Attachment 20170131112218-747.p

20170131112218-747.p

SUPPLEMENT

Supplement

1999-01-19

This document pretains to ITC-214-19990119-00027 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2141999011900027_1401452

ASSIGNMENT OF L GLOBAL FACILITI GLOBAL FACILITI CLOBAL RESALE SERVICE INDIVIDUAL FACI INTERCONNECTED LIMITED GLOBAL GLOBAL RESALE SERVICE LIMITED GLOBAL FACILITIES—BASE 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:

READ INSTRUCTIONS CAREFULLY BEFORE PROCEEDING FEDERAL COMMUNICATIONS COMMISSION APROVSE Sy ome socc—ostal REMITTANCE ADVICE ts 49e ; oz USsiOfaYy (1) LOCKBOX # 358115 C &C,/;:’C;::O‘.1._0'-1_;].@\1\5 ’! g “sr}(}-; on ——secrouc—raverRroskanon— MMFWII—I TelNet, LLC . 4) STREET ADDRESS LINE N. 1 Tt ———f 85 Argonaut, Suite 150 g_ 5) STREET ADDRESS LNENO. 2 6 ony ’m STATE [(s) zie cooe Aliso Vieio CA 92656 (3)cayTwae TEL rnzmoue NUMBER(include area code} (10) COUNTRY CODE (if mot in U.SA.) 949—595—4 737 IF PAYER NAME AND THE APPLICANT NAIMEARE DIFFERENT,coOMPLETESECTIONB _ IF MORE THAN ONE APPLICANT, USE CONTINUATION SHEETS (FORM 159—C) HM.se W_MWM_M_III- se cC—214—1949990119 —0000# (13) STREET ADDRESS LINE NO. 2 14) CY (15) STATE p.) .BP COdE 17) DAYTIME TELEPHONE NUMBENt (include area code) (18) COUNTRY CODE (if not in U.S.A.) COMPLETE SECTION C FOR EACH SERVICE, IF MORE BOXES ARE NEEDED, USE CONTINUATION SHEETS (FORM 159—C) MMF-HMH!HEWMW HH-F..- U 1 [lm FCC CODE 1 | 198) FCC CALL SGNOTHER iD 4 (208) PAYMENT TyPEcove {PTC) (218) QuaNTITY 228) FEE DUE FOR (PTC) IN BLOCK Toi omm 238) FCC CODE 1 frise) ree caLl.siGwomeR id _ TZoc) PATMENTTYPECODE (PTC) Tric Z2C) FEE DUE FOR (PTC) iN BLOCK 20G Fecustony? Fee [23C) cooe i Hno_)FCCCALL SIGNOTHER io * |(200) PAYMENT TYP 22D) FEE DUE FoR (PTC) iN SLOCK 200 Pecual? fonrerrunpromaremerme (230) rec cooe 1 | ~SEcTION D— TAXPAYER. INFORMATION RlW— PAYER TIN [|0| 3| slo |sli l2 l2 l6 |1 ~|APPLICANT TIN 0| T ) $ M 1 Douglas D. Orvis , Certify under penalty of perjury that the foregoing an irrginformation (PRINT NAME) e t] are true and correct to the best of my knowledge, infomation and belief. SIGNATURE A / T iZ. MASTERCARD MONTH YEAR tad SIGNA DATE (msa i hereby authorize the FCC to charge my VISA or MASTERCARD ffor the ser ) horein ribed. SEE PUBLIC BURDEN ESTIMATE ON REVERSE FCC FORM 159 JULY 1997 (REVISED)

SWIDLER BERLIN SHEREFF FRIEDMAN, LLP WASHINGTON OFFICE NEW YORK OFFICE 3000 K STREET, NW, SurTE 300 919 THIRD AvENUE WaAsSHINGTON, DC 20007—5116 . NEW YORK, NY 10022—9998 TELEPHONE (202) 424—7500 TELEPHONE (212) 758—9500 FACSIMILE (202) 424—7647 FACSIMILE (212) 758—9526 January 19, 1998 VIA COURIER Federal Communications Commission International Bureau Telecommunications Division P.O. Box 358115 Pittsburgh, PA 15251—5115 Re: Application of TelNet, LLC for Global Authority, Pursuant to Section 214 of the Communications Act, as amended, to Operate as an International Facilities—Based and Resale Carrier Between the United States and Various International Points. Dear Sir or Madam: Enclosed for filing with the Commission are an original and six (6) copies of the Application of TelNet, LLC for Global Authority, Pursuant to Section 214 of the Communications Act, as amended, to Operate as an International Facilities—Based and Resale Carrier Between the United States and Various International Points. As required by the Commission‘s Rules, enclosed is a checkin the amountof $780.00, payable to the Federal Communications Commission to cover the filing fee. Please date—stamp the enclosed extra copy of this application and return it in the self—addressed, stamped envelope provided. Should you have any questions concerning this application, please do not hesitate to contact the undersigned. Respectfully submitted% a. "Céherine Wang Douglas D. Orvis II Counsel for TelNet, LLC Enclosures ce: Troy Tanner (FCC—IB) Eric DiBella 266889.1

Before the DERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 s R.Z Ks K.i %/ _3 K2R DP &A _3R L2 w s scz In the Matter of TELNET, LLC File No. ITC—99—_______ 11tA2ld 174490119 .660 34 Application for GI1 \uthority Pursuant to Section 214 of the nunications Act of 1934, as amend Operate as an ) International Facil ased and Resale Carrier ) © Between the Unite es and Various ) International Point APPLICATION TelNet, LI TelNet" or "Applicant"), by its undersigned counsel, hereby requests "global" authority er Section 214 of the Communications Act of 1934, as amended, 47 U.S.C. § 214, ection 63.18 of the Cormmission‘s Rules, 47 C.F.R. § 63.18 (1997), to provide internatio1 ecommunications services between the United States and international points. ‘][. Summary TelNet is a California—based start—up company planning to provide competitive international services as a nondominant, unaffiliated U.S. carrier. TelNet herein requests four types of authority in this Application, all of which are eligible for streamlined processing under Section 63.12 of the Commission‘s Rules." TelNet specifically requests: (1) global facilities— U TelNet does not seek authority to serve countries or use facilities excluded by the Commission‘s Exclusion List.

based auth_ority; (2’) global authority to resell the international switched services of all U.S.— authorized carriers; (3) global authority to resell international priva :e lines to provide intern itional non—interconnected private line services; and (4) authority to resell international privat: lines interconnected to the public switched network at one or both ends to provide international switched services on all interrational routes on which the Comm ssion permits such services to be provided now and in the future. TelNet believes that th> added competition its entry will t ring to the marke: will »enefit the consumers of United States— overseas services by, aniong other tings, encouraging; comjpetitiv : pricing and creating more service options. A grant of this Applic ition will therefore furt ier the — public interest. II. Information Requirec! Under Section 63.18 As required by Sectior. 63.18 of the Commission‘s Rules, TelNet submits the fol owin,; information: (a) Name, address and telephone number of Applican: TelNet, LLC 85 Argonaut, Suite 150 Aliso Viejo, CA 92656 Tel: (949) 595—4737 Fax: (949) 595—4733 oc‘ (b) Applicant is incorporated under the law<>f California. w xt \‘——/-/’

(c) Correspondence concerning this application should be sent to: Catherine Wang, Esq. Douglas D. Orvis II, Esq. Swmmr ER ReRrpmw CusopepF FRICEDMAN, LLP 30C €S et, ., Suite 31 Wa ngt , C 0007 Tel (2 )4 20 Fax (2 ) 4 15 wit to —fo: Eri 1B a Tel t, I 2C 85. zor t, & 50 Alii Vie .C 56 Tel (9 ) 5 37 Fax (9 ) 5 33 (d) Ups gra of pplicatio1 [elNet will becon horized non—dominant can wi glo ilities—ba l and resale authoni :t to Section 214 of the Cor un tiol : of 1934, amended, and the ssion‘s Rules. TelNet lack he ark ver that v ild allow it to cor es to the detriment of mal tee aet: (e) Tel t s ufi requests: ) global facilitie: ruthority pursuant to Sec a 6 18( of the C mission‘s Rules, R. § 63.18(e)(1), to acq 2 i1 resi alf—circui n U.S.—authorizec s as well as necessary con tin aci o provide ternational telecor ions services between the itee tate all intern; »nal points except: ntries excluded by the Exc 1Ot _ist 1 global hority pursuant | n 63.18(e)(2) of the Cor iss i‘s . 47 C.F.] §63.18(e)(2), to r international switched seri »S C ull 1.. Juthorizec iwrriers to provide mal switched services between the United States and all international points served by those carriers; (3) global authority pursuant to Section 63.18(e)(2) of the Commission‘s Rules, 47 C.F.R. §63.18(e)(2), to resell international private lines to provide international non—interconnected private line services between the United States and all international points; and (4) authority pursuant Section 63.18(e)(2) of the Commission‘s Rules, 47 C.F.R. § 63.18(e)(2), to resell international private lines interconnected to the public switched network at one or both ends to provide 2 TelNet only seeks authority to own circuits on facilities and serve countries not excluded by the Exclusion List. —3.

international switched services on all international routes on which the Commission permits such services to be provided. () TelNet seeks the authority to provide only the services referenced under paragraph (e) of Section 63.18 of the Commission‘s Rules. (11) The authoriy requested in this Application is categorically excludec from environmental ; rocessing; as defined by Section 1. 1306 of the Commission‘s Rules, 47 C.F.R. § 1.1306. As such, an environmental assessment is not required for purposes of this Application. 0) (1) TelNet is nct "affiliated," either directly or indirectly, with any forei zn :arrier as that term is cefined in the Commission‘s Rules. See47 C.F.R. § 63.1i}(h). TelNet is not affiliated with any of the U.S. carriers whose services TelNet plans to resell. Infcormation regarding ‘CelNei‘s 10% or greater direct 0: iidirect shareholders is as follows: 1. Name: James L. Johnson*‘ Address: 12 Hastings Laguna Niguel, CA $2677 Percents ge Held: 26% Citizens 1ip: \/ United States of America *m Principal Business: Telecommurications «— 2 Name: Jasmine Holdings Limited Address: P.O;. Box 127 Town Centre Mall Providenciales Turks & Caicos Islands Percentsge Held: : 26% Citizens 1ip: / British West Indies Principal Business: Holding Company Information regarding Jasmine Holding Limited‘s 10% or greater direct or indirect shareholders is as follows: 3. Name: Dale Jacobs Address: Same as above 3 The Johnson Family Trust is the direct owner of the ownership share in TelNet. Mr. Johnson is the sole trustee of the Johnson Family Trust, a retirement and estate planning vehicle; as such, Mr. Johnson has de facto control over this ownership interest in TelNet. —4—

Percentage Held: 100% Citizenship: Canada Principal Business: Chairman of the Board, TelNet, LLC w"/’“—"“w\\ 4. Name: ComTel International _ o = Address: 8542 Del Webb Blvd. Las Vegas, NV 89134 Percentage Held: 26% _ o Citizenship: United States of America Principal Business: Telecommunications Infc iation regarding ComTel International‘s 10% or greater direct or indirect shar olders is as follows: d Name: Rick Thompson: Address: Same as Above Percentage Held: 50% _ Citizenship: C( United States of America Principal Business: President of ComTel International Name: Julie Thompson— Address: Same as Above Percentage Held: 25% Citizenship: , United States of America </ Principal Business: Telecommunications _ _ Name: Arnold and Caroline Freeman Address: |_ Same as Above Percentage Held: | 20% Citizenship: \(”United States of America Principal Business: Telecommunications (2) Information concerning the TelNet‘s interlocking officers and directors is attached hereto as Attachment A to this application. (0) As required by Section 63.18 (i) of the Commission‘s Rules, 47 C.F.R. § 63.18(i), TelNet certifies that it has not agreed to accept nor shall it accept in the future any 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 TelNet may be authorized to serve.

0) TelNetis not subject to a denial of Federal benefits pursuant to Section 5301 of the Anti—Drug Abuse Act of 1988. TelNet‘s certification pursuant to Section 1.2002 of the Commission‘s Rules (implementing the Anti—Drug Abuse Act of 1988, 21 U.S.C. § 3301) is attached. CONCLUSION For the reasons stated above, TelNet, LLC respectfully submits that the public interest, convenience, and necessity would be furthered by a grant of this Section 214 Application. Respectfully submitted, » § ~. '. Fal /{ /"L_’ . / By: /’27“”‘/ Aall *4 // €Catherine Wang Douglas D. Orvis II SWIDLER BERLIN SHEREFF FRIEDMAN, LLP 3000 K Street, N.W., Suite 300 Washington, DC 20007 (202) 424—7500 (tel) (202) 424—7645 (fax) Counsel for TelNet, LLC Dated: January 19, 1999 255415.1

ATTACHMENT A INTERLOCKING OFFICERS AND DIRECTORS NAME POSITION COMPANY Dale Jacobs Chairman of the Board TelNet, LLC Chairman of the Board Wittcomm Incorporated James L. Johnson Chief Executive Officer TelNet, LLC ' Director* Wittcomm Incorporated Rick Thompson President TelNet, LLC President ComTel International Eric DiBella Vice President TelNet, LLC Director* Wittcomm Incorporated * Messrs Johnson and DiBella have been appointed to the Board of Directors of Wittcomm Incorporated, however, an official meeting of the Board has not been held to confirm their appointments. 257015.1

CERTIFICATION OF APPLICANT On behalf of TelNet, LLC and in accordance with Section 1.2001—1.2003 of the Co aission‘s Rules, 47 C.F.R. §§ 1.2001—1.2003, I hereby certify that no party to this Application is s sct to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the ti—Drug Abuse Act of 1988. See 21 U.S.C. § 853a. I also hereby certify that the statements in the regoing Application for Section 214 authority are true, complete, and correct to the best of my | wledge and are made in good faith. To the extent required by the Commission‘s Rules, TelNet, LLC has not agreed to ept any special concessions directly or indirectly from any foreign carrier or administration with pect to traffic or revenue flow between the United States and various international points under th ithority granted under Section 214 of the Communications Act of 1934, as amended, and the Cor ission‘s Rules, and has not agreed to enter into such agreements in the future. TELNET, LLC By: f A Name: ( q, . _ se Title: s Date: “\"‘\f\%

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