22nd February, 2017

-R"'': C EIV. E.-IDate' a~~1] .

0UB'Ue uilitlEs COMMISSION

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DigicelGuyana's Bigger, Better Network.

Mr. Vidiahar PersaudSecretaryPublic Utilities Commission106 New Garden StreetQueenstownGeorgetown

U·MOBILE (CELLULAR) INC.56 High Street, Kingston,

Georgetown, Guyana, S.ATel: + (592) 690-0000Fax: + (592) 223-6532

www.digicelguyana.com

Dear Mr. Persaud,

Re: Anti-Competitive Promotions by GT &T

We write in relation to the matter at caption.

Reference is made to our letter to the Commission dated the 28th day of September, 2015 in which~.' --

a request was made for a formal hearing to address the consistent blatant disregard by GTT forsrheretail international rates set by the PUC and the Commissions letter~~!~~?4~h June, 2015.

In today's edition of the Chronicle, Stabroek, Guyana Times and the Kaieteur Newspapers, GTTaiaIni~ok out full page Ads to display its promotion "GET MORE PAY LESS". This promotionpromises to provide all of its customers with "MORE DATA, MINUTES AND TEXT FOR LESS"which they can utilize to make all calls to the USA and Canada ..,The advertised offer and rates are captured in the table below:

Pla'ns~;'~:Co~~':' , •~.•t'~-r;~":b >; '<"~1r"~;-",~' ~. ~ ",.,,~= ..-,"" -"'~""'~~~~~ ~-.' ~":{

~ "~. j "-"',,.. " ' M_I!J~~~~': D~!~~~i:".:,Text .- Cost Vat ~)(,lfV!"e~.Sg~~R~~~.~I),~I~J:Daily+ $449 15 200MB 30 $393.86 ,.- ..e ~ '" •. ' $26.2613Days $749 25 500MB 50 $657.02 $26.28,Weekly $1.499 40 1000MB 80 $1,314.91 $32.87i

$3,499 $3,069.30;Monthly 100 3000MB 200 $30.69iMonthly+ $5,199 150 4200MB 250 $4,560.53 ~ -, - - . $30.40

In the last two columns i~e were!o mak~the assumptionthl~t ~u~tomers onlYuse the bun.2!e fgroverseas calls to Canada and USA then their call rate will be between $26.26 and $30.40. This is.....,!~ •.•• --

significantly below the PUC set retail rates of $100 ($90 off peak) and $134.50 ($94.15 off peak)for the USA and Canada respectively.

At present GTT gives Digicel a discount on these PUC set retail rates which on average is 35%.Therefore Digicel's cost per minute would be in the region of $65 ($58.50 off peak) and $87.42($61.20)

This promotion is clearly anti-competitive since GTT, which still holds a monopoly in the marketfor international services in Guyana, is providing Digicel with a wholesale rate which is

considerably in excess of the hi hest £ossible ,retaill1!lk~]J-::~.oll1~Es ~ould 2Y' Logically wewould expect GTT's customers to utilize the data and SMS allowance thus significantly loweringthe cost of the international call below our estimate above.

In this case the Commission is again directed to consider its own letter to GTT dated March 26,2014, a copy which is enclosed, in which the Commission directed that these internationaloutbound rates be extended to Digicel to neutralize the anti-competitive nature ofthe promotion.

In light of our previous complainants of "Anti-Competitive Behavior by GTT" to the PUCby letters dated the 19th June, 2015, the 30th July, 2015 and the 28th September, 2015respectively, copies of which are enclosed, which the PUC choose not to impose no effectiveresolution. Digicel respectfully renews its call for GTT to be ordered immediately to ceasethis and any future promotions until the hearing and determination of this complaint.

Alternativel we request that the Commission makes an order forthwith that all present and futurepromotions concerning international rates, be extended by GTT to Digicel to be offered as part ofour bundled minutes to our Customers. l

Therefore, given the urgency of the issues raised herein, we would appreciate a timely response toour objections and recommendations.

As ever, Digicel shall make itself available to provide any additional information or clarification

that the, Commission might require in its consideration of this matter.

Yours sincerely,

c

Kevin Kelly

Chief Executive Officer

Copy: Mrs. Catherine Hughes

Honourable Minister of Telecommunications