Letter dated March 2

COMMENT submitted by AT&T CORP

Americas I Application

2019-03-27

This document pretains to ITC-214-19930103-00258 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2141993010300258_1640377

James J.R. Talbot AT&T Services, Inc. Assistant Vice President- 1120 20th Street NW Ste. 1000 Senior Legal Counsel Washington, D.C. 20036 Phone: 202.457.3048 Fax: 202.463.8066 E-mail: jjtalbot@att.com March 27, 2019 Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: American Telephone and telegraph Company, et al., The Americas I Submarine Cable System, File No. ITC-214-19930103-00258 Dear Ms. Dortch: The Americas I Consortium supplements and amends the above-referenced Application filed on March 6, 2019 (“Application”) as follows. The table set forth below replaces the table set forth in Appendix B, pages 3-4, of the request to modify the Section 214 authority previously granted to construct and operate the Americas I Cable System. The modification seeks, inter alia, Federal Communications Commission approval to add Atlantic Telecommunication Operation Company Limited (“ATOC”) as a licensee of the Americas I Cable System. No individual or entity other than those set forth in the table below holds a ten percent or greater direct or indirect equity or voting interest in ATOC. Blackrock, Inc. (“Blackrock”) has been added to this new table. Although Blackrock will not hold a ten percent or greater indirect interest in ATOC if the multiplier is used to calculate Blackrock’s interest, use of the multiplier is inappropriate in this instance pursuant to the Note to Section 63.18(h) of the FCC’s rules, 47 C.F.R. § 63.18(h), note. This is because the indirect interest of ATN International, Inc. (“ATNI”) in ATOC is above 50 percent and is controlling, and Blackrock holds a direct interest in ATNI. The multiplier is not used to dilute an indirect interest in a submarine cable landing licensee held through the controlling ownership chain of that licensee. Percentage of Citizenship Principal Name Address Equity/Voting or Country Business Held Atlantic Commerce House, Teleconnection Wickhams Cay 1, POB British 100% of Holdings Company 3140, Road Town, Virgin Telecom ATOC Limited Tortola, British Virgin Islands (“ATHC”) Islands, VG111TBC GTT International 79 Brickdam Barbados Telecom 100% of

2 Percentage of Citizenship Principal Name Address Equity/Voting or Country Business Held Service SRL Georgetown, Guyana ATHC (“GTT SRL”) Guyana Telephone & 79 Brickdam 100% of GTT Telegraph Company Georgetown, Guyana Guyana Telecom SRL Ltd (“GTT”) Room 2801A, Lippo Hong Kong Golden Centre, Tower 1, Telecom Company Hong Kong Telecom 20% of GTT 89 Queensway, Hong Limited (“HKGT”)* Kong 500 Cummings Center, ATN International, Suite 2450, Beverly, USA Telecom 80% of GTT Inc. (“ATNI”)** MA 01915 55 East 52nd Street New Investment 10.2% of Blackrock, Inc. USA York, NY 10055 Management ATNI P.O. Box 12030 St. Thomas, 27.4% of Cornelius B. Prior Jr. USA Retired U.S. Virgin Islands ATNI 00801 * ATOC was informed by representatives of HKGT in May 2018 that HKGT is 100% owned by Datang Telecom International Technology (Hong Kong) Co., Ltd. (“DTIT”) and that DTIT is indirectly controlled, but not wholly owned, by China Academy of Telecommunications Technology. ATOC does not have any additional information about HKGT’s ultimate ownership. ** ATNI is a publicly traded company listed on the NASDAQ (Ticker: ATNI). As of the date of this filing, no individual or entity, has reported to the Securities and Exchange Commission that it holds a direct or indirect 10 percent or greater equity or voting interest in ATNI, other than the individual and the entity listed in the table above.

3 Please let us know if you have any questions. Respectfully submitted, Of Counsel: James Talbot Mark D. Schneider AVP- Senior Legal Counsel Sidley Austin LLP AT&T Services, Inc. & 1501 K Street, NW Assistant Secretary Washington, DC 20005 AT&T Corp. (202) 736-8058 mschneider@sidley.com CC: Jodi Cooper, International Bureau David Krech, International Bureau U.S. Coordinator, EB/CIP, U.S. Department of State Office of Chief Counsel/NTIA, U.S. Department of Commerce Defense Information Systems Agency, Attn: GC/DOI

CERTIFICATION I am authorized to enter this certification on behalf of Atlantic Teleconnection Operating Company Limited. All of the information contained herein is true and correct to the best of my knowledge and belief. Dated: March 27, 2019 Christopher Pepper c/oATOC 500 Cummings Center, Suite 2450 Beverly, MA 01915 (561) 414-5543


Document Created: 2019-03-27 14:40:45
Document Modified: 2019-03-27 14:40:45
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