Attachment 20170112164148-387.p

20170112164148-387.p

SUPPLEMENT

Supplement

1998-09-30

This document pretains to ITC-214-19980930-00670 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2141998093000670_1395826

Catagori~:—“%kvices for 214 A / (Streaml/ine/Non—streamli hss f 32 (C ASSIGNMENT OF LICENSE DDD‘KDDD GLOBAL FACILITIES—BASED SE GLOBAL FACILITIES—BASED/GLOE GLOBAL RESALE SERVICE INDIVIDUAL FACILITIES—BASE INTERCONNECTED PRIVATE LINE LIMITED GLQBALFACILITIES—LA GLOBAL RESALE SERVICE C LIMITED GLOBAL FACILITIES—B C LIMITED GLOBAL RESALE SERVICE C1 INMARSAT AND MOBILE SATELLITE SERVICE C SWITCHED RESALE SERVICE C TRANSFER OF CONTROL C SUBMARINE CABLE LANDING LICENSE INTERNATIONAL SPECIAL PROJECT Description of Application:

LAW OFFICES OF THOMAS K. CROWE, P.C. 2300 M STREET, N.W. sUITE 800 WwASHINGTON, D.C. 20037 TELEPHONE (202) 973—2890 FAX. (202) 973—2891 E—MAIL tkcerowe@mci2000.com September 30, 1998 BY HAND Federal Communications Commission International Bureau—Telecommunications P.O. Box 358115 Pittsburgh, PA 15251—5115 Re: Section 214 Global Resale Application; JPS Consulting & Trading Corp. Dear Sir/Madam: Please find enclosed an original and six copies of JPS Consulting & Trading Corp.‘s Application for Section 214 Global Resale Authority. Also enclosed is an FCC Form 159 and a check in the amount of $780.00 payable to the "Federal Communications Commission" to cover the requisite filing fee. Please file—stamp and return the extra copy of this filing in the self—addressed, stamped envelope enclosed for this purpose. Questions regarding this filing should be directed to the undersigned. Thomas K. Crowe, Counsel for JPS Consulting & Trading Corp. Enclosures to: Kaan Kamali

mommmmmmmmmemmmns READ INSTRUCTIONS CAREFULLY APPROVED BY omBs 3080—.0: 89 BEFORE PROCEEDING FEDERAL CCMMUNICATIONS COMMISSION REMITTANCE ADVICE 358115 PAGE NO._ _____ OF ______ 1) LOCKBOX # ieSETONA PAYVER_INFOR MEEH—_ PAYER NAME( [ paymg by credit card, enti name ai actly as it appears on your card) (3) TOTAL AMOUNT PAID (doilars and conts) JPS Consulting & trading Corp. 780 .00 4) STREET ADORESS LINE NO. 1 11 Broadway TTCL—A)4— ]992@22"00(or}o 5) STREET ADDRESS LINE NO. 2 Syvite_ 851 6 cny n stare (® a» cooe New York NY 10004 DAYT ME TELEPHONE NUMBER (inchide is code) (10) COUNTRY CODE (ifn x in U.S.A.) A 212344 8234 x[tiRer at sns ce !")APP‘JCMI’NAMEflp-mbyM card enter na maunlynunwanonyowcm 17) STREET ADORESS LINE NO. 1 (13) STREET ADDRESS LINE NO. 2 14) CY (15) STATE (19 uP CoDE 17) DAYTME TELEPHONE NUMBER (Inci sde area code} (15) COUNTRY CODE (if not in U.S.A.) jogesAbFE NeE tep:USsEcommaUAnonN:SHEErsoni1s9:B) (Z0A) PAYME) T TYPE CODE (PTC) : ~ Srrint C iNFou MaAT FOR (PTC) IN BLOCK 20A c | u | T | 1 |,780.00 (234) FCC CODE 1 [24A) FCC CODE 2 T‘ua; FCC CALL sIGNOTHER iD (208) PAYME] T TYPE CODE (PTC) Taimauaiamy aam ree ue Fom ic aLOcK 208 (238) FCC CODE 1 [L_ [ | : K2«8) FCC CODE 2 190) FCC CALL SIGN/OTHER ID (200) PAYMENT TYPE CODE (PTC) 210 ouantty (220) ;-EE DUE FOR (’TC‘IhDCK 20C 23C) FCC CODE 1 [ _| | : rzlc) FCC CODE 2 190) ce cauL. steavormer io (200) PAYMENT TYPE CODE (PTC) @iorauainty |@zn ree oue rom (Prc) im alock z0o TZJD) FCC CODE 1 _ [ [ | s (24D) FCC CODE 2 25) =*LAXPAYER«INFORMAEION:—;(REQUIRED) . Av MB Wn And) PAYER TIN 0| 1] 1) 33 |2 |6 12 |2 |1 [WEIAPPLICANT TIN SECIION E_ — CERTIFICATION 27) CERTIFICATION STATEMENT ; Thomas K. Crowe , Certify under penalty of perjury that the foregoing and supporting information (Prmt Name) are true and correct to the best of my knowledge, infomation and belief. SIGNATURE $ L\ TION F — CREDIT CARD PAYMENT INFORMATION B MASTERCARD MONTH YEAR [AUTHORIZED SIGNATURE DATE isA I herey suthorite the FCC to charge my VISA or MASTERCARO ____.> fer tna service(s¥autharitadons(s) herein described. oorprommmemane SEE PUBUC BURDEN ESTRIATE on REveRse FEC Form 133 JulY 191 (Reviseo)

Cocmemecers 1—7055/2260 JPS CONSULTING & TRADING CORP. 80 11 BROADWAY, STE. 851 NEW YORK, NY 10004 Date-if_—,eil&,fi_f Pay tothe . P 5e ty 22 Grastor__ Ee Jef-c.,é Communlca.‘//ons Commussice $ _/yO /22 _23 «Cen am~ Aancffe,a} OIAJ 41\'9})2[}’ 64 Dollars MSSRT GreenPoint @ Beank COLLEGE POINT OFFICE #080 12243 14TH AVENUE, COLLEGE POINT, NY 11386 For FLC F‘/’/I'f)‘q 'F-“‘ n 2 260 70 § 5 §512 Uncormmmmcrrman ©Clarke American

Before the _ FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) In the Matter of ) ) JPS CONSULTING & TRADING CORP. ) File No. I—T—C—98— ) Application for Authority Pursuant to ) Section 214 of the Communications Act ) of 1934, as Amended, for Global Authority § to Operate as an InternationalResale Carrier )) zcss > ) APPLICATION OF JPS CONSULTING & TRADING CORP. JPS Consulting & Trading Corp. ("JPS"), by its undersigned counsel, hereby requests "global" authority, finder Section 214 of the Communications Act of 1934, as amended, 47 U.S.C. § 214, and Section 63.18 of the Commission‘s Rules, 47 C.F.R. § 63.18, to provide international telecommunications services betweenthe United States (and its territories and/or possessions) and various international points. L. The Proposed International Services JPS requests three types of authority in this application, all of which are eligible for streamlined processing.‘ JPS specifically requests (1) global authority pursuant to Section 63.18(e)(2) of the FCC‘s Rules, 47 C.F.R. § 63;@)@Llo/;SSCH international switched services of all unaffiliated authorized carriers to provide international switched services between the United I See Streamlining the International 214 Authorization Process and Tariff Requirements, IB Docket No. 95—118, FCC 96—79 (released March 13, 1996)(adopting streamlined 35—day processing procedures for certain international resale applications)("Streamlining Order"); 47 C.F.R. § 63.12 (1996).

States and all international points served by those carriers; (2) global authority pursuant to Section 63.18(e)(2)(A) of the FCC‘s rules, 47 C.F.R. § 63.18(e)(2)(A¥), to resell international private lines to provide international private line services between the United States and all international points, other than those on the Exclusion List;* and (3) authority pursuant to Section 63.18(e)(2)(B) of the mt FCC‘s Rules, 47 C.F.R. § 63.18(e)(2)(B), to resell international private lines interconnected to the public switched network at one or both ends to provide international switched services between the United States and all countries found to offer equivalent resale opportunities to U.S. carriers," and via "switched hubbing" to authorized "points beyond."* Accordingly, JPS‘s application for authority pursuantto Section 214 is eligible forstreamlined processing.‘ 2 Pursuant to the StreamliningOrder, the FCC will automatically amend all Section 214 authorizations to resell international private lines to provide international switched services between the United States and countries that afford U.S. carriers equivalent resale opportunities to add all additional countries found to meet the equivalent resale opportunities standard. Streamlining Order at « 34. * Id. § See, e.g., ACC Global Corporation/Alanna Inc., Memorandum Opinion & Order, 9 FCC Red 6240 (1994); fONOROLA/EMI Order, Memorandum Opinion and Order, 7 FCC Red 7312 (1992); fONOROLA/EMI Order on Reconsideration, 9 FCC Red 4066 (1994); Cable & Wireless Inc., Application for Authority Pursuant to Section 214 of the Communications Act of 1934, as Amended, to Operate as an International Private Line Carrier, Memorandum Opinion, Order, & Certification, 11 FCC Red 1089 (1996)("Sweden Resale Order"). $ See Streamlining Order; 47 C.F.R. § 63.12 (1996). 2

JPS will report its resale ofinternational switched service and international private lines to provide international and switched services in its traffic reports filed pursuant to Section 43.61 of the Commission‘s Rules.® JPS believes that the added competition thatits entry will bring to the market will benefit the customers of United States—overseas services. These benefits include competitive pricing and increased availability of a variety of service options. A grant of this application will therefore further the public interest. II. TheApplicant JPS is a corporation organized under the lawsof the state czf:New York. JPS is not affiliated with the U.S. facilities—based carriers whose international services it seeks to resell. JPS is also not affiliated with any foreign carriers as defined in Part 63 of the Commission‘s Rules. Thus, JPS‘s application is eligible for streamlined processing. III. Public Interest Considerations In the Market Entry Order,‘ the Commission set forth the following policy goals for its regulation of the U.S. international telecommunications market: to promote effective competition in the U.S. telecommunications market, particularly the market for international telecommunications services; to prevent anticompetitive conduct in the provision of international services or facilities; and to encourage foreign governments to open their communications markets.® The Commission also stated that "establishing an effectively competitive global communications See Streamlining Order at «[ 34. 7 Market Entry and Regulation of Foreign—affiliated Entities, Report and Order, 11 FCC Red 3873 (1995)("Market Entry Order"). 8 I4. at C 5.

market could result in reduced rates, increased quality, and new services."" In addition, the Commission found that "effective competition directly advances the public interest and the Commission‘s paramount goal of making available a rapid, efficient, worldwide wire and radio communication service with adequate facilities at reasonable charges.""" Grant of JPS‘s request for resale authority to provide international services will directly further the Commission‘s policies of bringing increased competition to the U.S. international telecommunications services market and is therefore in the public interest. IV. Information Required under Section 63.18 As required by Section 63.18 of the Commission‘s Rules, JPS submits the following information: (a) Name and address of applicant: JPS Consulting & Trading Corp. 11 Broadway Suite 812 New York, NY 10004 (b) JPS is a corporation organized under the laws of the state of New York. _ & Id. at [( 6, 8. s Id. at 10.

(c) Correspondence concerning this application should be sent to: Thomas K. Crowe Law Offices of Thomas K. Crowe, P.C. 2300 M Street, N.W., Suite 800 Washington, D.C. 20037 (202) 973—2890 with a copy to: Kaan Kamali JPS Consulting & Trading Corp. 11 Broadway Suite 812 New York, NY 10004 (d) Upon grant of this application, JPS will become an authorized non—dominant reseller with global authority, subject to Section 214 of the Communications Act of 1934, as amended, and the Commission‘s Rules. JPS lacks the market power that would allow it to control prices to the detriment of market competition. (e) JPS requests Section 214 authority to: operate as a resale carrier pursuant to the _ terms and conditions of Section 63.18(e)(2). Specifically, JPS seeks to (1) provide international telecommunications services between the United States and all international points; (2) obtain global authority to resell the international services of all authorized common carriers, except affiliated carriers regulated as dominant on the route to be served, to provide international telecommunicationsservices between the United States and all international points; and (3) obtain global authority to resell international private lines to provide international private line services between the United States and all international points. 8 At this time, JPS does not seek authority to provide services 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.FE.R. § 1.306. As such, an environmental assessment is not required for purposes of this application and is therefore not attached. (h) JPS certifies that it is not affiliated with any U.S. carriers whose facilities—based services it proposes to resell. JPS is not affiliated with any foreign carriers pursuant to Section 63.01(r)(1)(i). 47 C.F.R. § 63.01(1)(1)(1).

The following entities hold a ten percent (10%) or greater ownership or management interest in JPS. AY f Name/Address % Held C'rfénship > Principal Business Kaan Kamali 100% Turk'ey Telecom, ent ced 40 Hamilton PI. information : zices 3" Floor j Tarrytown, NY 10591 (i1) As required by Section 63.18(i) of the Commission‘s Rules, 47 ( ‘.R. § 63.18(i), JPS certifies that it has not agreed to accept nor shall it accept the future any special concessions, as defined by the Commission‘s Rules, dire y or indirectly from any foreign carrier or administration with respect to traffic revenue flows between the U.S. and any foreign country for which JPS may be at jrized to serve. (J) JPS is not subject to a denial of Federal benefits pursuant to Se m 5301 of the Anti—Drug Abuse Act of 1988. JPS‘s certification pursuant to Sec 1 1.2002 of the Commission‘s Rules (implementing the Anti—Drug Abuse Act of | 8, 21 U.S.C. § 3301) is attached.

v. Conclusion For the reasons stated above, JPS Consulting & Trading Corp. respectfully submits that the public interest, convenience and necessity would be furthered by a grant of this Section 214 application. Respectfully submitted, JPS CONSULTING TRADING CORP. : (1 ,ébs/?- Thomas K. Crowe LAW OFFICES OF THOMAS K. CROWE, P.C. 2300 M Street, N.W. Suite 800 Washington, D.C. 20037 (202) 973—2890 COUNSEL FOR JPS CONSULTING & TRADING CORP. Dated: September 30, 1998

CERTIFICATIONS OF APPLICANT On behalf of JPS Consulting & Trading Corp., and in accordance with Sections | 001— 1.2003 of the Commission‘s Rules, 47 C.F.R. §§ 1.2001—1.2003, I hereby certify that no ; y to this application is subject to a denial of Federal benefits that includes FCC benefits purs it to Section 5301 of the Anti—Drug Abuse Act of 1988. See 21 U.S.C. § 853(a). I also hereby rtify that the statements in the foregoing application for Section 214 authority are true, comple and correct to the best of my knowledge and are made in good faith. JPS Consulting & Trading Corp. has not agreed to accept any concessions dire y or indirectly from any foreign carrier or administration with respect to traffic or revenue flow b veen the Untied States and various international points under the authority granted under Section 4 of the Communications Act of 1934;, as amended, and the Commission‘s Rules, and has not ag d to enter into such agreements in the future. JPS CONSULTING & TRADING CORP. By: ./’(oa,-:. %ama L’J Name: @SM T 4 Title: flf‘cs /401&'\ 'vZ Date: Se 4e en 23’_’, 4199

CERTIFICATE OF SERVICE I, Melissa Sheehy, a paralegal with the Law Offices of Thomas K. Crowe, P.C., certify that on September 30, 1998, a copy of the foregoing Application was served by first class U.S. mail, postage prepaid, on the parties listed below. Deputy Assistant Secretary of Troy Tanner Defense (Telecommunications) Chief, Policy and Facilities Branch Office of the Assistant Secretary International Bureau, Telecommunications of Defense Division Pentagon, Room 3E160 Federal Communications Commission Washington, D.C. 20401 2000 M Street, N.W. Room 800 ' National Security Agency Washington, D.C. 20554 GO042, NSA, EMC Center Room 1C166 Francis Eisenstein 9800 Savage Road International Bureau, Telecommunications Fort George Meade, MD 20755 Division Federal Communications Commission U.S. Coordinator and Director 2000 M Street, N.W. Office of International Communications Room 843 Policy (EB—TD) Washington, D.C. 20554 Department of State 21st and C Street, N.W. ITS Washington, D.C. 20305—2000 1231 20th Street, N.W. Attn: Code 15 Washington, D.C. 20036 Chief Regulatory Counsel Defense Communications Agency Washington, D.C. 20305—2000 Attn: Code 115 National Telecommunications and Information Administration 14th & Constitution Ave., N.W. Room H4717 Washington, D.C. 20320 .”7/_:7/. ; f // A, 4 {ukt &4o— a /fA_f 2 AAf Melissa Sheehy ~ f


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