Attachment 20170202152614-010.p

20170202152614-010.p

SUPPLEMENT

Supplement

1999-02-18

This document pretains to ITC-214-19990218-00144 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2141999021800144_1413285

Categories of Services for 2: (Streamline/Non—strea ASSIGNMENT OF LICENSE @9 C (a €L4a C GLOBAL FACILITIES—BASED SERVIC GLOBAL FACILITIES—BASED/GLOBAL GLOBAL RESALE SERVICE INDIVIDUAL FACILITIES—BASED © INTERCONNECTED PRIVATE LTI] LIMITED GLOBAL FACILITIES— GLOBAL RESALE SERVICE LIMITED GLOBAL FACILITIES—BASEL o =. ®© 3 9 9 9 LIMITED GLOBAL RESALE SERVICE IMARSAT AND MOBILE SATELLITE SERVICE SWITCHED RESALE SERVICE TRANSFER OF CONTROL SUBMARINE CABLE LANDING LICENSE INTERNATIONAL SPECIAL PROJECT

GLOBAL LEASING COMPANY Application for Section 214 Authority For Global Facilitics—bisec©/G‘obrl tes ile Ser ces Fel ruery 2, 99) Befo e the FEDER AL C JMIV JNIC ATIC NS C )MMISSION Wash ngtor DC 2055 3 4 ,\9 a¢ %% Ir th NMaticr f G C 34 L _E \S N jCOMPANY ITC—2 4—1909 A »pl ca io: . fir(loal Author ty Pu suant to Se tion : 14 of the C im nu ic iti ns A. t of 1934, as An ende: , (1) : ) Proide Fi cil tie s—t as¢ 1, 3w tched, Pri ate L ne, C ita, T ‘Jevis on an I Bisit es S ‘rv ceb tween the Unite 1 Stat :s anc Inter iation i Pcin ;, ind (2 to Pr»vide Res:le of . atern tiona Serv ces 0: A ith »riec U S. 2o amon Car iers f ir the ?rovi ion o In er at on il] as ci witched, l rivate Line Data Tele ision ar 11 us ness jer ic :s betweer the U nited States: and In er at on i1 ] oi ts To:Chicf, nt rn tic aal Burea. (Cile »a. L as ag Comp: ny (° SLC ), het ‘by 1: spect ully requests authority, pursuant to se ti n‘ l4 0: th: C ammunic: tions Act o0 193« , as a nend: d (the "Act"), 47 U.S.C. § 214, and se ‘ti n u3. .8 of the Commission‘s —ules, 47 C F.R. ) 63.1 3, to provide global facilities—based and resale of iwitched, privat line and c ata se vice: origi iating from all points in the United States except the in—region states served by its local exchange carrier affiliate, BellSouth Telecommunications, Inc. ("BST"),‘ and terminating at all international points, except within ‘ Until such time as BellSouth Corporation ("BellSouth"), BellSouth Long Distance, Inc., or another BellSouth affiliate or subsidiary is authorized to provide interLATA services in the BellSouth Region, in accordance with the provisions of section 271 of the Communications Act of 1934;, as amended, 47 U.S.C. § 271, GLC, in the United States, will provide only facilities— based and resale of international telecommunications services originating outside of the BellSouth Region. The "BellSouth Region" is comprised of the states of Alabama, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina and Tennessee. 101246v3 1

GLOBAL LEASING COMPANY Application for Section 214 Authority For Global ~acilities—based/Globz! Fesale Service : February 12, 199 / countrie . li tec. on th 2 Cor im ss on‘s ¢ xclusion list (the "Exc lusior List‘ ); an | (ii) originating 2: all intert ati onl poir :s, 2x: ep: w thin t 10se countries listed i1 the I xclus on Li st, and term natin;; in the Uait:d Stitee* It the j rovis on of these services, GLC seeks to be treated as a non— doininar t c rri:r:or he re sc is iet fo1 h below. (CLC: is a corpo1 ati m org anize:. under the laws of the State of Georgia GLC is a wholl owned s ib: idiary ol B Illf ovuth ntern itional Network Hold ngs, nc. (Hold ags") a Delawar corporat on Eol lin3s :s ; v ho ly > aed subsidiary of Bel Soutk Corp oratic a ("B :IlSou th"), :. Georgia co pcat on 3e ISeut . is a widely held, publich trad d enmiity in which no »ersor (foreign or. lormes:ic is kn ow 1 t own five percent or more c f the i ssued and o itstan ling s ock. ES1, : Gzo:igii corpor:tion, s also a wholly owred stbsidigry of Belli outh. BS!" provides lo:al exch ng s i sle :o imun cations services in portion | of rine s »uthe; stern states Alabsem;, Flor da C eo gi , ie tucky Louisiana, Mississigp pi, Nrth C arolit a, So ith Curolin{ and T zn es; ee See, Exclusion List for International Section 214 Authorizat.ons, Last Amended Miy 11, 1998, at <<http://www.fee.gov/ib/td/pf/exclusionlist.html>>. * Section 271(j) of the Communications Act of 1934, as amended, 47 U.S.C. § 271(j), authorizes BellSouth and its subsidiaries and affiliates to terminate interLATA and international traffic within the BellSouth Region. See also, Pacific Bell Communications Application pursuant to Section 214 ofthe Communications Act of 1934, as Amended, to Offer International Facilities— based Switched and Private Line Servicesfrom Out—of—Region States, Order, Authorization and Certificate, DA 97—1928, File No. ITC—96—692, 12 FCC Red. 13723, 13726—727 (1997); and Bell Atlantic Communications, Inc. and NYNEX Long Distance Company Applications for Authority pursuant to Section 214 ofthe Communications Act of1934, as amended, to Provide Facilities— based Switched, Private Line, and Data Services between the United States and International Points, Order, Authorization and Certificate, DA 97—285, File Nos. ITC—96—451 & ITC—96—520, 12 FCC Red. 1880, 1890—94 (1997). 101246v3 2

GLOBAL LEASING COMPANY Application for Section 214 Authority ~For Global Facilities—based/Global R: sale Services Febr ary 12, 1999 GLC intends to obain lizensecl Unitsd States common cariier and nor —comiion carrier facilities, not appearing on the Excluson Li t, to provide its intern; tional swit hed, »rivat line and data services, which w:ll be tariffe | whe e required ty law and Commission regul tion. Grant of th: ins:ant application will enhance compe:ition in <ae i1 ternaiional telecommunications market, ther :by pi ovidii g an additional service option for : onsuw iers. Such grant would be consonant with the airis of ‘ongress expressed in ‘he Telecon muni ation : Act of 1996." For these reasons and those set fo th below, GLC respeci fully submi :s tha the ; ablic interest, convenience and necessity wil be served by grant of the req uested auth irity. As required by section 63.18 of the C ammission‘s rules, 47 C.F.R. § 63. .8, G. C su imits the following information. (a) Global Leasing Company‘s addres;: and telephone number are: 1100 Peachtree Street, NE Suite 500 Atlanta, Georgia 30309—4599 (404) 249—4813 (404) 249—5074 (facsimile) (b) GLC is organized under the laws of the State of Georgia. (e) Correspondence concerning this application should be addressed to: Vice President, Secretary and General Counsel Global Leasing Company 1100 Peachtree Street, N.E. Suite 400 Atlanta, Georgia 30309—4599 (404) 249—4426 (404) 249—4853 (facsimile) * Pub L. 104—104, 110 Stat. 56 (1996). 101246v3 3

GLOBAL LEASING COMPANY Application for Section 214 Authority For Global Facilities—base!4201 _1 1 Resale is February 9 (d) GLC does not hold any section 214 authorization from the Commission. (e)(1) In accordance with section 63.18(e)(1) of the Commission‘s rules, GLC seeks auth! provide facilities—based switched, private line, data, television and business services betw U.S. and all international points except countries which appear on the Exclusion List. particularly, GLCrequests authority to provide facilities—based switched, private line art services: (i) originating from all points in the U.S., except the states in the BellSouth F and terminating at all international points, except within countries listed in the Exclusio and (ii) originating at all international points, except within countries listed in the Exclusic and terminating in the U.S. GLC will comply with the terms and conditions set forth in ; 63.18(e)(1)(ii)(A)—(E) of the Commission‘s rules, 47 C.F.R. § 63.18(e)(1)(ii)(A)—(B). regard, GLC points out that, as disclosed to the Commission in previous filings," Bel affiliates are affiliated® with certain foreign carriers‘ in specific foreign countries as discu; the following responses to section 63.18(h)(1) and (7) of the Commission‘s rules, 47 C. 63.18(h)(1) and (7). However, as shown below, in the specific countries where GLC affiliation with a foreign carrier, GLC qualifies for non—dominant regulation pursuant to se ° See, e.g., File Nos. ITC—97—645 and ITC—97—644, Overseas Common Carrier Section 214 Applications, Actions Taken, Report No.: 1—8277, DA 97—2586, released Dec. 11, 1997; and File No. ITC—214—19980728—00520, Overseas Common Carrier Section 214 Applications, Actions Taken, Report No. TEL—00006, DA No. 98—1811, released Sept. 10, 1998. © Affiliation is defined in section 63.18(h)(1)(i) of the Commission‘s rules, 47 C.F.R. § 63.18(hb)(1)G). ‘ Foreign carrier is defined in section 63.18(h)(1)(ii) of the Commission‘s rules, 47 C.F.R. § 63.18(D)(DGi). 101246v3 4

GLOBAL LEASING COMPANY Application for Section 214 Authority Flobal Facilities—based/Global Resale Services February 12, 1999 63.10(a)(3) of the Commission‘s rules, 47 C.F.R. § 63.10(a)(3). reover, the Commission effectively determined that the foreign carriers discussed below 1: fficient market power in their respective markets to affect competition adversely in the market when it granted certain previously filed applications of BellSouth International, . ‘BSI"), BellSouth Long Distance, Inc. ("BSLD"), and BellSouth International Long I ce Services, Inc. (now BellSouth International ACCESS, Inc. ("ACCESS")) (e)(2) In accordance with the terms and conditions ofsection 63. 2) of the Commission‘s rules, GLC seeks authority to operate as a resale carrier of intern l services of authorized U.S. common carriers for the provision of international basic hed, private line, data, television and business services to all international points, except only will originate such services from points in the United States outside the BellSouth Rey GLC acknowledges that it will comply with the terms and conditions set forth in section (e)(2)(ii)(A)—(D) of the Commission‘s rules, 47 C.F.R. § 63.18(e)(2)(ii)(A)—(D). In that re GLC points out that, as disclosed to the Commission in previous filings," BellSouth affili: ‘e affiliated with certain foreign carriers in specific foreign countries as discussed in the f ng responses to section 63.18(h)(1) and (7) of the Commission‘s rules. However, as shown below, in the specific countries where GLC has an affiliation with a foreign carrier, GLC qualifies for non—dominant regulation pursuant to section 63.10(a)(3) of the Commission‘s rules, 47 C.F.R. § 63.10(a)(3). Moreover, the Commission effectively determined that the foreign carriers discussed below lack ® See, n.5, supra. ° 1d. 101246v3 5

GLOBAL LEASING COMPANY Application for Section 214 Authority For Slobal Facilities—basc d/Global Resale Services February 12, 1999 sufficient market power in th:ir res ~ective markets to affe t coripetit on adversely in tae U. 3. market when it granted certain previ jusly iled applic: tions f BS ;, BSI D anc. ACCESS. ° (f) Not applicable. (g) Not applicable. GI C is not secking to provide iaciliti:s pmsuant to section 63.18(:)(6) of the Commission‘s rules, 47 C. *.R. § 63.18(e)(6). (bh)(1) As disclosed in t ie pre vious filing ; by its affiliates 3SI, ESLD and A CCESS ref rence d above, GLC is affiliated with certair forei zn carriers ¢s affiliation and foreigr carrier are defined in section 63.18(h)(1)(i) ind (i@) of the Coinmission‘s ules. See lixhibi} A. Mowever, as showvu n below in response to section 63.18(t )(7) cf the Comn issior ‘s rul :s, the Commission effictive y determined that the fo—eign carries discussed below lack sufficieet maket power in the international transport :ind the local accuess | markeis in heir respective countries t« affet competition adversely it the U.S. n arket when the Commission granted BS °s application Fi e No. ITC—97—645, BESLD‘s appicatio 1 File No. ITC—9‘ —644, and CCE $8‘s a »plication I ile No. ITC—214—19980728—005% 0.‘ (b)(2) GLC is a wholly owne d subsidiar of Holding;s, a Lielawiire co porat on, which, n tun,, is a wholly owned subsidiary of BellSouth, a Georgia corporation. BellSouth is a widely held, publicly traded entity in which no person (foreign or domestic) is known to own five percent or more of the issued and outstanding stock. Holdings is headquartered at 1100 Peachtree Street, N.E., Suite 400, Atlanta, GA 30309—4599. BellSouth is headquartered at 1155 Peachtree Street, See, n.5, supra. 11 [d 101246v3 6

GLOBAL LEASING COMPANY Application for Section 214 Authority For Global Facilities—based/Global Resale Services February 12, 1999 N.E., Atlanta, Georgia 30309—3610. There are nc locking directors between or among GLC, Holdings and BellSouth. (bh)(3) GLC certifies that it may acquire some : ies through the resale of the international switched or private line services of another U. rier. However, GLC does not have an affiliation with the U.S. carrier(s) whose faciliti ied service(s) it proposes to resell (either directly or ihdirectly through the resale of anothe1 ler‘s service). (h)(4) GLC acknowledges thatit is responsible : > continuing accuracy of the certifications required by paragraphs (h)(1) and (h)(3) of secti« 18. Whenever the substance of any such certification is no longer accurate, GLC shall as ptly as possible and, in any event, within thirty days, file with the Secretary of the Con on in duplicate a corrected certification referencing the FCC File Number under which th inal certification was provided. (h)(5) GLC respectfully submits that, as require« »ction 63.18(h)(5)(i) of the Commission‘s rules, it seeks authority to operate as a facilities— international carrier to Argentina, Brazil, Chile, Ecuador, Israel, Peru and Venezuela, eac which is a Member of the World Trade Organization ("WTO"). GLC is affiliated with ign carrier in each of those countries as shown in the response to section 63.18(h)(7). GLC also respectfully submits that, as required by Section 63.18(h)(5)(ii) of the Commission‘s Rules, it seeks authority to operate as a facilities—based international carrier to Denmark, Nicaragua, Panama and Uruguay, each of which is not a Member of the WTO. GLC is affiliated with a foreign carrier in each of those countries as shown in the response to section 63.18(h)(7). However, as delineated in the response to section 63.18(h)(7), GLC‘s affiliated 101246v3 7

GLOBAL LEASING COMPANY Application for Section 214 Authority For Global Facilities—based/Glob: * Resale Service February 12, 199 foreign carrier in each of those countries lacks sufficient market power in those countries t affect competition adversely in the U.S. market. (h)(6) GLC respectfully submits that, as required by section 63.18(h)(6)(i) ofthe Commission‘ rules, it seeks authority to resell the international switched or non—interconnected private lin services of another U.S. carrier for the purposes of providing international communication services to Argentina, Brazil, Chile, Ecuador, Israel, Peru and Venezuela, each of which is Member of the WTO. GLC is affiliated with a foreign carrier in each of those countries a shown in the response to section 63.18(h)(7). GLC also respectfully submits that, as required by section 63.18(h)(6)(ii) of th Commission‘s rules, it seeks authority to resell the international switched or non—interconnecte private line services of another U.S. carrier for the purposes of providing internation: communications services to Denmark, Nicaragua, Panama and Uruguay, each of which is not Member of the WTO. GLC is affiliated with a foreign carrier in each of those countries a shown in the response to section 63.18(h)(7). However, as delineated in the response to sectio1 63.18(L)(7), GLC‘s affiliated foreign carrier in each of those countries lacks sufficient marke power in those countries to affect competition adversely in the U.S. market. (h)(7) GLC proposes to resell the international switched services of an unaffiliated U.S. carrier for the purpose of providing international communications services to Argentina, Brazil, Chile, Denmark, Ecuador, Israel, Nicaragua, Panama, Peru, Uruguay, and Venezuela, each of which is a country in which GLC has an affiliated foreign carrier as shown herein. GLC respectfully submits that the following showing demonstrates that it meets the standard set forth in section 101246v3 8

GLOBAL LEASING COMPANY Application for Section 214 Authority For Global Facilities—based/Global Resale Services February 12, 1999 63.10(a)(3) of the Commission‘s rules for GLC to qualify for non—dominant classification in the provision ofsuch international communications to those countries. GLC, through BellSouth, is affiliated with four foreign carriers that have specific authority to provide international telecommunications service to the public in their countries: BellSouth Chile S.A. ("BCSA"), Otecel S.A. ("Otecel") (Ecuador), Dansk Mobiltelefon I/S d/b/a/ SONOFON ("SONOFON) (Denmark), and Tele 2000, S.A. (Peru)." As shown herein, none has the ability to discriminate against unaffiliated carriers on the foreign end of a particular route because none has a 50 percent or more market share in the international transport and the local access markets in its respective foreign country. BCSA is an indirect, wholly owned subsidiary of BellSouth. It operates in the Santiago and Region 5 concession areas of Chile. BCSA currently provides domestic and international long distance voice services to its cellular customer base, and to the local landline customer base via a code access process (a rudimentary form of equal access) and via customer delivery BellSouth has ownership interests in other carriers providing telecommunications services in foreign countries. However, BellSouth does not have an interest in or affiliation with any other foreign carriers as the terms affiliation and foreign carrier are defined in section 63.18(h)(1)(i) and (ii) of the Commission‘s rules, 47 C.F.R. § 63.18(h)(1)(i) and (ii), respectively. " BellSouth anticipates that in the very near future GLC‘s affiliated foreign carrier in Argentina, Compatfiia de Radiocomunicaciones Moviles S.A. ("CRM"), in which BellSouth holds an indirect 65% equity interest, will be awarded a long distance and an international authorization by Argentina. CRM, like most of GLC‘s affiliated foreign carriers in this hemisphere, is a licensed cellular carrier. Obviously, as a new entrant, CRM will not have a 50 percent or more market share in the international and the local access markets in Argentina upon its entry into those markets and could not hope to achieve such shares for many years to come. It will continue to be a non—dominant carrier in Argentina. 101246v3 9

GLOBAL LEASING COMPANY Application for Section 214 Authority For Global | rcilitie —base ‘Glob; ~ ] esale ervice Felt uary 2, 199 methoc ; for corporite custome s. BCSA‘s dome ig dis ance market sha : (in hile} is les than 1(%; this service is pro ided ‘via resale is. ECSA s internati nal l ng d stanc market share is less than 10%;© ais service is offe satelite ez th station : id ba k— haul fa :ilities. In addition, 1 CSA does not ie means, n terms o mar et sI ire c resoure s, t cortrol eithe tra ismis:sion vitchiig 1 ottleneck facilii es. Th telecorm nunications mar :et in Chile is cconside extre mely competitiv : olig poly Th three 1 rgest long distz ice carrier in Chile , C1C arl1 Telex C uiile) iwcou it fo approxi natel ; 80% of al orig i1ating internatiotr : distance 1 rinutes. A cordi igly, 3CSZ lacks 5( perc nt or nore markc t shar : in thie ints ial tr; nspor : and the lo al ac ess n arket in Chile JellSouth current y hol is an indirect 89 uity ntere t in Otecel a ce ular sarrie licensec to provide service in Ecua or. ‘Jnder rms of its icense, Ot cel is allo ed t« provide aatio ial and intei aatior al lor 3 distance : to it ; celli lar custome + base. Cu1 ently Otecel : oes 1 ot use any ntern tiona switching smission f cilities anc as such de :s no have th abil ty to contr ol any bottl neck facili Jtece. expe cts to lease capacity i1 such facilities in the future. However, even with the addition of that capability, it is unlikely that Otecel will ever attain more than a marginal market share in the Ecuador international telecommunications market. Thus, Otecel lacks 50 percent or more market share in the international transport and the local access markets in Ecuador. BellSouth also owns an indirect 46.5% equity interest in SONOFON, a Danish cellular carrier. While SONOFON has the necessary licensing requirements to provide international 101246v3 10

GLOBAL LEASING COMPANY Application for Section 214 Authority For Global Facilities—based/Global Resale Services February 12, 1999 facilities—based telecommunications services to an n Denmark, SONOFON only recently began offering international services between Denn nd the United Kingdomusing capacity leased from another international carrier. Consic the highly competitive nature of the Danish telecommunications market, it is unlikely t JNOFON will ever attain more than a 10%market shareof the facilities—based Danish int onal telecommunications market, or be in a position to control international bottleneck swit and transmission facilities. As shown above, SONOFON lacks 50 percent or more marke ‘e in the international transport and the local access markets in Denmark. BellSouth also owns an indirect 58.98% equ erest in Tele 2000, S.A. ("Tele 2000"), a Peruviancellular carrier. Tele 2000 was granted 1 :cently the necessary license to provide national and international telecommunications serv o and from Peru. Tele 2000 has not begun offering international services between Pert other countries. Currently, Tele 2000 does not use any international switching or transmi: ‘acilities and as such does not have the ability to control any bottleneck facilities. Tele 20( mects to lease capacity in suchfacilities in the future and, indeed, may construct its own in ional gateway facilities by means of a satellite earth station. Clearly, as a new entrant, Tele 2000 lacks 50 percent or more market share in the international transport and the local access markets in Peru. BellSouth also has equity positions in licensed wireless communications carriers in Argentina, Brazil, Chile, Israel, Nicaragua, Panama, Uruguay, and Venezuela. However, currently none of these affiliated carriers is authorized to provide international facilities—based communications services or to engage in the resale of such. These foreign carriers only have 101246v3 11

GLOBAL LEASING COMPANY Application for Section 214 Authority For Global T **‘_s—based/Globrl lesale iservice s ruary |2, 199 authority to ocrigingte anc terminate ‘ntern; tiona. cominunicaitions, which are led b: other non—affiliated internatioral telecomiqunic itions service providess. None e ability to discriminate agains : unaf iliatedcarri »rs on the fcreign end 0 a paiticular rout: ise ncne has a 50 percent or mors mar) :et share in he iniarnatinal transpcrt and the local a« rarkets in it respective foreign :sountiy. Further nore, the customer base served by eac e af iliate carriers is so relatively sn iall a: to eliminat : any sonce n abc ut market power. instance do the subscribers served by the affiliae excesed 19% o1 the populetion for wt e respectiv: foreign affiliate is authorized tc provide service. Thus, no affiliated foreign cz ossesses th: ability to discriminite ag: inst cther U .S. czrriers in the origination or terminat traffic in it : foreign market. Exhibit A lists eich of GLC‘s afiliated fore gn carriers, the count which eacl. operates, and BellSouth‘s 1lirect or inc irect ¢ quity positi>n in each. For the forsgoing reasons, it is 1sspecifully submitted that the C« sion should consider GLC to bz non domiaant 01 the sarticilar routes on which it has n« gn af iliate: and on the particuler rout :s where it 1as a foreign affiliate becaus: no such fc affiliste ha: the ability to discriminate against unaffiliated U.S. carriers in the countries wnere it provides telecommunications service. Moreover, the Commission effectively authorized non—dominant treatment of GLC‘s affiliates in granting previously filed applications of BSI, BSLD and ACCESS. Thus, the Commission‘s streamlined processing procedures should apply to the instant application. 101246v3 12

GLOBAL LEASING COMPANY Application for Section 214 Authority For Clobal Facilities—based/Global Resale Service i Fet ruary 12, 199 ) (h)(8) With respet to non—dominait classification inder sectioi 63. 0 of the Commission‘; rules, GLC certifics that it hes affi iatiors with foreign carriers in Argentna, Brazil, Chile, Denmark, Ecuador, Israel, Nicaragua, Pana na, Peru, U uguay, and Vene zuela, and t 1at it desire ; to be regulated as ion—domina it for the provision of international communication:; services to those countrizss. (LC 1iespecfully submits that the shoviing sbove in respons: to section: 63.18(h)(7) demon itrates that it quslifies for non—do ninant clasiificat.on pirsuart to section. 63.10 of the Comm ssion‘s rules, 47 C.F.R. § 63.10. (i) GLC certfies that it has not agre :d to :riccept special cor cessicns di: ectly or incirectly fron any foreign carrie with respect to any U.S. interration:il rou:e wkere tlie foreign carrie: possesses sufficient market povwer on the foreign end 0‘ the route to affect com petition adversely in the U.S. market s nd will not enter i ito such agreemeits in che fuiure. (J) GLC certifies p irsuant to section : 1.20)1 through 1.200:) of the Corimiss on‘s ules that n« party to the applica ion is subject to :. denial of Federsl bene fits pursuar t to section 5301 of the Anti—Drug Abuse A :t of 1988, .1 U.S.C. § 3$53a. (k) GLC respectully submi;s tha: it cualifies fo: streimlined precessing of the instan application pursuan« to section 63.12 of the Commission‘s rules, 47 C.F.R. § 533.12, because, as shown above in response to section 63.18(h)(7), GLC qualifies for a presumption of non— dominance under section 63.10(a)(3) of the Commission‘s rules. Therefore, GLC meets the exclusion under section 63.12(c)(1)(i) of the Commission‘s rules, 47 C.F.R. § 63.12(c)(1)(i), that authorizes streamlined processing of the instant application. 101246v3 13

GLOBAL LEASING COMPANY Application for Section 214 Authority I or Glo »al Fac ilities—based/Global Resale Services February 12, 1999 Additionally, as required by the Commission for intern:tiona. carricrs afliliatec. with Bell Operating Companies, GLC agrees to accept the following condition on tie gre at of ‘he instant application: IT IS ORDERED that any agreements that Global Lessing Zompany ngotiates with foreign carriers to route U.S. inbound switche¢ traffic to the E ellSouth Telecommunications, Inc., in—region states via Global easirg C(mpany‘s authorized private lines are subject to our section 43.51(2) req iiremnts. CONCLUSION For the reesons sta:ed above, and the faci that grant of th s aprlicaticon will enhance consumer choice snd competition in international services, GLC respect: ully : ubmi‘s that the instant épplication qualifies for streamlined processng pursuani to setion 63.12 »f the Commission‘s rules and grant of the instant application for global facil ties—kased :ind resale authority will serve the public interest, convenience and necessity. Respectfully submitted, GLOBAL LEASING COMPANY G—FH/Zlam) _ Clifton D. McElveen President Global Leasing Company 1100 Peachtree Street, NE Suite 500 Atlanta, Georgia 30309—4599 February 12, 1999 (404) 249—4813 101246v3 14

GLOBAL LEASING COMPANY Application for Section 214 Authority For Global Facilities—based/Global Resale Services February 12, 1999 EXHLDBIT A BELLSOUTH LICENSED CARRIER CCUNTRY EQUITY (%) Abiatar S.A. UJruguay 46.0 BCP S.A. Brazil 44.467 BellSouth Chile S. A. Chile 100.0 BellSouth Comunicaciones S.A. Chile 100.0 BSC de Panama S.A. Panama 42.025 BSE S.A. Brazil 45.999 CellCom Israel Ltd. Israel 34.75 Compafiia de Radiocomunicaciones Moviles S.A. Argentina 65.0 Dansk Mobiltelefon I/S d/b/a/ SONOFON Denmark 46.5 Otecel S.A. Ecuador 89.4 Telcel Celular C.A. Venezuela 78.1565 Telefonia Celular de Nicaragua, S.A. Nicaragua 49.0 Tele 2000, S.A. Peru 58.98 101246v3


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