Page:2020-06-09 PSI Staff Report - Threats to U.S. Communications Networks.pdf/74

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and AT&T.[1] These relationships primarily include the provision of network or other retail services.[2] Verizon maintains an interconnection agreement and peering arrangement with CTA, as well as separate agreements with its Chinese parent companies.[3] Although CenturyLink does not maintain any formal partnership or arrangement with CTA, it does have a limited commercial relationship with the company.[4] CenturyLink did not specify the nature of its commercial relationship with CTA; rather, it generally described the relationship as involving the sale of network services, circuits, or collocation services.[5] These services allow CTA to deliver traffic from a CTA point of presence through CenturyLink's network to a CTA customer located in the United States.[6]

AT&T sells CTA voice and data transport services, which CTA uses to provide services to its customers in the United States.[7] 410 AT&T has also established relationships with China Telecom. The two companies maintain a free-of-charge peering arrangement.[8] Further, the companies established a joint venture Shanghai Symphony Telecommunications-in 2001.[9] While China. Telecom is the majority stakeholder, AT&T owns a 25 percent stake in the venture.[10] The joint venture only provides services within the Pudong district of Shanghai; however, it has separately entered into contractual agreements with China Telecom, China Unicom, and China Mobile to provide VPN and other IP-based services throughout China.[11] The joint venture is set to expire in 2039.[12] Neither Verizon, AT&T, nor CenturyLink maintains any mitigation or other agreement focused on network security with CTA or its parent company.[13] The


  1. Briefing with Verizon (Sept. 4, 2019); Briefing with CenturyLink (Sept. 10, 2019); Briefing with AT&T (Sept. 17, 2019).
  2. Briefing with Verizon (Sept. 4, 2019); Briefing with CenturyLink (Sept. 10, 2019); Briefing with AT&T (Sept. 17, 2019).
  3. Briefing with Verizon (Sept. 4, 2019).
  4. Briefing with CenturyLink (Sept. 10, 2019).
  5. Id.
  6. Id. CenturyLink purchases the same network services from Chinese carriers in China, to allow CenturyLink to deliver traffic to a CenturyLink customer based in China. Id.
  7. Briefing with AT&T (Sept. 17, 2019). AT&T representatives told the Subcommittee that the revenue generated by these agreements is relatively small, particularly when compared to similar agreements with other large international carriers. For example, similar arrangements with other large international carriers generate up to 36 to 62 times as much revenue as arrangements with the Chinese state-owned carriers discussed in this report. Id.; Email from Gibson, Dunn & Crutcher LLP, counsel to AT&T, to the Subcommittee (June 2, 2020) (on file with the Subcommittee).
  8. Briefing with AT&T (Sept. 17, 2019). AT&T described the peering arrangement as "among the smallest . . . in terms of network capacity that AT&T maintains" with foreign carriers. Id.
  9. Id.
  10. Id.
  11. Teleconference with Gibson, Dunn & Crutcher LLP, counsel to AT&T (Oct. 15, 2019).
  12. Email from Gibson, Dunn & Crutcher LLP, counsel to AT&T, to the Subcommittee (June 2, 2020) (on file with the Subcommittee).
  13. See Briefing with Verizon (Sept. 4, 2019); Briefing with CenturyLink (Sept. 10, 2019); Briefing with AT&T (Sept. 17, 2019).

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