- CoviNGTON & BuRLING LLP 1:101 PENNSYLVANIA AVENUE NW

WASHINGTON, OC :10004-:1401

TEL :102.66:1.6000

FAX 202.662.6291

WWW.COV.COM

Ms. Marlene Dortch Secretary

BEIJING 8RUSSEl.S LONDON NEWYO~I(

SAN DIEGO SAN FRANCISCO SILICON VALLBY WASHINGTON

Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554

GERARD J. WALDRON

TEL 202.662.5360

GWALORON 0 COV.COM

June 6, 2014

Re: Modernizing the £-Rate Program (WC No. 13-184) -- Ex parte meeting

Dear Ms. Dortch:

On June 4, 2014, Hewlett-Packard Company (HP) met with Commission staff to discuss E-rate reform proposals in the above-referenced docket. HP was represented by undersigned counsel and by Greg Herbold, HP Director, US SLED Programs; Nancy Schwarz, HP Networking Program Manager- Education; Tom Williams, Software Defined Networking (SON) Strategy & Deployment, HP Networking; and Deborah Krabbendam, Esquire of Conrad O'Brien, P.C. Commission staff attending the meeting included Michael Steffen, Office of Managing Director; Lisa Hone, Bryan Boyle, Soumitra Das, Kate Dumouchel, Charles Eberle and James Bachtell with the Wireline Competition Bureau, and Nick Alexander, Office of Strategic Planning and Policy Analysis.

First, HP reiterated its support for the Commission's E-rate Modernization efforts and, in particular, its commitment to fund internal connections. As the Commission has recognized, "the deployment of equipment inside school and library facilities is as essential to comprehensive broadband service at a given location as the high-speed connectivity to that facility." Public Notice,~ 6. Considerations that should drive reform are outlined in HP's comments filed in response to the Commission's Public Notice, and include the need to give at least equal priority to internal connections; provide flexibility, predictability and equitable funding to applicants; focus on technologies that will meet applicants' needs cost-effectively into the future (in Chairman Wheeler's words, "future-proof!)" the program); and streamline program administration and avoid introducing new complexities.

Second, HP shared information about networking technologies- specifically, unified wired/wireless networks and Software Defined Networking (SON) - that are available to schools and libraries now and provide significant advances in flexibility, scalability and long-term cost effectiveness. A copy of HP's presentation slides is attached. Supporting these technologies through E-rate would further the Commission's goal of"future proofing" the program.

DC: 5356250-1

C 0 VI N G T 0 N & 8 U R L I N G LLP Ms. Marlene Dortch June 6, 2014 - 2 -

Third, HP asked the Commission to clarify the E-rate gift and competitive bidding rules. Clarification of the rules with respect to legitimate research, development and marketing activities would assist schools and libraries in making informed decisions and choosing cost-effective solutions that meet their individualized needs, and would thereby further the Commission's desire to "encourage public-private partnerships to promote our proposed E-rate goals." Clarification of the rules with respect to charitable donations would "allow schools and libraries to take greater advantage of private philanthropy while still allowing the Commission to maintain appropriate control over E-rate expenditures and to prevent improper influence over E-rate service provider selections." Consistent with its filed NPRM comments, HP asks the Commission to:

1. Clarify the factors which would lead it to conclude that a charitable donation was inappropriate and consider adopting safeguards for donors and recipients.

2. Modify theE-rate gift rule to distinguish between gifts to individuals and gifts to entities, and, for gifts to entities, adopt a procedure and conditions similar to those the Commission has adopted to govern its own receipt of gifts from regulated entities (see 47 C.F.R. § 1.3000 et seq. (regulations applying to "gifts, donations and bequests made to the Commission itself')).

3. Establish a procedure and conditions to allow service providers to work withE-rate eligible entities to assess and meet their technology needs without violating the rules of fair and open competition.

HP also wants to use this opportunity to make two additional points. Fir:st, the Commission should explicitly identify Software Defined Network components as E-rate eligible. As demonstrated in detail in the presentation to the staff, SON offers E-rate recipients tremendous cost savings, flexibility, and the capability to extend the life of previously purchased components. Consequently, the Commission should give schools and libraries the flexibility to spend smarter and more efficiently by purchasing SON components. Second, the Commission should look closely at the timing for filing Form 470s. We urge the Commission to direct USAC not to open the Form 470 filing window until the details of program reform are set, since the Form 470 contains the criteria of the current program. It is HP's opinion that briefly delaying the usual timing of Form 470s until the rules and eligibility criteria are known will avoid uncertainty for program participants and for USAC, and is strongly preferable to issuing the forms in the next month with the changes not yet in place.

Cov iN GT ON & BuRL I NG LLP

Ms. Marlene Dortch Junc6, 2014

.., - .) -

Please direct any questions to the undersigned.

cc: Mr. Nick Alexander Mr. James Bachtell Mr. Bryan Boyle Mr. Soumitra Das Ms. Kate Dumouchel Mr. Chas Eberle Ms. Lisa Hone Mr. Michael Steffen

Attachment -- HP PowerPoint Presentation

Sincerely, ~

= lf;'L"! Counsel to Hew/eft -Packard

·-

Legacy networks unable to meet today's demands

Network is not aligned to the requirements of schools

2 ©Copyright 2013 Hewlett-Packard Development Company. L.P. The information contained herein IS subject to change without not1ce fiJi

Separate Wired & Wireless Architectures & Networks Legacy wireless deployment model

Wired Network

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k~ ..

Desktops

Access switch

Core switch

Wired Network .,. Management -= Appl ication( s)

Wireless Network

0 0 0 Mobile devices

~~ -

Access points

WLAN controller

Core switch

Wireless Network

Management App lication(s)

3 Q Copynght 2013 Hewlett-Packard Development Company, LP The information contained herein is subject to change without notice

Unified Wired-Wireless access revolutionizes networks

Unified Wired-Wireless Network

DO (( T )) I (( T ))

~ -

Desktop & Mobile

devices

Access points

Unified Wired-WLAN Switch Infrastructure

Integ rated Security

-Access Control and IPS

Single-pane-of glass

management

Enhanced scalability and performance • Comprehensive, unified portfolio of high-performing

wired and wireless access solutions

Unified access • Single pane-of-glass management from edge to core

Optimized connectivity • 1- and 2-tier networks reduce latency and increase

resiliency

• Optimized WLAN architecture reduces latency & traffic bottlenecks

Robust security • Industry-leading research powers best-in-class threat

protection

• Comprehensive identity management and endpoint security

4 ©Copyright 2013 Hewlett-Packard Development Company, l P The information contained herein JS subject to change without notice (I1J

Embrace SON -the Future of Networking is Here

0 Copyright 2013 Hewlett-Packard Development Company, L.P. The mformation contained herein 1s subject to change without notice.

SDN -A New Style of Network Control Customer-Focused & Market Right-Sizing

Network features (apphcauons)

Open interfaces and progranvnm~ lan~uages

Standard onterfaces and control protocols

... --:...----:;

• Protectionist Business Model • Market Driven Business Model • Vendor-Chosen lnteroperability • Standards-Compliant lnteroperability • All-ln-One Compromise • Best-of-Breed & Value Innovation • Normalize" Pools of Excellence" • Vendor Selection Based Upon Capability • Loss of Customer Leverage • Cust0mer-Driven Requirements with Market Pricing

6 ©Copyright 2013 Hewlett·Packard DevP.Iopment Company, L P. The information contained herein is subject to change wtthout notice fJj)

Open Network Forum- Open Ecosystem ... Delivered

Board Members 120+ Vendors To Date

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• Microsoft

. rl' "ed CiTRIX

Thonk fast. •

NTT (MWTIUtlJC.JIIOm

Goldman SaChs

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vmware·

Go ogle

YAHOO!

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Quali systems

Th~ NetwO>rk '' lnformdrion

. RMIT UNIVERSITY pwc

Tech mahindra EC()DE

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7 CCopyright 2013 Hewlett-Packard Development Company, L.P. The information containt.'

SDN- A New Style of Procurement & Operation

Network features (applications)

Open interfaces and programming languages

: Standard interfaces and control protocols

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• Cost Alignment

• Consortium/Aggregate Buying

• Market Innovation

• Wh ite Labeling

• Multi-Use & Repurposing

• CapEx and OpEx Scalabilities

ll ~Copyright 2013 Hewlett-Packard Development Company. L P. The information contained herein IS subject to change without not1ce (/tJ

SDN Stoplight Theory & Flow Concepts

• Single Intersection Programming = Single Network Element Programming

• More Efficiencies Gained with E911 Integration

• Types of Emergency Vehicle= Classes of Applications & Services

• Dynamic Reconfiguration of Throughput based upon Real-time Traffic

• Overlay vs Rip-and-Replace

• District-wide Policy via" Instances"

• Minimize Disruption I Self-Funding Policies

• Product Re-Usability

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y HP VAN SDN Controller wrlh Network Protector SDN Apphcatron

Edge

---~-

SLED SON Use Cases

• K-12 school (Victoria, Australia) • 250 faculty, 1,400 students (>200 students in boarding houses) • Installed antivirus software in school-owned machines • Installed intrusion prevention in the firewall

BALLARAT GRAMMAR

• IT team was still bogged down with hours of manually identifying and eliminating network threats (botnets, spyware, and malware)

"HP Network Protector SDN Application takes away a lot of the manual labor that we used to do. We now know exactly where the infections are and how many there are-we can detect threats and respond in a proactive manner. That saves us hours of work every week." -Gregory Bell, Head of Technical Services, Ballarat Grammar

Side Benefit: "We use Network Protector to help us wtth challenges around sites like Facebook, which are a distraction during class. With the DNS Blacklist feature, we restrict access to websites like that, which encourages the staff and students to enga9e rnore with one another during class."

10 ©Copyright 2013 Hewlett-Packard Development Company, L.P The information co1•tained her• in i subject to chj;!nge without notice

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Video #1

11 ©Copyright 2013 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice. (1/J

Network Application Deployment - Microsoft Lync Model

Active Directory,

Exchange & SharePoint

SIP Signaling

SON API

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HPVAN SON Controller Open flow

1 OpenFiow I Modify QoS DSCP Rules

User Lin! rJ \.

• ~ ©Copyright 2013 Hewlett-Packard Developmrnt Company, L.P The information contained herein is subject to change without not1ce ~~.) Lync (/1)

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Video #2

13 ©Copyright 2013 Hewlett-Packard Development Company, L.P. The information contained herein Is subject to change without notice. (/;)

Applying Model to Common Core Application Deployment

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Active Directory,

Exchange & SharePoint

SIP Signaling

SON API

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1 OpenFiow I Modify QoS DSCP Rules

Student _. D \. !4 () Copyright 2013 Hewlolt-Pac~ard Development Company, L.P The tnformatton contained herein is subject to change withoutnoltce

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SON Benefits

Agility

Alignment

Consistency

Open Standards

Innovation

Accessibility

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Network Ability to Grow, Move and Adjust to Future Application Demands

Network Resources Allocated by Pre-Defined Application Templates

Network Configuration Changes Consistently Applied Through Templates

Best-of-Breed to Support Application Demands and Market Trends

Open-ended Application Development Due to Unrealized Capabilities

Utilize Time-Tested Human Factors Deployment Techniques

15 e Copyright 2013 Hewlett-Packard Development Compnny L.P The 111formatio chf:1ge without notice

--:._~ ·::II