Abstract image representing the idea of circumventing or finding a loophole

Dish’s Legal Obligations & Ting’s Acquisition

In the leadup to the merger between T-Mobile and Sprint, Dish acquired Sprint’s prepaid subscribers and made a number of commitments to regulators. Among other obligations, Dish agreed to offer nationwide, postpaid service:1

DISH must offer nationwide postpaid retail mobile wireless service to American consumers within one year of the closing of the sale of the Prepaid Assets.

Peter Adderton, the original founder of Boost Mobile, brought Dish’s commitment up on Twitter:

Stephen Stokols, the CEO of Boost (now a Dish-owned company) pointed out that Dish met its commitment after acquiring Ting:


Technically, Stokols is right. Ting offers postpaid service, and it’s available nationwide.

I feel like Dish found a loophole. I’m guessing regulators perceived “nationwide postpaid” to be a proxy for something like “high-end service for the mass market.” Ting is a small-scale carrier that largely caters to budget-conscious consumers.

Hands shaking

Dish And AT&T Announce Network Services Agreement

Today, AT&T and Dish announced that they are entering into a Network Services Agreement (NSA).1 Here’s the key bit from Dish’s press release:

[DISH announced a] Network Services Agreement (NSA) with AT&T, making AT&T the primary network services partner for DISH MVNO customers. Through this agreement, DISH will provide current and future customers of its retail wireless brands, including Boost Mobile, Ting Mobile and Republic Wireless, access to best-in-class coverage and connectivity on AT&T’s wireless network, in addition to the new DISH 5G network.

SEC Filing Insights

An SEC filing provides more insights than Dish’s press release. The deal between AT&T and Dish involves a minimum payment of five billion dollars over ten years.

DISH has agreed to pay AT&T at least $5 billion over the course of the ten-year term of the NSA, subject to certain terms and conditions.

People are already suggesting that Dish got a bargain by striking this deal for only five billion. They may be misunderstanding the arrangement. I expect the amount Dish pays to AT&T will depend on how heavily Dish relies on AT&T’s network. While five billion dollars is a minimum Dish, I think it’s likely Dish will end up paying more.2

Network Access

Dish has committed to activating a certain portion of its subscribers on AT&T’s network, but the SEC filing suggests Dish is permitted to activate some subscribers on other networks:

Under the NSA, AT&T becomes the primary network services provider for DISH, as DISH has committed to activate on AT&T’s network at least a minimum percentage of certain of its MVNO subscribers in the U.S. who receive services through a third-party network and to cause no less than a specified percentage of certain of its domestic roaming data usage for DISH’s MNO subscribers to be on AT&T.

Roaming

It looks like most of AT&T’s roaming agreements may be extended to Dish (emphasis mine):

AT&T will provide DISH with…services in all U.S. geographic areas…where AT&T or any AT&T affiliate has the right to use another wireless service provider’s network and is authorized to extend such right to DISH.
I’m unsure how often AT&T is prohibited from extending its roaming agreements to other parties. Further, it’s possible Dish won’t take advantage of some of AT&T’s roaming arrangements due to cost considerations.3

Prioritization

The SEC filing briefly touches on prioritization:

Under the NSA, AT&T will provide DISH postpaid and prepaid customers with similar quality of service as compared to certain AT&T postpaid and prepaid customers.
While the phrasing is vague, I expect it indicates Dish subscribers will have a QCI of 8 for regular data use on AT&T’s LTE network. That’s the same QCI for regular data received by the large majority of consumers on AT&T-branded plans.

Spectrum Use

Dish has extensive spectrum holdings that AT&T may take advantage of:

The NSA also provides an avenue for AT&T to deploy portions of DISH’s spectrum to support DISH customers on the AT&T network, by allowing AT&T the right, but not the obligation, to request to use portions of DISH’s spectrum.

Other Brands

The filing makes it clear that access to AT&T’s network is available for both existing and future brands under Dish (emphasis mine):

[The agreement provides] customers of Boost, Ting and Republic Wireless and all future DISH brands coverage on AT&T’s network.

Speculation

My hunch is that this deal is good news for both AT&T and Dish. For a while, I’ve heard people express skepticism about whether Dish actually intends to build its own network. I’m finding the skepticism less plausible as time goes on. With the backing of AT&T, Dish can focus on building out a 5G network in dense areas while offloading to AT&T for more extensive coverage.

The new agreement is probably bad news for T-Mobile. The company’s stock closed today a bit over 3% down from its opening price.4

Ting Launches New Plans & Pricing

Ting’s subscribers and some of the company’s other assets were acquired by DISH earlier this year. At the time of the acquisition, Elliot Noss, the CEO of Ting’s parent company, wrote:

Soon, DISH will be offering much improved pricing.

Today, Ting is delivering on that promise. The carrier just launched four new plans. While almost all Ting subscribers will get better prices through the new plans, an email I received stated, “Existing customers are also welcome to keep their current Ting Mobile rates should they wish to.”

Ting’s new Flex option is similar to Ting’s old pay-for-what-you-use model. A base price of $10 per month provides service with unlimited minutes and texts. Subscribers on the Flex plan then pay $5 per gigabyte of data used (half of Ting’s old $10 per gigabyte rate).

Ting’s new plans include three other options that may make sense for heavier data users. Each option includes unlimited minutes and texts:

Set 5 GB

  • $25 per month
  • 5GB of full-speed data each month
  • No restrictions on mobile hotspot data

Unlimited

  • $45 per month
  • 22GB of full-speed data each month
  • Up to 12GB of data per month can be used for mobile hotspots

Unlimited Pro

  • $60 per month
  • 35GB of full-speed data each month
  • Up to 30GB of data per month can be used for mobile hotspots

Subscribers on these plans that run out of full-speed data can use additional data at sluggish, 2G speeds at no extra charge.

“Unlimited” done right

I’m normally critical of carriers offering “unlimited” plans that cap full-speed data. While the word “unlimited” in the names of some of Ting’s plans could be misleading, Ting is transparent about data caps. The screenshot below comes from Ting’s Plans page:

Ting "Unlimited" plan characteristics screenshot

Ting’s transparency stands in contrast to the usual strategy of burring limitations in fine print.

Ting post-acquisition

I’m not sure how much confidence I have in Ting following the acquisition by DISH. While Ting currently offers a great customer experience and some of the best support agents in the industry, I’m less optimistic about the long term.

I’m guessing Ting’s subscriber base will eventually be folded into DISH or another carrier owned by DISH. In all likelihood, the transition will lead to deterioration in the quality of subscribers’ experiences.1

Ting To Drop Hotspot Pricing

Ting has been offering one of the best deals for mobile hotspot service. For $25 per month, subscribers using a Franklin R850 Hotspot get 30GB of data over Sprint’s network. It looks like that deal will come to a close:1

After extending it as long as possible, Ting Mobile will be discontinuing its special hotspot pricing plan after October 14, 2020. Any customers currently using this pricing plan will receive an email informing them that they will switch to regular Ting Mobile rates from their first full billing cycle after this date.

I expect this change in policy is due to either (a) T-Mobile’s merger with Sprint or (b) DISH’s acquisition of Ting’s subscriber base.

Rumors About A Potential Consumer Cellular Sale

Earlier this week, Mike Dano of Light Reading reported on rumors about Consumer Cellular:

Consumer Cellular – one of the nation’s largest MVNOs – is in discussions with other companies for a potential sale, according to two people familiar with the issue. The discussions appear to be in the early stages, and may not result in a transaction.

An acquisition of Consumer Cellular’s roughly four million subscribers would be big news. The new rumors combined with Ting’s sale of its subscriber base earlier this month raise the possibility that MVNOs are feeling squeezed.

As Sprint folds into T-Mobile, network operators may be increasing what they charge MVNOs for network access. MVNOs may also worry their offerings will become less competitive as DISH enters the marketplace. The CEO of Ting’s parent company, Elliot Noss, suggested something along those lines:

For many quarters now, I have discussed the outlook for Ting Mobile within the context of how DISH enters the market and what that would mean for the industry competitively. I absolutely believe that they will be very aggressive with pricing, which has two implications for our announcement. First, it would make remaining as a retail MVNO that much more difficult. Second, it will make their entry into the market that much more successful. The net result is that DISH is well positioned to disrupt the US mobile market.

Reflecting On Ting

Ting had a phenomenal reputation for its customer support. Given that lackluster support is par for the course in the cellular industry, it’s particularly impressive that Ting managed to buck the trend while offering a low-cost service.

Earlier this month, DISH acquired Ting’s subscriber base. DISH’s customer support has a lousy reputation. I’m worried that a lot of what made Ting special will disappear as subscribers gradually become integrated with DISH.

While I’m sad to see Ting changing, the recent moves were reasonable for Tucows, Ting’s parent company. Here’s a screenshot I took showing the change in Tucows’ share price in the handful of hours after the news about the acquisition of Ting’s subscribers went public:

Tucows' stock rose over 16%

Changes for Ting subscribers

I’ve found Elliot Noss, Tucows’ CEO, and many of Ting’s employees to be unusually straight talkers. While understandable, it was a bit disappointing that some of the usual candor was missing in statements and discussions related to the acquisition. Still, light was shed on important factors that could affect Ting subscribers going forward. The excerpts below come from Elliot Noss’ Reddit post.

Pricing

For those following, DISH is now becoming a fourth competitor in mobile with T-Mobile taking over Sprint. We are going to help them grow their business and try and make tens of millions of customers as happy and satisfied as you all have been. And for you, soon, DISH will be offering much improved pricing.

I have no reason to doubt that prices will come down. Ting did a great job pushing forward pay-for-what-you-use pricing, but Ting’s data charges haven’t been competitive with the rest of the market for several years. While I expect data prices will come down, I don’t know if DISH will let Ting’s customer base stick with pay-for-what-you-use pricing indefinitely.

Customer support

Our customer service people will still be the ones answering your calls, etc. for the first while and before they are not we intend to help DISH be able to provide service that has you just as happy.

In my view, Ting managed to offer far better support than any of the major carriers offer their own, postpaid customers. I seriously doubt DISH’s customer support will offer the same quality that Ting’s support agents offer.

Ting’s Subscriber Base Acquired by DISH

News came out today that most of Ting’s assets, including Ting’s mobile customers, have been acquired by DISH:1

Effective August 1, 2020, most Ting Mobile customers across the U.S. became customers of DISH. These customers will continue to use their current phones and will enjoy the same rates and excellent customer experience. As with DISH’s recently acquired Boost customers, these Ting Mobile customers will have access to the new T-Mobile network.

Tucows, Ting’s original parent company, will retain ownership of Ting’s technology stack. Tucows plans to offer Mobile Service Enabler (MSE) solutions to help wireless carriers run their businesses. Here’s a bit of information I received from Tucows’ PR team:

Now, as a Mobile Services Enabler (MSE), Tucows is opening up its mobile platform and the foundation on which the MVNO Ting Mobile was built. The same platform that helped Ting Mobile create some of the happiest mobile customers and top Consumer Reports lists year over year. DISH is becoming Tucows’ first MSE customer—starting with Ting Mobile, and adding Boost Mobile’s estimated 9 million customers in the 2nd half of 2021.

The Verizon Network

So far, I haven’t seen Ting directly address the plans for the carrier’s Verizon-based service. An email from Ting’s PR team said there would be “no data migration, service interruption or billing changes.”

I expect customers on Ting’s Verizon-based service will not be forced to migrate immediately. I’m not sure what will happen in the long term.

Ting’s New Verizon Service: Initial Impressions

Last week, the mobile virtual network operator Ting launched a new service running over Verizon’s network. The day it launched, I went to Ting’s website to order a SIM card and begin trialing the service.

Ordering process

Initially, I ran into a bug during Ting’s checkout process that prevented me from finishing an order. I think this was a launch-day issue with Ting’s website. A few hours later, the bug seemed to be fixed, and I ordered a SIM card. I paid about $5 for the SIM, shipping, and taxes:

Ting receipt showing about $5 in total charges

Activation process

Two days after placing my order, a SIM card arrived at my door. I popped it into a Moto G7 Play and went to Ting’s website to activate service. Activation wasn’t difficult, but it felt a bit clunky. Some of the information I had to provide when ordering the SIM card needed to be re-entered during the activation stage.

Once I’d finished the process on Ting’s website, I restarted my phone. The service worked immediately.

Service quality

Coverage has been great, as I expected from Verizon’s network. I’ve run speed tests under a variety of signal strengths, and the speeds have mostly been solid:

Several speed test results from Ting's Verizon service showing decent speeds

As expected, I didn’t notice any throttling of regular data speeds. However, it looks like most video traffic is throttled to a maximum of about 4Mbps:1

Test results suggestive of video throttling

Possible low prioritization

I’m suspicious that Ting has low priority on Verizon’s network (despite some suggestions to the contrary).

Using the app Network Signal Guru, I found my data traffic to generally be associated with a QCI value of 9. I expect a QCI of 9 on Verizon’s network is indicative of low priority.

Network Signal Guru test result hsowing a QCI of 9 for Ting's Verizon service.

I also found low speeds in the downtown area of Boulder, Colorado despite having a strong signal:

Speed test result from Downtown Boulder, CO showed a speed of 0.1Mbps

The most plausible explanation I can come up with for the lousy speeds is a combination of congestion and low priority.2

In most situations, low-priority service won’t cause subscribers much trouble. My best guess is that Ting users have the same priority level as Verizon’s prepaid customers, most Xfinity Mobile customers, and customers on Verizon’s cheapest post-paid unlimited plan.3 I reached out to Ting to see if the company could provide any additional information about prioritization. At the time of writing, I have not heard back.

Tentative view

So far, I’m a big fan of Ting’s new service: Ting offers way better coverage than it used to, Ting didn’t raise its prices, and the company continues to offer awesome customer support.

Downsides

Despite my generally positive view, I have a few quibbles about Ting’s new service:

  • I don’t think Ting adequately discloses video throttling. I don’t remember any notifications about it during the ordering process. That said, I don’t think the video throttling is a big deal. It may actually help subscribers keep their data charges low.
  • Ting’s coverage page states: “By piggybacking on America’s largest network, Ting makes sure you’re covered from coast-to-coast. Period.” This implies that subscribers will be covered by Verizon’s network. It would be more transparent for Ting to indicate that most, but not all, subscribers can access Verizon’s network. Further, Ting said this on its coverage page for a little while before the service over Verizon’s network even launched.
  • Ting doesn’t allow subscribers to choose a network directly. Instead, potential subscribers provide information about their devices and where they live and are then matched with a network. I understand why Ting uses this approach for most website visitors. Many people would end up confused and choose networks poorly if they had to choose a network on their own. Still, I wish there was an option for knowledgeable users to explicitly sign up for Verizon’s network.4
  • Wi-Fi calling doesn’t seem to be supported at this time.

Ting Launches Service Over Verizon’s Network

Yesterday, the MVNO Ting released a video and a blog post announcing that the company will now offer service over a third network.

Hidden network partners

In the announcements, Ting acknowledges contractual obligations that prohibit the company from explicitly mentioning all of the networks the company offers service over:

Why not just say directly who our network service providers are? We’re not allowed. Pretty simple, really. We have contracts with each of our carrier partners…Detailed in those contracts is how, exactly, we’re allowed to refer to the specific networks we offer service on.

Due to the restrictions, Ting makes roundabout statements like: “Ting Mobile offers service on every network but AT&T.”

Fortunately, I’m not bound by the same contractual arrangements that restrict Ting. Before yesterday’s announcement, Ting offered service over T-Mobile and Sprint’s networks. As of yesterday, the company now offers service over Verizon’s network as well.

Better coverage with Verizon

Michael Goldstein, Ting’s Chief Revenue Officer, was surprisingly candid in the announcement video. He acknowledged that Ting hasn’t always been able to offer stellar coverage (emphasis mine):

For years, people have saved a ton of money on Ting. People have been thrilled with our customer experience and our customer support. But we have heard at times that people felt they were sacrificing a little something on coverage. With this addition and with this portfolio of networks we have, I think Ting Mobile pretty much gives people everything they need: the savings, the experience, and the coverage. All at once.

An improved value proposition

Despite the fact that Verizon’s network offers the best coverage in the nation, Ting didn’t change its pricing structure. Ting’s now has some of the best options on the market for families that don’t use a lot of data. That said, Ting’s options for heavy data users and single-line plans aren’t as enticing.

Discovering your Ting network

I’m really optimistic about Ting’s new service, and I’ve gone ahead and ordered a SIM card to trial it. I plan to update my review of the carrier as soon as I get a chance.

To keep things simple and stay in accordance with the contractual obligations discussed earlier, Ting doesn’t explicitly tell each subscriber the network he or she is being placed on. Instead, potential customers enter their addresses and their devices’ IMEI numbers, and Ting’s automated system places appropriate SIM cards in customers’ carts. In most cases, I expect new Ting customers will be placed on Verizon’s network, but there will be exceptions. Customers with certain kinds of devices and customers living in certain regions may still be matched with Sprint or T-Mobile’s networks.

To verify that you’re being matched with Verizon’s network, take a look at the type of SIM card that ends up in your cart during the checkout process. Verizon SIM cards will be marked as V1:

Ting V1 Verizon SIM card checkout screenshot

MVNOs Hiding Their Host Operators

Mobile virtual network operators (MVNOs) often appear to be prohibited (or at least discouraged) from explicitly acknowledging which networks they run over. Still, it seems that most MVNOs don’t have to keep their host networks entirely secret. The effects of these policies can be kind of funny.

Red Pocket

The MVNO Red Pocket operates over all of the major U.S. networks, but it only mentions Sprint by name. The following screenshot comes from a part of Red Pocket’s website that lists the networks the company offers service over:



The unnamed networks are color-coded to match the colors used in the host networks’ branding: AT&T in blue, T-Mobile in pink, and Verizon in red.

Ting

The MVNO Ting currently operates over Sprint and T-Mobile’s networks. Verizon will be added to the list soon. Today, Ting published a blog post about the upcoming addition. Ting still isn’t naming the networks it works with, but the company is making easy-to-interpret statements like: “In 2020, Ting will be on every major coast-to-coast network except AT&T.” The blog post included a video where the names of each network the company works with were censored out: