Attachment 20170202144841-417.p

20170202144841-417.p

SUPPLEMENT

Supplement

1999-03-10

This document pretains to ITC-214-19990310-00138 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2141999031000138_1413246

Streamlined ITC-21 4-19990310-00138 COMMUNICATIONS NETWORK INTERNATIONAL. LTD. Categories of Services for 214 Applications (Streamline/Non-streamline) LI ASSIGNMENT OF LICENSE LIIJ GLOBAL FACILITIES-BASED SERVICE V GLOBAL FACILITIES-BASED/GLOBAL RESALE SERVICE LI GLOBAL RESALE SERVICE LI INDIVIDUAL FACILITIES-BASED SERVICE LI INTERCONNECTED PRIVATE LINE RESALE SERVICE LI LIMITED GLOBAL FACILITIES-BASED SERVICE/LIMITED GLOBAL RESALE SERVICE LI LIMITED GLOBAL FACILITIES-BASED SERVICE LI LIMITED GLOBAL RESALE SERVICE LI INMARSAT AND MOBILE SATELLITE SERVICE LI SWITCHED RESALE SERVICE LI TRANSFER OF CONTROL LI SUBMARINE CABLE LANDING LICENSE LI INTERNATIONAL SPECIAL PROJECT Description of Application:

,YFAD IWSTRUCI1ONS CAREFULLY APPROVED BY 0MB 3060-0589 BEFORE PROCEEDING FEDERAL COMMUNICATIONS COMMISSION SPEcIALUSE REMITTANCE ADVICE i FCC USE ONLY - PAGENO. I OF__....... . - .Lo t f i.- t1)LOCKBOX# SECTION A - PAYER IN F ORMATION 3 PAYER NAME4R !R51B9 by c,.Elt c nnDU 114n14 .cdy non .pp..o An yo.n cArd) (3) TOTAL AMOUNT PAID (A384RN nnd cnrNNI COMMUNICATIONS NEIORK INTERNATIONP4L , LTD. 780.00 4) STREET ADDUESS LINE NO. I 53 DARBY ROAD 5) STREET ADORESS LINE NIX B) CITY (7) STATE (8) PP CODE PAOLI PA 19301 (8DAYTIME TELEPHONE NUMBER (IBBUB. Er. TUBA) (15) COUNTRY CODE Of 10140 U.S.A.) (610) 647-5555 ______________________________________ IF PAYER NAME AND THE APPU CANT NAME ARE DIFFERENT. COMPLETE SECTION B IF MORE THAN ONE APPUCANT, USE CONTINUATION SHEETS (FORM 159-C) SECTION B..-. .APPUC ANT I N FORMATI O N Ii) APPUCAZ4T NAME(EpAyln9 by ETACIt ERG AltAr BAIRN NtAcUy 458 AppMBs An y&. ERrS 12) STREET ADDRESS LINE 90.1 13) STREET ADDRESS LINE 90.3 14) Cliv (151 STATE (18) ZIP CODE II) DAYTIME TELEPHONE NUMBER (lochni. nm. coth) 1B) COUNTRY CODE (i not in U.S.A.) COMPLETE SECTiON C FOR EACH SERVICE, IF MORE BOXES ARE NEEDED, USE CONTINUATION SHEETS (FORM 159-C) S E C!1 ON C - /MEN T I N FORM AT IO N nA) FCC CALL SIONIOI HER ID )20A) PAYMENT TYPE CODE (FTC) CR(* (IDA) FEE DUE FOR Of TC) 94 BLOCK IDA FCC USE ONLY - - C U T 1 780 . 00 IDA) FCC CODE 1 24A) FCC CODE U 1DB) FCC CALL SIGN)OTHER ID I (208) PAYMENT TYPE CODE (PT C) (AIR )DDA) FEE DUE FOR (FTC) 14 BLOCK 299 FCC USE ONLY I QURA Y 238) FCC CODE 1 i t I laB) FCC CODE I (SC) FCC CALL S1GN(OTHER ID )20C) PAYMENT TYPE CODE (FTC) (2101 FEE DUE FOR )P1V1 94 BLOCK 210 FCC USE ONLY I (PCI QURNERV TIC) FCC CODE I -I I ---I .1 24C) FCC CODE 2 190) FCC CALL SIUNIOTHEB ID (200) PAYMENT TYPE CODE (FTC) (Alli QUANmY (ER) FEE DUE FOR (FTC) 14 BLOCK ZN) FCC USE ONLY- 230) FCC CODE I I i i I I 240) FCC CODE 2 5) SECTION D TAXPAYER INFORMATION (REQUIRED) 20) Cc*APLERETRS BLOcK ONLY F APPUCMIT NAME IN 0-11 IS DEFERENT FROM PAYER NAIK 9*4 PAYERTIN 21) CERIIFICA)ION SFAIEMENT I2 2 6 91 27 SECTION E I IAPPLICANT TIN CERTIFICATION [j I. I LI H I, Rebecca J . Antico - Certify under penalty of perjury that the for oing and supporting i formation are true and correct to the best of my knowledge, infomation and belief. SIGNATURE SECTION F - CREDIT CARD PAYMENT INFORMATION 28) MASTERCAIISA AcOOlSil NUIN4ER ESPU9ATION DATEI JAcTERCARD WHl HIHMONTH YEAR AUTHCJRIZELISICTNATURE DATE VISA J INCItES .AI1N*RU1CFCCtA0INR!,Y VISA,, N555IEROARO IS AR rCTVIEHURIAOAAUISRO$( untIl RaclOtA. SEE PUBLIC BUIIDEN ES) (MA) EON GEVEI)SE (-CC (-0108159 JULY 1991 (REVISED)

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of COMMUNICATIONS NETWORK INTERNATIONAL, LTD. Application for Authorization Pursuant File No. __________________ to Section 214 of the Communications Act of 1934, as Amended, to Operate Both a Reseller and as a Facilities- based Provider of international Telecommunications Services Pursuant to a Certificate of Public Convenience and Necessity APPLICATION OF COMMUNICATIONS NETWORK INTERNATIONAL, LTD FOR SECTION 214 AUTHORIZATION AND CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY Lawrence L. Willis, President COMMUNICATIONS NE1WORK INTERNATIONAL, LTD. 53 Darby Road Paoli, PA 19301 (610) 647-5555

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D. C. 20554 In the Matter of COMMUNICATIONS NETWORK INTERNATIONAL, LTD. Application for Authorization Pursuant File No. __________________ 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 FOR SECTION 214 AUTHORIZATION AND CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY Pursuant to title II of the Communications Act of 1934, as amended, COMMUNICATIONS NETWORK INTERNATIONAL, LTD.,("Applicant" or 'CNI "), a Pennsylvania corporation, hereby requests authority to operate both as a reseller and as a facilities-based provider of international telecommunications services. CNI 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: Public Interest Considerations The market for interexchange telecommunications services continues to be dominated by AT&T Communications. Directly related to that dominance are economies of scale and scope realized by AT&T which cannot be achieved by other interexchange carriers. In the face of such economies favoring the dominant carrier and the struggle to establish viable competition in the interexchange telecommunications market, it is essential that the Federal Communications Commission ("FCC" or "Commission") encourage market entry by non-dominant carriers seeking success in the interexchange market. This is particularly true in the instant case where CNI intends to offer a competitively priced interexchange service for its customers while providing high quality customer service.

Over the past several years, the commission has seen graphic evidence of cost- driven pressure on carriers endeavoring to maintain a viable position in the interexchange market, in competition with AT&T, through multiple consolidations of formerly independent interexchange carriers. In this environment of scope/scale economies and cost-driven consolidations, CNI 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 CNI team will enable CNI 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 telecommunications services through the addition of a well managed new entrant into the market. II FCC Authority Sought The Applicant requests such authority as may be required under Title II of the Communications Act of 1934, as amended, specifically Section 214 of the Act and Part 63 of the Commission's Rules, for issuance of a Certificate of Public Convenience and Necessity to CNI to operate both as a reseller and as a facilities-based provider of telecommunications services between the United States on the one hand and those international points listed in CNI's tariff designated Tariff F.C.C. No. 2 on the other hand. The Applicant requests that this Application be processed in accordance with the Commission's procedures for streamlined processing, 47 C.F.R. §63.12. Accordingly, CNI will hereafter address the criteria established by the Commission's Rules for approval of such a request. To address the specific criteria established by Part 63 of the Commission's Rules for approval of the international authorization requested, the Applicant hereafter submits the information required by Section 63.18 of those rules. CNI notes that this Section 63.18 information is limited to the provision of international telecommunications services. Section 63.18 Information (a) Name and address of the applicant: Lawrence L. Willis COMMUNICATIONS NETWORK INTERNATIONAL, LTD 53 Darby Road Paoli, PA 19301 (610) 647-5555

(b) COMMUNICATIONS NETWORK INTERNATIONAL, LTD. is a corporation organized under the laws of the State of Pennsylvania. (c) Correspondence or communications concerning this Application should be directed to: Rebecca J. Antico, Regulatory Consultant Telecom Tariff Consultants P.O. Box 275 Center LoveD, ME 04016 (207) 928-2144 with a copy to: Lawrence L. Willis COMMUNICATIONS NETWORK INTERNATIONAL, LTD 53 Darby Road Paoli, PA 19301 (610) 647-5555 (d) Applicant has not previously received authority under Section 214 of the Communications Act of 1934. (e) Applicant is requesting Section 214 authority to operate as a reseller of international basic switched, private line, data, television and business services pursuant to the terms and conditions of Section 63.18(e)2. (f) Applicant is also requesting Section 214 authority to operate as a facilities- based carrier pursuant to the terms and conditions of paragraph 63.1 8(e)(1). (g) 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-based international carrier whose services will be resold. All shareholders are U.S. citizens. Officers, and shareholders holding 10% or greater interest in the company as follows: Name Address Citizenship Principal ______________________ ___________________________ ______________ Business Lawrence L. Willis 53 Darby Raod United States Telecommunications __________________ Paoii, Pa 19301 ____________ _______________ Joseph coffey 700 Long Lane United Slates Telecommunications _________________ Upper Darby, Pa 19082 ___________ ______________ Curtis A. Cooke 53 Darhy Road United States Telecommunications __________________ Paoli, Pa 19301 ____________ _______________

(i) CNI has agreed not 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 the Applicant may serve under the authority granted under this part and will not enter into any such agreements in the future. a) No party to this Application is subject to a denial of federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988. In summary, CNI submits that this Application is clearly non-controversial. The carrier for which Section 214 authority is sought will be one of a number of non- dominant carriers providing international service under the Commission's jurisdiction. Moreover, the vitality of the competitive 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, COMMUNICATIONS NETWORK INTERNATIONAL, LTD. respectfully urges the Commission to promptly grant this Application for such authority as may be required pursuant to Section 214 of the Act and grant a Certificate of Public Convenience and Necessity to COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. Respectfully submitted, COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. By: ___________ Rébécca J. ntico, Regulatory Consultant For Lawrence L. Willis, President COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. 53 Darby Road Paoli, PA 19301 (610) 647-5555

CERTIFICATION OF APPLICANT I hereby certify that the statements contained in the attached COMMUNICATIONS NETWORK INTERNATIONAL, LTD's Application for Authorization Pursuant to Section 214 of the Communications Act of 1934, as Amended, to Operate both as a Reseller and Facilities- based Provider of International Telecommunications Services Pursuant to a Certificate of Public Convenience and Necessity are true and correct to the best of my knowledge and are made in good faith. COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. By: ________________ Rebecca J. Aftico, Regulatory Consultant For Lawrence L. Willis, President COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. 53 Darby Road Paoli, PA 19301 (610) 647-5555

CERTIFICAT[ON OF APPLICANT Section 63.18(j) I hereby certify that COMMUNICATIONS NETWORK INTERNATIONAL, LTD. has not been denied funds from the federal government under Section 53-0 1 of the Anti Drug Abuse Act of 1988. COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. By: 4 '4 / R becca J. 'ntico, Regulatory Consultant For Lawrence L. Willis, President COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. 53 Darby Road Paoli, PA 19301 (610) 647-5555

CERTIFICATION OF APPLICANT Section 63.18(i) I hereby certify that COMMUNICATIONS NETWORK INTERNATIONAL, LTD. has agreed not to accept special concessions directly or indirectly from any foreign carrier of administration with respect to traffic or revenue flows between the U.S. and any foreign country which the Applicant may serve under the authority granted under this part and will not enter into any such agreements in the future. COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. By: 4'%/w /, 4' I(eecca J. Arjtco, I-(egulatory eansuitant For Lawrence L. Willis, President COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. 53 Darby Road Paoli, PA 19301 (610) 647-5555

CERTIFICATION OF APPLICANT Section 63.1 8(h)(i) I hereby certify that COMMUNICATIONS NETWORK INTERNATIONAL, LTD. is not affiliated with any foreign carrier. COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. By: /I"(/ /L41 Rebecca J. Antico, Regulatory Consultant For Lawrence L. Willis, President COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. 53 Darby Road Paoli, PA 19301 (610) 647-5555

CERTIFICATION OF APPLICANT I hereby certify that COMMUNICATIONS NETWORK INTERNATIONAL, LTD. is not affiliated with any U.S. facilities-based international carriers whose services are being resold. COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. By: /f1 / Liii R, ecca J. ntico, Regulatory Consultant For Lawrence L. Willis, President COMMUNICATIONS NETWORK INTERNATIONAL, LTD.. 53 Darby Road Paoli, PA 19301 (610) 647-5555


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