UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSI 

COMMISSIONERS: JosephJ. Simons, Chairman 

Noah Joshua Phillips 

Rohit Chopra 

Rebecca Kelly Slaughter 

Christine S. WIison 

In the Matter of 

PUBLIC 

Raging Wire Data Centers, Inc., 

a corporation, Docket No. 9386 

Respondent. 

CONSENT MOTION TO LIFT STAY AND AMEND THE COMPLAINT TO 

SUBSTITUTE THE NAME OF RESPONDENT 

For purposes of facilitating settlement and preserving resources, Complaint Counsel and 

Respondent RagingWire Data Centers, Inc. (''RagingWire'~ respectfully request the Commission 

to lift temporarily the stay in the above-captioned proceedings, entered on March 19, 2020, for 

the limited purpose of amending the Complaint under Rule 3.15 of the Commission Rules of 

Practice to substitute the name of Respondent. 1 The parties have agreed that NTT Global Data 

Centers Americas, Inc., as successor in interest to RagingWire, should be substituted into the 

action as Respondent in place of Raging Wire. Once this substitution is complete and there is a 

new caption, the parties anticipate being able to move quick1y to withdraw the matter from 

adjudication for consideration of a settlement. Acting now, rather than after the conclusion of 

the 30-day stay, will preserve party resources as well as those of third-party subpoena recipients, 

1 While consent motions tosubstitutea successor in interest fora Respondent are routinely granted by the 

Administrative Law Judge,seeln rePOMWonderjulet al.,Dkt. No. 9344 (Mar. 22, 2011), available at 

https://www ftc.gov/sites/default/files/documents/cases/201 l/03/l 10322aljordgrantmosubrollglobal.pdf, the cmrent 

Connnission-ordered stay of proceedings appears to cmtail theAU's authority todo soduringthependencyofthe 

stay. 

1 
Public

2 

a number of which have indicated that they intend to use the time afforded by the stay to respond 

to their subpoenas. Complaint Counsel, with the consent of Respondent’s Counsel,2 respectfully 

request that the Commission enter the proposed order.

Dated: April 2, 2020 Respectfully submitted,

 /s/ Linda Holleran Kopp 

Linda Holleran Kopp

Robin L. Wetherill

Division of Privacy and Identity Protection

Bureau of Consumer Protection 

Federal Trade Commission 

600 Pennsylvania Avenue, NW

Mailstop CC-8402

Washington, DC 20580

Telephone: (202) 326-2267 (Kopp)

Facsimile: (202) 326-3393 

Electronic mail: lkopp@ftc.gov (Kopp)

Complaint Counsel

 

2 Respondent’s Counsel also represents NTT Global Data Centers Americas, Inc. for purposes of this action.
Public

3 

STATEMENT REGARDING MEET AND CONFER

 

On March 23, 2020 and March 31, 2020, Complaint Counsel Linda Holleran Kopp and 

Counsel for Respondent Corey Roush communicated by email and by phone, and agreed to 

substitute NTT Global Data Centers America, Inc., as successor in interest to RagingWire Data 

Centers, Inc., as a Respondent In the Matter of RagingWire Data Centers, Inc., Docket No. 9386. 

The corporate filing effectuating the change in corporate status was filed by Respondent on 

March 30, 2020.

Dated: April 2, 2020 Respectfully submitted,

 /s/ Linda Holleran Kopp 

Linda Holleran Kopp

Robin L. Wetherill

Division of Privacy and Identity Protection

Bureau of Consumer Protection 

Federal Trade Commission 

600 Pennsylvania Avenue, NW

Mailstop CC-8402

Washington, DC 20580

Telephone: (202) 326-2267 (Kopp)

Facsimile: (202) 326-3393 

Electronic mail: lkopp@ftc.gov (Kopp)

Complaint Counsel
Public

UNITED STATES OF AMERICA

4 

BEFORE THE FEDERAL TRADE COMMISSION

COMMISSIONERS: Joseph J. Simons, Chairman

Noah Joshua Phillips 

Rohit Chopra

Rebecca Kelly Slaughter

Christine S. Wilson

In the Matter of

 PUBLIC

RagingWire Data Centers, Inc.,

a corporation, Docket No. 9386

Respondent.

[PROPOSED] ORDER GRANTING CONSENT MOTION TO LIFT STAY AND 

AMEND THE COMPLAINT TO SUBSTITUTE THE NAME OF RESPONDENT 

Upon consideration of the agreement of the parties, and it otherwise appearing 

proper to do so, the Consent Motion to Lift Stay and Amend the Complaint to Substitute 

the Name of Respondent is GRANTED.

IT IS HEREBY ORDERED that the stay in the above-captioned action is lifted 

for the sole purpose of amending the Complaint to substitute the name of Respondent. 

IT IS FURTHER ORDERED that the Complaint is amended to substitute NTT 

Global Data Centers Americas, Inc., as successor in interest to RagingWire Data Centers, 

Inc., into the action as a Respondent in place of RagingWire Data Centers, Inc.. 

IT IS FURTHER ORDERED that the case caption read:
Public

5 

UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

COMMISSIONERS: Joseph J. Simons, Chairman

Noah Joshua Phillips 

Rohit Chopra

Rebecca Kelly Slaughter

Christine S. Wilson

_____________________________________ 

In the Matter of ) 

 ) 

NTT GLOBAL DATA CENTERS ) 

AMERICAS, INC., as successor in ) 

interest to RagingWire Data Centers, Inc. ) DOCKET NO. 9386

a corporation. ) 

 ) 

____________________________________ )

By the Commission.

 April J. Tabor

Acting Secretary

SEAL:

ISSUED:

 
Public

CERTIFICATE OF SERVICE

I hereby certify that on April 2, 2020, I caused the foregoing document to be filed 

electronically through the Office of the Secretary's FTC E-filing system, which will send 

notification of such filing to:

6

April S. Tabor 

Acting Secretary

Federal Trade Commission

600 Pennsylvania Ave., NW, Rm. 

H-113 Washington, DC 20580

I also certify that I caused a copy of the foregoing document to be transmitted via 

electronic mail to:

The Honorable D. Michael 

Chappell Administrative Law Judge

Federal Trade Commission

600 Pennsylvania Ave., NW, Rm. 

H-110 Washington, DC 20580

I further certify that I caused a copy of the foregoing document to be served via 

electronic mail to:

Corey W. Roush

C. Fairley Spillman

Diana E. Schaffner

Akin Gump Strauss Hauer & Feld LLP

2001 K. Street, N.W.

Washington, DC 20006

(202) 887-4000

croush@akingump.com

fspillman@akingump.com

dschaffner@akingump.com

Counsel for Respondent RagingWire Data Centers, Inc.

April 2, 2020 By: /s/ Linda Holleran Kopp 

Linda Holleran Kopp

Federal Trade Commission

Bureau of Consumer Protection
Notice of Electronic Service 

I hereby certify that on April 02, 2020, I filed an electronic copy of the foregoing Consent Motion to Lift S

and Substitute Name of Respondent, with: 

D. Michael Chappell 

Chief Administrative Law Judge 

600 Pennsylvania Ave., NW 

Suite 110 

Washington, DC, 20580 

Donald Clark 

600 Pennsylvania Ave., NW 

Suite 172 

Washington, DC, 20580 

I hereby certify that on April 02, 2020, I served via E-Service an electronic copy of the foregoing Consent 

Motion to Lift Stay and Substitute Name of Respondent, upon: 

Linda Kopp 

Federal Trade Commission 

lkopp@ftc.gov 

Complaint 

Robin Wetherill 

Federal Trade Commission 

rwetherill@ftc.gov 

Complaint 

Corey Roush 

Partner 

Akin Gump Strauss Hauer & Feld LLP 

croush@akingump.com 

Respondent 

C. Fairley Spillman 

Partner 

Akin Gump Strauss Hauer & Feld LLP 

fspillman@akingump.com 

Respondent 

Diana Schaffner 

Akin Gump Strauss Hauer & Feld LLP 

dschaffner@akingump.com 

Respondent 

tay 

Linda Kopp 

Attorney