Attachment 20161227131751-307.p

20161227131751-307.p

SUPPLEMENT

Supplement

1999-10-12

This document pretains to ITC-214-19991012-00751 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2141999101200751_1387250

Streamlined ITC-21 4-19991012-00751 CI SERVICES, INC. Categories of Services for 214 Applications (Streamline/Non- streamline) LI LIMITED/GLOBAL RESALE SERVICE LI LIMITED/GLOBAL FACILITIES-BASED SERVICE LII LIMITED/GLOBAL FACILITIES-BASED/RESALE SERVICE LI INDIVIDUAL FACILITIES-BASED SERVICE LI INTERCONNECTED PRIVATE LINE RESALE SERVICE LI INHARSAT AND MOBILE SATELLITE SERVICE LI INTERNATIONAL SPECIAL PROJECT LI SWITCHED RESALE SERVICE LI TRANSFER OF CONTROL LI ASSIGNNENT OF LICENSE LI PRO FORMA TRANSFER/ASSIGNMENT LI SPECIAL TEMPORARY AUTHORITY LI SUBMARINE CABLE LANDING LICENSE Description of Application:

CI Services, Inc. 6560 Rock Spring Drive DVPIJCRTE OR!I1NAt Bethesda, Maryland 20817 (301) 2143000 FCC/MELLON OCT 12 iggg October 12, 1999 Magalie Roman Salas Secretary Federal Communications Commission l2 street, S.w. Washington, D.C. 20554 Re: Application of CI Services, Inc. for Authority Pursuant to Section 214 of the Communications Act of 1934, as amended, For Authority to Operate as an International Resale Carrier Dear Ms. Salas: Pursuant to Section 214 of the Communications Act of 1934, as amended, and Section 63.18 of the Commission's rules, CI Services, Inc. files herewith an original and five copies of its Application for Authority to provide international resale services between the United States and international points. The filing fee of $780 is also enclosed. An additional copy is also enclosed. Please date stamp this copy and return it in the enclosed envelope. Please direct any questions to the undersigned at (301) 214-3347. Yours truly, Bruce A. Henoch Attorney for CI Services, Inc. Enclosures

Before the FEDERAL COMMUNICATIONS COMMTSSION Washington, D.C. 20554 In the Matter of CI SERVICES, NC. File No. Application for Authority Pursuant to Section 214 of the Communications Act of 1934, as amended, For Authority to Operate as an International Resale Carrier j''1ication for Authority CI Services, Inc. ("CI Services") hereby requests authority, pursuant to Section 214 of the Communications Act of 1934, as amended, 47 U.S.C. Section 214, and Section 63.18 of the Commission's rules, 47 CFR Section 63.18, to provide international resale services between the United States and international points as described herein. This application qualifies for streamlined processing procedures pursuant to Section 63.12 of the Commission's rules. CI Services, which is organized and incorporated in the State of Delaware, is a wholly- owned subsidiary of COMSAT International, Inc. ("COMSAT International" or "CI"), which in turn is a wholly-owned subsidiary of COMSAT Corporation ("COMSAT"), which currently holds carrier authorizations through its various other business units.' CI Services, through its parent corporation CI, is affiliated with Cl's 12 international subsidiaries, all of which are located in countries that CI Services may serve pursuant to the authority requested herein. These affiliates are all relatively ne\: companies whose principal COMSAT business units that hold 214 authorizations are COMSAT World Systems, COMSAT Mobile Communications, and COMSAT General Corporation.

business is to provide private networking services for corporate clients in their respective markets, and none of them currently provides local or long-distance services directly to the general public. Each of these affiliated entities has less than a five percent share of the relevant market in its respective country, so none of these affiliates has sufficient market power to adversely affect competition in the U.S. market. Thus, pursuant to Section 63.1 O(a)(3) of the Commission's rules, 47 CFR Section 63.10(a)(3), CI Services should presumptively be considered a non-dominant carrier for service to each of these countries. CI Services is also affiliated, through COMSAT, with COMSAT World Systems ("CWS"), which distributes INTELSAT space segment. Pursuant to a 1998 Commission Order, CWS is regulated as a non-dominant carrier except on certain designated routes where it is still regulated as dominant (the "thin routes").2 CI Services may, pursuant to the authority requested herein, resell services obtained from CWS, but CI Services agrees to be regulated as dominant to the extent that it resells CWS services to those countries for which CWS is regulated as a dominant carrier.3 By ganting this application, the Commission will serve the public interest, convenience, and necessity by increasing competition in the international service market. Competition will 2 In the Matter of COMSAT Corporation Petition Pursuant to Section 10(c) of the Communications Act of 1934, as amended, for Forbearance from Dominant Carrier Regulation and for Reclassflcation as a Non-Dominant Carrier, Order and Notice of Proposed Rulemaking, 13 FCC Rcd 14083 (1998) ("Non-Dominance Order"). The list of countries for which CWS is still regulated as a dominant carrier for switched services can be found in Appendix A of the Non-Dominance Order, 13 FCC Red at 14176. The list of countries for which CWS is still regulated as a dominant carrier for occasional-use video services can be found in Appendix B of that Order, 13 FCC Red at 14178. These appendices are attached to this Application. 2

benefit U.S. consumers by increasing service options and lowering prices. Thus, the public interest will be served by the grant of Section 214 authority to CI Services as requested herein. The following information is submitted, as required by Section 63.18 of the Commission's rules, 47 CFR Section 63.18, in support of CI Services' request for authorization. (a) The name, address, and telephone number of the applicant are as follows: CI Services, Inc. 6560 Rock Spring Drive Bethesda, Maryland 20817 (301) 214-3000 (b) CI Services, Inc., is a corporation organized under the laws of the State of Delaware. (c) Correspondence concerning this application should be sent to: Bruce A. Henoch General Attorney CI Services, Inc. 6560 Rock Spring Drive Bethesda, Maryland 20817 (301) 214-3347 (d) CI Services, Inc. has not received authority previously under Section 214 of the Communications Act. (e) CI Services requests Section 214 authority to operate as a resale carrier pursuant to the terms and conditions of Section 63.1 8(e)(2). CI Services requests authority to provide such resale services on a global basis, except that it does not seek authority pursuant to Section 63.1 8(e)(2) to resell services obtained from CWS to those countries listed on the Commission's list of "thin route" countries for which CWS is regulated as a dominant carrier, in accordance with Section 63.1 8(e)(2)(ii).4 In addition, while CI Services is affiliated with COMSAT International's As stated above, the list of "thin route" countries is found in the Non-Dominance Order. The list of countries is attached to this application. 3

foreign carrier subsidiaries in several countries as discussed below, each of these carriers has less than a five percent share of the relevant markets in its respective country. Thus, none of these affiliate carriers has sufficient market power in the destination market to affect competition adversely in the U.S. market. CI Services certifies that it will comply with the terms and conditions contained in Sections 63.21 and 63.23 of the Commission's rules. (f) Pursuant to Section 63.1 8(e)(4), CI Services also seeks specific authority to resell the services of CWS to those markets for which CWS is still regulated as a dominant carrier. CI Services agrees to be regulated as a dominant carrier to the extent that it resells CWS services to countries for which CWS is regulated as dominant.5 CI Services certifies that it will comply with the terms and conditions contained in Sections 63.21 and 63.22 andlor 63.23 of the Commission's rules, as appropriate. (g) Not applicable. (h) CI Services is a wholly-owned subsidiary of COMSAT International, which in turn is a wholly-owned subsidiary of COMSAT Corporation, a publicly-held U.S. company incorporated and organized under the laws of the District of Columbia. Both COMSAT Corporation and COMSAT International have their principal place of business at: 6560 Rock Spring Drive Bethesda, Maryland 20817 As stated above, the list of "thin route" countries is found in the Non-Dominance Order. The list of countries is attached to this application. 4

Approximately 49 percent of the outstanding shares of COMSAT Corporation are owned by COMSAT Government Systems, Inc. ("CGSI"), with a principal place of business at: 22001 COMSAT Drive Clarksburg, Maryland 20871 CGSI is a wholly-owned subsidiary of Lockheed Martin Corporation, with a principal place of business at: 6801 Rockledge Drive Bethesda, MD 20817 (i) CI Services, as a wholly-owned subsidiary of COMSAT International, is affiliated with the following foreign carrier subsidiaries "f COMSAT International: 1) COMSAT Argentina, S.A. Carlos Pellegrini 1363-PISO 6 (1011) Buenos Aires, Argentina 2) COMSAT Brasil, Ltda. R. Sansao Alves dos Santos, 76-12 Andar CEP 0457 1-090 Sao Paulo, SP, Brasil 3) COMSAT TTS (GZ) Rm 11-14, 23/F Metro Plaza No. 183, Tian He Road North Guangzhou, Peoples Republic of China, 510620 4) Comunicaciones Satelitales de Colombia S.A. Carrera 15 No. 1O1A-77 Santa Fe de Bogota Colombia 5) COMSAT de Guatemala, S.A. 6a Avenida 7-39 Zona 10 Edificio Las Brisas - 3er nivel Ciudad de Guatemala Guatemala 5

6) COMSAT Max Limited 507/508 Madhva Building Bandra Kurla Complex Bandra East Mumbai, India 400051 7) COMSAT Mexico Avenida Renato Leduc 321 Col. Toriello Guerra, Tialpan C.P. 10450, Mexico, D.F. 8) COMSAT Peru Martir Olaya 129 Of. 1901 Centro Empresarial Jose Pardo Miraflores, Lima 18 Peru 9) BelCom, Inc. Shluzovaya Naberezhnaya #6-3 Moscow, Russia 113114 10) COMSAT Dijital Hizmetleri Ticaret A.S. Cedidiye Sokak No. 11 80700 Yildiz Istanbul, Turkey 11) COMSAT Iletisim Hizmetleri Ticaret A.S. Cedidiye Sokak No. 11 80700 Yildiz Istanbul, Turkey 12) COMSAT Venezuela, C.A. Av. Fco de Miranda, Edif. Parque Cristal Tone Este, Mezzanina 2, Local 28 Caracas -- DF, Venezuela (j) CI Services seeks authority to provide international resale services to each of the countries listed in paragraph (i) above. (k) Each of the affiliates listed in paragraph (i) above is a relatively new company providing a limited range of services in their respective countries. These affiliates primarily provide private networking services to corporate clients and do not currently provide local and long distance 6

services directly to the general public. Each of these affiliates has a relevant market share of less than five percent in its respective country, so these affiliated foreign carriers lack sufficient market power in their respective countries. Thus, applicant satisfies Section 63.1 8(k)(2). (1) Each of the affiliates listed in paragraph (i) above has a market share of less than five percent in its respective country, so these affiliated foreign carriers lack sufficient market power in their respective countries to affect competition adversely in the U.S. market. Thus, because the foreign affiliates lack 50 percent market shares in the international transport and the local access markets in their respective countries, the criteria in Section 63.1 0(a)(3) are satisfied. (m) The foreign affiliates listed in paragraph (i) each have less than a five percent market share in their respective countries, so they each lack a 50 percent market share in the international transport and the local access markets in their respective countries. Thus, CI Services shall presumptively be classified as non-dominant. (n) CI Services certifies that it has not agreed to accept special concessions directly or indirectly from any foreign carrier with respect to any U.S. international route where the foreign carrier possesses market power on the foreign end of the route and will not enter into such agreements in the future. (o) CI Services certifies pursuant to Sections 1.2001 through 1.2003 of the Commission's rules that no party to this application has been denied federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988. (p) This application qualifies for streamlined processing pursuant to Section 63.12 of the Commission's rules. Although the applicant is affiliated with a number of foreign carriers as described above, it qualifies for a presumption of non-dominance in the relevant markets under Section 63.10(a)(3) because each of the foreign afiliates lacks 50 percent market share in the 7

international transport and the local access markets on the foreign end of the routes. In addition, although the applicant is affiliated with a carrier, CWS, that is regulated as dominant on a number of routes, app1icant agrees to itself be regulated as a dominant carrier to the extent that it resells CWS services to countries for which CWS is regulated as a dominant carrier. Thus, pursuant to Section 63.12(c)(1)(ii) and Section 63.12(c)(2), this application qualifies for streamlined processing. Conclusion: In conclusion, CI Services certifies that all of the information in this application is accurate and correct. For these reasons, CI Services respectfully requests that the Commission grant this application. Respectfully submitted, CI Servic9s, Inc. iF By:/ James J. Welch, President CI Services, Inc. 6560 Rock Spring Drive Bethesda, Maryland 20817 (301) 214-3000 October 12, 1999 8

Federal Communications Commission APPENDIX A List of Thin Route Market Countries 1. Algeria 2. American Samoa 3. Angola 4. Armenia 5. Azerbaijan 6. Benin 7. Bolivia 8. Bosnia & Herzegovina 9. Botswana 10. Burkina II. Cam croon 12. Cape Verde 13. Central African Republic 14. Chad IS. Congo 16. Cote d'lvoire 17. Estonia 18. Ethiopia 19. French Polynesia 20. Gabon 21. Ghana 22. Guinea, 23. Iran 24. Iraq 25. Jordan 26. Kenya 27. Lesotho 28. Libya 29. Lithuania 30. Malawi 31. Mali 32. Maritime -Atlantic 33. Maritime -Pacific 34. Mauritania 35. Mauritius 36. Micronesia, Federated States of 37. Midway Atoll 38. Moldova 39. Mozambique 40. Namibia 41. Nauru 94

Federal Communications Commission FCC 9S- APPENDIX A cont. 42 New Caledonia 43. Nicaragua 44. Niger 45. Northern Mariana Islands 46. Pacific islands (Palau) 47. Paraguay 48. Rwanda 49. Saint Helena 50. Senegal 51. Sierra Leone 52. Somalia 53. Sudan 54. Suriname 55. Swaziland 56. Tanzania 57. Togo 58. Tonga 59. Turks and Caicos Islands 60. Uganda 6 1. Western Samoa 62. Zaire 63. Zambia 95

Federal Communications Commission FCC 98-8 APPENDIX B List of Occasional-Use Video Single Carrier Mark et Countries South America Central America! Caribbean Saint Kitts & Nevis Saint Lucia Saint Vincent Turks & Caicos Western Europe Cyprus Greenland Iceland Malta Norway Eastern Europe Albania Belarus Bulgaria Czech Republic Estonia Lithuania Macedonia Mo Idova Russia Serbia Slovenia 96

Federal Communications Commission FCC 98-78 ApDendix B cont. Middle East Bahrain Iran Israel Jordan Kuwait Lebanon Oman Qatar Saudi Arabia S yri a United Arab Emirates Yemen Columbia French Guiana Guyana Paraguay Suriname Trinidad & Tobago Central America! Caribbean Anguilla Antigua Aruba Bahamas Belize Bermuda British Virgin Islands Cayman Islands Chagos Archipelago Costa Rica Dominica 97

Federal Communications Commission Appendix B cont. Dominican Republic El Salvador Gibraltar Grenada Guadeloupe Guatemala Haiti Honduras Martinique Montserrat Netherlands Antilles Panama Africa Algeria Angola Benin Botswana Burkina Faso Cameroon Cape Verd& Central African Republic Chad Congo Cote d'Ivoire Dem Rep Congo Djibouti Egypt Ethiopia Gabon Gambia Ghana Guinea Guinea Bissau Kenya Lesotho 98

Federal Communications Commission FCC 98-78 Appendix B cont. Liberia Libya Malawi Mali Mauritania Mauritius Africa (continued) Morocco Mozambique Namibia Niger Nigeria Rwanda Saint Helana Senegal Sierra Leone Somalia South Africa Sudan Swaziland Tanzania Toga Tunisia Uganda Zaire Zambia Zimbabwe Central Asia Armenia Azerbaijan Georgia Kazakhstan 99

Federal Communications Commission FCC 98-S ApDendix B cont. Kyrgystan Mongola Uzbekistan South Asia Bangladesh India Maldives Nepal Pakistan Sri Lanka Far East Brunei Cambodia Malaysia South Korea Thailand Vietnam Pacific Rim American Somoa Fiji French Polynesia Macau Marshall Islands Micronesia Midway Island Nauru New Caledonia New Zealand Palau Papua New Guinea Tonga I

READ INSTRUCTIONS CAREFULLY APPROVED BY 0MB 3O6O.c5a BEFORE PROCEEDING COMMUNICATIONS COMMISSION _____________________________ REMITTANCE ADVICE 358115 - 1 1 PAGENO__QF_ FcCUMQM.Y LOCKBOX I SECTION A . PAYER iNFORMATION 2) PAYER Y4AME(d paysig by dodd 50,4. 11uSd OSMS WCt1 U * 6QpSIf$ Oli yOur card) (3) TOTAL AMOUNT PMO (deSati slid 511113) COMSAT CORPORATION 780.00 4) STREET ADDRESS JOE NO. I 6560 Rock Spring Drive 1) STREET ADDRESS LINE NO. 6) CITY 7) STATE (I) ZIP CODE Bethesda MD 20817 6) DAYTiME TELEPHONE NUMEER (bickids 5,00 cods) (10) COUNTRY CODE (wools, USA.) (301) 214-3347 IF PAYER NAME AND THE APPLICANT NAME ARE DIFFERENT, COMPLETE SECTION B IF MORE THAN ONE APPLICANT, USE CONTINUATION SHEETS (FORM 159-C) - SECTION B - APPLICANT INFORMATION (I) APFUCMIT 6IAME(4 paying by clods Cold. 505Sf flails, IoaCtIy ISO IppSIrS so your card) CI SERVICES, INC. IS) STREET ADDRESS LOdE NO. I 6560 Rock_ Spring _ Drive ____________________________________________________ 3) STREET ADORESS LOdE NO.2 14) CITy 16) STATE 1 (1.) zp coo Bethesda 17) DAYTIME TELEPHONE NUMEER )kick.ds am cods) T"1D IS) COUNTRY COOt 0 aid Si U.S.A.) I 20817 (301) 214-3347 COMPLETE SECTION C FOR EACH SERVICE, IF MORE BOXES ARE NEEDED. USE CONTINUATION SHEETS (FORM 159-C) SECTION C - PAYMENT INFORMATION A) FCC CALL SIGMIOTHER ID (22*) PAYMENT TYPE COOE (FTC) (22*) FEE DUE FOR (PTp) 00 S*.OCK 20* USE ONLY I 21*) c U T f 1 )s78000 23*) FCC CODE I 24*) FCC COORS 568) FCC CAU. !IGN(OTMER C ____________________________ 238) FCC CODE I (205) PAYMENT TYPE CODE IPTC) 211) QUANI1TY 221) FEE DUE FOR )PTC) Pd SLOCK 205 240) F.C COORS r. (.ME ONLY IOC) FCC CALL 510 WOTHER ID (20C) PAYMENT TYPE COOt (FTC) SIC) QU000TTTY 1122C) PU DUE FOR (FTC) Pd Pd.OCK SOC USE ONLY 23C) FCC CODE I I i i , _______________ 1SSC) FCC COORS 160) FCC CALL SIGNIOTHER C (200) PAYMENT TYPE COOt (FTC) 210) QUANTITY 2) FEE DUE FOR (FTC) Pd ILOCK 250 USE ONLY 230) FCC COOE I li i i 1240) FCC COORS SECTION D - TAXPAYER INFORMATION (REQUIRED) 20) 21) COMPLETE TIll ILOCK ONLY F APIJCANT NAME Pd I-Il M OII1ERENT FROM PAYER 112*1004 A-SI PAYER TIN I5 12 0 7 .8 1 • I 8L6J 3 [ S C ON - rAPPLIcANT TIN CERTiFICATION 1L 1 I I I I I I _ 27) CERTIF)CAT1ON STATEMENT I, Bruce A. Henoch . Certify under penalty of perjury that the foeØoing a upporting information (FRill NAME) are true and correct to the best of my knowledge, infomation and belief. SIGNATURE' J4'i.. -- SECTiON F . CREDIT CARD PAYMENT INFORMATION 6) NASTERCARDOV51A ACOOUNT .LIMUE: EXPMATION DATE: MASThRCARDIIIIIIIIHIIII HIH MONTH YEAR I*UTHOR)ZED SIGNATURE DATE Y1SA I luNEy aulhonzs II,. FCC I. chorE, my V5SA or MASTERCARD 1sf 16. s.rncN$F.ulflonzat,olis(s) hsrsui d.scnb.d. - CC bIll I( ,lr5IJ TISAAT rsu ñPM 1Q ill) V 17 IRFVISED

COMSAT FCC FILING FEES 1620 COMSAT CORPORATION 6560 ROCK SPRING DRIVE BETHESDA, MD. 20817 65-270 ia, '999 PAY TO THE ORDEB OF. DATE I CRES!A1R Crestar Bank Bethesda, Maryland FOR 5tA - C er - / - Cj ) II'OOOO ou' ':0 500 270?': 000? 6 Th


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