What is your full title?
My full title is senior vice president and general counsel, Comcast Cable Communications.
What are your duties in this role?
Comcast is a global media and technology company with two primary businesses: Comcast Cable and NBCUniversal. As general counsel for Comcast Cable, I serve the nation's largest video provider, largest residential Internet service provider (ISP), and fourth-largest phone company, providing legal advice across a wide range of subjects and directing a team of attorneys and legal professionals who provide day-to-day support to the company's operating departments at headquarters and to our employees across 39 states and Washington, D.C.
What does your average week look like?
The great thing about my job is that there is no average week. We work at the intersection of media and technology, which is a rapidly changing environment. The most pressing and interesting thing I do this week is likely not to be on my calendar at the start of the next week.
How is the legal department structured and how many lawyers do you have in-house? Do they specialize in certain areas?
With few exceptions, our legal department resides at our corporate headquarters here in Philadelphia. We have about 40 attorneys and we're organized into five practice groups — litigation, content acquisition, licensing and technology, general operations and advertising sales. Each practice group is composed of attorneys and legal professionals who are dedicated to specific business groups and/or subject areas. The goal is to provide high-quality legal services by professionals who have the depth of understanding of both the law and the business in order to help achieve the company's business objectives. That means not simply dealing with the problems as they arise but looking ahead to solve issues before they become problems for the business.
How much a part of your job are compliance functions?
One of my functions is serving as the chief compliance officer for the cable division. I work closely with our corporate legal department and the internal audit group to ensure that the company is in compliance with applicable laws and regulations by identifying compliance risks, developing policies and training programs for our employees and monitoring compliance with company policies and procedures.
Has your department's budget grown or shrunk in the past year?
Our budget has grown slightly over the past year, primarily as a result of the unpredictable nature of the litigation process. When a number of cases become active simultaneously, it tends to drive up costs. Other costs have remained relatively consistent over the past year.
How has social media impacted your work in the past few years?
I can't say that social media has had a significant impact on the way we practice law, but there have been a number of positive benefits. For example, it has affected how we get information and perform background research. We've also seen a shift to social media in the way we identify candidates for open positions. More and more of our recruiting activity is happening through social media. At the same time, the growth of social media has vastly expanded the number of outlets of expression and reduced the amount of time one has to respond to a request for information. We work closely with our communications professionals, often under very tight time pressure, to make sure we get the facts straight before providing a comment or quote.
How many outside law firms do you most commonly use?
Because of our national footprint, we have to have a firm in every state where we do business, although activity levels vary greatly from state to state. Then there are firms that we rely on because of their expertise in a particular area of law. There are perhaps 25 to 30 of these who do a significant amount of work in a given year.
Have you recently or will you soon go through a convergence of the number of outside firms used? Explain.
Probably not. We tend to be very deliberate about adding firms to our list of approved counsel and very careful about assigning legal matters to outside counsel. So, we believe we currently have a pretty good mix of firms we can rely on to meet our needs for outside legal services. However, we are also very active managers of our outside counsel relationships and we continually adjust the number and mix of firms to make sure the company has effective, efficient and cost-effective outside counsel representation.
How do you most typically select outside counsel — i.e., existing relationships, RFPs, other GC recommendations?
It's a mix of a number of things. As I mentioned, we have a number of "go-to" firms we rely on for certain types of legal work and over the years have cultivated relationships with attorneys at the firms who understand our business and our culture. When we need additional firms, we generally rely on referrals/recommendations and our own research. We haven't relied much on formal RFPs, although, on occasion, we present a legal matter to multiple firms for informal proposals on how they would staff, manage and bill for the matter. We have also been very active in attending conferences and events where we have an opportunity to meet attorneys at women- and minority-owned law firms and we've made a conscious effort to include women- and minority-owned firms on our list of approved firms and engage them in meaningful legal work on behalf of the company.
What are your thoughts on outside law firms conducting surveys of your experience with them?
It's not something we see very often. Part of me thinks that if a firm needs a survey to know whether they are doing a good job or not, then the communication between client and firm isn't very good. The other part of me thinks that if a firm believes it to be a valuable tool and takes the feedback seriously, then surveys may be a good thing.
Do you hire the law firm or the lawyer? Why?
Generally speaking, we hire the lawyer, but we have relationships with a number of firms that have well-respected practice groups across a range of subjects and afford us the convenience of one-stop shopping. Not only do we look to engage lawyers who have the knowledge and experience to deliver excellent results, we prefer to engage lawyers we enjoy working with and who understand our corporate culture. So much of the relationship with outside counsel is based on trust in the individual's knowledge, commitment, integrity and judgment, which takes time to develop.
What is an example of something an outside counsel has done really well?
We are always impressed with attorneys who take the time to learn our business, both the financial and operational aspects. We are fortunate to have a number of firms we have worked with for years that have a deep understanding of our people and procedures, which has paid dividends in a number of cases I can think of. They know whether and why something is important to us and that allows us to move quickly to a more strategic discussion. We also tend to be very sensitive about the issue of conflicts. Firms that take a more conservative view of conflicts tend to earn our loyalty.
Do you use alternative fee arrangements and, if so, how often and in what form?
We use a number of alternative fee arrangements — fixed fee arrangements, incentive arrangements, fee caps and blended fee arrangements, for example. Alternative fee arrangements may account for 15 to 20 percent of our billing relationships, roughly speaking. In appropriate cases, we think they give us a better ability to predict and contain costs, which are goals I imagine most law departments are aiming for.
What keeps you up at night?