|  | WorldCom Policy for Settlement-Free 
            Interconnection with Internet NetworksBackground and IntroductionJanuary 
            2001
 
 This document sets forth WorldCom's Policy for Settlement-Free 
            Interconnection with Internet Networks ("Policy"), also referred to 
            as "peering." The Policy extends WorldCom's existing North American 
            Policy to Europe and Asia-Pacific and adjusts the minimum operating 
            requirements to current traffic levels. The Policy is consistent 
            with settlement-free interconnection policies recently announced by 
            other Internet Networks. WorldCom will publish, maintain, and update 
            its Policy on the WorldCom public Web site at www.worldcom.com/peering/. Part 1 of the Policy details the interconnection requirements 
            that an Internet Network requesting interconnection (the 
            "Requester") must meet in order to qualify for settlement-free 
            interconnection. The Policy establishes separate requirements for 
            each of WorldCom's three regional Internet Networks, AS701 
            (WorldCom-US), AS702 (WorldCom-Europe), and AS703 (WorldCom-ASPAC), 
            with the requirements scaled for each network. WorldCom also will 
            consider requests for settlement-free interconnection on a national 
            level or in other regions of the world, with the same guiding 
            principles and with appropriately scaled interconnection 
            requirements. Part 2 of the Policy specifies the operational 
            requirements for interconnecting networks, which both the Requester 
            and WorldCom must satisfy. Finally, Part 3 delineates some general 
            notifications regarding the Policy. This Policy is effective January 5, 2001, and applies to all 
            requests for settlement-free interconnection with a WorldCom 
            Internet Network, either via dedicated connections ("direct 
            peering") or via traffic exchange at a multi-party network access 
            point ("public peering"). WorldCom will not apply the Policy with 
            respect to existing agreements for settlement-free interconnection 
            via dedicated connections until January 5, 2002. At this time, due 
            in part to inadequate measurement capabilities and WorldCom's 
            traffic levels at public peering points, WorldCom has no plans to 
            apply the Policy with respect to existing agreements for 
            settlement-free interconnection at multi-party network access 
            points, and WorldCom will provide at least 12 months notice to 
            existing public peers before doing so. 1. Interconnection Requirements
 
              
              
                | 1.1 | Geographic Scope. The Requester shall 
                  operate facilities capable of terminating customer leased line 
                  IP connections onto a router in at least 50% of the geographic 
                  region in which the WorldCom Internet Network with which it 
                  desires to interconnect operates such facilities. This 
                  currently equates to 15 states in the United States, 8 
                  countries in Europe, or 2 countries in the Asia-Pacific 
                  region. The Requester also must have a 
                  geographically-dispersed network. In the United States, at a 
                  minimum, the Requester must have the ability to meet 
                  WorldCom's Internet Network at an East Coast location, a West 
                  Coast location, and at least two Midwest locations. |  
                | 1.2 | Traffic Exchange Ratio. The ratio of the 
                  aggregate amount of traffic exchanged between the Requester 
                  and the WorldCom Internet Network with which it seeks to 
                  interconnect shall be roughly balanced and shall not exceed 
                  1.5:1. |  
                | 1.3 | Backbone Capacity. The Requester shall 
                  have a fully redundant backbone network, in which the majority 
                  of its inter-hub trunking links shall have a capacity of at 
                  least 622 Mbps (OC-12) for interconnection with WorldCom-US, 
                  45 Mbps (DS-3) for interconnection with WorldCom-Europe, and 
                  12 Mbps for interconnection with WorldCom-ASPAC. |  
                | 1.4 | Traffic Volume. The aggregate amount of 
                  traffic exchanged in each direction over all interconnection 
                  links between the Requester and the WorldCom Internet Network 
                  with which it desires to interconnect shall equal or exceed 
                  150 Mbps of traffic for WorldCom-US, 30 Mbps of traffic for 
                  WorldCom-Europe, and 5 Mbps of traffic for WorldCom-ASPAC. |  2. Operational Requirements
 The following operational requirements apply both to the 
            Requester and to the WorldCom Internet Network with which it desires 
            to enter into a settlement-free interconnection arrangement: 
              
              
                | 2.1 | Each Internet Network must establish and 
                  maintain traffic exchange links of a sufficient robustness, 
                  aggregate capacity, and geographic dispersion to facilitate 
                  mutually acceptable performance across the interconnect links. |  
                | 2.2 | Each Internet Network must operate a fully 
                  functional 24x7 Network Operations Center. |  
                | 2.3 | Each Internet Network must set next hop to be 
                  itself, the advertising router of the network. Each Internet 
                  Network will propagate such routes to its transit customers 
                  with its own router as next hop. |  
                | 2.4 | Each Internet Network shall implement "shortest 
                  exit routing" and advertise routes consistent with that 
                  policy, unless both Internet Networks mutually agree otherwise 
                  based on special circumstances. |  
                | 2.5 | Each Internet Network must operate a fully 
                  redundant network, capable of handling a simultaneous 
                  single-node outage in each network without significantly 
                  affecting the performance of the traffic being exchanged. |  
                | 2.6 | The two Internet Networks must exchange with 
                  each other prior to any settlement-free interconnection 
                  agreement a free shell or PPP account for testing and auditing 
                  purposes related to routing. This will be used for 
                  confirmation of traffic flows, troubleshooting of 
                  interconnection-related issues, and auditing purposes. |  
                | 2.7 | Each Internet Network must be responsive to 
                  unsolicited email and network abuse complaints, as well as 
                  routing and security issues, providing a knowledgeable 
                  technician within a two-hour period after notice. |  
                | 2.8 | For the purposes of Requirements 1.2 and 1.4 of 
                  the Policy, all traffic is to be measured over interconnection 
                  links. In the event that such links do not exist, the two 
                  Internet Networks may establish temporary test links for the 
                  purposes of traffic measurement. In the event that 
                  establishing such links is not feasible or desirable, traffic 
                  will be measured at peak utilization, based upon a 
                  representative sample consistent with industry practice. |  
                | 2.9 | For the purposes of Requirements 1.2 and 1.4 of 
                  the Policy, the traffic to be measured will include only what 
                  is being exchanged by the two Internet Networks and their 
                  respective customers (excluding any transit traffic). |  3. General Policy Notifications
 
              
              
                | 3.1 | The two Internet Networks must enter into a 
                  Mutual Non-Disclosure Agreement and an Interconnection 
                  Agreement. |  
                | 3.2 | The requirements in Part 1 must be met at the 
                  time the request for settlement-free interconnection with 
                  WorldCom is made. |  
                | 3.3 | All requirements of the Policy must continue to 
                  be met to continue a settlement-free interconnection 
                  relationship. Status under the policy will be evaluated 
                  periodically. In the case of a change in ownership or control 
                  of an Internet Network with which WorldCom has an 
                  interconnection agreement, status under the policy will be 
                  evaluated within 30 days of such change. |  
                | 3.4 | WorldCom will continue to monitor the 
                  development of the Internet and traffic conditions and make 
                  appropriate changes in this Policy as the Internet continues 
                  to evolve. WorldCom reserves the right to modify this Policy 
                  at any time. Any contractual rights shall arise out of a 
                  bilateral interconnection agreement, not this Policy. |  
                | 3.5 | All requests for settlement-free 
                  interconnection should be submitted to WorldCom via e-mail at 
                  peering@wcom.com. 
                  An Internet Network may submit a request for interconnection 
                  once per calendar quarter. |  |