Attachment 20170214162542-117.p

20170214162542-117.p

SUPPLEMENT

Supplement

2004-03-19

This document pretains to ITC-214-19990708-00391 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2141999070800391_1423147

03/19/2004 18 :13 FAX 202 887 0763                  MORRISON & FOERSTER                                        [ 002



                                   MorrIson & FoOoERSTER us                                                    y
        SAN FRANGSCO                          ATTORNEYS AT LaAW                     NEW YORK
        LOS ANGELES                                                                 WASHINGTON, D.C.
        DENVER                           2000 PENNSYLVANIA AVENUE, NW               NORTHERN VIRGINIA
        PALO ALTO                         WASHINGTON, D.C. 20006—1888               LONDON
        WALNUT CREEK                        TELEPHONE (202) 887—1500                BRUSSELS
        SACRAMENTO                        TELEFACSIMILE (202) 887—0763              HONG KONG
        CENTUEY CITY                                                                BEJING
        ORANGE COUNTY                                                               SHANCHAI
        SAN DIEGO                                                                   SINGAPORE

                                                    March 19, 2004                  TOKYO

                                                                                  Writer‘s Direct Contact
                                                                                      (202) 778—1607
                                                                               Telefacsimile: (202) 785—7622

       By Telefacsimile 202—418—2824                                               jepmigin@mofscor
       Ms. Rebecca Halstead
       International Bureau
       Federal Communications Commission
       445 12th Street, S.W.
       Washington, D.C. 20554

                 Re: Incorrect Information In International Section 214 Public Notice DA 4No_ 04—737
                       {released March 18, 2004)
                       ITC—214—19990708—00391,ITC—98—342/ ITC—98—342A
       Dear Rebecea:

                 As we discussed this afternoon, the Public Noticereferenced above incorrectly lists the
       surrender ofcertain international authorizations. Specifically, the Public Notice states that Level
       3 Communications, LLC ("Level 3"°) surrendered international Section 214 authorization ITC—
       214—19990708—00391, as well as international authorizations ITC—98—342 and ITC—98—342A, by
       aletter dated March 5, 2004. As further explained below, Level 3 did not surrender these
       authorizations. Rather. GLT Liquidating Trust ("GLT Trust"), the successor—in—interest to
       Genuity Telecom Inc., Debtor—in—Possession ("Genuity"), surrendered Genuity‘s residual
       authority that it had retained under authorization ITC—214—19990708—00391 and surrendered the
       ITC—98—342 and ITC—98—342A authorizations.

               On March 5, 2004, counsel to GLT Trust submitted a letter to the Commission
       surrendering certain international authorizations previously held by Genuity, a copy of which is
       attached. As explained in that letter, Genuity assigned out of bankruptcy substantially all of its
       assets and customers to Level 3, including the international Section 214 authorization ITC—214—
       19990708—00391. The letter also explained that even though it was assigned to Level 3, Genuity
       retained residual? authority under that same authorization in the event that any of Genuity‘s
       international common carier customers were not transferred to Level 3.‘ GLT Trust surrendered


       \ Genuity Telecom Inc. and Level 3 Communications, LLC Joint Application to Assign
       Telecommunications Carrier Assets and International Section 214 Authority for Provision of Global
       Facilities—Based and Global Resale Services, and to Transfer Control of Domestic Common Carrier


       de—374616


03/19/2004 18§:14 FAX 202 887 0763                 MORRISON & FOERSTER                                      @003



                                       MorrIson & FoERSTER ur

        Ms. Rebecca Halstead
        March 19, 2004
        Page Two


        only its residual authoritythat it retained under this Section 214 authorization. It did not, and in
        fact has no authority to, surrender the authorization that is currently held by Level 3. The Public
        Notice thus incorrectly reports that Level 3 surrendered the ITC—214—19990708—00391
        authorization.

               The March 5 letter also surrendered international authorizations ITC—98—342 and ITC—98—
       342A, which authorizes the operation of certain cable capacity on the Americas—IJ undersea
       cable, on behalf of GLT Trust. The Public Notice inaccurately references these authorizations as
       also being surrendered by Level 3. These authonzations were never assigned to Level 3, and
       until they were surrendered on March 5, were held by Genuity.*

               Accordingly, GLT Trust requests that the Commuission amend its records and the Public
       Notice to reflect that Genuity surrendered its residual authority under the ITC—214—19990708—
       00391 authorization (not that Level 3 surrendered this authorization altogether) and that Genuity
       (not Level 3) surrendered the ITC—98—342 and ITC—98—342A authorizations. If you have any
       questions concerning this maiter, please contact the undersigned as soonas possible. Thank you
       for your assistance.



                                                        Very truly yours,



                                                         ennifef L. Kostyu       .
                                                        Counsel to GLT Liquidating Trust




       Transmission Lines Pursuant to Section 214 of the Communications Act of 1934, as Amended; ITC—214—
        19990708—00391, ITC—ASG—20021216—00592 (granted Jan. 22, 2003); WC Docket No. 02—385 (granted
       Jan. 20, 2003); Letter from Kent D. Bressie, Counsel, Level 3 Communications, LLC, to Marlene H.
       Dortch, Sectretary, FCC, File No. ITC—ASG—20021216—00592 and JTC—214—19990708—00391 (Mar. 19,
       2003) (notifying the Commission that the assignment of Genuity‘s international Section 214 anuthorization
       was consummated on February 4, 2003).

       * A notificationletterwasfiledonJanuary25,
                                                2002,tochangethenameonthese authorizations from
       GTE
         TelecomIncorporatedto@'enunyaTealse@m-:hewifghgFCC issued a publicnoticeonFebruary7.
       2002,acknowledging
                       receiptofthis
                                 thisnamechangenotification. TheFCC‘s
                                                                    internationallicensing_
       database(IBFS),however, was neverchangedto reflectthenewname.



       do—374616



Document Created: 2019-11-06 23:20:58
Document Modified: 2019-11-06 23:20:58

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