Attachment Attachment 1

This document pretains to FCN-NEW-20100419-00011 for New Application on a Foreign Carrier Notification filing.

IBFS_FCNNEW2010041900011_811215

                                                                                    StarHub, Inc.
                                                          Foreign Carrier Affiliation Notification

                                        ATTACHMENT 1

                             Foreign Carrier Affiliation Notification

       Pursuant to Section 63.11 of the Commission’s rules, StarHub, Inc. (“StarHub”) hereby
submits this foreign carrier affiliation notification, relating to an affiliation with the following
two foreign carriers: Mfone Co., Ltd (“Mfone”) in Cambodia, and Lao Telecommunications
Company Limited (“LTC”) in Laos. Mfone is a direct, wholly owned subsidiary of Shenington
Investments Pte Ltd (“Shenington”); Shenington also holds a 49 percent interest in LTC.
StarHub became affiliated with Mfone and LTC when Singapore Technologies Telemedia Pte
Ltd (“ST Telemedia”) acquired an indirect interest in Shenington.

Answer to Question 10

       ST Telemedia acquired its indirect interest in Mfone and LTC when its indirect
subsidiary, Asia Mobile Holdings Pte. Ltd. (“AMH”), acquired a 49 percent interest in
Shenington, in a transaction that closed on July 25, 2007.1 StarHub recently determined that
foreign carrier affiliation notifications had inadvertently not been submitted pursuant to Section
63.11(c) of the Commission’s rule, 47 C.F.R. § 63.11(c). Upon discovering this omission,
StarHub proceeded to prepare this notification.2

Answers to Questions 12 and 16

     Cambodia is a World Trade Organization (“WTO”) Member country. Laos is not yet a
WTO Member country, although its ascension to membership is in process.

       Mfone owns facilities in Cambodia; LTC owns facilities in Laos.

        With respect to the U.S.-Cambodia route, StarHub presumptively qualifies for non-
dominant classification pursuant to Section 63.10(a)(3) of the Commission’s rules. Mfone is a
wireless communications provider that lacks a 50 percent market share in Cambodia and is not
listed on the Commission’s List of Foreign Telecommunications Carriers That Are Presumed to
Possess Market Power in Foreign Telecommunications Markets.3



1
       The remaining 51 percent interest in Shenington is held by Thaicom Public Company
       Limited (“Thaicom”). Temasek Holdings (Private) Limited holds indirect interests in
       Shenington through both ST Telemedia and Thaicom, which when combined result in the
       affiliations addressed by this notice.
2
       Neither Mfone nor LTC holds Commission licenses, and thus, no Commission approval
       of ST Telemedia’s investments was required.
3
       See The International Bureau Revises and Reissues the Commission’s List of Foreign
       Telecommunications Carriers That Are Presumed to Possess Market Power in Foreign
       Telecommunications Markets, Public Notice, DA 07-233, at 3 (rel. Jan. 26, 2007).


        With respect to the U.S.-Laos route, the Commission presumes LTC to be dominant in
Laos, as it is listed on the Commission’s List of Foreign Telecommunications Carriers That Are
Presumed to Possess Market Power in Foreign Telecommunications Markets.4 StarHub agrees
that, with respect to the U.S.-Laos route, it will comply with the dominant carrier safeguards
contained in Section 63.10 of the Commission’s rules, subject to possible reclassification at a
later date.

       Accordingly, the instant notification is eligible for the post-consummation notification
procedures pursuant to Section 63.11(b) of the Commission’s rules.

Answer to Question 17

       Mfone is authorized to provide communications services in Cambodia. LTC is
authorized to provide communications services in Laos.

Answer to Question 18

      StarHub holds global facilities-based and resale authority pursuant to File Nos. ITC-214-
20000731-00473 and ITC-214-20000731-00474.

Answer to Question 19

       StarHub is dormant and thus does not currently provide service to Cambodia or Laos.

Answer to Question 20

       The following are the names, addresses, citizenship, and principal businesses of any
person or entity that directly or indirectly owns at least ten percent of the equity of StarHub:

               StarHub Ltd
               Address: 67 Ubi Avenue 1, #05-01 StarHub Green, Singapore 408942
               Citizenship: Singapore
               Principal Business: Communications and media services
               Relationship: 100 percent owner of StarHub, Inc.




4
       See id. at 6.


                                                  2


           Asia Mobile Holdings Pte. Ltd. (“AMH”)
           Address: 51 Cuppage Road #09-01, StarHub Centre, Singapore 229469
           Citizenship: Singapore
           Principal Business: Telecommunications and information technologies
           Relationship: 49.04 percent owner of StarHub Ltd

           Asia Mobile Holding Company Pte. Ltd. (“AMHC”)
           Address: 51 Cuppage Road #09-01, StarHub Centre, Singapore 229469
           Citizenship: Singapore
           Principal Business: Telecommunications and information technologies
           Relationship: 75 percent owner of AMH

           STT Communications Ltd (“STT Communications”)
           Address: 51 Cuppage Road #09-01, StarHub Centre, Singapore 229469
           Citizenship: Singapore
           Principal Business: Telecommunications and information technologies
           Relationship: 100 percent owner of AMHC

           Qtel Investment Holdings BSC (“QIH”)
           Address: Flat 51, Building 122, Road 1605, Block 31651, Manama, Kingdom of
              Bahrain
           Citizenship: Bahrain
           Principal Business: Investment holding company
           Relationship: 25 percent (plus one share) owner of AMH (thus, 12.27 percent
              indirect owner of StarHub Ltd)

           Qatar Telecom Q.S.C. (“Qtel”)
           Address: Qtel Building, 100 West Bay Centre, The Corniche, P.O. Box 217,
              Doha, Qatar
           Citizenship: Qatar
           Principal Business: Telecommunications and information technologies
           Relationship: 100 percent owner of QIH

           Singapore Technologies Telemedia Pte Ltd (“ST Telemedia”)
           Address: 51 Cuppage Road #09-01, StarHub Centre, Singapore 229469
           Citizenship: Singapore
           Principal Business: Telecommunications and information technologies
           Relationship: 100 percent owner of STT Communications5




5
    Of this amount, 0.01 percent of STT Communications’ shares are held by current
    members of ST Telemedia’s management, all of whom are citizens of Singapore, as
    nominees of and in trust for ST Telemedia.


                                          3


             Temasek Holdings (Private) Limited
             Address: 60B Orchard Road #06-18, The Atrium@Orchard, Singapore 238891
             Citizenship: Singapore
             Principal Business: Investment holding company
             Relationship: 100 percent owner of ST Telemedia6

             NTT Communications Corporation
             Address: 1-1-6 Uchisaiwai-cho, Chiyoda-ku, Tokyo 100-8019, Japan
             Citizenship: Japan
             Principal Business: Telecommunications and information technologies
             Relationship: 10 percent owner of StarHub Ltd

             Nippon Telegraph and Telephone Corporation
             Address: 2-3-1 Otemachi, Chiyoda-ku, Tokyo 100-8116, Japan
             Citizenship: Japan
             Principal Business: Telecommunications and information technologies
             Relationship: 100 percent owner of NTT Communications Corporation

Answer to Question 21

       There are no interlocking directorates between StarHub and Mfone or LTC. Mr. Anupam
Garg, Senior Vice President of International Business Development for ST Telemedia, is a
Director for both Mfone and LTC. In addition, Mr. Kek Soon Eng, Senior Vice President of
Management of Investee Companies for ST Telemedia, is a Director of Mfone.




6
      Temasek also holds indirect interests in StarHub Ltd through Aranda Investments Pte
      Ltd, Fullerton (Private) Limited, Temasek Fullerton Alpha Pte Ltd, Fullerton Fund
      Management Company Ltd, and subsidiaries of DBS Group Holdings Limited, which
      collectively are less than 10 percent.


                                             4



Document Created: 2010-04-19 15:31:20
Document Modified: 2010-04-19 15:31:20

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