Attachment 20170124092206-303.p

20170124092206-303.p

SUPPLEMENT

Supplement

1998-10-23

This document pretains to ITC-214-19981023-00731 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2141998102300731_1396148

Streamlined ITC—214—19981023—00731 ADVANTAGE TELECOMMUNICATIONS, CORP. Categories of Services for 214 Applications (Streamline/Non—streamline) ASSIGNMENT OF LICENSE DDDD{DD CLOBAL FACILITIES—BASED SERVICE GLOBAL FACILITIES—BASED/GLOBAL RESALE SERVICE GLOBAL RESALE SERVICE “ INDIVIDUAL FACILITIES—BASED SERVICE _ INTERCONNECTED PRIVATE LINE RESALE SERVICE LIMITED GLOBAL FACILITIES—BASED SERVICE/LIMITED GLOBAL RESALE SERVICE LIMITED GLOBAL FACILITIES—BASED SERVICE o aA 9 o a o a LIMITED GLOBAL RESALE SERVICE INMARSAT AND MOBILE SATELLITE SERVICE SWITCHED RESALE SERVICE ~TRANSFER OF CONTROL— SUBMARINE CABLE LANDING LICENSE INTERNATIONAL SPECIAL PROJECT Description of Application:

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 in the Matter of wu\“‘“‘\’w Advantage Telecommunications, Corp. Application for Authorization Pursuant File No. _LIC2»—1M5/013—t07 to Section 214 of the Communications Act of 1934, as Amended, to Operate — Both as a Reseller and as a Facilities— based Provider of International Telecommunications Services Pursuant to a Certificate of Public Convenience and Necessity APPLICATION OF ADVANTAGE TELECOMMUNICATIONS, CORP. FOR SECTION 214 AUTHORIZATION AND CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY Sonya Bly, President ADVANTAGE TELECOMMUNICATIONS, CORP. 125 S. Swoope, Suite 102 Maitlin, FL 32751 (407) 629—4883

3E OR E TFE fE FEI )EF AL CO YWN UN IC) TIO N: ; COMMISGION WAS HI I1G‘Ol|, D. C. 20554 File NC . neved ces ndsesd edeeel AiGeoeedzene iesns wl Pursuant 1 ) title II of the Communications Act of 1934, as amended, ADVANTAGE TELECOMMUNICATIONS, CORP., ("Applicant" or "ADVANTAGE "), a Delaware corporation, hereby requests authority to operate both as a reseller and as a facilities—based provider of international telecommunications services. ADVANTAGE intends to provide telecommunications services primarily through the resale of services offered by other carriers initially and, later, as a facilities—based provider of international telecommunications services.

In support of this Application, the following information is submitted: 1. Put lic aterest Con side ‘ations The market for intel exc 1ange telecomr wun cati ns servicess co itinues to be dominated by A &T Communicatior s. Jire stly elated to tt at doriinance are eco on ies of scale anc scope eal zed by AT&T which car not be achievec by other in<erexchiinge: cariers. In the face of such ecc nomies favorinc the doming nt carrier and thie s ruggle to establish viabile competition i1 th 3 intere:tchange tela:cor imt nications market, it is ess antial that the F 3de ‘al Com nunicat ons Co nmission ("FCC" or "Ce mmission") enc »ure ge rmnarliet entry by non —doininant carriers seet:ing suc ses:s in the inter exc 1ange market. This is parti sularly true n the inst ént sase where AD/AN TA3SE intends to cffer a competitively priced inte rexchange serv ce ‘or its customer: while ; rov ding high q a1ality cus tomar service. Over tha past seve al y ears, tha comirission has s een graphic eviderce of cost—driven pressuure on carr ers end sav prin j to maintain a ‘viable pos ition in the inter axchiance market, in co npe titio 1 with AT&"", through mu tiple consolidati ons of formerly inde per dent int srexchange cartiers. In this environment of scope/scale economies and cost—driven consolidations, ADVANTAGE believes that the entrance of new carriers into the market for international telecommunications is essential to the maintenance of a viable competitive interexchange telecommunications market. | The management and operations expertise of the ADVANTAGE team will enable ADVANTAGE to begin offering competitive high—quality service immediately upon the grant of the authority requested herein first as a reseller, and eventually as a facilities—based provider, in selected markets.

Thus, Commission grant of this Application will significantly serve the public interest through enhanced competition in the market for interexhange telecommi iniciatior s survices thro igh the add tior of i we II managed new entrant ir to the m ark t. ECCAu hority Sought The Apglicant requests such auhor ty as may ke requiread i nder Ti:le l of th 3 Cor munications Ac : of 193« , as amr ended, spesifically Sec ion 214 of th3 Act aind Part 63 of th e Comr iss on‘ Rules, for ssuanc : of a C artificate of Public Cor venienc 3 a1 d Necessit , to ADVAN TA3E to of 'eréte both as a resell ir and a s a acil ties—bamed jrov ide of te ecomxfiunications ser ces be we in tie United S :ate s or the one: ha id and those international jpoints lis ted in 2 DVANAGE ‘s tari f de signate 1 Tauriff F.C0.C. No. 2 on th3 other ian 1. The App icar t re jue its t 1at this A »plication be processe d in ace »rdi nce with th3 Comniuissi on‘s piocedures for streamlir ed procsss ng, 47 C.F.R. §53. 2. Accordingly AVANTAGE will here after ad Ires s the criteria establishe d b: the Commission‘s Rules for approv: | of such a request To address the specific criteria stablished by Part 33 ¢f the Commission‘s Rules for approval of the international acthorization requested, the Applicant hereafter submits the information required by Section 63.18 of those rules. ADVANTAGE notes that this Section 63.18information is limited to the provision of international telecommunications services. Section 63.18 Information (a) Name and address of the applicant: Sonya Bly ADVANTAGE TELECOMMUNICATIONS, CORP. 125 S. Swoope, Suite 102 Maitlin, FL 32751 (407) 629—4883

(b) ADVANTAGE TELECOMMUNICATIONS, CORP. is a corporation organized under the laws of the State of Delaware. (c) Correspondence or communications concerning this Application shoi iId k e directed t>: Alison K acu—ov, Requla ory Cor isul ant ‘Tele com Ta iff Cons ulta 1ts °O 3ox 275 Sercer l ovell ME 04013 20; ) 92 8—2 144 vith copy to: son ;a E ly, |Presidet it AD\ ANTACE TELE CO UMUNI 3A" 1I0NS, COFRP. 125 S. Ewoope, Suite 1 )2 Vial lin, "L €2751 40. ) 62 9—4383 (d) App icant hais not previc usly receiv d ze uthority unc er Section 2 4 of tt e C omriunications Act of 1334 (e) Aprf icanit is requesting section 214 authority to opi rate as a es ller of internaticnal jasic s\ ritcl ed, private line data, television and business services pursuan to he terms and conditions of . Sec ion 63.18(e)2. U Applicant is also requesting Section 214 authority to operate as a facilities—basedcarrier pursuant to the terms and conditions of paragraph 63.18(e)(1). Applicant does not propose to undertake any construction, extension, acquisition or operation of transmission facilities. Moreover, the proposed project is categorically excluded as defined by 47 CFR 1.1306, because the Applicant‘s proposal does not involve high intensity lighting or a site location specified in 47 CFR 1.307(b).

(h) The Applicant does not have an affiliation with a foreign carrier. The Applicant does not have an affiliation with any U.S. facilities— mased in termational car ier whe se sen ices will be resold. sAll sharehc‘deis are U.S. sitiz ené \Q fice ‘s, and shareholders hnlding [(0% "or jreiiter interest in 1 1e com »an / as fol ow: Name 11dd ‘ess C itizensk ip Princif al ampe ty 4 LE Af oL > e‘ L.£ w Sonya Bly 425 A Dani l W sbsizr L r. United Telecom: nunic atioi s _ifiA V E_ __ _ Suls _2 C (i) ADVAN TA 3E has ag ee no: to acec spt spe sial soncession:: lire stly or indirectly fro n a 1y forei Jn carrier o s ac ministre tion wit) | ‘esf ect to t affic or rev inu s ficws jetzeen th s U. 3. and ainy ‘ore gn sou itry which t ae wpplicar t m ay s arv : under the authority gr ante d ind ar tt is gart and will not entsar i1 to i ny suc i aq reemer ts ir the utuce. (J) \o part » to this Ap »lic:tior is sub act o a denial of federial be neft ts jur: uar t to Section, 53 91 of th 3 A iti—[ rub Ab se Act of 1988 In sum nan‘, Al)VZ NT.AGE st bm ts tt at t iis , pplicati on i ; clearly nor — controy ersial. ‘"he cartier for v hici Se ctio 1 214 autho ‘ity s sough : wil be one of i numbe r of nor —dominant arriers »roviding interni tional s arvice under tne Commission‘s jurisdictio i. Moreover, the vitality of the competiti e market for international telecommunications services is dependent on — Commission encouragement of new entrants into the market. Attached are the Applicant‘s certifications that the Applicant is not affiliated with the U.S. facilities—based international carriers the Applicant will be reselling, is not affiliated with any foreign carrier, has agreed to not accept special concessions directly or indirectly from any foreign carrier, and has not been denied funds from the federal government under Section 53—01 of the Anti—Drug Abuse Act of 1988.

WHEREFORE, ADV.ANTAG Z TELECOMMUN CATIONS, CORP respectfully urges the Comnmiis: sion t> promptly grant tt is Appl.cation for such authority as may be required p arsug nt to Section 214 >f the Act and grant a Certificate of Public Conven er ce and Necessity to AL VANTAGE TELECOMMUNICATIONS, CORP. . Re: pectiully submitted, AD /ANTAGE TELECOMN UNICATIONS, CORP. By: (MM@YL/ \LQ&(,WLGU’ Alison Kacurov, Regulatory Consultant For Sonya Bly, President ADVANTAGE TELECOMMUNICATIONS, CORP. 125 S. Swoope, Suite 102 Maitlin, FL 32751 (407) 629—4883

CERTIFICATION OF APPLICANT I hereby certify that the stetei 1ent: contained in tF 3 attached ADVANTAGE TELECOMMUNICAT ONS, CORP.‘s Appl cation for At tho za on Pursuant to Section 214 of the Com ni nications Act of 134, as Ame dei , tc Operate both as a Reseller iand Fac litias based Providei of Internatic 1al Telecommunications Services Purst ant t» a Certificate c‘ Public Con eni nc : and Necessity are true and correct 1 ) tie best of my kno‘ viedge and i re 1 iad : in good faith. ADVANTI AGE TELECOMMU JICATIONS, CC ?P. By: Q lisgn YCacunso Alison Kacurov, Regulatory Consultant For Sonya Bly, President ADVANTAGE TELECOMMUNICATIONS, CORP. 125 S. Swoope, Suite 102 Maitlin, FL 32751 (407) 629—4883

CERTIFICATION OF APPLICANT I hereby certify that ADVANTAG — TE .ECOMMUNIC\TIONS, CORP . is not affiliated with any U.S. facilities—bas d in ernational carri ars whose services are being resold. ADVANTAC E TELECOMMUNIC ATIONS, CORP. BY: (Alisin) CL&cimd) Alison Kacu ‘ov, Regulatory Con: ultant For Sonya Bly, President ADVANTAGE TELECOMMUNICATIONS, CORP. 125 S. Swoope, Suite 102 Maitlin, FL 32751 (407) 629—4883

CERTIFICATIQN OF APPLICANT Sect on 63.18(h)(i) I hereby certify that AD\ ANT AGE TELECON MUNICATIONS, CORP . is not affiliated with any foreigr c irrer AD‘ANTAGE TELECO!N IMUNICATIONS, CORP. BY: Qbfi@”v\ Ldaumd Alison Kacurov, Regulatory Consultant For Sonya Bly, President ADVANTAGE TELECOMMUNICATIONS, CORP. 125 S. Swoope, Suite 102 Maitlin, FL 32751 (407) 629—4883

CERTIFICATION OF APPLICANT Section 63.18(i) I hereby certify that ADVANTAGE TELECOMMUNICATIONS, CORP. has agreed not to accept special concession s dire ctly or indirectly from any foreign carrier of administration with respect to t affic or revenue flow s between the U.S. and any foreign country which the Apolicar t may serve unde! the authority granted under this part and will not ertel into any such agree nents in the future ADVANTAGI: TEL ECOMMUNICZ TIONS, CORP. By: W n_Caumd Alison Kacur wv, Regulatory Consi iItant For Sonys Bly, President ADVANTAGE TELECOMMUNICATIONS, CORP. 125 S. Swoope, Suite 102 Maitlin, FL 32751 (407) 629—4883

CERTIFICATION OF APPLICANT Section 63.18(J) I hereby certify that ADVANTAGE TE .ECONV MUNICATIO «S, CORP. has not been denied funds from the federal ge ve mme nt under Sectio 1 53—01 of the Anti Drug Abuse Act of 1988. ADVANTAGE TE LEC DMMUNICATIC NS, CORP. BY: enA Eanimiss Alison Kacurov, l iegulatory Consultar t For Sonya Bly President ADVANTAGE TE LECOMMUNICATIC NS, CORP. 125 S. Swoope, Suite 102 Maitlin, FL 32751 (407) 629—4883


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