Telecom - Secretary General Letter addressed to Paul Beaudry (Cogeco Communications)
Gatineau, 6 June 2025
Our reference: 1011-NOC2024-0318
BY EMAIL
Paul Beaudry
Vice President, Regulatory and Government Affairs
Cogeco Communications
telecom.regulatory@cogeco.com
Subject: Making it easier for consumers to shop for Internet services (2024-318)—Disclosure of information filed as confidential—Cogeco
Dear Paul Beaudry,
By way of this letter, please find the Commission’s binding determinations regarding the disclosure of the information Cogeco Communications Inc., on behalf of its subsidiary Cogeco Connexion Inc. (Cogeco) filed as confidential in the context of the proceeding initiated by Telecom Notice of Consultation 2024-318 (NoC 2024-318).
On 6 May 2025, staff issued a letter to five (5) parties, including Cogeco, requesting that they disclose certain information filed as confidential to the record of NoC 2024-318. In your 13 May 2025 response, you disagreed with staff’s assessment of your confidentiality designation and requested a binding Commission determination on the matter. You also provided further justification for your designation of certain pieces of information as confidential.
Increase in churn rate from 2022 to 2024
In your request, you reiterated that you do not provide information related to churn publicly in securities law filings or otherwise. You also submitted that your competitors’ decision to make this information public “does not change its confidential status at Cogeco.”
Within the same footnote in your intervention, but not filed in confidence, you noted that churn has increased and only the actual amount of the increase was designated as confidential, thus providing some insights to readers into the claim you are making.
The Commission, by majority decision, accepts Cogeco’s designation of churn information as being confidential as the public interest in this case does not outweigh the specific and direct harms to Cogeco.
General implementation and ongoing cost estimates of the measures considered in this proceeding
In your request, you argued that, named or not, general cost estimates qualified by internal teams would be sufficient to provide competitors with the high-level costs needed to change your operations support system/business support system (OSS/BSS) platform to accommodate the introduction of a broadband label.
You further argued that any insights into this critical system could enable your competitors to develop more effective marketing strategies, prejudicing your position in the market.
In your intervention, you filed in confidence the entire section on estimated costs, including the costs themselves, thereby entirely preventing the parties from assessing the possible impact to your operations.
It is important for other parties to have this information on the public record to assess the potential impacts of the measures considered by the Commission in this proceeding. Also, the information in question is only an estimate. Therefore, the public interest in this case outweighs the specific and direct harms to Cogeco for part of the information at issue.
The Commission, by majority decision, directs Cogeco to disclose the topline costs involved on the public record by no later than 16 June 2025, but accepts Cogeco’s designation as confidential of the detailed information that describes what the topline costs include.
Frequency that plans are introduced or changed
In your request, you argued that “considerable thought and effort goes into plan development and review and Cogeco considers information around the frequency of plan updates to be commercially sensitive information” and that disclosure would “give our competitors easily accessible insight into Cogeco’s marketing strategies that would otherwise not be readily available to them.”
Your intervention argued on the public record that “[t]here is significant dynamic competition in the market for broadband services, and competitive offerings can change at a very rapid pace” and you provided only the actual number in confidence as an example to argue this point.
Though the number is not readily available, any party can monitor your website and determine how many times you make changes to your plans or introduce new plans. Moreover, the truly sensitive information would be the decision making behind the changes, which would not be disclosed in this instance.
In light of the above, the potential specific and direct harms to Cogeco are limited and do not outweigh the public interest.
The Commission directs Cogeco to file this information on the public record by no later than 16 June 2025.
Sincerely,
Marc Morin
Secretary General
CC: Nanao Kachi, Director, Consumer, Analytics and Strategy, CRTC, nanao.kachi@crtc.gc.ca
Albert Xie, Hearing Manager, Consumer, Analytics and Strategy, CRTC, albert.xie@crtc.gc.ca
Michael Ostroff, Legal Counsel, Legal Services, CRTC, michael.ostroff@crtc.gc.ca
Distribution List
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