPPIC’s application for costs should be dismissed in its entirety.

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Trusting this is satisfactory, we remain, Yours truly,

Dennis Béland Senior Director, Regulatory Affairs Telecommunications

cc :

Parties to TNC 2011-77

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