What changed in this filing

/stocks — the workspaceLOADING

Item 1. Business

2022-02-23 compared with 2021-03-01 · 460 added, 430 removed, 613 unchanged (59% of the section changed)

(a) General Development of Business

Liberty Latin America Ltd.

( Liberty Latin America ) is a registered company in Bermuda that primarily includes:

(i) Cable & Wireless Communications Limited and its subsidiaries (collectively C&W ), which includes Cable & Wireless Panama, S.A.

(ii) Liberty Communications PR Holding LP and its subsidiaries (collectively Liberty Puerto Rico ), which include Liberty Communications of Puerto Rico LLC ( LCPR ) and, as of October 31, 2020 and as further described in note 4, Liberty Mobile Inc.

and its subsidiaries ( Liberty Mobile );

(iii) VTR Finance N.V.

and its subsidiaries (collectively VTR , which includes VTR.com SpA ( VTR.com ));

(iv) LBT CT Communications, S.A.

and its subsidiary, Cabletica S.A.

( Cabletica ).

VTR, Liberty Communications PR Holding LP and LCPR were formerly known as VTR Finance B.V., Leo Cable LP and Liberty Cablevision of Puerto Rico LLC, respectively.

C&W owns less than 100% of certain of its consolidated subsidiaries, including The Bahamas Telecommunications Company Limited ( C&W Bahamas ) (a 49%-owned entity that owns all of our operations in the Bahamas), Cable & Wireless Jamaica Limited ( C&W Jamaica ) (a 92%-owned entity that owns the majority of our operations in Jamaica), and CWP (a 49%-owned entity that owns most of our operations in Panama).

Liberty Latin America owns 80% of LBT CT Communications S.A.

Liberty Latin America, which was originally formed on July 11, 2017, is a registered company in Bermuda that primarily includes:

(ii) Liberty Communications PR;

and (iv) LBT CT Communications, S.A.

(a less than wholly-owned entity) and its subsidiaries, which include Cabletica and, as of August 9, 2021 and as further described below, Telefónica Costa Rica.

C&W owns less than 100% of certain of its consolidated subsidiaries, including C&W Bahamas, C&W Jamaica and CWP.

We are an international provider of fixed, mobile and subsea telecommunications services.

We provide residential and business-to-business ( B2B ) services in (i) over 20 countries across Latin America and the Caribbean, through two of our reportable segments, “ C&W Caribbean and Networks ” and “ C&W Panama ”, (ii) Chile and Costa Rica, through our reportable segment, “ VTR/Cabletica ”, and (iii) Puerto Rico, through our reportable segment, Liberty Puerto Rico.

Through our “ Networks & LatAm ” business, C&W Caribbean and Networks also provides (i) B2B services in certain other countries in Latin America and the Caribbean and (ii) wholesale communication services over its subsea and terrestrial fiber optic cable networks that connect over 40 markets in that region.

In the following text, the terms “ Liberty Latin America ,” “ we ,” “ our ,” “ our company ” and “ us ” may refer, as the context requires, to Liberty Latin America or collectively to Liberty Latin America and its subsidiaries.

We were originally formed as a Bermuda company on July 11, 2017, as a wholly-owned subsidiary of Liberty Global plc ( Liberty Global ) under the name LatAm Splitco Ltd.

and we changed our name to Liberty Latin America Ltd.

on September 22, 2017.

During October 2017, the Board of Directors of Liberty Global authorized a plan to distribute to the holders of its ordinary shares (the LiLAC Shares ) common shares in our company (the Split-Off ), which was completed on December 29, 2017.

The LiLAC Shares were tracking shares, which were intended to reflect or “track” the economic performance of Liberty Global’s “ LiLAC Group ” rather than the economic performance of Liberty Global as a whole.

The LiLAC Group comprised the same entities as Liberty Latin America at the time of the Split-Off.

References in the following text to our assets, liabilities or businesses reflect the historical information of (i) certain former subsidiaries of Liberty Global for periods prior to the Split-Off and (ii) Liberty Latin America and its consolidated subsidiaries for the period following the Split-Off.

Although Liberty Latin America was previously reported on a combined basis, the financial and operating information presented herein includes Liberty Latin America and its consolidated subsidiaries for all periods presented, unless stated otherwise.

residential and B2B services in:

over 20 countries across Latin America and the Caribbean through two of our reportable segments, C&W Caribbean and Networks and C&W Panama;

Puerto Rico, through our reportable segment Liberty Puerto Rico;

Chile, through our reportable segment VTR;

Costa Rica, through Cabletica and its subsidiary, Telefónica Costa Rica;

through the Networks & LatAm business of our C&W Caribbean and Networks segment, (i) B2B services in certain other countries in Latin America and the Caribbean and (ii) wholesale communication services over subsea and terrestrial fiber optic cable networks that connect approximately 40 markets in that region.

Prior to the first quarter of 2021, VTR and Cabletica were collectively one operating segment.

As a result of organizational changes during the first quarter of 2021, these operations became separate operating segments.

Following the Telefónica Costa Rica Acquisition on August 9, 2021 (as further described in note 4 to our consolidated financial statements), Cabletica and Telefónica Costa Rica now comprise our Costa Rica operating and reportable segment.

For additional information regarding our segment changes, see note 21 to our consolidated financial statements.

Effective September 29, 2021, in connection with the pending formation of the Chile JV, we began accounting for the Chile JV Entities as “held for sale.” Accordingly, the assets and liabilities of the Chile JV Entities, excluding certain cash balances, are included in assets held for sale and liabilities associated with assets held for sale, respectively, on our December 31, 2021 consolidated balance sheet.

Consistent with the applicable guidance, we have not reflected similar reclassifications to exclude the Chile JV Entities from continuing operations in our consolidated statements of operations or cash flows and related footnote disclosures.

For additional information, see note 9 to our consolidated financial statements.

Developments in the Business

5 unchanged sentences

Within the last three years, we completed, or have entered into definitive agreements to complete, the following transactions:

• the acquisition on October 31, 2020, of AT&T’s wireless and wireline operations in Puerto Rico and the U.S.

Virgin Islands in an all-cash transaction (the AT&T Acquisition) based upon an enterprise value of $1.95 billion;

• on July 30, 2020, we entered into a definitive agreement to acquire Telefónica S.A.’s operations in Costa Rica in an all-cash transaction based upon an enterprise value of $500 million on a cash- and debt-free basis (the Telefónica-Costa Rica Acquisition ).

• on September 29, 2021, we entered into an agreement with América Móvil to contribute the Chile JV Entities to América Móvil’s Chilean operations, to form the Chile JV that will be owned 50:50 by Liberty Latin America and América Móvil.

América Móvil is a telecommunications service provider with over 6.5 million mobile customers in

The consummation of the transaction is subject to certain customary closing conditions, including regulatory approvals, and is expected to close in the second half of 2022;

• on September 14, 2021, we entered into an agreement to acquire América Móvil’s operations in Panama in an all-cash transaction based upon an enterprise value of $200 million on a cash- and debt-free basis.

The transaction is subject to certain customary closing conditions, including regulatory approvals, and is expected to close in the first half of 2022;

• the disposition on November 5, 2019 of Cable & Wireless Seychelles based on an enterprise value of approximately $104 million to a consortium of local investors (the Seychelles Disposition );

• the acquisition on March 31, 2019 of an 87.5% stake from the government of Curacao in United Telecommunications Services N.V.

( UTS , and the acquisition, the UTS Acquisition ), which provides fixed and mobile services to the island nations of Curacao, St.

• on August 9, 2021, we completed the acquisition Telefónica S.A.’s operations in Costa Rica in an all-cash transaction based upon an enterprise value of $500 million on a cash- and debt-free basis;

• on October 31, 2020, we completed the acquisition of AT&T’s wireless and wireline operations in Puerto Rico and the U.S.

Virgin Islands in an all-cash transaction based upon an enterprise value of $1.95 billion;

• on November 5, 2019, we completed the disposition of Cable & Wireless Seychelles based upon an enterprise value of approximately $104 million to a consortium of local investors;

• on March 31, 2019 we completed the acquisition of an 87.5% stake from the government of Curacao in United Telecommunications Services N.V., providing fixed and mobile services to the island nations of Curacao, St.

Martin, Bonaire, St.

1 unchanged sentence

Maarten, each in an all cash transaction;

• the acquisition on October 17, 2018 of Searchlight Capital Partners L.P.’s 40% interest in both Leo Cable LP and Leo Cable L.L.C., which in turn gave us 100% ownership of Liberty Puerto Rico, in exchange for 9,500,000 unregistered Class C common shares;

• the acquisition on October 1, 2018 of an 80% stake in Cabletica (the Cabletica Acquisition ), which is a leading cable operator in Costa Rica that provides television, broadband internet and fixed-line telephony services to residential customers, from Televisora de Costa Rica S.A.

in an all cash transaction.

For information regarding our material financing transactions, see note 10 to our consolidated financial statements included in Part II of this Annual Report on Form 10-K.

12 unchanged sentences

changes in competitive, regulatory and economic factors;

the timing and impacts of proposed transactions, including the Telefónica-Costa Rica Acquisition;

anticipated changes in our revenue, costs or growth rates;

the timing and impacts of proposed transactions, including the Claro Panama Acquisition and the Chile JV;

our anticipated integration plans, synergies, opportunities and integration costs in Puerto Rico following the AT&T Acquisition and in Costa Rica following the Telefónica Costa Rica Acquisition;

the UPR Fund;

changes in our revenue, costs or growth rates;

our liquidity and our ability to access the liquidity of our subsidiaries;

credit risks;

the interest rate risks associated with the phasing out of LIBOR;

internal control over financial reporting;

the interest rate risks associated with the transition of LIBOR;

internal control over financial reporting and remediation of material weaknesses;

foreign currency risks;

compliance with debt, financial and other covenants;

our future projected contractual commitments and cash flows;

our future projected sources and uses of cash;

the effects and potential impacts of COVID-19 on our business and results of operations;

and other information and statements that are not historical fact.

6 unchanged sentences

• fluctuations in currency exchange rates, inflation rates and interest rates;

• our relationships with third-party programming providers and broadcasters and the ability to acquire programming;

• our relationships with third-party programming providers and broadcasters, some of which are also offering content directly to consumers, and our ability to maintain access to desirable programming on acceptable economic terms;

• our relationships with suppliers and licensors and the ability to maintain equipment, software and certain services;

14 unchanged sentences

• our ability to renew necessary regulatory licenses, concessions or other operating agreements and to otherwise acquire future spectrum or other licenses that we need to offer new mobile data or other technologies or services;

• our ability to obtain regulatory approval and satisfy other conditions necessary to close acquisitions and dispositions, and the impact of conditions imposed by competition and other regulatory authorities in connection with acquisitions, such as with respect to the Telefónica-Costa Rica Acquisition;

• our ability to successfully acquire new businesses and, if acquired, to integrate, realize anticipated efficiencies from and implement our business plan with respect to the businesses we have acquired or that we expect to acquire, such as with respect to the Telefónica-Costa Rica Acquisition;

• changes in laws or treaties relating to taxation, or the interpretation thereof, in the U.S.

1 unchanged sentence

• changes in laws and government regulations that may impact the availability and cost of capital and the derivative instruments that hedge certain of our financial risks;

• the ability of suppliers and vendors, including third-party channel providers and broadcasters (including our third-party wireless network provider under our mobile virtual network operator ( MVNO ) arrangement), to timely deliver quality products, equipment, software, services and access;

• the ability of suppliers and vendors, including third-party channel providers and broadcasters (including our third-party wireless network provider under our MVNO arrangement), to timely deliver quality products, equipment, software, services and access;

• the availability of attractive programming for our video services and the costs associated with such programming, including retransmission and copyright fees payable to public and private broadcasters;

13 unchanged sentences

• our ability to recoup insurance reimbursements and settlements from third-party providers;

• our ability to comply with anti-corruption laws and regulations, such as the FCPA;

• our ability to comply with economic and trade sanctions laws, such as the U.S.

Treasury Department’s Office of Foreign Assets Control ( OFAC );

Treasury Department’s OFAC;

• the impacts of climate change such as rising sea levels or increasing frequency and intensity of certain weather phenomena;

• events that are outside of our control, such as political conditions and unrest in international markets, terrorist attacks, malicious human acts, hurricanes and other natural disasters, pandemics, including the COVID-19 pandemic, and other similar events.

5 unchanged sentences

The communications and entertainment services that we deliver to our residential and business customers include video, broadband internet, telephony and mobile services.

In most of our operating footprint, we offer a “triple-play” of bundled services of video, internet and telephony in one subscription.

In most of our operating footprint, we offer bundles of services, including video, broadband internet and telephony products in one subscription.

We are also focused on leveraging our full-service product suite to deliver fixed-mobile convergence offerings.

Available fixed service offerings depend on the bandwidth capacity of a particular system and whether it has been upgraded for two-way communications.

Our business products and services also include enterprise-grade connectivity, data center, hosting and managed solutions, as well as IT solutions with customers ranging from small and medium enterprises to international companies and governmental agencies.

We also operate an extensive subsea and terrestrial fiber optic cable network that connects over 40 markets in the region, providing connectivity solutions both within and outside our operating footprint.

We also operate an extensive subsea and terrestrial fiber optic cable network that connects approximately 40 markets in the region, providing connectivity solutions both within and outside our operating footprint.

We are the largest fixed-line provider of high-speed broadband and video services across a number of our markets, including Puerto Rico, Chile, Jamaica and Trinidad and Tobago.

We also operate the largest telephony network in most of our C&W markets where we provide residential communications services.

In addition, we offer mobile services throughout most of our operating footprint, including Puerto Rico and the U.S.

Virgin Islands.

Across C&W’s markets, we are a mobile network operator in Panama and most of our Caribbean markets, including the Bahamas and Jamaica.

As a network provider, we are able to offer a full range of voice and data services, including value-added, data-based and fixed-mobile converged services.

In addition, we offer mobile services across our operating footprint.

As a network operator across most of our markets, we are able to offer a full range of voice and data services, including value-added, data-based and fixed-mobile converged services.

In Chile, VTR provides mobile services as an MVNO and leases a third-party’s radio access network.

1 unchanged sentence

Our operating brands include the following:

C&W VTR.com Liberty Puerto Rico Cabletica

Trends in Market Demand

In December 2019, COVID-19 was reported in Wuhan, China.

On March 11, 2020, the World Health Organization declared the outbreak a “pandemic,” pointing to the sustained risk of further global spread.

To date, confirmed cases of COVID-19 have been experienced in each of the markets in which we operate.

During 2020, COVID-19 has negatively impacted our operations, primarily within our C&W Caribbean and Networks, C&W Panama and VTR/Cabletica segments, due to resulting lockdowns, moratoriums, cancellation of live sporting events, and mobility, travel and tourism restrictions across many of the markets in which we operate.

The implications of these restrictions have been (i) the issuance of discounts to customers, (ii) the pause in certain managed service projects, particularly with government agencies, (iii) at VTR, customers experiencing network connection-related issues stemming from the significant increase, over a short period of time, in the capacity usage by our customers, and (iv) delayed or deferred customer payments and increased customer churn.

In VTR, our most competitive consumer fixed market, we experienced increased revenue generating unit churn during the third quarter following network challenges related to the increased bandwidth demand earlier in the year.

We have carried out a number of operational actions to improve the experience for our customers.

Within our mobile operations, the lockdowns negatively impacted, primarily at C&W Caribbean and Networks and C&W Panama during the second quarter of 2020, our customers’ ability to recharge their prepaid mobile devices.

In addition, we experienced declines in inbound roaming activity as a result of travel restrictions and reduced tourism activities in the markets in which we operate.

These factors collectively resulted in declines in revenue within our B2B and mobile operations and lower ARPU (as defined below) associated with our residential fixed subscription services.

Given the impacts of COVID-19 continue to rapidly evolve, the extent to which COVID-19 may further impact our financial condition or results of operations continues to be uncertain and cannot be predicted at this time.

C&W VTR.com Liberty Puerto Rico Costa Rica

Operating Data

The following tables present certain operating data as of December 31, 2021.

The tables reflect 100% of the data applicable to each of our reportable segments, and for the key markets within the segments of C&W Caribbean and Networks, C&W Panama and VTR/Cabletica, regardless of our ownership percentage.

The tables reflect 100% of the data applicable to each of our reportable segments, and for the key markets within the segments of C&W Caribbean and Networks, C&W Panama and Costa Rica, regardless of our ownership percentage.

For additional information regarding terms used in the following tables, see the Operating Data Glossary below.

Passed Two-way

Passed Customer

Passed Fixed Line Customer

Relationships Total

RGUs Video RGUs Internet RGUs Telephony RGUs Total Mobile Subscribers (d)

C&W Caribbean and Networks:

RGUs Video RGUs Internet RGUs Telephony RGUs Total Mobile Subscribers Prepaid Postpaid

C&W Caribbean & Networks:

Jamaica 646,400 646,400 330,200 733,400 138,800 300,200 294,400 1,111,500 1,072,200 39,300

5 unchanged sentences

1,581,300 1,561,500 833,700 1,695,800 364,000 729,700 602,100 1,821,400 1,650,500 170,900

C&W Panama (a) (b) 687,900 687,900 184,700 405,500 89,900 155,900 159,700 1,461,900

Total C&W 2,229,200 2,209,400 990,000 1,988,700 443,400 828,700 716,600 3,148,400

VTR/Cabletica:

VTR 3,848,600 3,424,700 1,465,800 2,848,800 1,065,500 1,286,100 497,200 280,300

Cabletica 633,000 627,100 268,300 443,200 206,900 214,800 21,500 —

Total VTR/Cabletica (c) 4,481,600 4,051,800 1,734,100 3,292,000 1,272,400 1,500,900 518,700 280,300

Liberty Puerto Rico (d) 1,137,700 1,137,700 480,500 905,600 235,200 434,300 236,100 1,022,600

Total 7,848,500 7,398,900 3,204,600 6,186,300 1,951,000 2,763,900 1,471,400 4,451,300

(a) RGU balances do not include 58,600 RGUs that, due to the impact of COVID-19, have not been disconnected in accordance with our normal disconnect policy for non-payment and continue to receive services.

(b) During the fourth quarter of 2020, we announced that we would shut down our DTH operations in Panama, which went into effect in January 2021, and as such, the associated customer relationships and RGUs are no longer included in our subscriber count.

(d) On October 31, 2020, we closed the AT&T Acquisition at which point Liberty Puerto Rico began to provide mobile services.

Mobile subscriber information associated with the AT&T Acquisition is preliminary and subject to adjustment until we have completed our review of such information and determined that it is presented in accordance with our policies.

RGU balances do not include 11,200 fixed RGUs representing customers that, due to the impact of COVID-19, have not been disconnected in accordance with our normal disconnect policy for non-payment and were moved to an "essential services plan", a basic service plan.

(d) Mobile subscribers comprise the following:

Prepaid Postpaid Total

C&W Caribbean and Networks:

Jamaica 970,000 22,300 992,300

The Bahamas 150,800 30,300 181,100

Barbados 88,400 30,200 118,600

Other 346,500 48,000 394,500

Total C&W Caribbean and Networks

1,555,700 130,800 1,686,500

C&W Panama (a) 1,338,900 123,000 1,461,900

C&W Panama 774,300 774,300 200,200 467,100 108,200 179,400 179,500 1,712,200 1,550,900 161,300

Total C&W 2,355,600 2,335,800 1,033,900 2,162,900 472,200 909,100 781,600 3,533,600 3,201,400 332,200

Liberty Puerto Rico (a) 1,160,200 1,160,200 520,500 977,100 245,700 478,900 252,500 1,022,400 199,900 822,500

VTR 4,175,900 3,809,300 1,388,800 2,824,300 1,060,500 1,218,900 544,900 251,200 8,200 243,000

Liberty Puerto Rico (b) 239,000 783,600 1,022,600

Costa Rica (b) 663,100 657,200 283,200 476,700 200,800 243,300 32,600 2,733,100 2,031,200 701,900

Total 8,354,800 7,962,500 3,226,400 6,441,000 1,979,200 2,850,200 1,611,600 7,540,300 5,440,700 2,099,600

(a) RGU balances do not include 12,400 mobile subscribers that, due to the impact of COVID-19, have not been disconnected in accordance with our normal disconnect policy for non-payment and continue to receive services.

(b) Postpaid mobile subscribers include 126,800 Corporate Responsible Users ( CRU ).

A CRU represents an individual receiving mobile services through an organization that has entered into a contract for mobile services with us and the organization is responsible for the payment of the CRU’s mobile services.

(a) Postpaid mobile subscribers include 139,700 CRUs.

A CRU represents an individual receiving mobile services through an organization that has entered into a contract for mobile services with us and where the organization is responsible for the payment of the CRU’s mobile services.

(b) Our homes passed in Costa Rica include 55,000 homes on a third-party network that provides us long-term access.

Subscriber information related to the Telefónica Costa Rica Acquisition is preliminary and subject to adjustment until we have completed our review of such information and determined that it is presented in accordance with our policies.

Operating Data Glossary

Customer Relationships – The number of customers who receive at least one of our video, internet or telephony services that we count as RGUs, without regard to which or to how many services they subscribe.

To the extent that RGU counts include equivalent billing unit (“ EBU ”) adjustments, we reflect corresponding adjustments to our customer relationship counts.

To the extent that RGU counts include EBU adjustments, we reflect corresponding adjustments to our customer relationship counts.

For further information regarding our EBU calculation, see Additional General Notes below.

5 unchanged sentences

Internet (Broadband) RGU – A home, residential multiple dwelling unit or commercial unit that receives internet services over our network.

Mobile Subscribers – Our mobile subscriber count represents the number of active subscriber identification module (“ SIM ”) cards in service rather than services provided.

Mobile Subscribers – Our mobile subscriber count represents the number of active SIM cards in service rather than services provided.

For example, if a mobile subscriber has both a data and voice plan on a smartphone this would equate to one mobile subscriber.

2 unchanged sentences

In a number of countries, our mobile subscribers receive mobile services pursuant to prepaid contracts.

Revenue Generating Unit (RGU) – RGU is separately a video RGU, internet RGU or telephony RGU.

RGU – RGU is separately a video RGU, internet RGU or telephony RGU.

A home, residential multiple dwelling unit, or commercial unit may contain one or more RGUs.

47 unchanged sentences

(1) Percentage of total homes passed that are two-way homes passed.

(2) Percentage of two-way homes passed served by a cable, fiber-to-the-home/-cabinet/-building/-node ( FTTx ) or digital subscriber line ( DSL ) network, as applicable.

(2) Percentage of two-way homes passed served by a cable, FTTH or DSL network, as applicable.

“VDSL” refers to both our DSL and very high-speed DSL technology networks.

6 unchanged sentences

Network System (1)

VDSL/HFC/FTTx VDSL/HFC/FTTx VDSL/FTTx HFC FTTx VDSL/HFC/FTTx HFC/FTTx HFC/FTTx HFC / FTTx

VDSL/HFC/FTTH VDSL/HFC/FTTH VDSL/FTTH HFC FTTH VDSL/HFC/FTTH HFC/FTTH HFC/FTTH HFC / FTTH

Broadband internet service:

3 unchanged sentences

Network Technology (3)

LTE LTE LTE — LTE LTE / HSPA+ LTE — 5G

LTE LTE LTE — LTE LTE / HSPA+ LTE LTE 5G

(1) These are the primary systems used for delivery of services in the countries indicated.

29 unchanged sentences

Panama X X X X

VTR/Cabletica:

Chile X X X X

Costa Rica — X X X

Liberty Puerto Rico

Puerto Rico X X X X

Costa Rica X X X X

We believe that our ability to offer our customers greater choice and selection in bundling their services enhances the attractiveness of our service offerings, improves customer retention, minimizes churn and increases overall customer lifetime value.

1 unchanged sentence

Mobile Services .

We offer mobile services throughout most of our operating footprint.

We are a mobile network provider, delivering high-speed services in Puerto Rico, Panama and all but one of our Caribbean markets, but excluding Costa Rica.

We offer mobile services throughout our operating footprint.

We are a mobile network operator, delivering high-speed services in Puerto Rico and the USVI, Panama, Costa Rica and all but one of our Caribbean markets.

In Chile, we provide mobile services as an MVNO, where VTR leases a third-party’s radio access network.

2 unchanged sentences

We hold spectrum licenses as a mobile network provider, with terms typically ranging from 10 to 15 years across our C&W markets.

In Puerto Rico, spectrum licenses are typically held for perpetuity with the exception of CBRS spectrum which has a term of 10 years.

In Puerto Rico, spectrum licenses are

typically held for perpetuity with the exception of CBRS spectrum which has a priority term of 10 years.

We also hold mobile spectrum licenses in Costa Rica with a 15-year term that may be extended for an additional 10 years.

Subscribers to our mobile services pay varying monthly fees depending on whether the mobile service is bundled with one of our other services or includes mobile data services over their phones, tablets or laptops.

3 unchanged sentences

Customers subscribing to a postpaid plan generally enter into contracts ranging from 12 to 24 months.

The long-term contracts are often taken with a subsidized mobile handset.

Our mobile services include voice, SMS and internet access via data plans.

Customers subscribing to a postpaid plan in Puerto Rico are offered installment agreements if they buy a new handset with acceleration provisions if they cancel the account without penalty.

Long-term contracts are often taken with a subsidized mobile handset.

Our mobile services include voice, Short Message Service (SMS) and internet access via data plans.

Broadband Internet Services .

To support our customers’ expectations for seamless connectivity, we are expanding our networks to make ultrafast broadband available to more people.

This includes investment in the convergence of our fixed and mobile data systems and making wireless systems available in the home.

During 2020, our Network Extension programs (as defined and described below) passed approximately 387,000 homes across Liberty Latin America.

We provide next generation WiFi and telephony gateway products to our subscribers.

These products enable us to maximize the impact of our ultrafast broadband networks by providing reliable wireless connectivity anywhere in the home.

To support our customers’ connectivity demands, we are expanding our networks to make ultrafast broadband available to more people.

This includes investment in the convergence of our fixed and mobile data systems and through our next generation WiFi products, which enable us to maximize the impact of our ultrafast broadband networks by providing reliable wireless connectivity anywhere in the home.

These gateway products can be self-installed and have an automatic WiFi optimization function, which selects the best possible wireless frequency.

During 2021, our Network Extension programs (as defined and described below) passed approximately 738,800 homes across Liberty Latin America.

The internet speeds we offer are one of our differentiators, as customers spend more time streaming video and other bandwidth-heavy services on multiple devices.

1 unchanged sentence

We plan to continue the upgrade and expansion of our fixed networks so that we can deploy high-speed internet service to additional customers in the coming years.

Our residential subscribers access the internet via DSL over our fixed-line telephony networks, FTTx or hybrid fiber coaxial cable networks and with cable modems connected to their internet capable devices, including personal computers, or wirelessly via next generation WiFi and telephony gateway products.

Our residential subscribers access the internet via DSL over our fixed-line telephony networks, FTTH or hybrid fiber coaxial cable networks and with cable modems connected to their internet capable devices, including personal computers, or wirelessly via next generation WiFi and telephony gateway products.

In each of our markets, we offer multiple tiers of internet service.

8 unchanged sentences

We offer video services in Puerto Rico, Chile, Costa Rica, and in most of C&W’s residential markets.

To meet the demands of our customers, we have enhanced our video services with next generation, market-leading digital television platforms that enable our customers to control when and where they watch their programming.

These advanced services are delivered over our FTTx, VDSL and hybrid fiber coaxial cable networks and include a digital video recorder ( DVR ), a video-on-demand ( VoD ) offering and an advanced electronic programming guide.

In most of our markets, customers can pause their programming while a live broadcast is in progress as well as access a selection of channels and VoD content through a mobile application.

We have also launched “Replay TV” in many of our markets.

Replay TV allows a viewer to watch a TV program from the beginning after it has started or has concluded.

In Chile, our TV Everywhere app (branded “VTR Play”) extends the advanced video viewing experience to connected devices beyond the set-top box, including mobile phones and tablets.

In our Caribbean video markets and Panama, we offer a comprehensive internet streaming video service (branded “ Flow ToGo ” and “ +TV Go ”) that allows our video customers to stream an increasing number of channels with a broadband connection in and out of the home and on multiple devices.

In Puerto Rico, our video customers can watch their favorite channels on the TiVO serviced Liberty Go app as well as access over 65 applications from content providers to watch streamed linear and VoD programming by authenticating as a Liberty Puerto Rico customer.

Our operations with video services offer multiple tiers of digital video programming starting with a basic video service.

In addition, subscribers have the option to select extended and/or premium subscription tiers.

Fixed digital video services require a set-top box provided by us that also enables access to enhanced features such as VoD.

Subscribers to our basic digital video services pay a fixed monthly fee and generally can elect to receive, in most of our markets, a skinny entry tier or a basic tier, including a number of high definition ( HD ) channels.

We also offer a variety of premium packages combining linear channels and VoD.

In the few markets where our analog service is still available, including Costa Rica, subscribers to that service typically receive fewer channels than subscribers to our digital services, with the number of channels dependent on their location.

Subscribers to our digital services in each case receive the channels available through our analog service.

In all of our video operations, we continue to upgrade our systems to expand our digital services and encourage our remaining analog

subscribers to convert to a digital or premium digital service.

In most markets, we are enhancing our video offerings with next generation, market-leading digital television platforms that enable our customers to control when and where they watch their programming.

These advanced services are delivered over our FTTH, hybrid fiber coaxial cable and VDSL networks and customers access a range of features that include a DVR, a VoD offering and an advanced UI including an electronic programming guide, voice search and recommendation.

These video customers can also pause their programming while a live broadcast is in progress, return to the start and find programs they may have missed.

They can also stream a selection of channels and non-linear content on their own devices through “TV Everywhere” mobile applications such as, “VTR Play” in Chile, “Flow ToGo” and “Flow Sports” in the Caribbean, “Liberty Go” in Puerto Rico, “+movil” in Panama and “Cabletica Play” in Costa Rica.

Our operations with video services typically offer multiple tiers of digital video programming starting with affordable entry or skinny and basic video service tiers.

In addition, subscribers have the option to select extended and/or premium subscription packages combining linear channels and VoD.

Subscribers to our digital video services pay a fixed monthly fee and, in most of our markets, all tiers include a number of HD channels as well as access to enhanced features.

In addition, through our latest generation of video CPE (Customer Premise Equipment), subscribers can access most leading internet streaming services.

In the few markets where our analog service is still available, subscribers to the analog service typically receive fewer channels than subscribers to our digital services, with the number of channels dependent on their location and we continue to upgrade our systems to expand our digital services and encourage our remaining analog subscribers to convert to a digital or premium digital service.

Discounts to our monthly service fees are generally available to a subscriber who selects a bundled service of at least two of the following services:

video, internet and fixed-line telephony.

We tailor our video services in each country of operation based on local preferences, culture, demographics and local regulatory requirements.

Our channel offerings include the most relevant content to our subscribers, combining general entertainment, sports, movies, documentaries, lifestyle, news, adult, children and foreign channels, as well as local, regional and international broadcast networks.

We also operate several channels in the Caribbean, including a leading Caribbean sports network, Flow Sports, and through a consolidated joint venture, RUSH, the channel operating the rights to broadcast the Premier League across the Caribbean (excluding Puerto Rico).

We tailor our video services in each country of operation based on local preferences, culture, demographics and regulatory requirements.

We aim to offer the most relevant mix of content to our subscribers, combining general entertainment, sports,

movies, documentaries, lifestyle, news, adult, children and foreign channels, as well as local, regional and international broadcast networks.

We also operate several channels in the Caribbean, including a leading Caribbean sports network, Flow Sports, and through a consolidated joint venture, RUSH, a sports channel available across the Caribbean (excluding Puerto Rico and the US Virgin Islands).

Telephony Services .

1 unchanged sentence

VTR is the second largest residential fixed-line telephony operator, and a leading provider within its footprint.

LCPR and Cabletica also offer telephony services over their respective cable networks.

We offer multi-feature telephony service over our various fixed networks, including cable, FTTx and copper networks.

Depending on location, these services are provided via either circuit-switched telephony or voice-over-internet-protocol ( VoIP ) technology.

In Puerto Rico and Costa Rica we also offer telephony services over our respective networks.

We offer multi-feature telephony service over our various fixed networks, including cable, FTTH and copper networks.

Depending on location, these services are provided via either circuit-switched telephony or VoIP technology.

As we continue to develop and invest in new technologies that will enhance our customers’ experiences, we are replacing obsolete switches with VoIP technology and older copper networks with modern fiber optics.

3 unchanged sentences

We offer cloud-based integrated communication services, connectivity and wholesale solutions to carriers and businesses throughout the Caribbean and in parts of Latin America via our subsea and terrestrial fiber optic cable networks.

Our systems include long-haul terrestrial backbone and metro fiber networks that provide access to major commercial zones, wireless carrier cell sites and customers in key markets within our operating footprint.

Our networks deliver critical infrastructure for the transit of growing traffic from businesses, governments and other telecommunications operators across the region, particularly to the high-traffic destination of the United States.

Our systems include long-haul terrestrial backbone and metro fiber networks that provide service to major commercial zones, wireless carrier cell sites and customers in key markets within our operating footprint.

Our networks deliver critical infrastructure for the transport of growing traffic from businesses, governments and other telecommunications operators across the region, particularly to the high-traffic destination of the United States.

Below is a map of our subsea fiber network.

With over 50,000 km of fiber optic cable, and a capacity of over 3 terabits per second ( Tbps ), C&W is able to carry large volumes of voice and data traffic on behalf of our customers, businesses and carriers.

C&W’s networks also allow us to provide point-to-point, clear channel wholesale broadband capacity services and IP transit, superior switching and routing capabilities and local network services to telecommunications carriers, internet service providers ( ISPs ) and large corporations.

In the case of outages on portions of the cable systems, our network provides inbuilt resiliency through our traffic re-routing capability.

With over 50,000 km of fiber optic cable, and activated capacity of over 10 Tbps, C&W is able to carry large volumes of voice and data traffic on behalf of our customers, businesses and carriers.

In the case of network outage or maintenance activity, our network provides built-in resiliency through our traffic re-routing capability.

C&W has received recognition for its wholesale services.

In 2020, C&W was recognized by Frost & Sullivan with the Latin American and Caribbean Hosted IP Telephony and UCaaS Growth Excellence Frost Radar Award.

Our C&W Caribbean and Networks business was named the Best Marketing Team and Best Social Media Campaign at the 2020 Global Carrier Awards.

We hold several notable certifications, including the International ISO 27001 Certification, which reinforces the commitment to customer data safety, as well as CISCO Cloud and Managed Services Partner Master Certification, along with several others such as SOC 1 Type 2 and SOC 2 Type 2 attestations and PCI-DSS for select services.

We also provide services to business customers across various segments, from small and medium businesses to larger corporate and enterprise organizations including multi-national companies and governments.

We work with our business customers to customize the information and communication services they require.

For the second year in a row, C&W Business won the award for “Best Marketing Team” at the 2021 Global Carrier Awards.

The creative team of C&W Business stood out for their work in the development of marketing campaigns and was given this award for their dynamism, success and efficiency.

The Global Carrier Awards are the most prestigious in the wholesale telecommunications industry, annually honoring innovation in the regional and global markets, as well as vision and excellence in the sector.

Across our regional footprint we also provide services to business customers in various segments, from small and medium businesses to larger corporate and enterprise organizations including multi-national companies and governments.

We work with our business customers to customize the best end-to-end solutions, using standardized best in class products to fit their service needs.

We target specific industry segments, such as financial institutions, the hospitality sector, education institutions and government ministries and agencies.

We have agreements to provide our services over fully managed and monitored network bandwidth, dedicated fiber lines and third-party fiber networks.

We have agreements to provide our services over fully managed and monitored dedicated multiprotocol label switching networks and metro-access fiber lines.

We offer tailored solutions that combine our standard services with value-added features, such as dedicated customer care and enhanced service performance monitoring, to meet specific customer requirements.

Our business products and services include voice, broadband, enterprise-grade connectivity, network security, unified communications and a range of cloud based IT solutions, such as Infrastructure as a Service ( IaaS ), disaster recovery and other service offerings.

Our business products and services include voice, broadband, enterprise-grade connectivity, network security, unified communications and a range of cloud-based IT solutions, such as Infrastructure as a Service, disaster recovery and other service offerings.

We also offer a range of data, voice and internet services to carriers, ISPs and mobile operators.

Our extensive fiber optic cable networks allow us to typically deliver redundant, end-to-end connectivity.

Our networks also allow us to provide business customers our services over fiber lines and local networks;

thereby, seamlessly connecting businesses anywhere in the region.

We continuously enhance our capabilities and offerings to be the preferred provider for the business market.

Our extensive fiber optic cable networks allow us to typically deliver redundant, end-to-end connectivity backed by a strong service level agreement guarantee.

Our networks also allow us to provide our services over dedicated access fiber lines, and local and international private networks which are dedicated to our business customers.

Our business services fall into five broad categories:

• VoIP and circuit-switch telephony, on-premise and hosted private branch exchange solutions and conferencing options, hosted contact center solutions;

• Data services for internet access, virtual private networks, high capacity point-to-point, point-to-multi-point and multi-point-to-multi-point services, managed networking services such as wide area networks and WiFi networks;

• VoIP and circuit-switch telephony;

• Wireless services for mobile voice and data;

• Interactive TV service with specialized channel lineups for targeted industries;

• Value added services, including cloud IT services such as disaster recovery as a service, backup services, and IaaS ;

managed network security services;

and specialized services such as digital signage, retail analytics and location based marketing.

• Interactive TV service with specialized channel lineups for targeted industries, such as hospitality;

• Value added Managed Services, including

◦ Private and Public Cloud Infrastructure Services and integration, including Disaster Recovery Backup Services;

◦ Cloud and premise based Private Branch eXchange solutions, conferencing options and Hosted Contact Center solutions;

◦ Cyber Security Services, including structured solutions, rapid response, and other professional services;

◦ Emerging technologies in Software Defined Networking, Internet of Things, Digitalization and Digital Currencies;

◦ Specialized services such as Tele-Health, Digital Signage, and Retail Analytics.

The extensive reach of our network and assets, as well as our comprehensive set of capabilities positions us to meet the needs of carriers, businesses and government customers that are searching for a capable, progressive provider to manage their ever more complex communications, connectivity and information technology needs .

In many of our markets, we transmit our broadband internet, video and fixed-line telephony services over a hybrid fiber coaxial ( HFC ) cable network, and increasingly through FTTx networks.

An HFC network consists primarily of fiber networks that we connect to the home over the last few hundred meters by coaxial cable and an FTTx network uses fiber-to-the-home/-cabinet/-building/-node.

In several of our Caribbean markets, we transmit our services over a fixed network consisting of FTTx , VDSL or DSL copper lines.

In many of our markets, we transmit our broadband internet, video and fixed-line telephony services over aN HFC cable network, and increasingly through FTTH networks.

An HFC network consists primarily of fiber networks that we connect to the home over the last few hundred meters by coaxial cable and an FTTH network uses fiber-to-the-home/-cabinet/-building/-node.

In several of our Caribbean markets, we transmit our services over a fixed network consisting of FTTH , VDSL or DSL

copper lines.

Approximately 95% of our networks allow for two-way communications and are flexible enough to support our current services as well as new services.

6 unchanged sentences

◦ converting analog channels to digital;

◦ bonding additional data over cable service interface specification ( DOCSIS ) 3.0 channels;

◦ deploying VDSL over our fixed telephony network;

◦ bonding additional DOCSIS 3.0 channels and adding DOCSIS 3.1 channels;

◦ replacing copper lines with modern optic fibers;

1 unchanged sentence

• freeing spectrum for high-speed internet, VoD and other services by encouraging customers to move from analog to digital services;

• increasing the efficiency of our networks by moving headend functions (encoding, transcoding and multiplexing) to cloud storage systems;

• increasing the efficiency of our networks by moving head-end functions (encoding, transcoding and multiplexing) to cloud storage systems;

• enhancing our network to accommodate further business services;

7 unchanged sentences

This will allow us to offer converged fixed-line and mobile services to our customers.

We deliver high-speed data and fixed-line telephony over our various fixed networks, including cable, FTTx and copper networks.

We deliver high-speed data and fixed-line telephony over our various fixed networks, including cable, FTTH and copper networks.

These networks are further connected via our subsea and terrestrial fiber optic cable networks that provide connectivity within and outside the region.

Our subsea network cables terminating in the United States carry over 3 Tbps , which represent less than 10% of their potential capacity based on current deployed technology, presenting us with significant growth opportunities.

Our subsea network cables terminating in the United States carry over 10 Tbps , which represent approximately 10% of their potential capacity based on current deployed technology, presenting us with significant growth opportunities.

In Puerto Rico, our network includes a fiber ring around the island that provides enhanced interconnectivity points to the island’s other local and international telecommunications companies.

1 unchanged sentence

For more information about our subsea network, see — Business Services above.

We operate mobile networks in all of our consumer markets except Chile (where we operate as an MVNO), Costa Rica and Trinidad & Tobago.

Our networks deliver high-speed services across our markets, with approximately 95% LTE population coverage .

Our primary wireless networks use GSM/EDGE, 3G and 4G LTE technologies, which we offer in most of the

countries where we operate.

We aim to increase the speed of transmission of our data services and have been expanding our 3G and 4G LTE coverage.

We operate mobile networks in all of our consumer markets except Chile (where we operate as an MVNO) and Trinidad & Tobago.

Our networks deliver high-speed services across our markets, with over 90% LTE population coverage .

Our primary wireless networks use HSPA+ and LTE technologies, which we offer in most of the countries where we operate.

In Puerto Rico and USVI we operate 5G networks and across other markets we aim to increase the speed of transmission of our data services and have been expanding our HSPA+ and LTE coverage.

We transmit wireless calls and data through radio frequencies that we use under spectrum licenses.

We have a diversified portfolio of frequencies which support 3G, 4G and 5G (Puerto Rico & USVI only) technologies.

We have a diversified portfolio of frequencies which support HSPA+, LTE and 5G (Puerto Rico & USVI only) technologies.

While spectrum is a limited resource, and, as a result, we may face spectrum and capacity constraints on our wireless network in certain countries.

3 unchanged sentences

We continue to invest significant capital in expanding our network capacity and reach and to address spectrum and capacity constraints on a market-by-market basis.

Our prime 5G deployed market is Puerto Rico and USVI where over 90% of the population is served by our 5G capable network.

Our prime 5G deployed market is Puerto Rico and USVI where approximately 95% of the population is served by our 5G capable network.

We continually look for opportunities to expand our 5G footprint to other countries where a positive business case exists.

4 unchanged sentences

Supply Sources

With telecommunication companies increasingly offering similar services, content is one of the drivers for customers in selecting a provider of video, broadband and/or wireless services.

Therefore, in addition to providing products that allow our customers to consume content whenever and wherever they want, we continue to invest into content that matters the most to our customers.

Content is one of the drivers for customers in selecting a provider of video, broadband and/or wireless services.

Therefore, we aim to provide products that allow our customers to consume content whenever and wherever they want and feature content that matters the most to our customers.

Our programming strategy is based on:

• product (enabling access through home and mobile screens at anytime, including live, restart, catch-up, personal recording, on-demand and third party apps);

• proposition (exceeding our customers’ expectations on content and entertainment by offering access to the wider range of channels and third party app services);

• acquisition (investment in the most relevant channels, sports and on-demand);

• partnering (alliances with content partners and leading distributors to aggregate the best linear, non linear and third party apps content).

Except for Flow Sports and Flow 1 services in the Caribbean, and the RUSH sports channel operated by a consolidated joint venture with the Digicel Group, we license almost all of our programming and on-demand content through distribution agreements with third-party content providers, including broadcasters and leading cable networks.

For such licenses, we generally pay a monthly fee on a per subscriber basis, through long-term programming licenses.

In our distribution agreements, we seek to include the rights to offer the licensed channels and programming to our authenticated customers through multiple delivery platforms including through our apps for IP-connected mobile and fixed devices, and our websites.

We also acquire rights to make available, in selected markets, our and third party video services to mobile and/or broadband subscribers that are not subscribers to fixed TV services.

With respect to rights for the sports and entertainment services we operate directly or in a joint-venture in the Caribbean, we seek to license the most locally relevant sports content, such as the English Premier League, UEFA Champions League and Bundesliga soccer, Indian Premier League cricket, and WWE Wrestling.

Our latest video device that is distributed to a growing number of markets, including Puerto Rico, Chile and Panama, also enables our customers to access, through its App Store, leading subscription video on demand ( SVOD ) services such as Netflix, HBOMax and Amazon Prime Video.

• product (enabling access through home and mobile screens at anytime, including live, restart, catch-up, personal recording, on-demand and internet streaming apps);

• proposition (meeting our customers’ content and entertainment expectations by offering access to a wider range of channels and on-demand content, and internet streaming services at affordable and competitive price points);

• partnering (alliances with content partners and leading distributors to aggregate the best linear, non-linear and streaming content).

Except for Flow Sports and Flow 1 services, that we operate, in the Caribbean, and the RUSH sports channel operated by a consolidated joint venture with the Digicel Group, we license our programming and on-demand content through distribution agreements with third-party content providers, including broadcasters and leading cable networks.

For such licenses, we generally pay a variable monthly fee on a per subscriber basis, through multi-year programming licenses.

In our distribution agreements, we seek to include the rights to offer the licensed channels and on-demand programming to our authenticated customers through multiple delivery platforms including through our apps for IP-connected mobile and/or fixed devices, and our websites.

We also acquire rights to make available, in selected markets, video services to mobile subscribers and broadband subscribers that are not subscribers to fixed TV services.

With respect to rights for the sports and entertainment services we operate directly or in a joint-venture in the Caribbean, we seek to license locally relevant sports content.

Our latest video consumer equipment that is distributed to a growing number of markets, including Puerto Rico, Chile, Costa Rica and Panama, also enables our customers to access, through the Google App Store, leading streaming services such as Netflix, Disney+, HBOMax and Amazon Prime Video.

Mobile Handsets and Customer Premises Equipment

21 unchanged sentences

The video, broadband, telephony and mobile services provided by C&W Caribbean and Networks are subject to regulation and enforcement by various governmental and regulatory entities in each of the jurisdictions where such services are provided.

The scope and reach of these regulations are distinct in each market.

The scope and reach of these regulations are distinct in each market, with some markets such as the Dutch Caribbean being more heavily regulated than others.

Generally, C&W Caribbean and Networks provides services in accordance with licenses and concessions granted by national authorities pursuant to national telecommunication legislation and associated regulations.

3 unchanged sentences

These licenses and concessions are typically non-exclusive and have renewable multi-year terms that include competitive, qualitative and rate regulation.

Licenses and concessions are scheduled to expire over the next two years in the Cayman Islands and Turks and Caicos Islands.

Licenses and concessions are in the process of being renewed in the Cayman Islands, the British Virgin Islands, Antigua and the Turks and Caicos Islands.

We believe we have complied with all local requirements to have existing licenses renewed and have provided all necessary information to enable local authorities to process applications for renewal in a timely manner.

In addition, in some of the ECTEL (as defined below) states we are operating under expired licenses and have applied for renewal of such licenses.

In addition, in some of the ECTEL states we are operating under expired licenses and have applied for renewal of such licenses.

We expect that such licenses will be granted or renewed, as applicable, on the same or substantially similar terms and conditions in a timely manner.

Pending issuance of new or renewed licenses or concessions, we continue to operate on the same terms and conditions as prior to the licenses expiring.

With respect to licenses for mobile spectrum, the initial grant of the spectrum is sometimes subject to an auction process, but in a number of other cases, the license may be granted on the basis of an administrative process at a set level of fees for a fixed period of time, typically to coincide with carrier licenses, subject to the payment of annual fees and compliance with

applicable license requirements.

fixed period of time, typically to coincide with carrier licenses, subject to the payment of annual fees and compliance with applicable license requirements.

In very rare cases, spectrum previously assigned to C&W Caribbean and Networks may be re-allocated by regulatory authorities to other operators in the market.

1 unchanged sentence

By and large, spectrum assignments, once granted, remain unchanged for the duration of a license and beyond.

Rate regulation of C&W Caribbean and Networks’ telephony services typically includes price caps that set the maximum rates it may charge to customers, or legislation that requires consent from a regulator prior to any price increases.

In the Dutch Caribbean the frequencies are allotted on a “first come, first serve” basis, and they operate in the same frequency band divisions as mainland Europe.

The regulator reserves the various spectrum evenly between the market players and grants these when needed.

Once granted, the operator must start paying for the allocated spectrum.

In addition, all regulators determine and set the rates that may be charged by all telephony operators, including C&W Caribbean and Networks, for interconnect charges, access charges between operators for calls originating on one network that are completed through connections with one or more networks of other providers, and charges for network unbundling services.

In addition, in certain markets, regulators set, or are seeking to set, mobile roaming rates.

In addition, in certain markets, regulators set, or are seeking to set, mobile roaming rates and wholesale dedicated internet access.

Interconnection rates (and primarily mobile termination and roaming rates) in the telecommunications industry worldwide are decreasing, and we are experiencing this trend towards lower interconnection rates in our markets.

On the BES-islands, also known as the Caribbean Netherlands, data services are considered obligated services that are subject to price regulation requiring regulatory approval of any pricing changes, and Curacao is also considering whether to adjust its rules and regulations to make data services obligated services.

In recent years, a number of markets in which C&W Caribbean and Networks operates have demonstrated an increased interest in regulating various aspects of broadband internet services due to the increasing importance of high speed broadband.

1 unchanged sentence

Certain regulators are also seeking to mandate third-party access to C&W Caribbean and Networks ’ network infrastructure, including dark fiber and landing stations, as well as to regulate wholesale services and prices.

In the Dutch Caribbean and French territories, there are rules and regulations requiring such third party access to network infrastructure.

Any such decision and application to grant access to our network infrastructure may strengthen our competitors by granting them the ability to access our network to offer competing products and services without making the corresponding capital intensive infrastructure investment.

1 unchanged sentence

The extent of any such adverse impacts ultimately will be dependent on the extent that competitors take advantage of the resale access ultimately afforded to our network, the pricing mandated by regulatory authorities and other competitive factors or market developments.

As an example of infrastructure sharing, the Office of Utilities Regulation ( OUR ) in Jamaica has completed a consultation process on telecom facilities sharing rules that would require all licensees to share infrastructure (including dark fiber, ducts, subsea cable landing stations and mobile network towers) with third parties, including competitors, without any requirement of making a corresponding capital intensive infrastructure investment.

As an example of infrastructure sharing, the Office of Utilities Regulation in Jamaica has completed a consultation process on telecom facilities sharing rules that would require all licensees to share infrastructure (including dark fiber, ducts, subsea cable landing stations and mobile network towers) with third parties, including competitors, without any requirement of making a corresponding capital intensive infrastructure investment.

Once the rules are finalized by the Chief Parliamentary Counsel in Jamaica, they will be formally published and thereafter become law.

1 unchanged sentence

The process of such a challenge is likely to be long and we cannot at this time determine the possibility of a successful outcome.

In addition, the Eastern Caribbean Telecommunications Authority ( ECTEL ), the regulatory body for telecommunications in five Eastern Caribbean States (Commonwealth of Dominica, Grenada, St.

In addition, the ECTEL , the regulatory body for telecommunications in five Eastern Caribbean States (Commonwealth of Dominica, Grenada, St.

Kitts & Nevis, St.

7 unchanged sentences

• mandated unbundled access to all landing station network elements at cost-based rates.

We currently cannot determine the impact these provisions will have on our operations because national regulators are required to conduct extensive market reviews before adopting specific measures and these measures might be reconsidered in

accordance with the market reviews.

It is currently unclear as to when the new legislation will be enacted.

1 unchanged sentence

As such, the timing and ultimate effect of the bill is unclear.

In addition to rate regulation, several markets in which C&W operates have imposed, or are considering imposing, regulations designed to further encourage competition, including introducing requirements related to unbundling, network access to third parties, and local number portability ( LNP ) for fixed and mobile services.

Jurisdictions such as the Bahamas, the Cayman Islands and Jamaica have implemented fixed and mobile LNP and ECTEL has implemented mobile LNP .

Other jurisdictions, including Barbados, have considered or begun to implement LNP.

Trinidad and Tobago has yet to implement fixed LNP, although mobile LNP rules are already in place.

Other jurisdictions, including Antigua & Barbuda, Barbados and Turks and Caicos, have considered or begun to implement LNP .

Although fixed LNP and mobile LNP are already in place in Trinidad and Tobago, the regulator has yet to enforce it amongst the operators.

Additionally, regulators in The Bahamas are considering reviewing the current mobile restrictions on BTC, the incumbent, to ensure they are still applicable to the current state of the market.

The pay television service provided in certain C&W markets is subject to, among other things, subscriber privacy regulations, data protection laws and regulations, and the must-carry rule (as defined below) and retransmission consent rights of broadcast stations.

Pay television service in certain C&W markets is also under heavy pressure from illegal IP-setup boxes that are swamping the markets.

The price point that these pirates offer are difficult to compete against, and regulators are having a difficult time acting against these pirates or, in some cases, are unwilling to act against them.

C&W is also subject to universal service obligations in a number of markets.

1 unchanged sentence

In a number of cases, C&W is required to support universal access/service goals through contributions to universal service funds or participate in universal service-related projects.

In Panama, there is a proposal to modify the universal service law to expand its scope to include television services and provide conditions that would diminish the value of the contribution to the fund vis-a-vis projects covered by the law.

An additional process regarding coverage of maintenance cost of universal service law phones is ongoing.

In addition to the industry-specific regimes discussed above, C&W ’s operating companies must comply with both specific and general legislation concerning, among other matters, data retention, consumer protection and electronic commerce.

These operating companies are also subject to national level regulations on competition and on consumer protection.

In Trinidad and Tobago, C&W was required by the Telecommunications Authority of Trinidad and Tobago ( TATT ), in connection with TATT ’s approval of C&W ’s acquisition of Columbus International Inc.

in March 2015, to dispose of its 49% shareholding in the Telecommunications Services of Trinidad and Tobago Limited ( TSTT ).

In Trinidad and Tobago, C&W was required by the Telecommunications Authority of Trinidad and Tobago, in connection with its approval of C&W ’s acquisition of Columbus International Inc.

in March 2015, to dispose of its 49% shareholding in TSTT .

The disposal of C&W ’s stake in TSTT is not complete.

9 unchanged sentences

and its territories.

These facilities are regulated by the Federal Communications Commission ( FCC ), the Department of Homeland Security and other U.S.

These facilities are

regulated by the FCC , the Department of Homeland Security and other U.S.

governmental agencies that impose additional reporting and licensing obligations on C&W Caribbean and Networks .

C&W Panama is subject to regulatory entities, principally the National Authority of Public Services ( ASEP ), created in 1996 and modified in 2006 through Decree Law No.

C&W Panama is subject to regulatory entities, principally ASEP, created in 1996 and modified in 2006 through Decree Law No.

ASEP regulates and controls the public services for the supply of drinking water, sanitary sewerage, telecommunications and electricity.

Also, C&W Panama is subject to the Authority for Consumer Protection and Defense of Competition ( ACODECO ), guarantor of consumer protection and antitrust, which operates under the direction of the Ministry of Commerce and Industries.

Also, C&W Panama is subject to the ACODECO, guarantor of consumer protection and antitrust, which operates under the direction of the Ministry of Commerce and Industries.

By virtue of the Telecommunications Law 1996, public services in Panama are classified as “Type A services” and “Type B services,” with Mobile Telephony (STMC) and Personal Communication (PCS) services being classified as Type A services.

In 1997, the concession was awarded to BSC (now Grupo Milicom) and C&W Panama.

On January 2, 2003, the Local, National and International Basic Services were opened to competition by virtue of the termination of the temporary exclusivity granted to C&W Panama for the privatization of the public operator, INTEL.

With the opening of the market, in 2008, concession contracts for the PCS Service were granted to Digicel (Panamá), S.A.

and Claro Panamá, S.A., resulting in a total of four mobile telecommunications operators in Panamá, which remain to date.

However, the Consolidation Law was approved in 2018, allowing for mobile consolidation from four to three operators.

In 2019, all interested parties responded to the Public Consultation.

Resolution AN No.13200-Telco of March 20, 2019.

ASEP then issued the pending regulation of Law 36 of June 5, 2018 (Consolidation Law), whereby the regulator confirmed the proposed ruling:

(1) numbering plan and return of numbers after consolidation;

and (2) the obligation to return the spectrum of the target company without compensation in the case of consolidation.

After the ACODECO lawsuit of nullity against the regulation was admitted by the Supreme Court, C&W Panama withdrew all claims presented before the Supreme Court in view of ASEP’s compromise to have a new public consultation with an aligned view of the regulation among operators and the claims.

C&W Panama filed comments to the new public consultation 011-19, in which whoever buys the fourth operator would be allowed up to 130MHz of spectrum.

If, as a result of the transaction, the purchaser acquires more than that amount, it will be obliged to return the surplus amount, and ASEP will recognize the value of the returned spectrum and issue a credit to the purchaser in exchange.

The credit may be used to buy spectrum in the future;

extend the use of the spectrum or to renew the concession term.

ASEP has issued a pending resolution aligned with the telecommunications industry’s recommendations, which would allow mobile market consolidation to proceed and the shift from four to three operators remains pending.

See also Item 1.

Business — Developments in the Business regarding our entry into an agreement to acquire América Móvil’s operations in Panama, which is subject to customary closing conditions, including regulatory approval, and is expected to close in the second half of 2022.

C&W Panama has a total of 65MHz allocated (20 MHz in the 700 MHz band, 20 MHz in the 1900 MHz band and 25 MHz in the 850 MHz band);

Due to COVID-19, ASEP granted temporary use from April 2020 and until June 30th, 2021, free of charge, of 30 MHz to each of the 4 operators, between 1710 – 1780 MHz and 2110 – 2180 MHz (AWS Band).

due to COVID-19, ASEP granted temporary use until April 30, 2022, free of charge, of 30 MHz to each of the four operating companies, between 1710 – 1780 MHz and 2110 – 2180 MHz (AWS Band).

However, Digicel switched to the 10 MHz of Band 1900 and C&W Panama switched to the 10 MHz of Band 700.

Pursuant to Resolution AN No.

9319-Telco of November 18, 2015 based on Public Consultation No.

005-15, ASEP has confirmed that 140MHz are released in AWS Spectrum (1719-1780 MHz / 2110-2180 MHz), although it maintains the formula price calculation based on 1997 JD-080 resolution, which results in US $0.75 / MHz-Pop when the average price in Latin America is US $0.30 / MHz-Pop.

An authorization is pending from the regulator and the executive branch for a more reasonable price for the spectrum based on benchmark and current market status.

Through Resolution AN No.

13073-Telco was issued on January 21, 2019, Cable Onda (now Grupo Millicom) requested the reassignment of Bands 2500-2690 MHz for fixed wireless access using LTE Technology.

In response, Resolution AN No.

13073-Telco was issued, inviting all participants and interested third parties to submit technical contributions to promote the efficient use of the frequency band 2500 MHz to 2690MHz.

The 10 MHz in the 700 Band that have been granted for temporary use by C&W Panama, are reserved in the National Frequency Allocation Plan (PNAF), by recommendation of the International Telecommunications Union to comply with Public Protection, Relief Operations and Service Protocols.

However, based on the commercial benefits of using this spectrum and the reasons for the authorization of temporary use, C&W Panama obtained the use of the 10 MHz in the 700 Band, free of charge, until April 2022, subject to the lack of definition of a more efficient price for the purchase of spectrum and the current conditions due to the pandemic.

Concessions .

6 unchanged sentences

By means of Resolution AN No.

11208-Telco of May 3rd, 2017, renewed for the following twenty years the concession for the Public and Semi-Public Terminal Service (identified with No.

11208-Telco of May 3, 2017, renewed for the following twenty years the concession for the Public and Semi-Public Terminal Service (identified with No.

C&W Panama is the only operator that provides Public Telephone Service in Panama.

During 2021, efforts have been made with the regulatory authority to obtain authorization for disconnection and/or relocation of public phones, and a first relocation approval has been obtained for 48 units.

Fixed Services (Fixed-Line Telephony, Public and Semipublic Telephone) .

1 unchanged sentence

C&W Panama is a Type B concessionaire, with or without use of radio spectrum, subject to compliance with Law No.

31 of February 8th, 1996, Executive Decree No.

73 of 1997 and the Resolutions issued by the regulator regarding the fulfillment of quality goals for the provision of these services, such as the attention to recommendations issued by the International Telecommunications Union (ITU).

31 of February 8, 1996, Executive Decree No.

Mobile Services .

Through Contract DAF-034-2013, dated November 22nd, 2013, C&W Panama is authorized to install, maintain, manage, operate and commercially exploit the Mobile Telephone Service, in the assigned radio spectrum segments, which currently C&W Panama has 65 MHz (32.5MHz uplink + 32.5MHz downlink), under the prepaid and post-paid contract modalities, public and semi-public telephones, including supplementary services and other Mobile Telephony services, throughout Panama, which is valid until 2037.

Through Contract DAF-034-2013, dated November 22, 2013, C&W Panama is authorized to install, maintain, manage, operate and commercially exploit the Mobile Telephone Service, in the assigned radio spectrum segments, which currently C&W Panama has 65 MHz (32.5MHz uplink + 32.5MHz downlink), under the prepaid and post-paid contract modalities, public and semi-public telephones, including supplementary services and other Mobile Telephony services, throughout Panama, which is valid until 2037.

Internet Service:

Resolution AN No.

11370-Telco of June 26, 2017 establishes the conditions and quality parameters for providing internet service to the public.

These parameters became effective in 2018, setting new regulatory conditions and supervision of the service providers starting in 2019.

During May 2019, ASEP conducted an inspection intended to validate that the six goals established in Resolution AN No.

11370-Telco were duly configured in the system.

Currently, C&W Panama has complied with the regulatory requirements.

Pay Television Service .

3 unchanged sentences

The license was granted to retransmit audio and video signals through coaxial cable and fiber optics in the province of Panama, with a validity of 25 years, which was later extended to other provinces in the coverage area for the provision of paid TV service.

VTR / Cabletica

VTR is subject to regulation and enforcement by various governmental entities in Chile including the Chilean Antitrust Authority, the Ministry of Transportation and Telecommunications (the Ministry ) through the Chilean Undersecretary of Telecommunications ( SubTel ), the National Television Council ( CNTV ) and the National Consumer Service ( SERNAC ).

In addition to the specific regulations described below, VTR.com is subject to certain regulatory conditions which were imposed by the Chilean Antitrust Authority in connection with VTR.com ’s combination with Metrópolis Intercom SA in April 2005.

These conditions are indefinite and include, among others, (i) prohibiting VTR.com and its control group from participating, directly or indirectly through a related person, in Chilean satellite or microwave television businesses, (ii) prohibiting VTR.com from using its market power over programmers without justification, (iii) prohibiting VTR.com from obtaining exclusive broadcast rights, except for specific events, (iv) requiring VTR.com to offer its broadband capacity for resale of internet services on a wholesale basis, and (v) requiring VTR to maintain a uniform single price policy for all of the national territory.

In September 2019, VTR submitted a petition to the Chilean Competition Court ( TDLC ) to lift all the above-mentioned conditions.

VTR asserts that such conditions should only have been adopted for a transitional period and that they have been in place for an excessively long period during which the market structure and levels of competition have materially changed.

Objections were filed by other operators and by the Free Competition Prosecutor and SubTel.

In December 2019, the TDLC joined this procedure with an adversarial procedu re initiated by AMC Networks Latin America LLC ( AM C ) against VTR.

In 2019, AMC alleged that VTR had violated condition (ii) noted above by not agreeing to a content distribution agreement with AMC (see below for more information regarding this matter).

We can’t estimate at this time when this matter will be resolved.

In 2020, C&W Panama announced the suspension of the satellite prepaid television (DTH) service, as of January 10, 2021 in response to a commercial decision, which was authorized by ASEP.

Other Panamanian Regulation

Regulatory Fees :

Law 26/1996 established the obligation for the payment of a control, surveillance and inspection fee by companies that provide public services and that would allow to cover operating expenses of the entity, determining that it must be set annually by ASEP and that it should not exceed 1% of the gross income of the concessionaire’s immediately preceding year.

Currently, C&W Panama pays an amount equivalent to 0.25%, since it is within the first five years of the concession contract, after which it will increase by 0.25% every five years until reaching 1%.

Price increase :

C&W Panama, as a concessionaire within a competing market, may modify its prices provided that it advertises the price changes in two nationally-circulated newspapers at least 30 days before the new price takes effect.

Universal service obligations :

An additional process regarding coverage of maintenance cost of universal service law phones is ongoing.

Liberty Puerto Rico

Liberty Puerto Rico is subject to regulation in Puerto Rico by various governmental entities at the Puerto Rico and the U.S.

federal level, including the FCC and the TB.

The TB has primary regulatory jurisdiction in Puerto Rico at the local level and is responsible for awarding franchises to cable operators for the provision of cable service in Puerto Rico and regulating cable television and telecommunications services.

Our business in Puerto Rico is subject to comprehensive regulation under the Communications Act, which regulates communication, telecommunication and cable television services.

The Communications Act also provides the general legal framework for, among other things, the provision of telephone services, services related to interconnection between telephone carriers, and television, radio, cable television and direct broadcast satellite services.

The FCC and/or the TB have the authority to impose sanctions, including warnings, fines, license revocations and, in certain specific cases, termination of the franchise, although license revocation and franchise termination are rare.

The Communications Act specifies causes for the termination of licenses, including, for example, the failure to comply with license requirements and conditions or to pay fines or fees in a timely manner.

Such sanctions by the TB and/or FCC can be appealed to, and reviewed by, Puerto Rican courts and U.S.

federal courts.

In May 2018, the FCC established the UPR Fund to provide subsidies for the deployment and hardening of fixed wireline and mobile wireless communications networks in Puerto Rico.

Stage 1 of the UPR Fund made $51 million of new funding available for Puerto Rico telecommunications providers following Hurricanes Maria and Irma in 2017.

Stage 2 of the UPR Fund made additional funding available to providers of services over fixed wireline networks through a competitive bidding process, and to mobile wireless providers subject to those providers meeting certain conditions.

To be eligible for Stage 2 UPR funding for fixed services, Liberty Puerto Rico requested that TB designate it as an ETC, which the TB did in June 2018.

As part of its obligations as an ETC, Liberty Puerto Rico must offer services at a discounted rate to low income customers under the federal Lifeline Program and low-cost services to schools and libraries under the Schools and Libraries Program (E-Rate).

Both programs provide FCC subsidies to ensure access to telecommunications and broadband access services for specified classes of customers.

Liberty Puerto Rico began offering Lifeline services in April 2019.

On November 2, 2020, LCPR received preliminary approval from the FCC for an award of approximately $72 million through the UPR Fund.

The funds are in support of providing high-speed broadband access to all locations within 43 of Puerto Rico’s 78 municipalities, representing service to over 914,000 locations.

After LCPR submitted all required materials in June 2021, the associated funding with this program was authorized by the FCC.

Liberty Puerto Rico will have six years to complete the network expansions and upgrades, during which certain milestones must be met.

Liberty Puerto Rico is expected to receive approximately $72 million, which will be paid in 120 equal monthly payments over a 10-year period that began in July 2021.

The revenue recognized from such project will be reflected as “other revenue” in our revenue by product disclosures in our financial statements.

In 2021, we received $4 million in fixed funding.

With respect to Stage 2 UPR funding for mobile wireless providers, the FCC also established in September 2019 that mobile wireless providers providing service in Puerto Rico as of June 2017 were eligible to receive up to $254 million over three years based on their relative number of subscribers for such service as of June 2017.

In order to obtain such support, the mobile providers were required to confirm the number of mobile wireless subscribers they served as of June 2017, and obtain FCC approval of a plan that describes and commits to the methods and procedures that will be used to prepare for and respond to disasters in Puerto Rico.

Liberty’s predecessor wireless provider in Puerto Rico (AT&T) submitted the required documentation and in June 2020, the FCC authorized that entity to receive approximately $33 million in funding over three years or a total amount of $102 million in funding to expand, improve and harden the mobile networks in Puerto Rico and the U.S.

Virgin Islands.

That entity had previously obtained the required ETC designation in Puerto Rico.

Having purchased this business in connection with the AT&T Acquisition, Liberty Puerto Rico is receiving these funds.

The funds are paid in equal installments of $3 million and since the date of the AT&T Acquisition, we have received $40 million in funding, including approximately $38 million and $2 million received by our mobile operations in Puerto Rico and the U.S.

Virgin Islands, respectively.

Similarly, effective December 31, 2021, Liberty Puerto Rico acquired 96% of the outstanding shares of Broadband VI, LLC for $33 million, subject to certain post-closing adjustments.

On June 8, 2021, the FCC's Wireline Competition Bureau issued a public notice authorizing $85 million in Connect USVI funding for Broadband VI, LLC to deploy wireline networks and provide voice and broadband services to more than 46,000 locations in the U.S.

Virgin Islands.

Given its acquisition of Broadband VI, LLC, Liberty Puerto Rico will now be the recipient of these funds, as well as responsible for the network expansions and upgrades committed to in the bid.

Liberty Puerto Rico will have six years to complete the network expansions and upgrades committed to in the bid, and will receive FCC funding support over the course of ten years.

In addition to

expansions and upgrades, Broadband VI, LLC committed to a robust disaster preparation and response plan to harden its network and make it more resistant to storm damage.

Liberty Puerto Rico also is subject to certain regulatory requirements specific to it.

Liberty Latin America entered into a Letter of Agreement on July 1, 2020 with the DOJ and the U.S.

Department of Defense in connection with the AT&T Acquisition, and Liberty Communications PR entered into a Letter of Agreement on November 20, 2020 with the DOJ regarding an FCC application.

Further, Liberty Latin America and LCPR are subject to a Final Judgment, filed on February 3, 2021, in connection with the divestiture of certain assets to complete the AT&T Acquisition, which does not expire for 10 years.

Failure to comply with the Letters of Agreement or the Final Judgment could result in a variety of sanctions, including, for example, fines and/or license revocation.

In Puerto Rico, antitrust regulation is governed by the U.S.

Sherman Act, other federal antitrust legislation, and the Puerto Rico Anti-Monopoly Law.

In particular, the Sherman Act seeks to prevent anti-competitive practices in the marketplace and requires governmental review of certain business combinations, among other things.

The Puerto Rico Anti-Monopoly Law substantially parallels the Sherman Act and authorizes the Puerto Rico Department of Justice to investigate and impose competition-related conditions on transactions.

The Attorney General of Puerto Rico is permitted to investigate a transaction under federal law or under the Puerto Rico Anti-Monopoly Law.

Puerto Rico Law 5 of 1973, as amended, created the Puerto Rico Department of Consumer Affairs, which regulates marketing campaigns, publicity, and breach of service contracts, and prohibits false advertising.

Law 213 , which created the TB , requires that rates for telecommunication services be cost-based, forbids cross-subsidies and focuses on encouraging, preserving and enforcing competition in the cable and telecommunications markets.

Although Law 213 does not require Liberty Puerto Rico to obtain any approval of rate increases for cable television or telecommunication services, any such increases must be in compliance with Law 213 ’s requirements, including notification to the TB before such increases take effect.

The provision of cable television services requires a franchise issued by the TB .

Franchises are subject to termination proceedings in the event of a material breach or failure to comply with certain material provisions set forth in the franchise agreement governing a franchisee’s system operations, although such terminations are rare.

In addition, franchises require payment of a franchise fee as a requirement to the grant of authority, which is passed to Liberty Puerto Rico’s customers.

Franchises establish comprehensive facilities and service requirements, as well as specific customer service standards and monetary penalties for non- compliance.

Franchises are generally granted for fixed terms of up to ten years and must be periodically renewed.

Our pay television service in Puerto Rico is subject to, among other things, subscriber privacy regulations and must-carry and retransmission consent rights of broadcast television stations.

The Communications Act and FCC rules govern aspects of the carriage relationship between broadcast television stations and cable companies.

To ensure that every qualifying local television station can be received in its local market without requiring a cable subscriber to switch between cable and off-air signals, the FCC allows every qualifying full-power television broadcast station to require that all local cable systems transmit that station’s primary digital channel to their subscribers within the station’s market (the “must-carry” rule ) pursuant to the Cable Television Consumer Protection and Competition Act of 1992.

Alternatively, a station may elect every three years to forego its must carry rights and seek a negotiated agreement to establish the terms of its carriage by a local cable system, referred to as retransmission consent.

Communications Act requirements and FCC regulations applicable to the video services provided by Liberty Puerto Rico include, among other things:

(1) licensing of communications systems and facilities, such as various spectrum licenses;

(2) customer and technical service standards;

(3) ownership restrictions;

(4) emergency alert systems;

(5) disability access, including video description and closed captioning;

(6) competitive availability of cable equipment;

(7) equal employment obligations;

and (8) public, education and government entity access requirements.

Liberty Puerto Rico offers high-speed internet access throughout its entire footprint.

In March 2015, the FCC issued an order classifying mass-market broadband internet access service as a “telecommunications service,” changing its long-standing treatment of this offering as an “information service,” which the FCC traditionally has subjected to limited regulation.

The rules adopted by the FCC prohibited, among other things, broadband providers from:

(i) blocking access to lawful content, applications, services or non-harmful devices;

(ii) impairing or degrading lawful internet traffic on the basis of content, applications, services or non-harmful devices;

and (iii) favoring some lawful internet traffic over other lawful internet traffic in exchange for consideration (collectively, 2015 Restrictions ).

In addition, the FCC prohibited broadband providers from unreasonably interfering with users’ ability to access lawful content or use devices that do not harm the network, or with edge providers’ ability to disseminate their content, and imposed more detailed disclosure obligations on broadband providers than were previously in place.

On December 14, 2017, the FCC adopted a Declaratory Ruling, Report and Order (the 2017 Order ) that, in large part, reversed the regulations issued by the FCC in 2015.

The 2017 Order, among other things, restores the classifications of broadband internet access as an information service under Title I of the Communications Act , and mobile broadband internet access service as a private mobile service, and eliminates the 2015 Restrictions.

The 2017 Order does require ISPs to disclose information to consumers regarding practices such as throttling, paid prioritization and affiliated prioritization, and restores broadband consumer protection authority to the Federal Trade Commission.

In 2019, the United States Court of Appeals for the District of Columbia Circuit largely upheld the 2017 Order.

However, the current FCC may seek to re-impose the 2015 Restrictions or some variation thereof.

Legislative proposals regarding the net neutrality rules also are pending in Congress.

Liberty Puerto Rico is a participating provider in the Emergency Broadband Benefit Program (EBB), which provides discounts to eligible households to support internet connectivity during the COVID-19 pandemic.

The Infrastructure Investment and Jobs Act (Infrastructure Act), enacted on November 15, 2021, renamed the EBB Program the Affordable Connectivity Program (ACP).

The Infrastructure Act, among other things, reduced the standard benefit discount from $50 per month to $30 per month and requires a broadband provider to allow enrolled households to apply the ACP benefit to any of the provider’s internet service offerings.

The ACP launched on December 31, 2021.

Fixed-Line Telephony Services.

Liberty Puerto Rico offers fixed-line telephony services, including both circuit-switched telephony and VoIP .

Its circuit-switched telephony services are subject to FCC and local regulations regarding the quality and technical aspects of service.

All local telecommunications providers, including Liberty Puerto Rico , are obligated to provide telephony service to all customers within the service area, subject to certain exceptions under FCC regulations, and must give long distance telephony service providers equal access to their network.

Under the Communications Act , CLEC s, like us, may require interconnection with the ILEC , and the ILEC must negotiate a reasonable and nondiscriminatory interconnection agreement with the CLEC .

Such arrangement requires the ILEC to interconnect with the CLEC at any technically feasible point within the ILEC ’s network, provide access to certain unbundled network elements of the ILEC ’s network, and allow physical collocation of the CLEC ’s equipment in the ILEC ’s facilities to permit interconnection or access to unbundled network element services.

Therefore, we have the right to interconnect with the ILEC, PRTC .

We have negotiated an interconnection agreement with PRTC , and the physical interconnection between both companies has been activated.

All of the circuit-switched telephony and VoIP services of Liberty Puerto Rico are subject to a charge for the federal USF , which is a fund created under the Communications Act to subsidize telecommunication services in high-cost areas, to provide telecommunications services for low-income consumers, and to provide certain subsidies for schools, libraries and rural healthcare facilities.

The FCC has redirected the focus of USF to support broadband deployment in high-cost areas.

In addition, our circuit-switched telephony and VoIP services are subject to a charge for a local Puerto Rico Universal Service Fund, which was created by law to subsidize telecommunications services for low-income families under the federal USF Lifeline and Link-Up programs.

The FCC has adopted other regulations for VoIP services, including the requirement that interconnected VoIP providers and facilities-based broadband internet access providers must comply with the Communications Assistance for Law Enforcement Act, which requires carriers to provide certain assistance to federal law enforcement authorities.

VoIP providers are also required to offer basic and enhanced 911 emergency calling services, which requires disclosure to all VoIP customers.

VoIP providers are also subject to federal rules regarding, among other things:

(1) customer proprietary network information and c ustomer privacy protections;

(2) number portability;

(3) network outage reporting;

(4) rural call completion;

(5) disability access;

(6) back-up power obligations;

and (7) robocall mitigation.

Mobile Services .

Liberty Mobile Puerto Rico and Liberty Mobile U.S.

Virgin Islands offer mobile services in Puerto Rico and the U.S.

Virgin Islands.

The FCC regulates virtually all aspects of United States wireless communications systems, including spectrum licensing, tower and antenna construction, modification and operation, the ownership and sale of wireless systems and licenses, as well as the acquisition and use of wireless spectrum.

Local governments, such as in Puerto Rico and the U.S.

Virgin Islands, typically regulate the placement of wireless towers and similar facilities via zoning laws.

At present, neither the FCC nor state or local governments regulate specific service offerings or rate plans.

In addition, other federal and state agencies have asserted jurisdiction over consumer protection and the elimination and prevention of anticompetitive business practices in the wireless industry.

The specific issues as to which our United States mobile services operations are subject to regulatory oversight include:

roaming, interconnection, spectrum allocation and licensing, facilities siting, pole attachments, intercarrier compensation, USF contributions and distributions (such as through the UPR Fund), network neutrality, 911 services, consumer protection, consumer privacy protections, number portability, and cybersecurity.

Failure to comply with applicable regulations could subject us to fines, forfeitures, and other penalties (including, in extreme cases, revocation of our spectrum licenses), even if any non-compliance was unintentional.

VTR is subject to regulation and enforcement by various governmental entities in Chile including the Chilean Antitrust Authority, the Ministry through the SubTel , the CNTV and SERNAC .

In addition to the specific regulations described below, VTR is subject to certain regulatory conditions which were imposed by the Chilean Antitrust Authority in connection with VTR ’s combination with Metrópolis Intercom SA in April 2005.

These conditions are indefinite and include, among others, (i) prohibiting VTR and its control group from participating, directly or indirectly through a related person, in Chilean satellite or microwave television businesses, (ii) prohibiting VTR from using its market power over programmers without justification, (iii) prohibiting VTR from obtaining exclusive broadcast rights, except for specific events, (iv) requiring VTR to offer its broadband capacity for resale of internet services on a wholesale basis, and (v) requiring VTR to maintain a uniform single price policy for all of the national territory.

The provision of pay television services requires a permit issued by the Ministry .

Cable pay television permits are granted for an indefinite term and are non-exclusive.

As these permits do not involve radio electric spectrum, they are granted

without ongoing duties or royalties.

VTR.com has permits to provide cable pay television services in most of the medium- and large-sized markets in Chile.

As these permits do not involve radio electric spectrum, they are granted without ongoing duties or royalties.

VTR has permits to provide cable pay television services in most of the medium- and large-sized markets in Chile.

Cable television service providers in Chile are free to define the channels and content included in their services and are not required to carry any specific programming, except as described below.

1 unchanged sentence

Pay television operators are directly responsible for violation of such prohibitions.

Additionally, the Chilean Television Act (the Television Act ) requires pay television operators to offer a certain quota of cultural content and to distribute public interest campaigns.

Additionally, the Television Act requires pay television operators to offer a certain quota of cultural content and to distribute public interest campaigns.

The Television Act establishes a retransmission consent regime between broadcast television concession holders and pay television operators.

1 unchanged sentence

In addition, the Television Act requires that the technical or commercial conditions imposed by broadcast operators not discriminate among pay television operators.

Also, the Television Act establishes a must carry regime requiring pay television operators to distribute up to four local broadcast television channels in each operating area.

Also, the Television Act establishes a must carry regime requiring pay television operators to distribute at least four local broadcast television channels in each operating area.

The channels that must be carried by any particular pay television operator are to be selected by CNTV .

The full implementation of the retransmission and must carry regimes are still pending.

VTR.com ’s ability to change its channel lineup is restricted by an agreement reached with SERNAC in July 2012 and the general regulation established by SubTel in February 2014 (by the Telecommunication Services General Rulemaking).

This framework allows VTR.com to change one or more channels from its lineup after a 60-day notice period to its subscribers.

In such cases, VTR.com shall offer a channel of similar content and quality or proportional compensation.

Despite this, TVI, a mid-sized programmer in Chile, sued VTR in July 2016, after VTR’s decision to remove TVI’s channels from its channel lineup.

TVI argued that VTR was violating the condition set out in the 2005 VTR/Metrópolis merger conditions (as summarized above), which prohibits VTR from using its market power to unjustifiably refuse to contract with programmers.

The TDLC dismissed the lawsuit, but the Supreme Court, in May 2019, reversed that decision questioning the termination procedure applied by VTR.

The Supreme Court required VTR to open a new negotiation period and if no agreement was reached, to return TVI’s channels until the original contractual term is fulfilled.

As a result, the TVI channels have been reinstated on VTR’s channel lineup.

Using the precedent from the TVI case, in August 2019, AMC sued VTR claiming a breach of the condition related to contracting with programmers.

This process is still pending and was joined with VTR’s petition to lift the 2005 merger conditions as described above.

Additionally, a consumer association filed a class action against VTR requesting that VTR compensate clients with a permanent discount on the monthly rent for each change of channels or, in the alternative, the nullification of the power enshrined in VTR’s subscriber contract that authorizes the company to change its channel lineup.

This collective process is still pending.

VTR ’s ability to change its channel lineup is restricted by an agreement reached with SERNAC in July 2012 and the general regulation established by SubTel in February 2014 (by the Telecommunication Services General Rulemaking).

This framework allows VTR to change one or more channels from its lineup after a 60-day notice period to its subscribers.

In such cases, VTR shall offer a channel of similar content and quality or proportional compensation.

Despite this, using a mid-size programmer from former precedent, in August 2019, AMC sued VTR claiming a breach of the condition related to contracting with programmers, arguing that VTR was violating the condition set out in the 2005 VTR/Metrópolis merger conditions (as summarized above), which prohibits VTR from using its market power to unjustifiably refuse to contract with programmers.

This process is still pending.

A law passed in November 2017 requires all ISPs to apply for a public service concession for data transmission within three months of the passage of such law.

Because VTR.com operates via networks that were previously approved by SubTel , VTR.com timely applied and an approval is pending.

Because VTR operates via networks that were previously approved by SubTel , VTR timely applied and an approval is pending.

A law on internet neutrality prohibits “arbitrary blockings” of legal content, applications or services and the provision of differentiated service conditions according to the origin or ownership of the content or service provided through the internet.

5 unchanged sentences

The law also provides for the right of intellectual property owners to judicially request from ISPs the delivery of necessary information to identify the provider of infringing content.

A law passed in November 2017 requires all fixed and mobile ISP s to meet levels of quality of service, guarantee a minimum broadband throughput based on the offered speed, and provide their subscribers with a certified measurement tool allowing subscribers to verify this minimum service level, imposing fines or penalties to ISPs if the service level is not fulfilled.

During 2020, the Ministry issued the Regulation on the Organization, Operation, and Public Tender Mechanism of the

Independent Technical Body ( OTI ) which, according to this legal framework, will be responsible for performing the quality-of-service measurements.

A law passed in November 2017 requires all fixed and mobile ISPs to meet levels of quality of service, guarantee a minimum broadband throughput based on the offered speed, and provide their subscribers with a certified measurement tool allowing subscribers to verify this minimum service level, imposing fines or penalties to ISPs if the service level is not fulfilled.

During 2020, the Ministry issued the Regulation on OTI which, according to this legal framework, will be responsible for performing the quality-of-service measurements.

Also, SubTel issued a technical rule on the service levels that ISPs need to comply with in the provision of their internet service.

Finally, as required by the above regulation, major ISPs organized a Representative Committee and filed before SubTel a proposal of the terms and conditions of the public tender to designate the OTI (which is not approved by Subtel yet).

After approval, the industry through this Representative Committee called for a public auction which failed to appoint a provider, given no bidder applied with a valid offer, the Representative Committee has a filed a new proposal of terms and conditions for a public tender to designate the OTI again (which has not been approved by SubTel yet).

Fixed-Line Telephony and Mobile Services .

5 unchanged sentences

VTR has concessions to provide this service, which is non-exclusive, for a 30-year renewable term expiring in September 2025.

VTR.com holds concessions to provide fixed wireless local telephony service on the 3.5 GHz band in several regions of the country.

VTR holds concessions to provide fixed wireless local telephony service on the 3.5 GHz band in several regions of the country.

These concessions have renewable 30-year terms, expiring in 2036.

During 2018, SubTel partially froze 20MHz of the 50 MHz concession granted to VTR.com in order to evaluate future 5G concession auctions.

VTR.com is contesting SubTel’s legal ability to take such a measure.

In November 2018, Movistar asked the TDLC to rule on whether the decision to keep part of the spectrum at 3.5 GHz available for immediate deployment (with potential use for mobile services), was consistent with previous decisions requiring this band to be allocated to fixed services.

Although the TDLC rejected Movistar’s request, it considered that in order to allow the use of this already assigned spectrum for mobile services, SubTel should open public tenders to assign the concessions for mobile services.

This decision has been challenged before the Supreme Court by all interested parties, including VTR, and a final decision on the case is pending.

In January 2020, SubTel opened for public comments its plan for a 5G tender, which ended with a contest for four bands of spectrum:

1 unchanged sentence

Technical proposals were submitted in October 2020, and given that several competitors tied there was an auction to define the winners.

In February 2021, Entel, Movistar, WOM and Claro were awarded with several spectrum bands to provide mobile services using 5G technologies.

In February 2021, Entel, Movistar, WOM S.A.

and Claro were awarded with several spectrum bands to provide mobile services using 5G technologies.

Additionally, the concessions granted in this tender allow SubTel to modify the licenses in case of non-use or inefficient use of the spectrum.

With respect to mobile services, in 2009, SubTel awarded VTR.com a 30MHz license in the 1700/2100 MHz band.

With respect to mobile services, in 2009, SubTel awarded VTR a 30MHz license in the 1700/2100 MHz band.

The license has a 30-year renewable term, expiring in 2040.

1 unchanged sentence

Therein for the low macro-band from 0 to 1000 MHz the cap is 32% of the band, from 1001 MHz to 3000MHz the cap is 30% of the band, for 3001MHz band to 6000MHz band the cap is 30% and for higher than 6001MHz the cap is 25%.

VTR.com has concessions to provide fixed-line telephony in most major and medium-sized markets in Chile.

VTR has concessions to provide fixed-line telephony in most major and medium-sized markets in Chile.

Telephony concessions are non-exclusive and have renewable 30-year terms.

The original term of VTR.com ’s fixed-line telephony concessions expires in November 2025.

The original term of VTR ’s fixed-line telephony concessions expires in November 2025.

Long distance telephony services are considered intermediate telecommunications services and, as such, are also regulated by the Ministry .

VTR.com has concessions to provide this service, which is non-exclusive, for a 30-year renewable term expiring in September 2025.

VTR has concessions to provide this service, which is non-exclusive, for a 30-year renewable term expiring in September 2025.

There are no universal service obligations in Chile.

However, local service concession holders are obligated to provide telephony service to all customers that are within their service area or are willing to pay for an extension to receive service.

All local service providers, including VTR.com , must give long distance telephony service providers equal access to their network connections at regulated prices and must interconnect with all other public service concession holders whose systems are technically compatible.

All local service providers, including VTR , must give long distance telephony service providers equal access to their network connections at regulated prices and must interconnect with all other public service concession holders whose systems are technically compatible.

As a general rule, fixed-line telephony service providers are free to establish the rates directly charged to their customers, unless the Chilean Antitrust Authority concludes that due to a lack of sufficient competition in the market, rates should be fixed by SubTel .

However, SubTel sets the maximum rates that may be charged by each operator for interconnect charges, access charges between operators for calls originating on one network that are completed through connections with one or more networks of other providers.

Rate regulation on interconnection charges is applicable to all fixed-line and mobile telephony companies, including VTR.com .

Rate regulation on interconnection charges is applicable to all fixed-line and mobile telephony companies, including VTR .

The determination of the maximum rates that may be charged by operators for their fixed-line or mobile services are made on a case-by-case basis by SubTel and are effective for five years.

2 unchanged sentences

The Consumer Rights Protection Law has been interpreted to require that any raise in rates exceeding inflation must be previously accepted and agreed to by subscribers.

Although VTR.com disagrees with this interpretation, in July 2012, VTR.com reached an agreement with SERNAC that permits VTR.com to make adjustments to its published prices twice per year to adjust for inflation, except those services that are subject to rate regulation.

VTR.com is generally prohibited from increasing the rates over the inflation adjustment.

VTR.com may, however, cancel a subscriber’s contract after 12 months and propose a new contract with new rate provisions.

Once a year VTR.com may propose to its existing subscribers additional changes to their rates, which must be accepted by the subscriber for the rates to go into effect.

Although VTR disagrees with this interpretation, in July 2012, VTR.com reached an agreement with SERNAC that permits VTR to make adjustments to its published prices twice per year to adjust for inflation, except those services that are subject to rate regulation.

VTR is generally prohibited from increasing the rates over the inflation adjustment.

VTR may, however, cancel a subscriber’s contract after 12 months and propose a new contract with new rate provisions.

Once a year VTR may propose to its existing subscribers additional changes to their rates, which must be accepted by the subscriber for the rates to go into effect.

In 2012, the Chilean Antitrust Authority issued its regulation governing the on-net/off-net pricing practice in the mobile industry and the offering of bundled telecommunication services.

6 unchanged sentences

In 2018, a bill was enacted introducing significant new powers to SERNAC including a material increase in its ability to levy fines and compensations.

Cabletica is subject to regulation and enforcement by various governmental entities in Costa Rica, including the Ministry of Science and Technology, the Costa Rican Telecommunications Superintendence ( Sutel ), and the Consumer Support Office of the Ministry of Economy, Industry and Commerce ( MEIC ).

Cabletica and Telefonica are subject to regulation and enforcement by various governmental entities in Costa Rica, including the MICITT, Sutel, and the Consumer Support Office of the Ministry of Economy, Industry and Commerce.

Cabletica holds a telecommunications services concession, expiring in 2028, issued by Sutel that authorizes the deployment and operation of its wireline HFC network throughout the country.

4 unchanged sentences

and (iv) data links.

Telefonica has a total of 100 MHz allocated in two concessions.

For the first, i n 2011, MICITT awarded Telefonica a 10 MHz license in the 850 MHz band, a 30 MHz license in the 1800 MHz band and 20 MHz in the 1900/2100 MHz band.

These licenses have a 15-year renewable term, expiring on May 12, 2026, that may be extended an additional 10 years.

For the second, in 2018, MICITT awarded Telefonica a 20 MHz license in the 1800 MHz band and 20 MHz in the 1900/2100 MHz band.

These licenses have a 15-year renewable term, expiring on April 23, 2033, that may be extended an additional 10 years.

Cable television service providers in Costa Rica are free to define the channels and content included in their services and are not required to carry any specific programming, except as described below.

2 unchanged sentences

The Costa Rican General Telecommunications Law (art.138) establishes a retransmission consent regime between broadcast television concessionaires and pay television operators.

This regime provides that (i) the concessionaires must include within their programming the Costa Rican television channels that have coverage in at least sixty percent of the national territory, excluding Isla del Coco, which complies with at least fourteen minimum hours of daily transmission, and (ii) the reception of the signal complies with the minimum signal requirements established in this regulation, which have acceptable ratings and have the corresponding transmission rights.

This regime provides that (i) the concessionaires must include within their programming the Costa Rican television channels that have coverage in at least sixty percent of the national

territory, excluding Isla del Coco, which complies with at least fourteen minimum hours of daily transmission, and (ii) the reception of the signal complies with the minimum signal requirements established in this regulation, which have acceptable ratings and have the corresponding transmission rights.

The Regulation of Provision and Quality of Services of Sutel establishes minimum quality thresholds, such as minimum speeds, oversubscription, and delay.

Fixed-Line Telephony Services .

The current regulations separate VoIP fixed telephony from traditional fixed telephony (e.g., copper lines) and there is no fixed number portability.

Other Costa Rican Regulation

The powers of the Agency for the Protection of Data of Inhabitants (Prohab) are stipulated in the Law on the Protection of the Person against the Processing of Personal Data (Law No.

Its functions are focused on compliance with data protection regulations.

The Commission to Promote Competition (Coprocom) is a maximum deconcentration body attached to MEIC.

Its fundamental purpose is to comply with the provisions of the Law on Promotion of Competition and Effective Defense of the Consumer (Law No.

7472) through the protection and promotion of (i) the process of competition and free

competition, (ii) investigating and sanctioning monopolistic practices, and (iii) other restrictions related to the efficient functioning of the market.

Liberty Puerto Rico

Liberty Puerto Rico is subject to regulation in Puerto Rico by various governmental entities at the Puerto Rico and the U.S.

federal level, including the FCC and the Puerto Rico Telecommunications Regulatory Bureau ( TRB ).

TRB has primary regulatory jurisdiction in Puerto Rico at the local level and is responsible for awarding franchises to cable operators for the provision of cable service in Puerto Rico and regulating cable television and telecommunications services.

Our business in Puerto Rico is subject to comprehensive regulation under the United States Communications Act of 1934, as amended (the Communications Act ), which regulates communication, telecommunication and cable television services.

The FCC and/or the TRB have the authority to impose sanctions, including warnings, fines, license revocations and, in certain specific cases, termination of the franchise, although license revocation and franchise termination are rare.

Such sanctions by the TRB and/or FCC can be appealed to, and reviewed by, Puerto Rican courts and U.S.

federal courts.

In May 2018, the FCC established the Uniendo a Puerto Rico Fund ( UPR Fund ) to provide subsidies for the deployment and hardening of fixed wireline and mobile wireless communications networks in Puerto Rico.

Stage 1 of the UPR Fund made $51 million of new funding available for Puerto Rico telecommunications providers following Hurricanes Maria and Irma in 2017 (the 2017 Hurricanes ).

Stage 2 of the UPR fund made additional funding available to providers of services over fixed wireline networks through a competitive bidding process, and to mobile wireless providers subject to those providers meeting certain conditions.

To be eligible for Stage 2 UPR funding for fixed services, Liberty Puerto Rico requested that TB designate it as an Eligible Telecommunications Carrier ( ETC ), which the TB did in June 2018.

As part of its obligations as an ETC, Liberty Puerto Rico must offer services to low income customers under the federal Lifeline Program and low-cost services to schools and libraries under the Schools and Libraries Program ( E-Rate ).

Both programs provide FCC subsidies to ensure access to telecommunications and broadband access services for specified classes of customers.

Liberty Puerto Rico began offering Lifeline services in April 2019 and will bid on Funding Year 2022 for E-Rate subsidies.

In September 2019, the FCC established rules governing UPR Fund Stage 2 funding to support certain fixed and mobile providers of voice and broadband service in Puerto Rico.

The FCC stated that it would award up to $505 million over 10 years to eligible providers of fixed voice and broadband services in Puerto Rico through a single round competitive bidding process that would select one support recipient in each of the 78 municipalities in Puerto Rico, using a specified formula for evaluating bids.

Entities winning Stage 2 support must also:

(1) submit to the FCC’s Wireline Competition Bureau ( Bureau) a detailed network deployment plan as well as a plan that describes and commits to the methods and procedures that will be used to prepare for and respond to disasters in Puerto Rico;

and (2) participate in the FCC’s Disaster Information Report System, which is a web-based system that communications companies can use to report to the FCC communications infrastructure status during disasters.

On February 5, 2020, the Bureau released a Public Notice that established the application requirements and submission process for the UPR Fund Stage 2 Competition.

The Bureau later released an application form and instructions, and announced the application deadline.

On November 2, 2020 LCPR received preliminary approval from the FCC for an award of approximately $71.54 million through the UPR Fund.

The funds are in support of providing high-speed broadband access to all locations within 43 of Puerto Rico’s 78 municipalities, representing service to over 914,000 locations.

Liberty Puerto Rico is in the process of submitting all required materials to finalize its award and is awaiting final FCC action.

That entity had previously obtained the required ETC designation in Puerto Rico.

Liberty, having purchased that business in the AT&T Acquisition, will now receive those funds.

In Puerto Rico, antitrust regulation is governed by the U.S.

Sherman Act, other federal antitrust legislation, and the Puerto Rico Anti-Monopoly Law.

In particular, the Sherman Act seeks to prevent anti-competitive practices in the marketplace and requires governmental review of certain business combinations, among other things.

The Attorney General of Puerto Rico is permitted to investigate a transaction under federal law or under the Puerto Rico Anti-Monopoly Law.

The Puerto Rico Telecommunications Act of 1996 ( Law 213 ), which created the TRB , requires that rates for telecommunication services be cost-based, forbids cross-subsidies and focuses on encouraging, preserving and enforcing competition in the cable and telecommunications markets.

The provision of cable television services requires a franchise issued by the TRB .

In addition, franchises require payment of a franchise fee as a requirement to the grant of authority.