Network Management Policy

COMPLIANCE STATEMENT AND DISCLOSURES FOR FCC “TRANSPARENCY RULE”

LigTel Communications, Inc. (the “Company”) provides this information in its good faith effort to comply with the disclosures required by the Federal Communications Commission

(“FCC”) revised “transparency” rule effective on June 11, 2018. In this regard, we endeavor through these disclosures to provide consumers with information necessary for them to make informed choices about the purchase and use of the Company’s broadband Internet access service (the “Company’s Service”).

To place our compliance efforts in context, the FCC transparency rule states as follows:

• Any person providing broadband Internet access service shall publicly disclose accurate information regarding the network management practices, performance characteristics, and commercial terms of its broadband Internet access services sufficient to enable consumers to make informed choices regarding the purchase and use of such services and entrepreneurs and other small businesses to develop, market, and maintain Internet offerings. Such disclosure shall be made via a publicly available, easily accessible website or through transmittal to the Commission.

• Broadband internet access service is a mass-market retail service by wire or radio that provides the capability to transmit data to and receive data from all or substantially all Internet endpoints, including any capabilities that are incidental to and enable the operation of the communications service, but excluding dial-up Internet access service. This term also encompasses any service that the Commission finds to be providing a functional equivalent of the service described in the previous sentence or that is used to evade the protections set forth in this part. 83 Fed. Reg. 7852, 7922 (Feb. 22, 2018) to be codified at 47 C.F.R. §8.1(b).

• A network management practice is reasonable if it is appropriate and tailored to achieving a legitimate network management purpose, taking into account the particular network architecture and technology of the broadband Internet access service. 83 Fed. Reg. 7852, 7922 (Feb. 22, 2018) to be codified at 47 C.F.R. §8.1(c).

The Company reserves the right to update and modify these disclosures and the underlying policies, in a manner consistent with the FCC’s directives, including by way of example the Company’s terms and conditions, network management practices and performance characteristics. To the extent such changes are made they will be reflected in the links provided below.

COMMERICAL TERMS

The rates, terms and conditions associated with the Company’s Service, including by way of example only, early termination and/or additional network service fees, can be accessed via the following link

• Rates: https://www.ligtel.com/home-services/internet
  • Subscriber Agreement: https://www.ligtel.com/legal/subscriber-agreement/
  • Notice of Copyright Infringement Policy: https://www.ligtel.com/legal/notice-of-copyright-infringement-policy/

When changes are made to the rates, terms and conditions of the Company’s Service, we will post them on our website using the link referenced above.

The Company’s “Privacy Policies” can be accessed via the following link: https://www.ligtel.com/legal/privacy-policy/

If you believe that the Company’s Service is not meeting the rates, terms and conditions applicable to what you have ordered, please feel free to contact us so that we can address your concern:

Via Telephone :          (260) 894-7161

CSRs available 8 am – 4:30 pm M-F (Calls forwarded to Off-Hour service anytime a CSR is unavailable.)

Via Email :                  [email protected]

Via Mail :                    414 S Cavin St. Ligonier, IN 46767

We strongly encourage you to contact us in order to discuss your concerns. If based on those discussions there is some remedial action necessary, we can work together to implement it.



NETWORK MANAGEMENT PRACTICES

In offering the Company’s Service, the Company recognizes that, at times, network issues will arise and, during those times, the Company will undertake actions that are appropriate and tailored to achieving a legitimate network management purpose. The Company notes specifically, the following network management practices.

Please note that each of the statements below are subject to the Company’s “permitted use” policy available at the following link: https://www.ligtel.com/legal/acceptable-use-policy/

Blocking. The Company does not block or otherwise prevent end user customer access to lawful content, applications, service, or non-harmful devices. Additionally, the Company does not block users from accessing lawful web sites, subject to our reasonable network management practices nor does the Company block applications that may compete with either the Company’s or one of its affiliate’s voice service products, subject again to our reasonable network management practices.

Throttling. Except where network congestion may occur, the Company strives to avoid any degradation or impairment of access to lawful Internet traffic on the basis of content, application, service, user, or use of a non-harmful device. Where service congestion

occurs, the Company Service’s speed may be temporarily reduced.

Affiliated Prioritization. The Company does not engage in any practice that directly or indirectly favors any of its affiliates’ traffic over other traffic.

Paid Prioritization. The Company does not engage in any practice that directly or indirectly favors some traffic over other traffic in exchange for consideration, monetary or otherwise.

Congestion Management. Should congestion due to malfunctioning hardware and/or software occur, the Company will undertake reasonable efforts to remedy that congestion. At the same time, should such congestion occur as a result of a violation of our Acceptable Use Policy, the Company reserves the right to take all necessary actions to remedy such violations as stated in our Acceptable Use Policy. The Company’s network does not have any other existing congestion management practices. The network runs FIFO (first in, first out) best effort.

Application-Specific Behavior. The Company does not block or rate-control specific protocols or protocol ports.

Device Attachment Rules. Provided that an attachment does not cause network harm, including by way of example, interference with the Company’s network security measures, the Company does not restrict the types of devices that its end user customers may use and attach to the Company’s network nor does it have any approval procedures for devices to connect to the Company’s network.

Security. The Company has access control lists (ACLs) in place to protect its internal ISP transport network. In the event of Denial of Service (DoS), Distributed Denial of Service (DDoS) attack, spoofing or other malicious traffic, the Company will implement inbound and outbound traffic filtering and/or blocking on specific source and destination IP addresses. These actions will be performed to ensure reliability and availability of the Company’s network. These actions will not be utilized for normal Internet applications and traffic. In the case of any suspicious or malicious network activity, notification and forensic information will be made available to the appropriate law enforcement and network security resources for investigation.

The Company monitors the operability and security of its network. End customers are encouraged and responsible to protect their own home and business networks, including but not limited, to firewall, virus protection and securing internal wifi connections. If an end-user is unlawfully compromising the integrity of the Company’s network, they may be disconnected and notified. The Company will work with end-users on legitimate special applications that otherwise change normal security measures taken in the provisioning of the network for normal end users.

PERFORMANCE

Service Description. Descriptions of the Company’s Service, including (1) the service technology; (2) expected and actual access speed and latency; and (3) the suitability of the service for real-time applications.

Service Description

The Company provides internet services using multiple technologies on based on availability at a subscriber’s service location using the following technology:

1. Fiber High Speed Service technology that uses fiber optic cable.

Expected and Actual Transmission Speed

Based upon internal testing conducted by LigTel, the actual expected performance for LigTel’s service offerings are reasonably expected to be as follows:

This information is based upon the mean upload and download speeds in megabits per second during the “busy hour” between 6:00 p.m. and 11:00 p.m. on weeknights

Expected and Actual Latency

Based upon internal testing LigTel, the actual expected performance for LigTel’s service offerings are reasonably expected to be as follows:

This information is based upon the mean round trip latency during the “busy hour” between 6:00 p.m. and 11:00 p.m. on weeknights.

Suitability for Real-Time Applications

All of the Company’s Internet service offerings can be used for real time applications. However, performance of those applications may improve at higher transmission speeds.

1. Impact of Non-Broadband Internet Access Service Data Services. The Company’s Service does not currently include any non-broadband Internet access service data services.