July 25, 2016

Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554

Re: Written ex parte presentation in GN Docket Nos. 14-177, 13-5

Dear Ms. Dortch:

Congress has asked the Commission to make sure that networks serve the economic and social goals of the United States. Economically, to paraphrase Michael Porter of the Harvard Business School, the right economic policy is to act so as to improve the standard of living for all Americans. Socially, the goal is to permit all Americans the opportunity to express themselves, to associate with, and to receive information from all other Americans.

The Commission has pursued these goals through Democratic and Republican Administrations and Congresses with remarkable consistency. It has used a combination of competition policy, interconnection, and open access rulemaking in order to permit firms to invent new networks, compete with established networks, optimize existing networks. No other nation in the world can boast of a regulatory agency that has been so successful, and consistent in its policy goals.

Now the Commission faces the challenge and opportunity of helping to shape a new network -- a combination of digitization, phased array antenna breakthroughs, new forms of managing electromagnetic waves, signal processing on a finger nail sized chip, distributed data centers housing more information than any book-lined library, sensors and beacons operating on the bare suspicion of battery power, and many other inventions. This is what we call fifth generation or 5G.

Typically, the Commission has received from the laboratories of scientists and garages of entrepreneurs proposals concerning centralized networks. It has entertained visions of hundreds of satellites managed from a central point, or telephone networks with centralized signaling systems that direct traffic in optimal paths, or television networks that deliver the same programming to every household. But internet based networks are distributed. They operate not by central control but from one end point to another. Now that vision of decentralized, locally controlled management is about to be realized for wireless as never before. This is a big change between 4G and 5G.

The purpose of the slides enclosed herewith is to outline the difference between today's wireless network architecture and the possible architectures of 5G. The central difference is the change from one to many. Today's wireless architectures are not quite, but close to commodity services. They are more the same than different in every country, and in the hands of every competing service provider. The carrier manages them across their geographical regions with little variation in the service provided anywhere. They are designed primarily for people to communicate to people. This is shown on the first slide on the left.

Ms. Marlene S. Dortch July 25, 2016 Page 2

That same slide shows on the right hand side four different versions of 5G networks. These might be owned and operated by the carriers we know today. Indeed these firms may be the best at deploying 5G networks. But the network architectures of 5G will vary according to the uses of those networks. They will be versioned to specific ends. They will be nearly bespoke, suited to the needs of different end users. Like so many markets, the ability to learn about customers is now an essential feature of retailing, and translating that to network deployment we can see that homogeneous, one size fits all networks are the past. In the future every end use will get the network architecture optimally suited for it.

It is possible that a single firm will offer each of the four types of networks show in the slide. The backup slides to this first slide depict the types of services offered, and single firms may well be able to offer all of them. The four types might co-exist in the same geographic area. They could share common elements, such as macrocell base stations, or access to long-haul fiber. But even if there is one proprietor that firm will be offering at least the four types of networks show in the slide, if not more. The reason is that consumers will want high speed Internet access, businesses may privilege security and local control of data, a complex of health care facilities may attach great importance to sharing data among different treatment locations, and an airport may need to manage traffic and customers at the exact same time. These four types of networks need to provide different services. They need different architectures. The breakthroughs known collectively as 5G permit the individuation, and enable providers to profit by providing them. What's possible and valuable is what the Commission should enable to be delivered.

For the Commission the challenge is to determine how to apply a competition policy to this desirable business and technical future. Should licenses be designed for services? That has rarely been a good idea and is inconsistent with the spirit of the 1996 Act. Should multiple licenses be granted for the same geography? That's typical. But should they be as versioned and individualized as the networks, so that a certain geography might have a license for a wide area network and several licenses for very localized networks in that geographical space?

The purpose of this letter is not to answer such questions but to provide a schematic of possible network designs in order to make a contribution, however modest, to the important debate about the 5G future. This Commission is the thought leader among government agencies on a global basis in addressing 5G, but other nations are eager to move faster and farther. There's not a moment to lose in raising and answering the important questions.

Very truly yours, _/s/Reed Hundt_____ Reed Hundt

Networks of the Future Tomorrow’s Network: Need to serve diverse verticals :Mission critical IOT, MTC, Industrial as well as MBB Specific Network & Applications

Secure & Meeting Needs of Private Sectors/Verticals IT Centric + Connectivity Smart City/Communities

Heterogeneous small / macro cells Indoor and Outdoor Connectivity, presence Multi-Spectrum: 5G,Wifi, alternative

GE/Honeywell Network in a Box Managed by the Enterprise Indoor/outdoor connectivity

Airlines Segmented Network Specific local apps Licensed, Wifi, Small cell

Health

EPC Subscriber Mgmt/Charging

DC

• Dedicated, Static HW • Designed to serve mass

consumers • Designed mostly for

Mobile broadband • One network fits all

DC

BBU REGIONAL DC

Small Cell + edge computing RRH

BBU,MEC EPC, Regional DC

RRH

Small Cell + edge computing

Network in a Box + Regional DC

Health (Private Network as a Service) Segmented Network Specific local apps Indoor Connectivity, M2M presence Secure Private

Network in a Box, Regional DC

RRH

EPC=Evolve Packet Core

Network in a Box (BBU; Edge Computing, EPC)

RRH = Remote Radio Head

DC=Data Center

BBU=BaseBand Unit +edge computing

Today’s Public Network

Backhaul

Back Up

Networks of the Future Today’s Public Network General Purpose

Specific Network & Applications Secure & Meeting Needs of Private Sectors/Verticals IT Centric + Connectivity Smart City/Communities

Heterogeneous small / macro cells Indoor and Outdoor Connectivity, presence Multi-Spectrum: 5G,Wifi, alternative

GE/Honeywell Network in a Box Managed by the Enterprise Indoor/outdoor connectivity

Airlines Segmented Network Specific local apps Licensed, Wifi, Small cell

Health

EPC Subscriber Mgmt/Charging

DC

• Dedicated, Static HW • Designed to serve mass

consumers • One network fits all

DC EPC Subscriber Mgmt/Charging

DC

BBU REGIONAL DC

Small Cell + edge computing RRH

BBU,MEC EPC, Regional DC

RRH

Small Cell + edge computing

Network in a Box + Regional DC

Health (Private Network as a Service) Segmented Network Specific local apps Indoor Connectivity, M2M presence Secure Private

Network in a Box, Regional DC

RRH

EPC=Evolve Packet Core

Network in a Box (BBU; Edge Computing, EPC)

RRH = Remote Radio Head

Backhaul

Small Cell + edge computing

DC=Data Center

Small Cell

BBU=BaseBand Unit +edge computing

Invigorate Innovation & Standard of Living

Service Provider (Network Operator) Chooses Equipment Manufacturer (1 Or 2)

Machine to Machine Enterprise Driven Enterprises builds specific networks Solves Enterprise needs

N1 N2 N3 N4

S1 S2 S3 S4 S1 S2 S3 S4

S1 S2 S3 S4 S1 S2 S3 S4

… …

… Machine to X : Machine to Machine Machine to Person Machine to Enterprise Massively Connected Mobile Broadband Mission Critical IOT

Today: Homogeneous Network

2024: Heterogeneous Purpose Driven Network

Ex: Enterprises: GE, Auto Manufacturers, Airlines, Honeywell, Connected Healthcare, Real Time Gaming, Smart City

General Purpose Network

… … …

Rigid

ATT N (Network)

E/// Nokia Vz S/TMO

Invigorate Innovation, Raise Employment, Improve Quality of Life

Multiple Silicon choices

N# Network

S# Service/Slice

Network Slices

Transformation to Dynamic Network

L1

L1

L1 RAN RNL Mobility/Bearer RAN TNL MME HSS/PC RF

RAN RNL RAN TNL S-GW TNL P-GW App

NF Slice #1 (Wireless BB)

NF Slice #2 (Real time use cases e.g. Industrial Control)

RAN RNL Mobility/

Bearer HSS/PC RF L1

L1 App RAN RNL

RAN RNL GW L1 App

NF Slice #3 (IoT Sensor – Massive MTC)

RAN RNL L1 App

NF Slice #4 (Mobile Edge Cloud e.g. caching)

Dynamic Network Element Mapping

Mobile Edge Cloud

Flexible Definition

Diverse and Variable Processing

Requirements Dynamic Execution

Node

Network Slice

5

4G Architecture

• Dedicated, Static HW • Simple Policy/Profile • Vertical Silos

Many Industry; Diverse Use cases; Diverse network characteristics