Attachment 20170112145644-773.p

20170112145644-773.p

SUPPLEMENT

Supplement

1998-09-10

This document pretains to ITC-214-19980910-00642 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2141998091000642_1392970

            Categories of Services for
DDDB(DD




          GLOBAL FACILITIES
          GLOBAL FACILITIES
          GLOBAL RESALE SERVICE
          INDIVIDUAL FACILITIES—BASEL
          INTERCONNECTED PRIVATE LINE
          LIMITED GLOBAL FACILITIES—BA
          GLOBAL RESALE SERVICE
  C       LIMITED GLOBAL FACILITIES—BASE
  O       LIMITED GLOBAL RESALE SERVICE
  [       INMARSAT AND MOBILE SATELLITE SERVICE
  C       SWITCHED RESALE SERVICE
  G       TRANSFER OF CONTROL
  C       SUBMARINE CABLE LANDING LICENSE
  C       INTERNATIONAL SPECIAL PROJECT




  Description of Application:


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                                                                             See public burden estimate on reverse,                                                                  FCC FORM 159


September 8, 1998

VIA    OVERNIGHT MAL

Federal communications C       imission
International Bureau
Telecommunications Divi
P.O. Box 358115
Pittsburgh, PA. 15251—511

       Attention:      Diat    Zornell
                       Intel   tional Burea

       Re:             Autt    ity of Come:    Interr    on     Ltd.(CCI     for Section 214
                       Intel   tional Globs    aciliti   Ba:     Authorit    ind Global Resale
                       Autt    ity
Dear Sir or Madam:

Enclosed for filing with        Commissic      are t     orl    al and s     (6) copies of the
application of Comeard In      r1ational Ltd   ~CI) fi   aut    ‘ity pursu   t to Section 214 of
the Communications Act.        [ is requesti   1) glo!    fai   ties—base    uthority to acquire
interests in unaffiliated, U   owned cire      s and     If—c   uits in a    orized facilities to
provide international tele«    imunication     service   bet    en the U     ted States and all
international points; 2) gli   1 authority —   resell    ermm   onal, sw     ied services of all
unaffiliated carriers to pro   > internatiot   switcl    . se   ces betw     1 the United States
and all international poiu      served by      ose c;    lers   3) globa     wuthority to resell
international private lines     provide in     nation     pt    te line :    vices between the
United States and all inter    ional points    ad 4) ;   ho1     to resell   ternational private
lines interconnected to th     rublic swite   1 netv k ( SN") at > or both ends to
provide international, swi_ ed services ~«tween le ~.ited Statc. and all countries
found to offer equivalent resell opportunities to U.S. carriers.

As required by the Commission‘s Rules, enclosed is a check in the amount of $745.00,
payable to the F.C.C. Please stamp—date the extra copy of this application and return it in
the self—addressed, stamped envelope. Any questions regarding the enclosed application
should be addressed to the undersigned.

iectfufly sub


Dewey L. Ne

Enclosures


                                       Before the
                 FEDERAL COMMUNICATIONS COMMISSION
                                    Washington, D.C.


In the matter of Comcard International Ltd.                   } FileNo.L       C—98

Application for authority pursuant to
Section 214 of the Communications Act
of 1934, as amended, for global authority
to operate as a facilities—based carrier and
as an international resell carrier                             }




Comcard International (CCI) , by its undersigned director, hereby              juests global
authority, under Section 214 of the Communications Act of 1934, ;               amended, 47
U.S.C. & 214 (1996), and Section 63.18 of the Commission‘s Rules, |            ‘.R. & 63.18
(1996), to provide international telecommunications services betw.               the United
States and various international points.

1.     TheProposedInternationalServices

CCI requests four types of authority in this application, all of which     > eligible for
streamlined processing.      CCI specifically requests (1) global          rilities—based
authority pursuant to Section 63.18 (e) (1), to acquire ownersh              interests in
unaffiliated, U.S. licensed facilitiese to provide international telee       munications
services between the United States and all international points; ?) authority
pursuant to Section 63.18 (e) (2) of the FCC‘s Rules, 47 C.F.R. &          18 (e)(2), to
resell international, switched services of all authorized carrieas to provide
international switched services between the United States and all international
points served thereby; (3) global authority pursuant to Section 63.18 (e)(2)(a) of the
FCC‘s Rules, 47 C.F.R. 7 63.18 (e)(2)(B), to resell international private lines to
provide international private line services between the United States and all
international points, other than those requiring special authority because of their
listing on the mostly recent exclusion list; and (4) authority pursuant to Section
63.18 (e)(2)(B) of the FCC‘s Rules, 47 C.F.R. & 63.18 (e)(2)(B), to resell
international, private lines interconnected to the public switched network ("PSN")
at one or both ends to provide international switched services between the United
States and countries found to offer equivalent resell opportunities to U.S. carriers.

                                                                      Page 1, FCC Section 214
                                                    Application of Comcard International Ltd.


CCI is hereby requestin         a) facilities—based authority to obtain inter        s in U.S
authorized facilities, and      nnecting facilities not appearing on the Ex          sion Lis!
(b) authority to resell in      national private lines to provide internatior         switche
service between the Unit         States and countries designated by the Co           rission t
provide equivalent resell       pportunities; and (c) authority to resell it          —nationa
private lines to provide        ivate line services to countries not appea           g on th
Exclusion List. CCI is nc       iffiliated with any foreign carriers or admin        ‘ations a
defined in Part 63 of the (     nmission‘s Rules,

CCI will report its acq         ition of interest in facilities, including ear        stations
channels of communica           n to satelites, and submarine cables in              s circui
addition/circuit status refp    t files under Section 43.82 of the Commissio          Rules 4
C.F.K. & 43.82. CCI will        ;so report its resell of international, switched :    vices an
international private linee     ) provide international private line and swite       1 service
in its traffic reports filed:   rsuant to Section 43.61 of the Commission‘s L        es.

CCI believes that the add       competition which its expanded market entr           vill bring
to the market will beneil       the consumers of the United States overse             services
These benefits include co       etitive pricing and increased availability of        ariety o
service options. A grar         of this application will therefore, further          ie publi
interest.


IL.    The Applicant

CCI is a corporation org.       zed and existing under the laws of Delawar             CCI is :
privately held corporat         | and —no CCI officer is an employee,                gent, 0|
repréesentative of a foreig!    lecommunications entity. Further, CCI is n           affiliatec
with any foreign carriers       defined by Part 63 of the Commission‘s Rule:

CCI is a new entrant in t.. telecommunications industry which has no: | reviously
received authority under Section 214 to provide any telecommunications services or
operate any facilities which provide such services.      Upon the grant of this
application, CCI will become an authorized non—dominant facilities—based carrier
subject to    Section   214 of the Communications Act,              as amended, and        the
Commission‘s Rules.


IH.    Public Interest Considerations

The Commission‘s publicly stated policy goals for the regulation of the United States

                                                                       Page 2, FCC, Section 214
                                                      Application of Comcard International Ltd.


international telecommunications market to promote effective competition in the
U.S. telecommunications market, including the market for the international
telecommunications services, to prevent anti—competitive conduct in the provision for
international services or facilities and to encourage foreign governments to open
their communication markets. The Commission also has moved to establish an
effective global communications market that could result in reduced rates, increased
quality and new services. In addition, the Commission has found that effective
competition directly advances the public interests and the Commission‘s paramount
goal of making available a rapid, efficient, worldwide wire and radio
communications service with adequate facilities at reasonable charges.

The grant of CCTI‘s request for resale and facilities—based authority to provide
international services will further the Commission‘s policies of facilitating increased
competition within the U.S. international telecommunications services market and is
therefore in the public interest.


IV.    Information Required Under Section 63,.18

As required under Section 63.18 of the Commission‘s Rules, CCI submits the
following information:

              (a)    Name and Address of Applicant
                     Comcard International Ltd.
                     2231 E. Grand Avenue
                     Santa Ana, CA. 92705

              (b)    CCI is a corporation organized undei' the laws of the state of
                     Delaware.

              (c)    Correspondence concerning this application should be sent to:

                    _Dewey Newman, Ph.D;, Director
                     Comcard International Ltd.
                     11689 Newbridge Court
                     Reston, VA. 20191

             (d)     CCI is a new entrant in the telecommunications industry.
                     It has never received authority pursuant to Section 214 of the
                     Communications Act of 1934, as amended, and under the
                     Commission‘s Rules. CCI lacks market power that would
                     allow control of prices to the detriment of market competition.
                                                                  Page 3, FCC, Section 214
                                                 Application of Comcard International Ltd.


(e)    CCI requests Section 214 authority to: (1) operate as a
       facilities—based carrier pursuant to terms and conditions
       of Section 63.18 (e)(1); and (2) operate as a resale carrier
       pursuant to the terms and conditions of Section 63.18 (e)(2).
       Specifically, CCI seeks to (1) acquire capacity in full and
       half—circuits in submarine cables, and establish channels of
       communication with U.S. owned satellite systems, to provide
       international telecommunications services between the U.S.
       and all international points;(2) resell the international services
       of all authorized common carriers, except affiliated carriers
       regulated as dominant on the route to be served to provide
       international telecommunications services between the U.S.
       and all international points; (3) resell international private
       lines to provide international private line services between
       U.S. and all international points; and (4) resell international
       private lines for the provision of international switched services
       between the U.S. andall countries that the Commission finds
       provide U.S. carriers with effective competitive opportunities.

8      CCI does not seek authority to provide services which are
       not referenced under paragraph(e) of Section 63.18 of the
       Commission‘s Rules.

(g)    The authority requested in this application is categorically
       excluded from environmental processing as defined by
       Section 1.306 of the Commission‘s Rules, 47 C.F.R. & 1.306,
       obviating the needfor an environmental assessment.

(h)    CCI certifies that it is not affiliated, either directly or
       indirectly, with any foreign carrier (as that part is defined
       in Part 63 of the Commission‘s Rules) or with any U.S.
       carriers whose facilities—based services it proposes to resell.
       Should the substance of the certification cease to be true,
       CCI shall notify the Commission immediately of any
       affiliation with any foreign carrier or any U.S. carriers whose
       services CCI seeks to resell.

(i)    No individual holds 10% or greater ownership or management
      —interest in the corporation.




                                                    Page 4, FCC, Section 214
                                   Application of Comcard International Ltd.


               (J)    As required by Section 63.18 (1) of the Commission‘s Rules,
                      47 C.F.R. & 63.18 (1), CCI certifies that it has not agreed
                      to accept not shall it accept in the future special concessions
                      as defined by the Commission‘s Rules, directly or indirectly
                      from any foreign carrier or administration with respect to
                      traffic or revenue flows between the U.S. and any foreign
                      country for which CCI may be authorized to serve.




                                  CONCLUSION

CCI is legally, financially, and technically qualified to provide the services for which
it requests authority. For the reasons stated above, CCI affirms that the public
interest, convenience, and necessity would be furthered by a grant of this Section
214 application.

Respectfully submitted,
Comcard International




Dewey f?c;wman, NDirector
Comcard International Ltd.
11689 Newbridge Ct., Reston VA 20191

Dated: September 8, 1998




                                                                   Page 5, FCC, Section 214
                                                  Application of Comcard International Ltd.


                                CERTIFICATION



I hereby certify that Comcard International Ltd. is not affiliated with any

foreign carrier. CCI is not affiliated with any facilities—based carrier whose

services it intends to resell. CCI has not agreed to accept special concessions

directly or indirectly from any foreign carrier or administration with respect to

traffic or revenue flows between the U.S. and any foreign country which CCI may

serve under the authority granted under this part and will not enter into such

arrangements in the future.


To the best of my knowledge and belief, all statements made in this application are

true and correct.




Dewey Newman, Director
Comcard International Ltd.
11689 Newbridge Ct.
Reston, VA 20191




                                                                  Page 6, FCC, Section 214
                                                 Application of Comcard International Ltd.


                  ANTI—DRUG ABUSE CERTIFICATION



Applicant certifies that, to the best of its knowledge, information, and belief, neither

applicant nor any party to this application is subject to a denial of federal radio

licenses under Section 5301 of the Anti—Drug Abuse Act of 1988.




Respectfully submitted,




o~<AZamm
   Dewey L. Newman, Director
   Comcard International Ltd.
   11689 Newbridge Ct.
   Reston, VA 20191




                                                                   Page 7, FCC, Section 214
                                                  Application of Comcard International Ltd.



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